Effective date: 2021-07-12

1. Introduction

Welcome to Zeropay Private Limited. Zeropay Private Limited (“us”, “we”, or “our”) operates zeropay.fyi (hereinafter referred to as “Service”). Our Privacy Policy governs your visit to zeropay.fyi, and explains how we collect, safeguard and disclose information that results from your use of our Service. We use your data to provide and improve Service. By using Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions. Our Terms and Conditions (“Terms”) govern all use of our Service and together with the Privacy Policy constitutes your agreement with us (“agreement”). We at Zeropay understands managing your data is a big responsibility and we work hard to protect your information and put you in control. This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information. “Personal information” means any information that relates to an individual, which directly or indirectly, in combination with other information. “Sensitive Personal Information” means any Personal Information of an individual, such as, Identity and log-in information, contact information, financial information, payment information, usage information, credit information, marketing and communications informations and information in your device. Depending on who you are (e.g., a merchant, customer, cardholder, consumer, supplier or business partner) and how you interact with us (e.g., through Website, Platform, App, telephone, IVR, API, online or offline), we may collect, use, receive, store, analyze, combine, transfer or otherwise process different categories of your Personal Information (including Sensitive Personal Information). We may collect use/and or share non-personal information or data in accordance with our privacy statement and in compliance with applicable laws of India. Zeropay does not have oversight of these third-party websites, plug-ins and applications and we are not responsible for their processing or using of your Personal or Sensitive Information. Any information collected by a third party in this manner is subject to that third party’s own data collection. We also obtain personal information through third parties including our business partners, dependent service providers and our group entities, third parties or publicly available sources, as permitted under applicable laws of India.

2. Definitions

SERVICE means the zeropay.fyi website operated by Zeropay Private Limited. PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession). USAGE DATA is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit). COOKIES are small files stored on your device (computer or mobile device). DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data. DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively. DATA SUBJECT is any living individual who is the subject of Personal Data. THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

3. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you. We process Sensitive Personal Information only when we have obtained your consent. For collecting, processing (including using and storing), disclosing or sharing your Sensitive Personal Information as described in this ZeropayPrivacy Statement, we hereby through this Privacy Statement, seek your consent and give you a notice regarding collecting, processing (including using and storing), and sharing your Sensitive Personal Information for one or more of the purposes detailed herein. For any purposes, where, as per applicable laws of India, a specific consent is required, we will seek such specific consent from you from time to time.

4. Types of Data Collected

Personal Data While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to: 0.1. Email address 0.2. First name and last name 0.3. Phone number 0.4. Address, Country, State, Province, ZIP/Postal code, City 0.5. Cookies and Usage Data 0.6 KYC details We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link. We collect your SMS’s data time to time- Periodically we may collect Your transactional SMSs to provide relevant offers/rewards basis consumption pattern and facilitate the credit assessment to be undertaken by your Financing Partner. You may have restricted access to the Portal/services available through the Portal, if You disable/withdraw/do not provide this access. Camera Access- We require access to Your mobile device camera for a seamless experience for making UPI Payments. Location- We may collect and monitor Your locations to verify Your current address, to ensure/check, serviceability of our services, to let You search for Your company/college name, and to prevent any fraudulent activity. We collect the location data from You in two ways: (i) when You add Your pin code on the APP; and (ii) from Your mobile device when enabled by You to do so. We collect this data only when our APP is being used. You may have restricted access to the APP/services available through the APP, if You disable/withdraw/do not provide this access Contact- We may periodically collect Your contact information to facilitate credit assessment to be undertaken by your Financing Partner and to enable you access of some additional features on the APP. You may have restricted access to the APP/services available through the APP, if You disable/withdraw/do not provide this access. Installed Apps- We may periodically collect metadata information of apps installed on Your mobile device which includes the application’s name, package name, installed time, updated time, version name and version code of each installed application on Your device to assess and provide personalised offers to you. You may have restricted access to the APP/services available through the APP, if You disable/withdraw/do not provide this access. Transaction Information- The transaction information generated through the APP will be stored and used by each of the Financing Partners of Zeropay and/or by Emerald Finance (inits capacity as a prepaid instrument issuer) Device Data- When You browse Our Website or apps, We also automatically receive Your devices’ internet protocol (IP) address. This helps Us learn about Your browser and operating system, software, the date and time at which You visited the APP, the type of device being used (including the hardware models), the browser being used, etc, same would help us detect and prevent fraud. Storage- We may require this permission so that Your documents can be securely downloaded and saved on Your phone, and so You can upload any required documents easily for quicker approval and disbursal of credit facility. This helps in providing a smooth and seamless experience while using the APP. Feedback Data and Other Data- We may access and save data in the following instances: When You contact Us or We contact You, We may record information provided by You to service You, or record calls for quality and training purposes; When You participate in Our referral programs or use any discount codes offered by Us andinput such data; When You provide any feedback or comments to Us on the APP or any other platform. Usage Data We may also collect information that your browser sends whenever you visit our Service or when you access Service by or through any device (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When you access Service with a device, this Usage Data may include information such as the type of device you use, your device unique ID, the IP address of your device, your device operating system, the type of Internet browser you use, unique device identifiers and other diagnostic data. We process your Personal Information (including Sensitive Personal Information) for the purposes mentioned below:

1. To verify, authenticate and authorize your use of our products or services
2. To process the transactions
3. To provide products and services to you
4. To do internal risk assessments and analysis
5. To generate variables, affluence and reliability scores
6. To protect our business and to ensure compliance with the law
7. To manage our relationship with you
8. To market our products and services including products and services of our business partners
9. To conduct research and to develop and improve our products and services

We may share your Personal Information (including Sensitive Personal Information) with Zeropay Entities, and other entities from the group of companies to which Zeropay belongs. We may disclose your Personal Information (including Sensitive Personal Information) to these companies, to:

1. provide support services and technical services to Zeropay and group companies of Zeropayand to receive some of these services from them;

Zeropay may store your Personal Information and Sensitive Personal Information for as long as the same is required for the fulfilment of purposes for which we collected it. The retention of Personal Information and Sensitive Personal Information by Zeropay is determined by considering compliance with legal (contractual, statutory or regulatory requirements), accounting and compliance reporting requirements. We ensure that you may exercise your individual privacy rights under applicable privacy and data protection laws and as per our internal policies. This means that Zeropay seeks to provide reasonable assistance to cater to requests from individuals regarding the processing of their Personal Information and the right to amend their Personal Information and withdraw permission to the processing of their Sensitive Personal Information. The security of your Personal Information and Sensitive Personal Information is important to us. We take all physical, technical, managerial, and operational measures that are that are designed to improve the integrity and security of information that we collect and maintain as required by applicable law. Location Data We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service. You can enable or disable location services when you use our Service at any time by way of your device settings. Tracking Cookies Data We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service. Examples of Cookies we use: 0.1. Session Cookies: We use Session Cookies to operate our Service. 0.2. Preference Cookies: We use Preference Cookies to remember your preferences and various settings. 0.3. Security Cookies: We use Security Cookies for security purposes. 0.4. Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests. Other Data While using our Service, we may also collect the following information: sex, age, date of birth, place of birth, passport details, citizenship, registration at place of residence and actual address, telephone number (work, mobile), details of documents on education, qualification, professional training, employment agreements, NDA agreements, information on bonuses and compensation, information on marital status, family members, social security (or other taxpayer identification) number, office location and other data.

5. Use of Data

Zeropay Private Limited uses the collected data for various purposes: 0.1. to provide and maintain our Service; 0.2. to notify you about changes to our Service; 0.3. to allow you to participate in interactive features of our Service when you choose to do so; 0.4. to provide customer support; 0.5. to gather analysis or valuable information so that we can improve our Service; 0.6. to monitor the usage of our Service; 0.7. to detect, prevent and address technical issues; 0.8. to fulfil any other purpose for which you provide it; 0.9. to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; 0.10. to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.; 0.11. to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information; 0.12. in any other way we may describe when you provide the information; 0.13. for any other purpose with your consent.

6. Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

When you voluntarily send us electronic mail, we will keep a record of this information so that we can respond to you. We only collect information from you when you register on our site or fill out a form. Also, when filling out a form on our site, you may be asked to enter your: name, e-mail address or phone number. You may, however, visit our site anonymously. In case you have submitted your personal information and contact details, we reserve the rights to Call, SMS, Email or WhatsApp about our products and offers, even if your number has DND activated on it.

7. Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside India and choose to provide information to us, please note that we transfer the data, including Personal Data, to India and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. Zeropay Private Limited will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

8. Disclosure of Data

We may disclose personal information that we collect, or you provide: 0.1. Disclosure for Law Enforcement. Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities. 0.2. Business Transaction. If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred. 0.3. Other cases. We may disclose your information also: 0.3.1. to our subsidiaries and affiliates; 0.3.2. to contractors, service providers, and other third parties we use to support our business; 0.3.3. to fulfill the purpose for which you provide it; 0.3.4. for the purpose of including your company’s logo on our website; 0.3.5. for any other purpose disclosed by us when you provide the information; 0.3.6. with your consent in any other cases; 0.3.7. if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

9. Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at support@www.zeropay.fyi. In certain circumstances, you have the following data protection rights: 0.1. the right to access, update or to delete the information we have on you; 0.2. the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete; 0.3. the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format; Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not able to provide Service without some necessary data. 0.1. What personal information we have about you. If you make this request, we will return to you: 0.0.1. The categories of personal information we have collected about you. 0.0.2. The categories of sources from which we collect your personal information. 0.0.3. The business or commercial purpose for collecting or selling your personal information. 0.0.4. The categories of third parties with whom we share personal information. 0.0.5. The specific pieces of personal information we have collected about you. 0.0.6. A list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your personal information, we will inform you of that fact. 0.0.7. A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with. Please note, you are entitled to ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to the personal information we collected about you in the previous 12 months. 0.2. To delete your personal information. If you make this request, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate. 0.3. To stop selling your personal information. We don’t sell or rent your personal information to any third parties for any purpose. We do not sell your personal information for monetary consideration. However, under some circumstances, a transfer of personal information to a third party, or within our family of companies, without monetary consideration may be considered a “sale” under California law. You are the only owner of your Personal Data and can request disclosure or deletion at any time. If you submit a request to stop selling your personal information, we will stop making such transfers. Please note, if you ask us to delete or stop selling your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services which require the usage of your personal information to function. But in no circumstances, we will discriminate against you for exercising your rights.

13. Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analysing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

14. Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

15. CI/CD tools

We may use third-party Service Providers to automate the development process of our Service.

16. Behavioral Remarketing

We may use remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service.

17. Payments

We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

18. Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

19. Children’s Privacy

Our Services are not intended for use by children under the age of 18 (“Child” or “Children”). We do not knowingly collect personally identifiable information from Children under 18. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

20. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

21. Contact Us

If you have any questions about this Privacy Policy, please contact us by email: support@www.zeropay.fyi. Transaction Disputes/Refund Policy