Electronic Communications and Call-Recording Notice
Version 1.0 · Effective date: 21 September 2026 · Last updated: 21 September 2026
1. Channels we use
| Channel | Used for | With whom | Notes |
|---|---|---|---|
| Telephone (calls from +91 80 6824 8827 and our staff's business mobile numbers) | Operational calls: verifying a claim, discussing an account, agreeing a payment schedule, confirming a promise to pay | Clients; debtor representatives | Working hours only (Mon–Sat, 9 AM–6 PM IST, excluding public holidays) |
Email (from @kenstonecapital.in addresses only) |
Notices, statements, confirmations of promises, reports | Clients; debtor representatives | We never send from personal email accounts |
| WhatsApp (business account on +91 80 6824 8827) | Confirming promises to pay, sharing statements and documents, scheduling | Debtor representatives who use WhatsApp for business; clients | Messages come only from the official business account; staff do not use personal WhatsApp for any matter |
| SMS | Not used. We do not send SMS to clients or debtors | — | If we ever use SMS, it will be sent only under a registered header and template as the TRAI Telecom Commercial Communications Customer Preference Regulations, 2018 (as amended February 2025) require, and this notice will be updated first |
| Letters and courier | Demand communications, statements, settlement letters | Debtor businesses | On Kenstone letterhead showing the legal name, CIN, registered office and the client we act for |
| Visits | Field collection at business premises | Debtor businesses | See the Responsible Collection Policy §4.4 |
| Video meetings | Settlement discussions where useful | Clients; debtor representatives | By invitation only; not recorded without notice |
We do not contact anyone through personal social-media accounts, and we do not use auto-dialers or robocalls.
2. Call recording
2.1 We do not record calls at present. We intend to introduce call recording. Before we do, we will update this notice with the date recording starts and the system used, and from then on every recorded call will begin with: "This call is from Kenstone Capital on behalf of [client]. It is being recorded for accuracy and quality." Sections 2.2 to 2.4 describe how recordings will be handled once recording begins.
2.2 Recordings are used to keep an accurate record of what was said, to confirm promises to pay and disputes, to monitor quality and conduct, to investigate complaints, and, where necessary, as evidence in legal proceedings.
2.3 Recordings will be stored on our telephony system with the date, time and the identity of the caller, protected by access controls, and kept for 3 years after the matter closes unless a complaint, dispute or legal hold requires longer. Access is limited to the practitioner, a supervisor for quality review, and the Grievance Officer for a complaint.
2.4 You may ask for a copy of the recording of a call you took part in, through the Privacy Rights Request form. We will provide it, or a transcript, unless a legal reason prevents it.
2.5 If a call is not being recorded, we do not say that it is.
3. Written records
Emails, WhatsApp messages and letters exchanged on a matter are stored on our collection platform as part of the case file and are kept under the retention schedule in the Privacy Policy. WhatsApp threads are exported to the platform from the official business account; the account is not used from personal devices.
4. Quality monitoring
A supervisor who did not handle the account samples call notes and written communications (and, once introduced, recorded calls) monthly against the Responsible Collection Policy. Findings are used for training and, where needed, for disciplinary action.
5. Evidentiary use
Recordings and records may be produced in proceedings between the client and the debtor. We keep them with integrity — original files, timestamps and access logs — so that a certificate under section 63 of the Bharatiya Sakshya Adhiniyam, 2023 can be given when required.
6. Marketing communications
6.1 We do not send marketing communications to debtor businesses or their representatives. Ever.
6.2 We send marketing communications (for example an occasional practice note or invitation) to a client or prospect contact only where that person has separately opted in on our website or in writing. Marketing consent is never bundled with an enquiry, a contract or an operational message, and no marketing box is pre-ticked.
6.3 Every marketing message carries an unsubscribe link or reply instruction that takes effect within 5 working days.
7. Operational communications you cannot opt out of
While a matter is open, a debtor business will receive the operational communications the matter requires — statements, notices, confirmations — through the business channels above. You may nominate a contact person and channel in writing, and we will use them. You may ask us to stop calling and communicate in writing only; we will do so unless a matter needs a conversation, in which case we will ask for a time.
8. Legally required notices
Statutory notices — for example under section 8 of the Insolvency and Bankruptcy Code, 2016 or section 138 of the Negotiable Instruments Act, 1881 — are issued by, or under the supervision of, an independent advocate and served as the law requires. A communication from Kenstone is a demand on the client's behalf and is not a statutory notice unless it says so and is issued by an advocate.
9. Communication preferences and complaints
Write to info@kenstonecapital.in quoting the reference on any notice to set a preferred channel, contact person or time. Complaints about how we have communicated go to the Grievance Officer under the Grievance Redressal Policy.
Earlier versions of this document are available on request from info@kenstonecapital.in. Questions or complaints: Grievance Redressal Policy.