Reality Code ("We", "Us", "Our") operates the RinSolve mobile application ("App"). We are committed to protecting your privacy and handling your personal data responsibly and transparently. This Privacy Policy explains how we collect, use, process, store, and protect your Personal Data when you use our App. By using RinSolve, you acknowledge that you have read and agree to the practices described in this Policy.
This Policy complies with the Information Technology Act 2000, the IT (Reasonable Security Practices and Sensitive Personal Data) Rules 2011, the Digital Personal Data Protection Act 2023, and applicable RBI guidelines.
2. Information We Collect
A. Information You Provide Directly
Personal details: full name, mobile number, email address, date of birth, gender, PAN number.
Loan details: bank name, loan account number, outstanding balance, EMI amount, interest rate, loan start date, loan type (Term Loan or Overdraft), tenure.
Extra payment amounts and dates you log manually via the Pay Now feature.
Subscription and billing information (processed through our payment gateway partner Razorpay).
KYC information: Aadhaar number (via DigiLocker or manual entry), passport number, voter ID, driving license, ration card details.
Support communications and feedback you send us.
B. Credit Bureau Data (with your explicit consent)
With your prior digital consent during onboarding, we fetch your credit report via Surepass (a licensed bureau aggregator) from Experian and other credit information companies registered under the Credit Information Companies (Regulation) Act 2005. This includes:
Credit score and score history.
Outstanding home loan balance and other loan account details.
EMI payment history and account status (active/closed/written-off).
Applicable interest rate on your loans.
Loan account identifiers and subscriber information.
Personal information from credit reports: name, date of birth, PAN, addresses, email, phone numbers.
Important: This data is used ONLY to power loan optimization, extra payment verification, and generate your personalized amortization schedule. We do NOT use this for credit scoring, lending decisions, or sharing with any lender.
C. Information Generated Through App Usage
Device information: model, OS version, unique device identifiers, brand.
Feature usage: screens visited, buttons tapped, time spent.
OTP verification data: mobile number and verification logs.
D. Information from Third Parties
Credit bureau aggregators (Surepass) for credit report fetching — collected only upon your explicit consent.
IFSC validation data from Razorpay's IFSC API to auto-fill bank name during profile setup.
Firebase Cloud Messaging (FCM) for push notification delivery.
MSG91 for SMS-based OTP delivery.
3. How We Use Your Information
A. To Provide and Improve Services
Generate your personalized amortization schedule and SLR (Systematic Loan Repayment) recommendations.
Track and verify extra payments against credit report data (Pending → Verified/Invalid).
Display loan health metrics, tenure progress, interest savings, and savings projections.
Power the EMI Calculator, FD comparison, and credit score display features.
Provide loan optimization insights and comparisons (original vs optimized).
Detect missing interest rates and prompt you to provide them manually.
Reconcile your logged prepayments against credit bureau data.
B. Account & Subscription Management
Create and manage your RinSolve account.
Process subscription payments via Razorpay and send transactional notifications.
Sync Experian credit report automatically after subscription purchase.
Run automated monthly credit report syncs for active premium subscribers.
C. Security & Fraud Prevention
Detect and prevent fraudulent activity on the platform.
Verify identity through OTP-based authentication.
Verify payment data accuracy through credit report reconciliation.
Offer app lock features (PIN and biometric authentication) for device-level security.
D. Legal & Regulatory Compliance
Comply with applicable Indian laws, RBI guidelines, and regulatory requirements.
Respond to lawful requests from government authorities or courts.
Maintain transaction and payment logs for the period required under financial regulations.
E. Communications (with your consent)
Send loan optimization tips, payment reminders, and financial insights via push notifications.
Notify you of changes to the App, Terms, or Privacy Policy.
Send credit score updates (improvement/drop notifications) after monthly syncs.
You can opt out of non-essential push notifications at any time through App settings.
4. Data Storage & Security
4.1 All data is stored on secure AWS servers located in the India (ap-south-1) region, in compliance with RBI data localization guidelines.
4.2 We implement industry-standard security measures:
AES-256 encryption for data at rest.
TLS 1.3 encryption for data in transit.
Role-based access controls on all databases.
Regular security audits and vulnerability assessments.
JWT-based authentication for all API endpoints.
SHA-256 hashing with salt for PIN storage in app lock feature.
4.3 If a security breach occurs affecting your data, we will notify you and relevant authorities as required by law.
5. Data Sharing & Disclosure
We do NOT sell, rent, or lease your personal data to any third party. Data is shared only in the following limited circumstances:
A. Service Providers
Surepass (credit bureau aggregator) — for fetching Experian credit reports with your explicit consent.
AWS India (ap-south-1) — for secure cloud data storage and file hosting (S3).
Razorpay — for subscription payment processing only. No financial data is stored on our servers.
MSG91 — for SMS-based OTP delivery during authentication.
Firebase (Google) — for push notification delivery and app analytics (anonymized).
All service providers are bound by data processing agreements restricting use of your data.
B. Legal Requirements
We may disclose your data if required by court order, judicial process, or lawful government request under applicable Indian law.
C. Business Transfers
In a merger or acquisition, your data may transfer to the successor entity under the same privacy protections. You will be notified of any such change.
6. Data Retention
Account data: Retained for account lifetime plus 90 days after deletion.
Credit report data: Retained for the active loan period plus 12 months.
Amortization and optimization history: Retained for account lifetime.
Transaction and payment logs: Retained for 7 years as required under financial regulations.
OTP verification logs: Retained for 90 days.
After the retention period, data is securely erased or anonymized.
7. Your Rights
Right to Access: Request a copy of the personal data we hold about you.
Right to Correction: Request correction of inaccurate or incomplete data.
Right to Deletion: Request deletion of your account and data (subject to legal retention requirements). Account deletion can be initiated through the App's Profile section or by contacting support.
Right to Revoke Consent: Revoke consent for credit report fetching at any time.
Right to Object: Object to processing of your data for marketing purposes.
To exercise any of these rights, contact [email protected]. We will respond within 30 days.
8. Children's Privacy
RinSolve is not intended for persons under 18 years of age. We do not knowingly collect personal data from minors. If we become aware that we have collected data from a person under 18, we will delete it immediately. Contact us at [email protected] if you believe a minor has created an account.
9. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of significant changes through an in-app notification or email to your registered address. Continued use of the App after such changes constitutes acceptance of the updated Policy.
10. Grievance Officer
In accordance with the Information Technology Act 2000 and the Digital Personal Data Protection Act 2023: