DRAFT — for legal review. Not final. Do not rely on this document until approved by counsel.
Privacy Policy (DRAFT)
This Policy explains how personal data is handled in Thavana, provided by Twincord Technologies Pvt. Ltd., in line with India’s Digital Personal Data Protection Act, 2023 (“DPDP Act”).
1. Who is responsible for what
- Tenant (finance company / money lender): the data fiduciary for borrower, guarantor and staff data it enters. The Tenant decides why and how that data is used, and is responsible for notices, consent and lawful grounds toward its borrowers and for its lending activities and legal compliance.
- Twincord Technologies Pvt. Ltd.: the software provider and data processor, processing Tenant data only to provide the Service and on the Tenant’s instructions. For account and billing data of the Tenant itself, Twincord Technologies Pvt. Ltd. acts as fiduciary.
2. Data we process
- Tenant account data: company name, user names, mobile numbers, hashed passwords.
- Tenant-entered data: borrower details, loans, collections and receipts.
- Security data: login attempts, audit logs, IP address.
3. Security
Tenant data is logically isolated per company. Passwords are stored hashed. Sessions use signed, HTTP-only cookies.
4. Rights and grievance redressal
Under the DPDP Act, data principals may seek access, correction, erasure and grievance redressal. Borrowers should first contact the relevant Tenant. [Retention periods, sub-processors, breach notification and Grievance Officer details to be finalised by counsel.]