MeraEMI

Legal & Trust Centre

The terms on which MeraEMI provides its services. MeraEMI is a credit advisory firm and loan facilitator that operates on a conduit-pipe basis — it connects borrowers with lenders and is not a lender itself.

Not a lender Conduit-pipe model DPDP Act 2023 No document storage Mumbai, India
Operated by Checklyst Solutions Pvt Ltd CIN U74999MH2019PTC322109 Effective 1 Jan 2019 Version 3.0 | 2026

Terms of Use — definitions · conduit-pipe nature · information & document sharing · indemnity · Lender / Corporate DSA notice · governing law

PART A — DEFINITIONS AND INTERPRETATIONS

In this Legal Framework, unless the context otherwise requires, the following terms shall have the meanings ascribed to them:

1.1 Entity Definitions

  • "MeraEMI", "Company", "We", "Us", "Our" — refers to the brand MeraEMI, operated by Checklyst Solutions Pvt Ltd, a company incorporated under the Companies Act 2013 (CIN: U74999MH2019PTC322109), having its registered office at 2, Framroz Court, D.S. Phalke Road, Dadar (East), Mumbai – 400014, Maharashtra, India.

  • "Platform" — refers collectively to meraemi.com and all its subdomains including leads.meraemi.com (Arya), tools.meraemi.com, disha.meraemi.com, sahayak.meraemi.com, and all associated mobile-optimised interfaces, progressive web applications, WhatsApp channels, and social media pages.

  • "User", "Borrower", "Customer" — refers to any individual, proprietor, partner, director, or entity that accesses any part of the Platform, provides personal or financial data, or initiates contact with MeraEMI through any channel including web, WhatsApp, social media, telephone, or in person.

  • "Lender" — refers to any scheduled commercial bank, non-banking financial company (NBFC), housing finance company (HFC), microfinance institution (MFI), or other RBI-regulated credit institution to whom lead or loan application data is transmitted by MeraEMI.

  • "Corporate DSA" — refers to any corporate direct selling agent, channel partner, co-originator, or affiliate entity through which MeraEMI may route lead data to a Lender, and which has an independent contractual relationship with such Lender.

  • "Lead" or "Loan Application" — refers to the set of personal, financial, and documentary data submitted voluntarily by a User through the Platform for the purpose of expressing interest in a loan or credit facility.

1.2 Platform Components

  • "Arya" — MeraEMI's web-based loan eligibility and lead capture progressive web application accessible at leads.meraemi.com. Arya is a pre-qualification tool only and does not constitute a loan offer or sanction.

  • "Disha" — MeraEMI's WhatsApp-based AI conversational agent powered by Google Gemini 2.5 Flash (primary) and Anthropic Claude Sonnet (fallback), operating through the Meta WhatsApp Business API on WABA "Mera EMI" (ID: 1695688051600885). Disha is an automated information and lead-collection assistant.

  • "Loan Sahayak" — a borrower grievance facilitation platform operated separately from MeraEMI's loan sourcing business. Loan Sahayak assists Users in navigating formal grievance channels under the RBI Integrated Ombudsman Scheme 2021. Loan Sahayak does not file complaints on behalf of Users without explicit, OTP-verified authorisation at each step.

  • "Social Media Pages" — refers to MeraEMI's official presence on Facebook (Meta), LinkedIn, Google My Business, Instagram, and any future official pages on X (formerly Twitter) or any other platform, whether currently active or not.

1.3 Regulatory Definitions

  • "DPDP Act" — the Digital Personal Data Protection Act, 2023 (Act 22 of 2023) and all rules, regulations, and guidelines issued thereunder by the Data Protection Board of India or the Central Government from time to time.

  • "IT Act" — the Information Technology Act, 2000 (Act 21 of 2000), as amended, including the IT (Amendment) Act 2008, and all applicable rules made thereunder.

  • "RBI Guidelines" — all master directions, circulars, guidelines, and regulations issued by the Reserve Bank of India applicable to DSAs, digital lending, fair lending practices, and data handling, including the Digital Lending Guidelines 2022 and the Fair Practices Code for NBFCs.

  • "DSA" — Direct Selling Agent. MeraEMI operates as a DSA / credit advisory intermediary and is not itself a lender, bank, NBFC, or financial institution.

PART B — TERMS OF USE

Section 1 — Acceptance and Binding Nature

1.1 By accessing the Platform in any manner — including browsing meraemi.com, submitting any form on Arya, initiating a conversation with Disha on WhatsApp, following or interacting with any MeraEMI social media page, or providing contact details through any channel — you unconditionally and irrevocably agree to be bound by this Legal Framework in its entirety.

1.2 If you do not agree to any provision of this Legal Framework, you must immediately cease all use of the Platform. Continued use after any modification constitutes acceptance of the modified terms.

1.3 This Legal Framework applies to: - All Users who access any part of the Platform - All Users who interact with Disha via WhatsApp - All Users who engage with MeraEMI on any social media platform - All Lenders and Corporate DSAs who receive Lead data from MeraEMI - Any person or entity acting on behalf of any of the above

1.4 Users who are minors (below 18 years of age) are strictly prohibited from accessing the Platform or submitting any data. MeraEMI assumes no liability for misrepresentation of age.

Section 2 — Nature of MeraEMI's Business

⚠️ IMPORTANT: MeraEMI is NOT a lender, bank, NBFC, financial institution, or investment adviser. MeraEMI does NOT disburse loans, guarantee credit approvals, or make lending decisions. All credit assessment, underwriting, sanction, and disbursement decisions rest exclusively with the Lenders.

2.1 MeraEMI operates as a loan facilitation intermediary and Direct Selling Agent (DSA). Its sole function is to: - Receive expressions of interest for loans and credit from Users through the Platform - Conduct preliminary, non-binding eligibility screening - Transmit User Lead data to associated Lenders and/or Corporate DSAs for evaluation - Facilitate communication between Users and Lenders during the application process

2.2 MeraEMI's business model functions as a conduit pipe — it receives loan requirements from Users and transmits them to Lenders. MeraEMI is not a party to any loan agreement, credit facility, or financial contract entered into between a User and a Lender.

2.3 MeraEMI's Lead transmission chain may include one or more Corporate DSAs or channel partners who maintain independent contractual relationships with Lenders. The involvement of a Corporate DSA does not affect MeraEMI's status as a conduit intermediary and does not create any additional obligation on MeraEMI to the User or Lender.

2.4 No Fiduciary, Advisory, or Agency Relationship. Nothing in the User's use of the Platform creates, and the User shall not construe it as creating, any fiduciary, trustee, advisory, agency, partnership, or joint-venture relationship between the User and MeraEMI, Checklyst Solutions Pvt Ltd, or any of their directors, officers, employees, or affiliates. MeraEMI does not act for or on behalf of the User, does not owe the User any fiduciary duty, and does not provide investment, legal, tax, or financial advice. Any information, score, illustration, or eligibility indication provided through the Platform (including via Arya or Disha) is general, automated, and informational only, and must not be relied upon as professional advice or as a recommendation to enter into any credit facility.

2.5 No Liability for Loan Outcomes. As a conduit intermediary, MeraEMI is not responsible for, and the User shall not hold MeraEMI, its directors, officers, employees, or affiliates liable for, any approval, rejection, pricing, term, condition, delay, denial, recall, or any other decision, act, or omission of any Lender or Corporate DSA in respect of any loan or credit facility. The decision to lend, and all consequences thereof, rest solely with the Lender.

2.6 Information Shared Through Any Channel — Explicit Knowledge and Authorisation. By submitting or disclosing any personal, business, or financial information to MeraEMI through any channel — including the Platform, WhatsApp (Disha or any MeraEMI number), email, telephone, or in person — the User does so with explicit knowledge, understanding, and authorisation that such information will be, and is intended to be, shared and transmitted by MeraEMI to one or more prospective Lenders and/or Corporate DSAs for the purpose of loan-related enquiries, eligibility assessment, and the application or login process. The User acknowledges and accepts that: - (a) MeraEMI conducts a prima facie enquiry with prospective Lenders and may, at its sole discretion, choose to proceed or not proceed with any particular Lender based on the feedback it receives; - (b) such feedback is specific to the Lender, the officer handling it, the channel, and the point in time, and the same Lender may respond differently when approached by a different officer, branch, DSA, or at a different time; - (c) once information has been shared with a prospective Lender or Corporate DSA, the manner in which that recipient uses, stores, retains, or processes such information is outside MeraEMI's control and is governed by that recipient's own policies and regulatory obligations; and - (d) while MeraEMI endeavours to act in the best interests of the User, it does not and cannot guarantee, warrant, or obligate itself to any outcome, including any enquiry result, eligibility, sanction, disbursement, or the conduct of any Lender or Corporate DSA.

2.7 Documents Shared Through Any Channel — No Custodian Liability; No Document Storage. By transmitting any document, file, image, or attachment (including KYC, identity, financial, bank, GST, ITR, or property documents) to MeraEMI through WhatsApp, email, or any other mode of transmission, the User does so with the same explicit knowledge and authorisation set out in Clause 2.6 — namely, that such documents are provided for onward transmission to prospective Lenders and/or Corporate DSAs for loan-related processing. The User further acknowledges and agrees that: - (a) MeraEMI does not operate as a custodian, warehouse, bailee, or repository of User documents, and does not store User documents on its web-server; documents received are handled only as receipt-confirmation metadata or in transient form for the limited purpose of transmission, consistent with the principle of data minimisation under the DPDP Act 2023; - (b) the channels of transmission (such as WhatsApp, email, or telephone) are third-party services not owned or controlled by MeraEMI, and MeraEMI is not responsible for the security, interception, loss, or compromise of any document during transmission over such channels; - (c) to the maximum extent permitted by applicable law, MeraEMI, its directors, officers, employees, and affiliates disclaim any custodian, bailee, or safe-keeping liability in respect of User documents; and - (d) the User is solely responsible for the authenticity, accuracy, and lawful ownership of every document it submits.

2.8 Caveat Emptor — Conduit Services Only; No Assurance; Waiver. The User expressly acknowledges that MeraEMI operates in the transaction-advisory and lead-sourcing space on a conduit-point basis governed by the principle of caveat emptor (buyer beware). MeraEMI offers only conduit-point services and does not, and cannot, assure or guarantee any matter whatsoever — including, without limitation, the security or confidentiality of information or documentation once transmitted, the response of any Lender, or the eligibility, sanction, disbursement, pricing, or terms of any loan. All such matters and outcomes are an inherent part of the lending process and lie outside MeraEMI's control. By engaging with MeraEMI's website, WhatsApp channels, emails, telephone communications, or officers, the User knowingly and voluntarily accepts these risks and, to the maximum extent permitted by applicable law, waives and relinquishes any claim to indemnity, compensation, or recourse against MeraEMI, Checklyst Solutions Pvt Ltd, and their respective directors, officers, employees, agents, and affiliates arising from or in connection with such engagement or any outcome thereof.

2.4 Any information, content, or communication provided by MeraEMI — whether through the Platform, Disha, Arya, social media, or by its employees — is for general informational purposes only and does not constitute financial advice, legal advice, or a commitment to lend.

Section 3 — Permitted and Prohibited Use

3.1 Permitted Use

  • Accessing the Platform to explore loan facilitation services
  • Submitting genuine loan enquiries with accurate personal and financial information
  • Interacting with Disha or Arya for preliminary eligibility assessment
  • Contacting MeraEMI to receive assistance with loan documentation requirements

3.2 Prohibited Use — Strictly Forbidden

  • Submitting false, misleading, fabricated, or fraudulent data through any channel
  • Impersonating any person, entity, or authority
  • Attempting to reverse-engineer, scrape, crawl, or extract data from the Platform
  • Using automated bots, scripts, or tools to access or interact with the Platform
  • Transmitting malicious code, viruses, or any disruptive material
  • Using the Platform for any unlawful purpose under Indian or applicable international law
  • Attempting to circumvent any security, authentication, or verification measure
  • Commercially exploiting Platform content without written authorisation from MeraEMI

3.3 MeraEMI reserves the right to terminate access, blacklist, and report to appropriate authorities any User found engaging in prohibited use, without notice and without liability.

Section 4 — Arya — Loan Eligibility Platform (leads.meraemi.com)

4.1 Arya is a digital pre-qualification tool designed to collect preliminary loan eligibility information from Users seeking business loans, loan against property, or related credit facilities.

4.2 Arya's eligibility assessment is indicative and automated. It does not constitute a loan sanction, in-principle approval, commitment to lend, or any representation regarding a User's creditworthiness.

4.3 Data submitted through Arya — including name, mobile number, business turnover, vintage, CIBIL score, and loan requirement — is stored securely in MeraEMI's encrypted database and transmitted to Lenders and Corporate DSAs in the ordinary course of MeraEMI's DSA operations.

4.4 By submitting data through Arya, Users expressly consent to: - Electronic storage of their personal and financial data - Transmission of their Lead data to Lenders and Corporate DSAs - Being contacted by MeraEMI, its employees, agents, Lenders, and Corporate DSAs - Receiving communications via WhatsApp, SMS, email, and telephone

4.5 MeraEMI employs industry-standard encryption (Fernet symmetric encryption) for sensitive data fields including mobile numbers. However, MeraEMI makes no warranty of absolute data security.

Section 5 — Disha — WhatsApp AI Agent

5.1 Disha is MeraEMI's AI-powered conversational agent operating over WhatsApp. Disha is powered by Google Gemini 2.5 Flash as the primary AI engine with Anthropic Claude Sonnet as a technical fallback. Both models are used purely for natural language processing of User responses.

5.2 Conversations with Disha are automated. While Disha is designed to be helpful and informative, it is not a human financial adviser, loan officer, or regulatory authority.

5.3 By initiating or continuing a conversation with Disha: - Users explicitly consent to automated AI processing of their responses - Users consent to their conversation data being processed by Google (Gemini API) and/or Anthropic (Claude API) subject to MeraEMI's data processing agreements with those providers - Users consent to their Lead information collected through Disha being stored and transmitted to Lenders - Users acknowledge that Disha's responses are AI-generated and may not reflect the most current lending policies of any Lender

5.4 Disha is expressly not authorised to make loan offers, commitments, or guarantees. Any statement by Disha that could be construed as a loan offer is a system error and shall have no legal effect.

5.5 Disha operates under the 24-hour Meta WhatsApp messaging window framework. MeraEMI may transmit template messages outside this window as permitted by Meta's Business Messaging Policy.

5.6 Disha applies a DPDP-compliant sensitivity gate. Conversation data is classified as non-sensitive (loan requirement, business type) and semi-sensitive (turnover, vintage, CIBIL range). No document bytes are stored on MeraEMI's servers — only document metadata (file type received confirmation) is retained.

Section 6 — Social Media Presence

6.1 MeraEMI maintains official social media pages on the following platforms: - Facebook (Meta) — Active - LinkedIn — Active - Google My Business — Active - Instagram — Active - X (formerly Twitter) — Registered; currently not operationally active - Any other platform on which MeraEMI may establish a presence in the future

6.2 Content published on MeraEMI's social media pages is for informational and marketing purposes only. It does not constitute financial advice, a loan offer, or a guarantee of eligibility.

6.3 MeraEMI is not responsible for any third-party content, advertisements, or linked pages that appear alongside its social media content as a result of algorithms deployed by platform operators (Meta, LinkedIn, Google, etc.).

6.4 Direct messages, comments, or enquiries received through social media channels are not secure channels for transmission of sensitive financial data. MeraEMI will redirect such enquiries to the Platform.

6.5 MeraEMI's social media presences, including those that are currently inactive (X/Twitter), are reserved for MeraEMI's exclusive use. Impersonation of MeraEMI on any social media platform shall be reported to the relevant platform authority and appropriate law enforcement.

Section 7 — Loan Sahayak — Borrower Grievance Platform

📌 NOTE ON ARMS-LENGTH SEPARATION: Loan Sahayak is a borrower advocacy and grievance facilitation service operated by Checklyst Solutions Pvt Ltd. It is maintained at deliberate operational and functional arms-length from MeraEMI's loan sourcing and DSA business. A User engaged in the Loan Sahayak grievance process against a Lender will not be cross-sold MeraEMI loan products during the pendency of their active case. The two services share a legal entity and infrastructure but are kept strictly separated at the product and operations level.

7.1 Loan Sahayak assists Users in preparing and filing grievances with RBI-regulated lenders and, where the lender has failed to respond within statutory timelines, facilitating escalation to the RBI Integrated Ombudsman Scheme 2021.

7.2 Loan Sahayak is not the RBI, the RBI Ombudsman, or any regulatory authority. It is a private facilitation tool. It has no authority to compel lender action, award compensation, or adjudicate disputes.

7.3 Every action taken by Loan Sahayak on a User's behalf — including filing with a lender's Nodal Officer or initiating escalation — requires explicit, OTP-verified authorisation from the User at each stage. Nothing escalates automatically.

7.4 Loan Sahayak will not access a User's bank accounts, payment apps, or any financial system. It operates solely through structured text-based communications.

Section 8 — Intellectual Property

8.1 All content on the Platform — including but not limited to text, graphics, logos, product names, software code, AI prompt structures, database schema, UI/UX design, marketing creatives, and the Arya and Disha product names — is the exclusive intellectual property of Checklyst Solutions Pvt Ltd.

8.2 No part of the Platform may be reproduced, distributed, modified, adapted, published, translated, or commercially exploited without prior written consent from an authorised officer of Checklyst Solutions Pvt Ltd.

8.3 "MeraEMI", "Arya", "Disha", "Loan Sahayak", and "Checklyst Solutions" are proprietary brand names and are not available for use by third parties without written licence.

PART E — INDEMNIFICATION, HOLD HARMLESS, AND WAIVER OF RIGHTS

⚠️ THIS SECTION CONTAINS IMPORTANT PROVISIONS THAT LIMIT YOUR RIGHTS AND WAIVE CERTAIN LEGAL CLAIMS. READ CAREFULLY BEFORE USING THE PLATFORM.

Section 19 — Comprehensive User Indemnification

19.1 BLANKET INDEMNITY. The User, Borrower, or Customer (hereinafter "Indemnifying Party") shall, to the fullest extent permitted by applicable Indian law, indemnify, defend, and hold harmless MeraEMI, Checklyst Solutions Pvt Ltd, and each of their respective directors, officers, employees, agents, contractors, affiliates, assigns, successors-in-interest, and corporate DSA partners (collectively, "Indemnified Parties") from and against any and all claims, demands, proceedings, losses, damages, penalties, fines, costs, and expenses (including reasonable legal fees) arising out of or in connection with:

  • The Indemnifying Party's access to or use of the Platform
  • Any information, data, or documentation submitted by the Indemnifying Party through any channel
  • Any breach by the Indemnifying Party of this Legal Framework
  • Any inaccuracy, misrepresentation, or fraudulent statement in the Indemnifying Party's loan application
  • Any claim by a Lender, Corporate DSA, or regulatory authority arising from the Indemnifying Party's loan application
  • Any third-party claim arising from the Indemnifying Party's use of or interaction with the Platform
  • Any violation of applicable law by the Indemnifying Party

19.2 SPECIFIC INDEMNITIES. Without limiting the generality of Clause 19.1, the Indemnifying Party specifically indemnifies the Indemnified Parties against: - Any claim arising from falsification or fabrication of income documents, bank statements, GST returns, financial statements, KYC documents, or any other documentation submitted in support of a loan application - Any claim arising from misrepresentation of business vintage, turnover, outstanding liabilities, or CIBIL score - Any regulatory action, penalty, or investigation arising from the Indemnifying Party's use of the Platform for purposes contrary to RBI regulations or other applicable law - Any claim by any Lender that Lead data transmitted by MeraEMI was based on deliberately false information provided by the Indemnifying Party - Any claim arising from the Indemnifying Party's fraudulent obtaining of a loan using the Platform as a conduit

19.3 The indemnification obligations under this Section shall survive termination of access to the Platform and shall be binding on the Indemnifying Party's heirs, legal representatives, successors, and assigns.

Section 20 — Hold Harmless

20.1 The User irrevocably agrees to hold MeraEMI and all Indemnified Parties harmless from any and all claims, suits, proceedings, or demands — regardless of the nature, basis, or merit of such claim — arising from: - A Lender's rejection of the User's loan application - A Lender's modification, withdrawal, or revision of loan terms after initial communication - A Lender's exercise of its rights under a loan agreement including enforcement, recall, or foreclosure - Delays in loan processing by any Lender or Corporate DSA - The conduct, communication, or actions of any Lender, Corporate DSA, or their employees following receipt of Lead data from MeraEMI - Any loss of business opportunity, revenue, or financial benefit resulting from the outcome of a loan application - Technical errors, AI model failures, or service unavailability on the Platform

20.2 The hold harmless protection in this Section is unconditional and is not limited by any finding of MeraEMI's contributory negligence, except in cases of MeraEMI's gross negligence or wilful misconduct as finally determined by a court of competent jurisdiction.

Section 21 — Waiver of Rights

21.1 By using the Platform, the User knowingly and voluntarily waives the following rights to the maximum extent permitted by Indian law: - The right to hold MeraEMI responsible for the credit decisions, terms, or conduct of any Lender or Corporate DSA - The right to claim from MeraEMI any compensation for loss of loan opportunity, business loss, or financial loss arising from the ordinary conduct of MeraEMI's DSA business - The right to seek injunctive relief against MeraEMI's transmission of Lead data to Lenders once the User has submitted such data through the Platform - The right to class action or collective proceedings against MeraEMI; all disputes shall be resolved on an individual basis - Any right to indemnity, compensation, custodian/safe-keeping claim, or recourse against the Indemnified Parties in respect of information or documents voluntarily shared through any channel, the onward transmission of such information or documents to Lenders or Corporate DSAs, the security of any third-party transmission channel, or any outcome of the lending process — as more fully set out in Clauses 2.6 to 2.8

21.2 The waivers contained in this Section are a material condition of MeraEMI's provision of services and are made in full knowledge of their effect.

21.3 Nothing in this Section shall be construed to exclude or restrict MeraEMI's liability for death or personal injury resulting from its negligence, or any liability that cannot be excluded under the Consumer Protection Act, 2019 or any mandatory provision of Indian law.

PART F — NOTICE TO LENDERS AND CORPORATE DSAs

📌 This Part is addressed specifically to Lenders (Scheduled Commercial Banks, NBFCs, HFCs) and Corporate DSAs who receive Lead data from MeraEMI. The provisions of this Part form part of MeraEMI's standard DSA operating terms.

Section 22 — Nature of MeraEMI's Lead Sourcing

22.1 MeraEMI sources loan enquiries predominantly through: - Paid digital marketing campaigns on Meta (Facebook/Instagram), Google, and other digital advertising platforms - Organic search engine optimisation (SEO) and content marketing - WhatsApp-based lead engagement via the Disha AI agent - Referral networks and word-of-mouth - Google My Business and local search visibility

22.2 Leads transmitted by MeraEMI represent expressions of interest by Users who have voluntarily submitted their information through MeraEMI's digital channels. MeraEMI conducts preliminary, automated eligibility screening (via Arya and Disha) but does not conduct credit appraisal, document verification, or financial underwriting.

22.3 The nature of digital lead generation means that the User population includes: - Users who have expressed interest but whose financial profile may not ultimately meet the Lender's underwriting criteria - Users who have self-reported financial data that may differ from documentation - Users at various stages of business maturity and credit readiness

Section 23 — Lender's Independent Responsibility

⚠️ CREDIT ASSESSMENT IS THE SOLE RESPONSIBILITY OF THE LENDER. MeraEMI's transmission of a Lead does not constitute a recommendation, endorsement, or certification of the User's creditworthiness.

23.1 Lenders and Corporate DSAs receive MeraEMI's Lead data as a starting point for their own independent credit appraisal process. The following responsibilities rest exclusively with the Lender: - Verification of all documents submitted by the User including income proof, bank statements, GST returns, audited financials, ITRs, and KYC documents - Independent CIBIL / credit bureau enquiry and assessment - Determination of the User's repayment capacity and FOIR (Fixed Obligation to Income Ratio) - Legal, technical, and valuation due diligence for any secured loan product - Compliance with RBI's Fair Practices Code, Know Your Customer (KYC) Master Direction, and all applicable regulatory norms - Assessment of compliance with MCA / ROC filings for business borrowers - Determination of the appropriate loan product, tenure, interest rate, and security requirements

23.2 MeraEMI expressly states that it does not verify, certify, or warrant the accuracy, genuineness, or completeness of any document or information provided by the User and transmitted as part of the Lead data. Lenders must exercise their own due diligence without reliance on any representation or omission by MeraEMI.

23.3 Lenders are specifically cautioned that: - User-reported turnover, CIBIL scores, and business vintage are self-declared at the time of initial enquiry and may not reflect post-verification findings - The Arya and Disha eligibility assessments are automated tools with no human verification component - Digital marketing-sourced leads may include Users with varying degrees of documentation readiness

Section 24 — No Recourse and Revenue Finality

⚠️ ONCE A TRANSACTION HAS BEEN COMPLETED, BILLED, AND PAYMENT CLEARED, MERAEMI AND ITS ASSIGNS HAVE NO FURTHER LIABILITY, RESPONSIBILITY, OR INVOLVEMENT IN THAT TRANSACTION AND SHALL NOT BE SUBJECT TO ANY CLAWBACK, REVERSAL, OR RECOVERY DEMAND.

24.1 MeraEMI's DSA engagement is completed upon transmission of Lead data to the Lender or Corporate DSA. Following such transmission, MeraEMI has no further role in the credit appraisal, documentation collection, loan sanctioning, disbursement, or post-disbursement management of any loan.

24.2 Revenue Finality. Any DSA commission, sourcing fee, referral fee, or other remuneration payable by a Lender or Corporate DSA to MeraEMI that has been agreed, invoiced, and cleared by the Lender or Corporate DSA is final and irrecoverable. MeraEMI shall not be subject to: - Clawback of earned DSA revenue on account of subsequent default by the Borrower - Clawback on account of early prepayment by the Borrower - Clawback on account of fraud discovered by the Lender after disbursement, unless MeraEMI is found to have knowingly participated in such fraud by a court of competent jurisdiction - Revenue reversal on account of regulatory action against the Lender - Revenue reversal on account of the Lender's internal credit policy changes applied retrospectively to already-disbursed cases

24.3 No Ongoing Responsibility. Following billing and payment clearance, MeraEMI and its assigns bear no ongoing responsibility for: - The Borrower's repayment performance - The accuracy of documents submitted at the time of login - The Borrower's conduct, representations, or communications with the Lender after loan disbursement - Any dispute between the Lender and the Borrower arising post-disbursement - Any regulatory finding, notice, or investigation arising from the Lender's own credit assessment and disbursement process

24.4 Chain of Responsibility through Corporate DSAs. Where MeraEMI transmits Lead data through a Corporate DSA, and such Corporate DSA in turn transmits the data to the Lender, MeraEMI's responsibility is limited to the accuracy of its transmission to the Corporate DSA. Any error, omission, or misconduct introduced by the Corporate DSA in its own processing of the Lead data is the sole responsibility of the Corporate DSA. MeraEMI is not jointly liable for the Corporate DSA's conduct.

Section 25 — Lender's Indemnification of MeraEMI

25.1 Each Lender and Corporate DSA receiving Lead data from MeraEMI agrees, by the act of receiving such data, to indemnify and hold harmless MeraEMI and all Indemnified Parties from any claim, loss, penalty, or regulatory action arising from: - The Lender's or Corporate DSA's own credit appraisal, disbursement, or post-disbursement conduct - Any failure by the Lender or Corporate DSA to independently verify User documents - Any regulatory breach by the Lender or Corporate DSA in respect of KYC, Fair Practices Code, or digital lending norms - Any dispute or claim by the Borrower against the Lender that is brought in connection with or attributed to MeraEMI's role as a lead conduit

PART G — GOVERNING LAW, DISPUTE RESOLUTION, AND MISCELLANEOUS

Section 26 — Grievance Redressal

26.1 MeraEMI has designated the following Grievance Officer for the purposes of the IT Act 2000, DPDP Act 2023, and Consumer Protection Act 2019:

Field Detail
Name Mr. Vasant Patil
Designation Manager – Operations, Checklyst Solutions Pvt Ltd
Email meraemiloans@gmail.com
Contact Number +91 82919 79788
Address 2, Framroz Court, D.S. Phalke Road, Dadar (East), Mumbai – 400014, Maharashtra, India
Response Time Within 30 days of receipt of a verifiable written complaint

26.2 For complaints pertaining to data privacy and DPDP Act rights, Users may additionally approach the Data Protection Board of India upon its establishment under Section 18 of the DPDP Act.

Section 27 — Governing Law and Jurisdiction

27.1 This Legal Framework and all disputes arising out of or in connection with the Platform, MeraEMI's services, or any transaction facilitated by MeraEMI shall be governed by and construed in accordance with the laws of the Republic of India.

27.2 The parties irrevocably submit to the exclusive jurisdiction of the courts of Mumbai, Maharashtra, India.

27.3 Dispute Resolution Mechanism: 1. Step 1 — Written complaint to the Grievance Officer (Mr. Vasant Patil) at meraemiloans@gmail.com. Response within 30 days. 2. Step 2 — If unresolved, mediation through a mutually agreed mediator in Mumbai, costs shared equally. 3. Step 3 — If mediation fails, arbitration under the Arbitration and Conciliation Act, 1996, with a sole arbitrator appointed by mutual agreement, seated in Mumbai, proceedings in English. 4. Step 4 — Judicial recourse before the courts of Mumbai.

Section 28 — Regulatory Compliance Statement

28.1 MeraEMI operates in compliance with: - Information Technology Act, 2000 and the IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 - Digital Personal Data Protection Act, 2023 - RBI Master Direction on Digital Lending, 2022 - RBI Guidelines on Fair Practices Code for NBFCs (to the extent applicable to DSAs) - Prevention of Money Laundering Act, 2002 (PMLA) — reporting obligations as applicable - Consumer Protection Act, 2019 - Companies Act, 2013

28.2 MeraEMI is not a Regulated Entity under the RBI and is not required to obtain an NBFC licence for its DSA operations. However, MeraEMI acknowledges that its Lender partners are Regulated Entities and complies with their KYC and data handling requirements as part of its DSA obligations.

Section 29 — Amendments and Updates

29.1 MeraEMI reserves the right to amend this Legal Framework at any time. Amendments shall be effective upon posting of the updated document on meraemi.com.

29.2 Continued use of the Platform after the posting of amendments constitutes unconditional acceptance of the amended Legal Framework.

29.3 Material amendments that affect User rights under the DPDP Act will be communicated via email or WhatsApp to Users who have provided contact details, where reasonably practicable.

Section 30 — Severability, Waiver, and Entire Agreement

30.1 If any provision of this Legal Framework is found to be illegal, invalid, or unenforceable by a court of competent jurisdiction, such provision shall be severed and the remaining provisions shall continue in full force and effect.

30.2 MeraEMI's failure to enforce any provision of this Legal Framework on any occasion shall not constitute a waiver of its right to enforce such provision in the future.

30.3 This Legal Framework constitutes the entire agreement between MeraEMI and the User regarding the subject matter hereof and supersedes all prior representations, communications, and understandings.

Privacy Policy — DPDP Act 2023 · Data Fiduciary: Checklyst Solutions Pvt Ltd

PART C — PRIVACY POLICY

Effective Date: 1 January 2019 | Governing Law: Digital Personal Data Protection Act, 2023 (India)

Section 9 — Data Fiduciary Identity

9.1 Checklyst Solutions Pvt Ltd, operating as MeraEMI, is the Data Fiduciary within the meaning of the DPDP Act 2023 with respect to all personal data collected through the Platform.

9.2 MeraEMI's Data Protection contact for grievances, consent withdrawal requests, and erasure requests is: meraemiloans@gmail.com (or such address as MeraEMI may designate from time to time).

Section 10 — Data Collected

10.1 Data Collected through Arya (leads.meraemi.com)

  • Full name
  • Mobile number (stored in Fernet-encrypted form)
  • Business type and nature of enterprise
  • Business vintage (years in operation)
  • Annual turnover range
  • CIBIL score range (self-reported)
  • Loan type required and loan amount range
  • Device type and approximate location (city-level, from IP)
  • UTM campaign parameters and lead source tracking data

10.2 Data Collected through Disha (WhatsApp)

  • WhatsApp phone number and display name (provided by Meta platform)
  • All conversational responses to Disha's eligibility questions
  • Document upload confirmation metadata (file type only — no file bytes stored)
  • Session timestamps and conversation stage markers
  • AI-generated eligibility disposition (qualified / not qualified / manual review)

10.3 Data Collected through Social Media Interaction

  • Name and profile information visible on the relevant platform
  • Message content of direct messages sent to MeraEMI pages
  • Engagement data (likes, comments, shares) as made available by the platform

10.4 Technical and Analytical Data

  • Browser type, operating system, and device specifications
  • IP address and approximate geolocation
  • Meta Pixel event data (page views, lead events, conversion signals)
  • Server-side Conversions API (CAPI) data transmitted to Meta for ad performance measurement

Section 11 — Purpose and Legal Basis of Processing

11.1 MeraEMI processes personal data for the following purposes:

Purpose Legal Basis (DPDP Act) Retention Period
Lead capture and transmission to Lenders Consent (S.6) 3 years or until consent withdrawn
AI-driven preliminary eligibility assessment Consent (S.6) Session + 90 days
Communication with Users regarding loan enquiry Consent + Legitimate Use 3 years from last interaction
Regulatory compliance and audit trail Legal Obligation 7 years (IT Act / PMLA)
Digital advertising measurement (Meta Pixel / CAPI) Consent 90 days (Meta policy)
Fraud prevention and security Legitimate Use 3 years
Grievance redressal (Loan Sahayak) Consent + Legal Obligation 5 years from case closure

Section 12 — Data Sharing and Transmission

12.1 MeraEMI shares User personal data in the following manner, consistent with the purpose for which it was collected:

12.2 With Lenders (Banks and NBFCs)

User Lead data is transmitted to Lenders directly associated with MeraEMI for credit evaluation. Such Lenders are independently regulated by the Reserve Bank of India and are themselves Data Fiduciaries with independent obligations under the DPDP Act.

12.3 With Corporate DSAs

MeraEMI may route Lead data through Corporate DSAs who maintain independent agency or channel partner agreements with Lenders. Corporate DSAs process Lead data under their own regulatory and contractual obligations. MeraEMI is not responsible for data processing by Corporate DSAs after transmission.

12.4 With AI Service Providers

Disha's conversational AI engine relies on Google LLC (Gemini API) and Anthropic PBC (Claude API) as sub-processors. These providers process conversation text to generate AI responses. MeraEMI has entered into data processing agreements with these providers that prohibit use of User data for model training without explicit consent.

12.5 With Meta Platforms Ireland Ltd

Meta Pixel and Conversions API data is transmitted to Meta Platforms Ireland Ltd for advertising measurement and attribution. This is governed by Meta's Business Tools Terms and MeraEMI's ad account data use settings.

12.6 With Regulatory and Law Enforcement Authorities

MeraEMI will disclose personal data to regulatory bodies, law enforcement agencies, courts, or tribunals when required to do so by applicable Indian law, court order, or regulatory direction.

12.7 MeraEMI does NOT sell User personal data to any third party for commercial purposes unrelated to loan facilitation.

Section 13 — User Rights under DPDP Act 2023

13.1 As a Data Principal under the DPDP Act, Users have the following rights, exercisable by written request to meraemiloans@gmail.com: - Right to access a summary of personal data held by MeraEMI - Right to correct inaccurate personal data - Right to erasure of personal data, subject to MeraEMI's legal retention obligations - Right to withdraw consent at any time, prospectively, without affecting processing already completed - Right to grievance redressal within the timelines specified by the DPDP Act - Right to nominate a person to exercise rights on the User's behalf

13.2 Withdrawal of consent will result in cessation of the User's access to MeraEMI services and will not entitle the User to recall any Lead data already transmitted to Lenders prior to the withdrawal.

13.3 MeraEMI will respond to data rights requests within 30 days of receipt of a verifiable written request.

Section 14 — Data Security

14.1 MeraEMI implements the following technical and organisational security measures: - TLS 1.2+ encryption for all data in transit - Fernet symmetric encryption for sensitive data fields at rest - PostgreSQL database with role-based access controls - VPS infrastructure secured behind SSH key authentication with non-default port - No storage of document bytes — only document receipt confirmation metadata - Admin panel access protected by session-based authentication

14.2 Notwithstanding the above, no digital system is absolutely immune to security breaches. MeraEMI will notify affected Users and the Data Protection Board of India of any data breach in accordance with the notification requirements under the DPDP Act.

Section 15 — Cookies and Tracking

15.1 The Platform uses the following tracking technologies: - Session cookies for user authentication and form state management - Meta Pixel (ID: 836450395691718) for tracking standard events including PageView and Lead - Server-side Conversions API (CAPI) for privacy-resilient ad measurement - UTM parameter capture for marketing attribution

15.2 Users may disable cookies through their browser settings, which may affect Platform functionality.

Disclaimer & Limitation of Liability

PART D — DISCLAIMER AND LIMITATION OF LIABILITY

Section 16 — General Disclaimer

⚠️ THE PLATFORM AND ALL SERVICES ARE PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTY OF ANY KIND, EXPRESS OR IMPLIED. MERAEMI EXPRESSLY DISCLAIMS ALL WARRANTIES INCLUDING BUT NOT LIMITED TO WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.

16.1 MeraEMI makes no warranty or representation that: - Any User will be approved for a loan by any Lender - The Platform will be continuously available, error-free, or free of technical disruption - Any interest rate, loan term, or product feature communicated through the Platform reflects a Lender's actual current offering - Disha's AI-generated responses are accurate, complete, or current at the time they are read - A User's preliminary eligibility assessment through Arya will translate to formal loan approval

16.2 All loan disbursements, interest rates, processing fees, security requirements, and terms of credit are determined solely and exclusively by the relevant Lender in accordance with such Lender's internal credit policy. MeraEMI has no influence over, and makes no representation regarding, any Lender's credit decisions.

Section 17 — Limitation of Liability

17.1 To the maximum extent permitted by applicable Indian law, MeraEMI, its directors, officers, employees, agents, representatives, and assigns shall not be liable for: - Any direct, indirect, incidental, consequential, punitive, or special loss or damage arising from use of the Platform - Loss of loan opportunity, loss of business, loss of profit, or financial loss of any nature - Any loss arising from a Lender's rejection of a loan application, withdrawal of an in-principle offer, or imposition of terms different from those initially indicated - Errors, omissions, interruptions, or failures in the AI models (Gemini, Claude) powering Disha - Unauthorised access to User data resulting from a security breach beyond MeraEMI's reasonable control - Content on third-party websites or social media platforms linked to or from the Platform - Actions, omissions, decisions, or communications of any Lender or Corporate DSA following transmission of Lead data

17.2 Where liability cannot be excluded by law, MeraEMI's aggregate liability to any User shall be limited to an amount not exceeding INR 5,000 (Indian Rupees Five Thousand Only) or the documented direct loss suffered by the User as a result of MeraEMI's specific negligent act, whichever is lower.

Section 18 — AI and Automated Decision-Making Disclaimer

18.1 Disha and Arya use automated algorithms and AI models to conduct preliminary eligibility assessments. These assessments are indicative only. No automated decision on the Platform constitutes a final credit decision or legally binding determination of creditworthiness.

18.2 AI language models (Google Gemini, Anthropic Claude) may occasionally produce inaccurate, outdated, or contextually inappropriate responses. MeraEMI does not warrant the accuracy of AI-generated content and Users should not rely on it as the sole basis for financial decisions.

18.3 Disha applies sensitivity gates to prevent the transmission of legally sensitive statements. Notwithstanding this, MeraEMI expressly disclaims any AI "hallucination" or error that results in a statement that could be construed as a loan offer, regulatory advice, or legal commitment.