Privacy Policy

1. Who we are

My EMI is operated by Insur Lender Dynamics LLP ("My EMI", "we", "us" or "our"), 1st Floor, Urban Vault 19, 18th Cross Rd, Sector 6, HSR Layout, Bengaluru, Karnataka 560102.

We are the lending service provider for our lending partner, Sukhchain Hire Purchase Private Limited, a non-banking financial company (NBFC) registered with the Reserve Bank of India (the "Lending Partner"). The Lending Partner sanctions and disburses loans. We run the My EMI app and the customer experience.

2. What this policy covers

This policy explains how we handle your personal data when you use the My EMI app and this website (myemipay.com): what we collect, why we collect it, who we share it with, how long we keep it, and the choices and rights you have.

3. Information we collect

When you sign up, complete verification and take a loan, we collect:

• Identity and contact details: your name, mobile number, email address and date of birth.
• KYC details: your PAN; your Aadhaar details, obtained through DigiLocker with your consent; and a selfie or liveness photo to confirm that it's you.
• Address: your address.
• Employment and income: details of your employment and income.
• Bank account: your bank account details, which we verify with a small test credit.
• Credit report: with your consent, your credit report from credit information companies registered with the RBI.
• Loan records: your loan, repayment and communication records.
• Device and app information: information about your device and the app, which we use for security and fraud prevention.

At disbursement, you also complete a video KYC with the Lending Partner and, with your permission, we use your location to confirm your current address.

4. Phone permissions

We do not access your contacts, photo gallery or files, call logs or SMS.

We use your phone's camera, microphone and location only when they are needed for KYC or verification, such as your selfie, the video KYC and confirming your current address, and only after you give explicit permission. You can turn these permissions off in your phone's settings, but some verification steps may then not be possible.

5. How we use your information

We use your personal data to:

• create and manage your account;
• verify your identity and your bank account (KYC);
• assess your application, including a credit check with your consent, and pass it to the Lending Partner for its decision;
• show you the Key Facts Statement, arrange the e-signing of your loan agreement, and enable the Lending Partner to disburse the loan to your verified bank account;
• set up and collect repayments by auto-debit mandate or payment link;
• send you messages about your account, applications and loans, and answer your questions and complaints;
• keep the Service secure and prevent fraud; and
• meet our legal and regulatory obligations.

6. Who we share it with

We share your personal data only with:

• our Lending Partner, which sanctions and disburses your loan;
• credit information companies registered with the RBI, for credit checks;
• service providers that help us with KYC, e-sign, payments, messaging and hosting, for those purposes only; and
• authorities, such as regulators, courts or law enforcement agencies, where the law requires it.

We do not sell your personal data.

7. Where your data is stored

We store the personal data we collect through the My EMI app and during your loan on servers located in India.

8. How long we keep it

We keep your personal data for as long as we need it for your account and loan, and after that for as long as the law requires, for example under the record-keeping rules of the Reserve Bank of India and the Prevention of Money-laundering Act, 2002 (PMLA). When we no longer need it for these purposes, we erase it.

9. Keeping your data secure

We take reasonable security safeguards to protect your personal data against unauthorised access, use, disclosure and loss.

10. Your consent and withdrawing it

We ask for your consent in the app before we obtain your Aadhaar details through DigiLocker, before a credit check, and before using your camera, microphone or location.

You can withdraw your consent at any time by emailing support@myemipay.com. Withdrawal applies from then on; it does not affect anything done before you withdrew.

If you have an active loan: withdrawing consent does not cancel the loan or your obligation to repay it. We and the Lending Partner will continue to keep and use the data needed to service and collect the loan and to meet legal requirements. If you withdraw consent that is needed for verification or a credit check, we may not be able to process a new application.

11. Your rights

Under India's Digital Personal Data Protection Act, 2023, you have the right to:

• Access: ask for a summary of the personal data we hold about you, how we use it, and who we have shared it with.
• Correction and erasure: ask us to correct, complete or update your personal data, or to erase it. We may have to keep some data while a loan is active or where the law requires.
• Grievance redressal: complain to us about how we handle your personal data and get a response.
• Nomination: nominate someone to exercise these rights on your behalf if you die or become unable to do so.

To use any of these rights, email support@myemipay.com. We may need to confirm your identity before we act on a request. For privacy complaints, see Contact and complaints below.

12. This website

This website gives information about My EMI. It:

• does not use cookies, analytics or advertising trackers;
• has no forms, so it does not ask you for personal data;
• loads its typeface from Google Fonts, so your browser connects to Google's servers, which receive your IP address and browser details; and
• is served by a hosting provider that keeps standard technical logs, such as IP addresses and browser type, for security.

13. Changes to this policy

We may update this policy. We will post the new version on this page with a new "Last updated" date and, if the changes are significant, tell you in the app or by email.

14. Contact and complaints

Questions, requests and privacy complaints: support@myemipay.com. We acknowledge complaints within 24 hours and aim to resolve them within 30 days. If you are not satisfied, you can escalate to our Grievance Redressal Officer; see Grievance Redressal.

By post: Insur Lender Dynamics LLP, 1st Floor, Urban Vault 19, 18th Cross Rd, Sector 6, HSR Layout, Bengaluru, Karnataka 560102.