Privacy Policy

1. INTRODUCTION & CONSENT

This Privacy Policy ("Policy") governs Sujeet Uttam Hankare ("Individual", "we", "us"), operating under the brand My EMI Locker. By accessing or using our Platform, you freely and expressly consent to the collection, storage, use, and processing of your data as described in this Policy, in accordance with applicable Indian laws including the Digital Personal Data Protection Act, 2023.

2. INFORMATION WE COLLECT

2.1 Partner / Business Information

• Business name, type, and registration details
• GST number, PAN, and other tax identifiers
• Contact person name, mobile number, and email
• Business address and bank account details (for settlements)

2.2 Device & Customer Data (processed on behalf of partners)

• Customer name, mobile number, and address
• Device IMEI numbers and model details
• EMI plan details, purchase dates, and loan reference IDs
• Repayment status and locking/unlocking events

2.3 Technical Data

• IP address, device type, browser, and OS
• Login timestamps and session data
• API call logs and integration activity

3. PURPOSE OF DATA COLLECTION

• Partner onboarding, KYC verification, and account management
• EMI device locking and unlocking operations
• Real-time device status monitoring and reporting
• Finance partner API integration and data exchange
• EMI risk assessment and fraud prevention
• Customer support and grievance resolution
• Platform performance improvement and analytics
• Regulatory compliance and legal obligations

4. DATA SHARING & DISCLOSURE

4.1 Finance Partners (NBFCs & Banks)

Device status and EMI repayment data is shared with the associated finance partner as required for loan servicing.

4.2 OEM & Device Manufacturers

Device commands (lock/unlock) are transmitted to OEM servers. Only necessary IMEI and command data is shared.

4.3 Regulatory Authorities

Data may be disclosed to government or regulatory authorities as required by law or court order.

We do not sell or rent personal data to third parties for commercial purposes.

5. DATA SECURITY

• All data in transit is encrypted using TLS 1.2/1.3
• Sensitive data at rest is encrypted using AES-256
• Role-based access controls and multi-factor authentication for all admin accounts
• Regular security audits and penetration testing

6. DATA RETENTION

• Partner account data: retained for the duration of the partnership + 5 years
• Device and EMI records: retained for 7 years (statutory requirement)
• Access logs: retained for 1 year

7. USER RIGHTS

• Right to access your data
• Right to correction of inaccurate data
• Right to data portability (where applicable)
• Right to erasure (subject to legal retention requirements)

8. COOKIES & TRACKING

Our Platform uses cookies for session management, analytics, and security. Please refer to our Cookie Policy for details.

9. DATA BREACH RESPONSE

In the event of a breach, we will notify affected parties and relevant authorities within 72 hours as required by applicable law and take immediate remediation steps.

10. GOVERNING LAW

This Policy is governed by the laws of India including the IT Act 2000, DPDPA 2023, and RBI guidelines. Disputes are subject to jurisdiction of courts in Navi Mumbai, Maharashtra.

11. CONTACT / GRIEVANCE OFFICER