Privacy Policy

This Privacy Policy applies to TpiPay Financial Technology Private Limited, a company incorporated under the Companies Act, 2013, with its registered office in India (“TpiPay”, “we”, “our”, or “us”).

This policy describes how TpiPay collects, stores, uses, and otherwise processes your Personal Information through TpiPay websites, mobile applications, m-sites, chatbots, notifications, or any other medium used by TpiPay to provide its services to you (hereinafter referred to as the “Platform”). By visiting, downloading, using our Platform, and/or providing your information or availing our products/services, you expressly agree to be bound by this Privacy Policy (“Policy”) and the applicable service/product terms and conditions. We value the trust you place in us and respect your privacy, maintaining the highest standards for secure transactions and protection of your personal information.

This Privacy Policy is published and shall be construed in accordance with the provisions of Indian laws and regulations including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 under the Information Technology Act, 2000, the Digital Personal Data Protection Act, 2023, and the Aadhaar Act, 2016 and its Amendments, including the Aadhaar Regulations. Personal Information means and includes all information that can be linked to a specific individual and also includes Sensitive Personal Information, both hereinafter referred to as “Personal Information”, excluding any information that is freely available or accessible in the public domain. Your Personal Information processing will be subject to Indian laws. If you do not agree with this Privacy Policy, please do not use or access our Platform.

1. Information Collection

We may collect your Personal Information when you use our services or Platform or otherwise interact with us during the course of our relationship. We collect Personal Information which is relevant and necessary for providing the services requested by you and to continually improve the TpiPay Platform.

1.1 Personal and Sensitive Personal Information

Personal and Sensitive Personal Information collected, as applicable, includes but is not limited to:

• Name, age, gender, photo, address, phone number, e-mail ID, and any other details when you create an account with us, your contacts, and nominee details
• KYC-related information such as PAN, income details, disability status, your business-related information, videos, or other online/offline verification documents as mandated by relevant regulatory authorities
• Aadhaar information including Aadhaar number or Virtual ID for the purposes of e-KYC authentication with the Unique Identification Authority of India (UIDAI). Note that submission of Aadhaar information is not mandatory and there are alternatives for identity verification (e.g., Voter ID, Driving Licence)
• Transaction history and value, bank account details, wallet balance, payment details, and service or transaction-related communication
• Device details such as device identifier, internet bandwidth, mobile device model, browser plug-ins, cookies or similar technologies that may identify your browser/TpiPay Applications, and time spent, IP address, and location
• Short Messaging Service (SMS) data stored on your device for purposes including but not limited to registering you for payment services, OTPs for logins and payments, enhancing your security, and any other legitimate uses with your explicit consent
• Video, photo, audio, and location data based on your explicit consent through your app permissions (camera, microphone, location), where access is required for product functionality or as per regulatory requirements, e.g., video-based KYC

1.2 Stages of Collection

Information may be collected at various stages of your usage of the TpiPay Platform, including:

• Visiting the TpiPay Platform
• Registering on the TpiPay Platform as a “user” or “merchant” or any other relationship governed by terms and conditions listed on the TpiPay Platform
• Creating your TpiPay user account and associated profile information
• Transacting or attempting to transact on the TpiPay Platform
• Accessing links, e-mails, chat conversations, feedbacks, notifications sent by or owned by TpiPay, and if you opt to participate in our occasional surveys
• While applying for career opportunities with TpiPay or when onboarding for employment purposes

1.3 Information from Third Parties

We and our service providers or business partners may also collect your Personal Information from third parties or publicly available information, as applicable, including but not limited to:

• Financial history and other information for providing TpiPay services, verifying and authenticating transactions, and complying with court judgements or regulatory requirements, from credit reference and fraud prevention agencies
• Your credit information from credit bureaus including credit reports, credit scores, and related information, if any
• Your demographic and photo information including but not limited to Aadhaar number, address, gender, and date of birth as received from UIDAI upon successful Aadhaar e-KYC
• Your resume, past employment, and educational qualifications for background checks through online or offline databases legitimately obtained when you apply for employment with TpiPay

2. Purpose and Use of Information

TpiPay may process your Personal Information for the following purposes:

• Creation of your account and verification of your identity and access privileges
• Providing you access to the products and services offered by us, merchants, financial institutions, or our business partners on the TpiPay Platform
• Fulfilling your service requests and processing payments on your behalf and on your instructions
• Conducting the KYC compliance process as a mandatory prerequisite as per the requirements of various regulatory bodies, including UIDAI under the Aadhaar Act and its Regulations
• Validating, processing, and/or sharing your KYC information with relevant regulated entities, financial institutions, or service providers as required
• Authenticating transaction requests and confirming payments made via our services
• Enhancing your user experience by analysing user behaviour on an aggregated basis and simplifying your user journey
• Monitoring and reviewing products/services from time to time; customizing services to make your experience safer and easier; and conducting audits
• Carrying out credit checks, risk analysis, screening, or due diligence checks as lawfully required and detecting and protecting against error, fraud, money laundering, and other criminal activity
• Enforcing our terms and conditions and resolving disputes
• Informing you about online and offline offers, products, services, and updates; marketing, presenting advertising, and offering tailored products and services
• Troubleshooting problems, technical support, and fixing bugs; helping to promote a safe service
• Training our representatives and agents to ensure quality of support during your interactions with us
• Identifying security breaches and attacks; investigating, preventing, and taking action on illegal or suspected fraud or money laundering activities
• Meeting legal and regulatory obligations

3. Cookies and Similar Technologies

We use data collection devices such as “cookies” or similar technologies on certain pages of the Platform to help analyse our web page flow, measure promotional effectiveness, and promote trust and safety. Cookies are small files placed on your device storage that assist us in providing our services. Cookies do not contain any of your Personal Information.

We offer certain features that are only available through the use of cookies or similar technologies. Most cookies are “session cookies”, meaning they are automatically deleted from your device storage at the end of a session. You are always free to decline or delete our cookies if your browser/device permits, although in that case you may not be able to use certain features on the Platform. Additionally, you may encounter cookies placed by third parties on certain pages of the Platform. We do not control the use of cookies by third parties.

4. Information Sharing and Disclosures

Your Personal Information is shared as allowed under applicable laws, after following due diligence and in line with the purposes set out in this Policy. We may share your Personal Information with different categories of recipients such as business partners, service providers, merchants, TpiPay group entities, legally recognized authorities, regulatory bodies, governmental authorities, financial institutions, credit bureaus, and non-banking financial companies.

Personal Information will be shared, as applicable, on a need-to-know basis, for the following purposes, including but not limited to:

• Enabling the provision of the products/services availed by you and facilitating the services between you and the relevant service provider, business partners, or merchants, as requested
• For the Aadhaar authentication process by submitting Aadhaar information to Central Identities Data Repository (CIDR) and other authorized agencies as required
• For complying with applicable laws and meeting Know Your Customer (KYC) requirements as mandated by various regulatory bodies
• For completing a payment transaction initiated by you on a merchant site, where based on your instructions, the merchant requests to fetch your Personal Information from us
• For processing your financial product subscription requests placed with us and ensuring that these requests reach the relevant financial institution
• If required by financial institutions to verify, mitigate, or prevent fraud or to manage risk or recover funds in accordance with applicable laws/regulations
• For services related to communication, marketing, data and information storage, transmission, security, analytics, fraud detection, risk assessment, and research
• To enforce our Terms or Privacy Policy; respond to claims involving third-party rights; or protect the rights, property, or personal safety of our users or the general public
• If required to do so by law or in good faith where we believe that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal processes
• If requested by government authorities for government initiatives and benefits
• For grievance redressal and resolution of disputes
• Should TpiPay plan to merge with, or be acquired by any business entity, or undergo any re-organization, amalgamation, or restructuring of our business

TpiPay ensures that stricter or no less stringent privacy protection obligations are imposed on third parties, wherever applicable and to the extent possible. However, TpiPay may share Personal Information with third parties such as legally recognized authorities, regulatory bodies, governmental authorities, and financial institutions as per applicable laws. We do not accept any responsibility or liability for the usage of your Personal Information by these third parties or their policies.

5. Storage and Retention

To the extent applicable, we store Personal Information within India and retain it in accordance with applicable laws and for a period no longer than is required for the purpose for which it was collected. However, we may retain Personal Information related to you if we believe it may be necessary to prevent fraud or future abuse, or if required by law, including in the event of the pendency of any legal/regulatory proceeding or upon receipt of any legal and/or regulatory direction to that effect, or for other legitimate purposes.

Once Personal Information has reached its retention period, it shall be deleted in compliance with applicable laws.

6. Reasonable Security Practices

TpiPay has deployed administrative, technical, and physical security measures to safeguard users’ Personal Information and Sensitive Personal Information. We implement applicable security controls as required by the Aadhaar Regulations and other applicable laws to safeguard your Aadhaar information. We undergo strict internal and external reviews to ensure appropriate information security encryption or controls are in place for both data in motion and data at rest within our network and servers. The database is stored on servers secured behind a firewall; access to the servers is password-protected and strictly limited.

You are responsible for maintaining the confidentiality and security of your login ID and password. Please do not share your TpiPay login credentials, password, and OTP details with anyone. It shall be your responsibility to notify us in case of any actual or suspected compromise to your Personal Information.

We have implemented multiple levels of security to safeguard the TpiPay Application, including login/logout options and an application lock feature that can be enabled by you. Preventive controls are in place to ensure that the same login credentials cannot be used on a different device without additional authentication/OTP.

7. Third-Party Products, Services, or Websites

When you avail products and services of service providers on the TpiPay Platform, Personal Information may be collected by those respective service providers and such information shall be governed by their privacy policy. You may refer to their privacy policy and terms of service to understand how your Personal Information will be handled by such service providers.

Our services may include links to other websites or applications. Such websites or applications are governed by their respective privacy policies, which are beyond our control. Once you leave our servers, use of any Personal Information you provide on those third-party websites or applications is governed by the privacy policy of the operator of that application/website. We do not accept any responsibility or liability for the usage of your Personal Information by these third parties or their policies.

8. Your Consent

We process your Personal Information with consent. By using the TpiPay Platform or services and/or by providing your Personal Information, you consent to the processing of your Personal Information by TpiPay in accordance with this Privacy Policy. If you disclose to us any Personal Information relating to other people, you represent that you have the authority to do so and permit us to use such information in accordance with this Privacy Policy. Further, you agree and authorize TpiPay to communicate with you via channels such as phone calls and e-mail for the purposes set out in this Policy, irrespective of your registration with any authorized DND registries.

9. Choice / Opt-Out

We provide all users with the opportunity to opt-out of receiving non-essential (promotional, marketing-related) communications from us after setting up an account. If you want to remove your contact information from our lists and newsletters or discontinue any of our services, please click on the unsubscribe button on our emailers. In case you receive a call for any specific TpiPay product/service, you may opt-out from such calls by informing TpiPay’s representative during the call.

10. Access, Rectification, and Withdrawal of Consent

You can access and review your Personal Information by placing a request with us. In addition, you may at any time revoke consent given to us to store your e-KYC information, collected as part of the Aadhaar-based e-KYC process. Upon such revocation, you may lose access to services that were availed on the basis of the consent provided. In some cases, we may continue to retain your information as per the ‘Storage and Retention’ section of this Policy. To raise any of the above requests, you may write to us using the contact information provided under the ‘Contact Us’ section of this Policy.

In case you wish to delete your account or Personal Information, please use the ‘Help’ section of the TpiPay Platform. However, retention of your Personal Information will be subject to applicable laws.

For the above requests, TpiPay may need to request specific information from you to confirm your identity and ensure authentication. This is a security measure to ensure that Personal Information is not disclosed to any person who does not have a right to receive it, or is not incorrectly modified or deleted.

11. Children’s Information

We do not knowingly solicit or collect Personal Information from children under the age of 18, and use of our Platform is available only to persons who can form a legally binding contract under the Indian Contract Act, 1872. If you are under the age of 18, you must use the Platform or services under the supervision of your parent, legal guardian, or any responsible adult.

12. Changes to This Policy

Since our business changes constantly, so will our policies. We reserve the right, at our sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time without prior written notice to you. We may, however, reasonably endeavour to notify you of material changes. It is your responsibility to review the Privacy Policy periodically for updates/changes. Your continued use of our services/Platform following the posting of changes will mean that you accept and agree to the revisions. We will never make changes to policies in order to make them less protective of Personal Information already shared by you.

13. Grievance Officer

In accordance with the Information Technology Act, 2000 and the rules made thereunder, and the Digital Personal Data Protection Act, 2023, the name and contact details of the Grievance Officer of TpiPay are as follows:

The Grievance Officer shall acknowledge receipt of any complaint within 48 hours and endeavour to redress the complaint within one (1) month from the date of receipt of the complaint.

14. Contact Us

If you have any questions, concerns, or grievances regarding this Privacy Policy or the manner in which TpiPay processes your Personal Information, please contact us at:

TpiPay Financial Technology Private Limited
W-303, 3rd Floor, 22 Halasuru, Bengaluru- 560042, India
E-mail: nodalteam@tpipay.ai