PaySay
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Privacy Policy

PRIVACY POLICY

PaySay is a registered trademark of V. N. Credits Ltd, a company incorporated under the provisions of the Companies Act, 1956, and has its registered office at 3/2, Amar Park, New Rohtak Road, Zakhira, Delhi-110035. PaySay is engaged in the business of providing services to the Customers for receiving financial products and services from the Company’s Lending Partner(s) and the Company owns, manages and operates the mobile application “PaySay” and its website available at  https://www.paysay.in

This Privacy Policy (“Policy”) outlines the Company’s practices in relation to the collection, storage, use, processing, and disclosure of information that its Customers, including you, have chosen to share upon visiting, downloading and using the Company’s mobile application ‘PaySay Application’ (“App”) or ‘PaySay website’ available at https://www.paysay.in (“Website”), individually or collectively, as the context may require, hereinafter referred to as “Platform”). Please read this Policy carefully to understand the Company’s policies and practices regarding your information and how it will be treated in accordance with this Policy. 

The services offered to you on or through the Platform are referred to as “Services”. Please note that unless specifically defined in this Policy, capitalised terms shall have the same meaning ascribed to them in the Definitions in the Company’s Terms and Conditions, available at  https://www.paysay.in (hereinafter referred to as “Terms”). Please read this Policy in consonance with the Terms. 

By visiting, accessing the Platform and/ or downloading the App or by using all or any part of the Services, you are expressly agreeing to and consenting to the terms of this Policy and, by any use of the Platform, you shall be deemed to have given your consent for the processing of your Personal Data as set out in this Policy agree to the terms of this Policy.

1.          DEFINITIONS OF TERMS USED IN THE POLICY

(a)      ‘Company’ or ‘PaySay’ shall mean V. N. Credits Ltd, its group companies,

(b)       ‘We’ or “us” or “our” shall mean V. N. Credits Ltd, its Lending Partner(s) and their service providers.

(c)        ‘Customer’ or ‘you’ or ‘your’ shall mean the prospective and current customers of the Company (including representatives of the customers) and visitors to the PaySay’s Platform.

(d)       ‘App’ shall mean the mobile application named ‘PaySay’ owned by the Company.

(e)       ‘Collected Information’ shall mean a part or whole of Sensitive Personal Information, Personal Information, and other information pertaining to you received/ collected by us as per this Policy.

(f)        ‘Cookies’ shall mean bits of electronic information that can transfer to your hard drive, mobile device, or other device to keep records of your use or visit to the Platform.

(g)       ‘Device Information’ shall mean unique device identifier such as IMEI number, contact lists (in some cases), technical data about your computer and/ or your mobile device including details regarding associated applications and their usage details.

(h)       ‘Platform’ shall mean the Digital Platforms owned by V. N. Credits Ltd., including the Company’s website (available at https://www.paysay.in ), the Company’s mobile application (“App”), related online services and digital/ electronic media.

(i)         ‘Lending Partner(s)’ shall mean those regulated entities registered and authorized by the RBI which have partnered with us to offer loan and credit facilities to a Customer on the Platform.

(j)        ‘Location Information’ shall mean information that may be collected by certain mobile applications that identifies your physical location. This information may be collected from your mobile device’s location-aware features when you request certain services that are dependent on your physical location.

(k)       ‘Personal Information’ or ‘Personal Data’ shall mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with the Company, assists in identifying such person. It also refers to information/ data that identifies you (whether directly or indirectly), such as information you may provide in forms, surveys, online applications or similar online fields available on the Platform. The ‘Personal Information’ or ‘Personal Data’ for the purpose of this Policy shall include the following:

(i)         Your full name/ previous names.

(ii)        Your postal address, 

(iii)      Your email address

(iv)       Your mobile/ telephone number

(v)        Your domicile.

(vi)       Your nationality.

(vii)     Your date of birth.

(viii)    Details of your family.

(ix)       Details of your educational qualification, your college/ university etc.

(x)        Details of your profession, employment etc.

(l)         'RBI' shall mean the Reserve Bank of India.

(m)     ‘Sensitive Personal Information’ of a person shall mean ‘Sensitive Personal Data or Information’ as defined in the ‘Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011’ (“SPDI Rules”) and such ‘Sensitive Personal Information’ for the purpose of this Policy shall consist of the following information relating to you:

(i)         Password.

(ii)        Financial information such as Bank account or credit card or debit card or other payment instrument details or loan & its repayment details.

(iii)      Physical, physiological and mental health condition.

(iv)       Sexual orientation.

(v)        Medical records and history.

(vi)       Biometric information.

(vii)     Any such information relating to the above clauses received/ collected by the Company for providing the Services; and

(viii)    Any of the information received/ collected under above clauses by the Company for processing, stored or processed under lawful contract or otherwise.

However, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information for the purposes of these rules.

(n)       ‘Services’ shall mean the services offered by the Company or by the Company’s Lending Partner(s) to you on or through the Platform, whether the Website or the App.

(o)       ‘Website’ shall mean the Company’s website available at https://www.PaySay.in.

2.          INFORMATION COLLECTION

(A)     Collection of Personal Information and Sensitive Personal Information- When you use the Platform, whether the Website or the App, we collect and store your Personal Information and Sensitive Personal Information, from time to time, with your explicit consent. Our primary goal in doing so is to provide you with a safe, efficient, smooth, and customized experience and services. This allows us to provide services and features that meet your needs, and customize the Platform to make your experience safer and easier and improve the services provided by us. 

In general, you can browse the Website or App without telling us who you are or revealing some of the Personal Information about yourself. However, to create an account on the Website or App, you must provide us with the certain basic information required to provide customized services. The information we/ Platform collect from you, inter alia, may include the following data/ information:

(i)         Your Personal Information.

(ii)        Your Sensitive Personal Information.

(iii)      Your Permanent Account Number (“PAN”) details, Aadhaar Number (subject to the statutory requirements), copy or details of Identity Proof & Address Proof and photograph(s).

(iv)       Income, financial data and transaction data pertaining to you collected, with your consent, from your bankers, your lenders, your employer and the entities/ organisations.

(v)        Credit Information pertaining to you provided by you or received from Credit Information Companies on your behalf based on your authorisation.

Where possible, we/ PaySay shall indicate the mandatory and the optional fields. You shall always have the option to not provide your Personal Information/ Sensitive Personal Information by choosing not to use a particular service or feature on the Platform. 

By using the Services and the Platform, you give specific consent to us to collect, store, analyze, use, and otherwise exploit (including for commercial reasons) your Personal Information and Sensitive Personal Information. While you can browse some sections of the Platform without being a registered member as mentioned above, certain activities (such as availing of loans from the Company’s Lending Partner(s) on the Platform) require registration and for you to provide the above details. The Platform shall clearly display the Personal Information and Sensitive Personal Information it is collecting from you, and you have the option to not provide such Personal Information/ Sensitive Personal Information. However, this will limit the services provided to you on the Platform. Further, you specifically consent to share your Sensitive Personal Information and Personal Information for the usage of Services on the Platform.

(B)     Collection of Financial SMS Information- We don’t collect or store your personal SMS. However, we (through the Platform) collect, store, analyze, and process, your financial SMS (sent by 6-digit alphanumeric senders) data to the Platform’s/ PaySay’s servers, 

(C)    Collection of Mobile Number and E-mail Address- When you sign up with us, we collect your mobile number and email address to uniquely identify you. This helps us ensure that no unauthorised device or person is acting on your behalf.

(D)    Collection of Device Information- Our App collects information from your device that includes the IMEI number, model number, OS details, mobile network information and Wi-Fi information to provide additional security so that no unauthorized devices act on your behalf to prevent fraud.

(E)     Collection of Location- We collect and monitor the location information from your device to provide the serviceability of your line of credit. This also helps us to verify the addresses and make a better credit risk decision.

(F)    Collection of Contact Details of the References Provided by You- As a part of the Platform’s journey, we require contact details of the references to whom you can refer PaySay, to whom PaySay or its Lending Partner(s) can reach out for reference purposes to process your loan proposal. 

(G)     Storage- We require storage information permission so that you can upload photos and/or documents to complete your onboarding journey, for our lending Partners. However, we shall not be retained any photos and documents by PaySay.

(H)    Camera- We require camera access so that you can easily scan any document or scan any QR code to initiate KYC due diligence/ payment/ video verification/ verification of documents/ verification of identity documents etc. 

(I)        Collection of Usage Information- We automatically track certain information about you based on your behaviour on the Platform. We use this information to do internal research on our users’ demographics, interests, and behaviour to better understand, protect and serve our users and improve the Services offered by us or by the Company’s Lending Partner(s). This information is compiled and analysed, including on an aggregated basis. We also collect your Internet Protocol (IP) address and the URL used by you to connect your computer/ mobile to the internet, etc. This information may include the URL that you just came from (whether this URL is on the Platform/ Website/ App or not), which URL you next go to (whether this URL is on the Platform/ Website/ App or not), your computer browser information, and your IP address.

We will use cookies on the Platform/ Website/ App like other lending websites/apps and online marketplace websites/apps. Use of this information helps us identify you/ your preferences in order to make the Platform/ Website/ App more user friendly. Most browsers will permit you to decline cookies but if you choose to do this it might affect service on some parts of the Platform/ Website/ App. Please do refer to the section on cookies later for more detail on this.

If you choose to make a purchase through the Platform/ Website/ App, we collect information about your buying behavior. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.

If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Platform/ Website/ App, we collect such information into a file specific to you.

3.          PURPOSE, USAGE AND DISCLOSURE OF THE COLLECTED INFORMATION

The primary purpose of collecting your information is to provide you with the Services. We access, store and use the information we collect from to provide the Services, research and develop new ones. We use your Personal Information, Sensitive Personal Information and other Collected Information to provide the services you request, customize your user experience and improve our services. To the extent we intend to use your Personal Information/ Sensitive Personal Information to sell/ market any product to you, we will provide you with the ability to opt-out of such uses.

In our efforts to continually improve our product and service offerings, we collect and analyze demographic and profile data about our users' activity on the Platform/ Website/ App. We will use and retain your information for such periods as necessary to provide you with the Services, comply with our legal/ regulatory obligations, resolve any disputes, and enforce our agreements/ contractual rights.

PaySay may use and disclose the Collected Information (to its representatives and its Lending Partner(s)/ Agent(s) etc.) in the various ways to achieve the objectives such as the following:

(i)         To register you as a user of the Platform.

(ii)        To establish identity and verify the same.

(iii)      To monitor, improve and administer the Platform.

(iv)       To provide the Services offered by us or by the Company’s Lending Partner(s) including credit profiling for the purpose of facilitating loans to you.

(v)        To design and offer customized products and services offered by the Company’s third-party Lending Partner(s).

(vi)       To analyse how the Platform/ Website/ App is used, diagnose service or technical problems and maintain security.

(vii)     To send communications notifications, information regarding the products or services requested by you or process queries and applications that you have made on the Platform/ Website/ App.

(viii)    To manage our relationship with you and inform you about other products or services which as per us may be useful to you.

(ix)       To conduct data analysis in order to improve the Services/ Products provided to you or a Customer.

(x)        To use the Collected Information in order to comply with the applicable laws and regulations.

(xi)       To conduct your due diligence including KYC due diligence for the Company’s third-party Lending Partner(s) based on the information shared by you.

(xii)     To use the Collected information in other ways permitted by law to enable you to take financial services from the Company’s Lending Partner(s).

(xiii)    To detect and protect us against suspicious or illegal activity, fraud and other criminal activity.

(xiv)    To resolve disputes or troubleshoot problems.

In addition to the above, the Collected Information may be used by us for the following purposes:

(i)         To provide personalised offers.

(ii)        To manage our relationship with you, including notifying you of changes relating to any of the Services.

(iii)      To administer and protect our business and the Platform, including troubleshooting, data analysis, system testing, and performing internal operations.

(iv)       To deliver content.

(v)        To send you communication, including through WhatsApp business messages, in relation to your use of the Platform or the Services.

(vi)       To monitor trends so we can improve the Platform and the Services.

(vii)     To improve our business and delivery models.

(viii)    To perform our obligations that arise out of the arrangement the Company and its Lending Partners are about to enter or have entered with you.

(ix)       To enforce our Terms and legal requirements.

(x)        To perform collection related activities.

(xi)       To undertake marketing services, including sending you promotional messages.

(xii)     To respond to court orders, establish or exercise our legal rights, or defend ourselves against legal claims.

PaySay will not use the Collected Information for any purpose other than in connection with this Platform or beyond the provisions of this Policy. PaySay will not rent, sell or share the Collected Information and will not disclose any of Personal Information or Collected Information to third parties, unless:

(a)     it is pursuant to obtaining your consent.

(b)     it is in connection with the Services being rendered through the Platform.

(c)     it is to help investigate, prevent or take action regarding unlawful and illegal activities.

(d)     it is to investigate suspected fraud, potential threat to the safety or security of any person, violations of the Platform’s/ PaySay's Terms & Conditions, or as defense against legal claims.

(e)     if it forms part of the information, PaySay shares with advertisers on an aggregate basis.

However, PaySay shall not share/ disclose your Sensitive Personal Information to any third party unless it has your prior permission, or you have agreed for the same with us.

4.          SHARING OF INFORMATION

As mentioned above, any or all information pertaining to you, whether or not you directly provided it to us, may be shared in order to render the Services to you. In addition, PaySay may share your information with the following:

(a)     The Company’s affiliate or subsidiaries or any company that it intends to merge with or acquire.

(b)     The Company’s Lending Partner(s) in order to provide the Services to you or develop new products.

(c)     Credit Bureau and other third parties (including collection agencies) are involved directly or indirectly in providing services or in running our business operations. This may include but not be limited to our Lending Partner(s), storage providers, data analytics providers, consultants, lawyers, and auditors.

(d)     Where PaySay is required by any applicable law, any court, a government agency, or authority to disclose such information. Such disclosures are made in good faith and belief that it is reasonably necessary to do so for enforcing this Policy or the Terms, or in order to comply with any applicable laws and regulations.

(e)     The acceptance of this Policy by you authorizes the Company, the Company’s Lending Partner(s), its affiliates/ agents/ representatives and subsidiaries to contact you via SMS email, phone, or otherwise regarding the Services or any promotional offers.

5.          ACCESS AND UPDATE YOUR INFORMATION

As and when you provide any information/ documents on the Platform, you hereby warrant that all information that you provide us with is accurate, up-to-date, and true. 

6.          DATA SECURITY

PaySay implements appropriate security measures to protect your information from unauthorised access, and follow standards prescribed by the applicable law. PaySay uses appropriate security based on the type and sensitivity of data being stored. As with any internet-enabled system, there is always a risk of unauthorised access, so it’s important to protect your password and to contact us if you suspect any unauthorised access to your account.

PaySay take appropriate security measures such as using HTTPS to transfer your data to protect against unauthorised access, alteration, disclosure, or destruction of your personal data that it collects and stores. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so PaySay cannot guarantee that communications between you and Platform/ PaySay, the Services, or any information provided to it in connection with the data collected through the Services will be free from unauthorised access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately. 

7.          DATA RETENTION

You agree and acknowledge that your information will continue to be stored and retained by us for as long as necessary to fulfil our stated purpose(s) or for a reasonable period after termination of your account on the Platform or access to the Services, whichever is later.

Criterion for Determining Data Retention Period- It is not possible for us to determine a specific period for which PaySay may retain your data. However, PaySay will use and retain your information for such periods as necessary to provide you with the Services, comply with our legal/ regulatory obligations, resolve any disputes, and enforce our agreements/ contractual rights.  PaySay will retain your data for longer than necessary, taking into account the following:

(a)     The purpose(s) and use of your data, both now and in the future (such as whether it is necessary to continue to store that information in furtherance of our obligations under a contract with you, or to contact you in the future);

(b)     Whether PaySay have any legal obligation to continue processing your data (such as any record-keeping obligations imposed by any applicable law);

(c)     Whether PaySay have any further legal basis to continue processing your information (including your consent);

(d)     Whether there is any relevant agreed industry practice on how long such data should be retained;

(e)     The levels of risk and liability involved for us to continue holding the data;

(f)      The amount of difficulty PaySay may face to ensure the data can be kept updated and accurate; and

(g)     Any other circumstances, such as the nature and status of the Company’s and the Company’s Lending Partner(s)’s relationship with you.

8.          COOKIE POLICY

8.1       What are cookies?

Cookies are small text files stored by your browser as you browse the internet. They can be used to collect, store, and share data about your activities across the Platform/ PaySay, including the Website/ App. Cookies also allow us to remember parameters/ credentials pertaining to your visits to the Platform/ PaySay, like your account ID, and to make the Platform easier to use.

PaySay uses both types of cookies, i.e. the Session Cookies (which expire after a short time or when you close your browser) and the Persistent Cookies (which remain stored in your browser for a set period of time). PaySay uses the Session Cookies to identify you during a single browsing session, like when you log into the Website/ App. PaySay uses the Persistent Cookies where it needs to identify you over a longer period, like when you request that the Platform should keep you signed in.

8.2       Why does the Platform/ PaySay use cookies and similar technologies?

PaySay uses cookies and similar technologies like web beacons, pixel tags, or local shared objects (“Flash Cookies”), to deliver, measure, and improve the Services offered by us or by the Company’s Lending Partner(s) in various ways. PaySay uses these cookies both when you visit the Platform and the Services through a browser and through the Website/ App. As PaySay adopts additional technologies, PaySay may also gather additional data through other methods.

8.3       PaySay uses cookies for the following purposes:

Authentication and Security

- To log you into the Platform/ PaySay 

- To protect your security

- To help detect and fight spam, abuse, and other activities that violate the Platform’s/ PaySay’s agreements

For example, cookies help authenticate your access to the Platform/ PaySay and prevent unauthorised parties from accessing your accounts:

Preferences

- To remember data about your browser and your preferences

- To remember your settings and other choices you have made

For example, cookies help us remember the program/ offer you are interested in, so PaySay can provide communication relevant to such program/ offer each time you visit.

Analytics and Research

- To help us improve and understand how people use the Platform/ PaySay 

- For other purposes we may want to use/analyse your data.

For example, cookies help us test different versions of the Platform/ PaySay to see which features or content, users prefer, web beacons help us determine which email messages are opened, and cookies help us see how you interact with the Platform/ PaySay, like the links you click on.

We also work with a number of analytics partners, including Google Analytics, Hotjar and Mixpanel, who use cookies and similar technologies to help us analyse how users use the Services, including by noting the sites from which you arrive. Those service providers may either collect that data themselves or we may disclose it to them.

Personalised Content

- To customise PaySay with more relevant content

For example, cookies help us show a personalised list of recommended programs/ offers on the homepage.

Advertising

- To provide you with more relevant advertising

Please note that where advertising technology is integrated into the Services, you may still receive advertising on other websites and applications, but it will not be tailored to your interests.

When using mobile applications, you may also receive tailored in-app advertisements. Apple iOS, Android OS, and Microsoft Windows each provide its own instructions on how to control in-app tailored advertising. For other devices and operating systems, you should review your privacy settings or contact your platform operator.

8.4       What are my privacy options?

You have a number of options to control or limit how PaySay and its Lending Partner(s) use cookies:

§      Most browsers automatically accept cookies, but you can change your browser settings to decline cookies by consulting your browser’s support articles. If you decide to decline cookies, please note that you may not be able to sign in, customise, or use some interactive features in the Services.

§   Flash Cookies operate differently than browser cookies, so your browser’s cookie-management tools may not remove them. 

9.          TRANSFER OF INFORMATION

PaySay complies with applicable laws in respect of storage and transfer of your information. Please note that your financial data available with/ provided to PaySay is only stored on the servers/ systems located in India.

10.       LINKS TO THIRD PARTY WEBSITES

The Services offered by PaySay or its Lending Partner(s) may, from time to time, contain services provided by or links to and from the websites of the Company’s Lending Partner(s)’s networks, service providers, financial institutions, advertisers, and affiliates (“Third Party Services”). Please note that the Third Party Services that may be accessible through our Services are governed by their own privacy policies. PaySay does not accept any responsibility or liability for the policies or for any information that may be collected through such Third-Party Services. Please check their policies before you submit any personal data to such websites or use their services.

11.       BUSINESS TRANSITIONS

You agree and acknowledge that in the event PaySay goes through a business transition, such as a merger, acquisition by another organization, or sale of all or a portion of our assets, your personal data might be among the assets transferred.

12.       YOUR RIGHTS

You have certain rights around the use of your data, including the ability to opt out of promotional emails, cookies, and collection of your data by certain analytics providers. You can update or terminate your account registered with us for the Services, and can also contact us for individual rights requests about your personal data such as to restrict our processing of your data, to erase all data PaySay has stored about you, and the right to ask for the data to be provided to you/ ported to any other service in a commonly used machine readable format.

12.1     Your Choices About the Use of Your Data

(a)     You can choose not to provide certain data to us, but you may not be able to use certain features of the Services.

(b)     To stop receiving promotional communications from us, you can opt out by using the unsubscribe mechanism in the promotional communication you receive or by changing the email preferences in your account. Note that regardless of your email preference settings, we will send you transactional and relationship messages regarding the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about the Company’s policies.

(c)     The browser or device you use may allow you to control cookies and other types of local data storage. Your wireless device may also allow you to control whether location or other data is collected and shared.

If you have any questions about your data, our use of it, or your rights, contact us at support@paysay.in

12.2     Accessing, Updating and Correcting, Porting and Deleting Your Personal Data- You can access and update your personal data that PaySay collects and maintains as under:

(a)     To update data you provide directly, log into your account and update your account at any time.

(b)     To terminate your account:

§ If you are a user, write to delete your account permanently.

§  Please note that, even after your account is terminated, some or all of your data may still be visible to others, including without limitation any data that has been (a) copied, stored, or disseminated by other users; (b) shared or disseminated by you or others (including in your shared content); or (c) posted to a third-party platform. Even after your account is terminated, we may retain your data for as long as we have a legitimate purpose to do so (and in accordance with applicable law), including to assist with legal obligations, resolve disputes, and enforce our agreements. We may retain and disclose such data pursuant to this Privacy Policy after your account has been terminated.

(c)     To request to access, correct, port, or delete your personal data, or to restrict processing of your personal data, please email support@paysay.in. Please allow us up to 30 days for a response. For your protection, we will require that the request be sent through the email address associated/ registered with your account, and we may need to verify your identity before implementing your request. Please note that post deletion, we may retain certain data for which we have legal rights/ obligations to do so, including for mandatory record-keeping and to complete transactions.

12.3     Withdrawal of Consent- You may withdraw your consent given for collecting any information and personal data under this Privacy Policy and pursuant to use of the Services, at any time by sending an email tosupport@paysay.in. Please allow us up to 30 days for a response. 

In case of withdrawal of your Consent or deletion of your Personal Data, PaySay reserves the right to not allow you further usage of the Platform/ Website/ App or to not to provide/ use any Services thereunder, without any obligations or liability, whatsoever, whether in contract, tort, law, equity or otherwise, in this regard. Further, please note that such withdrawal of consent shall be prospective in nature, and shall not affect the lawfulness of any data processed based on your consent given prior to withdrawal.

13.      EXPLOREExplore feature in an independent service offered by PaySay. In which a user which is registered with PaySay Platform broadcast himself to other users of PaySay Platform and provide for real time interactions with other Users along with other different options.

13.1. Information We Collect:

13.1.1 User-Provided Information: When you use the Explore, you may provide us with certain personal information, including but not limited to:

·       Your username

·       Profile picture

·       Broadcast content and videos (not mandatory)

·       Interactions and messages within the Explore

13.1.2. Usage Information: We collect information about how you use the Explore, including your interactions, preferences, and settings. This information may include:

·       Device information

·       IP address

·       Location information 

·       Log data

·       Usage patterns and behaviors

13.2. How We Use Your Information:

13.2.1. Providing Services: We use the information we collect to provide and improve the services offered through the Explore. This includes displaying your broadcast content to other users as per your settings and preferences opted by the User.

13.2.2. Personalization: We may use your information to personalize your experience within the Explore, such as recommending content and connections that match your interests.

13.2.3. Communication: We may use your contact information to send you updates, notifications, and promotional materials related to the Explore. You can opt out of these communications at any time.

13.2.4. Research and Analytics: We may use your information for research and analytics purposes, such as understanding user behavior, improving the Explore's performance, and optimizing user experience.

13.3. Sharing of Information:

13.3.1. User Interactions: The nature of the Explore involves sharing your broadcast content with other users. Your interactions and content may be visible to other users according to your preferences.

13.3.2. Service Providers: We may engage third-party service providers to assist us in operating the Explore and delivering services. These providers will have access to your information to the extent necessary to perform their functions.

13.3.3. Legal Compliance: We may disclose your information if required by law or in response to valid legal requests, such as authority, regulatory body notices and court orders.

13.4. Children's Privacy:

The Explore is not intended for users under the age of 18. If you believe we have collected such information, please contact us immediately. We shall delete the same with immediate effect. Further in case you encounter any form of child abuse or child endangerment, it requested to report the same to https://www.childlineindia.org.in/ and report the same to us.

13.5. Anti-Harassment Policy

Harassment shall mean any unwanted or harmful behavior directed at an individual or group based on characteristics such as race, ethnicity, gender, sexual orientation, religion, disability, or any other protected category. Harassment can take various forms, including but not limited to:

·       Offensive comments, slurs, or language.

·       Threats, intimidation, or verbal abuse.

·       Cyberbullying or online stalking.

·       Posting or sharing explicit or inappropriate content without consent.

·       Discriminatory remarks or hate speech.

·       Trolling or deliberately inciting others to engage in harmful behavior.

·       False Report request

13.6. Prohibited Conduct:

Prohibited Conduct shall mean any content or conduct which shall be deemed inappropriate or may disturb the other Users or may case unrest in the society. Prohibited Conduct may be categorized into including but not limited to:

-Illegal Content

-Hate Speech and Discrimination

-Harassment and Threats

-Explicit or Adult Content or Nudity

-Violence and Gore

-Misinformation and Fake News

-Promoting Gambling or other activities prohibited by Applicable law

-Copyright Infringement

-Impersonation and Fake Accounts

-Extreme Political or Religious Content

-Child Endangerment

13.7. Investigation and Response

Upon receiving a harassment report, we will promptly investigate the matter. Our investigation will be conducted in a fair and confidential manner. If the reported behavior is found to violate our Anti-Harassment Policy, we will take appropriate actions, which may include:

- Warning the individual involved in the harassment.

- Temporarily or permanently suspending the individual's access to our Platform.

- Removing content that violates our policy.

- Cooperating with legal authorities in serious cases.

13.8. User Responsibilities

All users are expected to treat each other with respect and follow our Anti-Harassment Policy. Any violation of the same shall be treated as a breach of the Terms of Service of Platform which may result in banning you as a user. 

We are committed to maintaining a harassment-free environment on our Platform and will make every effort to prevent and address any incidents that violate this policy.

We only act as an “intermediary” as per clause (w) section 2 of Information Technology Act, 2000. Any information which is received from you is transmitted through us. The user using the Explore shall be solely responsible for any violations of Applicable Laws. 

13.9. Reporting Harassment/ Prohibited Conduct/ Contact us.

In case we encounter any form of Harassment/ Prohibited Conduct you shall immediately contact our support team at support@paysay.in. Please provide as much detail as possible about the incident, including usernames, dates, times, and descriptions of the behavior.

14.       CHANGE IN PRIVACY POLICY

PaySay keeps its Policy under regular review and may amend it from time to time, at its sole discretion. Any changes shall be deemed effective immediately upon publishing of the modified Policy on the Platform/ Website/ App and any continuous usage of the Services, following the modification will indicate acceptance of changes in Policy by you.

15.       GRIEVANCE OFFICER AND CONTENT CONTROL PERSONNEL

You may contact the Company’s Grievance Officer with any enquiry relating to this Policy or your personal data. Details of the Grievance Officer for this purpose are as under:

Name: Rahul Arora (GO) & Nikita Singh (CCP)

Address: 3/2, Amar Park, New Rohtak Road, Zakhira, Delhi-110035.

Email Address: compliance@PaySay.in

16.       UPDATES & CONTACT INFO

From time to time, PaySay may update this Policy. If this Policy is updated, PaySay will notify you by posting the policy on our site with a new effective date. If any material changes are made, PaySay will take reasonable steps to notify you in advance of the planned change.