1. Introduction

This Privacy Policy describes how AeronPay collects, stores, uses, and protects your Personal Information when you access our services, applications, websites, or interact with us in any way (hereinafter referred to as the "Platform"). By using the AeronPay Platform, you agree to this Privacy Policy and its terms.

This Privacy Policy complies with applicable Indian laws, including the Information Technology Act, 2000, and the rules framed thereunder, such as the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the Aadhaar Act, 2016.

2. Information Collection

We may collect your Personal Information when you use our services or Platform or otherwise interact with us during our relationship. We collect Personal Information that is relevant and necessary for providing the services requested by you and to continually improve the AeronPay Platform.

2.1 Personal and Sensitive Personal Information Collected

Personal and Sensitive Personal Information collected, as applicable, includes, but is not limited to:

• Name, Phone Number and E-mail ID.
• KYC-related information such as PAN, income details, your business-related information, or other online/offline verification documents as mandated by relevant regulatory authorities.
• Aadhaar information, including Aadhaar number, for e-KYC authentication with the Unique Identification Authority of India (UIDAI).
• OTP sent to you by your bank, NSDL, or AeronPay.
• Device details such as device identifier, internet bandwidth, mobile device model, browser/AeronPay Applications, plug-ins, time spent, IP address, and location.

2.2 Stages of Information Collection

Information may be collected at various stages of your usage of the AeronPay Platform such as:

• Visiting the AeronPay Platform.
• Registering on the AeronPay Platform as a “user” or “merchant” or any other relationship that may be governed by terms and conditions listed on the AeronPay Platform.
• Transacting or attempting to transact on the AeronPay Platform.
• Accessing links, e-mails, chat conversations, feedbacks, and notifications sent or owned by AeronPay Platform, and if you opt to participate in our occasional surveys.
• Otherwise dealing with any of the AeronPay Entities/Subsidiaries.
• While applying for career opportunities with AeronPay.

2.3 Collecting the Contact List

We collect your contact list for the following use cases:

• Mobile Recharge directly from your contact list for ease of use (App Functionality).
• UPI Payments towards listed contacts for seamless transactions.
• Note: We do not store your contacts on our servers. This access is solely for your Recharge, Bill Payments, and UPI Payment experience.
• This permission is mandatory to use the Mobile App and is taken with your explicit consent.

2.4 Collecting Images/Photos

We may request camera and image permissions for the following purposes:

• To enable seamless Scan & Pay functionality and UPI Payment experience.
• To capture or upload images for Live KYC Verification as mandated by relevant regulatory authorities.
• Note: These permissions are mandatory to use the Mobile App and are taken with your explicit consent.

2.5 Important Note

Image/Photo uploads, Contact List access, Location Permissions, and Camera Permissions in the mobile app are taken only after obtaining explicit customer consent. Prominent disclosure is provided when new or existing users install and open the app for the first time.

3. Purpose of Information Collection

We use your information for the following purposes:

• To create and manage your account on the AeronPay Platform.
• To process transactions and fulfill your service requests.
• To comply with KYC/AML regulations and other legal obligations.
• To improve and personalize your experience on the Platform.
• To detect and prevent fraud, unauthorized transactions, or security breaches.
• To provide customer support and respond to queries or complaints.
• To send notifications, updates, and marketing communications (with your consent).

4. Information Sharing and Disclosure

We do not sell or rent your personal information. However, we may share your information with third parties under the following circumstances:

• With regulatory or government authorities to comply with legal obligations.
• With service providers and partners who assist us in delivering our services (e.g., payment gateways, KYC verification providers).
• In case of mergers, acquisitions, or business transfers.
• To enforce our terms and conditions or protect our rights.
• With your explicit consent for specific purposes.

5. Storage and Retention of Data

AeronPay retains customer data (personal details, ID documents, contact information) for 5 years after account closure, while transaction data, financial records, and legal/compliance documents are stored for 10 years to meet legal, regulatory, and business requirements. All data is securely stored with encryption, access controls, and regular security audits, ensuring compliance through periodic reviews. Data exceeding its retention period is securely deleted or anonymized to prevent unauthorized access or reconstruction.