Your borrowers' data, processed only on your instructions.

1. Who does what

You, the DSA, lender or other professional using SanctionDesk, decide why and how borrower personal data is collected. You are the Data Fiduciary. Saraogi & Saraogi, Chartered Accountants, which operates SanctionDesk, acts as your Data Processor only for the CreditLink relay, which carries borrower files from the borrower's device to yours.

The SanctionDesk desktop application stores and analyses case data on your own computer. We do not receive or host that local data. These terms do not make us a processor of it.

If your organisation runs its own relay, we are not a processor for data that passes only through your relay.

2. Processing only on your instructions

We process borrower personal data only to deliver CreditLink as you configure it: issue collection links, receive encrypted packages, hold them until your SanctionDesk application imports them, report delivery status, and delete them. We do not use borrower data for our own purposes. We do not sell it, use it for marketing, or use it to train artificial-intelligence or machine-learning models.

3. What data the relay handles

Borrower files. CreditLink encrypts documents on the borrower's device to an encryption key held by your SanctionDesk installation, before upload. We do not hold the key that opens these packages.

Limited link and delivery information. This includes collection-link status, timestamps, the borrower's consent record, the borrower name shown so the borrower can confirm the right case, requested-document labels, masked identifiers (never a full PAN), package size and delivery status, and your business contact details shown to the borrower. It also includes ordinary technical data such as IP addresses that any web service receives.

4. Your responsibilities

You must have a lawful basis and every consent, authority and notice that the law and your lender require before you send a collection link. This includes valid consent from each co-borrower and co-applicant, normally through the loan application they sign. CreditLink records the primary borrower's consent and confirmation; it does not replace the consent you must obtain. You must handle access, correction, erasure and grievance requests from borrowers, and we will help as described below.

5. Security safeguards

We maintain reasonable security safeguards for the relay, including:

• encryption of borrower files before they leave the borrower's device;
• encrypted connections (HTTPS);
• link-specific access tokens;
• restricted administrative access;
• automatic deletion;
• logs reasonably needed to detect and investigate unauthorised access.

Our personnel with relay access are bound by confidentiality.

6. Personal data breaches

If we become aware of a personal data breach affecting the relay, we will tell you without undue delay, and in any event within 24 hours. We will give you the information we have, including:

• what happened;
• the likely effect;
• the data and borrowers affected, where known;
• the steps taken.

This allows you to inform the Data Protection Board of India and affected borrowers as the law requires. We will update you as we learn more.

7. Retention and deletion

An encrypted package is deleted from the relay after your SanctionDesk application confirms it has imported it. A package not imported is deleted automatically within 30 days. When a collection link is revoked or expires, we stop accepting uploads for it.

Copies in our hosting provider's backups expire on that provider's backup cycle. Your local imported copy is under your control. Our deletion does not affect it.

8. Sub-processors and location

The relay is hosted by Hostinger International Ltd on a server in India. Hostinger's automatic backups of that server are currently stored in Singapore. Files in those backups are the encrypted packages described above. You authorise us to use Hostinger for this purpose. We will update this page before we add or replace a sub-processor that handles borrower data, or change where the relay's data is stored. You may object by writing to us.

9. Assistance and information

We will reasonably help you respond to borrower requests to access, correct or erase data held on the relay, and to requests from regulators. On request, we will give you the information reasonably needed to show that we comply with these terms.

10. End of service

When your use of CreditLink ends, packages and link information held for you on the relay are deleted under section 7, unless the law requires us to keep them.

Contact

Data protection questions and breach contact: hello@sanctiondesk.in, Saraogi & Saraogi, Chartered Accountants, 301, 3rd Floor, D K House, Opp. Mithakhali Municipal Garden, Mithakhali, Ahmedabad – 380006.