A. INTRODUCTION

Updated at 20th March 2024

• Paysall (hereinafter Paysall) recognizes the importance of privacy of its users and also of maintaining confidentiality of the information provided by its users as a responsible data controller and data processor.
• This Privacy Policy provides for the practices for handling and securing user's Personal Information (defined hereunder) by Paysall and its subsidiaries and affiliates.
• This Privacy Policy is applicable to any person (‘User’) who purchases, intends to purchase, or inquire about any product(s) or service(s) made available by Paysall through any of Paysall’s customer interface channels including its website, mobile site, mobile app & offline channels including call centres and offices (collectively referred herein as "Sales Channels").
• For the purpose of this Privacy Policy, wherever the context so requires "you" or "your" shall mean User and the term "we", "us", "our" shall mean Paysall. For the purpose of this Privacy Policy, Website means the website(s), mobile site(s) and mobile app(s).
• By using or accessing the Website or other Sales Channels, the User hereby agrees with the terms of this Privacy Policy and the contents herein. If you disagree with this Privacy Policy please do not use or access our Website or other Sales Channels.
• This Privacy Policy does not apply to any website(s), mobile sites and mobile apps of third parties, even if their websites/products are linked to our Website. User should take note that information and privacy practices of Paysall’s business partners, advertisers, sponsors or other sites to which Paysall provides hyperlink(s), may be materially different from this Privacy Policy. Accordingly, it is recommended that you review the privacy statements and policies of any such third parties with whom they interact.
• This Privacy Policy is an integral part of your User Agreement with Paysall and all capitalized terms used, but not otherwise defined herein, shall have the respective meanings as ascribed to them in the User Agreement.
• The provisions of Indian laws and regulations, such as the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, the Aadhaar Act, 2016, and its Amendments, including the Aadhaar Regulations, which mandate publication of the privacy policy for collection, use, storage, transfer, and disclosure of information, are incorporated into this privacy statement. Personal Information refers to and encompasses all information that can be used to identify a specific person, as well as Sensitive Personal Information (all Personal Information that needs increased data protection due to its sensitive and private nature), both collectively referred to as "Personal Information" in the following, with the exception of any information that is publicly accessible or freely available. Please be aware that we only provide products and services through our platform within India. Please refrain from using or accessing our Platform if you disagree with this Privacy Policy.

B. TYPE OF INFORMATION WE COLLECT/SHARE AND ITS LEGAL BASIS

Personal and Sensitive Personal Information collected includes but not limited to:

• name, phone number, e-mail id, photo
• The information as detailed is collected for us to be able to provide the services chosen by you and also to fulfil our legal obligations as well as our obligations towards third parties as per our User Agreement.
• "Personal Information" of User shall include the information shared by the User and collected by us for the following purposes:
  1. Registration on the Website: Information which you provide while subscribing to or registering on the Website, including but not limited to information about your personal identity such as name, email address, telephone (mobile or otherwise).

C. HOW WE USE YOUR PERSONAL INFORMATION

The Personal Information collected maybe used in the following manner:

• We may also use your Personal Information for several reasons including but not limited to:
  1. Confirm your reservations with respective service providers;
  2. keep you informed of the transaction status using email notification;
  3. Send booking confirmations either via sms or Whatsapp or any other messaging service;
  4. Send any updates or changes to your transactions like Mobile Recharge, Bill Payments, etc;
  5. Allow our customer service to contact you via Phone number or Email, if necessary;
  6. Send verification message(s) or email(s);
  7. Validate/authenticate your account and to prevent any misuse or abuse.
  8. Contact you on festive season to offer a special gift.
• Surveys:
  1. We value opinions and comments from our Users and frequently conduct surveys, both online and offline. Participation in these surveys is entirely optional. Typically, the information received is aggregated, and used to make improvements to Website, other Sales Channels, services and to develop appealing content, features and promotions for members based on the results of the surveys. Identity of the survey participants is anonymous unless otherwise stated in the survey.
• Marketing promotions, research and programs:
  1. Marketing promotions, research and programs help us to identify your preferences, develop programs and improve user experience. Paysall frequently sponsors promotions to give its Users the opportunity to win great utility related prizes. Personal Information collected by us for such activities may include contact information and survey questions. We use such Personal Information to notify contest winners and survey information to develop promotions and product improvements.
  2. From time to time we may add or enhance services available on the Website. To the extent these services are provided, and used by you, we will use the Personal Information you provide to facilitate the service(s) requested. For example, if you email us with a question, we will use your email address, name, nature of the question, etc. to respond to your question. We may also store such Personal Information to assist us in making the Website the better and easier to use for our Users.
  3. Paysall may from time to time launch reward programs by way of which users may stand to win utility related rewards or other rewards. We may use your Personal Information to enroll you in the rewards program and status of the same will be visible each time you log in to the Website. Depending on the reward program, each time you win a reward, Paysall may share your Personal Information with a third party that will be responsible for fulfilling the reward to you. You may however choose to opt out of such reward programs by writing to us. For various purposes such as fraud detection, offering bookings on credit etc., we at times may verify information of customers on selective basis, including their credit information. Additionally, Paysall may share your Personal Information, anonymized and/ or aggregated data to a third party that Paysall may engage to perform certain tasks on its behalf, including but not limited to payment processing, data hosting, data processing and assessing credit worthiness for offering bookings on credit.

D. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

• Paysall will retain your Personal Information on its servers for as long as is reasonably necessary for the purposes listed in this policy. In some circumstances we may retain your Personal Information for longer periods of time, for instance where we are required to do so in accordance with any legal, regulatory, tax or accounting requirements.
• Where your personal data is no longer required we will ensure it is either securely deleted or stored in a way which means it will no longer be used by the business.

E. COOKIES AND SESSION DATA

1. Cookies
   • Paysall uses cookies to personalize your experience on the Website and the advertisements that maybe displayed. Paysall’s use of cookies is similar to that of any other reputable online companies.
   • Cookies are small pieces of information that are stored by your browser on your device's hard drive. Cookies allow us to serve you better and more efficiently. Cookies also allow ease of access, by logging you in without having to type your login name each time (only your password is needed); we may also use such cookies to display any advertisement(s) to you while you are on the Website or to send you offers (or similar emails – provided you have not opted out of receiving such emails) focusing on destinations which may be of your interest.
   • A cookie may also be placed by our advertising servers, or third party advertising companies. Such cookies are used for purposes of tracking the effectiveness of advertising served by us on any website, and also to use aggregated statistics about your visits to the Website in order to provide advertisements in the Website or any other website about services that may be of potential interest to you. The third party advertising companies or advertisement providers may also employ technology that is used to measure the effectiveness of the advertisements. All such information is anonymous. This anonymous information is collected through the use of a pixel tag, which is an industry standard technology and is used by all major websites. They may use this anonymous information about your visits to the Website in order to provide advertisements about goods and services of potential interest to you. No Personal Information is collected during this process. The information so collected during this process, is anonymous, and does not link online actions to a User.
   • Most web browsers automatically accept cookies. Of course, by changing the options on your web browser or using certain software programs, you can control how and whether cookies will be accepted by your browser. Paysall supports your right to block any unwanted internet activity, especially that of unscrupulous websites. However, blocking Paysall cookies may disable certain features on the Website, and may hinder an otherwise seamless experience to purchase or use certain services available on the Website. Please note that it is possible to block cookie activity from certain websites while permitting cookies from websites you trust.
2. Automatic Logging of Session Data:
   • Each time you access the Website your session data gets logged. Session data may consist of various aspects like the IP address, operating system and type of browser software being used and the activities conducted by the User while on the Website. We collect session data because it helps us analyze User’s choices, browsing pattern including the frequency of visits and duration for which a User is logged on. It also helps us diagnose problems with our servers and lets us better administer our systems. The aforesaid information cannot identify any User personally. However, it may be possible to determine a User's Internet Service Provider (ISP), and the approximate geographic location of User's point of connectivity through the above session data.

F. WITH WHOM YOUR PERSONAL INFORMATION SHARING

1. COMPANIES IN THE SAME GROUP:
   • In the interests of improving personalization and service efficiency, we may, under controlled and secure circumstances, share your Personal Information with our affiliate or associate entities.This will enable us to provide you with information about various products and services, both leisure- and travel-related, which might interest you; or help us address your questions and requests in relation to your bookings.
   • If the assets of Paysall are acquired, our customer information may also be transferred to the acquirer depending upon the nature of such acquisition. In addition, as part of business expansion/development/restructuring or for any other reason whatsoever, if we decide to sell/transfer/assign our business, any part thereof, any of our subsidiaries or any business units, then as part of such restructuring exercise customer information including the Personal Information collected herein shall be transferred accordingly.
2. BUSINESS PARTNERS and THIRD-PARTY VENDORS:
   • We may also share certain filtered Personal Information to our corporate affiliates or business partners who may contact the customers to offer certain products or services, which may include free or paid products / services, which will enable the customer to have better travel experience or to avail certain benefits specially made for Paysall customers. Examples of such partners are entities offering co-branded credit cards, travel insurance, insurance cover against loss of wallet, banking cards or similar sensitive information etc. If you choose to avail any such services offered by our business partners, the services so availed will be governed by the privacy policy of the respective service provider.
   • Paysall may share your Personal Information to third party that Paysall may engage to perform certain tasks on its behalf, including but not limited to payment processing, data hosting, and data processing platforms.
   • We use non-identifiable Personal Information of Users in aggregate or anonymized form to build higher quality, more useful online services by performing statistical analysis of the collective characteristics and behaviour of our customers and visitors, and by measuring demographics and interests regarding specific areas of the Website. We may provide anonymous statistical information based on this data to suppliers, advertisers, affiliates and other current and potential business partners. We may also use such aggregate data to inform these third parties as to the number of people who have seen and clicked on links to their websites. Any Personal Information which we collect and which we may use in an aggregated format is our property. We may use it, in our sole discretion and without any compensation to you, for any legitimate purpose including without limitation the commercial sale thereof to third parties.
   • Occasionally, Paysall will hire a third party for market research, surveys etc. and will provide information to these third parties specifically for use in connection with these projects. The information (including aggregate cookie and tracking information) we provide to such third parties, alliance partners, or vendors are protected by confidentiality agreements and such information is to be used solely for completing the specific project, and in compliance with the applicable regulations.
3. DISCLOSURE OF INFORMATION
   • In addition to the circumstances described above, Paysall may disclose User's Personal Information if required to do so:
     • By law, required by any enforcement authority for investigation, by court order or in reference to any legal process;
     • To conduct our business;
     • For regulatory, internal compliance and audit exercise(s)
     • To secure our systems; or
     • To enforce or protect our rights or properties of Paysall or any or all of its affiliates, associates, employees, directors or officers or when we have reason to believe that disclosing Personal Information of User(s) is necessary to identify, contact or bring legal action against someone who may be causing interference with our rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by such activities.
   • Such disclosure and storage may take place without your knowledge. In that case, we shall not be liable to you or any third party for any damages howsoever arising from such disclosure and storage.

G. SUITABLE SECURITY PROCEDURES

• We go through rigorous internal and external reviews as part of our acceptable security policies to make sure the right information security encryption or controls are set up for both data in motion and data at rest within our network and servers, respectively. The database is kept on servers protected by a firewall, and access to the servers is highly controlled and password-protected.
• You are also in charge of protecting the privacy and security of your login information. Please don't divulge your Paysall login information, password, or OTP to anyone. Any actual or suspected compromise of your personal information must be reported to us immediately.
• In order to protect the Paysall Application, we have included numerous levels of protection, including a login/logout option and a lock function ("Enable Screen Lock") that you can turn on. We've put in place preventive measures to make sure you use the Paysall application on your device and that the same login information cannot be used on another device without further authentication.

H. HOW CAN YOU OPT-OUT OF RECEIVING OUR PROMOTIONAL E-MAILS?

• You will occasionally receive e-mail updates from us about fare sales in your area, special offers, new Paysall services, and other noteworthy items. We hope you will find these updates interesting and informative. If you wish not to receive them, please click on the "unsubscribe" link or follow the instructions in each e-mail message.

I. PERMISSIONS REQUIRED FOR USING OUR MOBILE APPLICATIONS

• When the Paysall app is installed on your phone or tablet, a list of permissions appear and are needed for the app to function effectively. There is no option to customize the list. The permissions that Paysall requires and the data that shall be accessed and its use is as below:
  1. Android Permissions:
     • Device & App history: We need your device permission to get information about your device, like OS (operating system) name, OS version, mobile network, hardware model, unique device identifier, preferred language, etc. Basis these inputs, we intend to optimize your travel booking experience, use OS specific capabilities to drive great in-funnel experiences using components of device’s OS, etc.
     • Wi-Fi connection information: When you allow us the permission to detect your Wi-Fi connection, we optimize your experience such as more detailing on maps, better image loading, more hotel/ flights/ package options to choose from, etc.

J. HOW WE PROTECT YOUR PERSONAL INFORMATION?

• All payments on the Paysall are secured. This means all Personal Information you provide is transmitted using TLS (Transport Layer Security) encryption. TSL is a proven coding system that lets your browser automatically encrypt, or scramble, data before you send it to us. Website has stringent security measures in place to protect the loss, misuse, and alteration of the information under our control. Whenever you change or access your account information, we offer the use of a secure server. Once your information is in our possession we adhere to strict security guidelines, protecting it against unauthorized access.

K. WITHDRAWAL OF CONSENT AND PERMISSION

• You may withdraw your consent to submit any or all Personal Information or decline to provide any permissions on its Website as covered above at any time. In case, you choose to do so then your access to the Website may be limited, or we might not be able to provide the services to you. You may withdraw your consent by sending an email to [email protected].

L. YOUR CONSENT

• We have your permission to process your personal information. You consent to the processing of your Personal Information by Paysall in line with this Privacy Policy by using the Paysall Platform or services and/or by supplying your Personal Information. You affirm that you have the right to do so and that you give us permission to use any Personal Information about other people that you reveal to us in line with this Privacy Policy.

M. INFORMATION ABOUT CHILDREN

• Only those who can enter into a legally binding contract under the Indian Contract Act, 1872 are permitted to use our Platform, and we never knowingly seek or collect Personal Information from children under the age of 18. If you are under 18, you must use the Platform or the services with the guidance of a parent, guardian, or other responsible adult.

N. CHANGES TO THE PRIVACY POLICY

• Our policies will change frequently as our business does. We reserve the right, in our sole discretion, to alter this Privacy Policy at any time without providing you with previous written notice. It is your duty to regularly check the Privacy Policy for updates/changes, even if we may make a reasonable effort to let you know about the changes. You will be deemed to have accepted and agreed to the updates if you continue to use our services/Platform after they have been posted. We will never amend our policies in a way that lessens their safeguarding of the Personal Information you have previously provided.

O. REFUND POLICY

• All sales of prepaid recharge on the PaysAll Platform are final with no refund or exchange permitted. You are responsible for the mobile number or DTH account number for which You purchase the prepaid recharge and all charges that result from those purchases. You are also responsible for the information relating to data card and toll-tag recharge and all charges that result from those purchases. PaysAll is not responsible for any purchase of prepaid recharge for an incorrect mobile number or DTH account number or incorrect toll or data card information. However, if in a transaction performed by You on the PaysAll Platform, money has been charged to Your card or bank account and a recharge is not delivered within 24 hours of the completion of the transaction, then You shall inform us by reaching out to our customer services on the PaysAll Platform. Please include the following details – the mobile number (or DTH account number or data card or toll-tag information), operator name, recharge value, transaction date and order number. PaysAll will investigate the incident and, if it is found that money was indeed charged to Your card or bank account without delivery of the recharge, then You will be refunded the money within 21 working days from the date of receipt of Your e mail. All refunds will be normally credited to PaysAll wallet by default.

P. RETURN POLICY

• Amount added through phonepe payment gateway into PaysAll application, will not be return to you source of payment at any cost. You must have to use the PaysAll services to use that amount.

Q. SHIPPING POLICY

• We are digital platform and we don't require any shipping.