ClearDu Privacy Policy

1. Introduction & Enterprise Scope

ClearDu Fintech Private Limited (CIN: U74999GJ2022PTC129797), headquartered in Ahmedabad, Gujarat, India (“ClearDu”, “we”, “us”, or “our”), is committed to safeguarding the privacy, confidentiality, and integrity of personal data entrusted to us by our institutional banking partners, NBFC clients, enterprise users, and individual data principals.

This Privacy Policy outlines how ClearDu collects, stores, processes, transfers, and protects information across our proprietary FinTech software platforms (including Collexifi, Notifi X, SARFAESI 360, and Voicebot AI) in strict compliance with the Digital Personal Data Protection (DPDP) Act 2023, Information Technology Act, 2000, and the Reserve Bank of India (RBI) Fair Practices Code.

2. Categories of Information We Process

In our capacity as a data processor for licensed financial institutions and a data fiduciary for direct inquiries, we process:

• Institutional Contact Information: Name, professional email address, corporate phone number, organization name, designation, and billing details provided during enterprise engagement or demonstration requests.
• Loan Account Delinquency Telemetry: Account identifiers, outstanding dues, delinquency aging (DPD brackets), loan portfolio classification, notice dispatch history, and borrower communication logs provided by originating lenders under lawful collection mandates.
• Technical & System Telemetry: IP addresses, browser specifications, access timestamps, API authentication headers, and audit trails logged during platform usage.

3. Purpose of Processing & Legal Grounds

We process personal and institutional data strictly for lawful purposes directly related to our services, including:

• Delivering automated multi-channel loan recovery notices, digital conciliation reminders, and Lok Adalat pre-litigation notices via Speed Post and digital channels.
• Providing real-time portfolio health dashboards, SARFAESI Section 13/14 tracking, and advocate liaison workflows.
• Fulfilling statutory compliance reporting required by Indian judicial authorities, the Reserve Bank of India, and MeitY directives.
• Preventing financial fraud, unauthorized platform access, and security breaches.

4. Data Storage, Sovereignty & Retention

All sensitive information is processed with end-to-end encryption. In adherence to Indian data sovereignty norms, no customer or borrower records are exported to foreign jurisdictions without explicit statutory authorization. Data is retained strictly for the duration specified in institutional Master Service Agreements (MSAs) or as mandated by applicable statutory limitation periods.

5. Third-Party Integrations & Disclosures

ClearDu does not sell, rent, or commercialize data to advertising networks. Data is shared exclusively with:

• India Post Speed Post APIs: For physical dispatch of legal notices under Section 138 NI Act and SARFAESI Act with real-time barcode tracking.
• Licensed Telecom & SMS Gateways: For sending multi-lingual DLT-approved transactional SMS, WhatsApp updates, and voice nudges.
• Law Enforcement & Regulators: When strictly required by court orders, statutory tribunals, or lawful directives.

6. Rights of Data Principals & Grievance Redressal

Under the DPDP Act 2023, data principals hold rights to request access, correction, and grievance resolution regarding their processed data. For inquiries or concerns, please contact our dedicated Data Protection & Grievance Redressal Officer: