CoolPay India Digital Services Private Limited ("CoolPay", "we", "us" or "our") is committed to protecting the privacy of every visitor, merchant, partner, agent, developer and end-user (collectively, "you", "your") who interacts with our website, platforms, mobile applications and APIs (together, the "Services"). This Privacy Policy explains what information we collect, how we use it, how we share it, and the choices you have.
This Policy is published in accordance with the provisions of the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, the Digital Personal Data Protection Act, 2023 (as and when its provisions are in force) and other applicable Indian laws, including guidelines issued by the Reserve Bank of India (RBI).
1. Information we collect
a. Information you provide to us
- Identity data: name, date of birth, photograph, gender.
- Contact data: email, phone, postal address, WhatsApp number.
- KYC data: PAN, Aadhaar (where legally permissible), Passport, Voter ID, Driving Licence, Selfie/liveness, Video KYC, GST and shop-establishment details.
- Financial data: bank account number, IFSC, UPI VPA, wallet balances, transaction history, settlement details, tax records.
- Business data: company name, CIN, GST, registered office, authorised signatories.
- Communications: information you share with our support, sales or partnership teams.
b. Information collected automatically
- Device identifiers, IP address, browser type, operating system, mobile network.
- Location (city / state level, and precise location only with your consent).
- Usage data, log files, API request/response metadata, referrer URLs.
- Cookies and similar technologies as described in Section 8.
c. Information from third parties
- Banking partners, payment aggregators, NPCI, UIDAI (via authorised agencies), CIBIL / credit bureaus.
- Sanction / PEP / AML screening providers.
- Advertising, analytics and infrastructure partners.
2. How we use your information
- To provide, maintain and improve our Services.
- To onboard merchants, agents and users and to run KYC / AML checks.
- To authorise, execute, record and settle transactions.
- To generate settlement reports, invoices and statements.
- To prevent fraud, money laundering and abuse of the Services.
- To send transactional, informational and (where permitted) marketing communications.
- To comply with applicable laws, regulatory directions and lawful requests.
3. Legal basis for processing
We process your data on one or more of the following bases: (i) performance of a contract with you; (ii) your consent; (iii) compliance with a legal obligation; (iv) our legitimate interests in operating the business, subject to your rights and freedoms.
4. Sharing of information
We do not sell your personal information. We may share it only with the following categories of recipients:
- Banking, payment and payout partners necessary to complete a transaction.
- Sub-processors — cloud hosting (AWS / Azure / GCP), analytics, communication and CRM tools — under contractual data-protection commitments.
- Auditors, advisors, legal counsel and regulators when required.
- Enforcement authorities or courts pursuant to a lawful request.
- An acquirer or successor entity in the event of a merger, acquisition, reorganisation or sale of assets, with the same protections continuing.
5. Data retention
We retain personal data only for as long as required to provide the Services and to comply with legal, regulatory, tax, audit and record-keeping obligations (typically 8–10 years for financial records under Indian law). When no longer required, data is either securely deleted or anonymised.
6. Security
We follow industry best practices to safeguard your information — including AES-256 encryption at rest, TLS 1.2+ in transit, HSM-backed key management, role-based access control, least-privilege engineering, quarterly VAPT, and alignment with ISO/IEC 27001 and PCI-DSS controls. However, no system is 100% secure, and we cannot guarantee absolute security.
7. Your rights
Subject to applicable law, you have the right to (i) access, correct or update your personal data; (ii) withdraw consent where processing is based on consent; (iii) request erasure of data no longer required; (iv) restrict or object to certain processing; (v) lodge a complaint with the appropriate authority. To exercise these rights, write to admin@coolpayindia.com.
8. Cookies
We use first-party and third-party cookies for authentication, preference storage, analytics and (where permitted) marketing. You can control cookies through your browser settings; blocking certain cookies may impair functionality.
9. Children
Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe a minor has provided us information, please contact us and we will delete it.
10. Cross-border transfers
Payment data of Indian users is stored within India in line with RBI directions. Certain administrative or support-tool data may be processed by our sub-processors outside India, under appropriate safeguards and contractual commitments.
11. Changes to this policy
We may amend this Policy from time to time. Material changes will be notified via email or in-product notice. The "Last updated" date at the top of the page indicates when the Policy was last revised.
12. Grievance Officer
In accordance with the Information Technology Act, 2000 and the Consumer Protection Act, 2019, the details of the Grievance Officer are provided below:
Grievance Officer
CoolPay India Digital Services Private Limited
H.No 6, Vrindavan Colony, Rohtas Nagar, Khajuri Kalan, Huzur, Bhopal — 462022, Madhya Pradesh, India
Email · admin@coolpayindia.com
Phone · +91 9422799504
Response time · Within 30 days of receipt of your complaint.