https://www.YuvaPay.com/, www.udmatech.com (“our”, “us”, “we”, “Website or Mobile Website”, “YuvaPay”, “YuvaPay’s mobile applications or App or Services”), owned, developed and operated by UDMA Technologies Private Limited, a company incorporated under the Companies Act, 1956 with its registered office at #365/1, 52 Heroor Village Brahmavar Post, Udupi District, Karnataka -576 213 India, is committed to the protection of Information provided by the users (“you”, “your”, “users”) to us. You agree that your use of YuvaPay’s services or our interface implies your consent to the collection and use of your Information in accordance with the terms of this Privacy Policy (“Privacy Policy”).

We take the privacy of our users seriously and that’s why we follow the highest standards for secure transactions. We are committed to safeguarding the privacy of our users while providing a personalized and valuable service. In addition to this Privacy Policy, we have taken the following steps to further safeguard your privacy:

I General

YuvaPay has established a set of “Binding Corporate Rules”. These Binding Corporate Rules are a commitment by YuvaPay to protect your Information regardless of where the data resides. Depending upon where you live, the Binding Corporate Rules may provide additional privacy rights through your local privacy regulator or government. For more information about our Binding Corporate Rules, including information on how to contact us for any clarifications, please write to [email protected]

By visiting our Websites, downloading the YuvaPay app or providing your personal information to one of our call-center operators or live chat representatives or signing up or logging in you are accepting and consenting to the practices described in this policy. Please note that this includes consenting to the processing of any personal information you provide, as described below.

Please review this Privacy Policy carefully. By using our Services, you consent to the use and sharing of your personal information as described in this Privacy Policy. IF YOU DO NOT AGREE WITH THESE PRACTICES, PLEASE DO NOT USE THE SERVICES, OR OTHERWISE PROVIDE US WITH YOUR PERSONAL INFORMATION.

II. Information Collected

A. Traffic Data Collected

We automatically track and collect the following categories of information when you use our Services:

1. IP addresses; 2. Domain servers; 3. Types of computers and Mobile Phones accessing the Website and App; 4. Types of web browsers used to access the Website and App; 5. Referring source which may have sent you to the Website/App; and 6. Other information associated with the interaction of your browser, App and the Website (collectively “Traffic Data”).

B. Information Collected from You

In order for you to access certain areas of the App, we may require you to provide us with certain information (“Personal Information”). Personal Information includes the following information:

1. Your full name, address, e-mail address, telephone number, date of birth and bank or payment card details and any proof of your identity and/or address that we may request; 2. Details of any transactions you carry out through our App using your YuvaPay account and of the fulfillment of your requests; 3. Details of any bank account (including but not limited to, account holder, account name, account number, sort code, online banking PIN, Transaction Authentication Number “TAN” and password, available balance and transaction history of your bank/wallet account), ITR, Tax certificates or any other income documents as necessary by us; 4. Details of any credit, debit or other card used by you for transactions; 5. Your participation in any promotion sponsored by us; 6. Correspondence that you send us; 7. Calls that we make to you or you make to us; 8. Surveys that you complete through the App or based on our request; 9. Information collected through cookies. Please see Paragraph I (Cookies) of this Privacy Policy for more details; 10. Your IP address, log-in times, operating system, device ID and browser type; and 11. Details of your visits to our App are including, but not limited to, Traffic Data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access whilst visiting our App.

In order to fulfill our legal obligations to prevent fraud and money laundering, we will obtain information about you from third party agencies (“Third Party Information”), including your financial history, court judgments and bankruptcies, from credit reference and fraud prevention agencies when you open a Yavapay account and at any time when we feel it is necessary to prevent fraud and minimize our financial risks. Please refer to Paragraph VIII (Anti-Money Laundering Policy) of this Privacy Policy for further details.

Personal Information and Third Party Information are collectively referred to as “Information”.

III. Use and Storage of Information

We use your Information for the following purposes:

1. To operate and administer your YuvaPay account and to provide services that you have requested; 2. To carry out your instructions to make and receive payments and undertake transactions using our services, including verifying that you have sufficient funds in your YuvaPay wallet to make such payments; 3. To allow you to participate in interactive features of the App; 4. To notify you about changes to our Services; 5. To improve our internal customer training, 6. To comply with financial services regulations including retention of financial information and transactions; 7. For financial and identity checks, fraud prevention checks, anti-money laundering and credit checks; 8. For customer service, including answering questions and responding to feedback and complaints; 9. To enhance the security of our Services; 10. To ensure that content on our App is presented in the most effective manner for you and for your mobile; and 11. To provide you with information, products or services that you request from us or which we feel may interest you.

IV. Retention of Data.

We are required under applicable laws to retain certain records for a period of at least 7 (Seven) years after closure of your YuvaPay account, which will include your personal data such as your name, contact details, customer number and transaction history, etc. (“Retained Data”). Other than the Retained Data, we will delete and destroy all Personal Information that we hold about you when you (or we) terminate your YuvaPay account.

1. Please note that we do not store your online banking login PIN and/or password. 2. Please note that we will not store your debit card or credit card information. 3. Please note that we will never ask you to disclose your personal or security details by e-mail. If you receive any e-mail purportedly from YuvaPay requesting your personal or security details, please do not respond to it (“Such E-mail”) and report the same to [email protected]

V. Disclosure of Information

1. We do not disclose your Information to any third parties other than the Yuva pay’s affiliates and the following: 2. a prospective buyer of our business or a buyer of a substantial number of the shares in our business; 3. the police, other lawful enforcement body, regulatory body or court if we are under a duty or required by law to disclose or share your personal data, or to protect the rights, property, or safety of ourselves or our group companies, our customers, or others; 4. Financial institutions with whom we partner to jointly provide better services, facilities or products to you. These financial institutions may only use your information for providing to you their services and market YuvaPay related products without requiring your further consent. 5. Third parties where you have expressed an interest in receiving information about their goods and services; 6. We also use Information in aggregate form (so that no individual user is identified): a) To aid strategic development; b) To audit usage of the App 7. We reserve the right to disclose Information if required to do so by law or if we believe that it is necessary to do so to protect and defend the rights, property or personal safety of the App, or its users.

VI. Fraud Prevention

When you open a YuvaPay account, at intervals of up to every 3 (three) months and at any other time we feel it is necessary to do so to protect our financial interests and prevent money-laundering or fraud, we share certain information about you and your YuvaPay account, financial history and transactions as part of our normal business operations with banks, payment facilitator partners, credit/debit card processing services, identity verification service providers and credit reference agencies (including, but not limited to) to identify and verify users, to limit our exposure to fraud and other criminal activities and to manage our financial risk. When conducting identification or fraud prevention checks, the relevant parties may retain a record of our query along with your information and may share this information with other fraud prevention agencies.

VII. Anti-Money Laundering Policy

In order to comply with anti-money laundering laws that exist in various jurisdictions especially India, we reserve the right to report suspicious transactions to central, state or local authorities and law enforcement agencies within those jurisdictions. In exchange for us permitting you to participate in, use and access our App and services you hereby grant us the right to report any transactions which we deem suspicious, as determined solely by YuvaPay acting in its sole discretion. Examples of a suspicious transaction include but are not limited to use of funds suspected to be derived from illegal activities, any suspected intention to conceal or disguise funds derived from illegal activities, or suspicion that the involvement of our App and services is in any manner intended to facilitate criminal activity. If for any reason we are of the belief or become aware of any transaction which we deem suspicious in nature, we may without prior notice or explanation to you take the following actions, which are in addition to all other rights and remedies available to us under this Privacy Policy, at law or in equity:

1. report such transaction to the applicable central, state, provincial or local authorities and law enforcement agencies; 2. de-activate or terminate your YuvaPay account forthwith; 3. withhold any funds held in your YuvaPay wallet; and/or 4. restrict you from registering a YuvaPay account on or with our App or any of our affiliated websites.

VIII. Communications

1. We may contact you via the e-mail address and phone number registered with your YuvaPay account. You may also receive system-generated transactional e-mails such as confirmations, notification of receipt of payments, notification of password changes etc. which are necessary for the proper operation and administration of your YuvaPay account. You expressly consent to receive such communications from us, irrespective of whether your phone number is registered on the National Do Not Call Registry. 2. As a YuvaPay account holder, you will occasionally receive information by e-mail from us, unless you have expressly chosen not to receive such communication, about products, services and special deals which we think will be of interest to you via our newsletter. You can change whether or not you receive newsletters from us. However please note that you will still receive communication regarding your YuvaPay account such as transactional e-mails or other notifications affecting the operation of your YuvaPay account or our legal relationship.

IX. Links to Our Website and to Other Websites

1. Our App and/or Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own terms of use and privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. Please also note that the products and services offered on these websites may be limited to persons located or residing in only that particular jurisdiction. In addition, the content on these linked websites may not be intended for persons located or residing in jurisdictions that restrict the distribution of such content.

X. Cookies

1. “Cookies” are small computer or mobile files that are transferred to your mobile’s hard drive that contain information such as user ID, user preferences, lists of pages visited and activities conducted while browsing the App. At your option, expense and responsibility, you may block cookies or delete cookies from your hard drive of your computer or mobile phone. However, by disabling cookies, you may not have access to the entire set of features of the App. 2. Generally, we use Cookies to customize your experience on our App and to store your password so you do not have to re-enter it each time you visit the App. 3. In addition, our business partners may use Cookies to provide us with anonymous data and information regarding the use of our App. Specifically, some of our business partners use Cookies to show the App’s ads on other websites on the internet as a result of you using the App. Such Cookies do not contain any Information. You may opt out of receiving Cookies placed by such third party vendors by visiting the opt-out page or please click on the unsubscribe button on the mailers. 4. Other Cookies used by our business partners may collect other non-personally identifying information, such as the Mobile or computer’s IP address, type of operating system, type of internet browsing software, what web pages were viewed at what time, the geographic location of your internet service provider and demographic information, such as gender and age range. This information is used to provide the App with more information about our user’s demographics and internet behaviors. You may find out more about the information collected and how to opt-out of receiving these Cookies by visiting our partner’s website. 5. We do not link the information stored in these Cookies directly to any of your Information you submit while on the App. 6. In order to comply with legislation, we have reviewed the use of Cookies on our App and set out the information below. This is to ensure that you are aware of these cookies and are able to give your consent for the placing of some or all of these cookies on your device when you use our App. In summary, we use the following types of cookies:

a) Strictly Necessary Cookies

These are cookies which are essential for our App to operate such as those which identify you so you can log into your YuvaPay account. They allow you to move around our App and use the services you have requested. These Cookies will be activated when you enter our App and as you use our App.

b) Compliance Cookies

These include Cookies which are necessary to assist in meeting our regulatory compliance obligations, such as anti-money laundering and anti-fraud obligations, and prevent your YuvaPay account from being hijacked. These cookies will be activated when you enter our App and as you use our App.

c) Performance Cookies

These are Cookies that help us to improve how our App works and to deliver a better service to you. For example, they will assess which pages you visit most often or if you get an error message. They also allow us to see if you have used the App of one of our group or affiliated companies. All information collected by these Cookies is aggregated and is therefore anonymous.

d) Functionality Cookies

These Cookies allow us to deliver a more personalized service to you and allow our App to remember choices you have made such as the language you prefer or the region you are in. They may also be used to provide services you have requested such as being able to comment on one of our blogs.

e) Third Party Cookies

When you visit a page on our Website or App with content embedded from third parties, for example, YouTube or Twitter, Cookies may be downloaded onto your device. We do not set or control these Cookies. If you are concerned about the types of Cookies that may be downloaded you check the third party websites for more information about these Cookies.

We may use other Cookies from time to time in accordance with this Privacy Policy. By using our App and other online services, you acknowledge that we may use some or all of the Cookies set out in this Privacy Policy and you agree that we can place performance and functionality Cookies on your mobile device when you use our App. If you do not agree to this you should cease using our App and online services.

f) Blocking Cookies

Should you want to continue using our services but restrict our use of Cookies, you can block Cookies by activating the setting on your App which allows you to refuse the setting of all or some cookies. However, if you use your App settings to block all Cookies (including Strictly Necessary and/or Compliance Cookies, as described above) you may not be able to access all or parts of our App. Our App may issue some of the Cookies described above as soon as you visit our App unless you have adjusted your App setting so that it will refuse Cookies.

XI. App Analytics

We may use third party analytics services in connection with the App. These App analytics services do not collect information that you do not voluntarily enter into the App. We are using the information collected from these services to find usability problems to make the App easier to use. The recordings will never identify you or your account.

XII. Security Checks, Review and Releases

To maintain a high level of security, we reserve the right to conduct a security review at any time to validate your identity, verify your financial transactions and further document your consent to this Agreement. To facilitate these security checks, you agree to provide such identification or other information or documentation as we, in our sole and unfettered discretion, deem necessary. If you fail to comply with any security request, we reserve the right to void your YuvaPay account. You will be notified of such verification request by e-mail or telephone and your YuvaPay account balances will be forfeited if you fail to provide us with such requested documentation and information within the time period reasonably specified by us. Such request for documentation and information may include a sworn affidavit of identity and eligibility, release of liability in favor of us and publicity authorization.

XIII. User Choice

You may choose not to provide us with any Information while accessing the App. In such an event, you can still access much of the App; however you will not be able to access and use those portions of the App that require your Information.

XIV. Confidentiality and Security

Except as otherwise provided in this Privacy Policy, we will keep your Information private and will not share it with third parties, unless we believe in good faith that disclosure of your Information or any other information we collect about you is necessary to:

1. comply with a court order or other legal process; 2. Protect the rights, property or safety of YuvaPay or another party. 3. Enforce our Terms and Conditions or 4. Respond to claims that any posting or other content violates the rights of third parties.

XV. Security

We are committed to ensuring that your Information is secure. To prevent unauthorized access or disclosure of Information we have physical, electronic and managerial procedures in place to keep your information safe. Once logged into your YuvaPay account, all internet communication is secured using Transport Layer Security (TLS) technology and the connection is encrypted and authenticated. However, this high level of protection can only be effective if you follow certain security practices yourself. You must never share your YuvaPay account or login details with anyone. If you are concerned that any of your login details have been compromised, you can change them any time once you are logged on. Although we make good faith efforts to store Information in a secure operating environment that is not open to the public, you should understand that there is no such thing as complete security, and we do not guarantee that there will be no unintended disclosures of your Information. If we become aware that your Information has been disclosed in a manner not in accordance with this Privacy Policy, we will use reasonable efforts to notify you of the nature and extent of the disclosure (to the extent we know that information) as soon as reasonably possible and as permitted by law.

XVI. Updates and Changes to Privacy Policy

We reserve the right, at any time, to add to, change, update, or modify this Privacy Policy so please review it frequently. If we do, then we will notify you by posting a notice on our App and, where appropriate, a link to the modified policy so that you can review it. In all cases, use of Information we collect is subject to the Privacy Policy in effect at the time such information is collected.

XVII. Restriction of Liability

1. We make no claims, promises or guarantees about the accuracy, completeness, or adequacy of the contents of the App and expressly disclaim liability for errors and omissions in the contents of the App. 2. No warranty of any kind, implied, expressed or statutory, including but not limited to the warranties of non-infringement of third party rights, title, merchantability, fitness for a particular purpose and freedom from virus, is given with respect to the contents of the App or its hyperlinks to other internet resources. 3. Reference in the App to any specific commercial products, processes, or services, or the use of any trade, firm or corporation name is for the information and convenience of the public, and does not constitute endorsement, recommendation, or favoring by us. 4. The contents of the App are under copyright of their original author(s) unless otherwise noted on the page itself.