Privacy Policy — Payledger

This Privacy Policy explains how Opticap Holding India Private Limited (CIN: U70200DL2023PTC418996) ("Opticap", "we", "us"), operating the Payledger platform at payledger.in (the "Platform"), collects, uses, shares, and protects your personal data. It is published in accordance with the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the Information Technology Act, 2000 and rules thereunder, and the Reserve Bank of India (Digital Lending) Directions, 2025 ("Digital Lending Directions").

Payledger acts as a lending service provider to Nipun Projects and Finance Private Limited (CIN: U74899DL1993PTC054883), an NBFC registered with the Reserve Bank of India under Certificate of Registration No. B-14.01-787 (the "Lender"). Where your data is processed in connection with a credit facility, the Lender acts as a data fiduciary for lending decisions and loan servicing, and Opticap processes data on the Lender's behalf and for the purposes described below.

1. Data we collect

Category	Examples	Source
Identity & KYC	Name, PAN, entity name, CIN/registration details, address, photographs, KYC documents	You; DigiLocker/CKYC with your consent
Contact	Phone, email, business address	You
Business & trade	GSTIN, GST returns (GSTR-1/3B), invoices, purchase orders, buyer/supplier relationships, payment history	You; GST systems via GST Suvidha Providers, with your consent
Financial	Bank account details, bank statements, cash-flow data	You; RBI Account Aggregator framework, with your explicit consent
Credit information	Credit reports and scores of the entity and its promoters/guarantors	RBI-licensed credit information companies, with your consent
Technical	Device type, browser, IP address, log data, cookies	Automatically, when you use the Platform

In line with the Digital Lending Directions, we do not access your mobile phone contacts, call logs, files, or media. Any one-time access needed for onboarding (such as camera for KYC) is taken only with your explicit consent for that specific purpose.

2. How we use your data

To assess eligibility and process applications for credit facilities offered by the Lender;
To perform KYC, anti-money-laundering, and fraud checks as required by law;
To set up, maintain, and refresh your working-capital line, including ongoing monitoring of trade and repayment behaviour with your consent;
To service facilities: disbursals, repayments, statements, reminders, and collections;
To communicate with you about your application, account, and Platform updates;
To improve the Platform, develop credit models, and generate aggregated or anonymised analytics;
To comply with applicable law, regulatory directions, and lawful requests from authorities.

3. Consent

We process your personal data on the basis of your consent, obtained through clear, affirmative action, and for the specific purposes notified to you at the time of collection. You may manage or withdraw consent at any time by writing to us at the contact below or, for data obtained via the Account Aggregator framework, through your Account Aggregator. Withdrawal of consent may affect our and the Lender's ability to provide or continue services, and does not affect processing already carried out or processing required under law (for example, retention of loan records).

4. Sharing of data

We share your data only as needed and with appropriate safeguards:

The Lender and co-lenders: for credit assessment, sanction, disbursal, servicing, and collections;
Credit information companies: for credit reports and for reporting facility performance, as required under the Credit Information Companies (Regulation) Act, 2005;
Service providers: KYC/verification agencies, GST Suvidha Providers, Account Aggregators, cloud hosting, communication, payment, and analytics providers, bound by contractual confidentiality and security obligations;
Regulators and authorities: RBI, statutory bodies, law enforcement, or courts, where required by law;
Group entities and in corporate events: within the Opticap group for the purposes above, and in connection with a merger, acquisition, or restructuring, subject to this Policy.

We do not sell your personal data. Biometric data, if any, is never stored by us.

5. Storage, security, and retention

Your data is stored on servers located in India. We use reasonable security practices, including encryption in transit, access controls, and periodic reviews, to protect your data against unauthorised access, alteration, or disclosure. We retain personal data only as long as necessary for the purposes stated above or as required by law, including RBI record-keeping requirements applicable to the Lender; thereafter it is deleted or anonymised.

6. Cookies

The Platform uses cookies and similar technologies for essential functionality, session management, and analytics. You can control cookies through your browser settings; disabling them may affect Platform functionality.

7. Your rights

Under the DPDP Act, you have the right to:

Access a summary of your personal data and the processing activities;
Seek correction, completion, or updating of your data;
Seek erasure of data no longer necessary, subject to legal retention requirements;
Nominate an individual to exercise your rights in the event of death or incapacity;
Raise a grievance and, if unresolved, approach the Data Protection Board of India.

To exercise these rights, write to us at the contact below. We will respond within the timelines prescribed under applicable law.

8. Grievance Officer

Grievance Officer: Mr. Shreenivas Hegde
Opticap Holding India Private Limited
223, F.I.E., Patparganj Industrial Area, New Delhi, Delhi – 110092
Corporate Office: #448, 3rd Floor, 17th Cross Road, Sector 4, HSR Layout, Bengaluru, Karnataka – 560102
Email: grievance@optimoloan.com
Phone: +91 99641 64700

For grievances relating to a credit facility, you may also contact the Lender's Grievance Redressal Officer — details are on our Regulatory Disclosures page.

9. Changes to this Policy

We may update this Policy from time to time. Material changes will be notified on the Platform. The "Last updated" date reflects the current version.

Payledger is a brand of Opticap Holding India Private Limited. Lending is powered by Nipun Projects and Finance Private Limited, an RBI-registered NBFC (CoR No. B-14.01-787). Full regulatory disclosures are available on our Regulatory Disclosures page and at optimocapital.in/opticap-policy.