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Privacy Policy

Last Updated : 11 Aug 2026

This is a global Privacy Policy that describes how Pine Labs, which term includes all its group companies (collectively referred to as “Pine Labs”, “Company”, “We”, “Us” or “Our”) collect, use, disclose, transfer, store, retain, and otherwise process Information, including Personal Data in connection with Your access to the Website and use of the Pine Labs Services (as defined herein).

By accessing the Website or using the Services, You acknowledge that You have read, understood, and agree to be bound by the terms of this Privacy Policy and, where required under Applicable Laws, provide Your consent to the collection and processing of Your Personal Data as described herein. For this Privacy Policy, the individual accessing the website or using the Services shall be referred to as “You”, “Your” or the “User”.

This Privacy Policy should be read in conjunction with the applicable Terms and Conditions of service, product or nature of relationship, as well as any other policies, notices, guidelines, or disclosures made available on the Website or otherwise communicated by Pine Labs from time to time.

1. Defined Terms

“Information or Personal Data” refers to any Information associated with an identified or identifiable individual, which can include data that you provide to us, and that we collect about you during your interaction with our Services (such as device Information, IP address, etc.).

“Applicable law” refers to relevant laws, statutes, regulations, rules, notifications, guidelines, directions, orders, judgments, and other legally binding requirements applicable to the collecting, storage, use  of Personal Data in the relevant jurisdiction(s), such as Digital Personal Data Protection Act, 2023 (DPDPA, Australia Privacy Act 1988, Singapore  Personal Data Protection Act 2012 (“PDPA”), US privacy laws including CCPA, UAE Protection of Personal Data (PDPL), or Malaysia Personal Data Protection Act 2010 (PDPA).

Compliance with Applicable Law: This Privacy Policy is subject to relevant local laws to the extent to Pine Labs operations and nature of service or offering. To such extent only local requirements, if more rigorous, shall prevail.

“Services” refer to products, services, platforms, applications, websites, software, devices, technologies, solutions, programs, features, content, support services, and related offerings provided, operated, distributed, or made available by Pine Labs, whether through online, mobile, digital, physical, or any other channel  and shall include  any  products, services, features, functionalities, platforms, websites, applications, or offerings made available or offered by Pine Labs from time to time. Annexure A details broadly some key services or products offers by various group companies under Pine Labs, and broad types of Personal Data collected, stored and/or used, as per this Privacy Policy.

2. Information we collect or recieve about you

We need to collect, use receive, process or store Information about you to provide you with the Services and to support your requests. This Information can vary depending on the jurisdiction from which you access our Services.

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Information You Provide

We collect or receive Information you provide when you apply, use or sign up for any of our Services, go through our identity or account verification process, authenticate into your account, communicate with us, answer our surveys, upload content, or otherwise use our Services.

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Information we collect or receive about you when you use our Services, including:

  • Data about you: This may include, without limitation, your (i) name, date of birth, gender, user IDs, signature, email addresses, phone numbers, addresses, contact details, government issued KYC/identity documents (for example: Tax ID, other Government identity card as specified), biometric data, (ii) communications with us, (iii) device and location data, (iv)Information about how you use our Services, etc.
  • Financial data: This may include, without limitation, Information about your bank account details, financial Information, payment credentials, transaction data (credit details such as amounts, lending history, and repayments, credit history, income details, payment Information, such as credit, debit card or gift card Information, billing address, through our payment processing system etc.
  • Marketing and communication data: This may include without limitation, your preferences relating to receiving marketing messages from us and our service providers, and your communication preferences, knowing customer preferences, such as spending patterns, preferences, and interests etc.
  • Technical data - This may include device and technical Information you give us when using our website, such as IP addresses, cookie identifiers, or other unique identifiers, like mobile carrier, time zone setting, operating system, platform, etc.
  • Other Information You Provide. This may include Information that you voluntarily provide to us, including any survey responses; participation in contests, promotions, or other prospective seller marketing forms or devices; suggestions for improvements; referrals; or any other actions performed on the Services.

User must ensure that all Personal Information that User provides us is accurate, up-to date, and true. The User will be responsible for any errors, discrepancies, or inaccuracies in the Personal Information that has been shared with us. When You use our Services, we make best efforts to provide you with the ability to access and correct inaccurate or deficient Personal Information, subject to any legal requirements or Applicable Law.

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Information We Collect Or Receive From Other Sources

We also collect or receive Information about you from third parties, including:

  • Identity Verification. Information from third-party verification services, credit bureaus, financial institutions, mailing list providers, and publicly available sources. In some circumstances, where lawful, this Information may include your government-issued identification number.
  • Background Information. To the extent permitted by Applicable Laws, we may obtain background check reports from public records of criminal convictions and arrest records. We may use your Information, including your full name, government-issued identification number, and date of birth, to obtain such reports.
  • Credit, Compliance and Fraud. Information about you from third parties in connection with any credit investigation, credit eligibility, identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by Applicable Law. This includes, without limitation, the receipt and exchange of account or credit-related Information with any credit reporting agency or credit bureau, where lawful, and any person or corporation with whom you have had, currently have, or may have a financial relationship, including without limitation past, present, and future places of employment, financial institutions, and personal reporting agencies.

Our Services may include offerings that are intended for or may be used by Child who are below the age at which they may independently provide valid consent under Applicable Law.

‍Information We Collect or Receive from a Child

Under this Privacy Policy, a “Child” means an individual below the age at which they may independently provide valid consent under Applicable Laws, which may vary by jurisdiction and may range from 13 to 18 years of age, as prescribed by Applicable Law. If you are a Child, you will be required to provide the mobile number of your parent or legal guardian for consent and verification purposes. The Child should not make any interaction or register themselves for our Services or submit Personal Data to us in absence of parental or guardian consent.

If we obtain actual knowledge that the Information of the Child has not been provided with necessary guardian consent as required under Applicable Law, we will take action in accordance with Applicable Law. A parent or lawful guardian may contact us at DPO@pinelabs.com to submit a request concerning a Child’s Personal Data.

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Your Consent to collect, use and/or process Information for or as Data Fiduciary(ies)/Co-Data Fiduciary(ies):

By providing your Information and using our Services, you expressly consent to the collection, use, storage, disclosure, sharing and processing of your Personal Data by the Company in accordance with this Privacy Policy. You acknowledge and agree that, depending on the nature of the service being provided:

  • We may act as a Data Processor on behalf of Data Fiduciary(ies) and process your Personal Data strictly in accordance with the instructions of such Data Fiduciary(ies);
  • We may act as a Data Fiduciary(ies)/ Co-Data Fiduciary(ies) jointly with one or more entities where both parties independently determine or jointly determine the purposes and means of processing your Personal Data; and/or
  • In such cases, your Personal Data may be shared between and processed by us and such other Data Fiduciary(ies)/Co-Data Fiduciary(ies) for the purposes described in this Privacy Policy, including customer onboarding, service delivery, transaction processing, fraud prevention, compliance with legal and regulatory obligations, customer support, analytics, risk management and other legitimate business purposes.
3. How we use our information

We may use Information about you for number of purposes, including:

  • Providing, Improving, and Developing our Services
  • Determining whether the Services are available in your country;
  • Processing or recording payment transactions or money transfers;
  • Otherwise providing you with the Pine Labs products and features you choose to use;
  • Displaying your historical transaction or appointment Information;
  • Providing, maintaining and improving our Services;
  • Developing new products and services;
  • Delivering the Information and support you request, including technical notices, security alerts, and support and administrative messages including to resolve disputes, collect fees, and provide assistance for problems with our Services or your Pine Labs account;
  • Improving, personalizing, and facilitating your use of our Services;
  • Measuring, tracking, and analyzing trends and usage in connection with your use or the performance of our Services;
  • Performance of a contract for providing products or services;
  • Use your Personal Data to take and handle orders, deliver products and services;
  • Optimise our website to suit your interest and your usage patterns;
  • to get in touch with you when necessary and sending materials regarding upcoming offers or any Information that we deem material in order for you to be a fully informed user and customer of Pine Labs Services, and visitor to the Website.

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Communicating with You About our Services

  • Sending you Information we think you may find useful or which you have requested from us about our products and Services;
  • Conducting surveys and collecting feedback about our Services.

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Protecting our Product and Services and Maintaining a Trusted Environment

  • Investigating, detecting, preventing, or reporting fraud, misrepresentations, security breaches or incidents, other potentially prohibited or illegal activities, or to otherwise help protect your account, including to dispute chargebacks on your behalf;
  • Protecting our, our customers’, or your customers’ rights or property, or the security or integrity of our Services;
  • Enforcing our Terms of Use or other applicable agreements or policies;
  • Verifying your identity (e.g., through government-issued identification numbers);
  • Complying with any Applicable Laws or regulations, or in response to lawful requests for Information from the government or through legal process;
  • Fulfilling any other purpose disclosed to you in connection with our Services;
  • Contacting you to resolve disputes, collect fees, and provide assistance with our Services.

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Advertising and Marketing

  • Communicating with you about opportunities, products, services, contests, promotions, discounts, incentives, surveys, and rewards offered by us and select partners;
  • If we send you marketing emails, each email will contain instructions permitting you to ‘opt out’ of receiving future marketing or other communications from relevant company.

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Other Uses

  • For any other purpose disclosed to you in connection with our Services from time to time and based on your opt-in consents obtained for such purposes.
4. Legal basis for processing, reserach and training

Depending on the jurisdiction and the context in which Personal Data is collected and processed, we may process Personal Data on one or more lawful bases, including (i) performance of a contract, (ii) compliance with legal and regulatory obligations, (iii) our legitimate business interests,(iv) prevention, detection ,protection and investigation of  frauds or security threats,(v) conducting research, analytics, product development, and the training, testing, validation, and improvement of artificial intelligence and machine learning models and related technologies,(vi) your consent where consent is required by Applicable Law.

5. How we share your information

We may share Personal Data belonging to you with your consent and at your direction, or as described at the time you agree to share. We may also share your Information when you authorize a third-party application or website to access your Information.  We may share your Information as follows:

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With Other Users of our Services with Whom You Interact

  • With other users of our Services with whom you interact through your own use of our Services. For example, we may share Information when you make or accept a payment, appointment, or money transfer using our Services.

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With our Affiliates

  • With our group companies and corporate affiliates, for agreed purposes outlined herein in this Policy or pursuant to applicable agreed contractual arrangements.

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With Third Parties

  • With third parties to provide, maintain, secure, support, and improve our Services, such as : (i) Technology Infrastructure and Hosting Providers (such as data centre hosting, website hosting, and log management providers); (ii) Communication Service Providers (such as SMS, email, and dialler service providers); (iii) Identity, Verification and Compliance Service Providers (such as identity verification, KYC, anti-money laundering (AML), fraud prevention and monitoring, and consent management providers); (iv) Payment and Financial Service Providers (such as UPI switch providers, card networks, bill payment service providers, and fee collection service providers); and (v) Operational and Transaction Support Providers (such as NFC support providers, printing service providers, and other operational support providers). We may also share Information with third parties that conduct advertising campaigns, promotional programs, contests, special offers, or other activities on our behalf or in connection with our Services.
  • With financial institutions, payment networks, payment card associations, credit bureaus, merchants, Lending Service providers, partners or any other entities in connection with the Services;

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Business Transfers and Corporate Changes

  • To a subsequent owner, co-owner, or operator of one or more of the Services; or
  • In connection with (including, without limitation, during the negotiation or due diligence process of) a corporate merger, consolidation, or restructuring; the sale of substantially all of our stock and/or assets; financing, acquisition, divestiture, or dissolution of all or a portion of our business; or other corporate change.

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Safety and Compliance with Applicable Law

  • If we believe that disclosure is reasonably necessary (i) to comply with any Applicable Law, regulation, legal process or governmental request (e.g., from tax authorities, law enforcement agencies, etc.); (ii) to enforce or comply with applicable agreements or policies; (iii) to protect our or our customers’ rights or property, or the security or integrity of our Services; or (iv) to protect us, users of our Services or the public from harm, fraud, or potentially prohibited or illegal activities.

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Aggregated and Anonymized Information

  • We also may share (within our group of companies or with third parties) aggregated and anonymized Information that does not specifically identify you or any individual user of our Services.
6. How long we retain your information

We retain your Information as long as it is reasonably necessary to provide you the Services or to comply with Applicable Law. We will remove your Personal Data after the purpose of collecting such data is achieved, as per the consent obtained by you However, even after you deactivate your account or place such requests, we may retain copies of Information about you and any transactions or Services in which you may have participated for a period of time that is consistent with Applicable Law, applicable statute of limitations or as we believe is reasonably necessary to comply with Applicable Law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our Terms of Use or other applicable agreements or policies, or to take any other actions consistent with Applicable Law.

7. Cross border data movement

Pine Labs may transfer Personal Data to countries where we, our group companies or service providers operate. Such transfers will be made in accordance with Applicable Law and subject to required safeguards, including contractual protections, data minimisation, access controls, and appropriate technical and organisational measures. Where Applicable Law requires local storage or restricts cross-border transfers, we will comply with those requirements.

8. Cookies and other similar technologies

We use various technologies to collect or receive Information when you access or use our Services, including placing a piece of code, commonly referred to as a ‘cookie,’ or similar technology on your device and using web beacons. Cookies are small data files that are stored on your hard drive or in your device memory when you visit a website or view a message. Among other things, cookies support the integrity of our registration process, retain your preferences and account settings, and help evaluate and compile aggregated statistics about user activity. We will begin collecting Information about you or from activity on devices you use as soon as you use our Services. By using our Services and as per your cookie settings, you permit us to collect or receive and use your Information from activity on devices you use in accordance with this Privacy Policy.

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Certain cookies we use last only for the duration of your web or application session and expire when you close your browser or exit the application. Other cookies are used to remind you when you return to use the Services and, as such, will last longer.

We may use cookies to:

  • Remember that you have visited us or used the Services before. This allows us to identify the number of unique visitors we receive, so that we can provide enough capacity to accommodate all of our users.
  • Customize elements of the promotional layout and/or content of our Services.
  • Collect data about the way you interact with our Services (e.g., when you use certain features).
  • Collect data to assess and improve our advertising campaigns, including sending Information to our business partners.
  • Allow our business partners (including third parties) to use these tracking technologies to track your behavior on our behalf on our website/platform (including when you use multiple devices) and on partner websites.
  • Enable third parties to collect data about the way you interact across sites outside of our Services.
  • Collect anonymous statistical Information about how you use the Services (including the length of your web or application session) and the location from which you access the Services, so that we can improve the Services and learn which elements and functions of the Services are most popular with our users.

Some of the cookies used in the Services are set by us, and others are set by third parties who deliver services on our behalf.

Most web and mobile device browsers are set to automatically accept cookies by default. You will be presented with a cookie banner at the time of visiting our Website and Platforms where you can select your cookie preferences. Please note, however, that by blocking deleting or disabling cookies used in the Services, you may not be able to take full advantage of the Services.

We also may collect or receive Information using web beacons. Web beacons are electronic images that may be used in our Services or emails. We use web beacons to deliver cookies, track the number of visits to our website and apps, understand usage and campaign effectiveness, and determine whether an email has been opened and acted upon. This Website may contain links to other websites. We are not responsible for the privacy practices of websites which we do not own, manage or control. Please find more details about our Cookie Policy here www.pinelabs.com/cookie-policy.

9. Third-party advertising and analytics
  • We can use third-party service providers to provide site metrics and other analytics services. These third parties can use cookies, web beacons, and other technologies to collect Information, such as your IP address, identifiers associated with your device, other applications on your device, the browsers you use to access our Services, webpages viewed, time spent on webpages, links clicked, and conversion Information (e.g., transactions entered into). This Information can be used by Pine Labs and third-party service providers on behalf of Pine Labs to analyze and track usage of our Services, determine the popularity of certain content, and better understand how you use our Services. The third-party service providers that we engage in are bound by confidentiality obligations and other restrictions with respect to their use and collection of your Information.
  • This Privacy Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies, which are covered by such third parties’ privacy policies. For more Information, we encourage you to check the privacy policies of these third parties to learn about their privacy practices.
10. Your rights and choices

Deactivating Your Account

You may deactivate your account through the account settings available for the relevant Service or by contacting us through the channels specified below. Deactivating your account does not necessarily result in the deletion of your Personal Data. We may retain Personal Data where required or permitted by Applicable Law, including for regulatory compliance, fraud prevention, dispute resolution, security and record-keeping purposes.

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Location Information

Certain Services may require access to location Information, including precise geolocation, to provide a requested feature, prevent fraud, maintain security or comply with Applicable Law. Where required, we will obtain your consent or device permission before collecting precise geolocation Information. You may manage location permissions through your device settings; however, disabling location access may prevent the relevant location-dependent feature from operating.

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Promotional Communications

  • You may receive promotional, marketing, and other commercial communications from us based on your consent.
  • You may opt out of receiving such promotional messages by following the instructions in those messages or in case of tele offers, informing the caller of your preference to opt out of promotional calls.
  • Opting out of promotional communications may affect certain aspects of your use of our Services. However, opting out of promotional communications will not affect your receipt of transactional, security, legal, administrative or other non-promotional communications relating to the Services.

Your Data Protection Rights

You may exercise certain rights related to your Personal Data, subject to Applicable Laws. These can be exercised through our Privacy Center where this feature is active, or you may write to us at DPO@Pinelabs.com  

These rights may include:

  • Right to correction or erasure of Personal Data: You have the right to modify/update or erase the Personal Data provided to us. However, please note that in some cases, we may need to retain certain data to provide our products or Services or to comply with legal obligations. In such cases, we will inform you and provide appropriate reasons for not adhering to such deletion request.
  • Right to Access: You have the right to access Personal Data we process about you, the relevant processing activities and such other Information as Applicable Law requires:
    • by requesting the following Information: a summary of your Personal Data we possess, collect and the processing activities undertaken, categories of Personal Data involved;
    • identities of all other recipients of your Personal Data;
    • and such other Information as per Applicable Law.
  • Right to withdraw consent: Where we rely on your consent to process your Personal Data, you have the right to decline consent and/or to withdraw your consent to Process or collection of your Personal Data for a particular purpose. This will not affect the lawfulness of processing prior to the withdrawal of your consent. We may not be able to stop the processing of your Personal Data immediately, depending on any legal obligations that require such processing. We will inform you and provide appropriate reasons for continuation of processing in such a case. At any time, you can request that we stop using your Personal Data for direct marketing purposes.
  • Right to Nominate: You may nominate an individual who may, in the event of your death or incapacity, exercise your rights with respect to your Personal Data in accordance with Applicable Law.
    • You may communicate the details such as name, email address and phone number of such nominee by using the methods provided above.
  • Right of grievance redressal: In case of any grievances with respect to your Personal Data used, collected, stored or processed by us, your rights or this Privacy Policy, you may contact us by using the channels and methods provided above. We shall respond to your grievances within 90 days.
  • You have a right to raise questions or complaints with your local data protection authority at any time. If your Personal Data is processed in India and you are not satisfied with our response to your grievance, you may raise a complaint with the Data Protection Board of India in accordance with Applicable Law.
  • We may need to verify your identity before adhering to certain requests and will take reasonable steps to do so. If you have an account with us, we may verify you through your login credentials. If you do not have an account with us, we may seek a confirmation by email or any relevant identification Information, including government-issued identification, to verify your identity
  • You may authorize an agent to make a request to us on your behalf and we will verify the identity of your agent or authorized legal representative by either seeking confirmation from you or documents that establish the agent’s authorization to act on your behalf.

Please note your rights and choices vary depending upon your location. Certain Personal Data may be exempt from such requests under Applicable Law. We need certain types of Personal Data so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.

11. Security

We take reasonable measures, including administrative, technical, and physical safeguards, to protect your Information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, the internet is not a 100% secure environment, and we cannot guarantee absolute security of the transmission or storage of your Information. We hold Information about you both at our own premises and with the assistance of third-party service providers.

12. Changes to this privacy policy

We may amend this Privacy Policy from time to time by posting a revised version and updating the ‘Effective Date’ above. Such amendments may include addition of our new products, group companies and affiliates and/or any new Servies offered as part of Pine Labs environment, where this policy may become applicable. The revised version will be effective on the ‘Effective Date’ listed. We will provide you with reasonable prior notice of material changes in how we use your Information, including by email, if you have provided an email address. If you disagree with these changes, you may cancel your account at any time. Your continued use of our Services constitutes your consent to any amendment of this Privacy Policy.

13. Contact details

Please contact our Data Protection Officer with any questions or concerns regarding this Privacy Policy and/or security by reaching out on: DPO@Pinelabs.com

If you have any questions or concerns regarding our Policy, or if you believe our Policy or Applicable Laws relating to the protection of your Personal Data have not been respected, you may file a complaint with our Data Privacy Office listed above, We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We may keep records of your request and any resolution.

14. Jurisdiction

Your access to and use of the Website is subject to this Privacy Policy and the applicable Terms of Use. Any dispute arising out of or relating to this Privacy Policy shall be governed by the law and jurisdiction specified in the applicable Terms of Use, to the extent permitted by Applicable Law.

Nothing in this Privacy Policy limits or excludes any mandatory rights or remedies available to you under Applicable Law, including your right to submit a complaint to, or seek relief from, a competent data protection authority, regulator or court.

If you choose to visit, access or use the Website, your visit and any dispute relating to privacy shall be subject to this Privacy Policy and the Website’s Terms of Use. Any dispute, controversy, or claim arising out of or in connection with this Privacy Policy shall be governed by law and exclusive jurisdiction of the Court(s) as located in the relevant jurisdiction.

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Note: This Policy is relined as per the DPDPA and accordingly to come into effect post DPDPA implementation in Pine Labs environment, and before 13th May 2027.

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ANNEXURE A

Payment Services- The core payments business that provides merchant acquiring, POS machines, payment gateway services, QR payments, Buy Now Pay later, EMI solutions, marketplace or acceptance infrastructure for online and offline merchants. It enables businesses to accept digital payments across cards, UPI, wallets, and other payment modes.

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Issuing Business Services - Focuses on card issuance and embedded financial products. Pine Labs Issuing Business provides a comprehensive suite of prepaid solutions, including gift cards, brand wallets, refunds, promo vouchers, transit cards, expense management cards, e-RUPI vouchers, fuel cards, forex cards and more. Our platform supports issuing, processing, and distribution, making it a one-stop solution for all your prepaid needs.

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Setu – Setu by Pinelabs provides API-based infrastructure that enables businesses to embed regulated financial services within their own products and platforms, without building the underlying regulatory and technical infrastructure themselves. These include, among others, digital onboarding and identity verification, electronic signature, payments and collections, bill payments, and consent-based access to financial information under the Account Aggregator framework.

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Shopflo - Shopflo provides a technology-enabled checkout platform that is integrated into the storefronts of select third-party online brands and retailers, i.e. Merchants, who offer purchase of goods/services online.  

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Fave India: Fave is a UPI-powered financial platform designed for shared money management, offering features such as group and household finances, UPI payments, utility bill and salary payments, savings and expense splitting, gifting, and personal finance management.

We may actively collect the following Personal Data about you when you visit our platform:

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Payment Services

Fave

Shopflo

Issuing Services

Setu

Precise Geolocation Information

Yes

Yes

Information categories

Yes

Yes

Yes

Device Information (Device ID i.e type, model, OS, network data)

Yes

Yes

Yes

Yes

Yes

Identity data (KYC, bank/Card details, transaction details, business information, profile picture, Utility documents)

Yes

Yes

Yes

Yes

Yes

Behavioural and Session Data (Web interactions such sites visited/ viewed, features used, timestamps, search queries, checkout journeys, carts details, payment preferences, metadata)

Yes

Yes

Yes

Yes

Yes

Cross-Merchant Network Data when using checkout services to enable pre-filled checkout details, cross-merchant login, and a seamless checkout experience.

No

No

Yes

No

No

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