Privacy Policy
Platform Name: RinSetu
Operated by: Archway Commercial Solutions Private Limited
CIN: U67100WB2022PTC254888
Effective Date: January 1, 2025
Last Updated: March 2025
Version: 2.0
1. Introduction
Archway Commercial Solutions Private Limited ("Company", "we", "us", "our"), operating under the brand name RinSetu, respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, share, and protect your information when you access or use the RinSetu platform ("Platform"), including our website at rinsetu.online and the RinSetu mobile application.
This Policy is published in accordance with the provisions of the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules"), and other applicable laws and regulations in India, including guidelines issued by the Reserve Bank of India (RBI) applicable to Lending Service Providers (LSPs).
By using the Platform, you consent to the collection and use of your information as described in this Privacy Policy. If you do not agree with any part of this Policy, please discontinue use of the Platform.
2. About Our Role
RinSetu operates as a Lending Service Provider (LSP). We facilitate credit services between our partner Regulated Entity (RE) and eligible borrowers. Our lending partner is:
Blue Jay Finlease Private Limited
CIN: U65910DL1996PTC083130
Operating as: ZipLoan
RBI Registered Non-Banking Financial Company (NBFC)
Registered Office: Flat No. 608, 5th Floor, Kailash Building, 26 K.G. Marg, New Delhi – 110001
Certain personal data collected through this Platform is shared with Blue Jay Finlease Private Limited (ZipLoan) for the purposes of credit assessment, loan sanctioning, disbursal, and account management. Both entities are independently responsible for compliance with applicable data protection regulations in respect of the data they process.
3. Information We Collect
We collect only such information as is necessary to provide our services and fulfill our regulatory obligations. The categories of information we collect are as follows:
3.1 Personal Information
- Full name
- Date of birth
- Gender
- Photograph
- Contact details (mobile number, email address, residential address)
3.2 Identity Documents
- PAN Card number and copy
- Aadhaar number and copy (as per UIDAI guidelines)
- Voter ID or Driving Licence (optional, for additional KYC)
3.3 Financial Information
- Bank account details (account number, IFSC code)
- Bank statements (up to 12 months)
- Income and cash flow details
- GST registration and returns (if applicable)
- Credit bureau scores and reports (CIBIL, Experian, CRIF, Equifax)
3.4 Business Information
- Business name and type (proprietorship, partnership, etc.)
- Business address and place of operations
- Shop & Establishment licence or equivalent registration
- Business vintage and operational history
- Daily / monthly turnover and revenue details
3.5 Device and Technical Information
- Device type, model, and unique device identifiers
- Operating system and browser type
- IP address and network information
- Approximate location data (collected only with your explicit consent)
- App usage patterns and interaction data
4. How We Use Your Information
4.1 Primary Purposes
We use the information collected for the following primary purposes:
- Processing and evaluating your loan application
- Verifying your identity, address, and business details (KYC)
- Assessing your creditworthiness in collaboration with our lending partner
- Facilitating loan disbursal to your registered bank account
- Collecting repayments and managing your loan account
- Providing customer support and resolving grievances
- Communicating loan offers, account updates, payment reminders, and important notices
4.2 Secondary Purposes
We may also use your information for the following secondary purposes:
- Improving, enhancing, and personalising our Platform and services
- Developing new products and features suited to micro-merchant needs
- Detecting, preventing, and investigating fraud and unauthorised activity
- Complying with applicable legal, regulatory, and audit requirements
- Conducting internal analytics, research, and risk management
5. Legal Basis for Processing
We process your personal data on the following legal bases:
- Consent: Where you have provided explicit, informed consent for a specific purpose (e.g., accessing your location or device data)
- Contractual Necessity: Where processing is necessary to perform our obligations under the loan facilitation agreement with you
- Legal Obligation: Where processing is required to comply with applicable laws, RBI regulations, PMLA obligations, or court orders
- Legitimate Business Interests: Where processing is necessary for fraud prevention, risk management, and service improvement, provided such interests are not overridden by your rights
- Protection of Vital Interests: Where processing is necessary to protect the vital interests of any person
6. Data Sharing
6.1 Sharing With Your Consent
With your explicit consent, we may share your data with:
- Blue Jay Finlease Private Limited (ZipLoan): Our partner NBFC, for credit assessment, loan sanctioning, disbursal, and account management
- Credit Bureaus: CIBIL, Experian, CRIF High Mark, and Equifax, for credit score enquiries and reporting
- Payment Gateways and Banks: For processing disbursals, repayments, and UPI Autopay mandates
6.2 Sharing Without Consent (Mandatory Disclosures)
We may be required to share your data without consent in the following circumstances:
- With the Reserve Bank of India (RBI), SEBI, income tax authorities, or other regulators in discharge of statutory obligations
- With law enforcement agencies upon receipt of a valid court order, summons, or legal process
- With courts, tribunals, or arbitral panels in connection with any legal proceedings
6.3 Third-Party Service Providers
We engage certain third-party service providers who process data on our behalf under strict contractual obligations of confidentiality. These include:
- Cloud hosting and data storage providers (India-based)
- KYC verification and e-sign service providers (licensed by UIDAI / MeitY)
- Communication service providers (SMS, email, push notifications)
- Analytics and fraud detection service providers
We do not sell, rent, or trade your personal data to any third party for marketing or commercial purposes.
7. Data Storage and Security
7.1 Storage Location
All personal data collected through the Platform is stored exclusively on India-based servers located in Mumbai and Chennai data centres, in compliance with applicable data localisation requirements.
7.2 Security Measures
We implement industry-standard technical and organisational security measures to protect your data, including:
- 256-bit SSL/TLS encryption for all data in transit
- AES-256 encryption for data at rest
- Multi-factor authentication (MFA) for system access
- Role-based access controls (RBAC) limiting data access to authorised personnel only
- Regular security audits and vulnerability assessments
- ISO 27001 certified infrastructure
Notwithstanding the above, no method of electronic transmission or storage is completely secure. While we strive to protect your personal data, we cannot guarantee absolute security.
7.3 Data Retention
We retain your personal data for the following periods:
| Category | Retention Period |
|---|---|
| Active loan account data | Duration of the loan + 7 years |
| Rejected or declined applications | 2 years from the date of rejection |
| Marketing and communication data | Until consent is withdrawn |
| Legal hold data | As required by applicable law or court order |
7.4 Data Destruction
Upon expiry of the applicable retention period, personal data is securely destroyed as follows:
- Digital files: Electronic shredding using certified data destruction methods
- Physical documents: Physical destruction by authorised personnel
- A certificate of destruction is maintained for audit purposes
8. Your Rights
As a user of the Platform, you have the following rights with respect to your personal data:
8.1 Right to Access
You may request a copy of all personal data we hold about you. We will respond to such requests within 30 days.
8.2 Right to Correction
You may update or correct any inaccurate or incomplete personal information through the RinSetu app or by contacting our support team.
8.3 Right to Erasure
You may request deletion of your personal data. Please note that erasure requests may be limited where:
- You have an active loan obligation with Blue Jay Finlease Private Limited (ZipLoan)
- Applicable law or regulation requires us to retain the data
- The data is subject to a legal hold or court order
8.4 Right to Data Portability
You may request your personal data in a structured, commonly used, and machine-readable format for transfer to another service provider.
8.5 Right to Withdraw Consent
You may withdraw your consent for non-essential data processing (such as marketing communications or location tracking) at any time. Withdrawal of consent will not affect the lawfulness of processing carried out prior to withdrawal.
To exercise any of the above rights, please contact us at support@rinsetu.online or write to our Grievance Officer at nodal@rinsetu.online.
9. Cookies and Tracking Technologies
Our Platform uses the following types of cookies and tracking technologies:
- Essential Cookies: Required for the basic functionality of the app and website, including session management and security
- Analytics Cookies: Used to understand how users interact with the Platform, helping us improve user experience
- Marketing Cookies: Used to deliver personalised communications and relevant offers
You may manage cookie preferences through your device or browser settings. Disabling essential cookies may affect the functionality of the Platform.
10. Children's Privacy
Our services are intended solely for individuals who are 18 years of age or older. We do not knowingly collect, store, or process personal data of any person under 18 years of age. If we become aware that we have inadvertently collected data from a minor, we will take immediate steps to delete such data.
11. Data Breach Notification
In the event of a personal data breach, we will:
- Notify affected users within 72 hours of becoming aware of the breach, wherever feasible
- The notification will include the nature of the breach, the categories of data affected, and the remedial steps being taken
- Report the breach to the relevant regulatory authorities as required under applicable law
12. Cross-Border Data Transfers
We do not transfer your personal data outside the territory of India, except:
- Where you have provided explicit consent for such transfer
- Where the transfer is necessary for regulatory compliance or legal proceedings
- Where adequate data protection measures are in place in the recipient country, as assessed by us
13. Changes to This Privacy Policy
We reserve the right to update or revise this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or for any other reason. When material changes are made, we will notify you through one or more of the following:
- Email notification to your registered email address
- In-app notification on the RinSetu app
- A prominent notice on our website at rinsetu.online
Your continued use of the Platform after the effective date of the revised Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically.
14. Grievance Redressal
If you have any concerns, complaints, or queries regarding our privacy practices or the handling of your personal data, you may contact us through the following escalation levels:
Level 1 - Customer Support
Email: support@rinsetu.online
Expected Resolution Time: Within 24 business hours
Level 2 - Grievance / Nodal Officer (Archway Commercial Solutions Private Limited)
Name: Nishikanta Das
Email: nodal@rinsetu.online
Expected Resolution Time: Within 7 working days of receipt
Level 3 - RBI Ombudsman
If your grievance remains unresolved within 30 days:
Website: https://cms.rbi.org.in
Toll-Free: 14448
Level 4 - Data Protection Board of India
Once constituted and operational under the Digital Personal Data Protection Act, 2023 (DPDPA), you may also approach the Data Protection Board of India for complaints related to personal data processing.
15. Contact Information
Archway Commercial Solutions Private Limited (RinSetu)
- CIN: U67100WB2022PTC254888
- Registered Office: Room No. 1308, 13th Floor, Todi Mansion, 1 Lushun Sarani, Tiretta Bazar, Kolkata – 700073, West Bengal
- Customer Support: support@rinsetu.online
- Grievance / Nodal Officer: Nishikanta Das | nodal@rinsetu.online
- Platform: rinsetu.online
Blue Jay Finlease Private Limited (ZipLoan)
- CIN: U65910DL1996PTC083130
- Registered Office: Flat No. 608, 5th Floor, Kailash Building, 26 K.G. Marg, New Delhi – 110001
- Customer Care: customer.care@ziploan.com | 011-4310 9577 (Mon–Fri, 9:30 AM – 6:00 PM)
- Nodal Officer: nodal.officer@ziploan.com | 9818128000
- Website: https://ziploan.in
Last Updated: March 2025 | Version 2.0 © 2025 Archway Commercial Solutions Private Limited. All rights reserved.