Privacy Policy

1. Introduction and Applicability

This policy applies to **KGI Tech Private Limited**, a company incorporated under the Companies Act, 2013 with its registered office at **[Your Registered Office Address Placeholder, e.g., No. XX/X, Your City, India]**, and its Entities/Subsidiaries including but not limited to **KGIPAY** (collectively “**KGIPAY**”, “we”, “our”, or “us” as the context may require).

This policy describes how **KGIPAY** collects, stores, uses and otherwise processes your **Personal Information** through **KGIPAY** websites, **KGIPAY** Applications, m-sites, chatbots, notifications or any other medium used by **KGIPAY** to provide its services to you (hereinafter referred to as the “Platform”). By visiting, downloading, using **KGIPAY** Platform, and/or, providing your information or availing our product/services, you expressly agree to be bound by this Privacy Policy (“Policy”) and the applicable service/product terms and conditions.

Note: 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. Our products/services are offered in India for Indian customers, and your Personal Information processing will be subject to Indian laws.

2. Information Collected (Including Sensitive Data)

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 absolutely necessary for providing the services requested by you.

Personal and Sensitive Personal Information collected includes:

• Name, age, gender, photo, address, phone number, e-mail id, your contacts, nominee details.
• KYC-related information such as PAN, income details, your business-related information, and verification documents as mandated by regulatory authorities.
• Aadhaar information including Aadhaar number or Virtual ID for e-KYC authentication (submission is not mandatory).
• Financial transaction data: OTPs, balances, transaction history, bank account details, wallet balance, and investment goals.
• Device details: device identifier, IP address, location, browser plug-ins, and cookies.
• SMS content: Your Short Messaging Service (SMS(es)) stored on your device for specific purposes like registering for payments or OTPs, **with your explicit consent**.

3. Purpose and Use of Information

**KGIPAY** may process your Personal Information for the following key purposes:

• Account Creation: Verification of identity and access privileges.
• Service Provision: Providing access to products and services offered by us, merchants, and business partners.
• Regulatory Compliance: To conduct KYC compliance, including requirements under the Aadhaar Act and its Regulations.
• Transaction Processing: To process payments, authenticate requests, and validate instructions.
• Security and Risk Management: To carry out credit checks, detect and protect us against error, fraud, money laundering, and other criminal activity.
• Marketing: To inform you about online and offline offers, products, services, and updates, and customizing your experience.
• Legal Obligations: To meet legal obligations, resolve disputes, and respond to legal process.

4. Information Sharing, Disclosures, and Third Parties

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.

Recipients of Information:

• Business Partners, service providers, sellers, logistic partners, and merchants for service delivery.
• Legally recognized authorities, regulatory bodies, governmental authorities, and financial institutions (e.g., for KYC and fraud prevention).
• Internal teams for marketing, security, and investigation purposes.
• For the Aadhaar authentication process by submitting Aadhaar information to CIDR and NSDL.

When availing third-party products/services on the **KGIPAY** Platform, your information is governed by the respective service provider’s privacy policy. We do not accept any responsibility or liability for usage of your Personal Information by these third parties.

5. Data Security, Storage, and Retention

Storage and Retention

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. We may retain information if necessary to prevent fraud, future abuse, or if required by law (e.g., in the event of legal proceedings). Once the retention period is reached, the data shall be deleted in compliance with applicable laws.

Reasonable Security Practices

**KGIPAY** has deployed administrative, technical, and physical security measures to safeguard your Personal Information. We implement controls for both data in motion and data at rest. You are responsible for maintaining the confidentiality and security of your login ID, password, and OTP. Please do not share these details with anybody.

6. Your Rights, Consent, and Opt-out

Your Consent

By using the **KGIPAY** Platform or services and/or by providing your Personal Information, you consent to the processing of your Personal Information by **KGIPAY** in accordance with this Privacy Policy.

Choice/Opt-out

We provide all users with the opportunity to opt-out of receiving any of our services or non-essential (promotional, marketing-related) communications from us. You can usually do this by clicking the unsubscribe button on our emailers.

Access, Rectification, and Revocation

You can access and review your Personal Information by placing a request. You may also **revoke consent** given to us to store your e-KYC information (Aadhaar-based) at any time. Upon revocation, you may lose access to services that relied on that consent. To raise any of these requests, use the ‘Help’ section or write to us via the **Contact Us** details.

7. Children Information and Policy Changes

Children Information

We do not knowingly solicit or collect Personal Information from children under the age of 18. 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 18, you must use the Platform under the supervision of your parent or legal guardian.

Changes to Policy

We reserve the right to change, modify, add, or remove portions of this Privacy Policy at any time without prior written notice. We will endeavor to notify you of the changes, but it is your responsibility to review the Policy periodically. Your continued use means you accept the revisions. We will never make changes to policies in order to make it less protective of Personal Information already shared by you.