1 Data Fiduciary Identity & Scope
This Privacy Notice is provided by Imbu Shankar Chits Pvt. Ltd. ("Company", "We", "Us", or "Data Fiduciary"), registered under the Karnataka Chit Funds Act and Chit Funds Act 1982, having its registered office at 48/Y, 14th Main Road, 3rd Block, Rajajinagar, Bangalore - 560 010, Karnataka, India.
As a Data Fiduciary under the Digital Personal Data Protection (DPDP) Act, 2023, we are committed to processing the personal data of individuals ("Data Principals" or "You") in a lawful, transparent, and secure manner. This Notice explains what digital personal data we collect, why we process it, how long we retain it, who we share it with, and your statutory rights.
2 Categories of Personal Data Collected
We collect personal data directly provided by you when you interact with our website, submit online enquiry forms, request chit plan quotes, or enter into chit subscriber agreements:
Identity & Contact Data
Full Name, Mobile Phone Number, Email Address, Residential Address, and Preferred Language.
Financial & Plan Preferences
Preferred chit scheme value (e.g., ₹2.5L to ₹25L), savings goals, and inquiry details.
Statutory KYC Data (Subscribers)
Aadhaar number, PAN card, address proof, passport photos, bank details, and surety documentation required under Chit Funds Act 1982.
Technical & Consent Metadata
IP address, browser type, consent selection timestamps, and cookie preferences stored locally.
3 Specified Purposes of Processing
In strict compliance with Section 4 of the DPDP Act, your personal data is processed solely for specified, explicit, and legitimate purposes:
- Responding to Enquiries: Contacting you via Phone, WhatsApp, or Email to explain requested chit schemes and monthly installment schedules.
- Chit Agreement Enrollment: Processing subscriber registration, evaluating eligibility, and executing formal chit agreements under the Chit Funds Act 1982.
- KYC & Statutory Compliance: Verification of identity and background as required by the Registrar of Chits, Government of Karnataka, and Anti-Money Laundering (PMLA) regulations.
- Customer Support & Grievances: Addressing inquiries, account updates, dividend calculations, auction notifications, and dispute resolution.
- Marketing Updates (Optional): Sending promotional chit scheme announcements only where explicit separate consent has been provided.
4 Consent & Lawful Grounds
Under Section 6 of the DPDP Act 2023, processing of personal data is based on your free, specific, informed, unconditional, and unambiguous consent signified through affirmative action (unticked opt-in checkboxes on our forms).
Right to Withdraw Consent:
You have the right to withdraw your consent for data processing at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal, nor does it impact data retained under statutory financial laws (Chit Funds Act 1982).
5 Data Retention & Statutory Overrides [LEGAL REVIEW REQUIRED]
Personal data is retained only for as long as necessary to fulfill the specified purpose or as required by applicable statutory laws:
| Data Type | Retention Period | Statutory Basis / Reason |
|---|---|---|
| Unconverted Web Inquiries | 180 Days | Erased after follow-up unless subscriber agreement is initiated. |
| Active Chit Subscribers | Duration of Chit Group + 5 Years | Mandatory statutory record keeping under Chit Funds Act 1982 & PMLA rules. |
| Consent Audit Logs | 2 Years | Demonstrating proof of consent under DPDP Act obligations. |
6 Third-Party Disclosures & Data Processors
We do not sell, rent, or trade your personal data. Disclosures are strictly limited to authorized Data Processors bound by confidentiality:
- Government Authorities & Regulators: Registrar of Chits (Karnataka), statutory auditors, and judicial courts as mandated by law.
- IT & Infrastructure Service Providers: Secure hosting providers and SMTP direct mail transport infrastructure for dispatching form inquiries.
- Legal Counsel & Sureties: Legal advisors for auction verification and contract enforcement under Section 28 & 30 of the Chit Funds Act.
7 Statutory Rights of Data Principals
Under Chapter III of the DPDP Act 2023, you enjoy the following statutory rights regarding your personal data:
Summary of personal data being processed and identities of Data Processors with whom data has been shared.
Correction of inaccurate data, updating of incomplete records, and erasure of data no longer necessary for purpose.
Access to a readily available grievance redressal mechanism with response within statutory SLA.
Nominate any individual to exercise data rights on your behalf in event of death or incapacity.
8 Children's Data & Competency
In accordance with Section 9 of the DPDP Act 2023, our website and chit fund services are directed exclusively at individuals who are legally competent to contract (minimum 18 years of age). We do not knowingly process personal data belonging to minors without verifiable parental or legal guardian consent.
9 Technical Security Safeguards
We implement appropriate technical, physical, and organizational security measures to protect personal data against unauthorized access, loss, alteration, or disclosure:
- Encrypted communication protocols for data in transit.
- Restricted access control and role-based administrative permissions.
- Regular technical vulnerability monitoring and incident triage runbooks.
10 Grievance Redressal Officer Details
If you have questions, concerns, or grievances regarding the processing of your personal data or wish to exercise your statutory rights under the DPDP Act, please contact our designated Grievance Officer:
Data Protection & Grievance Officer
Imbu Shankar Chits Pvt. Ltd.
48/Y, 14th Main Road, 3rd Block, Rajajinagar, Bangalore - 560 010, Karnataka, India