PRIVACY POLICY

Effective from January 07, 2025

1. PURPOSE AND APPLICATION

This Privacy Policy (“Policy”), as defined herein explains how Moopay Private Limited (hereinafter  referred to as “We” and/or “Us” and/or “Our” and/or “Company” and/or “Moopay”) collects, uses,  stores, discloses or otherwise processes “Information” (as defined in this Policy) from its  users/customers (“User(s)” and/or “Customer(s)” and/or “You” and/or “Your”) using its  applications and/or accessing its website in the name and style of www.moopay.in (the “Website”).  This Policy also describes the rights that the Customers and Users have with respect to their  Information.  

We request You to read this Policy carefully before using the Website or any of Our applications. If  You do not agree with the terms of this Policy, do not use the Website or avail any of the services  offered by Us including usage or access of Our applications. By using the Website/applications, You  signify Your acceptance to the terms of this Policy and agree to be legally bound by the same.  Whenever You submit Information via the Website or Our applications, You explicitly consent to the  collection, use, store and disclosure of the Information in accordance with this Policy.  

We do not provide services to children. If You are under the age of 18 years, you may visit the Website  and use Our applications only under the guidance and responsibility of a parent or guardian who is  above 18 years. In such cases, while we will not store the data of children, the data of parent/  guardian will be treated similar to as if the parent/ guardian is accessing our Website/ application.  

We shall collect, use, distribute, process and store Your Information in accordance with the  Information Technology Act, 2000, as amended from time to time (“Act”) and the  Information Technology (Reasonable Security Practices and Procedures and Sensitive  Personal Data or Information) Rules, 2011, as amended from time to time (“Rules”).  

We shall protect the Information by using a reasonable degree of care, to prevent the unauthorized  use, dissemination, or publication of such Information. We will not disclose the Information to any  person without the relevant User’s/Customer’s consent and limit dissemination of “Confidential  Business Information” (as defined in this Policy) only to Customer’s employees or agents  nominated by Customer having a “need to know”.  

We respect and value Your privacy and shall strive towards protecting the Information that You  provide. We shall keep the Information provided to Us as confidential and secure, as required under  the applicable laws.

2. ABOUT MOOPAY PRIVATE LIMITED

Moopay Private Limited having its registered offices at Bengaluru, India is engaged in the fintech  business activities and to act in various roles such as business correspondent, outsourcing partner,  service provider, data provider, program manager, partner, customer to various banks, financial  institutions and other players in the finance and dairy ecosystem.

3. DEFINITION

  • Confidential Business Information means the confidential information or data collected  from our Customers and dairy farmers through Our applications or mobile phones and which  may include details including names and contact information of the dairy farmers; quantum of  milk collected, banking information, details of livestock etc.
    However, such Confidential Business Information does not include information which: (i) is or  becomes a part of the public domain (ii) was in Our possession prior to Our arrangement with  the relevant Customer; (iii) is obtained by Us in good faith from a third party having the right to  disclose such information without an obligation of confidentiality; or (iv) is independently  acquired or developed by Us (and can be shown by records) without breaching any of its  obligations under this Policy.  
  • Cookies means small text files that are downloaded on the computer while visiting a website.  The Cookie helps the website recognize a device for their next visit. They are widely used in order  to make websites work, or work more efficiently, as well as to provide information to the owners  of the website.   
  •  Force Majeure Event shall mean any event that is beyond Our reasonable control and shall  include, without limitation, fire, flood, explosion, acts of God, civil commotion, strikes,  insurrection, war, acts of government, pandemic, epidemic, embargo, computer hacking,  software failure including unauthorized access by third parties, storage device and computer  crashes etc.  
  • Information collectively refers to the Confidential Business Information, Personal  Information and Sensitive Personal Information in this Policy which is collected from third  parties (including Customers, vendors, etc.) and through use of Website, applications, Cookies  or other similar tools. 
  •  Personal Information means 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 Moopay is capable of identifying such person. Examples include first name, last name,  mobile number, email address, Ip address, etc. 
  •  Process or Processing in relation to Information, means an operation or set of operations  performed on Information, and may include operations such as collection, recording,  organization, structuring, analysis, evaluation, segregation, storage, adaptation, alteration,  retrieval, use, alignment or combination, indexing, disclosure by transmission, dissemination or  otherwise making available, restriction, erasure or destruction. 
  • Policy refers to this Privacy Policy. 
  • Sensitive Personal Information of a person means such personal information which  consists of information relating to; (i) password; (ii) financial information such as Bank account  or credit card or debit card or other payment instrument details; (iii) physical, physiological and  mental health condition; (iv) sexual orientation; (v) medical records and history; (vi) Biometric  information; (vii) any detail relating to the above clauses as provided to Moopay for providing  service.
    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.  
  • User/Customer means the natural person to whom the Information relates.

Website means www.moopay.in 

ANY CAPITALIZED WORDS USED HENCEFORTH SHALL HAVE THE MEANING ACCORDED  TO THEM UNDER THIS POLICY.

4. COLLECTION OF INFORMATION

For the purposes of effective functioning of the Company’s application(s), We may collect and store  Confidential Business Information from You, which includes but shall not be limited to:  

  • Details of Your interactions with farmers, agents, animals, extension staff etc., including but  not limited to their names and contact details;  
  • Details of the quantum of milk or other dairy products;  
  • Details of the livestock and infrastructure available; and  
  • Payment terms agreed  

The Personal Information and Sensitive Personal Information You may provide to Us, includes and  that We may use are as follows:  

  • Personal details, such as usernames provided by You for which We use reasonable security  measures for password protection from anyone;  
  • Your usage of the Website and Our applications;  
  • The details of the computer system, mobile phone, or computer network that You use to visit  the Website or towards Our applications or any activities undertaken through the usage of  the Website;  
  • Your first, middle and last name, e-mail address, phone number, copy of PAN, Voter ID, etc.;  and  
  • Sensitive Personal Information like a copy of Aadhar, password, bank account details,  annual income, credit card or debit card details, etc.  

We also collect and store an activity log unique to You that collects certain administrative and traffic  information including without limitation source IP address, time of access, date of access, web  page(s) visited, language use, Website and Our applications crash reports, type of browser used, the  technical operation of the Website and Our applications, and any information required to ensure  Your use of the Website and any of Our applications are compliant with the applicable laws.

5. PROCESSING THE INFORMATION

The Company may process Your Information where such relevant Information is required to be  Processed for the following, but not limited to, the Company’s purposes:  

  • The fundamental reason behind collecting Your Information is to support and facilitate Your  effective use of various features and services as provided on Our Website and applications.
  • We use the Information for enhanced behaviour of our applications, and Your user  experience.  
  • We also use the Information to be able to provide value added services to the dairies,  farmers, agents, Customers, vendors, extension staff, financial and insurance institutions,  banks etc. We select and track Your preferences to provide You with a customized  experience, to notify You of any updated information and new developments/features and  other related functions offered by our applications and Website, to otherwise support Your  relationship with Us and to prevent fraud and unlawful use. 

It is Our policy to limit the Information collected to only the essential Information required to offer  the services effectively and efficiently and cater to the requirements of the emerging needs of the  various stakeholders in the dairy ecosystem and also to develop the digital access network to digitize  the dairy supply chain and enable financial inclusion of the dairy farmers.  

By accepting the terms of this Policy, You understand, agree and recognize that Our storage and  processing of Your Information is for a purpose associated with a function or an activity of the  Website and business of the Company. You further understand, agree and acknowledge that You may be required to provide Information that is classified as “Sensitive Personal Information” as per  applicable laws for Us to provide various services.  

Please note that, it is entirely up to the discretion of the user to provide this information.

6. DISCLOSURE OF INFORMATION

We do not sell, trade or rent Your Information to any third party, unless We have been expressly  authorized by You either in writing or electronically to do so.  

We may disclose Your Information solely in the legitimate conduct of the business to deliver services  to meet Your demands and offer you the services. We may use a range of service providers and  contractors to help us maximize the quality and efficiency of our services and our business  operations. This means that third-party individuals and organizations may sometimes have access  to Information held by the Company and may collect it for process or use it on behalf of the Company.  For this reason, You hereby agree that for every authorization which You grant to us in this Policy,  You also grant to any third party that we may hire or enter into a contract with for conducting our  business and for providing You the services. We require our service providers and contractors (third 

party individuals and organizations) to ensure at least the same level of data protection (if not more)  that is adhered by Us and be under appropriate confidentiality requirements, maintain adequate  technical and network security and not to use or disclose such information for any unauthorized  purposes. 

We may share Your Information within the organization, in order to facilitate the provision of  services in connection with Your use of Our Website or Your membership to Our network of  Website or applications. We may also release information when We believe, in good faith, that such  release is reasonably necessary to (1) comply with legal or regulatory requirements; (2) enforce or  apply terms of use of our Website; (3) enforce or apply terms of use of Our applications; or (4) protect  Our rights, property or safety of the rights of others.  

In case the Company is merged with or acquired by another business entity, it will be required to  transfer all Your Information to such merging or acquiring entity. In such a case, the Company will  take all reasonable efforts to make sure that the Information is protected by the merging or acquiring  entity, in conformity with applicable laws.  

All payments for the services availed on the Website and towards the usage of our applications shall  be made on the secured payment gateway or by other agreed mode(s). We shall use necessary  measures to protect the payment gateway from any unauthorized use, however, We shall not be  responsible for any such use which is beyond our reasonable control or which may result in a “Force  Majeure Event” (as defined in this Policy).

7. RIGHTS OF THE USERS/CUSTOMERS

  • You have the right to review the Information provided by You and correct or amend such  Information, if necessary.  
  • You have the right to withdraw Your consent to the use of Your Information by Us and also the  right to get Your Information erased/deleted which will lead to the User not being able to avail  services from Us. The erasure/deletion of Information is subject to Us retaining the Information  for as long as required under applicable law.  
  • You have the right of data portability. Data portability is the ability to obtain some of Your  Information in a format You can move from one service provider to another. Depending on the  context, You may also be entitled to request copies of Information that You have provided to us  in a structured, commonly used, and machine-readable format and/or request us to transmit  this Information to another service provider (where technically feasible). 

For exercising any of the above-mentioned rights, you can contact Us via e-mail on  outreach@moopay.in

8. CAREERS

If You apply for jobs through the Website, You accept that the application will be processed by the  Company. The Company will use the Information supplied by the applicants for the purpose of  processing the application. The applicant shall have the right to consult their Information, to correct  the Information, if necessary, and to withdraw their consent to the use of their Information.

9. RETENTION OF YOUR INFORMATION

The Company will retain Your Information only for as long as is necessary for the purposes set out  in this Policy. We will retain and use Your Information to the extent necessary to comply with our  legal obligations (for example, if we are required to retain your data to comply with applicable laws),  resolve disputes, and enforce our legal agreements and policies.

10. LEGAL COMPLIANCE

We abide by all the applicable laws in force as well as the mandates of government agencies. We will  disclose any Information about You to government or law enforcement officials that We, in Our sole  discretion, believe necessary or appropriate to respond to claims and legal processes, to protect the  property and rights of the Company or a third party, to protect the safety of the public or any person,  or to prevent or stop any illegal, unethical or legally fraudulent activity. We may also provide Your  Information to various regulatory authorities upon any demand or request from them.  

We may provide Your Information, in connection with a merger, acquisition, reorganization or sale  of assets or in the event of insolvency or bankruptcy of the Company.

11. SECURITY

In compliance to Our Information Security Policy, we adopt reasonable security measures including  those as required under the applicable laws to ensure adequate security of Your Information.  

We strive to work towards the security, integrity and privacy of Your Information and to protect Your  Information against unauthorized disclosure, access or destruction to the extent reasonably possible  by Us. Notwithstanding anything contained in this Policy or elsewhere, We shall not be held  responsible for any loss, damage, breach of security or misuse of Your Information, if such loss,  damage or misuse takes place as a result of a Force Majeure Event. Further, if the Company believes  that the harm is grievous in nature which is likely to result in a risk to Your rights and freedoms, We  will notify You of such breach of security or safety of Your Information as soon as We have had a  chance to review the nature and extent of such breach.

12. LINKS TO OTHER SITES

The Website and Our applications may provide third party content and links to other websites. We  do not provide Your Information to these third-party websites unless mandated under any applicable  laws at that time.  

The links to other websites are operated by third parties and are not controlled by, or affiliated to, or  associated with Us unless expressly specified on the Website and Our applications. Therefore, We do  not make any claims concerning the privacy practices or policies of such third parties or terms of use of such websites, nor do We control or guarantee or endorse the accuracy, integrity, or quality of the  information available on such websites. Any information provided by You to such third-party  websites shall be governed in accordance with the privacy policies of the respective websites and it  is strongly recommended that You review the privacy policy on any such websites prior to using such  websites.

13. PHISHING

Identity theft and the fraudulent practice currently known as “phishing” are of great concern to Us.  Phishing is an attempt to acquire personal/sensitive information which the legitimate organization  already has. Safeguarding information to help protect You from identity theft is a top priority. We  do not and will not, at any time, request Your credit card information or national identification  numbers in a non-secure or unsolicited e-mail or telephone communication.

14. COOKIES

The Company uses Cookies across its Website to improve performance and enhance the experience.  Cookies can be used for a variety of purposes such as remembering your preference, measuring your  activity and optimizing your user experience.  

Usage of Cookies  

When consulting the Website, Cookies may get placed on Your computer, mobile or tablet. Cookies  could contain the following data:  

  • Information about the browser; an identifier, in the form of a unique identification number.
  • An expiration date (some Cookies only)  

Cookies used by the Company and its purposes:  

Following are the Cookies we use and why:  

  • Google Analytics (utma; utmb; utmc; utmz)These Cookies are used to collect information about how visitors use Our Site. We use the  information to compile reports and to help us improve the site. The Cookies collect information  in an anonymous form, including the number of visitors to the site, where visitors have come to  the site from and the pages they visited.  

Purpose for which Cookies are used includes but not limited to:  

Generally, Cookies perform the following functions:  

  • Enabling our Website to function properly –Some Cookies are essential for the functioning of our Website. For example, Cookies ensure  that you are shown the correct webpages for your location, or to identify when we have a  broken link or technical issue with the Website.  
  • Analyzing visitor’s behavior –We may use Cookies to analyze how Our visitors use our Website and to monitor Website  performance. This allows Us to provide a high-quality experience by making sure that Our  content and layout remains relevant to You. For example, Cookies to keep track of which  pages and links are most popular and which are not providing the information that’s  required by Our visitors. 
  • Optimizing and personalizing –Cookies are used to optimize the webpages that You visit and to personalize the content that  is shown to You across all our digital assets, based on Our understanding of Your  requirement.  

Manage your Cookies  

You can control whether to accept Cookies or not. If You decide to not accept Cookies, some features  and services on Our Website will not function properly.  

If You prefer not to accept Cookies, You can either:  

  • Change Your browser setting to notify when You receive a Cookie, which gives You the  discretion to choose whether or not to accept it; or  
  • Set Your browser to automatically not accept any Cookies. You can manage Cookies in the  privacy settings of the web browser You are using. Please keep in mind that if You use Your  browser settings to block all the Cookies, You may not be able to access parts of Our Website  or others’ website.  

You can modify the Cookies setting by the links provided below. These links will guide You through  the process of modifying Your browser settings:  

15. CONTACT US

If You have any questions about this Policy, the practices of the Company or Your dealings with the  Website/application, You can contact Us via email on: outreach@moopay.in

16. GRIEVACE OFFICER

Please find below the details of the Grievance Officer:  

Name: Mr. Ganesh Nagarajan 

E-mail: outreach@moopay.in 

If You wish to make a complaint regarding any violation of the provisions of the Policy, You may  send a written complaint to the Grievance Officer, who shall redress the complaint in accordance  with the provisions of the Information Technology Act, 2000 and Rules made thereunder

17. GOVERNING LAW

Please be informed that any proceedings arising out of or relating to Your use of this  Website/application, its content and services will be subject to the laws of India and the state of  Karnataka and the courts in Bengaluru shall have exclusive jurisdiction.

18. MODIFICATIONS

The Company reserves the right to modify or amend this Policy at any time with or without notice  for legal, administrative and technical reasons. It is important that You review the Privacy Policy for  updates. The effective date will be displayed at the beginning of this Policy.