This Website https://emeraldfin.com/, and other related internet-based applications (collectively referred to as “website” or “services” or “Platform”) is owned and operated by Emerald Finance Limited (formerly known as Emerald Leasing, Finance and Investment company Ltd.), (hereinafter referred to as “We” or “Us” or “Our” or “Emerald”), a Company incorporated under Companies Act, 1956 and having its registered office at SCO 7 Industrial Area, Phase 2 Chandigarh -160002.
This Privacy Policy gives YOU (“You” or “Your” or “user” or “customer”), the user of the website https://emeraldfin.com/ and its associated internet-based applications details behind the collection of your information and its usage as well as the manner in which we collect, use, store and share information about you. You are advised to read this privacy policy along with and in conjunction with the https://emeraldfin.com/terms-and-conditions-loan-agreement/ and other information on the website/Platform.
You are also advised to please take note that any statements made on the Emerald website/Platform shall not be construed as an offer or promise for grant of any financial services.
This Privacy Policy has been prepared in compliance with:
1. Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011;
2. Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021
3. Guidelines on Digital Lending issued by the Reserve Bank of India (RBI), 2022;
4. Other applicable acts, regulations and rules which require the publishing of a privacy policy for handling of or dealing in personal information including sensitive personal data or information and all applicable laws, regulations, guidelines provided by applicable regulatory authorities including but not limited to the RBI.
1. CONSENT
You hereby expressly consent to provide the information that may be required in relation to the Services (as defined below) being rendered by us. You acknowledge that we shall collect the information detailed under this Privacy Policy to facilitate lending &non-lending services by partnering with various financial lenders, third parties, service providers, etc based on your requirement to avail such Services (“Services”).
Emerald will only be using the information for providing the Credit facility/Loans and Services to you.
In order to avail any Services being provided by Emerald by itself or in partnership with other third parties it is important that YOU READ, UNDERSTAND, ACKNOWLEDGE AND UNCONDITIONALLY AGREE TO BE BOUND BY THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY.
IF YOU DO NOT AGREE TO THIS POLICY OR ANY PART THEREOF, PLEASE DO NOT USE/ ACCESSTHE PLATFORM OR ANY PART THEREOF.
For the users consenting to continue accessing the website and avail the services we offer, this Privacy Policy explains our policies and practices regarding the collection, use, and disclosure of your information.
2. INFORMATION COLLECTED AND USED BY EMERALD
This section describes the categories of information that Emerald Finance Limited (“Emerald”, “We”, “Us”, “Our”) may collect about You and the manner in which such information is used. The information collected is strictly limited to what is necessary for providing lending and non-lending financial services, complying with applicable laws, preventing fraud, and improving platform functionality.
The information collected by Emerald is broadly categorised into:
(A) Information Provided Directly by You
(B) Information Collected Automatically or With Your Explicit Consent Through Device or Platform Access
A. INFORMATION PROVIDED DIRECTLY BY YOU
We may collect information that You voluntarily provide while accessing or using the Platform, including but not limited to:
1. Information submitted while filling forms on the Website, Mobile Application, or associated internet-based applications.
2. Information shared during communication with Emerald through email, chat, telephone calls, or other communication channels.
3. Information provided at the time of registration or onboarding to avail any Services, including loan or credit facilities.
4. Personal details such as:
o Full name
o Gender
o Date of birth
o Residential and correspondence address
o Mobile number and email address
o Username and password
5. KYC and identity-related information including:
o PAN card
o Proof of possession of Aadhaar card (with Aadhaar number masked or redacted)
o Address proof and identity proof
o Selfie or photograph for identity verification
6. Financial and employment-related information such as:
o Employer name
o Salary or income details
o Bank account details
o Bank statements
o Credit information and repayment history
7. Information generated through your usage of the Platform, including transaction history, service requests, and interaction logs.
This information is used for user identification, regulatory compliance, credit assessment, service delivery, customer support, internal audits, and risk management.
B. INFORMATION COLLECTED WITH YOUR CONSENT OR AUTOMATICALLY THROUGH DEVICE / PLATFORM ACCESS
Subject to Your explicit consent and device permissions, Emerald may collect and process the following categories of information:
1. Device & Technical Information
We may collect information about the device used to access the Platform, including:
• Device type, hardware model, operating system, and version
• Network information such as IP address, Wi-Fi status, mobile network state
• Application installation data and referral information
• Crash logs, diagnostic data, and performance metrics
This information is used to ensure platform security, prevent fraud, improve app performance, and troubleshoot technical issues.
2. Location Information
With Your permission, Emerald may collect:
• Approximate location (such as network-based location)
Location data is collected solely for:
• Address verification
• Fraud prevention
• Regulatory and KYC compliance
• Risk assessment
Emerald does not track real-time movement or collect continuous background location data.
3. Camera Access
With Your consent, the Platform may access the device camera for:
• Capturing photographs or selfies for identity verification
• Scanning and uploading KYC documents
• Conducting Video KYC as required under applicable regulations
Camera access is enabled only during user-initiated actions and is not used in the background.
4. Microphone & Audio Recording
The Platform may request microphone access to:
• Enable Video KYC interactions
• Facilitate two-way communication with authorised representatives
Audio recordings, where applicable, are retained strictly for regulatory, quality assurance, and fraud prevention purposes.
5. SMS Access
With Your explicit permission, Emerald may access SMS data limited strictly to:
• Reading one-time passwords (OTPs) for authentication
• Identifying financial transactional messages from verified alphanumeric senders
No personal, private, or non-financial SMS content is accessed, stored, or analysed.
6. Biometric Information
The Platform may support biometric authentication features such as fingerprint or facial recognition to enhance login security.
Biometric data is processed locally on the device and is neither stored nor transmitted to Emerald’s servers.
7. Notifications & Background Services
The Platform may send push notifications and alerts related to:
• Transaction updates
• Service communications
• Account-related notifications
Permissions such as vibration, wake-lock, and notification access are used solely to ensure timely and reliable service delivery.
8. Local Storage & App State Data
The Platform may use local storage and cached data to:
• Maintain user sessions
• Improve app loading speed and performance
• Preserve user preferences
No personal data is accessed from device storage beyond what is required for Platform functionality.
9. Cookies & Similar Technologies
Emerald may use cookies and similar technologies on its Website to:
• Improve user experience
• Analyse platform usage
• Enhance security
Users may control cookie preferences through browser settings; however, disabling cookies may affect certain features.
10. Call Recording
Calls made to or from Emerald may be recorded for:
• Quality assurance
• Staff training
• Fraud prevention
• Regulatory compliance
11. Social Login & Feedback
The Platform may allow optional social or email-based login mechanisms solely for authentication and feedback purposes. Emerald does not access private content or communications associated with such accounts.
12. EXPRESSLY EXCLUDED DATA ACCESS
It is expressly clarified that Emerald does not access:
• Contact lists
• Call logs
• Personal files or media
• Telephony functions beyond OTP verification
• Background audio or video without user action
C. OVERARCHING PRINCIPLES
• All data collection is purpose-driven and consent-based
• Data is processed in accordance with applicable laws, RBI guidelines, and industry best practices
• Information is retained only for legally permissible durations
• User privacy and data security are treated as paramount
D. Retention of information collected: The information collected from you will be retained during the (i) validity of your Account and for the purpose of submission of such information, (ii) As consented by you while creating your User Account (iii) As required by any regulatory norms including but not limited to the norms prescribed under Prevention of Money Laundering Act, 2002, as per
Directions/Circulars/Notifications of RBI, and Guidelines for Digital Lending, 2022 prescribed by the RBI , as amended from time to time/any statutory modification thereto, or re-enactment thereof..
11. We ask visitors to our site to use their social media logins (Facebook, Twitter, Gmail) to provide customer reviews and feedback on our site.
12. It is expressly stated that we are not accessing mobile phone resources like file and media, contact list, call logs, telephony functions, etc.
3. PURPOSE OF INFORMATION COLLECTED BY EMERALD:
Apart from section 2 where we describe the information we collect and how we use the information we collect, we may also use the information we collect for the following purposes:
(a) To provide products or services you have requested.
(b) To provide information to our partners to assist in making credit decisions about you.
(c) To help investigate violations of our terms of use or to defend against legal claims.
(d) To disclose the information under special circumstances such as compliance with the applicable local law, court summons, court orders, requests/order from legal authorities or law enforcement agencies requiring such disclosure.
(e) Search credit bureaus, generate credit reports and fraud prevention agencies.
(f) To get in touch with you when necessary and contact you by email, SMS, letter, telephone or in any other way about our products and services.
(g) To identify, prevent, detect or tackle fraud, money laundering, terrorism and other crimes.
(h) To form a view of your credit worthiness, as per Emerald’s policies and to identify, develop or improve products that may be of interest to you.
(i) Provide information to independent external bodies such as governmental departments and agencies, universities and similar to carry out research.
(j) Perform other administrative and operational actions including the testing of systems.
(k) Trace your whereabouts for the purpose of on-boarding / KYC (know your customer) requirements.
(l) Recover any payments you owe to Emerald.
(m) To show you advertisements.
(n) Contact you as a survey respondent.
(o) To maintain records under applicable law or a may apply to pursuant to agreements executed by Emerald.
(p) Carry out, monitor and analyse our business, carry out market research, business, and statistical analysis and also direct our efforts for product improvement.
(q) Carry out process review and audits under regulatory framework.
(j) Details required for administration or services and product improvement.
(k) Record and/or monitor calls if Emerald feel necessary for quality checks and staff training. Such recordings may also be used to help Emerald combat fraud.
(r) Location information – for validating your address and to increase the chances of your loan approval. These accesses are for the purpose of on-boarding/ KYC (know your customer) requirements.
(s) Information about Apps and Accounts – for credit profile enrichment.
(t) to avail identity verification services.
(u) To generate and maintain User profiles, to provide personalised features, to facilitate collection activities, to maintain regular communications with the User.
(v) To use/modify/display, distribute and create new material from the information you provide.
4. DATA RETENTION AND DELETION
We at Emerald, promise to protect your personal data from unauthorised access, misuse, and disclosure using the right security measures based on the type of data and how we are processing the same. We retain information about you to provide a seamless experience, to contact you in case of support required and about your account, to detect, mitigate, prevent, and investigate fraudulent or illegal activities during the course of the Services. We retain your data for as long as necessary based on statutory requirements and to provide you with our services. We may also retain and use your basic personal information inter alia as name, contact number, transactional details and address details as necessary to comply with our legal obligations, resolve disputes, send you notifications about dues or past dues that you owe to Emerald and enforce our agreements which shall always be in accordance with applicable laws.
5. PROCEDURE FOR DATA DESTRUCTION AND REMOVAL OF USER DETAILS FROM THE RECORD:
User desirous of having his/her name and other details removed from the records of Emerald, on receiving the User’s request, Emerald shall, subject to the terms mentioned in section 4 and extant acts, rules, regulations, supervisory body/ies guidelines, directions, circulars, notification, as amended from time to time/any statutory modification thereto, or re-enactment thereof, modify, remove and/delete such information. Once the requested action has been taken, Emerald will inform you via email or call, as per the user’s preference. However, you may not be able to use our services after deletion.
6. SPECIFIC CONSENT
A. You consent and grant us authority to share your information with third parties to
1. provide the product or service you have requested;
2. enable them to contact you or to certain service partners in order to respond to your queries / comments or to resolve service issues and to serve you better and
3. to collect information about you as mentioned in section 2 of this Privacy Policy and use the same for those purposes mentioned in sections 2 & 3 of this Privacy Policy.
B. By using the Website/Services/Platform you authorise us, our affiliates & our associate partners to contact you via email or phone call or sms and offer you their services/ product, imparting product knowledge, offer promotional offers running on their websites & offers offered by the associated third parties. Irrespective of the fact if you have also registered yourself under DND or DNC or NCPR service, you still authorise us to give you a call from Emerald& its associates/partners for the above-mentioned purposes.
C. By providing information, you automatically agree, or promise that the owner of such information has expressly agreed to allow or licence, as the case may be, us to use the information in the manner set out in this Privacy Policy, without the payment of any fees, to the extent permitted by law, also use, licence, reproduce, distribute disclose, and aggregate, non-personally identifiable information that is derived through your use of the App and you hereby provide consent for the same.
D. You can revoke consent already granted to collect personal data at any point in time on your device by using the privacy controls available to you. Please note however that this might impact our ability to render our services to you.
7. SHARING OF INFORMATION
Emerald will not rent, sell or share User information and will not disclose any of the User’s personally identifiable information to third parties (apart from the third parties whose details are mentioned in the links provided herein. Click here and here for a full list), except when the disclosure is
(a) pursuant to obtaining the User’s permission
(b) in connection with disclosure to financial institutions and banks
(c) in connection with the services being rendered through the Platform
(d) help investigate, prevent or take action regarding unlawful and illegal activities
(e) special circumstances such as compliance with court orders
(f) to enforce your contractual obligations to us
8. SECURITY SAFEGUARDS AND ONGOING VIGIL:
Emerald intends to protect your information and to maintain its accuracy as confirmed by you. We implement reasonable physical, administrative and technical safeguards to help us protect your information from unauthorised access, use and disclosure. For example, we encrypt all information when we transmit over the internet. We also require that our registered third-party service providers protect such information from unauthorised access, use and disclosure.
Emerald has stringent security measures in place to protect the loss, misuse and alteration of information under control. We endeavour to safeguard and ensure the security of the information provided by you. We use Secure Sockets Layers (SSL) based encryption, for the transmission of the information, which is currently the required level of encryption in India as per applicable law.
We aim to protect from unauthorised access, alteration, disclosure or destruction of information we hold, including:
1. We use encryption to keep your data private while in transit;
2. We offer security feature like an OTP verification to help you protect your account;
3. We regularly review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorised access to our systems;
4. We restrict access to personal information to our employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations;
5. Compliance & Cooperation with Regulations and applicable laws;
6. We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.
However, we do not warrant that such User information may not be misused in the event our safeguards and protocols are breached by a malicious third-party. Your use of the Platform is at your sole risk and discretion. You shall be the custodian of your password and comply with the applicable terms mentioned on the Website/Platform in this regard., We are not liable to actions of other users with whom you may choose to share your information. The collection, usage, and sharing of User information are in compliance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and other applicable laws.
9. STANDARDS FOR HANDLING DATA BREACHES:
While Emerald invests in best in class Data Safety and Security Standards, in the improbable event of a data breach; Emerald will activate its Incident Management protocol to mitigate and safeguard our user’s data. Furthermore, Emerald shall inform and update its users as prescribed by the prevalent guidelines at the time.
10. PROCEDURE FOR CORRECTING INACCURACIES IN YOUR INFORMATION:
In the event that any Personal Information provided by You is inaccurate, incomplete or outdated then You shall have the right to provide Us with the accurate, complete and up to date data and have Us rectify such data at Our end immediately. We urge You to ensure that You always provide Us with accurate and correct information/data to ensure Your use of Our Services is uninterrupted. In case of modification of Personal Information, Users will be required to furnish supporting documents relating to change in Personal Information for the purpose of verification by Emerald.
11. CHANGES IN PRIVACY POLICY:
Our Privacy Policy might change from time to time, and Emerald will provide notice of it on your email address linked to your Account or can be seen by you on our Website.
12. INCORPORATION OF PRIVACY POLICY TO THE TERMS OF USE:
This Privacy Policy is incorporated to the Terms of use (Terms) and other specific terms of this Website/Services/Account.
13. CONTACT:
For any information regarding the Privacy Policy, please contact https://emeraldfin.com/contact/