Privacy Policy

JUST RUPEE

A Digital Lending Platform of Sehgal Televisions Private Limited.

RBI-Registered Non-Banking Financial Company

I. INTRODUCTION

This Privacy Policy (“Policy”) explains how Sehgal Televisions Private Limited, a Non-Banking Financial Company (NBFC) registered with the Reserve Bank of India, operates its digital lending platform under the brand “Just Rupee” (the “Platform”), and how it collects, uses, stores, shares and protects the personal information of anyone who visits or transacts on the Just Rupee website, mobile application, or any related digital service.

This Policy has been prepared having regard to:

• Section 43A of the Information Technology Act, 2000, read with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011;
• The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021;
• The Digital Personal Data Protection Act, 2023, and the rules framed under it as notified from time to time; and
• The Reserve Bank of India’s Digital Lending Directions, 2025, and other applicable guidelines issued by the RBI from time to time.

By using the Just Rupee Platform, you agree that your personal information may be collected, used and disclosed on the terms described in this Policy. If you are not comfortable with any part of this Policy, please do not use or access the Platform. Any question about this Policy may be sent to care@justrupee.com.

II.  DEFINITIONS

For this Policy, the terms below carry the meanings set out against them:

1. “We”, “Our”, “Us” refer to Just Rupee, the digital lending platform of Sehgal Televisions Private Limited.
2. “Platform” refers to the Just Rupee website (www.justrupee.com), its mobile application, and every associated digital interface or service.
3. “User”, “You”, “Your” refers to any person who visits, registers on, or otherwise uses the Just Rupee Platform.
4. “Personal Information” means information relating to a natural person which, on its own or together with other information, can identify that person.
5. “Sensitive Personal Data or Information (SPDI)” includes financial details, passwords, biometric information, and any other category the law treats as sensitive.
6. “Consent” means a clear, freely given, specific, informed and unambiguous indication of your agreement to a particular processing activity.
7. “Lender” means Sehgal Televisions Private Limited, acting as the RBI-registered NBFC that sanctions and disburses loans to eligible users through the Just Rupee Platform. Every lending decision is taken directly by Sehgal Televisions Private Limited.

III. CONSENT

By registering on, or otherwise using, the Just Rupee Platform, you give your free, specific, informed and unambiguous consent to the collection, storage, processing, use and disclosure of your personal information and sensitive personal data in the manner set out in this Policy. This consent is taken in a manner consistent with the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000, and the RBI’s Digital Lending Directions, 2025.

Your consent is recorded through verifiable means, such as OTP confirmation, electronic acceptance forms, and in-application prompts, depending on the category of data involved. No personal, financial or device data is collected without your specific consent for that category.

Your consent, in particular, covers:

1. Collecting the information needed for KYC verification, credit assessment, and underwriting of the loan products offered through Just Rupee.
2. One-time access to your device camera and microphone, used only for video KYC or e-KYC as required under RBI guidelines.
3. Access to your credit bureau data and, where relevant, financial SMS metadata, each time only after your specific and recorded consent.
4. Secure processing of your personal data by Just Rupee to deliver the services you have requested or already availed.

You may withdraw your consent at any time by writing to our Grievance Officer at gro@justrupee.com. Please note that:

• Withdrawing consent does not undo the lawfulness of anything already processed before the withdrawal;
• Withdrawing consent for essential information, such as KYC details or repayment records, may limit your ability to use certain features and does not remove any obligation tied to an active loan account;
• We may continue processing your data to the extent needed to service an active loan, meet a legal or regulatory requirement, or defend a legal claim.

TO USE ANY JUST RUPEE SERVICE, IT IS IMPORTANT THAT YOU READ, UNDERSTAND AND AGREE TO THIS POLICY IN FULL. IF YOU DO NOT AGREE WITH ANY PART OF IT, PLEASE DO NOT ACCESS, DOWNLOAD OR USE THE PLATFORM.


IV.  COLLECTION OF INFORMATION

Just Rupee collects information from you only so that it can provide regulated digital lending services in a manner consistent with Indian law, including the RBI’s Digital Lending Directions, 2025, and the Information Technology Act, 2000. The categories of information collected are set out below.

Personal and Identity Information

When you register on or use the Platform, we collect:

• Your full name, date of birth, gender and photograph;
• Your email address, mobile number and residential address, including postal code;
• Your PAN, Aadhaar (masked wherever applicable), and other KYC documents required under RBI rules;
• Details of your employment and income;
• Your bank account number and IFSC code, needed to disburse and collect repayments on your loan.

Financial and Credit Information

For credit assessment and underwriting, we obtain:

• Your credit report and credit score from authorised credit information companies, such as CIBIL, Experian, CRIF High Mark and Equifax, with your specific consent;
• Limited financial SMS metadata, used only for verification and credit evaluation. We do not read or store your personal messages, or any OTP sent by a third party.

Device and Technical Information

When you access the Platform, we may collect:

• Your device model, operating system and available storage, used only for fraud detection and secure sign-in. We do not collect permanent device identifiers such as IMEI numbers;
• IP address, browser type, referring or exit page, and log data generated as you use the Platform, used for analytics and security;
• Details of applications installed on your device, including the app name, package name, install and update time, and version, used solely for fraud detection, underwriting and preparing suitable credit offers. This information may be collected even when the app is not actively open;
• Basic phone state information, limited to confirming the active SIM and network at the time of onboarding and disbursement, so that we can verify the transaction belongs to the rightful user.

Location Information

We collect your device location on a one-time basis to:

• Check whether your location is serviceable;
• Support address verification and KYC checks;
• Strengthen our credit risk and fraud assessment.

Location is collected only with your prior, explicit consent, and is never gathered while the application is running in the background.

Camera and Microphone Access

We request one-time camera access to capture your KYC documents and a selfie for identity verification, and microphone access solely to enable two-way conversation during video KYC. Audio recorded during a video KYC session may be kept to meet regulatory requirements.

Cookies and Log Files

The Platform uses cookies to recognise returning users, keep sessions secure, personalise your experience, and understand how the Platform performs. Information collected this way is stored securely and treated as confidential. You may turn off cookies through your browser settings, though certain features may then stop working properly.

Some pages may also carry web beacons, used alongside cookies to compile aggregated usage statistics, including within our email communications, to gauge their effectiveness. Just Rupee does not track you across other websites and does not permit third-party behavioural advertising tools on the Platform.

Information We Do Not Collect

Just Rupee does not collect or store biometric data. We do not access your contact list or call logs, and we do not read personal messages or OTPs other than OTPs we ourselves send for Platform-related purposes.

V. WHY WE COLLECT YOUR INFORMATION

We use the information collected from you strictly for the following purposes:

1. To verify your identity and complete KYC as required under applicable law;
2. To assess your creditworthiness and process your loan application, including underwriting, risk evaluation, and determination of eligibility;
3. To disburse loan amounts and enable repayment through the appropriate channels;
4. To operate, maintain, improve and personalise the Just Rupee Platform;
5. To keep you informed about your account, loan status, repayment schedule and service updates;
6. To send promotional communications and offers where you have given consent, which you may withdraw at any time;
7. To detect, prevent and investigate fraud, cybercrime and unauthorised activity;
8. To meet our legal, regulatory and statutory obligations;
9. To resolve disputes, handle complaints and enforce contractual obligations;
10. To study usage patterns and improve our services, features and products through data analytics.
11. Just Rupee does not use your personal data for anything outside the purpose for which it was consented, unless required by law or with your renewed, explicit consent. We do not sell, rent, or trade your personal data under any circumstances.
    
    VI. DISCLOSURE AND SHARING OF INFORMATION

Just Rupee shares your personal information only where necessary, strictly for the purposes described in this Policy, and under appropriate confidentiality safeguards. We do not hand over your personal data to unrelated third parties for commercial gain.

Your information may be shared with:

1. Credit Information Companies regulated under the Credit Information Companies (Regulation) Act, 2005, such as CIBIL, Experian, CRIF High Mark and Equifax, for credit assessment;
2. Third-party service providers, such as e-KYC vendors, e-sign providers, account aggregators and payment gateways, engaged only to deliver the services you have requested;
3. Government departments, regulators, courts and law enforcement agencies, where disclosure is required by law, court order or regulatory direction;
4. Technology and device-intelligence partners engaged for identity verification, fraud detection and underwriting, under appropriate data processing and confidentiality agreements;
5. Recovery and collection agents engaged in line with the RBI’s Fair Practices Code, for the collection of dues under an active loan.
6. Every third party with whom your information is shared is contractually bound to use it only for the purpose it was disclosed, and to apply reasonable security measures to protect it.

Personal information may also be disclosed:

• When required by a court order, statutory authority, government body, or law enforcement agency;
• To protect the rights, property or safety of Just Rupee or Sehgal Televisions Private Limited;
• In connection with a merger, acquisition, restructuring or amalgamation involving Sehgal Televisions Private Limited, provided the receiving entity remains bound by this Policy with respect to your information.
  
  

VII. DATA SECURITY

We take the security of your personal information seriously and have put in place reasonable technical, administrative and organisational measures to guard it against unauthorised access, use, disclosure, alteration or loss.

Our safeguards include:

1. Encryption of data in transit using SSL or an equivalent protocol;
2. Role-based access controls, so that only authorised personnel can view personal data, strictly on a need-to-know basis;
3. Regular vulnerability assessments, firewalls, anti-malware tools, and intrusion detection and prevention systems;
4. OTP-based authentication to protect your account;
5. Encryption and key management for stored data;
6. Segregation of systems and duties, supported by documented, role-based access controls.

All information collected from you is stored on servers located in India, consistent with the data localisation requirements under the RBI’s Digital Lending Directions, 2025, and other applicable law.

You are responsible for keeping your own account credentials safe. Just Rupee is not liable for unauthorised use of your account arising from your failure to protect your login details.

If your personal data is ever affected by a security incident, we will act promptly to prevent further misuse and reduce any harm, and will make reasonable efforts to notify you electronically so that you can safeguard your interests, in line with applicable law.

VIII. HOW LONG WE KEEP YOUR DATA

We retain your personal information only for as long as necessary for the purpose it was collected, or as required by applicable law.

Specifically:

1. If you registered on the Platform but never availed a loan or service, your profile data is retained for six years from the date of your last submission or activity, whichever is later;
2. If you have availed a loan or service through Just Rupee, your data is retained for ten years from the date the service ended, or your last activity, whichever is later;
3. Data may be kept for longer where required by law, or where needed to settle a dispute, enforce a contract, look into suspected fraud, or meet a regulatory obligation.

Your data may also sit temporarily in backup systems for disaster recovery, with access restricted and deletion scheduled under our internal retention protocols.

You may write to our Grievance Officer at gro@justrupee.com to request deletion of your personal data. Deletion requests are taken up only once every active service, transaction and loan account linked to you has been closed. On receiving a valid request, we will erase or anonymise your data within thirty days, subject to any retention duty under applicable law.

IX. YOUR RIGHTS

You have the following rights over the personal data Just Rupee holds and processes about you:

Right to Access and Correction

You may ask to see the personal information we hold about you, and request that we correct anything inaccurate, incomplete or out of date. Changing your personal details may require supporting documents for verification.

Right to Withdraw Consent

You may withdraw your consent for the collection, use or sharing of your personal data at any time by writing to our Grievance Officer at gro@justrupee.com. Once we receive a valid withdrawal request, we will stop processing your data for that purpose, except where the law, a regulatory duty, or the servicing of an active loan requires otherwise.

Right to Deletion

You may ask us to delete your personal data, subject to Section VIII of this Policy. We will not act on a deletion request while any service, loan or transaction linked to you remains active.

Right to Opt Out of Marketing

You may stop promotional messages at any time by writing to care@justrupee.com, or using the opt-out option on the Platform. This will not affect messages about your account, loan status, or any legal requirement.

Managing Device Permissions

You may change the permissions given to the Just Rupee application at any time through your device settings. Restricting certain permissions may limit your access to some features or services.

Right to Report a Security Concern

If you suspect your personal information has been misused, you may report it to our Grievance Officer within ten days of becoming aware of it.

X. LINKS TO OTHER WEBSITES

The Just Rupee Platform may carry links to third-party websites or applications that we do not operate or control. These are provided only for your convenience. We do not review, endorse, or take responsibility for the privacy practices, security, or content of such third-party platforms.

If you share personal information with a third-party website reached through Just Rupee, that information will be governed by that website’s own privacy policy. Just Rupee is not responsible for anything that occurs on a third-party site, or for your reliance on information found there. Please review the privacy policy of any such platform before sharing personal or financial details.

XI. CHILDREN’S PRIVACY

The Just Rupee Platform is meant for adults and is not directed at anyone under eighteen years of age. We do not knowingly collect personal information from minors, and our KYC and eligibility process requires documentary proof of age at the time of onboarding.

If a parent or guardian believes their child has shared personal information with us, please contact us immediately at care@justrupee.com, and we will act promptly to delete or anonymise that information.

By using the Just Rupee Platform, you confirm that you are at least eighteen years old and legally able to enter into a binding contract under Indian law.

XII. CHANGES TO THIS POLICY

We may update this Policy from time to time to reflect changes in law, regulatory requirements, or how we conduct business. Updates will be posted on the Just Rupee Platform and, unless stated otherwise, take effect as soon as they are posted. We encourage you to review this Policy periodically.

Continuing to use the Just Rupee Platform after a revision to this Policy means you accept the updated Policy.

This Policy is reviewed by the management of Sehgal Televisions Private Limited as and when needed. Any change required by a shift in applicable law or regulation will be placed before the Board of Directors of Sehgal Televisions Private Limited for approval at its next following meeting.

XIII. GENERAL PROVISIONS

This Policy is governed by, and will be read in accordance with, the laws of India. Any dispute arising out of, or connected to, this Policy falls under the exclusive jurisdiction of the courts at New Delhi.

If any part of this Policy is found invalid or unenforceable under applicable law, that part will be severed, and the rest of the Policy will continue to apply in full force. Where there is any conflict between language versions, the English version will prevail. Section headings are included only to aid navigation and do not affect how any clause is interpreted.

Nothing on the Just Rupee Platform amounts to financial, legal, tax or professional advice. You should verify information independently and consult your own advisors where needed. Just Rupee and Sehgal Televisions Private Limited will not be responsible for any direct, indirect, incidental or consequential loss, including loss of profit, data or business opportunity, arising from your use of, or reliance on, the Platform. We do not guarantee that the Platform will always be available, error-free, or free of viruses or other harmful components. You are responsible for taking adequate precautions on your own systems before downloading anything from the Platform.

XIV. GRIEVANCE REDRESSAL

Just Rupee has appointed a Grievance Officer, in line with applicable law, to address complaints and queries relating to the processing of personal data and any dispute arising out of this Policy.

Grievance Officer: Just Rupee (Sehgal Televisions Private Limited)

Email: care@justrupee.com / gro@justrupee.com

Website: www.justrupee.com

Working Hours: Monday to Friday, 10:00 AM to 6:00 PM

We aim to acknowledge and respond to all grievances within 48 to 72 hours of receipt. If you are not satisfied with the resolution provided, you may escalate the matter to the appropriate regulatory authority, including the Reserve Bank of India’s Integrated Ombudsman, at https://cms.rbi.org.in.

You may also write to our Grievance Officer to exercise any of your data rights, including access, correction, or deletion of your personal data, subject to the terms of this Policy and applicable statutory obligations.