Privacy Policy

📅 Effective Date: 1st September 2026

1. Who We Are

Reiod Locker ("we," "us," "our") is a Mobile EMI Security and Device Management Software provider operating under Indian law. Our website is www.reiodlocker.com.

For privacy-related inquiries, contact us at: 01866-882120 or via WhatsApp.

2. Information We Collect

2.1 From Retailers / Distributors

• Name, phone number, email address, and business details provided during registration.
• Login credentials (stored securely using encryption).
• Transaction and payment information.
• Device management actions performed on the platform (lock, unlock, track).

2.2 From End Customers (via Retailer)

• Device identifiers (IMEI, device ID, model number).
• GPS location data of the enrolled device (collected only when the Customer App is active).
• Device status (active, locked, power state).
• EMI payment status information provided by the retailer.

2.3 Automatically Collected Data

• IP address, browser type, and device information when you visit our website.
• Usage data and analytics (pages visited, session duration) via Google Analytics.
• Cookie data (see Section 9 on Cookies).

3. How We Use Your Information

We use the collected information to:

• Provide and operate the Reiod Locker device management platform.
• Enable retailers to remotely manage enrolled devices (lock, unlock, track).
• Send automated EMI due alerts and reminders to end customers.
• Process payments and manage subscriptions.
• Provide customer support and respond to inquiries.
• Improve our services and user experience through analytics.
• Comply with legal obligations under Indian law.
• Detect and prevent fraud, unauthorized access, and abuse.

4. Legal Basis for Processing (DPDP Act 2023)

Under the Digital Personal Data Protection Act, 2023, we process your personal data on the following legal bases:

• Consent: You have given consent to process your personal data for specific purposes (e.g., device enrollment).
• Contractual Necessity: Processing is necessary to perform our services under a contract.
• Legal Obligation: Processing is required to comply with applicable Indian laws.
• Legitimate Interests: Processing is necessary for our legitimate business interests (e.g., fraud prevention, service improvement).

5. Location Data

Reiod Locker collects GPS location data from enrolled devices. This data is:

• Accessible only by the registered retailer who sold the specific device.
• Collected only when the Customer App is installed and active on the device.
• Used solely for the purpose of EMI debt security and recovery under the buyer-seller agreement.
• Not shared with third parties for advertising or marketing purposes.

6. Data Sharing and Third Parties

We do not sell your personal data. We may share data with:

• Service Providers: Cloud hosting, payment processors, and analytics providers who process data on our behalf under strict data processing agreements.
• Legal Authorities: Law enforcement or regulatory bodies when required by law, court order, or to protect our legal rights.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred as part of the transaction.

We use the following third-party services:

• Google Analytics (website usage analytics)
• Facebook Pixel (marketing and retargeting)
• WhatsApp Business API (customer communication)

7. Data Retention

We retain your personal data for as long as necessary to:

• Provide our services during the active period of your account.
• Comply with legal obligations (typically 3–7 years under Indian law).
• Resolve disputes and enforce our agreements.

Device location history is retained for a maximum of 90 days from each data point. After account closure, personal data is deleted or anonymized within 30 days, unless required by law.

8. Your Rights under DPDP Act 2023

Under the Digital Personal Data Protection Act 2023, as a data principal (individual whose data is processed), you have the right to:

• Access: Request a summary of personal data we hold about you.
• Correction: Request correction of inaccurate or incomplete data.
• Erasure: Request deletion of your personal data, subject to legal retention requirements.
• Grievance Redressal: Raise a complaint with our grievance officer.
• Nominate: Nominate another person to exercise rights on your behalf in the event of death or incapacity.

To exercise any of these rights, contact us at: 01866-882120 or WhatsApp.

9. Cookies Policy

Our website uses cookies to improve your browsing experience. Types of cookies we use:

• Essential Cookies: Required for the website to function properly.
• Analytics Cookies: Google Analytics cookies to understand traffic patterns.
• Marketing Cookies: Facebook Pixel cookies for advertising.

You can control cookie preferences through your browser settings. Disabling cookies may affect some website functionality.

10. Data Security

We implement appropriate technical and organizational security measures including:

• SSL/TLS encryption for all data transmitted to/from our platform.
• Encrypted storage of sensitive personal data and credentials.
• Role-based access controls ensuring only authorized personnel can access personal data.
• Regular security audits and vulnerability assessments.

However, no internet-based system is 100% secure. We cannot guarantee absolute security of your data.

11. Children's Privacy

Reiod Locker services are not directed at children under 18 years of age. We do not knowingly collect personal data from minors. If we become aware of such collection, we will delete the data promptly.

12. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or applicable law. We will notify you of significant changes via in-app notice or email. Continued use of the platform after changes take effect constitutes your acceptance.

13. Grievance Officer

In accordance with the Information Technology Act, 2000 and the DPDP Act 2023, we have designated a Grievance Officer for privacy-related concerns:

• Contact: Reiod Locker Grievance Team
• Address: Mamudpur, Ambikapur, North 24 Parganas, West Bengal, India – 743251
• Phone / WhatsApp: +91 85138-72639
• Facebook: facebook.com/reiodlocker
• Response Time: Within 30 days of receiving the complaint.