Privacy Policy

[“TOPAY” ‚ “we” or “us”] is committed to protecting your information and privacy. This Privacy Policy is designed to help you understand how we may collect, process, store and use the information you provide to us and to assist you in making informed decision while using our Service. This policy is pursuant to the provisions of Rule 4(1) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 as may be amended from time to time.

1. Acceptance of this Policy

You are advised to read this Privacy Policy carefully. By accepting this Privacy Policy and the Terms and Conditions of Use, a User expressly consents to TOPAY collection, storage, use and disclosure of his information as described herein. If you do not feel comfortable with any part of this Privacy Policy or our Terms of Service, you must not use or access our Service or download, install and/or use the mobile application.

2. Applicability of this Policy

This Privacy Policy applies to any information of the user when he access/visits our Sites or uses our Services and does not apply to online platforms or services that TOPAY do not own or control, including platforms or services of third parties. TOPAY privacy policy applies to use of the Platform application, desktop, TOPAY platform and mobile WAP site, API, and all devices, functionalities, features, technologies and other services uniformly and its terms are made a part of these T&Cs by this reference. Additionally, by using our services, the user hereby expressly acknowledges and agree that Internet transmissions are never completely private or secure. The user understands that any message or information he sends to the Platform may be read or intercepted by others, even if there is a special notice that a particular transmission (for example, credit card information) is encrypted.

3. Changes to this Policy

We may revise this Privacy Policy from time to time to reflect changes to our business, the Sites or Services, or applicable laws. The revised Privacy Policy will be effective as of the published effective date. The revised terms will be notified once the user logs in and hence you should review and read the terms and conditions and the privacy policy regularly.

4. Definitions

TOPAY includes its affiliates and subsidiaries, TOPAY Associates shall mean such entities that provide and facilitate services with TOPAY, including banks, acquirers and providers of payment gateways or such other vendors engaged by TOPAY to provide its services.

TOPAY Account/Services means any services and any and all related TOPAY platforms, applications and services offered to you by TOPAY in connection with your TOPAY Account and include such services which may be offered by TOPAY including but not restricted to digital payment solutions, invoice discounting, facilitating business credit and such other services as may be offered by TOPAY from time to time.

Personal Data/Information means personal information that can be associated with an identified or identifiable person. “Personal Data” can include name, postal address (including billing and shipping addresses), telephone number, email address, credit card number, bank account number, other financial account information, financial statements, date of birth, and government-issued credentials (e.g., driver's license number, permanent account number Aadhar Number, passport etc.). Personal Data does not include information that does not identify a specific User.

Process means any method or manner in which we handle Personal Data whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, disseminating or erasure or destruction of Personal Data. Sites means the TOPAY website, mobile applications, official social media platforms, or other online properties through which TOPAY offers the Services and which has posted or linked to this Privacy Policy.

"User": shall mean and include a person who registers himself on the TOPAY platform to transact or avails all or any of TOPAY services this can include an individual resident in India or entity or company registered in India.

5.Information we collect

The user will be required to submit the following information while registering: When the users open a TOPAY account or avails of a TOPAY service or downloads a TOPAY application through a platform, TOPAY shall collect following information as necessary to render our services: - Name, postal address, date of birth, mobile/telephone phone number, email address, PAN, GST, financial information like bank account details, identification information of the user to set up the Account

TOPAY after obtaining the consent of the user at the time of registration also access the following information; device ID for mapping the application to the device on which it is registered, SMS for entering the activation code directly in the application during the activation, details of the browser, operating system, domain name, IP address, mobile application version.

When the user access TOPAY Sites, to process payments, or to send money, TOPAY may collect information about the transaction, as well as other information associated with the transaction such as amount sent or requested, amount paid for products or services, merchant information, including information about any funding instruments used to complete the transaction, Device Information, Technical Usage Data, and Geolocation Information. When the user uses the Services or access the Sites, TOPAY shall collect Personal Data the user provides TOPAY about the other participants associated with the transaction such as name, postal address, telephone number, and financial account information about the payee/payer who is receiving money from the user or sending money to user. This information related to the payee/payer and relating to transaction carried out on the Sites is also collected and stored by TOPAY.

Hence the user should ensure that the user has obtained explicit consent of the payer/payee to share, store, process and use its information as per this Privacy Policy.TOPAY may collect additional information from or about user when the users communicate with TOPAY, contacts our customer support teams or respond to a survey.

By choosing to provide this personal information, a User expressly consents to the transfer and storage of that information on TOPAY / TOPAY Associate servers.

6.Storage of Personal Information

TOPAY shall retain Personal information to fulfil our legal or regulatory obligations and to enable us to provide you seamless services. TOPAY may retain Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If your Account is closed, we may take steps to mask Data and other information, but TOPAY reserves our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Data in accordance with this Privacy Policy, if so required.

7. Use of Personal information

We use personal information for varied reasons:

to provide and improve the services you request

to initiate and complete the transaction and/or settlement as requested;

to authenticate your KYC documents;

to perform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes;

to tailor and customize your experience at our TOPAY platform;

to provide you with content that we think you might be interested in and to display content according to your preferences;

to resolve disputes; troubleshoot problems;

to promote a safe service;

to measure user interest in our services through monitoring, research and also analysis of the user behavior on the Sites;

to inform you on online and offline offers, products, services, and updates;

to detect and protect us against error, fraud and other criminal activity;

to comply with the relevant laws and regulations and enforce the terms and Services;

When a User utilizes the TOPAY platform or sends emails or other data, information or communication to TOPAY or any of its accredited service providers or banks, the User agrees and understands that such information and transaction related data may be communicated through a third-party payment gateway controlled by a TOPAY Associate through electronic records and to the acquirer or the banks. The User expressly consents that such personal information and transaction related data and/or data related to the payer/payee shall be shared to such parties in course of the services provided by us. The User consents to receive communications via electronic records from such TOPAY Associate periodically. Upon registration with TOPAY, a User agrees that he shall be contacted on his mobile or e mail address for authentication of a transaction or from time to time about updating his content to provide features which TOPAY believes may benefit him or for the purpose of receiving promotional messages. A User's information shall remain with TOPAY and TOPAY Associates. TOPAY does not sell or rent your personal information to anyone. The user hereby confirms that he has no objection to aforesaid use of his information

8. Disclosure of Information

TOPAY may in course of rendering its services share Personal Data of the User with third-party service providers, banks, acquirers and payment gateways that perform services and functions at our direction and on our behalf viz including but not limited to processing of the transactions, providing customer support or user behaviour analysis, KYC check etc. TOPAY also use such information to perform statistical analyses of User behaviour and characteristics in order to measure interest in and use of the user. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

TOPAY may also share a User's personal information with any statutory or legal authority as may be required or mandated by that authority. TOPAY may disclose personal information when required, such as to respond to legal requirements, enforce TOPAY policies or protect anyone's rights, property, or safety. Such information will be disclosed in accordance with applicable laws and regulations in good faith. Please note that we are not required to question or contest the validity of any search warrant, subpoena or other similar governmental request that we receive. If required by law to do so or if considered necessary to do so for proper management of credit or business risk, TOPAY reserves the right to disclose any and all such User information, including default in any payments or misuse of the service, to any court of competent jurisdiction, quasi-judicial authority, law enforcement agency, relevant wing of the Central Government or State Government, User's employer, credit reference agency, financial institution or any company which is an affiliate or associate or parent or subsidiary of TOPAY. TOPAY shall not sell or rent a User's personal information to third parties for their marketing purposes without his explicit consent. TOPAY shall comply with the DND regulations as framed and applicable from time to time. TOPAY will only disclose your information in accordance with this Privacy Policy. If there is a requirement to use it for any other purpose, the consent of the user will be obtained.

9. Information security

Our TOPAY platform has stringent security measures in place to protect the loss, misuse, and alteration of the information under our control. Whenever you change or access your account information, we offer the use of a secure server. Once your information is in our possession we adhere to strict security guidelines, protecting it against unauthorized access.

Once your information is in our possession we adhere to strict security guidelines, protecting it against unauthorized access. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current. We are not responsible for protecting any Personal Data that we share with a third-party based on an account connection that you have authorized. The TOPAY platform includes links to other platforms. Such platforms are governed by their respective privacy policies, which are beyond TOPAY control.

Once a User leaves the TOPAY / TOPAY Associate servers, use of any information provided by the User is governed by the privacy policy of the operator of the site which the User is visiting. That policy may differ from this TOPAY policy. All information gathered on the TOPAY platform is securely stored and access to such information is strictly limited based on need-to-know basis. In addition, details of a user’s credit/ debit card number, PIN details for payment or for verification purposes, password and account information are encrypted by TOPAY in accordance with the guidelines laid down by the RBI Standards. Further, TOPAY does not store the CVV number of a User.

10. Disclaimer

You are aware that however as robust and effective as the security measures are, no security system is impenetrable. You hereby acknowledge that the User is aware of all security risks, including possible third-party interception of any of his transactions and statements of account on the internet and the content of his transactions or statements of account becoming known to third parties. The User agrees and undertakes that he shall not hold TOPAY / TOPAY Associates liable therefore in any way. The use and storage of any information, including without limitation, the credit card number, PIN, password, account information, transaction activity, account balances and any other information available on the User's internet access device or computer or mobile phone is at his own risk and responsibility. The User furthermore acknowledges and accepts that TOPAY may not encrypt all content or communications from and to their TOPAY platform

11. Choice of opt in/opt out

We provide all users with the opportunity to opt-out of receiving non-essential (promotional, marketing-related) communications from us on behalf of our partners, and from us in general, after setting up an account. If you want to remove your contact information from all our lists and newsletters, please write to us on


User agrees not to disclose or attempt to use or personally benefit from any non-public information that he may learn on the TOPAY platform or through the Services.

This obligation shall continue until such time as the non-public information has become publicly known through no action of your own. If the User is compelled by order of a court or other governmental or legal body (or have notice that such an order is being sought) to divulge any such non-public information, he agrees to forthwith and diligently notify TOPAY and cooperate fully with TOPAY in protecting such information to the extent possible under applicable law. TOPAY may access, preserve and disclose any of the user's information if required to do so by law, or TOPAY believes in good faith that it is reasonably necessary to (i) respond to claims asserted against TOPAY or to comply with legal process, (ii) for fraud prevention, risk assessment, investigation, customer support, product development and de-bugging purposes, or (iii) protect the rights, property or safety of TOPAY, its Users or members of the public. Please refer to our Privacy Policy for further details.

13. General

The User hereby agrees that the account information and copies of all documents submitted by a User are and shall remain the sole and exclusive property of TOPAY, and TOPAY shall not be obliged to return the same to him upon his request. Any unauthorized access to the TOPAY web-site is a breach of these terms and a violation of the law

A User agrees not to access TOPAY web-sites by any means other than through the interface that is provided by TOPAY for use in accessing the same. Any content that maybe restricted or banned by a government order, will be withdrawn during the pendency of that order.

TOPAY is the sole and absolute owner of all and whatsoever intellectual property rights in the trade mark " TOPAY " and the design in respect thereof. TOPAY will be entitled to take any legal action against any person invading and/or encroaching upon the said rights.

This Policy does not apply to the practices of companies that TOPAY does not own or control, or to people that TOPAY does not employ or manage. If a User has any questions, he may write to TOPAY Customer Support at