Privacy Policy – Sarthi Pay

5.4.1

Data Collected

We collect only what is necessary to deliver our services securely and in full compliance with applicable Indian regulations.

Identity Data

Name, mobile number, email address (if provided)

KYC Documents

Aadhaar, PAN, or other government-issued ID

Financial Data

Bank account details for virtual account linkage

Usage Data

Device info, IP address, and in-app activity logs

5.4.2

Purpose of Collection

Your personal data is processed strictly for the following purposes:

Account creation, identity verification, and onboarding
KYC compliance as mandated by RBI and PMLA
Facilitating secure fund transfers and virtual account operations
Sending transactional notifications and service updates
Fraud prevention, risk management, and regulatory reporting
Improving platform features and overall user experience

5.4.3

Legal Basis for Processing

We process your personal data under one or more of the following legal bases under Indian data protection law:

Consent — You have given explicit consent for specific activities
Contractual necessity — Processing is required to perform our services
Legal obligation — Compliance with RBI, PMLA, and other regulations
Legitimate interests — Fraud prevention and platform security

5.4.4

Data Sharing

We do not sell your personal data. We may share it only with:

Banking partners and payment processors for transaction execution
KYC verification agencies (e.g., UIDAI, NSDL) as required
Regulatory and law enforcement authorities under legal obligation
Cloud and technology service providers under strict data processing agreements

All third-party partners are contractually bound to process your data only as instructed and in accordance with applicable data protection laws.

5.4.5

Data Retention

We retain personal data only as long as necessary for the purposes stated in this policy, or as required by law.

KYC & transaction records: minimum 5 years post account closure (per PMLA)
Account and usage data: duration of account + 2 years
Marketing preferences: until consent is withdrawn

Upon expiry, data is securely deleted or irreversibly anonymised.

5.4.6

Data Security

Sarthi Pay implements industry-standard technical and organisational measures to protect your data:

256-bit AES Encryption

AI Fraud Detection

Biometric Auth

PCI-DSS Compliant

Role-based Access

Pen Testing

5.4.7

Your Rights

Subject to applicable law, you have the following rights over your personal data:

🔍

Access

Request a copy of the data we hold about you

✏️

Correction

Have inaccurate or incomplete data corrected

🗑️

Erasure

Request deletion where no legal basis exists

🚫

Objection

Object to legitimate-interest processing

📦

Portability

Receive your data in a structured format

↩️

Withdraw Consent

Withdraw at any time without affecting prior processing

5.4.8

Cookies & Tracking

Our platform uses cookies and similar technologies for session management, analytics, and preference storage. You may manage non-essential cookies via your browser settings or our in-app cookie preference centre.

Disabling essential cookies may impair core platform functionality such as login and payments.

5.4.9

Children's Privacy

Sarthi Pay services are not directed at persons under 18 years of age. We do not knowingly collect personal data from minors. If we become aware that a minor has provided data, we will delete it promptly. Parents or guardians should contact us immediately at the details below.

5.4.10

Contact Us

For privacy queries, data requests, or complaints, reach our Data Protection Officer:

Data Protection Officer

Sarthi Pay Pvt. Ltd. · Registered in India 🇮🇳

privacy@sarthipay.in 1800-XXX-XXXX (Toll Free) [Registered Office, India]

We aim to respond to all requests within 30 days. If unsatisfied, you may escalate to the relevant data protection authority.