PRIVACY POLICY OF GLIMMER TECHNOLOGIES PRIVATE LIMITED

(ERSTWHILE DMI INFOTECH SOLUTIONS PRIVATE LIMITED)

ZestMoney (DMI Infotech Solutions Private Limited) (“we” or “us” or “our” or the “Company”) respects the privacy of its members (“you” or “your”) and has developed this Privacy Policy to demonstrate its commitment to protecting your privacy

1. APPLICABILITY

1.1. Glimmer Technologies Private Limited (previously known as DMI Infotech Solutions Private Limited) (“we” or “us” or “our”) maintains the website www.zestmoney.in (“Website”) and the mobile application by the name of ZestMoney (“App”, collectively with Website, referred to as the “Platform”). This privacy policy (“Privacy Policy”) applies in respect of all Personal Information (as defined below) collected by us from users, visitors and others (collectively “the User” and also indicated by “you” or “your”) who access or use the Platform, submit any information to us or who avail Services (as defined below) from us, including through any third-party application.

1.2. This Privacy Policy explains the manner in which we collect, use, disclose and otherwise process such Personal Information. We respect your privacy and therefore limit the collection, processing, storage and sharing of Personal Information to that which is required and appropriate for the purposes approved by you, or for our legitimate interest or any legal or regulatory requirement. Further, in addition to this Privacy Policy, we may obtain specific and explicit consent as and when practicable or required under applicable law.

1.3. This Privacy Policy has been prepared in compliance with the provisions of the applicable laws including Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and Reserve Bank of India (Digital Lending) Directions, 2025. This Privacy Policy is in addition to applicable law and in case of any contradiction between this Privacy Policy and applicable law, the provisions of applicable law will prevail.

1.4. Access to and the use of the Platform and availing of the Services is subject to this Privacy Policy. The services offered by us include, without limitation operating an online technology platform for persons to register for obtaining loans from financial institutions in India (“Services”).

1.5. It is important that you read the Privacy Policy carefully because by accessing the Platform or utilizing the Services, you shall be deemed to have agreed to all the terms and conditions of this Privacy Policy and have authorized us to collect, process and share the Personal Information as provided in this Privacy Policy, subject to any applicable law. However, we endeavour, as and when practicable or required by applicable law, to seek specific and explicit consent for collection, processing, storage and sharing of your personal information.

1.6. This Privacy Policy seeks to help you understand:

  • the type of data or information that directly or indirectly, in combination with other information would allow the identification of a specific living person, including sensitive personal data, (“Personal Information”) collected by us;
  • the purpose of collection, the manner of collection, storage, and processing of such Personal Information;
  • the parties with whom such Personal Information is shared and the manner in which they may process such Personal Information;
  • Your rights and obligations in respect of such Personal Information and the manner in which you may exercise your rights as per applicable law.

1.7. In the course of availing the Services or accessing the Platform, you may also be accessing or may be redirected to websites, platforms or apps of third parties, who may collect Personal Information for their own purposes or for providing you other services. This Privacy Policy does not govern Personal Information collected by any such third-party, even though their website, platform, or application may be linked to the Platforms. We advise that you understand and comply with privacy policies applicable to third-party websites, platforms or applications that you access or are redirected to. While we restrict the manner and extent to which we share your personal information with third parties and provide appropriate safeguards in our contractual arrangements with such third parties, we will not be liable or responsible in any manner for any Personal Information collected and processed by such third parties.

1.8. Further, any information that is freely available or accessible in public domain or shared by you in interactions with third parties in public platforms (including any part of our Platforms which are for general public interaction or which may be viewed by other Users), or furnished under the Right to Information Act, 2005 or any other law for the time being in force will not be subject to this Privacy Policy.

2. PERSONAL INFORMATION WE COLLECT

2.1. We may collect, store and use Personal Information about you when you visit or use our Platform or query on, apply for, or avail of any Services or submit any Personal Information to us, including through a third party website or an application (even if it does not specify our name as the service provider). Subject to applicable laws, the Personal Information provided by you may be utilized to procure such further information through independent or third-party sources, as may be needed by us for providing any Services.

2.2. We do not store your personal information except some basic minimal data (viz., name, address, contact details of the customer, etc.) that may be required to carry out our operations or service within the scope of the RBI Digital Lending Directions, 2025 as may be amended from time to time. We collect the following Personal Information for providing the services to the extent required for permitted purposes and do not collect data which is excessive or not required for such purposes:

  • Identification Data: name, phone number, date of birth, gender;
  • Contact Details: including, without limitation, address, mobile number, email address;
  • Financial Data: including, without limitation, your occupation and job position, financial information (such as income, income sources, assets, details of debit cards, credit cards, bank account details, bank statement etc.), credit bureau score, credit reports and credit data.
  • SMS: We do not access or collect personal SMS, contact lists, call logs, or media stored on your device. Where one time access to transactional SMS data is required for credit assessment during onboarding, we will obtain your explicit consent before such collection, and you will have the option to deny such access without impacting your use of other features of the Platform.
  • Device: specific information about your device including your device model, operating system and version, user profile information to uniquely identify the devices, your device’s internet protocol address, browser type and browser version.
  • Location: We collect location data only once during onboarding, for Know Your Customer (KYC) and fraud-prevention purposes, and do not track continuous location. Further, as and when requested by you, we may seek to access location with your explicit consent, for providing any specific location -based services as are explicitly sought by you.
  • We collect data about how you interact with our Services. This includes data such as access dates and times, App features or pages viewed, App crashes and other system activity, type of browser, and third- party sites or services used before or in the course of interacting with our Services.
  • Cookies: We may use various technologies to collect information about your activities on our Platform, including cookies and beacons. Cookies are small files transferred to your device when you visit a website that enables the websites to recognize your browser and capture and remember certain information. Such information may be used to improve your browsing and user experience and analyzing site operations. By using the Website, you consent to the storage of cookies on your devices. You may, however, disable the use of cookies by changing your browser settings. Furthermore, our Privacy Policy does not cover the use of cookies by its partners and affiliates since we do not have access or control over such cookies.
  • Other Information: We may seek additional information from you as needed and in accordance with the Applicable Law. You may choose to provide or reject the request for such additional information.

2.3. Further, to the extent possible and as required by applicable law, we may give you the option to not provide or agree to the collection of specific Personal Information. However, if you choose not to accept the Privacy Policy or not to provide any or all Personal Information as requested, we reserve the right to not provide certain features on the Platform or Services or offer them on terms which may be different (including more onerous or less beneficial) than the terms on which the Services may have otherwise been provided.

3. HOW WE USE PERSONAL INFORMATION

3.1. We may use your Personal Information for any other legitimate purpose for which you have given your consent , or to provide various Services to you, or for our internal business purposes, including, but not limited to:

  • open, maintain and manage your account with us, including for on-boarding and verification of identity;
  • to assist in assessing your creditworthiness;
  • respond to your requests for information;
  • provide the Services;
  • monitor and enforce compliance with the terms of use of the Services, contractual obligations (including payments of any dues to us) and our legal rights;
  • curate and optimize our Services for you and provide customized offers or rewards to you;
  • improve our Platform and Services and your experience in respect of the same;
  • undertake marketing, advertising and promotional activities to bring you products and services which may be appropriate or of interest to you. However, we do not sell or transfer your personal data to third parties for their marketing or promotional purposes, without your explicit and specific consent. We may also use your information for marketing communications only with your explicit and revocable consent
  • send you communications, including through SMS, voice call, IVR or any third-party messaging platform in relation to your use of the Services or Platform;
  • administer and ensure the security of our systems and Platform, including any updating, system testing, troubleshooting;
  • undertake risk control, investigations and other measures for detection and prevention of fraud, illegal activity, cyber incidents, or other wrongdoing.
  • protect our business and for our other legitimate interests;
  • comply with laws and regulations or requests from government authorities;
  • for business or portfolio transfers, including to evaluate or conduct assignment of receivables, securitization, restructuring, reorganization, mergers and acquisitions, divestiture, sale of all or any of our assets whether as a going concern or otherwise, including in and bankruptcy, dissolution or liquidation proceedings.

3.2. We may combine your Personal Information available collected through different modes and sources and aggregate any statistics or data that are collected for any of the purposes provided above. However, we are under no obligation to do so.

4. HOW WE SHARE PERSONAL INFORMATION

4.1. By using the Platform and our Services you authorize us to share your Personal Information, on a “need-to-know” basis, with third parties as below (to the extent required for any permitted purposes as set out in this Privacy Policy):

  • Service Providers: We may disclose your information to companies that provide services to or on our behalf, including without limitation providing statistical analysis, verification, risk management, or payment services.
  • Business Partners: We may share your Personal Information with our business partners to seek inputs and analysis in respect of the Services or to enable us to provide the Services to you. They may also use your information to provide you with promotional materials, advertisements, offers and other materials.
  • Group Companies: We may share collected Personal Information with our affiliates whose products and services we believe you may find of interest; in which case we will require that they comply with the terms of this Privacy Policy.
  • Statutory and other Disclosures: We may share your Personal Information with third parties as required for compliance with any applicable laws or directions from government or regulatory authorities.
  • Third Parties for Business Transfers: We may share your Personal Information with third parties with whom we are negotiating and/ or concluding any business or portfolio transfers, assignment of receivables, securitization, restructuring, reorganization, mergers and acquisitions, divestiture, sale of all or any of our assets whether as a going concern or otherwise, including in and bankruptcy, dissolution or liquidation proceedings, in order for them to evaluate the feasibility and terms of such arrangements or transfers and to undertake or implement the same.
  • Other Parties: We may share your Personal Information with other parties for any other purposes with your consent.

4.2. We intend to share your personal information such as your name, registered email address, registered phone number with the third parties as identified and listed in Annexure A. List shall be updated on a quarterly basis. We do not transfer any Personal Data to any such country or territory outside India that is restricted by the government.

5. DATA RETENTION

5.1. We will store and retain your Personal Information in India only to the extent and for the period necessary to provide you the Services the purposes set out in this Privacy Policy or as may be required for compliance with applicable laws, regulatory requirements, or to protect, enforce or establish our legal rights. Subject to Paragraph 5.2 below, all data will be deleted upon withdrawal of consent, or account deletion request, unless required to be retained by law. Your Personal Information shall be retained for a maximum period of three (3) years from the date it was first obtained by Us or 3 (three) years from the date you last accessed or used Our Services – whichever is later. For the avoidance of doubt, Your Personal Information shall continue to be retained for as long as you maintain an active account or have any ongoing relationship with us.

5.2. You may request us to delete your Personal Information by submitting a request in writing to the contact details provided in Paragraph 12 (Contact Information and Grievance Redressal) below/ You may request us to delete your information by submitting a request for account deletion through the ZestMoney mobile app via the personal details tab in the Profile section. Subject to any compliance with applicable laws, regulatory requirements, or except as required to protect, enforce or establish our legal rights, we will delete such personal information pursuant to receipt of such request. You understand that in case of any such request, your account may be permanently deleted, and you will not be able to reactivate your account. In such case, we may also not undertake any further communication with you. We also reserve the right to cease providing any Services to you and any such discontinuation will be without any liabilities or obligations on us on account of such discontinuation / deactivation.

6. WITHDRAWAL OF CONSENT

6.1.You have the right to withdraw your consent for collection or processing of your Personal Information at any time by contacting us as described in the “Contact Us” section on the Website or by switching off/disallowing ‘User Consent’ through App settings or by writing to the contact details provided in Paragraph 12 (Contact Information and Grievance Redressal) below.

6.2. If you revoke or withdraw your consent for collection or processing of your Personal Information, then, subject to any compliance with applicable laws, regulatory requirements, or to protect, enforce or establish our legal rights, we will immediately stop actively collecting and processing your Personal Information. Withdrawal will not affect the lawfulness of data processing carried out before withdrawal. Certain Services/Credit Facilities (including disbursement of any unavailed sanctioned credit or financial products) may not be available post withdrawal of consent since processing of personal data is essential for those Services. However, you will always retain the right to close your account and request deletion of data.

7. CHANGE OF INFORMATION

7.1. You are responsible for providing updated and correct information about yourself to us within 30 (thirty) days of such change. We are not responsible for the authenticity, completeness or correctness of the Personal Information supplied by you.

7.2. You are entitled to review the Personal Information provided by you to us and ask us in writing to update or correct such Personal Information after providing us reasons as to why you believe such information is inaccurate or incomplete. We will make the necessary corrections or updation on being satisfied that such change is warranted.

8. SECURITY MEASURES

8.1. We store your Personal Information only on servers located in India. We use security measures (including physical, electronic and procedural measures) as mandated by applicable law and in accordance with reasonable industry practices to safeguard Personal Information against loss, misuse, damage or modification and unauthorized access or disclosure. However, no system for transmitting or storing information electronically can be completely secure and we cannot guarantee that Personal Information or other communications will always remain secure. Therefore, the use of the Platforms and availing our Services will be at your own risk.

8.2. You are also solely responsible for protecting your password and device against unauthorized access.

8.3. We assume no liability for any disclosure of information due to errors in transmission, unauthorized third- party acts, or acts or omissions beyond our reasonable control.

8.4. If mandated by applicable law, we will notify you if a Personal Information breach occurs and the risk mitigation measures undertaken by us, to the extent required by applicable law.

8.5. We do not knowingly collect personal information from minor children. If we learn that we have collected personal information from a minor, we will delete that information from our database unless we have authorization from the parents or the guardian of such minor.

8.6. We also protect your personal information off-line other than as specifically mentioned in this Privacy Policy. Access to your personal information is limited to employees, agents, or partners and third parties as mentioned in above Paragraphs, who we reasonably believe will need that information to enable us to provide Services to you. However, we are not responsible for the confidentiality, security, or distribution of your own personal information by our partners and third parties outside the scope of our agreement with such partners and third parties.

9. PRIVACY POLICY CHANGES

9.1. We may update this Privacy Policy from time to time as we may deem fit. Any such changes will govern our practices in respect of all Personal Information, including that available or collected by us prior to such change. We will make reasonable efforts to update you of any such changes via SMS/ Whatsapp or through notification on the Platforms. The latest version can be found at https://www.zestmoney.in/. You will have the opportunity to review the updated Privacy Policy before deciding to continue using our products or services.

10. NO CONTRACTUAL OBLIGATION

10.1. Please note that this Privacy Policy and accessing the Platforms does not entitle you to any Services and does not create any right in your favour or impose any obligation on us, except as expressly set out in this Privacy Policy or otherwise mandated under applicable law.

11. GOVERNING LAW AND JURISDICTION

11.1. This Privacy Policy and any matter arising out of it will be subject to laws of India and courts at Delhi will have exclusive jurisdiction in respect of the same.

12. CONTACT INFORMATION AND GRIEVANCE REDRESSAL

12.1. In case of any complaints for breach of this Privacy Policy or review of information as provided in this Privacy Policy, you may contact the Grievance Officer as below, between 10:30 a.m. to 6:00 p.m. from Monday to Friday except on public holidays:

12.2. Grievance Redressal Officer:

Name:      Srinivas Pilli, AVP (Customer Success).

Address: Glimmer Technologies Private Limited (formerly known as DMI Infotech Solutions Private Limited), Express Building, Third Floor,9-10, Bahadur Shah Zafar Marg, New Delhi – 110002

Ph. No. –  022-68539501 / 079-64807777

Email: cxoforyou@zestmoney.in

12.3. We will resolve any complaints received by the Grievance Officer within thirty (30) days from the date of receipt of such complaint or within such time period as prescribed under applicable law. In case there is no resolution, then the person can lodge a complaint over the Complaint Management System (CMS) portal under the Reserve Bank-Integrated Ombudsman Scheme (RB-IOS) or send a physical complaint to “Centralised Receipt and Processing Centre, 4th Floor, Reserve Bank of India, Sector-17, Central Vista, Chandigarh – 160017” as per the grievance redressal mechanism prescribed by the Reserve Bank. As provided under applicable law, you will also have the right to file a complaint with the Data Protection Board of India as and when it is constituted.

13. DISCLAIMER

13.1. WITHOUT LIMITING THE FOREGOING, EVERYTHING ON THE PLATFORMS, THE CONTENT, SERVICES AND MATERIALS IN THE PLATFORM ARE PROVIDED “AS IS” AND ON AN “AS AVAILABLE”. TO THE MAXIMUM EXTENT PERMISSIBLE PURSUANT TO APPLICABLE LAW, WE DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES IN RESPECT OF FITNESS FOR A PARTICULAR PURPOSE, ACCURACY, SUFFICIENCY, SUITABILITY, CAPACITY, COMPLETENESS, AVAILABILITY, COMPATIBILITY OF THE SERVICES OR THE PLATFORM OR ANY INFORMATION PROVIDED THEREON. WE DO NOT WARRANT THAT THE SERVICES OR THE PLATFORM WILL BE CONTINUOUSLY AVAILABLE, UNINTERRUPTED OR BE FREE OF ERRORS VIRUSES OR OTHER HARMFUL COMPONENTS, OR THAT DEFECTS WILL BE CORRECTED. TO THE MAXIMUM EXTENT PERMISSIBLE PURSUANT TO APPLICABLE LAW, WE, INCLUDING OUR AFFILIATES, OFFICERS, EMPLOYEES AND AGENTS, DISCLAIM ALL LIABILITIES FOR ANY LOSS, DAMAGE OR EXPENSE ARISING OUT OF ANY ACCESS TO OR USE OF THE PLATFORMS OR ANY SITE LINKED TO IT OR THE SERVICES, INCLUDING, WITHOUT LIMITATION, ANY LOSS OF REVENUES OR PROFITS, LOSS OF BUSINESS OR LOSS OF DATA, INDIRECT, INCIDENTAL OR CONSEQUENTIAL LOSS. 

Annexure A 

  1. DMI Finance Private Limited – Lender
  2. Karix Mobile Private Limited – OTP service
  3. Moshpit Technologies, Pvt. Ltd.(Finbox) – SMS Transactional Intelligence
  4. Mcarbon Tech Innovation Private Limited- Marketing comms
  5. Webklipper Technologies Pvt. Ltd. (Webengage) – Analytics
  6. Google
  7. Meta Platforms Inc