Privacy Policy
Privacy Policy of Rezolv AI Technology Solutions Pvt. Ltd.
Introduction
Rezolv AI Technology Solutions Pvt. Ltd. or referred herein as “Rezolv” ("Company", "we", "our", or "us"), a digital debt recovery agency, is committed to protecting the privacy of individuals ("you", "your", or "users") who visit our website and/or use our mobile application (collectively, the "Platform"). This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal information when you interact with our Platform.
By accessing or using our Platform, you agree to the collection and use of information in accordance with this Privacy Policy. This policy has been developed in compliance with applicable data protection laws in India, including but not limited to the Information Technology Act, 2000, and the associated Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
The purpose of this Privacy Policy is to inform you about the types of personal data we collect, how we process it, your rights concerning your personal data, and the steps we take to protect it. If you do not agree with the terms of this policy, you are advised not to use our Platform.
Definitions
For the purposes of this Privacy Policy, the following terms shall have the meanings ascribed to them unless the context requires otherwise:
- "Personal Data" refers to any information that relates to an identified or identifiable individual, such as name, contact details, identification number, location data, financial information, or any other data that, either directly or indirectly, can be used to identify a person.
- "Processing" means any operation or set of operations performed on Personal Data, whether by automated means or otherwise, including but not limited to collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, alignment, combination, restriction, erasure, or destruction of such data.
- "Third Parties" refers to any external entities, including service providers, partners, or affiliates, that may access or process Personal Data in connection with the services provided by Rezolv.
- "Cookies" refers to small data files stored on your device when you visit a website, which may be used to remember your preferences, collect analytics, and improve your experience on the Platform.
- "Data Principal" refers to the individual to whom the Personal Data relates. In this Privacy Policy, the Data Principal is referred to as "you" or "your."
- "Data Fiduciary" means any person, including the State, a company, or any entity, who determines the purpose and means of processing Personal Data. For the purposes of this Privacy Policy, Rezolv is the Data Fiduciary.
- "Data Processor" refers to any person or entity that processes Personal Data on behalf of the Data Fiduciary.
- "Sensitive Personal Data or Information" (SPDI) refers to specific categories of personal data that are given a higher level of protection under Indian law. This includes but is not limited to passwords, financial information (such as bank account or payment instrument details), health information, biometric data, sexual orientation, and any other information as prescribed under applicable laws.
- "Anonymization" refers to the irreversible process of transforming personal data in such a manner that individuals can no longer be identified, either directly or indirectly, from the data, thereby making it impossible to trace the data back to a specific individual.
- "Pseudonymization" refers to the processing of Personal Data in such a manner that it can no longer be attributed to a specific Data Subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the Personal Data is not attributed to an identified or identifiable person.
- "Data Breach" refers to any unlawful or unauthorized access, acquisition, disclosure, alteration, loss, or destruction of Personal Data, which compromises the security, confidentiality, or integrity of such data.
- "Grievance Officer" refers to the individual designated by the Company, in compliance with Indian laws, who is responsible for addressing any concerns or complaints regarding the processing of Personal Data.
- "Third-Party Service Providers" refers to external entities that assist the Company in providing services, including but not limited to IT service providers, cloud service providers, payment processors, or marketing platforms, who may have access to Personal Data for the purpose of performing their services.
- "User Account" refers to the account created by a user on the Platform to access services, wherein certain personal information may be collected and stored for providing tailored services.
- "Profiling" refers to any form of automated processing of Personal Data intended to evaluate certain personal aspects of an individual, such as analyzing or predicting aspects concerning their economic situation, creditworthiness, behavior, interests, or location.
- "Withdrawal of Consent" refers to the right of a Data Subject to revoke their consent to the processing of their Personal Data at any time, without affecting the legality of processing based on consent prior to its withdrawal.
Types of Information Collected
Rezolv may collect the following types of information when you use our website and/or mobile application ("Platform"):
- Personal Information
Personal Information refers to any data that can identify you as an individual. The types of Personal Information we collect may include, but are not limited to:
- Contact Information: Name, email address, phone number, postal address, and other similar contact details.
- Identity Information: Date of birth, government-issued identification numbers (such as PAN, Aadhaar, or passport numbers), and any other information required for identity verification.
- Financial Information: Bank account details, credit or debit card information, loan or debt information, credit history, and other financial data necessary for providing debt recovery services.
- Communication Data: Information collected through your correspondence with us, including details of inquiries, complaints, or feedback submitted to us via the Platform or other communication channels.
- Account Information: Usernames, passwords, and any other information you provide when creating an account on the Platform.
- Transaction Data: Details of payments, recoveries, or any other transactions you perform using the Platform.
- Non-Personal Information
Non-Personal Information refers to any data that cannot be used to identify you as an individual and may include:
- Device Information: Details about the device used to access the Platform, such as hardware model, operating system, unique device identifiers, and mobile network information.
- Browser and Usage Information: Type of browser, IP address, Internet Service Provider (ISP), browsing patterns, time zone settings, and Platform usage details (e.g., time spent on the Platform, pages viewed, and navigation paths).
- Log Data: Information collected automatically each time you interact with our Platform, including server logs, error reports, and timestamps.
- Cookies and Similar Technologies: Data collected through cookies, pixels, web beacons, or other tracking technologies that enhance your browsing experience and help us analyze user behavior.
- Sensitive Personal Data or Information (SPDI)
In compliance with Indian laws, we may also collect Sensitive Personal Data or Information (SPDI), including but not limited to:
- Financial Information: Bank account details, payment instrument details, or any other payment-related data.
- Authentication Data: Passwords, security questions, and other authentication credentials.
- Biometric Data: If required by law or with your explicit consent, we may collect biometric data such as fingerprints or facial recognition data for identity verification purposes.
The collection of Sensitive Personal Data or Information is subject to specific legal and security safeguards, and we will only process such data with your consent or as required by applicable laws.
By using our Platform, you consent to the collection of the aforementioned information, which is essential for providing our services effectively and in compliance with legal obligations.
Method of Data Collection
- Rezolv collects Personal Information and Non-Personal Information through various methods to ensure efficient and effective use of our Platform and the services we provide. These methods include:
- Direct Collection
- Communication and Correspondence: Information you provide when communicating with us through customer service, submitting inquiries, participating in surveys, or providing feedback.
- Transaction Data: Information you provide when making payments, updating account information, or engaging with our debt recovery services.
- Forms and Applications: Information you provide through forms or applications available on our Platform, including those related to identity verification or debt settlement processes.
- Automated Collection
- Cookies: We use cookies and similar tracking technologies to collect data about your browsing behavior, device settings, preferences, and Platform usage patterns. This information helps us enhance user experience, personalize content, and improve the functionality of our services. You can manage your cookie preferences via browser settings or opt out where applicable.
- Web Analytics: We use analytics tools such as Google Analytics to automatically collect and analyze information about your interactions with our Platform. This may include your IP address, browser type, referral pages, time spent on pages, and other usage data. This data is anonymized and aggregated for statistical purposes.
- Log Files: Our servers automatically collect log files containing information such as your IP address, browser type, access times, pages viewed, and other diagnostic information that helps us monitor and improve the performance of our Platform.
- Device Information: We collect information about the device you use to access our Platform, including the hardware model, operating system version, and unique device identifiers. This data is used to optimize compatibility and improve service delivery.
- Third-Party Sources
- Service Providers: Information provided by third-party service providers (such as credit bureaus, debt recovery agents, or payment processors) to assist in providing our services or verifying the accuracy of your data.
- Partners and Affiliates: We may collect information from our business partners, affiliates, or other trusted entities that share data with us to help us fulfill our debt recovery services and comply with legal requirements.
Purpose of Data Collection
- Rezolv collects and processes Personal and Non-Personal Information for specific, legitimate purposes in connection with the services we offer through our Platform. The purposes for which we collect your data include, but are not limited to, the following:
- For Debt Recovery and Related Services
- Verification of Identity: Ensuring that the data provided by you is accurate and up-todate, and verifying your identity for the purposes of initiating the debt recovery process.
- Debt Collection Activities: Engaging in communications, negotiations, and transactions related to the recovery of outstanding debts. This may include reaching out via various communication channels, processing payments, and maintaining records of the debt recovery process.
- Reporting and Record-Keeping: Maintaining records of interactions, transactions, and recoveries for future reference, audits, or legal requirements.
- Compliance with Legal Obligations
- Regulatory Compliance: Ensuring that our debt recovery practices adhere to relevant legal and regulatory requirements, such as the Information Technology Act, 2000, and any rules or guidelines issued by regulatory authorities.
- Fraud Prevention and Risk Management: Detecting and preventing fraud, unauthorized transactions, and other illegal activities that may compromise the integrity of our services or data.
- Customer Support
- Responding to Inquiries and Complaints: Addressing any questions, concerns, or complaints you may have regarding our services, and providing timely responses to resolve issues.
- User Account Management: Assisting with the creation, updating, and management of your user account, including password resets, account settings, and other related functions.
- Assisting with Transactions: Helping you with payments, refunds, and any other transaction-related support you may require during your use of the Platform.
- Improvement of Services and Website/Application
- Enhancing User Experience: Using your feedback and behavioural data to optimize the performance, design, and functionality of our Platform, ensuring a better user experience.
- Platform Maintenance and Development: Monitoring usage patterns, diagnosing technical issues, and implementing upgrades to improve the stability, security, and performance of our Platform.
- Personalized Services: Using cookies and tracking technologies to tailor content and offers based on your preferences, past interactions, and behavior on the Platform.
- Research and Analytics: Analyzing trends, usage data, and feedback to gain insights into user needs, preferences, and satisfaction levels, which helps us improve our services and identify new offerings.
Legal Basis for Processing Personal Data
Rezolv processes Personal Data in accordance with applicable laws and only when we have a lawful basis for doing so. The legal bases for processing your Personal Data include, but are not limited to, the following:
- Consent of the Data Subject
We process your Personal Data based on your explicit and informed consent in the following circumstances:
- Marketing and Promotional Activities: When you agree to receive marketing communications, newsletters, or other promotional content, we process your data based on your consent.
- Optional Data Processing: When we collect data that is not strictly necessary for the provision of our services (such as certain types of cookies or analytics data), we seek your consent to process such information.
You may withdraw your consent at any time by contacting us or following the opt-out mechanisms provided in the communication, without affecting the legality of processing based on consent before its withdrawal.
- Performance of a Contract
We process your Personal Data when it is necessary to fulfill our contractual obligations with you. This includes:
- Provision of Debt Recovery Services: Processing your Personal Data to perform debt recovery services as part of our agreement with you or with third parties (such as creditors or financial institutions) on your behalf.
- User Account Management: Collecting and processing data for the creation, management, and maintenance of your user account, including authentication and security measures.
- Transaction Processing: Using your financial information to process payments, refunds, and related transactions associated with the services we provide.
If you do not provide the necessary data for the performance of a contract, we may be unable to fulfill our contractual obligations.
- Compliance with Legal Obligations
Rezolv may process your Personal Data when it is necessary to comply with our legal obligations under applicable laws and regulations. This includes:
- Regulatory Compliance: Ensuring compliance with Indian data protection laws, tax laws, anti-money laundering regulations, and other legal requirements that govern debt recovery activities.
- Legal Disclosures: Disclosing data to regulatory authorities, law enforcement agencies, courts, or other governmental entities when required by law, such as in response to subpoenas, court orders, or government investigations.
- Record Retention: Retaining data as required by law for auditing, reporting, or other compliance purposes.
- Legitimate Interests
We may process your Personal Data based on our legitimate business interests, provided that such processing does not override your fundamental rights and freedoms. Legitimate interests include:
- Service Improvement: Using your data to improve and personalize the services we offer, including enhancing the functionality, security, and performance of our Platform.
- Fraud Prevention and Security: Processing data to detect and prevent fraud, unauthorized activities, or security breaches that may compromise our services, data, or users.
- Legal Defence and Risk Management: Processing data in connection with potential legal claims, compliance audits, or risk assessments to protect our interests, as well as those of our clients and partners.
- Business Operations: Using data for general business operations, including conducting research and analysis to better understand user needs, developing new products, and growing our business.
In all instances, we will ensure that the processing of Personal Data is carried out in a fair, transparent, and lawful manner, in compliance with applicable Indian data protection regulations. If you have any questions about the legal basis for processing your Personal Data, you can contact us for further clarification.
Use of Cookies and Tracking Technologies
- Rezolv uses cookies and similar tracking technologies to enhance your experience on our website and/or mobile application ("Platform"). This section explains the types of cookies we use, how we use them, and your choices regarding their use.
- Types of Cookies Used
- Functional Cookies: These cookies are essential for the proper functioning of the Platform. They enable core features such as secure logins, session management, and user preferences. Without these cookies, certain features of the Platform may not work correctly.
- Analytics Cookies: These cookies help us understand how users interact with the Platform by collecting information about usage patterns, such as pages visited, time spent on the Platform, and any errors encountered. This information is anonymized and used to improve the functionality and performance of our services. For example, we may use Google Analytics to gather and analyze usage data.
- Performance Cookies: These cookies collect information about how the Platform performs, including the speed of page loading and any performance issues. The data collected is used to monitor and improve the Platform’s efficiency and user experience.
- Advertising and Targeting Cookies: These cookies may be used to deliver personalized advertisements based on your browsing habits and interests. They help us understand your preferences and provide content that is relevant to you. We may also use these cookies to limit the number of times you see an ad and to measure the effectiveness of advertising campaigns.
- Third-Party Cookies: In some cases, third-party service providers (such as social media platforms or advertising networks) may place cookies on your device when you interact with certain features of our Platform. These cookies are subject to the privacy policies of the respective third parties.
- How We Use Cookies
- To remember your preferences and settings (e.g., language, region) during your visits to the Platform.
- To authenticate users and prevent unauthorized access to secure areas of the Platform.
- To track and analyse usage data, helping us understand how users navigate through the Platform and identify areas for improvement.
- To deliver personalized content and advertisements based on your interests and online behavior.
- To manage and improve the security and performance of our Platform.
Data Sharing and Disclosure
- Rezolv is committed to safeguarding your Personal Data and ensuring that it is shared only under appropriate circumstances. This section outlines the situations in which we may share or disclose your data, and the safeguards we employ to protect your privacy.
- With Third-Party Service Providers
- Payment Processors: Entities that handle payment processing, including financial institutions and payment gateways.
- Technology Providers: Providers of IT infrastructure, cloud storage, data analytics, and technical support that help us maintain and improve our Platform.
- Debt Collection Agents: External agents or companies that assist in the recovery of debts.
- Verification and Authentication Services: Providers who assist in identity verification and fraud prevention.
- With Regulatory Authorities
- Compliance with Legal Requirements: We may disclose your data to comply with applicable laws, regulations, or legal processes, such as responding to court orders, subpoenas, or requests from government authorities.
- Regulatory Reporting: In cases where we are legally required to report certain activities, such as debt recovery transactions, to government or regulatory bodies.
- Public Safety and Risk Prevention: When necessary, we may share your data to protect public safety, prevent fraud, or mitigate security risks.
- In Case of Business Transfers
- Mergers and Acquisitions: If Rezolv is acquired by or merges with another company, your data may be transferred to the acquiring entity as part of the business transaction.
- Asset Transfers: In the case of the sale, liquidation, or transfer of some or all our assets, your data may be included as part of the transferred assets.
- Business Reorganization: If we undergo any form of restructuring, your data may be shared with the relevant entities to ensure continuity of service.
- For Legal Compliance
- Legal defence: To defend or enforce our legal rights in the event of legal disputes, including disputes relating to debt recovery.
- Fraud and Security Monitoring: To detect, prevent, or respond to fraud, unauthorized access, or other illegal activities.
- Protection of Others: To protect the rights, property, or safety of our users, employees, or the public.
Data Security Measures
- Rezolv is committed to ensuring the security and confidentiality of your Personal Data. We implement a variety of technical, administrative, and organizational measures to protect your data from unauthorized access, disclosure, alteration, or destruction. The following outlines our key data security measures:
- Encryption, Firewalls, and Other Security Measures
- Data Encryption: We use encryption protocols (such as SSL/TLS) to protect your Personal Data during transmission over the internet. This ensures that sensitive information such as financial data and login credentials are securely transmitted between your device and our Platform.
- Firewalls: Our systems are protected by firewalls that help prevent unauthorized access to our networks and servers. Firewalls act as a barrier between trusted internal networks and untrusted external sources, ensuring that only authorized traffic is allowed.
- Access Controls: We limit access to Personal Data to authorized personnel who require such access for the performance of their duties. Access controls, such as multi-factor authentication (MFA) and role-based access control (RBAC), are in place to ensure that only authorized individuals can access sensitive data.
- Data Masking and Anonymization: Where possible, we use techniques such as data masking or anonymization to further protect sensitive information, especially when handling or storing data that is not required to identify specific individuals.
- Regular Security Audits and Vulnerability Testing: We conduct regular security audits, vulnerability assessments, and penetration testing to identify and address any potential security risks or vulnerabilities in our systems and infrastructure.
- Monitoring and Incident Response: Our systems are continuously monitored for unusual or unauthorized activity. In the event of a security breach or data incident, we have an incident response plan in place to quickly contain and mitigate any damage.
- ISO 27001 or Other Certifications
- ISO 27001 Certification: We are certified under the ISO 27001 standard, which demonstrates our adherence to international best practices for information security management. This certification requires us to implement and maintain rigorous security controls to protect the confidentiality, integrity, and availability of Personal Data.
- Compliance with Industry Standards: In addition to ISO 27001, we adhere to other relevant security standards and frameworks applicable to the financial and data processing industries. This includes compliance with regulatory security guidelines set forth by Indian authorities, such as the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
- Periodic Security Audits: Our security practices are regularly audited by external auditors to ensure that we maintain compliance with applicable laws, certifications, and internal policies. These audits help us identify potential areas for improvement and ensure continuous enhancement of our security measures.
Data Retention Policy
- Rezolv is committed to retaining Personal Data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws and regulations. This section outlines our data retention practices and the criteria we use to determine how long your data will be stored.
- Duration for Which Personal Data Will Be Retained
- Service-Related Data: We retain your Personal Data for the duration of your relationship with us, including the period during which we provide debt recovery services and any post-service interactions. Once the relationship has ended or the services have been completed, we may retain your data for a specified period to comply with legal and regulatory obligations, resolve disputes, and enforce agreements.
- Financial Data: Personal financial information, including payment and transaction data, is retained for as long as necessary to comply with financial reporting, auditing, and taxation requirements under applicable laws.
- Communication Data: We retain records of your communications with us, including emails, phone calls, or other forms of correspondence, for as long as needed to resolve your inquiries, maintain customer support records, and comply with legal obligations.
- Anonymized or Aggregated Data: In some cases, we may anonymize your Personal Data so that it can no longer identify you. This anonymized data may be retained indefinitely for analytical purposes, research, or to improve our services.
- Biometric/Face Data Collection and Retention: We operate as a data processor on behalf of its institutional customers, such as banks and NBFCs, which control the workspace and determine the business purpose of processing. Face data is collected solely for agent identity verification at the time of access to sensitive field workflows and customer-linked financial operations. This is done to support the subscribing institution's operational security, fraud prevention, and audit trail requirements.Face data is retained for the duration of the subscribing institution's active engagement with the Rezolv platform. This period is necessary to maintain a verifiable audit trail for all field operations conducted on the institution's behalf, as required under applicable regulatorygidelines.
- Criteria for Determining Retention Periods
- Legal and Regulatory Requirements: We are obligated to retain certain types of data to comply with applicable laws, including tax, anti-money laundering (AML), and financial regulations. Data retention periods may vary depending on the jurisdiction and specific regulatory requirements.
- Contractual Obligations: Data necessary for the performance of a contract, including debt recovery agreements, will be retained for the duration of the contract and as required for post-contractual obligations, such as dispute resolution or contract enforcement.
- Business Needs: Personal Data may be retained for as long as necessary to meet our legitimate business interests, such as fraud prevention, maintaining accurate business records, and defending or enforcing legal claims.
- User Requests: If you request the deletion or anonymization of your Personal Data, we will assess whether we are required to retain the data by law or for legitimate business purposes. Where no such requirement exists, we will delete or anonymize your data as requested.
- Data Minimization: We follow the principle of data minimization, ensuring that we only retain the minimum amount of Personal Data necessary to achieve the purposes outlined in this Privacy Policy.
Changes to the Privacy Policy
- Rezolv reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or service offerings.
- Continued Use of the Platform: By continuing to use our Platform after any changes to this Privacy Policy become effective, you are deemed to have accepted the revised terms. If you do not agree with the updated policy, you must discontinue your use of the Platform and may contact us for further clarification or assistance.
- Rezolv reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or service offerings.
Grievance Redressal Mechanism
- We take your privacy and concerns seriously and have implemented a Grievance Redressal Mechanism to address any issues related to the collection, use, or protection of your Personal Data.
- Grievance Officer: In compliance with applicable Indian laws, we have appointed a Grievance Officer to handle your concerns and complaints regarding data privacy.
- Grievance Officer: Anil Chatla
- Email: anil.chatla@rezolv.com
- Phone: 9029693406
- Address: Unit #214, D-Wing, Kanakia Zillion, Kurla West, Kurla, Mumbai, Maharashtra 400070
- Process for Raising Concerns or Complaints:
- If you have any concerns or complaints regarding the processing of your Personal Data or believe that your privacy rights have been violated, you may contact the Grievance Officer.
- You may submit your complaint in writing, via email, or through any other form of communication provided in the contact details above.
- Upon receiving your complaint, the Grievance Officer will acknowledge receipt and investigate the matter. You will receive a response within a reasonable timeframe, typically no later than 30 days from the receipt of your complaint.
- If you are not satisfied with the resolution provided by the Grievance Officer, you have the right to escalate the matter to the relevant data protection authorities as applicable under Indian law.
- Process for Raising Concerns or Complaints:
Applicable Laws and Jurisdiction
- This Privacy Policy is governed by and construed in accordance with the laws of India.
- In the event of any disputes arising from or relating to this Privacy Policy, the courts of Mumbai, Maharashtra shall have exclusive jurisdiction, subject to any applicable dispute resolution mechanisms agreed upon by the parties.
- By using our Platform, you acknowledge that any legal disputes concerning your data and privacy will be governed by Indian law, and you agree to submit to the jurisdiction of the courts of India for resolution of such matters.
Introduction
Rezolv AI Technology Solutions Pvt. Ltd. or referred herein as “Rezolv” ("Company", "we", "our", or "us"), a digital debt recovery agency, is committed to protecting the privacy of individuals ("you", "your", or "users") who visit our website and/or use our mobile application (collectively, the "Platform"). This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal information when you interact with our Platform.
By accessing or using our Platform, you agree to the collection and use of information in accordance with this Privacy Policy. This policy has been developed in compliance with applicable data protection laws in India, including but not limited to the Information Technology Act, 2000, and the associated Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
The purpose of this Privacy Policy is to inform you about the types of personal data we collect, how we process it, your rights concerning your personal data, and the steps we take to protect it. If you do not agree with the terms of this policy, you are advised not to use our Platform.
Definitions
For the purposes of this Privacy Policy, the following terms shall have the meanings ascribed to them unless the context requires otherwise:
- "Personal Data" refers to any information that relates to an identified or identifiable individual, such as name, contact details, identification number, location data, financial information, or any other data that, either directly or indirectly, can be used to identify a person.
- "Processing" means any operation or set of operations performed on Personal Data, whether by automated means or otherwise, including but not limited to collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, alignment, combination, restriction, erasure, or destruction of such data.
- "Third Parties" refers to any external entities, including service providers, partners, or affiliates, that may access or process Personal Data in connection with the services provided by Rezolv.
- "Cookies" refers to small data files stored on your device when you visit a website, which may be used to remember your preferences, collect analytics, and improve your experience on the Platform.
- "Data Principal" refers to the individual to whom the Personal Data relates. In this Privacy Policy, the Data Principal is referred to as "you" or "your."
- "Data Fiduciary" means any person, including the State, a company, or any entity, who determines the purpose and means of processing Personal Data. For the purposes of this Privacy Policy, Rezolv is the Data Fiduciary.
- "Data Processor" refers to any person or entity that processes Personal Data on behalf of the Data Fiduciary.
- "Sensitive Personal Data or Information" (SPDI) refers to specific categories of personal data that are given a higher level of protection under Indian law. This includes but is not limited to passwords, financial information (such as bank account or payment instrument details), health information, biometric data, sexual orientation, and any other information as prescribed under applicable laws.
- "Anonymization" refers to the irreversible process of transforming personal data in such a manner that individuals can no longer be identified, either directly or indirectly, from the data, thereby making it impossible to trace the data back to a specific individual.
- "Pseudonymization" refers to the processing of Personal Data in such a manner that it can no longer be attributed to a specific Data Subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the Personal Data is not attributed to an identified or identifiable person.
- "Data Breach" refers to any unlawful or unauthorized access, acquisition, disclosure, alteration, loss, or destruction of Personal Data, which compromises the security, confidentiality, or integrity of such data.
- "Grievance Officer" refers to the individual designated by the Company, in compliance with Indian laws, who is responsible for addressing any concerns or complaints regarding the processing of Personal Data.
- "Third-Party Service Providers" refers to external entities that assist the Company in providing services, including but not limited to IT service providers, cloud service providers, payment processors, or marketing platforms, who may have access to Personal Data for the purpose of performing their services.
- "User Account" refers to the account created by a user on the Platform to access services, wherein certain personal information may be collected and stored for providing tailored services.
- "Profiling" refers to any form of automated processing of Personal Data intended to evaluate certain personal aspects of an individual, such as analyzing or predicting aspects concerning their economic situation, creditworthiness, behavior, interests, or location.
- "Withdrawal of Consent" refers to the right of a Data Subject to revoke their consent to the processing of their Personal Data at any time, without affecting the legality of processing based on consent prior to its withdrawal.
Types of Information Collected
Rezolv may collect the following types of information when you use our website and/or mobile application ("Platform"):
- Personal Information
Personal Information refers to any data that can identify you as an individual. The types of Personal Information we collect may include, but are not limited to:
- Contact Information: Name, email address, phone number, postal address, and other similar contact details.
- Identity Information: Date of birth, government-issued identification numbers (such as PAN, Aadhaar, or passport numbers), and any other information required for identity verification.
- Financial Information: Bank account details, credit or debit card information, loan or debt information, credit history, and other financial data necessary for providing debt recovery services.
- Communication Data: Information collected through your correspondence with us, including details of inquiries, complaints, or feedback submitted to us via the Platform or other communication channels.
- Account Information: Usernames, passwords, and any other information you provide when creating an account on the Platform.
- Transaction Data: Details of payments, recoveries, or any other transactions you perform using the Platform.
- Non-Personal Information
Non-Personal Information refers to any data that cannot be used to identify you as an individual and may include:
- Device Information: Details about the device used to access the Platform, such as hardware model, operating system, unique device identifiers, and mobile network information.
- Browser and Usage Information: Type of browser, IP address, Internet Service Provider (ISP), browsing patterns, time zone settings, and Platform usage details (e.g., time spent on the Platform, pages viewed, and navigation paths).
- Log Data: Information collected automatically each time you interact with our Platform, including server logs, error reports, and timestamps.
- Cookies and Similar Technologies: Data collected through cookies, pixels, web beacons, or other tracking technologies that enhance your browsing experience and help us analyze user behavior.
- Sensitive Personal Data or Information (SPDI)
In compliance with Indian laws, we may also collect Sensitive Personal Data or Information (SPDI), including but not limited to:
- Financial Information: Bank account details, payment instrument details, or any other payment-related data.
- Authentication Data: Passwords, security questions, and other authentication credentials.
- Biometric Data: If required by law or with your explicit consent, we may collect biometric data such as fingerprints or facial recognition data for identity verification purposes.
The collection of Sensitive Personal Data or Information is subject to specific legal and security safeguards, and we will only process such data with your consent or as required by applicable laws.
By using our Platform, you consent to the collection of the aforementioned information, which is essential for providing our services effectively and in compliance with legal obligations.
Method of Data Collection
- Rezolv collects Personal Information and Non-Personal Information through various methods to ensure efficient and effective use of our Platform and the services we provide. These methods include:
- Direct Collection
- Communication and Correspondence: Information you provide when communicating with us through customer service, submitting inquiries, participating in surveys, or providing feedback.
- Transaction Data: Information you provide when making payments, updating account information, or engaging with our debt recovery services.
- Forms and Applications: Information you provide through forms or applications available on our Platform, including those related to identity verification or debt settlement processes.
- Automated Collection
- Cookies: We use cookies and similar tracking technologies to collect data about your browsing behavior, device settings, preferences, and Platform usage patterns. This information helps us enhance user experience, personalize content, and improve the functionality of our services. You can manage your cookie preferences via browser settings or opt out where applicable.
- Web Analytics: We use analytics tools such as Google Analytics to automatically collect and analyze information about your interactions with our Platform. This may include your IP address, browser type, referral pages, time spent on pages, and other usage data. This data is anonymized and aggregated for statistical purposes.
- Log Files: Our servers automatically collect log files containing information such as your IP address, browser type, access times, pages viewed, and other diagnostic information that helps us monitor and improve the performance of our Platform.
- Device Information: We collect information about the device you use to access our Platform, including the hardware model, operating system version, and unique device identifiers. This data is used to optimize compatibility and improve service delivery.
- Third-Party Sources
- Service Providers: Information provided by third-party service providers (such as credit bureaus, debt recovery agents, or payment processors) to assist in providing our services or verifying the accuracy of your data.
- Partners and Affiliates: We may collect information from our business partners, affiliates, or other trusted entities that share data with us to help us fulfill our debt recovery services and comply with legal requirements.
Purpose of Data Collection
- Rezolv collects and processes Personal and Non-Personal Information for specific, legitimate purposes in connection with the services we offer through our Platform. The purposes for which we collect your data include, but are not limited to, the following:
- For Debt Recovery and Related Services
- Verification of Identity: Ensuring that the data provided by you is accurate and up-todate, and verifying your identity for the purposes of initiating the debt recovery process.
- Debt Collection Activities: Engaging in communications, negotiations, and transactions related to the recovery of outstanding debts. This may include reaching out via various communication channels, processing payments, and maintaining records of the debt recovery process.
- Reporting and Record-Keeping: Maintaining records of interactions, transactions, and recoveries for future reference, audits, or legal requirements.
- Compliance with Legal Obligations
- Regulatory Compliance: Ensuring that our debt recovery practices adhere to relevant legal and regulatory requirements, such as the Information Technology Act, 2000, and any rules or guidelines issued by regulatory authorities.
- Fraud Prevention and Risk Management: Detecting and preventing fraud, unauthorized transactions, and other illegal activities that may compromise the integrity of our services or data.
- Customer Support
- Responding to Inquiries and Complaints: Addressing any questions, concerns, or complaints you may have regarding our services, and providing timely responses to resolve issues.
- User Account Management: Assisting with the creation, updating, and management of your user account, including password resets, account settings, and other related functions.
- Assisting with Transactions: Helping you with payments, refunds, and any other transaction-related support you may require during your use of the Platform.
- Improvement of Services and Website/Application
- Enhancing User Experience: Using your feedback and behavioural data to optimize the performance, design, and functionality of our Platform, ensuring a better user experience.
- Platform Maintenance and Development: Monitoring usage patterns, diagnosing technical issues, and implementing upgrades to improve the stability, security, and performance of our Platform.
- Personalized Services: Using cookies and tracking technologies to tailor content and offers based on your preferences, past interactions, and behavior on the Platform.
- Research and Analytics: Analyzing trends, usage data, and feedback to gain insights into user needs, preferences, and satisfaction levels, which helps us improve our services and identify new offerings.
Legal Basis for Processing Personal Data
Rezolv processes Personal Data in accordance with applicable laws and only when we have a lawful basis for doing so. The legal bases for processing your Personal Data include, but are not limited to, the following:
- Consent of the Data Subject
We process your Personal Data based on your explicit and informed consent in the following circumstances:
- Marketing and Promotional Activities: When you agree to receive marketing communications, newsletters, or other promotional content, we process your data based on your consent.
- Optional Data Processing: When we collect data that is not strictly necessary for the provision of our services (such as certain types of cookies or analytics data), we seek your consent to process such information.
You may withdraw your consent at any time by contacting us or following the opt-out mechanisms provided in the communication, without affecting the legality of processing based on consent before its withdrawal.
- Performance of a Contract
We process your Personal Data when it is necessary to fulfill our contractual obligations with you. This includes:
- Provision of Debt Recovery Services: Processing your Personal Data to perform debt recovery services as part of our agreement with you or with third parties (such as creditors or financial institutions) on your behalf.
- User Account Management: Collecting and processing data for the creation, management, and maintenance of your user account, including authentication and security measures.
- Transaction Processing: Using your financial information to process payments, refunds, and related transactions associated with the services we provide.
If you do not provide the necessary data for the performance of a contract, we may be unable to fulfill our contractual obligations.
- Compliance with Legal Obligations
Rezolv may process your Personal Data when it is necessary to comply with our legal obligations under applicable laws and regulations. This includes:
- Regulatory Compliance: Ensuring compliance with Indian data protection laws, tax laws, anti-money laundering regulations, and other legal requirements that govern debt recovery activities.
- Legal Disclosures: Disclosing data to regulatory authorities, law enforcement agencies, courts, or other governmental entities when required by law, such as in response to subpoenas, court orders, or government investigations.
- Record Retention: Retaining data as required by law for auditing, reporting, or other compliance purposes.
- Legitimate Interests
We may process your Personal Data based on our legitimate business interests, provided that such processing does not override your fundamental rights and freedoms. Legitimate interests include:
- Service Improvement: Using your data to improve and personalize the services we offer, including enhancing the functionality, security, and performance of our Platform.
- Fraud Prevention and Security: Processing data to detect and prevent fraud, unauthorized activities, or security breaches that may compromise our services, data, or users.
- Legal Defence and Risk Management: Processing data in connection with potential legal claims, compliance audits, or risk assessments to protect our interests, as well as those of our clients and partners.
- Business Operations: Using data for general business operations, including conducting research and analysis to better understand user needs, developing new products, and growing our business.
In all instances, we will ensure that the processing of Personal Data is carried out in a fair, transparent, and lawful manner, in compliance with applicable Indian data protection regulations. If you have any questions about the legal basis for processing your Personal Data, you can contact us for further clarification.
Use of Cookies and Tracking Technologies
- Rezolv uses cookies and similar tracking technologies to enhance your experience on our website and/or mobile application ("Platform"). This section explains the types of cookies we use, how we use them, and your choices regarding their use.
- Types of Cookies Used
- Functional Cookies: These cookies are essential for the proper functioning of the Platform. They enable core features such as secure logins, session management, and user preferences. Without these cookies, certain features of the Platform may not work correctly.
- Analytics Cookies: These cookies help us understand how users interact with the Platform by collecting information about usage patterns, such as pages visited, time spent on the Platform, and any errors encountered. This information is anonymized and used to improve the functionality and performance of our services. For example, we may use Google Analytics to gather and analyze usage data.
- Performance Cookies: These cookies collect information about how the Platform performs, including the speed of page loading and any performance issues. The data collected is used to monitor and improve the Platform’s efficiency and user experience.
- Advertising and Targeting Cookies: These cookies may be used to deliver personalized advertisements based on your browsing habits and interests. They help us understand your preferences and provide content that is relevant to you. We may also use these cookies to limit the number of times you see an ad and to measure the effectiveness of advertising campaigns.
- Third-Party Cookies: In some cases, third-party service providers (such as social media platforms or advertising networks) may place cookies on your device when you interact with certain features of our Platform. These cookies are subject to the privacy policies of the respective third parties.
- How We Use Cookies
- To remember your preferences and settings (e.g., language, region) during your visits to the Platform.
- To authenticate users and prevent unauthorized access to secure areas of the Platform.
- To track and analyse usage data, helping us understand how users navigate through the Platform and identify areas for improvement.
- To deliver personalized content and advertisements based on your interests and online behavior.
- To manage and improve the security and performance of our Platform.
Data Sharing and Disclosure
- Rezolv is committed to safeguarding your Personal Data and ensuring that it is shared only under appropriate circumstances. This section outlines the situations in which we may share or disclose your data, and the safeguards we employ to protect your privacy.
- With Third-Party Service Providers
- Payment Processors: Entities that handle payment processing, including financial institutions and payment gateways.
- Technology Providers: Providers of IT infrastructure, cloud storage, data analytics, and technical support that help us maintain and improve our Platform.
- Debt Collection Agents: External agents or companies that assist in the recovery of debts.
- Verification and Authentication Services: Providers who assist in identity verification and fraud prevention.
- With Regulatory Authorities
- Compliance with Legal Requirements: We may disclose your data to comply with applicable laws, regulations, or legal processes, such as responding to court orders, subpoenas, or requests from government authorities.
- Regulatory Reporting: In cases where we are legally required to report certain activities, such as debt recovery transactions, to government or regulatory bodies.
- Public Safety and Risk Prevention: When necessary, we may share your data to protect public safety, prevent fraud, or mitigate security risks.
- In Case of Business Transfers
- Mergers and Acquisitions: If Rezolv is acquired by or merges with another company, your data may be transferred to the acquiring entity as part of the business transaction.
- Asset Transfers: In the case of the sale, liquidation, or transfer of some or all our assets, your data may be included as part of the transferred assets.
- Business Reorganization: If we undergo any form of restructuring, your data may be shared with the relevant entities to ensure continuity of service.
- For Legal Compliance
- Legal defence: To defend or enforce our legal rights in the event of legal disputes, including disputes relating to debt recovery.
- Fraud and Security Monitoring: To detect, prevent, or respond to fraud, unauthorized access, or other illegal activities.
- Protection of Others: To protect the rights, property, or safety of our users, employees, or the public.
Data Security Measures
- Rezolv is committed to ensuring the security and confidentiality of your Personal Data. We implement a variety of technical, administrative, and organizational measures to protect your data from unauthorized access, disclosure, alteration, or destruction. The following outlines our key data security measures:
- Encryption, Firewalls, and Other Security Measures
- Data Encryption: We use encryption protocols (such as SSL/TLS) to protect your Personal Data during transmission over the internet. This ensures that sensitive information such as financial data and login credentials are securely transmitted between your device and our Platform.
- Firewalls: Our systems are protected by firewalls that help prevent unauthorized access to our networks and servers. Firewalls act as a barrier between trusted internal networks and untrusted external sources, ensuring that only authorized traffic is allowed.
- Access Controls: We limit access to Personal Data to authorized personnel who require such access for the performance of their duties. Access controls, such as multi-factor authentication (MFA) and role-based access control (RBAC), are in place to ensure that only authorized individuals can access sensitive data.
- Data Masking and Anonymization: Where possible, we use techniques such as data masking or anonymization to further protect sensitive information, especially when handling or storing data that is not required to identify specific individuals.
- Regular Security Audits and Vulnerability Testing: We conduct regular security audits, vulnerability assessments, and penetration testing to identify and address any potential security risks or vulnerabilities in our systems and infrastructure.
- Monitoring and Incident Response: Our systems are continuously monitored for unusual or unauthorized activity. In the event of a security breach or data incident, we have an incident response plan in place to quickly contain and mitigate any damage.
- ISO 27001 or Other Certifications
- ISO 27001 Certification: We are certified under the ISO 27001 standard, which demonstrates our adherence to international best practices for information security management. This certification requires us to implement and maintain rigorous security controls to protect the confidentiality, integrity, and availability of Personal Data.
- Compliance with Industry Standards: In addition to ISO 27001, we adhere to other relevant security standards and frameworks applicable to the financial and data processing industries. This includes compliance with regulatory security guidelines set forth by Indian authorities, such as the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
- Periodic Security Audits: Our security practices are regularly audited by external auditors to ensure that we maintain compliance with applicable laws, certifications, and internal policies. These audits help us identify potential areas for improvement and ensure continuous enhancement of our security measures.
Data Retention Policy
- Rezolv is committed to retaining Personal Data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws and regulations. This section outlines our data retention practices and the criteria we use to determine how long your data will be stored.
- Duration for Which Personal Data Will Be Retained
- Service-Related Data: We retain your Personal Data for the duration of your relationship with us, including the period during which we provide debt recovery services and any post-service interactions. Once the relationship has ended or the services have been completed, we may retain your data for a specified period to comply with legal and regulatory obligations, resolve disputes, and enforce agreements.
- Financial Data: Personal financial information, including payment and transaction data, is retained for as long as necessary to comply with financial reporting, auditing, and taxation requirements under applicable laws.
- Communication Data: We retain records of your communications with us, including emails, phone calls, or other forms of correspondence, for as long as needed to resolve your inquiries, maintain customer support records, and comply with legal obligations.
- Anonymized or Aggregated Data: In some cases, we may anonymize your Personal Data so that it can no longer identify you. This anonymized data may be retained indefinitely for analytical purposes, research, or to improve our services.
- Criteria for Determining Retention Periods
- Legal and Regulatory Requirements: We are obligated to retain certain types of data to comply with applicable laws, including tax, anti-money laundering (AML), and financial regulations. Data retention periods may vary depending on the jurisdiction and specific regulatory requirements.
- Contractual Obligations: Data necessary for the performance of a contract, including debt recovery agreements, will be retained for the duration of the contract and as required for post-contractual obligations, such as dispute resolution or contract enforcement.
- Business Needs: Personal Data may be retained for as long as necessary to meet our legitimate business interests, such as fraud prevention, maintaining accurate business records, and defending or enforcing legal claims.
- User Requests: If you request the deletion or anonymization of your Personal Data, we will assess whether we are required to retain the data by law or for legitimate business purposes. Where no such requirement exists, we will delete or anonymize your data as requested.
- Data Minimization: We follow the principle of data minimization, ensuring that we only retain the minimum amount of Personal Data necessary to achieve the purposes outlined in this Privacy Policy.
Changes to the Privacy Policy
- Rezolv reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or service offerings.
- Continued Use of the Platform: By continuing to use our Platform after any changes to this Privacy Policy become effective, you are deemed to have accepted the revised terms. If you do not agree with the updated policy, you must discontinue your use of the Platform and may contact us for further clarification or assistance.
- Rezolv reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or service offerings.
Grievance Redressal Mechanism
- We take your privacy and concerns seriously and have implemented a Grievance Redressal Mechanism to address any issues related to the collection, use, or protection of your Personal Data.
- Grievance Officer: In compliance with applicable Indian laws, we have appointed a Grievance Officer to handle your concerns and complaints regarding data privacy.
- Grievance Officer: Anil Chatla
- Email: anil.chatla@rezolv.com
- Phone: 9029693406
- Address: Unit #214, D-Wing, Kanakia Zillion, Kurla West, Kurla, Mumbai, Maharashtra 400070
- Process for Raising Concerns or Complaints:
- If you have any concerns or complaints regarding the processing of your Personal Data or believe that your privacy rights have been violated, you may contact the Grievance Officer.
- You may submit your complaint in writing, via email, or through any other form of communication provided in the contact details above.
- Upon receiving your complaint, the Grievance Officer will acknowledge receipt and investigate the matter. You will receive a response within a reasonable timeframe, typically no later than 30 days from the receipt of your complaint.
- If you are not satisfied with the resolution provided by the Grievance Officer, you have the right to escalate the matter to the relevant data protection authorities as applicable under Indian law.
- Process for Raising Concerns or Complaints:
Applicable Laws and Jurisdiction
- This Privacy Policy is governed by and construed in accordance with the laws of India.
- In the event of any disputes arising from or relating to this Privacy Policy, the courts of Mumbai, Maharashtra shall have exclusive jurisdiction, subject to any applicable dispute resolution mechanisms agreed upon by the parties.
- By using our Platform, you acknowledge that any legal disputes concerning your data and privacy will be governed by Indian law, and you agree to submit to the jurisdiction of the courts of India for resolution of such matters.
Introduction
Rezolv AI Technology Solutions Pvt. Ltd. or referred herein as “Rezolv” ("Company", "we", "our", or "us"), a digital debt recovery agency, is committed to protecting the privacy of individuals ("you", "your", or "users") who visit our website and/or use our mobile application (collectively, the "Platform"). This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal information when you interact with our Platform.
By accessing or using our Platform, you agree to the collection and use of information in accordance with this Privacy Policy. This policy has been developed in compliance with applicable data protection laws in India, including but not limited to the Information Technology Act, 2000, and the associated Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
The purpose of this Privacy Policy is to inform you about the types of personal data we collect, how we process it, your rights concerning your personal data, and the steps we take to protect it. If you do not agree with the terms of this policy, you are advised not to use our Platform.
Definitions
For the purposes of this Privacy Policy, the following terms shall have the meanings ascribed to them unless the context requires otherwise:
- "Personal Data" refers to any information that relates to an identified or identifiable individual, such as name, contact details, identification number, location data, financial information, or any other data that, either directly or indirectly, can be used to identify a person.
- "Processing" means any operation or set of operations performed on Personal Data, whether by automated means or otherwise, including but not limited to collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, alignment, combination, restriction, erasure, or destruction of such data.
- "Third Parties" refers to any external entities, including service providers, partners, or affiliates, that may access or process Personal Data in connection with the services provided by Rezolv.
- "Cookies" refers to small data files stored on your device when you visit a website, which may be used to remember your preferences, collect analytics, and improve your experience on the Platform.
- "Data Principal" refers to the individual to whom the Personal Data relates. In this Privacy Policy, the Data Principal is referred to as "you" or "your."
- "Data Fiduciary" means any person, including the State, a company, or any entity, who determines the purpose and means of processing Personal Data. For the purposes of this Privacy Policy, Rezolv is the Data Fiduciary.
- "Data Processor" refers to any person or entity that processes Personal Data on behalf of the Data Fiduciary.
- "Sensitive Personal Data or Information" (SPDI) refers to specific categories of personal data that are given a higher level of protection under Indian law. This includes but is not limited to passwords, financial information (such as bank account or payment instrument details), health information, biometric data, sexual orientation, and any other information as prescribed under applicable laws.
- "Anonymization" refers to the irreversible process of transforming personal data in such a manner that individuals can no longer be identified, either directly or indirectly, from the data, thereby making it impossible to trace the data back to a specific individual.
- "Pseudonymization" refers to the processing of Personal Data in such a manner that it can no longer be attributed to a specific Data Subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the Personal Data is not attributed to an identified or identifiable person.
- "Data Breach" refers to any unlawful or unauthorized access, acquisition, disclosure, alteration, loss, or destruction of Personal Data, which compromises the security, confidentiality, or integrity of such data.
- "Grievance Officer" refers to the individual designated by the Company, in compliance with Indian laws, who is responsible for addressing any concerns or complaints regarding the processing of Personal Data.
- "Third-Party Service Providers" refers to external entities that assist the Company in providing services, including but not limited to IT service providers, cloud service providers, payment processors, or marketing platforms, who may have access to Personal Data for the purpose of performing their services.
- "User Account" refers to the account created by a user on the Platform to access services, wherein certain personal information may be collected and stored for providing tailored services.
- "Profiling" refers to any form of automated processing of Personal Data intended to evaluate certain personal aspects of an individual, such as analyzing or predicting aspects concerning their economic situation, creditworthiness, behavior, interests, or location.
- "Withdrawal of Consent" refers to the right of a Data Subject to revoke their consent to the processing of their Personal Data at any time, without affecting the legality of processing based on consent prior to its withdrawal.
Types of Information Collected
Rezolv may collect the following types of information when you use our website and/or mobile application ("Platform"):
- Personal Information
Personal Information refers to any data that can identify you as an individual. The types of Personal Information we collect may include, but are not limited to:
- Contact Information: Name, email address, phone number, postal address, and other similar contact details.
- Identity Information: Date of birth, government-issued identification numbers (such as PAN, Aadhaar, or passport numbers), and any other information required for identity verification.
- Financial Information: Bank account details, credit or debit card information, loan or debt information, credit history, and other financial data necessary for providing debt recovery services.
- Communication Data: Information collected through your correspondence with us, including details of inquiries, complaints, or feedback submitted to us via the Platform or other communication channels.
- Account Information: Usernames, passwords, and any other information you provide when creating an account on the Platform.
- Transaction Data: Details of payments, recoveries, or any other transactions you perform using the Platform.
- Non-Personal Information
Non-Personal Information refers to any data that cannot be used to identify you as an individual and may include:
- Device Information: Details about the device used to access the Platform, such as hardware model, operating system, unique device identifiers, and mobile network information.
- Browser and Usage Information: Type of browser, IP address, Internet Service Provider (ISP), browsing patterns, time zone settings, and Platform usage details (e.g., time spent on the Platform, pages viewed, and navigation paths).
- Log Data: Information collected automatically each time you interact with our Platform, including server logs, error reports, and timestamps.
- Cookies and Similar Technologies: Data collected through cookies, pixels, web beacons, or other tracking technologies that enhance your browsing experience and help us analyze user behavior.
- Sensitive Personal Data or Information (SPDI)
In compliance with Indian laws, we may also collect Sensitive Personal Data or Information (SPDI), including but not limited to:
- Financial Information: Bank account details, payment instrument details, or any other payment-related data.
- Authentication Data: Passwords, security questions, and other authentication credentials.
- Biometric Data: If required by law or with your explicit consent, we may collect biometric data such as fingerprints or facial recognition data for identity verification purposes.
The collection of Sensitive Personal Data or Information is subject to specific legal and security safeguards, and we will only process such data with your consent or as required by applicable laws.
By using our Platform, you consent to the collection of the aforementioned information, which is essential for providing our services effectively and in compliance with legal obligations.
Method of Data Collection
- Rezolv collects Personal Information and Non-Personal Information through various methods to ensure efficient and effective use of our Platform and the services we provide. These methods include:
- Direct Collection
- Communication and Correspondence: Information you provide when communicating with us through customer service, submitting inquiries, participating in surveys, or providing feedback.
- Transaction Data: Information you provide when making payments, updating account information, or engaging with our debt recovery services.
- Forms and Applications: Information you provide through forms or applications available on our Platform, including those related to identity verification or debt settlement processes.
- Automated Collection
- Cookies: We use cookies and similar tracking technologies to collect data about your browsing behavior, device settings, preferences, and Platform usage patterns. This information helps us enhance user experience, personalize content, and improve the functionality of our services. You can manage your cookie preferences via browser settings or opt out where applicable.
- Web Analytics: We use analytics tools such as Google Analytics to automatically collect and analyze information about your interactions with our Platform. This may include your IP address, browser type, referral pages, time spent on pages, and other usage data. This data is anonymized and aggregated for statistical purposes.
- Log Files: Our servers automatically collect log files containing information such as your IP address, browser type, access times, pages viewed, and other diagnostic information that helps us monitor and improve the performance of our Platform.
- Device Information: We collect information about the device you use to access our Platform, including the hardware model, operating system version, and unique device identifiers. This data is used to optimize compatibility and improve service delivery.
- Third-Party Sources
- Service Providers: Information provided by third-party service providers (such as credit bureaus, debt recovery agents, or payment processors) to assist in providing our services or verifying the accuracy of your data.
- Partners and Affiliates: We may collect information from our business partners, affiliates, or other trusted entities that share data with us to help us fulfill our debt recovery services and comply with legal requirements.
Purpose of Data Collection
- Rezolv collects and processes Personal and Non-Personal Information for specific, legitimate purposes in connection with the services we offer through our Platform. The purposes for which we collect your data include, but are not limited to, the following:
- For Debt Recovery and Related Services
- Verification of Identity: Ensuring that the data provided by you is accurate and up-todate, and verifying your identity for the purposes of initiating the debt recovery process.
- Debt Collection Activities: Engaging in communications, negotiations, and transactions related to the recovery of outstanding debts. This may include reaching out via various communication channels, processing payments, and maintaining records of the debt recovery process.
- Reporting and Record-Keeping: Maintaining records of interactions, transactions, and recoveries for future reference, audits, or legal requirements.
- Compliance with Legal Obligations
- Regulatory Compliance: Ensuring that our debt recovery practices adhere to relevant legal and regulatory requirements, such as the Information Technology Act, 2000, and any rules or guidelines issued by regulatory authorities.
- Fraud Prevention and Risk Management: Detecting and preventing fraud, unauthorized transactions, and other illegal activities that may compromise the integrity of our services or data.
- Customer Support
- Responding to Inquiries and Complaints: Addressing any questions, concerns, or complaints you may have regarding our services, and providing timely responses to resolve issues.
- User Account Management: Assisting with the creation, updating, and management of your user account, including password resets, account settings, and other related functions.
- Assisting with Transactions: Helping you with payments, refunds, and any other transaction-related support you may require during your use of the Platform.
- Improvement of Services and Website/Application
- Enhancing User Experience: Using your feedback and behavioural data to optimize the performance, design, and functionality of our Platform, ensuring a better user experience.
- Platform Maintenance and Development: Monitoring usage patterns, diagnosing technical issues, and implementing upgrades to improve the stability, security, and performance of our Platform.
- Personalized Services: Using cookies and tracking technologies to tailor content and offers based on your preferences, past interactions, and behavior on the Platform.
- Research and Analytics: Analyzing trends, usage data, and feedback to gain insights into user needs, preferences, and satisfaction levels, which helps us improve our services and identify new offerings.
Legal Basis for Processing Personal Data
Rezolv processes Personal Data in accordance with applicable laws and only when we have a lawful basis for doing so. The legal bases for processing your Personal Data include, but are not limited to, the following:
- Consent of the Data Subject
We process your Personal Data based on your explicit and informed consent in the following circumstances:
- Marketing and Promotional Activities: When you agree to receive marketing communications, newsletters, or other promotional content, we process your data based on your consent.
- Optional Data Processing: When we collect data that is not strictly necessary for the provision of our services (such as certain types of cookies or analytics data), we seek your consent to process such information.
You may withdraw your consent at any time by contacting us or following the opt-out mechanisms provided in the communication, without affecting the legality of processing based on consent before its withdrawal.
- Performance of a Contract
We process your Personal Data when it is necessary to fulfill our contractual obligations with you. This includes:
- Provision of Debt Recovery Services: Processing your Personal Data to perform debt recovery services as part of our agreement with you or with third parties (such as creditors or financial institutions) on your behalf.
- User Account Management: Collecting and processing data for the creation, management, and maintenance of your user account, including authentication and security measures.
- Transaction Processing: Using your financial information to process payments, refunds, and related transactions associated with the services we provide.
If you do not provide the necessary data for the performance of a contract, we may be unable to fulfill our contractual obligations.
- Compliance with Legal Obligations
Rezolv may process your Personal Data when it is necessary to comply with our legal obligations under applicable laws and regulations. This includes:
- Regulatory Compliance: Ensuring compliance with Indian data protection laws, tax laws, anti-money laundering regulations, and other legal requirements that govern debt recovery activities.
- Legal Disclosures: Disclosing data to regulatory authorities, law enforcement agencies, courts, or other governmental entities when required by law, such as in response to subpoenas, court orders, or government investigations.
- Record Retention: Retaining data as required by law for auditing, reporting, or other compliance purposes.
- Legitimate Interests
We may process your Personal Data based on our legitimate business interests, provided that such processing does not override your fundamental rights and freedoms. Legitimate interests include:
- Service Improvement: Using your data to improve and personalize the services we offer, including enhancing the functionality, security, and performance of our Platform.
- Fraud Prevention and Security: Processing data to detect and prevent fraud, unauthorized activities, or security breaches that may compromise our services, data, or users.
- Legal Defence and Risk Management: Processing data in connection with potential legal claims, compliance audits, or risk assessments to protect our interests, as well as those of our clients and partners.
- Business Operations: Using data for general business operations, including conducting research and analysis to better understand user needs, developing new products, and growing our business.
In all instances, we will ensure that the processing of Personal Data is carried out in a fair, transparent, and lawful manner, in compliance with applicable Indian data protection regulations. If you have any questions about the legal basis for processing your Personal Data, you can contact us for further clarification.
Use of Cookies and Tracking Technologies
- Rezolv uses cookies and similar tracking technologies to enhance your experience on our website and/or mobile application ("Platform"). This section explains the types of cookies we use, how we use them, and your choices regarding their use.
- Types of Cookies Used
- Functional Cookies: These cookies are essential for the proper functioning of the Platform. They enable core features such as secure logins, session management, and user preferences. Without these cookies, certain features of the Platform may not work correctly.
- Analytics Cookies: These cookies help us understand how users interact with the Platform by collecting information about usage patterns, such as pages visited, time spent on the Platform, and any errors encountered. This information is anonymized and used to improve the functionality and performance of our services. For example, we may use Google Analytics to gather and analyze usage data.
- Performance Cookies: These cookies collect information about how the Platform performs, including the speed of page loading and any performance issues. The data collected is used to monitor and improve the Platform’s efficiency and user experience.
- Advertising and Targeting Cookies: These cookies may be used to deliver personalized advertisements based on your browsing habits and interests. They help us understand your preferences and provide content that is relevant to you. We may also use these cookies to limit the number of times you see an ad and to measure the effectiveness of advertising campaigns.
- Third-Party Cookies: In some cases, third-party service providers (such as social media platforms or advertising networks) may place cookies on your device when you interact with certain features of our Platform. These cookies are subject to the privacy policies of the respective third parties.
- How We Use Cookies
- To remember your preferences and settings (e.g., language, region) during your visits to the Platform.
- To authenticate users and prevent unauthorized access to secure areas of the Platform.
- To track and analyse usage data, helping us understand how users navigate through the Platform and identify areas for improvement.
- To deliver personalized content and advertisements based on your interests and online behavior.
- To manage and improve the security and performance of our Platform.
Data Sharing and Disclosure
- Rezolv is committed to safeguarding your Personal Data and ensuring that it is shared only under appropriate circumstances. This section outlines the situations in which we may share or disclose your data, and the safeguards we employ to protect your privacy.
- With Third-Party Service Providers
- Payment Processors: Entities that handle payment processing, including financial institutions and payment gateways.
- Technology Providers: Providers of IT infrastructure, cloud storage, data analytics, and technical support that help us maintain and improve our Platform.
- Debt Collection Agents: External agents or companies that assist in the recovery of debts.
- Verification and Authentication Services: Providers who assist in identity verification and fraud prevention.
- With Regulatory Authorities
- Compliance with Legal Requirements: We may disclose your data to comply with applicable laws, regulations, or legal processes, such as responding to court orders, subpoenas, or requests from government authorities.
- Regulatory Reporting: In cases where we are legally required to report certain activities, such as debt recovery transactions, to government or regulatory bodies.
- Public Safety and Risk Prevention: When necessary, we may share your data to protect public safety, prevent fraud, or mitigate security risks.
- In Case of Business Transfers
- Mergers and Acquisitions: If Rezolv is acquired by or merges with another company, your data may be transferred to the acquiring entity as part of the business transaction.
- Asset Transfers: In the case of the sale, liquidation, or transfer of some or all our assets, your data may be included as part of the transferred assets.
- Business Reorganization: If we undergo any form of restructuring, your data may be shared with the relevant entities to ensure continuity of service.
- For Legal Compliance
- Legal defence: To defend or enforce our legal rights in the event of legal disputes, including disputes relating to debt recovery.
- Fraud and Security Monitoring: To detect, prevent, or respond to fraud, unauthorized access, or other illegal activities.
- Protection of Others: To protect the rights, property, or safety of our users, employees, or the public.
Data Security Measures
- Rezolv is committed to ensuring the security and confidentiality of your Personal Data. We implement a variety of technical, administrative, and organizational measures to protect your data from unauthorized access, disclosure, alteration, or destruction. The following outlines our key data security measures:
- Encryption, Firewalls, and Other Security Measures
- Data Encryption: We use encryption protocols (such as SSL/TLS) to protect your Personal Data during transmission over the internet. This ensures that sensitive information such as financial data and login credentials are securely transmitted between your device and our Platform.
- Firewalls: Our systems are protected by firewalls that help prevent unauthorized access to our networks and servers. Firewalls act as a barrier between trusted internal networks and untrusted external sources, ensuring that only authorized traffic is allowed.
- Access Controls: We limit access to Personal Data to authorized personnel who require such access for the performance of their duties. Access controls, such as multi-factor authentication (MFA) and role-based access control (RBAC), are in place to ensure that only authorized individuals can access sensitive data.
- Data Masking and Anonymization: Where possible, we use techniques such as data masking or anonymization to further protect sensitive information, especially when handling or storing data that is not required to identify specific individuals.
- Regular Security Audits and Vulnerability Testing: We conduct regular security audits, vulnerability assessments, and penetration testing to identify and address any potential security risks or vulnerabilities in our systems and infrastructure.
- Monitoring and Incident Response: Our systems are continuously monitored for unusual or unauthorized activity. In the event of a security breach or data incident, we have an incident response plan in place to quickly contain and mitigate any damage.
- ISO 27001 or Other Certifications
- ISO 27001 Certification: We are certified under the ISO 27001 standard, which demonstrates our adherence to international best practices for information security management. This certification requires us to implement and maintain rigorous security controls to protect the confidentiality, integrity, and availability of Personal Data.
- Compliance with Industry Standards: In addition to ISO 27001, we adhere to other relevant security standards and frameworks applicable to the financial and data processing industries. This includes compliance with regulatory security guidelines set forth by Indian authorities, such as the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
- Periodic Security Audits: Our security practices are regularly audited by external auditors to ensure that we maintain compliance with applicable laws, certifications, and internal policies. These audits help us identify potential areas for improvement and ensure continuous enhancement of our security measures.
Data Retention Policy
- Rezolv is committed to retaining Personal Data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws and regulations. This section outlines our data retention practices and the criteria we use to determine how long your data will be stored.
- Duration for Which Personal Data Will Be Retained
- Service-Related Data: We retain your Personal Data for the duration of your relationship with us, including the period during which we provide debt recovery services and any post-service interactions. Once the relationship has ended or the services have been completed, we may retain your data for a specified period to comply with legal and regulatory obligations, resolve disputes, and enforce agreements.
- Financial Data: Personal financial information, including payment and transaction data, is retained for as long as necessary to comply with financial reporting, auditing, and taxation requirements under applicable laws.
- Communication Data: We retain records of your communications with us, including emails, phone calls, or other forms of correspondence, for as long as needed to resolve your inquiries, maintain customer support records, and comply with legal obligations.
- Anonymized or Aggregated Data: In some cases, we may anonymize your Personal Data so that it can no longer identify you. This anonymized data may be retained indefinitely for analytical purposes, research, or to improve our services.
- Criteria for Determining Retention Periods
- Legal and Regulatory Requirements: We are obligated to retain certain types of data to comply with applicable laws, including tax, anti-money laundering (AML), and financial regulations. Data retention periods may vary depending on the jurisdiction and specific regulatory requirements.
- Contractual Obligations: Data necessary for the performance of a contract, including debt recovery agreements, will be retained for the duration of the contract and as required for post-contractual obligations, such as dispute resolution or contract enforcement.
- Business Needs: Personal Data may be retained for as long as necessary to meet our legitimate business interests, such as fraud prevention, maintaining accurate business records, and defending or enforcing legal claims.
- User Requests: If you request the deletion or anonymization of your Personal Data, we will assess whether we are required to retain the data by law or for legitimate business purposes. Where no such requirement exists, we will delete or anonymize your data as requested.
- Data Minimization: We follow the principle of data minimization, ensuring that we only retain the minimum amount of Personal Data necessary to achieve the purposes outlined in this Privacy Policy.
Changes to the Privacy Policy
- Rezolv reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or service offerings.
- Continued Use of the Platform: By continuing to use our Platform after any changes to this Privacy Policy become effective, you are deemed to have accepted the revised terms. If you do not agree with the updated policy, you must discontinue your use of the Platform and may contact us for further clarification or assistance.
- Rezolv reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or service offerings.
Grievance Redressal Mechanism
- We take your privacy and concerns seriously and have implemented a Grievance Redressal Mechanism to address any issues related to the collection, use, or protection of your Personal Data.
- Grievance Officer: In compliance with applicable Indian laws, we have appointed a Grievance Officer to handle your concerns and complaints regarding data privacy.
- Grievance Officer: Anil Chatla
- Email: anil.chatla@rezolv.com
- Phone: 9029693406
- Address: Unit #214, D-Wing, Kanakia Zillion, Kurla West, Kurla, Mumbai, Maharashtra 400070
- Process for Raising Concerns or Complaints:
- If you have any concerns or complaints regarding the processing of your Personal Data or believe that your privacy rights have been violated, you may contact the Grievance Officer.
- You may submit your complaint in writing, via email, or through any other form of communication provided in the contact details above.
- Upon receiving your complaint, the Grievance Officer will acknowledge receipt and investigate the matter. You will receive a response within a reasonable timeframe, typically no later than 30 days from the receipt of your complaint.
- If you are not satisfied with the resolution provided by the Grievance Officer, you have the right to escalate the matter to the relevant data protection authorities as applicable under Indian law.
- Process for Raising Concerns or Complaints:
Applicable Laws and Jurisdiction
- This Privacy Policy is governed by and construed in accordance with the laws of India.
- In the event of any disputes arising from or relating to this Privacy Policy, the courts of Mumbai, Maharashtra shall have exclusive jurisdiction, subject to any applicable dispute resolution mechanisms agreed upon by the parties.
- By using our Platform, you acknowledge that any legal disputes concerning your data and privacy will be governed by Indian law, and you agree to submit to the jurisdiction of the courts of India for resolution of such matters.