Privacy Policy

Our Privacy Promise

WHAT ASPECTS DOES THE PRIVACY STATEMENT COVER?

This Privacy Statement shall apply uniformly to Nupi's desktop website, mobile WAP site & mobile applications. This Privacy Statement outlines how Nupi collects, uses, retains, and stores your Personal Data. We also inform you about your rights with respect to your Personal Data. Nupi may share the personal data of users with any third party, as may be required, for statutory purposes or implementation of certain critical functionalities.

By using our products or services, you agree to this Privacy Statement and provide your free, specific, informed, unambiguous and unconditional consent to the practices described in this Privacy Statement. Nupi collects your Personal Data only to the extent necessary to process your requirements, in the manner prescribed in this Privacy Statement, and in accordance with the applicable laws. However, in case you choose not to share your Personal Data as required, with us, we may not be able to provide you with any products or services.

WHAT ARE THE GOVERNING LAWS AND JURISDICTION?

Our commitment to safeguarding your privacy has been outlined in this Privacy Statement, which shall be governed by the Digital Personal Data Protection Act, 2023. This Privacy Statement shall also be governed by the Information Technology Act, 2000, and other applicable laws of India, subject to the exclusive jurisdiction of Courts of Mumbai.

WHAT PERSONAL DATA DOES NUPI COLLECT?

We may further collect the following personal information, either through the mobile application or other relevant Platform. This information will further be processed and stored with Nupi (as mentioned above). Permissions to these settings may be essential for adequate running of the relevant Platform and can be managed through the respective user device’s controls The Personal Data collected includes but is not limited to:

i. Name, Email address, Address (including country/ State/ and ZIP/ postal code), Shipping address, Gender, Age, DOB, PAN card, Bank details (Account No. and IFSC code), Mobile Number, Password chosen by the User, other details as you may volunteer.

ii. Transaction and Financial Details- Transaction history, payment details and financial details, such as credit history needed as part of availing some of our products/ services.

iii. Employment Details- Occupation, designation, employment history, salary and/ or benefits, as part of our record retention.

iv. Surveys- Opinions provided by you to us by way of feedback or responses to surveys.

v. Mobile Device Information- Information obtained from your mobile device by way of using the Nupi application, like device location, camera read only, Media, device details.

vi. In-app Functionalities-

• Access to your mobile camera device for the functioning of many in-app functionalities for recording video including, but not limited to video KYC process, scan & pay etc.

• Access to files from your mobile device such as audio, video files, images, documents, for the functioning of many in-app functionalities.

At times, Nupi may make personal information available to its third party strategic partners, or other third parties that help Nupi in marketing and research. When you register with our Platform, you authorize Nupi to exchange the information you provide for the purpose of provision of the services as well as to improve the services and for our marketing aspects. Such exchange of information by Nupi shall be governed by our Privacy Policy.

HOW DOES NUPI PROCESS YOUR PERSONAL DATA?

Nupi processes your Personal Data with your consent or for Legitimate uses, in its business activities for providing our products or services, and to perform, among other actions, the following:

i. To process the data for the specified purposes for which it was provided to us voluntarily. For example, if you make a purchase and request a receipt from us, Nupi may process your Personal Data for that purpose.

ii. To facilitate the transactions or report on these transactions.

iii. To undertake research and analytics for offering or improving our products/ services and our security and service quality.

iv. To develop new products/ services and to monitor and review products/ services from time to time.

v. To check and process the requirements submitted to us for availing products/ services and/ or instructions or requests received from you in respect of the products/ services.

vi. To respond to queries or feedback submitted by you.

vii. To verify your identity for us to provide or offer products/ services to you.

viii. To share with you, updates on changes to the products/ services and their terms and conditions including the Nupi Platform’s terms and conditions.

ix. To take up or investigate any complaints, claims or disputes raised by you or any third- parties.

x. To notify in case of suspicious activities or blocking of transactions as per our risk engines.

xi. To carry screenings, audits, due diligence checks and/ or record keeping purposes as lawfully required by us.

xii. To undertake financial, regulatory or management reporting and create and maintain various risk management models and for record keeping/ fulfill statutory obligations

xiii. To enable us to show you advertisements, selective offers and promotions, search results, location-based services, which are relevant to you and your interests.

xiv. To auto populate such Third-Party pages based on your click on advertisement instances on our website and proceeding to such pages and sharing the data/ information with third-party to provide the services.

xv. To adhere to judgements, decrees, or orders issued under Indian Laws or those pertaining to contractual or civil claims.

xvi. To fulfill state requirements for subsidies, benefits, services, certificates, licenses, or permits, or to ensure sovereignty, integrity, and security of India.

xvii. To fulfill legal obligation under applicable laws to disclose information to the state or its instrumentalities.

xviii. To respond to a life-threatening medical emergency ensuring safety and providing necessary assistance or services during disasters, epidemics, or disease outbreak.

xix. To fulfill obligations entered with third party relating to the contracts/ arrangements/ agreements with them.

Nupi may also receive information about you through other Users or by third parties with whom the User has consented to sharing correspondence about their activities (“TPI”). It is clarified that Nupi does not undertake any obligation to verify if the User has consented to third parties sharing TPI with Nupi and any damage arising to the User thereto shall be a matter solely and exclusively between the User and the concerned third party.

HOW DOES NUPI HANDLE PERSONAL DATA OF CHILDREN AND PERSONS WITH DISABILITY?

Services offered by Nupi are not available to persons below the age of 18 nor does Nupi knowingly solicit or collect Personal Data from such persons. We obtain verifiable consent of the parent or lawful guardian prior to processing children’s Personal Data. If you have shared any Personal Data of children under the age of 18 years, you represent that you have the authority to do so and permit us to use it in accordance with this Privacy Statement. Additionally, we obtain verifiable consent of the parent or lawful guardian of Persons with Disability, prior to processing their Personal Data.

Nupi does not engage in tracking, behavioural monitoring or targeted advertising concerning children’s Personal Data.

DOES NUPI USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

Nupi may use cookies and other tracking technology depending on the features offered, to enhance your experience, analyse usage patterns, and personalize content. We do not collect any Personal Data via cookies and other tracking technology, however, if you previously provided Personal Data, cookies may be tied to such data.

DOES NUPI SHARE PERSONAL DATA WITH THIRD PARTIES/ SUBSIDIARIES/ AFFILIATES/ HOLDING COMPANY?

We only share the data on a “need-to-know” basis to designated personnel or third-parties, Affiliates or Subsidiaries or holding company in our business and operational processes.

For example, when you make purchases through the Nupi Platform, Nupi may collect and store information about you to process your requests and auto populate forms for future transactions. This information may be shared with third parties which assist in processing and fulfilling your requests, including but not limited to Payment Card Industry (PCI) compliant payment gateway processors, and for providing you with products/ services to better serve your needs and interests.

HOW DOES NUPI KEEP YOUR PERSONAL DATA SAFE?

Nupi takes reasonable security safeguards to protect your Personal Data from misuse, loss, unauthorised access, modification, or disclosure and uses the latest secure server layers encryption and access control on its systems. Among the other things, we use the following measures-

i. When you submit credit or payment card information, we encrypt the Data in compliance with PCI Data security standards.

ii. Nupi provides multiple levels of security to safeguard your Nupi Application by login/ logout option, and app lock feature for payments, that may be enabled by you.

iii. Nupi makes sure that once you login, you can't use the same account on a different device without extra security like additional authentication/ OTP. While Nupi implements reasonable security measures, we cannot guarantee absolute protection for Personal Data due to factors beyond our control, such as hacking, virus, dissemination, force majeure events, breach of firewall etc.

However, in this digital era, the transmission of information via the internet is never completely impenetrable. Hence, users should also take requisite steps to protect their personal information against any unauthorized access. Such steps include choosing a strong password, signing off after using a shared device, and keeping your log-in details, especially your password, private. Nupi shall not be held responsible for any lost, stolen or for any activity on your account via unauthorized password usage. Further, Nupi disclaims all liability for the breach of any of the User’s data in the event the said User fails to follow or knowingly breaches the mentioned guidelines for access.

HOW CAN YOU EXERCISE YOUR RIGHTS?

You have certain rights in relation to the Personal Data processed by Nupi as described below-

a. Right to Access: You can access a summary of your Personal Data that we process, including the processing activities for which it is being used..

b. Right to Correction and Erasure of Personal Data: You can request the correction, completion, updating of your Personal Data that we possess. If you wish to delete your personal information, please send an email request to us at support@nupipay.com for deletion of your personal information, provided there is no regulatory or legal obligation to retain the data, on receiving your request for deletion and we will inform you accordingly by email.

c. Right to Grievance Redressal: You may contact us in respect of any act or omission by Nupi regarding the performance of its obligations in relation to your Personal Data or the exercise of any rights.

d. Right to Nominate: You may nominate any other individual to exercise any of your above- mentioned rights in the event of your incapacity or death.

For you to exercise these rights that you have regarding your Personal Data you may contact us by email at support@nupipay.com

HOW LONG DOES NUPI KEEP YOUR DATA?

You can delete your account through mobile application. Once deleted, we cease the external processing of your Personal Data.

We retain Personal Data until the purpose for its usage exists, after which the same is erased by us, or until you withdraw your consent, or until you exercise the right to erasure of your Personal Data, whichever occurs earlier. However, we may retain your Personal Data for longer periods in the following circumstances:

i. If it is necessary for the specified purpose for which it was collected or for compliance with any applicable law.

ii. In the event of pendency of any legal or regulatory proceeding.

iii. For safety, security, and integrity purposes.

iv. Any other purposes such as any judicial and/ or governmental investigations.

v. To protect our rights, property, or products/ services.

HOW WILL YOU KNOW THE CHANGES IN PRIVACY STATEMENT?

Nupi reserves the right to modify this Privacy Statement periodically to reflect updates to its business processes, current acceptable practices, or legislative or regulatory changes. You should check this page from time to time to ensure that you are happy with any changes.. You will have the opportunity to review the updated Privacy Statement before deciding to continue using our products or services.

HOW TO CONTACT US?

You may contact us on any aspect of this Privacy Statement or for any grievance(s) with respect to your Personal Data, through email at support@nupipay.com

WHAT ARE ACCESS GUIDELINES FOR USERS?

• Don’t break our security measures or test the vulnerability of our systems or networks.

• Don’t access or use the Platform by means of any mechanism or technology which conceals your actual geo-location or provides incorrect details of your location (for example, use a virtual private network (VPN) to access the services).

• Don’t try to interfere with our networks, like sending a virus, overloading, spamming.

• Don’t collect or store personally identifiable information of people on the Platform.

• Don’t provide any unauthorized personal information of third parties while providing or contributing any User generated content on the Platform.

• Don’t share your password, allow anyone to access your account or do anything that might put your account at risk.

• Don’t attempt to buy or sell access to your account, or Usernames, or otherwise transfer account features for compensation.

• Don’t create or operate accounts that aren’t authentic.

• Don’t create new accounts for the purpose of violating these guidelines.

• Don’t link your web browser to websites that are unsafe, deceptive, untrustworthy, unoriginal, or that facilitate or encourage spam.

Don’t send unsolicited messages or make irrelevant comments on the content of the Platform.

APPENDIX

DEFINITIONS

Affiliate- In relation to another company, it means a company in which that other company has a significant influence, but which is not a subsidiary company of the company having such influence and includes a joint venture company.

Data Principal- The individual to whom the Personal Data relates and where such individual is-

i. a child, includes the parents or lawful guardian of such a child.

ii. a person with disability, including her lawful guardian, acting on her behalf.

This includes Nupi’s users, employees, and other individuals whose Personal Data is being processed by the Company.

Incapacity - Inability to exercise rights due to unsoundness of mind or infirmity of body.

Legitimate use- It refers to the uses for which your Personal Data may be processed as per the Digital Personal Data Protection Act, 2023.

Persons with Disability- It includes those who have long term physical, mental, intellectual, or sensory impairments which in interaction with various barriers may hinder their full and effective participation in society on an equal basis with others.

Third Parties - Any individual or entity who processes Personal Data on behalf of Nupi. Third Parties include but are not limited to Partners and Service Providers.