Privacy Policy

DEFINITIONS

For the purposes of this Privacy Policy:

• •“Platform” refers to the Setlo website, applications, and services
• •“User”, “You”, “Your” refers to any individual accessing or using the Platform
• •“Setlo”, “We”, “Us”, “Our” refers to the entity operating the Platform
• •“Personal Data” means any information that identifies or can identify an individual
• •“Sensitive Personal Data” shall have the meaning ascribed under applicable Indian laws
• •“Act” means the Digital Personal Data Protection Act, 2023 of India
• •“Data Principal” means the individual to whom the Personal Data relates
• •“Data Fiduciary” means Setlo, which determines the purpose and means of processing
• •“Data Processor” means any entity processing Personal Data on behalf of Setlo
• •“Processing” includes collection, storage, use, sharing, disclosure, and erasure

ROLE OF SETLO

Setlo acts as a Data Fiduciary under the Act.

• •We determine the purpose of processing
• •We determine the manner in which Personal Data is processed

NOTICE AT THE TIME OF COLLECTION

At the time of collection, Users (Data Principals) are informed of:

• •The nature of Personal Data being collected
• •The purpose for which such data is processed
• •The manner in which Users may exercise their rights
• •The process for grievance redressal
• •By proceeding, the User provides free, specific, informed, unconditional, and unambiguous consent

CONSENT

Processing of Personal Data is based on:

• •Explicit User consent
• •Legitimate uses as permitted under the Act
• •Users may withdraw consent at any time
• •Withdrawal shall not affect processing already completed
• •Certain services may become unavailable upon withdrawal

INFORMATION COLLECTED

We collect information that is necessary, proportionate, and relevant to the provision of services.

• •Identity and Contact Information: Name, phone number, email address, identity verification details
• •Interaction and Platform Data: Records created by users, acknowledgements, communication logs
• •Technical Data: Device info, IP address, usage patterns, cookies and logs

PURPOSE LIMITATION

Personal Data shall be processed only for:

• •Providing and operating the Platform
• •Enabling structured interaction between Users
• •Ensuring security, fraud prevention, and system integrity
• •Maintaining records for audit and dispute resolution
• •Complying with legal obligations

DATA MINIMIZATION

We collect only such Personal Data as is relevant, necessary, and proportionate to the stated purpose.

DATA ACCURACY

Users are responsible for ensuring that the data provided is accurate, complete, and up to date.

• •Setlo shall take reasonable steps to maintain accuracy where feasible

DATA SECURITY

We implement commercially reasonable safeguards including:

• •Encryption protocols
• •Secure servers and storage
• •Access control mechanisms
• •Periodic security audits
• •Monitoring systems for unauthorized access

DATA RETENTION

Personal Data shall be retained only:

• •For as long as necessary for the stated purpose
• •As required under applicable law
• •Data may be deleted or anonymized once the purpose is fulfilled

DATA SHARING

We do not sell or rent Personal Data.

• •With other users only where necessary
• •With service providers under confidentiality obligations
• •With legal authorities when required

CROSS-BORDER DATA TRANSFER

Personal Data may be transferred outside India subject to applicable law and safeguards.

USER RIGHTS

Under applicable law, Users may:

• •Request access to Personal Data
• •Request correction or deletion
• •Withdraw consent
• •Seek grievance redressal
• •Nominate another person in case of incapacity

GRIEVANCE REDRESSAL

We provide a grievance mechanism as required under law.

• •Response time within defined period
• •Users may escalate to Data Protection Board of India if unresolved

THIRD-PARTY SERVICES

The Platform may rely on third-party services. Setlo is not responsible for their privacy practices.

CHILDREN’S DATA

We do not knowingly process Personal Data of minors.

• •Parental consent required where applicable
• •Additional safeguards applied

SIGNIFICANT DATA FIDUCIARY

If classified as such, Setlo shall comply with additional obligations.

• •Appointment of Data Protection Officer
• •Data Protection Impact Assessments
• •Periodic audits

POLICY UPDATES

We reserve the right to modify this Privacy Policy at any time.

• •Continued use constitutes acceptance