Privacy policy

1. Who we are

Setlo Technologies Pvt. Ltd. ("Setlo", "we", "our") operates the Setlo platform at setlo.in and via our mobile applications. We are a Data Fiduciary under the DPDP Act, 2023. Our registered address and grievance officer details are provided below.

2. Data we collect

We collect only the data necessary to provide the Setlo service:

Identity data: name, mobile number, email address

KYC data: PAN number, Aadhaar verification (for closure transactions only)

Obligation data: amounts, notes, dates, and connection to other users you invite

Device and usage data: app interactions, device type, and IP address for security

3. How we use your data

To create and manage your Setlo account

To facilitate obligation creation, confirmation, and closure

To detect closure paths (loop closure) across your network

To comply with RBI guidelines for payment facilitation

To communicate with you about your obligations and account

To improve the platform and prevent fraud

We do not use your data for advertising. We do not sell your data to third parties.

4. Data sharing

We share data only in the following circumstances:

With other Setlo users you invite to confirm an obligation - limited to what they need to see

With payment service providers for closure transactions, under strict data processing agreements

With regulatory authorities when legally required

With our infrastructure partners (cloud hosting, security) under DPDP-compliant agreements

5. Your rights as a Data Principal

Under the DPDP Act, 2023, you have the following rights:

Right to access your personal data held by Setlo

Right to correct inaccurate or incomplete personal data

Right to erasure of your personal data (subject to legal obligations)

Right to withdraw consent for processing at any time

Right to nominate a person to exercise rights on your behalf

Right to file a complaint with the Data Protection Board of India

To exercise any of these rights, contact our Grievance Officer at grievance@setlo.in.

6. Data retention

We retain your data for as long as your account is active or as required by applicable law. Closure records are retained permanently as part of your Circle history. You may request deletion of your account and associated data at any time.

7. Security

All data is encrypted in transit and at rest. We implement industry-standard security controls and conduct regular security reviews. In the event of a data breach, we will notify affected users and the Data Protection Board of India as required under the DPDP Act.