POLICY NO. 07 | VERSION 1.0
EFFECTIVE DATE: 29 SEPTEMBER 2026
| 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 / Vendor Management / Compliance / Risk / Technology |
| Review Frequency | At least annually and based on vendor criticality, incidents or material changes |
| Classification | Confidential – Third-Party / Vendor Risk Management Policy |
This Policy establishes a risk-based framework for selecting, onboarding, assessing, contracting, monitoring and exiting third-party vendors, service providers, technology partners and other external parties that support FINZOOPAY SOLUTIONS LLP.
This Policy applies to vendors, payment partners, banks, processors, gateways, API providers, cloud and hosting providers, KYC or verification providers, communication providers, technology vendors, consultants and other material third parties.
Vendors shall be classified according to criticality and risk. Factors may include access to customer or transaction data, financial impact, system dependency, service criticality, regulatory relevance, business continuity impact and substitutability.
Where a vendor handles sensitive information or connects to critical systems, the Company may assess access controls, encryption, vulnerability management, incident response, logging, backup, secure development and data-protection practices proportionate to risk.
Material vendor agreements should address, as appropriate, scope, service levels, confidentiality, data protection, information security, access controls, incident notification, audit or assurance rights, subcontracting, business continuity, termination and data return or deletion.
Vendor access shall be authorised, limited to business need, periodically reviewed and revoked when no longer required. Privileged or production access shall receive enhanced controls where appropriate.
Material subcontracting arrangements shall be disclosed or controlled according to contract and risk. Vendors shall remain responsible for applicable obligations relating to their approved subcontractors.
Critical vendors shall have appropriate service expectations, performance measures, escalation contacts and issue-management processes.
Vendor risk shall be monitored through performance reviews, security assessments, incidents, audit reports, service-level results, changes in ownership or service, regulatory developments and other relevant indicators.
Vendors shall promptly report material security, data, availability, fraud or operational incidents affecting the Company or its customers, in accordance with contractual requirements and applicable obligations.
Critical vendors shall be assessed for continuity capability, recovery arrangements and dependency risk. Where appropriate, alternative providers, contingency arrangements or documented recovery measures shall be considered.
For material vendors, the Company may obtain appropriate assurance such as security questionnaires, audit reports, certifications, penetration-test summaries or other evidence proportionate to risk.
Identified vendor risks shall be documented and assigned an owner. Material deficiencies may require corrective action plans, compensating controls, deadlines, management escalation or restriction of services.
Vendor onboarding and payment arrangements shall be subject to appropriate verification, approval, invoice validation, reconciliation and segregation of duties.
Vendor selection and management shall be conducted fairly and professionally. Conflicts of interest, suspected misconduct or inappropriate inducements shall be disclosed and escalated.
Upon termination or completion of services, vendors shall return, delete or securely dispose of Company and customer information as required by contract and applicable requirements, subject to lawful retention obligations.
Offboarding shall include service transition where required, access revocation, credential/token rotation, data return or deletion, outstanding reconciliation, asset recovery and closure of contractual obligations.
The Company shall maintain an appropriate record of material vendors, their services, owners, risk classification, contract status, review dates and material issues.
Vendor-risk exceptions shall be documented, risk-assessed and approved by authorised management. Mandatory legal, regulatory, contractual and security requirements shall not be waived without lawful authority.
| Function | Responsibility | Escalation |
|---|---|---|
| Management | Material vendor decisions, risk acceptance and resources | Authorised Management |
| Vendor Management | Due diligence, contracts, reviews and offboarding | Vendor Owner |
| Technology / Security | Security assessment, access, integration and incidents | Technology/Security Lead |
| Compliance / Legal | Legal, regulatory, privacy and contractual requirements | Compliance/Legal Lead |
| Risk / Fraud | Vendor risk, fraud exposure and monitoring | Risk/Fraud Lead |
| Finance | Commercial validation, payment and reconciliation | Finance Lead |
| Operations | Service performance and business dependency management | Operations Lead |
This Policy shall be reviewed at least annually and following material vendor incidents, major changes in critical services, significant outsourcing arrangements or changes in applicable requirements.
| Role | Name / Designation | Signature / Date |
|---|---|---|
| Prepared By | Vendor Management / Technology / Risk | |
| Reviewed By | Compliance / Legal / Finance | |
| Approved By | Authorised Partner / Designated Management |