Legal
Internal policy governing how Settl handles personal data
This Data Protection Policy (“Policy”) sets out how AIVONT AI LABS (“Settl”, “we”, “us”) organises itself internally to meet its obligations under the Digital Personal Data Protection Act, 2023 (“DPDP Act”), the Information Technology Act, 2000, and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
This Policy is an internal governance document. It applies to every employee, contractor, intern and consultant of Settl, having its registered office at 559-569, Tower-B1, Gurgaon, Haryana 122018, India, and to all systems, tools and vendors that store or process personal data on Settl's behalf. It does not replace, and must remain consistent with, Settl's public-facing Privacy Policy and its Terms & Conditions, which describe our commitments to Customers, Users and Debtors. Where this Policy and either of those documents appear to conflict, the public commitment governs and this Policy must be corrected.
This Policy covers all personal data Settl touches in any capacity, whether Settl acts as Data Fiduciary or as Data Processor (see Section 3).
3.1 Settl's dual role
Settl is a Data Processor in respect of Debtor Data, which it processes solely on the documented instructions of the Customer (the Data Fiduciary for that data). Settl is the Data Fiduciary in respect of Customer account data, billing data, and website/product usage data. Every employee must know which role applies before acting on a data request — see the table in Section 5 of the Privacy Policy for the authoritative mapping.
3.2 Accountable roles
| Role | Responsibility |
|---|---|
| Grievance Officer / Data Protection Contact | Single point of accountability for DPDP Act compliance; receives and tracks Data Principal requests and breach reports; liaises with the Data Protection Board of India. Named contact: [● OFFICER NAME] |
| Engineering / Security lead | Owns technical safeguards (Section 7), access provisioning, encryption, logging and incident response. |
| Founders / Management | Ultimate accountability for this Policy, budget for security controls, and sign-off on new features that process Debtor Data (e.g. AI-based intent detection). |
| All employees & contractors | Must complete the training in Section 15, follow least-privilege access practices, and report suspected incidents immediately to the Grievance Officer. |
The categories below mirror Section 3 of the Privacy Policy; this Policy adds internal handling notes for each.
| Category | Internal handling notes |
|---|---|
| Debtor Data | Names, mobile numbers, invoice numbers, amounts, due dates, payment status, message content. Processed only per Customer instruction; never used for our own purposes, advertising, or to train general-purpose AI models. |
| Customer account & billing data | Business details, user names, emails, login credentials (hashed), GSTIN, subscription and invoice records. Settl is Data Fiduciary; ordinary internal-access rules apply. |
| Website & product usage data | Device, log and analytics data collected from visitors and Users. Used only in aggregated or de-identified form for product improvement unless otherwise stated. |
We do not knowingly collect sensitive personal data (biometric, health, caste/religious identifiers, financial account credentials) and do not knowingly collect data relating to children. Any engineering proposal that would introduce collection of such data must be escalated to the Grievance Officer before build begins.
Every system design decision, feature build and vendor selection at Settl must be checked against these principles, which reflect Section 8 of the DPDP Act:
Because Settl acts as a Data Processor for Debtor Data, engineering and support teams must observe the following at all times:
These measures apply across all environments (production, staging, analytics, backups) that hold personal data:
No system is perfectly secure. These measures reduce risk; they do not eliminate it. Every employee must report suspected unauthorised access immediately rather than waiting to confirm impact.
A Debtor who replies STOP on a WhatsApp thread must have their opt-out actioned within 60 seconds and recorded on the permanent suppression list, so that they are never contacted again through Settl regardless of any later re-upload of their number by a Customer. This is the one Debtor-facing request Settl actions directly rather than redirecting to the Customer.
Retention periods must match the Privacy Policy and Terms & Conditions exactly. Any change to a system's retention behaviour requires the schedule below to be updated first.
| Data | Retention period |
|---|---|
| Debtor Data & message history | Life of the account; deleted or irreversibly anonymised within 90 days of account termination (30 days for export, then deletion). |
| Opt-out / suppression records | Retained indefinitely, in minimal form. |
| Billing and tax records | As required under the Income-tax Act, 1961, GST law and the Companies Act, 2013 — ordinarily 8 years. |
| Security and access logs | Up to 12 months, or longer for an ongoing investigation. |
| Support communications | Up to 24 months. |
| Marketing contact data | Until consent is withdrawn. |
Disposal must be irreversible — secure deletion or anonymisation such that the individual can no longer be identified — not merely hidden from the application layer.
Requests concerning Customer account data, or requests Settl is itself the Fiduciary for, must be logged, acknowledged within 48 hours, and resolved ordinarily within 15 days, within the statutory timelines under the DPDP Act. This includes:
Requests concerning Debtor Data must be redirected to the relevant Customer, with reasonable technical assistance offered to that Customer so they can respond within statutory timelines (see Section 6).
On suspicion or confirmation of a personal data breach, the following sequence applies:
Any new feature that introduces a new category of personal data collection, a new sub-processor, cross-border transfer, or a new automated/AI use of message content (such as payment-intent detection) must have a short written risk assessment reviewed by the Grievance Officer and Engineering/Security lead before launch. AI features may process message content solely to serve the originating Customer's own reminder workflow, and must not be used to train generally-available models.
Personal data is primarily stored on servers located in India. Any transfer of personal data outside India must be limited to jurisdictions permitted under the DPDP Act, and must be subject to a written contractual safeguard with the receiving party before the transfer takes place.
Failure to follow this Policy is treated as a disciplinary matter and may result in restricted access, disciplinary action up to and including termination, and — where a vendor or contractor is responsible — termination of the relevant contract. Nothing in this Policy limits Settl's rights or obligations under applicable law.
| Policy owner | [● OFFICER NAME / GRIEVANCE OFFICER] |
| Entity | AIVONT AI LABS |
| Review cycle | Annually, or on material regulatory or product change |
| Related documents | Privacy Policy, Terms & Conditions, Incident Response runbook, Sub-processor list |