Privacy Policy — Enyayasetu

1. Introduction

This Privacy Policy (“Policy”) describes the manner in which Sulahkar Private Limited, a company duly incorporated under the laws of India (“Sulahkar”, “Company”, “we”, “our” or “us”), collects, receives, records, stores, organises, structures, accesses, retrieves, uses, processes, analyses, discloses, transfers, shares, protects, retains, anonymises, archives and otherwise handles personal data and related information in connection with the operation of Enyayasetu, its technology-enabled Online Dispute Resolution (“ODR”) platform, together with all associated websites, applications, portals, virtual hearing systems, case management systems, communication channels, digital infrastructure, support services and related technologies (collectively, the “Platform”).

Enyayasetu has been developed as a secure, technology-enabled dispute resolution ecosystem designed to facilitate the efficient, transparent, accessible, cost-effective and legally compliant resolution of disputes through digital and hybrid processes including negotiation, mediation, conciliation, arbitration, settlement facilitation, grievance redressal, expert determination and other dispute resolution mechanisms recognised under applicable law.

Sulahkar primarily functions as a technology facilitator, platform provider and administrator of digital infrastructure. The Platform enables disputing parties, financial institutions, banks, non-banking financial companies, insurance companies, fintech entities, government authorities, public bodies, corporate entities, legal representatives, mediators, conciliators, arbitrators, experts, witnesses and other authorised participants to engage in dispute resolution processes through secure digital systems.

The Company recognises that dispute resolution proceedings often involve highly confidential, commercially sensitive and legally protected information, including personal data, financial information, contractual documents, settlement communications, legal submissions, evidentiary records, hearing materials and privileged communications. Accordingly, the protection of privacy, confidentiality, procedural integrity, cybersecurity and responsible information governance constitutes a fundamental principle of the Platform's design, administration and operation.

This Policy has been prepared in accordance with the Information Technology Act, 2000, the rules framed thereunder, the Digital Personal Data Protection Act, 2023 (“DPDP Act”), applicable contractual obligations, industry standards, internationally recognised privacy principles and other applicable laws governing data protection, confidentiality, information security and dispute resolution.

By accessing, browsing, registering on, participating in proceedings through, uploading information to, communicating through or otherwise using the Platform, you acknowledge that you have read, understood and agreed to the terms of this Policy.

2. Role of Sulahkar and Enyayasetu

Enyayasetu is a technology-enabled Online Dispute Resolution platform operated and managed by Sulahkar. The Platform provides digital infrastructure, case management systems, communication tools, workflow automation systems, hearing management facilities, document management systems and related technological services to facilitate dispute resolution proceedings.

Unless expressly agreed otherwise in writing, Sulahkar does not act as legal counsel, advocate, attorney, authorised representative, arbitrator, mediator, conciliator, expert, adjudicator or decision-maker in relation to any dispute conducted through the Platform. Sulahkar does not provide legal advice, legal opinions or recommendations regarding the merits of disputes. The Platform merely facilitates the conduct and administration of proceedings by authorised participants and dispute resolution professionals.

The substantive conduct, determination and resolution of disputes remain the responsibility of the parties and the appointed dispute resolution professionals. Nothing contained in this Policy shall be construed as imposing responsibility upon Sulahkar for the outcome, validity, enforceability, merits or legal consequences of any dispute resolution proceeding.

3. Applicability of This Policy

This Policy applies to all personal data and information processed through the Platform, irrespective of whether such information is provided directly by users, obtained from institutional users, received from dispute resolution professionals, generated during proceedings or otherwise lawfully collected in connection with the Platform.

This Policy applies to all categories of users including individual users, disputants, complainants, respondents, customers of financial institutions, legal representatives, authorised agents, witnesses, mediators, conciliators, arbitrators, experts, institutional users, banks, NBFCs, insurance companies, fintech entities, government authorities, corporate organisations and any other persons whose information may be processed through the Platform.

4. Consent

By accessing or using the Platform, you expressly consent to the collection, storage, use, disclosure, transfer and processing of your personal data in the manner described in this Policy to the extent consent is required under applicable law.

You acknowledge that participation in dispute resolution proceedings may require the collection, review, exchange, retention and processing of personal data, financial information, identity records, communications, contractual documents, evidentiary materials, settlement proposals, hearing records and other information necessary for the administration and conduct of proceedings.

Where personal data relating to another individual is submitted to the Platform, the person providing such information represents and warrants that they possess all necessary authority, permissions, consents or other lawful basis required for such disclosure and processing.

You may withdraw consent where consent constitutes the lawful basis for processing by contacting Sulahkar through the contact details provided in this Policy. Withdrawal of consent shall not affect processing undertaken before such withdrawal and may affect Sulahkar's ability to provide services, maintain user accounts, conduct proceedings or comply with legal obligations.

5. Information We Collect

In connection with the operation of the Platform, Sulahkar may collect, receive and process various categories of information relating to users and participants. Such information may be collected directly from users, received from institutional clients, generated through Platform usage, obtained through communications, created during proceedings or otherwise lawfully acquired in connection with the services provided through the Platform.

• Personal identification information such as names, dates of birth, gender, nationality, photographs, signatures, government-issued identification details, tax identification numbers, passport details, driving licence information, voter identification information and other information required for identity verification and authentication.
• Contact information including residential addresses, correspondence addresses, email addresses, telephone numbers, mobile numbers, emergency contact details and communication preferences.
• Account and authentication information including usernames, encrypted passwords, multi-factor authentication information, security credentials, access logs, login history, account preferences and security settings.
• Information relating to disputes and proceedings including notices, complaints, claims, counterclaims, statements of defence, pleadings, legal submissions, affidavits, witness statements, settlement proposals, evidence, supporting documents, contracts, agreements, correspondence, awards, settlement agreements and any other materials submitted or generated in connection with a dispute resolution proceeding.
• Where proceedings are referred by institutional users, information relating to customer accounts, financial transactions, contractual relationships, dispute histories, account status, communications records, repayment information, policy information, claims information and grievance records.
• Financial information including payment details, billing information, transaction records, bank account details, settlement information, invoice information and fee-related records where necessary for service administration.
• Information relating to communications exchanged through the Platform including emails, messages, notifications, support requests, chat records, hearing communications and correspondence.
• Where virtual hearings are conducted, audio recordings, video recordings, transcripts, attendance records, screen-sharing information, chat communications and hearing notes.
• Technical and device-related information including IP addresses, browser information, device identifiers, operating systems, network information, language settings, session information, timestamps, access logs, diagnostic information and usage analytics.

6. Purposes of Processing

Sulahkar processes information for the purpose of establishing and administering user accounts, verifying identity, facilitating dispute resolution proceedings, enabling communications between participants, managing case workflows, conducting virtual hearings, maintaining records, ensuring procedural integrity, complying with legal obligations, protecting rights and interests, investigating security incidents, preventing fraud, improving services, conducting audits, maintaining business continuity and fulfilling contractual obligations.

Information may also be processed for dispute administration, appointment of neutrals, scheduling proceedings, issuance of notices, generation of procedural records, enforcement of Platform rules, customer support, grievance management, compliance monitoring, statistical analysis and service improvement.

7. Confidentiality of Dispute Resolution Proceedings

Sulahkar recognises confidentiality as a cornerstone of dispute resolution. Information submitted, generated or exchanged during dispute resolution proceedings is treated as confidential and is protected through legal, contractual, organisational and technical safeguards.

Access to dispute-related information is restricted to authorised individuals who require such access for legitimate purposes connected with the administration or conduct of proceedings.

Nothing contained in this Policy shall diminish or override confidentiality obligations arising under applicable law, arbitration agreements, mediation agreements, procedural rules, confidentiality undertakings, court orders, professional obligations or institutional rules governing dispute resolution proceedings.

Confidentiality obligations shall survive the conclusion of proceedings, closure of accounts and termination of Platform access.

8. Artificial Intelligence Governance

Sulahkar may utilise certain artificial intelligence technologies for limited internal operational purposes including software development support, documentation assistance, design assistance, productivity enhancement, compliance drafting and administrative efficiency.

No personal data submitted by users in connection with dispute resolution proceedings shall be intentionally processed through third-party artificial intelligence systems unless expressly authorised by applicable law, contractual arrangements or specific user consent.

Artificial intelligence systems are not used to decide disputes, determine rights, assess liability, evaluate evidence, recommend outcomes, issue awards, conduct mediations, render decisions or otherwise influence the substantive outcome of proceedings.

All dispute-related decisions remain under the exclusive control and responsibility of qualified human professionals.

9. Disclosure of Information

Sulahkar does not sell personal data.

Information may be disclosed where necessary to parties participating in proceedings, dispute resolution professionals, institutional users, service providers, payment processors, cloud hosting providers, technology vendors, auditors, professional advisers, regulators, governmental authorities, courts, tribunals, arbitral tribunals, law enforcement agencies or other persons authorised by law.

Any disclosure shall be limited to the extent reasonably necessary for the relevant purpose and shall be subject to appropriate confidentiality and security safeguards.

10. Security Practices

Sulahkar maintains comprehensive administrative, organisational, technical and physical safeguards designed to protect information against accidental loss, unauthorised access, disclosure, misuse, alteration or destruction.

Such safeguards may include encryption, secure communication protocols, access controls, multi-factor authentication, monitoring systems, audit logging, vulnerability assessments, penetration testing, backup systems, disaster recovery procedures, incident response mechanisms, vendor management controls and employee training programmes.

While Sulahkar implements commercially reasonable security measures, no system can guarantee absolute security. Users acknowledge the inherent risks associated with internet-based communications and electronic storage systems.

11. Data Retention

Information shall be retained only for as long as necessary to fulfil the purposes for which it was collected, including dispute administration, legal compliance, regulatory requirements, audit obligations, contractual commitments, enforcement of rights and legitimate business purposes.

Retention periods may vary depending upon the nature of the dispute, the requirements of institutional users, statutory limitation periods, judicial directives, regulatory obligations and contractual arrangements.

Upon expiry of applicable retention periods, information may be securely deleted, anonymised, archived or destroyed in accordance with Sulahkar's retention and disposal procedures.

12. Rights of Users

Subject to applicable law, users may have the right to obtain information regarding the processing of their personal data, seek correction or updating of inaccurate information, request erasure of personal data, withdraw consent, seek grievance redressal, nominate another individual to exercise rights on their behalf and exercise such other rights as may be available under applicable law.

Requests relating to personal data may be submitted using the contact details provided in this Policy.

13. Children's Privacy

The Platform is intended for persons competent to contract under applicable law and is not directed towards children. Sulahkar does not knowingly collect personal data directly from children except where such information becomes relevant to a dispute resolution proceeding and is lawfully submitted by authorised persons.

Where personal data relating to children is processed, enhanced safeguards and additional protections shall be implemented consistent with applicable legal requirements.

14. Data Protection Officer and Grievance Officer

Any questions, concerns, complaints, requests or grievances relating to privacy, personal data, confidentiality, information security or this Policy may be directed to:

Data Protection Officer / Grievance Officer
Designation: Data Protection Officer and Grievance Officer
Email: support@enyaysetu.com
Sulahkar Private Limited, Nathdwara, Rajsamand – 313301, Rajasthan, India

Sulahkar shall endeavour to address grievances and requests within the timelines prescribed under applicable law.

15. Amendments

Sulahkar reserves the right to modify, amend, update or replace this Policy at any time to reflect changes in legal requirements, technological developments, business practices, security standards or operational requirements. Revised versions shall become effective upon publication unless otherwise required by law.

Continued use of the Platform following publication of an updated Policy shall constitute acceptance of the revised terms to the extent permitted by applicable law.

16. Governing Law

This Policy shall be governed by and construed in accordance with the laws of India. Any disputes arising out of or relating to this Policy shall be subject to the dispute resolution and jurisdiction provisions contained in the applicable Terms of Use, unless otherwise required by law.

By accessing or using Enyayasetu, you acknowledge that you have read, understood and agreed to this Privacy Policy.