PRIVACY POLICY OF V-Pay FINANCE

SIDDHI TRADERS PRIVATE LIMITED

PRIVACY POLICY

1. BACKGROUND

This Privacy Policy has been framed in compliance with:

• A. Information Technology Act, 2000 ("IT Act") and corresponding rules as may be notified from time to time, including Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021;
• B. Digital Personal Data Protection Act, 2023 ("DPDPA") and corresponding rules as may be notified from time to time;
• C. Guidelines on Digital Lending issued by the Reserve Bank of India (RBI), 2022 ("DLG"); and
• D. Other applicable acts, regulations and rules which requires the publishing of a privacy policy for handling of or dealing in personal Information including sensitive personal data or Information and all applicable laws, regulations, directions, guidelines provided by applicable regulatory authorities, including but not limited to the Reserve Bank of India ("RBI").

Which requires SIDDHI TRADERS PRIVATE LIMITED (hereinafter referred to as “V-Pay FINANCE”) to provide policy for collects, receives, possess, stores, deals, handle or storage and disclosure of information.

This Privacy Policy is incorporated into and at all times is subject to and is to be read in conjunction with the Terms of Use of the Platform and Terms and condition of Lender.

The “V-Pay FINANCE” or any person who on behalf of “V-Pay FINANCE” collects, receives, possess, stores, deals or handle information of provider of information, should adhere privacy policy for handling of or dealing in personal information including sensitive personal data or information and ensure that the same are available for view by such providers of information who has provided such information under a lawful contract. Such policy should be published on site of the “V-Pay FINANCE”.

2. PURPOSE

“V-Pay FINANCE” intends to protect the privacy of its users and members on its site and maintain the privacy of the data provided by them to V-Pay FINANCE from time to time and strongly committed to protecting the personal information, including but not restricted to, Sensitive Personal and Financial Information that customer submits to us and we would endeavour to protect it from unauthorized use.

This Privacy Policy provides you with details about the way your data is collected, stored, and used by us and you are advised to read this privacy policy carefully.

By visiting the site, you consent to the use and disclosure of your personal information in accordance with the terms and conditions of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use or access the site.

Please contact us at contact@Vpayfinance.in if you have additional questions or require additional information about our privacy policy. This Privacy Policy is applicable for all our ongoing online activities and is also valid for visitors who come to our website and the information that they share and/or collect in ‘V-Pay FINANCE”.

Information collected offline or through channels other than this website do not fall under the purview of this Privacy Policy.

Since the Platform provides (i) services in relation to facilitating the disbursement of lending products/loans offered by Lending Partners ("Digital Lending Services"); and any and all other services that may be provided on the Platform from time to time ("Additional Services"); and (collectively the "Services") to its Users, for the ease of reference, we have divided the Privacy Policy into four sections:

• Section A – Account Creation and Registration
• Section B – Digital Lending Services
• Section C – UPI Collection Services
• Section 4 – Miscellaneous Services

3. DEFINITIONS

“We”, “our” and “us” refer to “V-Pay FINANCE”

“Site” refers to the website, mobile application, and the application that we provide and which includes a link to our Online Privacy Policy

“You” or “your” refers to anyone who visits, accesses, browses or uses the V-Pay FINANCE website at https://Vpayfinance.com or obtains our services through our website.

“Personal Information”: means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.

“Sensitive Personal and Financial Information”: means such personal information that is otherwise not available to anyone except the customer, such as password, financial information, sexual orientation, medical records, and physical, physiological, and mental health condition. Such information is generally not available in the public domain.

4. Section A – Account Creation and Registration

1.1. COLLECTION OF INFORMATION

While availing of service or products or using the site V-Pay FINANCE all information’s collected on the Platform for Creation of Account and Registration to avail services as a user may collect and process information from the customers including your mobile no, e mail id, consent (other than consent specified in Digital Lending Services and Miscellaneous Services information that is confidential in nature but not limited to the below mentioned.

1. Information that the users provide to V-Pay FINANCE by filling in forms on the website. This includes contact information such as name, email address, mailing address, phone number, financial details, family details, banking relationships, password and transaction history, etc.
2. We also collect information through supporting documents collected as per Know Your Customer (KYC) guidelines issued by the Reserve Bank of India and other documents like statements of accounts, financial statements, etc. on behalf of our lending partner for the underwriting purpose.
3. Information that the users provide while registering for an account with us, such as name, address, email address, and telephone number.
4. Other personal information provided by third parties such as credit bureaus and identity verification services.
5. Information that you provide to V-Pay FINANCE when interacting with our customer support team or other team members via phone, email, online form, or other correspondence;
6. Personal information stored with third parties that you choose to provide to V-Pay FINANCE, such as social media account information and your social media contacts. By linking your third party accounts or using third party sign-in services, you authorize V-Pay FINANCE to have access to this information and you agree that V-Pay FINANCE may collect and use this information in accordance with this Privacy Policy.
7. Personal testimonial information or endorsements that you voluntarily provide to us and which we may display with your name on the V-Pay FINANCE Sites with your consent. To update or delete your testimonial, contact us at contact@Vpayfinance.in
8. Data provided during communications with us (for example, by e-mail or chat) with respect to Your account.
9. Data generated by Your general usage of our Platform, and when You report a problem with our Platform.

When the user uses the site, our servers automatically record certain information that the user’s web browser sends whenever the user visits any website. Such information is known as ‘LOG FILES’. These server logs may include information such as the user’s web request, Internet Protocol (IP) address, browser type, referring/exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information. We use this information, which may or may not identify users, to analyze trends, administer the site, track users movements around the site, and gather demographic information about the user base as a whole.

1.2. Collection of other than non personal information

Cookies: Cookies are small data files that the Website stores on Your computer. Use of this Information helps Us identify You in order to make our Website more user friendly. We do not store personal/identity Information in the cookies. You have the right to reject our access to Cookies since most browsers will permit You to decline cookies but if You choose to do this it might affect service on some parts of Our Website.

If You choose to avail any Services through the Platform, we collect Information about the manner in which You are using the Platform. We retain this Information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law. If You send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about Your activities or postings on the Website, we collect such Information into a file specific to You.

1.3. Consents sought as part of rendering the Services (through the Website or Application)

Upon creation of Your account and registration on the Platform, we collect the following Information which is mandatorily required for the Application’s functionality and performance. This access is enabled at the time You install the Application on Your mobile phone via Google PlayStore and Apple Store or visit the Website.

• Data Collected: Personal Information - Name, Contact No, E mail Address
  Purpose: Identification of user, prevention from unauthorized usages and platform or mobile application functionality.
• Data Collected:Device Information or other IDs such as log Information (via the domain server through which the User accesses the app search queries, IP address, crashes, date etc), browser details, device Information when You download and install the Application, usage Information, feedback and similar Information. Information the Website collects, and its usage, depends on how You manage Your privacy controls on Your device.
• Purpose: Your Log Information is collected (via the domain server through which the User accesses the Platform Search queries, IP address, crashes, date etc) for the purpose of improvising the Platform functionality, for Identity Verification, Fraud Prevention and app functionality.
• Data Collected: Application Information - Crash logs, Diagnostics and Other app performance data.
  Purpose: The Information related to the performance of the Platform and other diagnostic data is collected for identifying and resolving any technical glitches that may be identified from such Information, data analytics and also for app functionality.

1.4. Consents sought for Profile Creation and Registration (through our Application)

• Consent: You have read the terms of our Terms of Use/Terms & Conditions and this Privacy Policy.
  Purpose: Profile Creation and Registration
  Consent Type: Recurring
• Consent: to access Your Google email Information
  Purpose: Verify your identity and send communications.
  Consent Type: One Time
• Consent: Social Account Information - We may provide You with the option to register using social accounts (Google or Facebook) to access the app and shall collect only such registered email id and user public profile Information like name, email, ASID depending on the platform used by You to log-into the Website during registration/ sign in process for the Services.
  Purpose: We may collect and store email id and name associated with that account for the purpose of verification and to pre-populate relevant fields in the course of Platform interface.
  Consent Type: One Time
• Consent: Consent for sending promotional communication via SMS, Email and WhatsApp
  Purpose: Marketing and promotion.
  Consent Type: Recurring

2. Purpose of Collection

• 2.1. we strive to ensure that it is used for the following intended purposes only. We shall use the Information collected from You for facilitating the Services for the following purposes as detailed below


• Information is used for: Account/profile creation and registration
• Purpose of Collection : Your Profile Data is collected to establish/verify Your identity, and to create and verify Your account.


• Information is used for: For Enabling Customer Support
• Purpose of Collection : We use Your mobile number and email id (forming part of the Profile Data) to provide customer support, including to facilitate any request, customize Your experience and enforce our terms and conditions, and to resolve Your concerns in relation to Your account.


• Information is used for : Data Analytics
• Purpose of Collection : We may use the Profile Data collected to develop automated actions to be triggered in certain events. We may also use the Information collected to offer / recommend new products and services for Your use.We may further measure consumer interest and satisfaction in our products and services and manage Our relationship with You


• Information is used for : For Enabling Communications Between You and Us
• Purpose of Collection : We may add features that enable communications between You, and Us, and may access communications, notifications, Information regarding the products or services requested by You or process queries and applications that You have made on the Application, or for any transaction, promotion activity, marketing and/or commercial communications in relation thereto;
  We may also be required to disclose the Information under special circumstances such as compliance with the applicable local law, court summons, court orders, requests/order from legal authorities or law enforcement agencies requiring such disclosure.


• Information is used for : For Legal Purpose
• Purpose of Collection : We will use the Profile Data collected to and detect and protect us against suspicious or illegal activity, fraud, money laundering and other criminal activity, or to investigate, prevent, and take action against illegal activities, conduct forensic audits or investigate / address claims or disputes relating to Your account, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.


• Information is used for : Marketing and Promotion
• Purpose of Collection : We may use the Profile Data collected to market the different products and Services on the Application. This includes sharing Your feedback, ratings and screen names for purely promotion and marketing purposes. We may contact You for marketing and promotional purposes through e-mails, telephones, messages, SMS, WhatsApp or any other available modes and inform You about online and offline offers, products, services, and updates.

3. STORAGE OF PERSONAL INFORMATION

We ensure that all information collected by us from You under Account Creation and Registration stored in servers located within India. We ensure that no other personal Information belonging to You is collected by us. In case, if any of our representatives ask for the same from You, we request You to kindly refrain from doing the same and address this concern to our Grievance Officer (Mrs Tonika Jain)

4. DISCLOSURE TO GOVERNMENT AGENCIES

We will share Your Profile Data only on a need-basis with the governmental/ regulatory authorities, courts, regulators, law enforcement agencies, quasi-governmental authorities, judicial authorities and quasi-judicial authorities ("Government Agencies") if any Information is requested from us and we think that disclosure is required or appropriate in order to comply with laws, regulations or legal process. We may share Your Profile Data, as required, upon receipt of notice/communication/ order, as a part of Our legal obligations as per applicable laws as may be sought by the Governmental Agencies. By accepting this Privacy Policy, You hereby provide Your consent to disclose Your personal Information for such regulatory disclosure

5. DISCLOSURE TO THIRD PARTIES

• a) Your Profile Data will also be shared with Lending Partners and Additional Service Partners ("Platform Partners"), strictly based on the nature of Services availed by You, and in terms of the policy set out in the respective Part of this Policy, as applicable.
• b) We will share Your Information under a confidentiality agreement with these Platform Partners and restrict use of the said Information by these Platform Partners specifically for the purposes detailed hereinabove.
• c) If we are under a duty to disclose or share Your personal Information in order to comply with any legal or regulatory obligation or request, we shall not seek Your explicit consent nor notify the same to You;
• d) We shall share Your Information with third-party only on a need basis and only for the purpose stated hereunder, as per the applicable laws.
• e) We shall additionally seek explicit consent at appropriate stages of Information collection, if so required under applicable laws; and
• f) Usage of Your Information by such Platform Partners is subject to their privacy policies. We share Information with them to the extent required. We recommend You to go through the privacy policies of such Platform Partners

6. DATA RETENTION AND DELETION

• a) We retain Your Profile Data to provide a seamless experience, to contact You in case of support required and about Your account, to detect, mitigate, prevent, and investigate fraudulent or illegal activities during the course of the Services.
• b) We retain Your Profile Data from the date of creation of Your account on the Platform (a) for period of 8 (eight) years from the last date of submission of Information or inactivity, if You have registered on the Application but not availed any Services;
  and for a period of 10 (ten) years from the last date of Services availed, or inactivity, if You have availed any of the Services on the Application.
• c) The Profile Data retained by Us will be subject to Your right to withdraw/deny Your consents as per the terms of this Policy and the retention requirements as per applicable laws. Please note, certain Profile Data (such as mobile and email address required for account creation) is mandatory for maintaining an account with us and availing any of the Services on the Application, and hence Your request to delete such Information will be addressed only after closure of all Services availed by You and deletion of Your account on the Platform.

5. Section B – Digital Lending Services

“V-Pay FINANCE” only facilitate collection of the Digital Data via the Platform, We do not store any such Digital Data collected via the Platform (other than Profile Data as detailed in Part A of this Policy).

Below Digital Data is collected in addition to Profile data as described in Section A of this policy.

• - Data provided during communications with us (for example, by e-mail or chat) in relation to any Digital Lending Services
• - Data, consents and Information that You provide when You subscribe to any Digital Lending product or service, search for a loan product, and when You report a problem with any of our Digital Lending Services;
• - Data received by us from third parties based on consents given by You under this Part-B of Privacy Policy; and
• - Data generated by Your usage of our Platform while availing Digital Lending Services.

• Data Category:Personal and Demographic Information including but not limited to Mobile, Email, Name, Gender, DOB, Address, postal code, PAN.
• Purpose: Account Creation, Identity Verification, Customer KYC, Fraud Prevention, Underwriting Enabling Communication and Customer Support, Legal Compliance, Advertisement and Marketing. This Information is used for identifying You, preventing unauthorised access and providing the Digital Lending Services to uniquely identify, register and enable You to use the Website. This Information is also used for the purpose of underwriting You in order to determine Your eligibility as part of offer of loan products to You.
  Mandatory / Optional: Mandatory
• Data Category: PAN and Credit Info from Bureaus
  Purpose: Underwriting, Legal Compliance
  Mandatory / Optional: Mandatory

Data Category - Device hardware details Device hardware Information or other IDs such as log Information (via the domain server through which the User accesses the app search queries, IP address, crashes, date etc), device Information when You download and install the Application. Information the Website collects, and its usage, depends on how You manage Your privacy controls on Your device

Purpose - Your Log Information is collected (via the domain server through which the User accesses the Platform Search queries, IP address, crashes, date etc) for the purpose of improvising the Platform functionality, for Identity Verification and Fraud Prevention. The Information related to the performance of the Platform and other diagnostic data is collected for identifying and resolving any technical glitches that may be identified from such Information and also for improving the overall functionality of the Website.

Mandatory / Optional – Mandatory Mandatory if applied through the Applications on iOS or Android

Data Category - KYC Information

Purpose - Identity Verification and Fraud Prevention, Legal Compliance.

Mandatory / Optional – Mandatory

Data Category - Geolocation and IP Information

Purpose - Identity Verification/Customer KYC and Fraud Prevention

Mandatory / Optional – Mandatory

Data Category - Reference Information including name, number and address of References that You provide to the Lending Partners voluntarily

Purpose - Identity Verification, Fraud Prevention, and Loan Collection

Mandatory / Optional – Mandatory

Data Category - SMS and Installed apps Information –We collect, store and monitor SMS Information from your device. A list of specific installed applications’ metadata Information is collected, which includes the application name, package name, installed time, updated time, version name and version code of each installed application on Your device. This Information may be collected even when the application is closed or not in use.

Purpose - This Information is used to provide You with updates or confirmation of any actions taken during the term of Digital Lending Services, provide customised offers, Identity Verification, Fraud Prevention, Underwriting

Mandatory / Optional – Mandatory

Data Category - Transaction Information

Purpose - For Enabling the App and its Services, Legal Compliance

Mandatory / Optional – Mandatory

Data Category - Usage Information

Purpose - For enabling and enhancing the Digital Lending Services

Mandatory / Optional – Mandatory

Data Category - Feedback and similar Information

Purpose - For Enabling the App and its Services

Mandatory / Optional – Mandatory

Data Category - Risk evaluation score received from payment gateway providers

Purpose - underwriting

Mandatory / Optional – Mandatory

Data Category - Employment Information

Purpose - Underwriting and assessing financial repayment capability

Mandatory / Optional – Mandatory for Salaried

Data Category - Financial Information

Purpose - Underwriting and assessing financial repayment capability

Mandatory / Optional – Mandatory

Data Category - Financial Information

Purpose - Underwriting and assessing financial repayment capability

Mandatory / Optional – Mandatory for Salaried

Information collected by the Application from You

The collection of Data on the Platform in accordance with this Section-B of Privacy Policy is done for facilitating Digital Lending Services being provided by V-Pay FINANCE in the capacity of a ‘lending services provider’ (LSP) or ‘digital lending application’ (DLA) (both terms as defined under the DLG) of the regulated entities who are registered with the RBI, holding valid COR and whose details are available on the Website, the Application and application stores (such as Google PlayStore and Apple App Store) ("Lending Partners")

The entire collection, processing and storage (to the extent permitted under applicable laws) of DL Data is done on a standalone basis, in accordance with this Part-B of the Privacy Policy and not accessible for any of the other Services set out in other Parts of this Privacy Policy.

V-Pay FINANCE‘s role with respect to Digital Lending Services is limited to facilitating the access of Data pertaining to or provided by You on the Platform to our Lending Partners in a secure manner and to ensure that all the recipients of Your personal Information comply with data protection, confidentiality, fidelity and secrecy obligations and duly execute covenants in this regard.

V-Pay FINANCE have indicated in this Part-B the mandatory and the optional fields of Information required from You. You always have the option to not provide any Information by choosing not to use a particular service or feature on the Platform. While You can browse some sections of our Platform without being a registered member as mentioned above, certain activities (such as availing of loans from the Lending Partners on the Platform) require registration and for You to provide the mandatory details.

Consents sought by us and our Lending Partners as part of rendering Digital Lending Services

Nature of Information/Consent sought	Purpose	Mandatory/ Optional
Your consent that (a) You have read the terms of the Terms of Use/Terms & Conditions and privacy policy(ies) of the respective Lending Partners, (b) You consent to us sharing your Information with the Lending Partners as per this Policy, and (c) using the Platform and allowing Lending Partners to collect (via the Platform), process and further share the DL Data as per their policy(ies) for availing the Digital Lending Services.	For availing the Digital Lending Services Consent type: Recurring	Mandatory
Consent for Digital Lending Partners to send promotional communication via SMS, Email and WhatsApp	For availing Digital Lending Services Consent type: Recurring	Mandatory at the time of availing a Digital Lending Service
Consent for verifying Your PAN on the various PAN databases	Customer KYC Consent type: Recurring	Mandatory
Consent for increasing Your credit limit (if required) for availing any loan product on the Application.	Customer KYC Consent type: One-time	Mandatory
Consent to obtain Your CKYC record from CERSAI for CKYC verification	Customer KYC Consent type: Recurring	Mandatory
Consent for acceptance of Terms of Use of V-Pay FINANCE for completing video KYC	Underwriting Consent type: One time	Mandatory
Consent for submission of e-KYC	Customer KYC Consent type: One time	Mandatory (if option availed)
Consent for availing insurance services	Loan Servicing Consent type: One time	Mandatory (if insurance option availed)
Consent to fetch Your credit report from credit information bureaus	Underwriting, Loan Servicing Consent type: Recurring	Mandatory
Consent for obtaining Your SMS Information and installed apps on Your device	Underwriting, Fraud Prevention, Loan Servicing Consent type: Recurring	Mandatory for all Loan Products on Android Application. Optional for iOS Application and Website
Consent for collecting Your financial Information from account aggregators	Underwriting Consent type: Recurring	Optional
Consent to access Your Location and IP Information	Customer KYC, Fraud Prevention Consent type: One time	Mandatory
Consent to access Your Microphone	Customer KYC, Fraud Prevention Consent type: One time	Mandatory
Consent to access Your camera (to share photos of necessary documents)	Customer KYC, Fraud Prevention Consent type: One time	Mandatory
Consent to get Your risk evaluation score from payment gateways	Underwriting Consent type: Recurring	Mandatory

PURPOSE OF COLLECTION

V-Pay FINANCE strive to ensure that it is used for the following intended purposes only.

V-Pay FINANCE shall use the Information collected from You for facilitating the Digital Lending Services for the following purposes as detailed below.

At various stages during Your loan journey (i.e. from the moment You register on the Platform for availing a Digital Lending Service till the repayment of any loan product availed by You via our Platform), we facilitate collection of different sets of Digital Data via the Application. The intended purpose of collecting such Information provided by You is summarised below:

Used For	Purpose
Account creation and registration	Your personal Information is collected to establish/verify Your identity, register You as a User of the Platform, and to create and verify Your account.
Enabling the Application and the Services	We use this Information to enable the Digital Lending Services on the Application and Website, as well as the features on the Application that help You check Your loan and transaction history, and other such Website features as may be added from time to time. This also provides us critical usage Information and feedback Information on the activity on the Platform.
Supporting Customer KYC, Underwriting, and Loan Processing	We facilitate collection of the Data by the Lending Partners as per this Section -B of Privacy Policy to enable provision of Digital Lending Services on the Platform. All Information collected for supporting customer KYC, underwriting and loan processing aims to assess and analyse Your creditworthiness, loan eligibility, KYC documents and current employment verification as per instructions from our Lending Partners and to provide You with the Digital Lending Services i.e. facilitating loans and providing the terms of Your loan by our Lending Partners to You. For this purpose, by installing the Platform and availing the Digital Lending Services, You hereby consent to voluntarily submit KYC documents and other documents/Information to our Lending Partners as further detailed in this Privacy Policy. You further hereby grant the Lending Partners explicit consent to fetch Your KYC (Know Your Customer) details from the Central KYC Records Registry using the details provided by You. You are aware that Your KYC details would be downloaded from the Central KYC Registry, solely for performing customer due diligence on You in order to process the loan application. You also declare that Your Information on the Central KYC Registry is updated and has not been subjected to any change, as on the date of making the loan application. You further grant Lending Partners explicit consent to validate, process, upload and/ or share Your KYC details and other legally mandated Information with the Central KYC Records Registry. The Lending Partner also use the Information to track disbursement and repayment of Your loan and display the status of the loan on the Application. We have the right to receive the Information from the Lending Partners and facilitate the display on the Application. We may provide Your personal Information to such third parties as listed/linked in this Privacy Policy strictly for facilitating the Digital Lending Services, who may then use such Information in accordance with their privacy policy, which shall include to process such personal Information in order to send You communications to solicit their products or services.
For Enabling Customer Support	We and our Lending Partners use the Information to provide customer support, including to facilitate any transaction request, customize Your experience and enforce our terms and conditions, and to resolve Your concerns from the use of the services on the Platform (in consultation with our Lending Partners, if required). Further, the contact details (i.e. the phone number) of references provided by You at the time of loan application may be used for the purpose of establishing contact in case we are unable to contact You, including at the time of collection of instalments based on the instructions of our Lending Partners;
Data Analytics	We may use the Information collected for analysis, product development to improve the UI/UX experience, and also to analyse how the Platform is used, diagnose service or technical problems and maintain security, troubleshoot problems, monitor, improve and administer our Platform – all of which will ultimately improve how You experience the Platform. This also helps us develop automated actions to be triggered in certain events, such as to identify if photographs uploaded are not clear, occurrence of fraud, incorrect IFSC etc. We may also use the Information collected to offer / recommend new products and services for Your use. We may further measure consumer interest and satisfaction in our products and services and manage Our relationship with You.
For Enabling Communications Between You and Us	We may add features that enable communications between You, and Us, including through the Platform or other channels, and may access communications, notifications, Information regarding the products or services requested by You or process queries (in consultation with the Lending Partners, if required) and applications that You have made on the Platform, or for any transaction, promotion activity, marketing and/or commercial communications in relation thereto; We may also be required to disclose the Information under special circumstances such as compliance with the applicable local law, court summons, court orders, request/order from legal authorities or law enforcement agencies requiring such disclosure
For Legal Compliance and Requirements	We and our Lending Partners may use the Information collected to and detect and protect us against suspicious or illegal activity, fraud, money laundering and other criminal activity, or to investigate, prevent, and take action against illegal activities, conduct forensic audits or investigate / address claims or disputes relating to use of Services (in consultation with the Lending Partners, if required), or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
Marketing and Promotion	We and the Lending Partners may use the Information collected to market the Platform/other lending services. This includes sharing Your feedback, ratings and screen names for purely promotion and marketing purposes. We and our Lending Partners may contact You for marketing and promotional purposes through e-mails, telephones, messages, SMS, WhatsApp or any other available modes and inform You about online and offline offers, products, services, and updates.

STORAGE OF PERSONAL INFORMATION

For facilitating the Digital Lending Services on the Application, we only have access to the Profile Data collected and stored as set out in Section A of this Policy

For the Data that is collected by the Lending Partners on the Application for providing Digital Lending Services, we only facilitate collection of such Information upon the instructions of the Lending Partners and do not store the same.

DISCLOSURE TO THIRD PARTIES

V-Pay FINANCE will share Your Information on a need-basis with the third parties including our regulated financial partners, vendors etc for facilitation of Digital Lending Services on the Platform.

We will share Your Information with the following categories of third parties and for the purposes as described below

We will share Your Information under a confidentiality agreement with these third parties and restrict use of the said Information by such third parties specifically for the purposes detailed hereinabove.

We may share Your personal Information upon receipt of notice/communication/ order, as a part of Our legal obligations as per applicable laws as may be sought by the Governmental Agencies. By accepting this Privacy Policy, You hereby provide Your consent to disclose Your personal Information for such regulatory disclosure.

Any disclosure to the aforesaid third parties is subject to the following:

• a) If we are under a duty to disclose or share Your personal Information in order to comply with any legal or regulatory obligation or request, we shall not seek Your explicit consent nor notify the same to You;
• b) We shall share Your Information with third-party only on a need basis and only for the purpose stated hereunder, as per the applicable laws.
• c) Usage of Your Information by such third parties is subject to their privacy policies. We share Information with them to the extent required. We recommend You to go through the privacy policies of such third parties

DATA RETENTION AND DELETION

Please refer to Section-A of this Policy for further Information on our retention and deletion policy with respect to Profile Data.

With respect to Digital Data which is collected by the Lending Partners under this Section B, please refer to the privacy policy(ies) and data retention policy(ies) of the respective Lending Partners (available on their websites). In the event of receipt of Your request to modify Your Information /delete any Information which is collected by the Lending Partners, we will communicate the request to such Lending Partners for taking necessary actions as per their respective privacy and data retention policies. You are advised to review the privacy policy and data retention policy of the Lending Partners prior to availing any Digital Lending Services from them.

Section C – UPI Services

COLLECTION OF INFORMATION FOR PROVISION OF UPI SERVICE ON THE APPLICATION ("UPI SERVICE DATA")

All UPI Service Data collected on the Platform for provision of UPI services on the Platform ("UPI Services") is done through the means of:

• i. Profile Data as per Section A as provided by you
• ii. Data provided during communications with us (for example, by e-mail or chat) in relation to the UPI;
• iii. Data, consents and Information that You provide when You avail UPI Services, and when You report a problem with the UPI Services;
• iv. Data received by us from third parties based on consents given by You under this Section-C of Privacy Policy; and
• v. Data generated by Your usage of our Platform while availing UPI Services.

The entire collection of UPI Service Data is further detailed below.

Information collected by the Application from You

The collection of UPI Service Data in accordance with this Section-C of Privacy Policy is done for facilitating the UPI Services on the Platform in partnership with the multiple payment service provider banks ("PSP") and the National Payments Corporation of India ("NPCI") for the movement of funds between the sender's and receiver's bank accounts.

The entire collection, processing and storage of UPI Service Data is on a standalone basis, in accordance with this Section-C of the Privacy Policy and not accessible for any of the other Services set out in other Parts of this Privacy Policy.

V-Pay FINANCE‘s role with respect to UPI Services is limited to facilitating the access of UPI Service Data pertaining to or provided by You on the Platform to PSPs and NPCI in a secure manner and to ensure that all the recipients of Your personal Information comply with data protection, confidentiality, fidelity and secrecy obligations and duly execute covenants in this regard.

In addition to Your mobile and email id (forming part of Profile Data) collected for creating Your account, we also collect, store, process and share the following personal Information for facilitating the UPI Services.

Data Type	Purpose of Collection	Mandatory / Optional
Bank account Information	Provision of UPI Services	Mandatory
Masked debit card Information	Provision of UPI Services	Mandatory
Masked Aadhaar Information	Provision of UPI Services	Mandatory
Device contact Information	Provision of UPI Services, Identity Verification and Fraud Prevention	Mandatory
Device hardware details Device hardware Information or other IDs such as log Information (via the domain server through which the User accesses the app search queries, IP address, crashes, date etc), device Information	Identity Verification and Fraud Prevention	Mandatory
Transaction Information	For Enabling the App and UPI Services, Legal Compliance	Mandatory
Feedback and similar Information	For Enabling the App and its Services	Mandatory
CONSENT
Your consent to using the Platform and availing the UPI Services as per this Privacy Policy and the UPI Terms and Conditions available on the Website	For Enabling the Application and availing UPI Services Consent type: Recurring	Mandatory
Consent to read and send SMS Information	Identity Verification and Fraud Prevention Consent type: Recurring	Mandatory
Consent to read phone state	Provision of UPI Services Consent type: Recurring	Mandatory
Consent to monitor UPI usage	Provision of UPI Services Consent type: Recurring	Mandatory
Consent to access Your camera (to share photos of necessary documents)	Provision of UPI Services Consent type: Recurring	Mandatory
Consent for UPI usage	Provision of UPI Services Consent type: Recurring	Mandatory
Consent for linking Your mobile number to receive money	Provision of UPI Services Consent type: Recurring	Mandatory
UPI Lite enablement consent	Provision of UPI Services Consent type: Recurring	Mandatory
UPI International activation consent	Provision of UPI Services Consent type: Recurring	Mandatory
UPI international transaction charges consent	Provision of UPI Services Consent type: Recurring	Mandatory
Consent for sharing Your Aadhaar details	Provision of UPI Services Consent type: Recurring	Mandatory
Consent for adding payment instrument for UPI Services	Provision of UPI Services Consent type: Recurring	Mandatory

Collection of Information from NPCI and PSP banks

We receive financial Information about You and Your transactions from PSP bank, including Information to confirm Your registration, the payment sender's or receiver's name, account Information and status, balance sufficiency, transaction and account identifiers, risk or fraud alerts, etc. All such UPI Service Data is stored in encrypted format.

Please note that the PSP bank's or NPCI's terms/guidelines for provision of UPI Services will govern Your use of their services.

PURPOSE OF COLLECTION

We understand the importance of Your UPI Service Data and as a responsible company, we strive to ensure that it is used for the intended purposes only. We shall use the Information collected from You for facilitating the UPI Services.

STORAGE OF PERSONAL INFORMATION

For facilitating the UPI Services on the Platform, we store the personal Information as set out in Section- C, along with Profile Data stored in terms of Part A of this Policy. We ensure that the UPI Service Data that we collect and retain is stored in servers located in India and the same is compliance with all the statutory/regulatory obligations.

DISCLOSURE TO THIRD PARTIES

• You and people with whom You send or receive payments may store or re-share Your UPI ID, name, or transaction Information with others on or off Payments.
• If any Governmental Agency or law enforcement officers request or require any Information and we think disclosure is required or appropriate in order to comply with laws, regulations, or a legal process, we, PSP or our service partners may share such required Information with the Governmental Agency or law enforcement officers.
• In conformance with our relationship with PSP banks, We work with service providers to provide UPI Services to You. We may share Information collected under this Section C of Privacy Policy with identified service providers to send payment instructions to PSP banks; maintain Your transaction history; provide customer support; improve, understand, customize, support, and market UPI Services; and keep UPI Services safe and secure, including to detect, prevent, or otherwise address fraud, safety, security, abuse, or other misconduct. When we share Information with service providers, we require them to use Your Information on our behalf in accordance with our instructions, terms, and applicable law.
• We share Information with PSP banks and NPCI to help us operate UPI Services. The PSP banks and NPCI receive account Information, including Information to authenticate Your account; transaction Information, including payment amount and UPI IDs; country; transaction and account identifiers; Information to detect, prevent, or otherwise address fraud, safety, security, abuse, or other misconduct; and customer support Information. Please note that when You use PSP banks and NPCI services, their own terms and privacy policies will govern Your use of those services.

DATA RETENTION AND DELETION

Same as mentioned in Section A of the Privacy Policy

7. Section D – MISCELLANEOUS TERMS

Changes In This Privacy Policy

V-Pay FINANCE reserve the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. In case, any changes are made in the Privacy Policy, we shall update the same on the Platform. Once posted, those changes are effective immediately, unless stated otherwise. We encourage You to periodically review this Privacy Policy for the latest Information on our privacy practices. Continued access or use of the Services constitute Your acceptance of the changes to the Privacy Policy.

DATA SECURITY

We V-Pay FINANCE strongly committed to protecting the privacy of its customers and has taken all necessary and reasonable measures to protect the confidentiality of the customer information and its transmission through the world wide web and it shall not be held liable for disclosure of the confidential information when in accordance with this Privacy Commitment or in terms of the agreements, if any, with the customer.

We will limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know.

You are responsible for maintaining the security of your account credentials and other authentication involved in obtaining access to password-protected or secure areas. V-Pay FINANCE will not bear any liability in respect of such unauthorized use of your account.

Apart from the Central Consumer Protection Authority Privacy Rights consumer may ask V-Pay FINANCE to specify the categories and the nature of personal data collected by V-Pay FINANCE and ask to delete the personal information collected or to stop sharing his/her personal data.

Children's Information

Another part of our priority is to ensure protection for children while using the internet. We encourage parents and guardians of children to observe and participate in monitoring and/or guiding their online activities. V-Pay FINANCE will never knowingly collect any Personal Identifiable Information from children below the age of 18. If you think that your child has divulged any such information on our website, we strongly urge you to contact us immediately. We assure you of prompt action in removing any such information available in our records.

General

Any change due to legislative amendment or enchantment of functionality or in the content of the site we may make changes in the privacy policy and changes will be applicable only on a prospective basis so we recommend you to review this page periodically to know about the changes.

Please note that this privacy policy does not create any contractual or other legal rights in or on behalf of any party, nor is it intended to do so.

Disclaimer

All the information on our website is published in good faith and for general information purposes only. V-Pay FINANCE does not make any warranties about the completeness, reliability, and accuracy of this information. Any action you take upon the information you find on this website is strictly at your own risk. We will not be liable for any losses and/or damages in connection with the use of our site.

From our site, you can visit other sites by following hyperlinks to such external sites. While we strive to provide only quality links to useful and ethical websites, we have no control over the content and nature of these sites. These links to other websites do not imply a recommendation for all the content found on these sites. Site owners and content may change without notice and may occur before we have the opportunity to remove a link that may have gone 'bad'.

Please be also aware that when you leave our website, other sites may have different privacy policies and terms that are beyond our control. Please be sure to check the Privacy Policies of these sites as well as their "Terms of Service" before engaging in any business or uploading any information.

Review of the Policy

The Policy should be subjected to an annual review by the management and modifications, if any warranted, should be taken up for the approval of the Board. If there are any amendments in the regulations, revision in the policy should be staged for Board’s approval in the immediately ensuing Board Meeting, after the amendments are notified by the regulation.