Privacy Policy

A comprehensive guide to our Privacy Policy, how we collect, use, and safeguard your personal information, and your rights to control your data.

Effective date: 25th May 2026

About PayGlocal

PayGlocal Technologies Private Limited ("PayGlocal," "We," "Us," or "Our") is a payments processing company incorporated under the Companies Act, 2013, with its registered office at 6048, Prestige Shantiniketan, ITPL Main Road, Whitefield, Bengaluru, Karnataka - 560048, India. We provide payment processing and related services through our website, software, platforms, APIs, checkout pages, and payment infrastructure (collectively, the "PayGlocal Platform").

PayGlocal is authorized by the Reserve Bank of India ("RBI") as a Payment Aggregator - Online and Cross Border - Inward and Outward transactions - under the Payment and Settlement Systems Act, 2007. PayGlocal operates payment infrastructure that enables businesses in India and globally to accept and process digital payments from their customers across the world.

The processing of Personal Data is an integral part of providing payment services and complying with applicable legal, regulatory, and operational requirements. Accordingly, protecting personal data and maintaining data security are important considerations in how we design, build and operate our products and services.

This Privacy Policy ("Policy") applies to Personal Data processed in connection with PayGlocal's services and interactions, including in relation to merchants and other businesses using the PayGlocal Platform, individuals or entities making payments through our payment infrastructure, visitors to our websites, individuals exploring or applying to use our Services, job applicants, and other individuals whose Personal Data is processed by PayGlocal in the course of its business activities.

Defined terms used in this Policy, including the specific categories of individuals referred to above, are set out in the Definitions section immediately below.

Definitions

For the purposes of this Privacy Policy, the following terms have the meanings set out below. Where a term is not defined here, it has the meaning given to it under Applicable Laws.

Applicable Laws means all laws, regulations, rules, regulatory guidelines, master directions, and circulars applicable to PayGlocal's operations from time to time. This includes, without limitation, Indian laws and regulations governing data protection and privacy, payment services, anti-money laundering, KYC and identity verification, foreign exchange, and financial services, including those issued by the Reserve Bank of India applicable to Payment Aggregators, the "Digital Personal Data Protection Act, 2023," the "Payment and Settlement Systems Act, 2007," the "Prevention of Money Laundering Act, 2002," the "Foreign Exchange Management Act, 1999," and the "Information Technology Act, 2000;" and applicable foreign and international data protection, privacy, and financial services laws in any jurisdiction in which PayGlocal operates or in which individuals whose Personal Data we process are located. References to any law or regulation include references to that law as amended, re-enacted, or replaced from time to time, and to any subordinate legislation, rules, or regulatory guidance made thereunder.

You or Your refers to any individual or entity whose Personal Data is processed by PayGlocal under this Policy, including Merchants/Business Users, End-Customers, Leads, Prospective Merchants/Business Users, Website Visitors, and Job Applicants, as applicable. For the purposes of Applicable Laws, "You" corresponds to the "Data Principal" under the DPDPA, the "Data Subject" and equivalent terms under other Applicable Laws. Where the context relates to a specific category of individual, the relevant defined term is used.

Services means the payment processing products, platforms, applications, APIs, tools and related services offered by PayGlocal, as described on our website and in our agreements with Merchants.

Personal Data means any information that relates to an identified or identifiable individual, including information that you provide to us, information we collect about you, or information we receive in connection with providing our Services, as defined under applicable data protection laws.

Transaction Data means data generated, transmitted or processed in connection with a payment facilitated through the PayGlocal Platform, including transaction amount, currency, date and time, payment method, transaction status, and related operational details. Transaction Data constitutes Personal Data where it identifies or reasonably identifies an individual.

Processing means any operation or set of operations performed on Personal Data, including collection, recording, storage, organisation, retrieval, use, disclosure, transmission, transfer, erasure, or destruction, whether or not by automated means, as defined under Applicable Laws.

Business User means any individual, sole proprietor, partnership, company, or other legal entity that is approved to use the PayGlocal Platform to accept payments from End-Customers for goods or services.

End-Customer means an individual or entity who initiates or completes a payment to a Business User using a payment method facilitated through the PayGlocal Platform.

Lead means an individual or business that has expressed interest in PayGlocal or its Services, including through website forms, email communications, marketing campaigns, events, advertisements, referrals, or other lead-generation activities, but has not yet commenced formal onboarding as a Prospective Merchant.

Prospective Business User means an individual or entity that has progressed beyond the Lead stage and is undergoing evaluation, due diligence, or verification by PayGlocal prior to approval and onboarding as a Merchant/Business User.

Website Visitor means any individual who visits or interacts with PayGlocal's websites or online resources without being logged/authenticated into a PayGlocal account.

Job Applicant means any individual who applies for employment or engagement with PayGlocal and provides Personal Data as part of the recruitment or hiring process.

Financial Partners means banks, financial institutions, payment networks, payment method providers, acquiring banks, payment processors, and other partners that PayGlocal works with, directly or indirectly, to provide the Services.

Third-Party Service Providers means vendors and service providers engaged by PayGlocal to support its operations, including providers of fraud detection and prevention, KYC and KYB verification, data hosting and cloud infrastructure, analytics, and customer communications tools.

Data Fiduciary means an entity that, alone or in conjunction with others, determines the purpose and means of processing Personal Data, as defined under the DPDPA. For the purposes of this Policy, "Data Fiduciary" corresponds to "Data Controller" and to equivalent terms used under other Applicable Laws.

Data Processor means an entity that processes Personal Data on behalf of, and under the documented instructions of a Data Fiduciary. This term carries equivalent meaning under other Applicable Laws.

Entity means any type of legal entity as defined in jurisdiction-specific corporate structures.

Scope and Application of This Policy

This Policy describes how PayGlocal collects, uses, shares, and safeguards Personal Data in connection with the PayGlocal Platform and our Services. It describes the purposes for which we process Personal Data, the legal bases that apply under Applicable Laws, the rights available to You and how You can exercise those rights or contact us with questions or concerns. We encourage You to read this Policy carefully.

This Policy applies to Personal Data processed in the course of onboarding, providing Services to, and supporting Merchants; when facilitating or supporting payment transactions made by End-Customers; in connection with fraud prevention, risk management, identity verification, regulatory compliance, security, dispute handling, and related operational activities; through our websites, APIs, merchant dashboards, checkout pages, and other components of the PayGlocal Platform; and during communications, business development activities, and recruitment processes.

Who This Policy Applies To

This Policy applies to Personal Data processed by PayGlocal in relation to:

In some cases, an individual may fall into more than one category at different stages of engagement.

PayGlocal's Role in Processing Personal Data

PayGlocal's role in processing Personal Data depends on the context and nature of the processing activity.

Where PayGlocal independently determines the purposes and means of processing, including for merchant onboarding, identity verification, fraud detection and prevention, risk management, transaction monitoring, dispute handling, compliance with Applicable Laws, security operations, and the general operation of the PayGlocal Platform, PayGlocal acts as a Data Fiduciary.

Where PayGlocal processes Personal Data on behalf of a Merchant, in accordance with that Merchant's documented instructions, and where PayGlocal's own independent regulatory obligations do not govern that processing, PayGlocal acts as a Data Processor under Applicable Laws and the relevant contractual arrangements.

In certain payment processing scenarios, different elements of the same transaction may involve PayGlocal acting in different capacities: as a Data Processor to enable and complete a transaction on behalf of a Merchant; and independently as a Data Fiduciary where processing is necessary to comply with Applicable Laws, meet card network requirements, fraud prevention requirements, or to protect the integrity and security of the PayGlocal Platform.

Notwithstanding the above, PayGlocal remains independently responsible for complying with regulatory obligations applicable to Payment Aggregators under RBI directives, including in relation to payment system data.

What This Policy Does Not Cover

This Policy applies to PayGlocal's own processing activities. It does not govern how Merchants, Financial Partners, Third-Party Service Providers, or other third parties independently collect, use, or share Personal Data, each of which is subject to their own privacy policies and legal obligations.

When You transact with a Merchant, their privacy practices are governed by their own privacy notice. We encourage You to review it. Merchants remain responsible for providing appropriate privacy notices to End-Customers in respect of their own independent data processing activities.

Your rights and how to exercise them are described in the "Your Data Protection Rights" and "Contact Us" sections of this Policy.

For information about how we use cookies and similar technologies on the PayGlocal Platform, please visit our website or contact our Data Protection Officer.

Personal Data We Collect and How We Process and Share It

The Personal Data we process, the purposes for which it is processed, and the manner in which it is shared depends on your relationship with PayGlocal and the nature of your interaction with the PayGlocal Platform. For example, you may interact with us as a Business User, an End-Customer of a Business User, a lead or prospective Business User, a website visitor, or a job applicant. In some cases, an individual may fall into more than one category at different stages of engagement.

As an RBI-authorised Payment Aggregator, PayGlocal processes Personal Data in connection with merchant onboarding, payment transaction facilitation, fraud detection and prevention, risk management, regulatory compliance, dispute handling, and the operation and security of the PayGlocal Platform. Certain processing activities are required under Applicable Laws, including payment system regulations, KYC and anti-money laundering requirements, and card network rules.

This section describes the categories of Personal Data we collect; how we collect such data; the purposes for which we process it; the categories of recipients with whom it may be shared; and the context in which PayGlocal acts as a Data Fiduciary or Data Processor. Detailed information regarding legal bases, retention, international transfers, security safeguards, and data protection rights is provided in the relevant sections of this Policy.

Our Role in Processing Personal Data

For Business Users, Prospective Business Users, Website Visitors, and Job Applicants, PayGlocal acts as a Data Fiduciary, as we determine the purposes and means of processing their Personal Data.

For End-Customers, PayGlocal may act as a Data Processor when facilitating payment transactions on behalf of a Business User in accordance with that Business User's documented instructions; and act as a Data Fiduciary where processing is required to comply with Applicable Laws, card network requirements, fraud prevention and risk monitoring obligations, dispute resolution requirements, or to maintain the security and integrity of the PayGlocal Platform.

Notwithstanding the above, PayGlocal remains independently responsible for complying with regulatory obligations applicable to Payment Aggregators under RBI directives, including in relation to payment system data.

Business Users independently act as Data Fiduciaries in relation to Personal Data they collect and process outside the PayGlocal Platform, including data relating to their commercial relationship with End-Customers.

How We Collect Personal Data

We collect Personal Data in the following ways, depending on the nature of your interaction with us:

Information Provided Directly

We collect Personal Data that you provide to us, including when you submit onboarding applications and verification documents, register for or use our Services, communicate with us through email, support channels, or other correspondence, complete payment forms or transaction flows, or apply for employment opportunities.

Information Collected Automatically

When you access or use the PayGlocal Platform, we may collect some information automatically, including IP address, device information, browser and operating system information, transaction-related metadata, and cookie and similar technology data.

Information from Third Parties

Where necessary and permitted under Applicable Laws, we may collect Personal Data from government authorities and regulatory databases; KYC, KYB, AML, sanctions screening, and fraud prevention service providers; Financial Partners, acquiring banks, and payment networks; Background verification providers and professional references; and publicly available sources (company registries, business directories, news sources, social media where information is publicly posted).

Merchant Responsibility for End-Customer Data

When an End-Customer transacts with a Merchant, the Merchant independently acts as a Data Fiduciary for Personal Data relating to the commercial relationship, including purchase details, shipping information, and customer service. Merchants are responsible for providing their own privacy notices to End-Customers. PayGlocal and Merchants each have independent obligations to protect End-Customer data.

Third-Party Sharing

We share Personal Data with Financial Partners (banks, payment networks, card schemes, acquiring banks, payment processors), Third-Party Service Providers (fraud detection, KYC/KYB verification, identity authentication, cloud infrastructure, analytics, customer communications), regulatory authorities where required by Applicable Laws, and other parties where necessary to provide Services or comply with legal obligations.

All third parties processing Personal Data on our behalf are subject to contractual obligations to protect Your data and process it only for specified purposes. We conduct due diligence and ensure appropriate safeguards are in place before sharing Personal Data.

Across all categories, we use Personal Data to maintain security and prevent fraud, comply with lawful requests from courts and regulators, meet audit and record-keeping requirements, analyze and improve our Services using aggregated or anonymized data where possible, and generate de-identified statistics for business intelligence and reporting that do not identify individuals.

Category-Specific Information

Business Users
Personal Data We Collect

When Business Users use or apply to use the PayGlocal platform, we may collect Personal Data such as:

How We Use This Data

We use and share Business User Personal Data primarily to operate our Services and meet legal obligations, including to onboard and verify Merchants, evaluate applications, verify identity and eligibility, conduct KYC, KYB, AML, and sanctions screening checks, perform due diligence, and assess risk in accordance with RBI requirements; provide and operate Services, enable payment processing, execute settlements and payouts, facilitate reconciliation, manage refunds and chargebacks, support dispute resolution, and provide dashboard and API access; comply with legal obligations, meet KYC, AML, CTF, tax, and financial reporting requirements, respond to lawful requests from regulators and authorities, maintain records as required; and communicate, send service notices, transaction confirmations, settlement notifications, compliance updates, respond to support inquiries.

You are responsible for ensuring that the Personal Data You provide is accurate, complete, and up to date. If Your information changes, You should update it promptly through Your account settings or by contacting us.

How We Share This Data

Merchant Personal Data may be shared with Financial Partners, Third-Party Service Providers (KYC/KYB verification, fraud detection, cloud infrastructure, payment processors), regulatory authorities and government agencies where required, and other parties necessary to fulfill transactions or comply with legal obligations.

Legal Bases

We process Merchant Personal Data on the basis of performance of contract (to provide Services You have contracted for), compliance with legal obligations (RBI requirements, KYC/AML/CTF regulations, tax laws, financial services regulations), and legitimate uses permitted under law (fraud prevention, security, risk management).

End-Customers
Personal Data We Collect

When End-Customers make payments through the PayGlocal Platform, we process transaction details, including transaction amount, currency, date, time, payment method, and transaction status; payment-related information necessary to facilitate the transaction, processed in accordance with Applicable Laws and relevant payment network standards; information entered during checkout or payment flows, including where a transaction is initiated but not completed; identity or verification information where required for fraud prevention or regulatory compliance; and device, technical, and security-related information such as IP address and device identifiers.

Where required under Applicable Laws and regulatory directives, payment system data is stored in India, in accordance with applicable data localisation requirements. Limited transmission outside India may occur for the purpose of routing transactions through international payment networks, in accordance with regulatory requirements.

How We Use This Data

We use and share End-Customer Personal Data primarily to operate our Services and meet legal obligations, including to enable and authenticate payment transactions; process refunds, chargebacks, and disputes; prevent fraud and unauthorised transactions; comply with Applicable Laws, card network rules, and regulatory requirements; and support Business Users in delivering goods or services.

How We Share This Data

End-Customer Personal Data may be shared with the relevant Merchant, Financial Partners (issuing banks, acquiring banks, payment networks, card schemes), Third-Party Service Providers (fraud detection, risk management, payment processors, KYC verification where required, cloud infrastructure), and regulatory or law enforcement authorities where required by Applicable Laws.

Important: PayGlocal processes Your payment information to enable the transaction You have initiated with a Merchant. The Merchant independently determines what goods or services to provide and what information to collect from You beyond payment processing. The Merchant is responsible for providing their own privacy notice. If You have questions about how a Merchant uses Your Personal Data, contact the Merchant directly.

Legal Bases

We process End-Customer Personal Data on the basis of performance of contract (to execute the payment transaction You have initiated), compliance with legal obligations (payment system regulations, card network rules, AML/CTF requirements, data localization requirements), legitimate uses permitted under law (fraud prevention, security, transaction authentication, risk management), and consent where applicable (for saving tokenized credentials or optional features You have chosen).

Leads

We collect limited Personal Data from individuals or businesses expressing interest in PayGlocal through website forms, email, marketing campaigns, events, or referrals. This typically includes basic contact details (name, email, phone number, business name), details relating to the source of the inquiry, and information about the nature of interest.

We use this information to respond to inquiries, provide information about our Services, conduct sales and business development activities where permitted, manage lead qualification, and send marketing communications where You have consented or where permitted. We may share Lead Personal Data with Third-Party Service Providers supporting marketing, communications, or customer relationship management, subject to appropriate safeguards.

We process Lead Personal Data on the basis of consent (where provided), legitimate uses permitted under law (business development, inquiry response), or performance of pre-contractual steps at Your request.

Prospective Business Users

Prospective Business Users are individuals or entities that progress beyond the lead stage and undergo evaluation or verification prior to approval and onboarding.

In addition to basic contact information, we may collect identity, business, and KYC-related information, including government-issued identifiers and business documentation, as required to assess eligibility, risk, and compliance with applicable laws and internal policies.

We use this information to conduct due diligence and verification, evaluate eligibility and make onboarding or rejection decisions, comply with RBI requirements and Applicable Laws (including KYC/AML/CTF requirements), and communicate application status and next steps.

We may share Prospective Merchant Personal Data with KYC/KYB verification providers, government registries, regulatory databases, and credit information companies where permitted, subject to appropriate contractual safeguards.

Where a Prospective Business User is not approved, such data is retained and deleted in accordance with our data retention practices and applicable law.

We process Prospective Merchant Personal Data on the basis of performance of pre-contractual steps at Your request, compliance with legal obligations (KYC/AML/CTF requirements), and legitimate uses permitted under law (risk assessment, fraud prevention).

Website Visitors

When individuals visit or interact with our websites, we may collect device and browser information (IP address, browser type, operating system, device identifiers), browsing activity (pages visited, time spent, links clicked, referral sources), and information submitted through website forms. Some of this information is collected through cookies and similar technologies.

We use this information to operate, maintain, and improve our websites; understand usage trends; enhance security and performance; respond to inquiries submitted through forms; and conduct marketing activities where permitted. We may share Website Visitor Personal Data with Third-Party Service Providers supporting website analytics, hosting, security, and marketing, subject to appropriate safeguards.

We process Website Visitor Personal Data on the basis of consent (where required for cookies or marketing), legitimate uses permitted under law (website operation, security, analytics), or performance of pre-contractual steps where You have submitted an inquiry.

Job Applicants

We collect Personal Data from individuals who apply for employment or engagement with PayGlocal. This may include name, contact details, resumes or CVs, educational background, employment history, professional references, cover letters, responses to application questions, and any other information voluntarily provided. We may also collect assessment information such as interview results, skills assessments, and background check results.

We use Job Applicant Personal Data to evaluate applications, conduct recruitment and hiring processes, communicate with applicants, comply with Applicable Laws relating to employment, and where You have consented, retain Your information for future opportunities. Access is limited to personnel involved in recruitment and related administrative functions. We may share Job Applicant Personal Data with background verification providers and reference check services, subject to appropriate contractual safeguards.

Job Applicant Personal Data is retained and deleted in accordance with our data retention practices and Applicable Laws.

We process Job Applicant Personal Data on the basis of performance of pre-contractual steps at Your request, compliance with legal obligations (employment and tax laws), consent (where provided for future opportunities), and legitimate uses permitted under law (recruitment process management).

Automated Decision-Making

We use automated systems to assess fraud risk, authenticate transactions, detect suspicious activity, and evaluate Merchant applications. Certain real-time payment transactions may be automatically declined where fraud risk thresholds are met, in order to protect End-Customers, Merchants, and the payment ecosystem. However, significant decisions affecting You, including Merchant onboarding approvals or rejections, and transaction declines where manual review is possible, involve human oversight and are not made solely on the basis of automated processing.

Where automated processing significantly affects You, You may request further information, seek human review where applicable, or raise concerns using the contact details provided in the "Contact Us" section of this Policy.

Children's Personal Data

The PayGlocal Platform and Services are not directed to individuals under the age of 18. We do not knowingly collect Personal Data from children. If You are under 18, please do not use the PayGlocal Platform or provide any Personal Data to us. If we become aware that we have collected Personal Data from a child without appropriate consent or legal basis, we will take steps to delete such information.

Merchants must be at least 18 years of age or the age of majority in their jurisdiction, whichever is higher. PayGlocal does not knowingly onboard Merchants under the age of 18.

Legal Bases for Processing Personal Data

PayGlocal processes Personal Data only for lawful purposes and in accordance with Applicable Laws. The legal basis that applies depends on the nature of the Personal Data, the purpose of processing, and the relationship between PayGlocal and the individual concerned. The specific legal bases applicable to each category of individual are identified in the Personal Data We Collect and How We Use and Share It section of this Policy.

More than one legal basis may apply to a single processing activity. Where this is the case, our processing remains lawful as long as at least one applicable legal basis exists.

As a regulated payment aggregator, certain processing activities are required to provide payment services and to comply with legal and regulatory obligations. Under the DPDPA and other Applicable Laws, we rely on one or more of the following legal bases.

Processing Based on Consent

Where required under Applicable Laws, we process Personal Data on the basis of valid, informed and specific consent provided by You. Consent may be obtained directly by PayGlocal or, in applicable payment scenarios, through appropriate interfaces made available by Merchants.

Processing based on consent may include, for example, saving payment methods for future transactions; enabling and managing recurring payments or subscriptions where You have opted in; sending marketing or promotional communications; offering optional features or services that are not necessary to provide the core Services; participation in surveys, events, or promotional activities; and any other processing for which we specifically seek Your consent.

Where PayGlocal processes Personal Data on behalf of a Business User, the Business User is responsible for obtaining any required consent from End-Customers for processing carried out under the Business User's direction.

How to Withdraw Consent

Where processing is based on Your consent, You may withdraw that consent at any time, subject to legal or contractual restrictions, by using any "unsubscribe" or preference management link included in communications or contacting us at privacy@payglocal.in.

Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal and does not affect processing carried out on a different legal basis.

Processing Based on Legitimate Uses Permitted Under Law

We may process Personal Data without consent where such processing qualifies as a legitimate use under the DPDPA or is otherwise permitted by applicable law. This includes the following circumstances:

(a) Compliance With Legal Obligations and Regulatory Requirements

We process Personal Data where necessary to comply with Applicable Laws, regulatory requirements, directions, or lawful orders, including obligations relating to Know Your Customer (KYC) and identity verification as required by RBI guidelines and applicable KYC/AML/CTF regulations; anti-money laundering, counter-terrorism financing, and sanctions screening under the Prevention of Money Laundering Act, 2002 and other Applicable Laws; fraud monitoring, detection, prevention, and reporting, and transaction monitoring; data localisation and payment system regulations; financial record-keeping, audit, tax, and regulatory reporting; and responding to lawful requests, orders, or directions from courts, regulators, law enforcement, or other government authorities.

Such processing is mandatory in nature and may continue for the period required under Applicable Laws. These measures exist not merely to meet regulatory requirements, but because robust verification and monitoring processes are essential to protecting You and all participants in the payment ecosystem from financial crime and fraud.

(b) Processing for Purposes Related to a Contract or Pre-Contractual Request

We process Personal Data where necessary to perform a contract with You, or to take steps at Your request prior to entering into a contract, including evaluating Leads and Prospective Merchants and processing onboarding applications; onboarding and supporting Merchants, including creating and managing accounts and access credentials; processing payments, settlements, refunds, chargebacks, and disputes; delivering customer support and service-related communications; and fulfilling any other obligation arising from our contractual relationship with You.

Such processing is necessary to perform contractual obligations or to take steps at Your request prior to entering into a contract.

(c) Voluntary Disclosure by the Data Principal

Where You have voluntarily provided Personal Data for a specific purpose, and it is reasonable to expect processing for that purpose, we may process such data without separate consent to fulfil that purpose, subject to Applicable Laws.

(d) Other Legitimate Uses as Permitted Under Applicable Law

We may process Personal Data without consent where such processing is otherwise permitted under Applicable Laws, including fraud prevention, risk management, and platform security - monitoring transactions and platform activity to detect, investigate, and prevent fraud, unauthorized access, and misuse, protecting You and all participants in the payment ecosystem from financial harm; service improvement and analytics - analyzing usage patterns and operational data to improve the reliability, security, and quality of our Services, using aggregated or anonymized data where possible; and any other purpose recognised as a legitimate use under Applicable Laws.

Where Personal Data is used for service improvement or analytics, such processing is conducted using aggregated or de-identified data wherever reasonably possible.

Your Data Protection Rights

Depending on where you are located and the data protection laws that apply to you, you may have certain rights in relation to your Personal Data. These rights are subject to applicable legal requirements, limitations, and exceptions. PayGlocal enables the exercise of such rights in accordance with Applicable Laws.

Your Rights May Include
How to Exercise Your Rights

To exercise any of the rights described above, or if You have questions or concerns about how Your Personal Data is processed, You may contact our Data Protection Officer using the details provided in the Data Protection Officer section of this Policy.

We will acknowledge Your request promptly and respond within the timeframe required under Applicable Laws, and in any case within 30 days of receipt, unless an extension is permitted and notified to You. We may take reasonable steps to verify Your identity or the authority of a person making a request before responding, in order to protect Your Personal Data.

Where permitted under Applicable Laws, certain requests may be limited, delayed, or declined. This may occur where fulfilling a request would conflict with our legal or regulatory obligations, affect the rights of other individuals, relate to ongoing investigations or compliance requirements, or involve Personal Data that we are required to retain for financial, security, fraud prevention, or record-keeping purposes. Where we decline a request, we will inform You of the reason to the extent permitted by law.

Protection of Personal Data

PayGlocal implements technical, organisational, and administrative safeguards designed to protect Personal Data against unauthorised access, disclosure, alteration, loss, misuse, or destruction. Our security measures are proportionate to the nature of the data processed, the risks involved, and our obligations under Applicable Laws.

As an RBI-authorised Payment Aggregator, we operate within a regulated environment that requires structured controls over payment system data, transaction monitoring, and information security practices, controls that exist to protect You and every participant in the payment ecosystem.

Our security framework is designed to protect the confidentiality, integrity, and availability of Personal Data and includes, among other things:

Data Encryption and Transmission Controls

Personal Data transmitted over public or private networks is protected using industry-standard encryption protocols. Secure communication channels are used for transaction processing, API integrations, and dashboard access.

Data Storage and Access Controls

Personal Data stored within our systems is protected using encryption, role-based access controls, authentication mechanisms, and logging. Access to Personal Data is restricted to authorised personnel who require it for legitimate purposes and who are bound by confidentiality obligations.

Fraud Prevention and Transaction Monitoring

We operate continuous monitoring and detection systems to identify suspicious activity, prevent fraud, and protect against unauthorised transactions. Certain technical and device-related information is processed as part of these controls to enhance transaction security and protect You from unauthorised use of Your payment credentials.

Organisational and Operational Safeguards

Internal policies and procedures govern the handling, classification, and protection of Personal Data. Personnel with access to Personal Data are trained on data protection and information security requirements appropriate to their role. Third-Party Service Providers processing Personal Data on our behalf are subject to due diligence and contractual obligations requiring appropriate security measures before engagement.

Infrastructure and Resilience

Payment system data is stored and managed in accordance with RBI data localisation requirements, with systems designed for availability, redundancy, and recovery appropriate for regulated payment infrastructure.

While PayGlocal applies rigorous safeguards, no method of internet transmission or electronic storage is entirely immune to risk and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of Your credentials, including passwords, API keys, and authentication mechanisms. If You believe Your account or interaction with the PayGlocal Platform has been compromised, please notify us promptly using the contact details provided in the Contact Us section of this Policy.

Retention and Deletion

We retain Personal Data only for as long as necessary to fulfil the purposes for which it was collected and processed, as described in this Privacy Policy, and to comply with Applicable Laws.

Certain categories of Personal Data are retained in accordance with regulatory requirements, including transaction records and payment system data (retained for the minimum period required under RBI regulations and applicable financial laws); KYC and identity verification records (retained in accordance with Anti-Money Laundering and regulatory retention requirements); account and onboarding records (retained for the duration of the contractual relationship and for a reasonable period thereafter to comply with legal and audit obligations); and marketing data (retained until consent is withdrawn or the data is no longer required for the stated purpose).

Specific retention periods may vary depending on legal, regulatory, and operational requirements. When determining how long to retain Personal Data, we consider the purpose for which the data was collected and used; whether the data is still required to provide our Services; applicable legal, regulatory, tax, accounting, or reporting obligations; and the need to establish, exercise, or defend legal claims or to prevent and detect fraud.

We periodically review the Personal Data we hold and take reasonable steps to delete, anonymise, or securely dispose of data that is no longer required and not subject to retention obligations. Aggregated or de-identified data that does not reasonably permit re-identification may be retained for analytical, security, or operational purposes.

For information about your rights in relation to your Personal Data, including options that may be available to you to request deletion, please refer to the "Your Data Protection Rights" section of this Privacy Policy.

International Data Transfers

PayGlocal operates in India but works with Financial Partners and Third-Party Service Providers that may be located in other jurisdictions. In the course of providing our Services, Personal Data we collect may be transferred to, processed in, or accessed from countries outside India or Your country of residence, including jurisdictions whose data protection laws may differ from those applicable in Your jurisdiction.

We transfer Personal Data across borders only where necessary to facilitate payment transactions, including routing through international payment networks; support fraud detection, risk management, verification, or compliance processes; enable infrastructure, technology, or operational support services; or comply with Applicable Laws or lawful requests from competent authorities.

All international transfers are carried out in accordance with Applicable Laws, including the cross-border transfer provisions under the Digital Personal Data Protection Act, 2023. Where required, PayGlocal implements appropriate safeguards, which may include contractual protections, regulatory-approved mechanisms, or other lawful transfer arrangements recognised under Applicable Laws.

Where the Government of India notifies restrictions or conditions on transfers to specific jurisdictions under the DPDPA, PayGlocal will structure transfers in compliance with such notifications. Where applicable regulatory requirements impose localisation obligations on specific categories of payment system data, such requirements are complied with.

In accordance with directives issued by the Reserve Bank of India, payment system data is stored and maintained in India. Where cross-border transmission is required to facilitate international payment routing, such transmission is structured to ensure that localisation, supervisory access, and audit requirements under Applicable Laws are not compromised.

We apply the same security and data protection standards to Personal Data regardless of where it is processed. For further information regarding international transfers or applicable safeguards, you may contact us using the details provided in the "Contact Us" section of this Policy.

Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our Services, business practices, privacy practices, or Applicable laws. The "Effective date" at the top of this Policy indicates when this Policy was last materially revised.

If we make changes that are material, we will take reasonable steps to notify you, which may include posting a notice on our website or providing notice through other appropriate channels, such as email or your account dashboard.

Updates to this Privacy Policy take effect when the revised version is published. We encourage you to review this Policy periodically to stay informed about how we process and protect Personal Data.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your Personal Data, you may contact us using the details below.

PayGlocal Technologies Private Limited

6048, Prestige Shantiniketan, ITPL Main Road, Whitefield,

Bengaluru, Karnataka – 560048, India

Email: privacy@payglocal.in

You may contact us to request information about how we process Personal Data; exercise your data protection rights under applicable law; or raise privacy-related questions, concerns, or complaints.

We will review and respond to all communications in accordance with applicable data protection laws.

Data Protection Officer

PayGlocal has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with applicable data protection laws and advising on matters relating to the processing of Personal Data.

The Data Protection Officer can be contacted using the same contact details provided above:

Data Protection Officer

Email: privacy@payglocal.in

Location: India

EU and UK Local Representative

Where required under applicable data protection laws, PayGlocal has appointed a local representative in the European Union and the United Kingdom in accordance with Article 27 of the GDPR to act as a point of contact for data protection matters.

The appointed representative may be contacted by individuals and supervisory authorities in the EEA or the UK regarding issues related to the processing of Personal Data under this Privacy Policy. The appointment of a local representative does not affect PayGlocal's responsibility or liability as the data controller.

EU GDPR Representative

If you are located in the European Economic Area (EEA), our EU GDPR Representative is:

Rickert Rechtsanwaltsgesellschaft mbH

(acting as EU representative for PayGlocal Technologies Private Limited)

Colmantstraße 15

53115 Bonn, Germany

Email: art-27-rep-PayGlocal@rickert.law

UK GDPR Representative

If you are located in the United Kingdom (UK), our UK GDPR Representative is:

Rickert Services Ltd UK

(acting as UK representative for PayGlocal Technologies Private Limited)

PO Box 1487

Peterborough

PE1 9XX

United Kingdom

Email: art-27-rep-PayGlocal@rickert-services.uk

You may also contact PayGlocal or its Data Protection Officer directly using the contact details provided in the "Contact Us" and "Data Protection Officer" sections of this Privacy Policy.

For End-Customers (individuals transacting with Business Users), please refer to the privacy policy of the Business User for information regarding their privacy practices, choices, and controls, or contact the Business User directly.

For details on how we handle data during payment processing, see our Privacy Policy for Payments.