Privacy Policy

Effective Date: 09 June 2026  |  Last Updated: 09 June 2026

This Privacy Policy (“Privacy Policy”) describes how Prodigal Money (“Prodigal Money,” “we,” “our,” or “us”) collects, uses, shares, and safeguards personal information when consumers, creditors, and other parties interact with our services, including our websites (theprodigalmoney.com and prodigalmoney.com), telephony channels, SMS communications, and account servicing platforms (collectively, the “Services”).

Prodigal Money is a brand and division of ZAP TECH PRIVATE LIMITED, an Indian private company registered with the Ministry of Corporate Affairs under CIN U74900PN2012PTC143202, ISO/IEC 27001:2022 certified, with registered office at 534, Amanora Chambers, Amanora Park Town, Hadapsar, Pune – 411028, Maharashtra, India.

1. Scope and Applicable Law

This Privacy Policy applies to personal data processed in connection with consumer accounts placed with Prodigal Money by original creditors of record (such as banks, credit issuers, and lenders) for collection or servicing in the United States. We adhere to the following frameworks:

• Fair Debt Collection Practices Act (FDCPA), 15 U.S.C. § 1692 et seq.
• Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227 and 47 C.F.R. § 64.1200
• California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA)
• CTIA Short Code Monitoring Handbook and 10DLC carrier-compliance standards
• Digital Personal Data Protection Act, 2023 (DPDP Act) of the Republic of India, where applicable
• ISO/IEC 27001:2022 Information Security Management System controls

2. Personal Information We Collect

2.1 Data Received from Original Creditors

When an original creditor places a consumer account with Prodigal Money for collection or servicing, we receive identifying and account information transferred under written agreement and applicable law. This typically includes:

• Name, date of birth (last four digits), and last known addresses
• Last known telephone number(s), including mobile
• Email address(es) on file
• Account number(s), balance, last payment date, and account status
• Identity of the original creditor and any prior placement parties
• Consent records evidencing the consumer’s prior agreement to be contacted

2.2 Data We Collect Directly

• Information you provide when contacting us by phone, SMS, email, mail, or our consumer portal
• Payment information (processed through PCI-DSS-compliant third-party processors)
• Communication records including call recordings (where lawful and disclosed)
• Dispute submissions, identity-theft assertions, and cease-and-desist requests

2.3 Data We Obtain from Public and Authorized Sources

• Public records (court filings, civil judgments, address-history aggregators)
• Skip-trace and contact-verification vendors operating under license
• Credit reporting agencies under FCRA-permissible purposes

3. How We Use Personal Information

• To service consumer accounts placed by original creditors, including communicating about balance, status, payment options, and resolution paths
• To provide the FDCPA validation notice within five (5) business days of initial communication
• To process payments and issue receipts
• To respond to consumer disputes, identity-theft claims, and opt-out requests
• To send SMS communications strictly within the scope described in our SMS Policy
• To meet legal, regulatory, audit, and reporting obligations
• To prevent fraud and protect the integrity of our operations

4. SMS and Mobile Telephone Number Handling — Twilio / 10DLC Specific

Consent to receive SMS messages is established at the time of the consumer’s original agreement with the creditor of record and transfers to Prodigal Money under the placement assignment per FDCPA and CTIA Short Code Monitoring Handbook §5.2. Consumers may revoke that consent at any time by:

• Replying STOP, END, QUIT, CANCEL, UNSUBSCRIBE, OPTOUT, or REVOKE to any SMS
• Calling our toll-free consumer line published on our consumer page
• Emailing support@prodigalmoney.com
• Sending written notice by mail to the address in §15 below

Full SMS practice disclosures including message frequency, sample messages, opt-in keywords, help instructions, and rate disclosures are documented in our dedicated SMS Policy.

5. How We Share Personal Information

We share personal information only as needed to operate our Services and meet legal obligations:

• With the original creditor who placed the account, for status reporting and remittance
• With service providers bound by contractual confidentiality and data-use restrictions, including payment processors, telephony providers (Twilio), email and SMS infrastructure providers, skip-trace vendors, and licensed compliance auditors
• With governmental, regulatory, and judicial authorities as required by law, subpoena, or other valid legal process
• With consumer reporting agencies as permitted under the Fair Credit Reporting Act

We do not sell, rent, or share personal information — including mobile telephone numbers, SMS opt-in records, or message content — with any third party or affiliate for marketing, advertising, or resale purposes.

6. Consumer Rights and Choices

• Right to validate the alleged debt under FDCPA §1692g
• Right to dispute the debt or any portion of it
• Right to cease communication by written request under FDCPA §1692c(c)
• Right to opt out of SMS at any time by any of the methods in §4 above
• CCPA / CPRA rights for California residents: right to know, right to delete, right to correct, right to opt-out of sale or sharing, right to limit use of sensitive personal information, and right to non-discrimination. Submit requests to privacy@prodigalmoney.com. We do not sell personal information.
• DPDP Act rights for data principals in India: right to information, correction, erasure, and grievance redressal — see §13 below

7. Information Security

Personal information is protected under the ZAP TECH PRIVATE LIMITED ISO/IEC 27001:2022 Information Security Management System, including:

• Encryption in transit (TLS 1.2+) and at rest
• Role-based access controls and audit logging
• Regular vulnerability assessments and penetration testing
• Employee security training and confidentiality agreements
• Documented incident response and breach notification procedures

8. Data Retention

We retain personal information for the duration of the consumer account relationship and afterward only as required by:

• Federal and state record-retention laws applicable to debt collectors (typically 3–7 years post-resolution)
• FDCPA and state DCL compliance audit requirements
• Tax, accounting, and statute-of-limitation periods
• Pending or anticipated legal proceedings

Mobile telephone numbers and SMS opt-in records are retained for thirty-six (36) months following the last consumer interaction, after which they are anonymized or securely deleted.

9. Cookies and Online Tracking

Our public-facing websites use minimal cookies for site functionality and analytics. No cross-site tracking or advertising cookies are used.

10. Children’s Information

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors.

11. International Data Transfers

Personal information may be processed in the United States (by Prodigal Money U.S. operations and authorized service providers) and in India (by ZAP TECH PRIVATE LIMITED operations) under appropriate contractual safeguards.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be communicated by posting a revised version on this page with an updated “Last Updated” date. We encourage you to review this Policy periodically.

13. Grievance Officer (DPDP Act, India)

For complaints related to processing of personal data under Indian law, please contact:

Avinash Kushwaha
Founder & CEO, ZAP TECH PRIVATE LIMITED
Email: grievance@prodigalmoney.com
Response time: within thirty (30) days of receipt of complaint.

14. Governing Law

For U.S. consumer matters, this Privacy Policy is governed by applicable U.S. federal and state law including the FDCPA, TCPA, and CCPA. For matters governed by Indian law, it is governed by the laws of the Republic of India, including the Information Technology Act, 2000 and the Digital Personal Data Protection Act, 2023.

15. Contact Us

Prodigal Money – Consumer Support
Email: support@prodigalmoney.com
Privacy / data requests: privacy@prodigalmoney.com
Web: theprodigalmoney.com/consumer.html

Parent Entity:
ZAP TECH PRIVATE LIMITED — CIN U74900PN2012PTC143202
534, Amanora Chambers, Amanora Park Town, Hadapsar,
Pune – 411028, Maharashtra, India
Email: info@zaptech.co.in