This Privacy Policy applies to the PrimeLock website, retailer application, customer device-management application, administrative portal and related support services (together, the “Services”). PrimeLock is a device-finance management platform. Depending on the relationship, the retailer or financing business may decide why customer information is processed, while PrimeLock processes that information to provide the Services.
1. Information we process
We process information that is provided during account creation, customer onboarding, device enrolment, finance servicing and support. This may include:
- Retailer, distributor and customer identity and contact details, shop or business details, account credentials and support communications.
- Customer documents, photographs, signatures, agreements, product details, EMI schedules, collections, penalties, promise dates and transaction references entered by an authorised retailer.
- Device and installation data such as IMEI or other device identifiers, serial number, model, brand, operating-system and app versions, SIM and mobile-number information, enrolment state, network state, battery state and push-notification token.
- Device-management data such as lock state, kiosk and application restrictions, command requests, delivery and execution feedback, recovery codes, password or lock history, deregistration events and security signals.
- Location information and related logs when location features are enabled and legally authorised by the retailer and device user.
- Website enquiry information and limited technical data such as IP-derived security hashes, browser details, timestamps, diagnostic logs and security events.
2. Device-owner and managed-device functions
The customer application may be provisioned as an Android device owner for a financed or otherwise managed device. When enabled, PrimeLock can apply kiosk mode, lock or unlock the device, restrict selected applications or settings, detect relevant SIM or connectivity changes, display payment and retailer information, provide emergency and recovery access, and report command results. These functions should be activated only after the retailer has explained the arrangement and obtained every consent or authorisation required by law and the finance agreement.
3. Why we use information
We use information to create and secure accounts; enrol and identify managed devices; provide customer, EMI and collection workflows; deliver and verify authorised device commands; prevent fraud and misuse; diagnose failures; provide support; maintain audit records; comply with legal obligations; and improve reliability and security. We do not use managed-device data for unrelated advertising.
4. Legal basis and retailer responsibilities
Information must be processed for a lawful purpose and with a valid legal basis, which may include consent, performance of a contract, compliance with law or another legally recognised use. Retailers and financing businesses are responsible for giving customers clear notice, collecting only necessary information, keeping records accurate, limiting access to authorised staff and handling customer requests that relate to their own finance relationship.
5. Sharing and service providers
Information may be available to the authorised retailer and the distributor or administrator responsible for that account. We may use hosting, database, communications, mapping, push-notification, security and technical-support providers only as needed to operate the Services. Information may also be disclosed when required by law, to protect users or the platform, or as part of a business reorganisation subject to appropriate safeguards. We do not sell personal information.
6. Payments and third-party applications
PrimeLock may show a retailer’s UPI identifier, registered number or uploaded QR code and may open a compatible payment application selected by the customer. The payment is processed by the customer’s bank, UPI application or other payment provider under that provider’s terms. PrimeLock does not receive card PINs, UPI PINs or banking passwords and does not guarantee that opening a payment application confirms settlement.
7. Retention
We retain information while the relevant account, installation or finance relationship is active and afterwards for support, security, dispute, audit, backup and legal purposes. Retention periods vary by record type and applicable obligations. Information that is no longer reasonably required is deleted, anonymised or access-restricted. A device deregistration removes management controls but may not immediately erase lawful finance or audit records.
8. Security
We use access controls, scoped accounts, encrypted network transport, authentication, logging, backups and operational safeguards designed to protect information. No system is completely secure. Users must protect credentials, use only authorised devices and promptly report suspected compromise.
9. Your choices and rights
Subject to applicable law, an individual may ask for information about processing, request correction or erasure, withdraw consent where processing depends on consent, or raise a grievance. Some information may need to be retained for contracts, fraud prevention, security, legal claims or statutory duties. Customers should normally contact their retailer first because the retailer controls the finance and onboarding record. Requests may also be submitted through our support form or to [email protected].
10. Children
The Services are intended for lawful business use and are not directed to children. A retailer must not enrol a child or process a child’s information unless it has verified that the arrangement is lawful and completed all required parent or guardian steps.
11. International processing
Service providers may process information from locations other than the user’s own. Where cross-border processing occurs, PrimeLock and participating businesses must apply the safeguards and restrictions required by applicable law.
12. Updates to this policy
We may update this policy as the Services, providers or legal requirements change. The current version and update date will remain published at this address. Material changes may also be communicated through the Services.
13. Contact
For privacy questions, grievances or data requests, email [email protected] or use the PrimeLock contact form. Please include the retailer or account reference needed to locate the record, but do not send passwords, OTPs, UPI PINs or unnecessary identity documents by email.