Privacy & Data Governance Policy

1. Institutional Overview & Scope

This Privacy Policy explains how PES Collections (the dedicated debt resolution and recovery division of Payroll Expert Solutions Pvt. Ltd., having its corporate office at Plot No. 26, 4th Floor, Pocket 5, Sector 24, Rohini, Delhi - 110085) handles, stores, safeguards, and processes personal data and Personally Identifiable Information (PII) of borrowers, customers, website visitors, and institutional partners.

2. Nature of Data Processed

PES Collections acts strictly as an authorized Data Processor on behalf of our empanelled Principal Lenders (Scheduled Commercial Banks, Housing Finance Companies, and RBI-registered NBFCs). The data processed includes:

• Borrower Identifiers: Name, loan account number, registered contact details, and registered residential/work addresses provided strictly by the lending institution.
• Account Delinquency Details: Overdue amount, principal outstanding, default bucket, EMI tenure, and contractual payment schedules.
• Interaction Metadata: Telecalling audio recordings, timestamped call logs, disposition status, and GPS-verified Haversine doorstep coordinates.
• Institutional Inquiries: Contact details submitted via our website RFP portal for empanelment proposals.

3. Purpose of Data Processing

Data received by PES Collections is processed strictly for legitimate institutional purposes:

• Facilitating retail loan regularisation and debt recovery on behalf of authorized lenders.
• Serving statutory notices under Section 13(2) of the SARFAESI Act, 2002 and executing judicial warrants under Section 138 of the Negotiable Instruments Act.
• Generating dynamic, bank-owned payment gateway links and verifying transaction UTR numbers for daily electronic reconciliation.
• Conducting mandatory speech analysis, quality control audits, and investigating customer grievances.

4. Zero Third-Party Sale & Anti-Leakage Shield

We have a strict Zero-Monetization Policy. PES Collections does not sell, rent, trade, lease, or commercially exploit customer personal information to any third party, lead generation firm, credit repair company, or marketing broker under any circumstances.

Internally, our technology architecture enforces strict Anti-Leakage Controls:

• Telecaller terminals employ Phone Number Masking (e.g. XXXXXX4216) so telecallers never view raw debtor telephone numbers.
• Client spreadsheets and raw CSV data cannot be downloaded or exported by floor staff.
• Floor workstation USB ports and external drives are administratively disabled to prevent physical exfiltration.

5. Call Audio Recording & Retention

In strict compliance with the RBI Model Code of Conduct, 100% of telephone interactions made by our telecalling desks are recorded for quality assurance, training, and dispute audit. Audio recordings are stored in encrypted cloud archives for a mandatory retention period of 90 days, after which they are securely purged unless flagged for active court litigation or formal regulatory review.

6. Geolocation & Mobile Field Data

Field Recovery Officers (FOS) utilize our dedicated mobile application. Geolocation coordinates are accessed solely during the active check-in window at debtor premises to verify proximity within a 100-meter radius as required by bank audit standards. No continuous background tracking is performed outside operational hours.

7. Disclosure to Authorities

We may disclose information to statutory judicial authorities, law enforcement summon cells, Court Receivers, or District Magistrate desks solely when required by lawful subpoena, court warrant, or statutory SARFAESI enforcement orders.

8. Grievance Redressal & Data Protection Officer

If you have questions, concerns, or grievances regarding the processing of your personal data, you may directly reach our designated Data Compliance Desk:

Data Protection & Grievance Desk
PES Collections • Payroll Expert Solutions Pvt. Ltd.
Address: Plot No. 26, 4th Floor, Pocket 5, Sector 24, Rohini, Delhi - 110085
Email: grievance@pescollections.com
Phone: +91 8510000416