Version 1.0

Date: 10.02.2025

1. PURPOSE OF THIS PRIVACY NOTICE

1.1. Juspay Technologies Private Limited, or the applicable group company named in this privacy notice below, can act as both a controller and a processor of your Personal Data (collectively referred to as "Company", “Juspay”, "we", "us", or "our" in this privacy notice). “Personal Data” means any personal information we may collect from you either directly, or through our customers/ merchants or any other third parties, as applicable

1.2. The terms ‘you' or 'your' refer to any individual who accesses, uses, or interacts with our services, website or applications, including customers, visitors, and anyone who communicates with us. This includes individuals who apply for employment with us/ submit personal information through inquiries, feedback, or any other means of communication, such as emails or contact forms. By sharing your personal data with us, you agree to its processing in accordance with the terms of this privacy policy.

1.3. This privacy notice aims to inform you how we collect and process your Personal Data. Additionally, it is important that you read this privacy notice to fully understand how and why we are using your data. It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

2. THIRD-PARTY LINKS

2.1. This website includes links to third-party websites, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

3. THE DATA WE COLLECT ABOUT YOU

3.1. As a controller, we collect different types of Personal Data about you (as further enumerated under section 4 below). This includes:

3.1.1. Profile data information including your username and password, interests, preferences, records of your correspondence and engagement with us and feedback and survey responses.

3.1.2. Marketing and communications data, including your preferences in receiving marketing from us and our third parties and your communication preferences which may include your first name, last name, email address and contact number.

3.1.3. Technical data commonly known as online identifiers and includes internet protocol (IP) address, unique mobile device identification numbers (such as your Media Access Control (MAC) address, Identifier For Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI)), type of device, your login data, browser type and version, time zone setting and geolocation, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

3.2. Where we act as a processor, we process your Personal Data on behalf of our customers who avail Juspay services, in such cases we process data solely on the basis of our customers’ instructions. As a processor, we collect/ use/ store and transfer different categories of Personal Data about you for and on behalf of our customers (i.e., the controllers of your Personal Data), which we have grouped together as follows (further enumerated under section 4 below):

3.2.1. Identity data includes but is not limited to first name, last name, username or similar identifier, title, and date of birth.

3.2.2. Contact data includes postal address, email address and contact numbers.

3.2.3. Financial data includes bank account, payment card details, and payroll data.

3.2.4. Transaction data includes details about payments to and from you and other details of products and services you have purchased from us.

3.2.5. Usage data includes information about how you use our website, products, and services.

3.3. We also collect, use, and share aggregated data, such as statistical or demographic data, for the purposes such as but not limited to for improving our services, for performance of contract, marketing and any other allied purposes. Aggregated data is derived from your Personal Data but is not considered Personal Data under applicable law as this data does not directly or indirectly reveal your identity. For example, we aggregate your usage data to calculate the percentage of users accessing a specific website feature.

4. LEGAL BASIS AND PURPOSES FOR PROCESSING

4.1. We have set out below, in a table format, a description of all the ways we may process your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/ActivityType of dataLawful basis for processingDisclosure to third party
Onboarding and registration of vendors/ customersYour name, business email, phone number, company name, and websiteWhen you sign up for Juspay services or get onboarded as a vendor, we require this information for vendor due diligence and performance of the services.We may share this information with local payment providers, other third-party service providers, depending on the services acquired.
Enabling Juspay products and servicesCredit/ debit card details, UPI details, name, contact information, transaction amount, date and time of transaction, transaction idWe collect this information for the purpose of providing our products and servicesTo cloud service providers for data storage, for local payment service providers, Card networks for enabling Juspay services.
Marketing and promotional activitiesIdentity, contact and any communication information shared by youNecessary for our legitimate interests (i.e., to study how customers use our products/ services, to develop them and grow our business), we share this data with our third parties for the purpose of outreachWe disclose this information with our customer relationship management (“CRM”) service providers along with third party email aggregators so they can reach out and further build a relationship
To process your job application to work with with usIdentity, contact, identification proof and other such details/ documents voluntarily disclosed by you to process the applicationsTo conduct due diligence of candidates and undertake the onboarding processWe may disclose this information with a third party for background verification
Customer service and supportName, email-id, mobile numberConsentThird party email aggregators for customer support
Improvement of servicesStatistical data, usage dataLegitimate interestNot applicable
Constitutional changes to Juspay’s business through mergers or acquisitionsAll personal dataLegitimate interestTo our advisers and those of any prospective purchaser or partner, and the new owners or partners may use your Personal Data in the same way as set out in this privacy notice

Note: The legal basis for data processing described above may be subject to local laws and regulations that may differ from the ones mentioned in this privacy policy. In such cases, we will ensure that any processing of personal data complies with the applicable local laws and regulations in the relevant jurisdiction.

4.2. Your data will only be disclosed for the purposes identified in this privacy notice (as may be updated from time to time) unless a law or regulation specifically allows or requires otherwise. We require all third parties to respect the security of your Personal Data and to treat it in accordance with the applicable law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

5. IF YOU FAIL TO PROVIDE PERSONAL DATA

5.1. Where we need to collect Personal Data by applicable law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to our products and services). In this case, we may have to cancel a product or service you have with us, but we will endeavor to notify you if this is the case at the time.

6. HOW WE COLLECT YOUR DATA

6.1. We use different methods to collect data from and about you, including, but not limited to:

6.2. Direct interactions. You may give us your identity data, contact data and financial data by filling in forms or corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:

6.2.1. purchase / access our products or services;

6.2.2. request marketing to be sent to you;

6.2.3. request support for our products;

6.2.4 employment related queries.

6.3. Automated technologies or interactions. As you interact with our website or avail our services, we automatically collect technical data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, pixels, server logs and other similar technologies.

6.4. Contact and transaction data from providers of technical, payment and delivery services based inside and outside your location country

7.MARKETING

7.1. We provide you with choices regarding our use of your Personal Data for marketing and advertising purposes. We have established the following Personal Data control mechanisms:

7.1.1. You will receive marketing communications from us if (a) you have opted into our marketing channels or (b) you have subscribed for an account with us or purchased goods or services from us and you have not opted out of receiving that marketing (save where local data protection laws do not allow option (b)).

7.1.2. All of our marketing communications to you contain an opt out option and you can opt out at any time. Please note that the opt out will not affect the lawfulness of processing that has taken place before the opt out.

7.2. You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time using the details stated in section 16. Please note that the opt out will not affect the lawfulness of processing that has taken place before the opt out.

8. COOKIES

8.1. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

9. INTERNATIONAL TRANSFERS

9.1. Some of our external third parties are based outside your country and the European Economic Area (EEA), so their processing of your Personal Data will involve a transfer of data outside of your country.

9.2. Whenever we transfer your Personal Data out of your country, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

9.2.1. We will only transfer your Personal Data to countries deemed to provide an adequate level of protection for Personal Data by your country’s data protection authority;

9.2.2. appropriate safeguards are in place in accordance with data protection laws. These safeguards include the use of standard contractual clauses/ data protection clauses approved by the European Commission (as appropriate) or binding corporate rules; or

9.2.3. the transfer is otherwise allowed under data protection laws (including where we have your consent, or the transfer is necessary for the performance of a contract with you/ our customer, as permitted under applicable law)

10. DATA SECURITY

10.1. We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorised way, altered, disclosed or being unavailable. In addition, we limit access to your Personal Data to those employees, agents, professional advisers, contractors, and other third parties who have a need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality. We periodically review all privacy and security policies and update them, when necessary, in line with changes in data protection laws or when new technologies are introduced into our business.

10.2. Where the introduction of new technologies results in a high risk to your Personal Data, we may, where required by applicable law, perform a data protection impact assessment and will only proceed if we are able to mitigate any identified high risks.

11. DATA RETENTION

11.1. We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

11.2. In some circumstances, we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

12. DATA DISPOSAL

12.1. Once the data retention periods above expire, digital records are permanently destroyed or fully anonymised if retained for statistical or research purposes. In this case, all personal identifiers are removed permanently so individuals cannot be identified.

13. YOUR LEGAL RIGHTS

13.1. You may have the following rights in relation to the personal data processed by us, depending on the jurisdiction within which you reside:

13.1.1. Right to be Informed: You may have the right to be informed about the collection and use of your Personal Data.

13.1.2 Right of Access: You may have the right to request:

a. a summary of Personal Data which is being processed by us and the processing activities we undertake;

b. the identities of all other entities with whom your Personal Data has been shared, along with a description of the Personal Data so shared; and

c. any other information related to your Personal Data and its processing, as may be prescribed.

13.1.3. Right to Correction and Erasure: You may have the right to request the correction, completion, updating and erasure of your data.

13.1.4. Right to Restriction on Processing: You may request us to restrict the processing of personal data in case the data is inaccurate or unlawful, if you require the data to establish a claim or defend a legal right, or if you have objected to the processing of personal data.

13.1.5. Right to Object or Opt-Out: You may object to or request opting out of the processing (including sale or sharing) of personal data at any time. We may accommodate and address such requests to align with the exemptions provided to us as Controllers under the regulations applicable to us based on the jurisdiction in which you make such requests.

13.1.6. Right to Data Portability: You may request us to transmit data sets provided by you to any other business.

13.1.7. Right to Object or Review Decisions Based on Automated Processing: You may request us to not be subject to a decision based solely on automated processing, including profiling, which may have legal consequences for you.

13.1.8. Right to Grievance Redressal. You may have the right to seek grievance redressal with respect to the personal data we process.

13.1.9. Right to Nominate: You may have the right to nominate any other individual, who shall, in the event of death or incapacity, exercise the rights on your behalf.

13.2. If you would like to exercise any of these rights, please contact us via the details set forth under section 16. If you are not satisfied with how we process your request or are otherwise aggrieved by the manner in which we process your personal data, you may have a right to appeal our decision or make a complaint in the following manner:

13.2.1. If you are residing in India, you may submit a complaint to the Data Protection Board of India, once implemented.

13.2.2. If you are residing in the EU, you may file a complaint to your local member state data protection authority

13.2.3. If you are residing in Singapore, you may file a complaint to the Personal Data Protection Commission.

13.2.4. If you are residing in Brazil, you may file a complaint to the Brazilian Data Protection Authority (ANPD).

13.2.5. If you are residing in the State of Delaware, USA, you may file a complaint to the Delaware Attorney General Office.

We would, however, appreciate the chance to deal with your concerns before you approach the local authority.

14. DISCLAIMER

14.1. When we act as a Data Processor and process data on behalf of our customers, any request you submit regarding your data will be forwarded to the respective customer(s).

15. NOTICE UPDATES

15.1. Policies and procedures are reviewed and compared to the requirements of applicable laws and regulations at least annually, and whenever changes to such laws and regulations are made, privacy policies and procedures are revised to conform with the requirements of applicable laws and regulations.

15.2. We may update this privacy notice from time to time to reflect changes in our practices or to comply with applicable laws. We will notify you of any material changes to this privacy notice by posting the revised policy on our website or by sending you a notification. The revised policy will be effective as of the date it is posted. By continuing to use our services after we make changes to the privacy notice, you agree to be bound by the revised notice.

16. CONTACT DETAILS

JUSPAY INDIA

Full name of legal entity: Juspay Technologies Private Limited

Office address:Stallion Business Center, 444, 18th Main Rd, 6th Block, Koramangala, Bengaluru- 560095

Email address: privacy@juspay.in

JUSPAY SINGAPORE

Full name of legal entity: Juspay Global PTE LTD

Office address:160 ROBINSON ROAD, #20-03, SINGAPORE- 068914

Appointed Data Protection Officer :Shreya Pandey

DPO Email address: dpo-singapore@juspay.in

JUSPAY IRELAND

Full name of legal entity: Juspay Europe Limited

Registered Office address:29/30 Fitzwilliam Square, Dublin 2

Email address- juspaydpo@formiti.com; cc- privacy@juspay.in