Privacy Policy

Eshil Enterprises ("Eshil", "we", "our", or "us") respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy explains how we collect, use, share, and safeguard information when you interact with our services, including AI-driven voice calls, WhatsApp communications, and related collection and customer engagement activities undertaken on behalf of our partner lenders, NBFCs, and businesses.

This Policy is published in compliance with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the Digital Personal Data Protection Act, 2023 ("DPDP Act").

1. Scope of This Policy

This Policy applies to information processed by Eshil Enterprises when we:

• Contact customers on behalf of our partner lenders or businesses ("Clients") in connection with loan repayments, dues, reminders, customer service, or engagement campaigns;
• Operate AI voice agents and WhatsApp automation to engage with customers in supported Indian languages;
• Process information shared by Clients in the course of providing collection or engagement services;
• Maintain transcripts, recordings, and analytics generated from these interactions for the purposes set out below.

Where Eshil acts as a data processor for a Client (i.e. processing personal data on the Client's behalf and under their instructions), the Client is the data fiduciary and their own privacy policy governs the underlying customer relationship. This Policy describes Eshil's own practices.

2. Information We Collect

2.1 Information provided by our Clients

• Customer name, mobile number, email address, address;
• Loan / account identifiers, outstanding amount, EMI, due date, overdue days, payment status;
• Product or service identifiers, language preference, prior engagement history;
• Identifiers such as PAN (typically in masked form), customer IDs, or reference IDs.

2.2 Information generated during interactions

• Call recordings, voice transcripts, WhatsApp message history;
• Outcome classifications (e.g. payment committed, dispute raised, callback requested);
• Call metadata: timestamp, duration, language used, channel, agent (human or AI), disposition;
• Customer responses, sentiment, intent signals derived from conversation analysis;
• Aggregate analytics, recovery metrics, channel performance data.

2.3 Information from third parties

• Telecom delivery reports from carriers, WhatsApp Business platform providers, and SIP providers;
• Webhook events and message-delivery receipts from communication service providers.

3. How We Use Your Information

We use the information described above for the following purposes:

• To contact customers on behalf of our Clients in connection with overdue payments, reminders, or engagement;
• To deliver multi-channel communications (voice, WhatsApp, SMS) in the customer's preferred language;
• To capture customer responses, payment commitments, disputes, and other outcomes for our Clients;
• To improve the quality, accuracy, and tone of our AI agents and automation workflows;
• To maintain audit trails as required by our Clients and applicable law;
• To comply with legal, regulatory, and tax obligations including but not limited to RBI Fair Practices Code requirements applicable to our Clients;
• To detect, prevent, and respond to fraud, misuse, abuse, or security incidents.

We do not use customer information for marketing our own products, sell or rent personal data to third parties, or use it for any purpose other than as instructed by our Clients or as required by law.

4. Calling Practices & Communication Standards

• Calling windows: Voice calls are placed between 08:00 and 19:00 (local time of the recipient), in line with the RBI Fair Practices Code and our Clients' policies.
• Identity disclosure: Our AI agents disclose the name of the Client / lender they are calling on behalf of at the start of every call.
• Language: Conversations are conducted in the customer's preferred language wherever supported.
• Tone: Agents (human and AI) are configured to remain respectful, non-coercive, and compliant with applicable codes of conduct.
• Escalation: If a customer requests transfer to a human agent or to the lender, the request is escalated promptly.
• Opt-out: If a customer requests that we stop contacting them, we honor the request and notify the relevant Client.

5. Information Sharing

We share personal information only as follows:

• With our Clients — the lender, NBFC, or business on whose behalf we are conducting outreach. They remain the primary data fiduciary for their customers.
• With service providers — telecom and SIP providers, WhatsApp Business platform providers, cloud infrastructure providers, AI/LLM model providers, transcription services, and analytics tools, strictly to perform services on our behalf and under appropriate confidentiality and data-protection terms.
• With regulators & law enforcement — when required by applicable law, court order, or lawful request from a government authority.
• In a business transfer — in the event of a merger, acquisition, or asset sale, personal information may be transferred subject to the same protections in this Policy.

6. Data Retention

We retain personal information only for as long as is necessary to fulfil the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce agreements. Retention periods are typically aligned with the requirements of our Clients (which in turn follow RBI and statutory record-keeping norms). When personal information is no longer required, we delete or anonymize it.

7. Data Security

We implement reasonable security practices and procedures appropriate to the sensitivity of the information we handle. These include:

• Encryption of data in transit (TLS) and at rest;
• Role-based access controls and least-privilege principles for employees and contractors;
• Logical isolation of each Client's data;
• Audit logging of access to personal information;
• Periodic review of vendors and sub-processors;
• Incident response procedures in the event of a security breach.

8. Your Rights

Subject to applicable law (including the DPDP Act, 2023), you may have the following rights with respect to your personal information:

• Right to access: Request confirmation of whether we process your information and obtain a copy.
• Right to correction: Request correction of inaccurate or incomplete information.
• Right to erasure: Request deletion of your information, subject to legal retention requirements.
• Right to withdraw consent: Withdraw any consent previously given for processing.
• Right to grievance redressal: Lodge a complaint with our Grievance Officer (see below) or with the relevant data protection authority.

Because we typically process data on behalf of a Client, requests relating to the underlying customer relationship are usually best directed to the Client whose loan, account, or service you hold. We will forward such requests to the relevant Client where appropriate.

9. Cookies & Website Usage

This website (eshilenterprises.co.in) is primarily an informational site. We do not use tracking cookies or third-party advertising trackers. Standard server logs (IP address, browser type, referring page, timestamp) may be retained for security and operational purposes.

10. Children's Privacy

Our services are not directed to children under the age of 18. We do not knowingly collect or process personal information of children. If you believe a child's information has been provided to us, please contact our Grievance Officer for prompt deletion.

11. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top of this page reflects the most recent revision. Material changes will be highlighted on this page. Continued use of our services after changes are posted constitutes acceptance of the revised Policy.

12. Grievance Officer & Contact

If you have any questions, concerns, or grievances regarding this Privacy Policy or our handling of personal information, please contact:

We endeavour to acknowledge grievances within 48 hours and resolve them within 30 days of receipt, in line with applicable law.