Privacy Policy

1. Introduction

CodeWint Technologies ("we", "us", "our") provides EMILockerAdmin, a white-label EMI management software product. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal data when we provide the software and related services.

2. Scope and Business Model

EMILockerAdmin is supplied as a white-label product to clients who operate their own EMI and device-management businesses. Under this model:

• Clients brand and operate the product for their customers; they define business rules, pricing, and operational policies.
• We provide the software, technical support, hosting (if agreed), and tools to securely store and process data according to Indian IT laws.
• Clients are responsible for their customer-facing actions and compliance with local business laws; we assist by applying technical and contractual safeguards.

3. Legal Framework

This Policy is designed to comply with applicable Indian laws and regulations, including but not limited to the Information Technology Act, 2000 and its rules, the Digital Personal Data Protection Act and related guidance, the Aadhaar Act (where applicable), and other relevant statutory obligations.

4. Types of Personal Data Collected

We may process the following categories of data when providing the product and services:

• Identity & contact: names, business names, phone numbers, email addresses, postal addresses.
• Account & access: usernames, encrypted passwords, role and access information for Admins, Distributors, Retailers, Staff and Customers.
• Device & loan data: device identifiers (for example IMEI), device status (locked/unlocked), loan/EMI schedules, payment history, and loan documents.
• Location & control metadata: location information (when enabled), lock/unlock events, SMS locking commands, and feature usage logs.
• Support & communication: customer queries, uploaded documents, and support logs.

5. How We Use Personal Data

We use personal data to:

• Deliver the software functions such as device locking/unlocking, EMI reminders (audio/screen), social media restrictions, and offline SMS locking.
• Manage client accounts, authentication, and role-based access control.
• Maintain loan records, process reconciliations, and provide reporting tools to clients.
• Secure the product, prevent abuse, and carry out fraud detection and audits.
• Provide support, maintenance, and communicate important updates or legal notices.

6. Lawful Basis & Consent

Where required, we obtain consent for data processing (for example, location access or audio notifications). Our processing is also based on contractual necessity, compliance with legal obligations, and legitimate interests such as security and product improvement.

7. Data Sharing and Disclosures

We may share personal data with:

• Our clients (the white-label operators) to enable them to manage loans, devices, and customers.
• Service providers under contract (such as hosting, analytics, payment processors) who must follow confidentiality and security obligations.
• Law enforcement or regulators when required by law or to protect rights, safety, or to investigate fraud.
• Third parties in connection with a business transfer (sale, merger), subject to contractual protections and notice where required.

8. Data Storage, Retention and Security

We implement reasonable technical and organizational measures to protect personal data (encryption in transit, access controls, secure development practices). Data is stored in India unless otherwise agreed with a client and retained only for as long as required for business, legal, or regulatory needs.

9. Client Responsibilities

As a white-label provider, we supply tools and secure infrastructure, but our clients control customer onboarding, business policies, and operational decisions. Clients must ensure they obtain any required consents, follow applicable laws, and use the product responsibly.

10. Location & Device-Control Features

Features like "Get User Location" for new and running phone keys, social media locking, and offline SMS locking require explicit permissions from device users. We process only the minimum necessary data to provide these features and log events for audit and security purposes.

11. Rights of Individuals

Depending on your role and applicable law, individuals may have rights to access, correct, port, or delete personal data and to object to certain processing. Requests will be handled in accordance with applicable Indian law and contractual agreements with clients.

12. International Transfers

Where data is transferred outside India (for example to a cloud provider), we use contractual and technical safeguards to protect the data, consistent with legal requirements and any contractual commitments to clients.

13. Children

Our services are not intended for children under 18. We do not knowingly collect personal data of minors. If we learn that we have collected such data without proper consent, we will take steps to delete it promptly.

14. Grievance Officer

For privacy concerns and data requests, please contact our Grievance Officer:
CodeWint Technologies
Email: contact@codewint.com
Phone: 7976499049
Address: 8, B yojna, Radha Kunj, Mansarovar, Jaipur, Rajasthan 302020

15. Changes to This Policy

We may update this policy to reflect legal, operational, or technical changes. Revised policies will be posted with an updated "Last updated" date.

16. Governing Law

This Policy is governed by the laws of India. Any disputes in relation to this Policy or our data practices will be subject to the courts of Jaipur, Rajasthan, unless otherwise required by law.