Data Processing Agreement

Effective 24 June 2026

Parties

Data Fiduciary: The pawnbroker / money-lending firm using SthirApp ("Firm"). Data Processor: SthirApp / Aadinath Ventures ("Processor").

Subject matter

Processor hosts and syncs customer PII and loan records entered by the Firm, solely to provide the SthirApp service.

Processor obligations

  • Process personal data only on documented instructions from the Firm (via use of the app)
  • Implement encryption at rest and in transit for vault data
  • Not use customer vault data for Processor's own marketing
  • Assist the Firm with data principal requests where technically feasible
  • Notify the Firm of personal data breaches without undue delay
  • Use sub-processors (e.g. cloud hosting) under appropriate contracts

Firm obligations

  • Provide lawful notice and consent to customers before collecting Aadhaar, mobile, etc.
  • Record customer consent where required (in-app checkbox on loan create)
  • Respond to customer rights requests as Data Fiduciary

See also our Privacy Notice for account-level processing by Processor as Data Fiduciary.