DATA PROTECTION, PRIVACY, DATA RETENTION & RECORD-KEEPING POLICY
POLICY NO. 08 | VERSION 1.0
EFFECTIVE DATE: 29 SEPTEMBER 2026
| Document Control | Details |
|---|---|
| Legal Entity | FINZOOPAY SOLUTIONS LLP |
| LLPIN | ACY-8385 |
| Address | 0, Pal Katara, Sainik Chauraha, Ghazipur, Ghazipur Kotwali Police Station, Ghazipur – 233001, Uttar Pradesh, India |
| Website | finzoopay.com |
| Business Scope | Digital payment / gift card / gift voucher and related technology or transaction services, as applicable |
| Policy Owner | Management / Compliance / Legal / Information Security / Operations |
| Review Frequency | At least annually and after material privacy, security, legal or business changes |
| Classification | Confidential – Data Protection, Privacy, Retention & Record-Keeping Policy |
This Policy establishes the framework for responsible collection, use, access, protection, retention, disclosure and secure disposal of personal, customer, transaction, financial, business and security information handled by FINZOOPAY SOLUTIONS LLP.
This Policy applies to personal data, customer information, transaction records, payment information, voucher records, employee information, partner information, business records, logs, communications and other information processed by the Company or on its behalf.
Management shall assign appropriate ownership for privacy, information security, records and data management. Data owners shall define access, retention and protection requirements appropriate to information sensitivity.
The Company shall collect information that is relevant and reasonably necessary for legitimate business, contractual, security, transaction, compliance or other authorised purposes.
Personal and confidential information shall be used only for stated or otherwise lawful purposes and shall not be used in ways inconsistent with applicable requirements or the Company's documented business purposes.
Reasonable measures shall be taken to maintain accurate and relevant information. Where errors are identified, appropriate correction or updating processes shall be followed.
Access to personal and confidential information shall be granted on a need-to-know and least-privilege basis. Access shall be reviewed periodically and removed when no longer required.
Information may be shared with authorised employees, service providers, payment partners, banks, processors, regulators, law-enforcement agencies or other parties where necessary for legitimate business purposes, contractual obligations, legal requirements or authorised services, subject to appropriate controls.
Where data is processed by third parties or transferred across jurisdictions, the Company shall consider applicable legal requirements, contractual safeguards, security measures and vendor risk.
Where applicable, individuals may have rights relating to access, correction, deletion, consent withdrawal, grievance or other data rights. Requests shall be handled through designated processes subject to applicable law and lawful exceptions.
Where required, the Company shall provide appropriate privacy information describing relevant data collection, purposes, sharing, retention, security and applicable rights.
Where consent is required, it shall be obtained through an appropriate mechanism. Other lawful bases may be used where permitted by applicable law.
Information shall be retained only for as long as necessary for the relevant purpose, legal or regulatory requirements, contractual obligations, dispute management, security, audit or other legitimate requirements.
Records shall be maintained in a manner that supports accuracy, integrity, accessibility to authorised personnel, traceability and appropriate auditability.
When retention requirements expire, information shall be securely deleted, destroyed, anonymised or otherwise rendered appropriately inaccessible, subject to legal holds or continuing lawful retention requirements.
Where information is relevant to litigation, investigation, regulatory review, fraud investigation or other legal process, disposal shall be suspended to the extent required and the relevant information shall be preserved.
Suspected loss, unauthorised access, disclosure or compromise of personal or confidential information shall be escalated under the Company's Cyber Incident Response & Cyber Fraud Management Policy.
Vendors processing personal or confidential information shall be subject to appropriate due diligence, contractual requirements, security controls, confidentiality obligations and monitoring based on risk.
Requests concerning personal information shall be logged, verified as appropriate, assessed under applicable requirements and responded to within applicable timelines.
Records shall be protected against unauthorised alteration or deletion. Material changes to records shall be traceable where appropriate.
Systems containing sensitive information should maintain appropriate access logs or audit trails proportionate to risk and system capability.
Relevant personnel shall receive periodic awareness on privacy, confidentiality, data security, records management and incident reporting appropriate to their responsibilities.
Exceptions shall be documented, risk-assessed and approved by authorised management. Mandatory legal, regulatory or contractual requirements shall not be overridden.
| Function | Responsibility | Escalation |
|---|---|---|
| Management | Data governance, resources and material risk decisions | Authorised Management |
| Compliance / Legal | Privacy, legal, contractual and regulatory requirements | Compliance/Legal Lead |
| Information Security / Technology | Security controls, access, logging, backup and incident response | Security/Technology Lead |
| Operations | Record processes, customer requests and operational controls | Operations Lead |
| Finance | Financial and transaction record retention | Finance Lead |
| Vendor Management | Third-party data-processing controls | Vendor Owner |
| HR / Administration | Employee and administrative records | Designated Management |
This Policy shall be reviewed at least annually and after material privacy incidents, significant technology or business changes, changes in data-processing activities or applicable requirements.
| Role | Name / Designation | Signature / Date |
|---|---|---|
| Prepared By | Compliance / Legal / Information Security / Operations | |
| Reviewed By | Technology / Finance / Risk | |
| Approved By | Authorised Partner / Designated Management |