PRIVACY POLICY

By using AIRPAY’s website and services, you provide your consent for the collection and processing of your personal data as described in this Privacy Policy. You may withdraw or manage your consent at any time by contacting us at dpo@airpay.co.in. We will process your request in accordance with applicable laws.

We collect information from you regarding name, addresses, email addresses, passport number, Income, PAN, details of nominees, etc. and Demographic information such as preferences, interests, etc, to conduct AIRPAY's business.

By providing email address, telephone numbers and other contact information, the Visitor is agreeing that AIRPAY may contact by one or more of the modes of communications.

The use / purpose for which any information collected from the Visitor, through the website of AIRPAY, will vary depending upon the circumstances. Broadly, they may comprise all or any one or more of the following purposes (but shall not be restricted to):

1. To use the information for internal record keeping.
2. To use the information to improve our products and services.
3. To use the information for normal business functioning.
4. To send periodically promotional communication about new products, special offers or other information, which AIRPAY thinks the Visitor, may find interesting.
5. To contact the Visitor periodically for market research purposes. AIRPAY may contact the Visitor by email/post or by any other suitable mode of communication. We may use the information to customize the website according to the Visitors' interests.

We collect and retain information about you only for specific business purposes.

1. Open and administer your accounts and to protect your records and funds.
2. Comply with all applicable laws and regulations.
3. Understand your financial needs so that we can provide you with quality products and superior services.
4. To comply with laws, guidelines and regulations that govern the financial services in the country.
5. To quote examples we need to obtain Passport number for NRI account & PAN for deposit accounts in respect of resident customers for KYC (Know Your Customer Norms Set by Reserve Bank of India)
6. As part of our mandatory customer due diligence (CDD) obligations under Applicable Laws, Airpay may retrieve, verify, and periodically review your KYC documents from the Central KYC Records Registry (CKYCR) or directly from you, without prior notice. Where required, Airpay may share such information with its subsidiaries, affiliates, relevant authorities, including governmental bodies, law enforcement agencies, and the Financial Intelligence Unit-India (FIU-IND). Airpay also reserves the right to monitor, retain, and disclose information relating to your use of our Services to the extent required by law. You agree to promptly notify Airpay of any changes to your information and consent to Airpay relying on the documents and information you provide for the purpose of delivering its Services.

The access to the information provided through the AIRPAY's website would only be given to authorized employees or other AIRPAY Group Companies or affiliates or authorized agents or service provider for normal business purposes, only on need to know basis.

AIRPAY may be required, from time to time, to disclose the Visitor's information to Banks or Payment Services Providers or Governmental or judicial bodies or Regulators or any person to whom AIRPAY is under an obligation to make disclosure under the requirements of any law or terms of service agreement between you and Airpay.

AIRPAY does not release customer information except as directed by law or as per your mandate. We do not share specific information about customer accounts or other personally identifiable data with non-affiliated third parties for their independent use unless:

1. The information is provided to help complete a transaction initiated by you.
2. You request or authorize it.
3. The disclosure is required by/or directed by law.
4. You have been informed about the possibility of such disclosure for marketing or similar purposes through a prior communication and have been given the opportunity to decline.

AIRPAY retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, including including service fulfilment, legal compliance, regulatory obligations, accounting, or reporting requirements. The specific retention period may vary depending on the nature of the information and applicable laws. Once the data is no longer required, we securely delete or anonymize it in accordance with industry best practices. You may also request the deletion of your personal data, subject to any legal or contractual obligations that may require us to retain it for a longer period.

AIRPAY follows best security practices to help prevent unauthorized access to confidential information about visitors. AIRPAY's endeavour is to ensure that information is secure. In order to prevent unauthorized access or disclosure, AIRPAY has put in place suitable systems and procedures to safeguard and secure the information that it collects online. AIRPAY may also work with third parties for Web traffic analysis to research certain usage and activities on parts of the AIRPAY's website. The Web analysis software is used to find out more about the Visitor, including the Visitor demographics, behaviour and usage patterns, for more accurate reporting and to improve the effectiveness of AIRPAY's' marketing.

In the event of a data breach involving your personal information, AIRPAY will notify you and relevant authorities in accordance with applicable laws. Notification will be made without undue delay and will include details of the breach, the data involved, potential consequences, and the steps being taken to mitigate any harm.

AIRPAY is committed to protecting your personal data through robust security controls and best practices. We implement strict access restrictions, ensuring only authorized personnel can access sensitive information on a need-to-know basis. To maintain data integrity, we use validation mechanisms to detect unauthorized alterations. Our systems are protected through firewalls, intrusion detection tools, and regular security audits. We also conduct periodic reviews and assessments to strengthen our security posture and ensure compliance with applicable laws.

AIRPAY's website may contain links to other websites of your interest. Please note that once the Visitor opts to link to other websites, AIRPAY shall not be responsible for protection of further disclosure of information and this Privacy Policy / statement cease to be applicable for such disclosure of information. The Visitor may therefore, like to exercise caution and look at the privacy statement applicable to those websites

Similarly, link of AIRPAY's website may be available on various other third party websites. However, AIRPAY shall not be responsible to the contents and material of such other websites. If any person provides its information on other websites, where link of AIRPAY's website or AIRPAY's logo is available, AIRPAY shall not be responsible to any acts or omissions committed by third party websites including but not limited to data theft, misuse of information of such person.

AIRPAY may transfer your personal data to countries outside of India where our affiliates, service providers, or partners are located. These transfers are carried out in compliance with applicable data protection laws, and we ensure that appropriate contractual, technical, and organizational safeguards are in place to protect your information. Where required, we use standard contractual clauses or rely on regulatory approvals to legitimize such transfers. By using our services and providing your information, you consent to such cross-border transfers of your data, including to jurisdictions that may not have equivalent data protection standards.

The Company may deploy artificial intelligence (AI), machine learning models, and automated processing systems to enhance customer experience, perform risk assessment, detect fraud, improve service offerings, and support credit evaluation processes.

Such processing shall be conducted in a fair, transparent, and lawful manner, and shall not result in any unlawful discrimination or adverse impact without appropriate safeguards. Where required under applicable law, explicit user consent shall be obtained prior to such processing.

The Company may utilize Model Control Policies (MCP) and governed data-processing frameworks to ensure responsible use, monitoring, validation, and auditability of automated systems and data processing activities. These frameworks are designed to ensure compliance with regulatory standards, data protection laws, and internal risk management policies.

As a Data Principal, you have the following rights regarding your personal data processed by AIRPAY, subject to applicable laws:

• The right to request correction or update of inaccurate or incomplete data.
• The right to withdraw consent at any time, where processing is based on consent.
• The right to object to or restrict certain types of processing.
• The right to request erasure of your personal data (“right to be forgotten”), subject to legal obligations.

To exercise any of these rights, please contact our Data Protection Officer at dpo@airpay.co.in.

_You have the right to access, correct, update, or delete your personal information held by AIRPAY. You may also withdraw consent or object to certain types of data processing, subject to legal and contractual limitations. To exercise any of these rights, please contact our Data Protection Officer (DPO) with details of your request. We will process your request in accordance with applicable laws.

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at dpo@airpay.co.in