Online EMI ("we", "us", "the App") provides a device-financing and device-management platform that lets retailers finance smartphones on EMI and secure the financed device until the instalments are paid. This notice explains what personal data we collect, why, and your rights. It is issued in accordance with the Digital Personal Data Protection Act, 2023 (DPDP Act) and the Information Technology Act, 2000. For the purpose of the DPDP Act, we act as the Data Fiduciary and you (the customer whose device is financed) are the Data Principal.
To operate device financing and lawful recovery we collect, with your consent at enrolment: (a) Identity & contact data — name, mobile number, email and address; (b) Device data — IMEI number(s), serial number, device model, OS version and battery status; (c) SIM data — SIM serial numbers and network operator, used to detect SIM changes on a financed device; (d) Location data — approximate device location, used only to locate a financed device in case of default or theft; (e) Financing data — EMI amount, tenure, down payment, due dates and payment status. We do not intentionally collect contacts, messages, photos, call logs or browsing history.
We process your personal data on the basis of your consent and for the following specified, lawful purposes only: enrolling and managing the financed device; tracking instalment payments; sending payment reminders and pre-lock notices; locking or unlocking the device for lawful recovery when instalments are not paid as agreed; and preventing fraud (for example detecting an unauthorised SIM change or factory reset). We will not use your data for any purpose incompatible with these without seeking fresh consent.
Your explicit, informed consent is taken at the time of device enrolment, before any personal data is collected. Consent is recorded with a timestamp. You may withdraw your consent at any time by contacting the retailer or our Grievance Officer (details below). Withdrawing consent will end device-management services for that device; it does not affect your obligation to repay the financed amount, and does not affect processing already carried out on the basis of your earlier consent.
We collect only the data necessary for the purposes above. We retain your personal data only for as long as the financing relationship is active and for a further period required by law (for example, tax and accounting records). Once the EMI is fully cleared and any statutory retention period has passed, we stop location and SIM tracking and delete or anonymise your personal data. Financial transaction records may be retained in anonymised or minimal form as required by law.
We do not sell, rent or trade your personal data. We share it only with: the retailer/financier who financed your device (they need it to service your loan); payment processors, solely to process payments; and government or law-enforcement authorities where required by law. Any processor acting on our behalf is bound by contract to protect your data and use it only for the stated purpose.
We apply reasonable technical and organisational safeguards, including encryption in transit (HTTPS/TLS), authenticated and access-controlled APIs, per-device signing, rate-limiting and web-application-firewall protection, and need-to-know staff access. No system is perfectly secure, but we work to protect your data against unauthorised access, alteration or disclosure. In the event of a personal-data breach, we will notify the Data Protection Board of India and affected Data Principals as required by the DPDP Act.
Under the DPDP Act you have the right to: (a) access a summary of the personal data we hold about you and how it is processed; (b) request correction, completion or updating of inaccurate data; (c) request erasure of your personal data once it is no longer required for the purpose; (d) nominate another individual to exercise your rights in the event of death or incapacity; and (e) grievance redressal. To exercise any right, contact our Grievance Officer. We will respond within the timelines prescribed under the Act.
If you have any question, complaint or request regarding your personal data, you may contact our Grievance Officer:
Name: Arun Maurya
Email: [email protected]
Phone: 8976688672
We aim to acknowledge every grievance promptly and resolve it within the period prescribed under the DPDP Act. If you are not satisfied with our response, you may escalate to the Data Protection Board of India.
Our service is intended for adults entering a financing agreement. We do not knowingly process the personal data of children (persons under 18) without verifiable consent of a parent or lawful guardian. If you believe a child's data has been collected, contact the Grievance Officer for its removal.
By enrolling, you agree to receive service communications by SMS, email and phone calls relating to your financing (reminders, notices, disputes). You may opt out of non-essential communications at any time; essential service and recovery notices required for the financing will continue.
We may update this notice from time to time. Material changes will be made available here. Continued use of the App after an update constitutes acknowledgement of the revised notice.