Privacy Policy

This page explains what information EMI Guard collects and how it is used, at a plain-language level. For the full data-handling terms a shop owner agrees to, see the User Agreement accepted during signup on the app.

Information we may process

  • Retailer name and business information.
  • Retailer contact details.
  • Customer name and mobile number.
  • Device model and IMEI, where necessary.
  • EMI schedule and payment status.
  • Device registration and management records.
  • Consent records and agreement versions.
  • Live photographs, only where justified and lawfully collected.
  • Security and audit logs.

Why a live photograph is taken

Where a live photograph is collected at the time of sale or registration, it is used only for identity verification of the retailer or customer, confirming the device-management consent was given by the person named in the record, security and fraud prevention, and as part of the retailer's own Know-Your-Customer (KYC) process for that sale. It is not used for any other purpose.

Purpose of processing

Information may be processed for:

  • Account creation and verification.
  • Device registration.
  • EMI schedule management.
  • Payment status updates.
  • Customer support.
  • Security and fraud prevention.
  • Legal and regulatory compliance.

Data protection

EMI Guard will implement reasonable security safeguards, access controls, retention limits and appropriate deletion procedures.

Data retention and deletion

Personal information will not be retained indefinitely. Records relating to an EMI sale (customer details, consent record, EMI schedule, payment history and any live photograph) are retained for as long as that sale remains active, and for [RETENTION PERIOD TO BE CONFIRMED - e.g. a fixed number of years] after the sale is fully paid off or closed, to meet accounting, dispute-resolution and legal-compliance needs. After that period, the record is deleted or anonymized unless a longer period is required by applicable law.

What a retailer can see

A retailer can see the records of its own customers and devices only - their name, mobile number, device details, EMI schedule, payment status and consent record. A retailer cannot see another retailer's customers or devices, and does not have access to this app's underlying server infrastructure or to other retailers' business data.

Requesting deletion of your information

A customer or retailer who wants their personal information corrected or deleted can send a request to the grievance contact below, stating what information the request relates to. The request will be reviewed and acted on within a reasonable time, except where a record must be kept to meet a legal, accounting or dispute-related obligation, in which case the reason will be explained.

Customer rights

Customers may exercise applicable rights relating to their personal information, including correction, access, grievance and erasure where applicable, through the grievance contact below.

What EMI Guard does not access

EMI Guard does not read a customer's personal photos, messages, contacts or other personal files stored on the device. Device management is limited to the registration, lock/unlock and check-in functions described on the EMI Protection page.

Legal framework

EMI Guard is a technology-based Android device management solution designed to help independent mobile retailers manage their own installment-based device sales. EMI Guard does not independently provide loans, finance devices, act as a bank or NBFC, or determine ownership of any device.

The Sale of Goods Act, 1930 provides the legal framework for contracts of sale and agreements to sell: Section 4 distinguishes a sale from an agreement to sell, Section 19 addresses the transfer of ownership according to the intention of the parties, and Section 25 addresses a seller's reservation of the right of disposal in specified circumstances. Where a genuine installment sale agreement lawfully reserves ownership until agreed conditions are fulfilled, the retailer's own contractual and proprietary rights may be relevant - the legal effect depends on the actual agreement and transaction.

The Indian Contract Act provides the framework for valid contracts, free consent and contractual remedies. Retailers are responsible for entering into valid installment agreements and obtaining informed customer authorization for device management, and are expected to provide clear payment terms, transparent notices, reasonable opportunities to resolve defaults and fair complaint-handling procedures. No contractual term should be used to defeat any non-waivable consumer right.

EMI Guard uses authorized, recorded device-management permissions. Availability of Device Owner, remote management, lock and Factory Reset Protection features depends on device compatibility, Android version and the applicable provisioning method - technical capability does not by itself establish a legal right to restrict a customer's device.

This page describes the general legal and technical framework relevant to EMI Guard. It is not a legal opinion or a guarantee that every device restriction is lawful in every transaction - the legality of any restriction depends on the nature of the sale, the actual agreement, customer consent, applicable laws and the specific circumstances. EMI Guard does not independently create ownership rights or authorize retailers to take actions prohibited by law.

Grievance Officer

Questions, complaints or grievances about this policy, or about how personal information is collected or used, can be sent to our Grievance Officer, at hello@apnabillpay.in. Every grievance will be acknowledged and addressed within a reasonable time.

Last updated: 11 November 2026.