Privacy Policy

1. Introduction

JustForPay (“JustForPay”, “Company”, “we”, “us”, “our”) respects the privacy of every individual and entity that accesses or uses its website, mobile application, APIs, platforms, and services (collectively, the “Platform”).

We recognize that personal data, financial information, and payment-related data are highly sensitive in nature and are committed to safeguarding such data with the highest standards of security, transparency, and legal compliance.

This Privacy Policy (“Policy”) explains how JustForPay collects, processes, stores, uses, shares, and protects information in accordance with applicable Indian laws, including:

• Information Technology Act, 2000
• Information Technology (SPDI) Rules, 2011
• Digital Personal Data Protection Act, 2023 (DPDP Act)
• RBI circulars and directions
• NPCI rules
• AML and PMLA regulations

This Policy forms an integral part of JustForPay’s Terms & Conditions. By accessing or using the Platform, you expressly consent to the practices described herein.

2. Applicability & Scope

This Policy applies to:

• Visitors to the JustForPay website
• Registered users, merchants, retailers, and Digi Kendras
• API and white-label partners
• Customers transacting via JustForPay-enabled channels

This Policy applies irrespective of the access method, including desktop, mobile devices, tablets, APIs, or other technologies.

3. Definitions

• Personal Data: Any data relating to an identifiable individual as defined under the DPDP Act.
• Sensitive Personal Data: Financial data, payment credentials, Aadhaar, PAN, biometric and KYC data.
• Payment Data: Transaction details, account information, timestamps, amounts, and identifiers.
• Data Principal: The individual to whom personal data relates.
• Data Fiduciary: JustForPay, determining the purpose and means of data processing.

4. Consent

By using the Platform, you provide free, informed, unconditional, and unambiguous consent for the collection and processing of your data for lawful purposes.

Explicit consent is obtained where required through electronic confirmation, OTP verification, or other lawful mechanisms. Consent may be withdrawn subject to statutory data retention obligations.

5. Information We Collect

5.1 Personal Information

• Full name, date of birth, age
• Mobile number and email address
• Residential or business address
• PAN, Aadhaar (where legally permitted)
• Photographs and signatures for KYC

5.2 Financial Information

• Bank account details
• Payment instrument details
• Transaction history
• Settlement and commission data

5.3 KYC & Compliance Information

• Identity and business documents
• GST details (where applicable)
• Video KYC or biometric verification (if mandated)

5.4 Device & Technical Information

• IP address
• Device identifiers
• Browser and OS details
• App version and usage logs

5.5 Location Data

With your permission, approximate or precise location data may be collected for fraud prevention, regulatory compliance, and service improvement.

6. Purpose of Collection

• User onboarding and account management
• KYC and AML compliance
• Transaction processing and settlements
• Fraud detection and risk management
• Regulatory reporting
• Customer support and grievance handling
• Platform security and performance

7. Payment Data & Data Localization

All payment data is stored on servers located within India in compliance with RBI data localization requirements.

Limited data for cross-border transactions may be processed outside India strictly as permitted by Applicable Law.

8. Cookies & Tracking Technologies

Cookies and similar technologies are used to enhance security, analyze usage, and improve user experience. Cookies do not store sensitive personal data.

9. Data Sharing & Disclosure

JustForPay does not sell or rent personal data.

Data may be shared with:

• RBI-regulated banks and financial institutions
• NPCI and payment networks
• Government or regulatory authorities when legally required
• Authorized service providers under confidentiality obligations

10. Data Security Measures

• Encryption of sensitive data
• Secure servers and firewalls
• Role-based access controls
• Regular security audits

11. Data Retention

Data is retained only for the duration necessary to meet service, legal, regulatory, or audit requirements and is securely deleted or anonymized thereafter.

12. User Rights

• Access personal data
• Request correction or updating
• Request erasure (subject to law)
• Withdraw consent
• Raise grievances

13. Children’s Data

Services are not intended for individuals under 18 years of age, and we do not knowingly collect children’s personal data.

14. Grievance Redressal

For privacy-related concerns, contact:

📧 privacy@justforpay.in
📧 support@justforpay.in

15. Governing Law

This Policy shall be governed by the laws of India, with exclusive jurisdiction of Delhi courts.

16. Final Disclaimer

JustForPay acts as a technology facilitator and processes data strictly in accordance with legal and regulatory requirements.