Data Protection / DPDP Notice
Statutory notice issued pursuant to Section 5 of the Digital Personal Data Protection Act, 2023 (Act No. 22 of 2023) regarding the processing of borrower digital personal data.
This Notice is provided to you by Loan Resolution India in compliance with Section 5 of the Digital Personal Data Protection Act, 2023. It explains the specific personal data we collect from you, the precise purpose for which it is processed, how you may exercise your statutory rights as a Data Principal, and how you may lodge complaints with our Grievance Officer or the Data Protection Board of India.
1. Identification of the Data Fiduciary
Under the DPDP Act 2023, Loan Resolution India is designated as the Data Fiduciary responsible for determining the purpose and means of processing your personal data:
2. Categories of Digital Personal Data Processed
We process only those categories of personal data strictly necessary for debt evaluation, creditor containment, and settlement negotiation:
- Identity & Contact Credentials: Name, mobile phone number, email address, residential address, PAN number, and masked Aadhaar (last 4 digits only).
- Financial Liability & Credit History: Creditor bank names, loan account numbers, sanctioned loan amounts, default dates, interest components, and Credit Information Reports (CIBIL/Experian).
- Legal & Statutory Notices: Demand notices under Section 13(2) SARFAESI Act, possession notices under Section 13(4), Section 14 DM/CMM orders, DRT summons, and Section 138 NI Act notices.
- Evidence of Harassment: Time-stamped audio recordings of recovery agent conversations, SMS/WhatsApp communications, and home visit logs.
- Income & Cash Flow Records: Bank statements, salary slips, and income tax declarations shared voluntarily to justify financial hardship during compromise settlement requests.
3. Specified Lawful Purposes of Processing
In adherence to the principle of Purpose Limitation under Section 4 of the DPDP Act 2023, your personal data will be processed exclusively for:
- Analyzing default liabilities and formulating realistic One-Time Settlement (OTS) compromise structures.
- Drafting and dispatching formal anti-harassment containment notices to creditor recovery desks citing RBI Fair Practices Codes.
- Facilitating engagement with empanelled advocates to draft formal representations under Section 13(3A) of the SARFAESI Act or Securitisation Applications under Section 17 before the DRT.
- Processing the ₹499 Borrower Protection Membership fee via Razorpay and delivering payment receipts.
- Assisting with formal complaints to the Reserve Bank of India (RBI) Integrated Ombudsman Scheme.
4. Consent Architecture & Right of Withdrawal
In strict conformity with Section 6 of the DPDP Act 2023:
- Granular & Explicit Consent: Your consent is obtained through an unambiguous affirmative action (such as ticking the consent checkbox on our consultation and membership forms).
- Plain Language Notice: Our consent requests are presented in clear, accessible language, accompanied by direct access to this statutory notice.
- Right to Withdraw Consent: You have the absolute right under Section 6(4) to withdraw your consent at any time with the same ease with which it was given. To withdraw consent, email
grievance@legalloanresolutionindia.com. - Consequence of Withdrawal: Upon receipt of consent withdrawal, we will cease processing your personal data, except where retention is mandated by law (e.g. GST tax invoices). Please note that withdrawing consent will necessitate discontinuation of active debt negotiation and advocate coordination services.
5. Rights of Data Principals under DPDP Act 2023
As a Data Principal, you are entitled to exercise the following statutory rights:
| Statutory Right | DPDP Act Section | Scope & Procedure |
|---|---|---|
| Right to Access Information | Section 11 | Obtain a summary of all personal data being processed and identities of empanelled advocates or processors with whom it was shared. |
| Right to Correction & Erasure | Section 12 | Request correction of inaccurate/outdated debt balances or deletion of personal data upon completion of debt resolution. |
| Right of Grievance Redressal | Section 13 | Demand time-bound redressal from our Grievance Officer within 15 calendar days before escalating to the Data Protection Board of India. |
| Right to Nominate | Section 14 | Designate an authorized representative to exercise data rights in the event of death or permanent incapacity. |
6. Right to Nominate an Individual (Section 14)
In accordance with Section 14 of the DPDP Act 2023, every borrower enrolled in our resolution programs has the right to nominate an individual (spouse, child, legal heir, or trusted representative) who shall be authorized to exercise their data rights in the event of the borrower's death or physical/mental incapacity. You may file or update your nomination by writing to our compliance desk with proof of identity of the nominee.
7. Reasonable Security Safeguards (Section 8(5))
To prevent personal data breaches, unauthorized disclosure, or data loss, Loan Resolution India implements reasonable security practices pursuant to Section 8(5) of the DPDP Act:
- Cryptographic Controls: AES-256 encryption applied to all stored financial schedules and bank statements; TLS 1.3 transport encryption across web endpoints.
- Strict Role-Based Access: Access to borrower liability files is strictly restricted to assigned senior resolution managers and counsel holding client authorization.
- Indian Data Localization: All core databases and electronic records are hosted in sovereign data centers within the Republic of India.
8. Processing of Data of Children & Vulnerable Persons
Pursuant to Section 9 of the DPDP Act 2023:
- Loan Resolution India does not knowingly solicit or process the personal data of any child (defined under the Act as an individual who has not completed eighteen years of age).
- We do not undertake tracking, behavioral monitoring, or targeted advertising directed at minors.
9. Personal Data Breach Intimation (Section 8(6))
In the event of an identified personal data breach, Loan Resolution India will, without undue delay, notify:
- The Data Protection Board of India in the form, manner, and timeline prescribed under DPDP Rules; and
- Each affected Data Principal via their registered electronic communication channel (email/SMS).
10. Data Protection Officer & Board Escalation
For any queries regarding this Statutory DPDP Notice, or to submit a formal Data Principal Rights Request, please contact:
If your grievance is not redressed within thirty (30) days of submission, or if you are dissatisfied with our resolution, you reserve the statutory right under the DPDP Act 2023 to register a complaint with the Data Protection Board of India.