Sapthan Pay — Privacy Policy
1. Who we are
Sapthan Pay is operated by Sapthan AI and IT Solutions Private Limited, a company incorporated in India on 14 July 2026.
Registered office: H.No. 5-3-28/244, Plot-244, Sai Nagar Colony, Boduppal, Ghatkesar, Hyderabad, Telangana 500092, India
CIN: U62099TS2026PTC219322
For the UK and EU General Data Protection Regulation we are the data controller. Under India's Digital Personal Data Protection Act 2023 we are the Data Fiduciary.
Contact: business@sapthan.com
1.1 Grievance Officer (India)
Name: to be completed — name a director or officer
Email: business@sapthan.com
1.2 Representatives in the EU and UK
Because we are established outside the UK and EEA and offer our service to people there, we appoint representatives under Article 27 of the UK and EU GDPR. You may contact either instead of us on any matter relating to your data.
EU representative: to be appointed
UK representative: to be appointed
2. What we collect, and why
2.1 Information you give us
| Data | Why | Legal basis (UK/EU GDPR) |
|---|---|---|
| Full name | Account identity; shown on statements | Contract |
| Email address | Sign-in, account recovery, receipts | Contract |
| Phone number (optional) | Account recovery | Contract |
| Home country and country of residence | Which banks, billers and currencies apply to you | Contract |
| Your own UPI ID, if you enter one | Generating your receive-money QR code | Contract |
| Biller and loan reference numbers you add | Fetching the bills and instalments you asked us to track | Contract |
| Identity documents, where verification is required | Meeting anti-money-laundering obligations | Legal obligation |
2.2 Information from your bank
Only after you authorise it on your own bank's page, and only for the accounts you choose: the bank name, account holder name, a masked account number, the balance, and transaction history. We use it to show you your money, produce statements, and identify recurring bills.
Authentication happens on your bank's own page, opened in your phone's browser rather than inside our app. By design, we do not receive your banking password, PIN or one-time code, and we do not store them.
You may withdraw a bank authorisation at any time, with us and with your bank. Authorisations also expire under the rules of the framework they were granted through.
2.3 Information collected automatically
| Data | Why | Legal basis |
|---|---|---|
| A pseudonymous account identifier | Linking your data to your account | Contract |
| An app-scoped device identifier | Security: binding your verified identity to one device, so a stolen password alone cannot move money from a new phone | Legitimate interests (fraud prevention) |
| Push notification token | Delivering reminders and payment alerts | Contract |
| App version, screen names, feature usage, crash diagnostics | Fixing faults and understanding which features are used | Legitimate interests |
Our analytics are designed to exclude personal data. We send event names and safe dimensions — which screen, which feature, success or failure, the currency code — and not your email, phone number, account number, balance or payment amounts. Crash diagnostics may incidentally include technical information about the state of the app when a fault occurred.
2.4 Permissions
| Permission | What it is used for |
|---|---|
| Contacts (optional) | Showing the saved name for a single phone number you are recharging. Looked up one number at a time. We do not enumerate, copy, store or upload your address book. Declining shows a masked number instead. |
| Camera (optional) | Scanning payment QR codes, and identity verification if you complete it. |
| Notifications (optional) | Reminders and payment alerts. |
Each is optional and can be withdrawn in your phone's settings at any time.
3. Notifications and marketing
Service notifications — a payment result, a bill falling due, a security alert — are part of the service and are sent on the basis of our contract with you. You can turn them off in your phone's settings.
We will not send you marketing without your consent, and you may withdraw that consent at any time without affecting your use of the app.
4. Fraud, sanctions and legal screening
We screen accounts and transactions for fraud, money laundering and sanctions exposure. This is a legal obligation (GDPR Art. 6(1)(c)) and, where we act beyond what the law strictly requires, our legitimate interest in preventing crime against our users and ourselves.
Screening may cause a payment to be delayed, refused or reversed, or an account to be suspended. Where we are legally permitted to tell you why, we will.
5. Who we share it with
We do not sell your personal data, and we do not use it for advertising.
We share it only with service providers who process it on our instructions, in these categories:
- Cloud infrastructure and authentication — hosting, sign-in, storage, crash diagnostics.
- Bank connection providers — regulated providers who obtain your bank's authorisation and return your account data.
- Payment, top-up and bill-payment networks — to execute the transactions you request.
- Identity verification providers — where verification is required.
Our current providers are listed at sapthanpay.com/subprocessors. We publish changes to that list before a new provider begins processing your data. Each is bound by a data processing agreement and may use your data only to provide the service to us.
We may also disclose data where legally required — a court order, a regulator, or a law-enforcement request we are obliged to answer.
6. International transfers
We are established in India, and some of your data is processed there and by providers in other countries.
India is not covered by a UK or EU adequacy decision. Transfers of personal data from the UK or EEA are therefore made under the Standard Contractual Clauses approved by the European Commission, together with the UK International Data Transfer Addendum, and with technical protections described in section 8. You can request a copy of these safeguards at business@sapthan.com.
7. How long we keep it
| Data | Retention |
|---|---|
| Account and profile data | While your account is open, then erased within 30 days of closure or a valid erasure request — subject to the row below |
| Transaction records and related identity records | Retained after account closure for the period required by financial record-keeping and anti-money-laundering law — see section 9 |
| Bank authorisation records | For the life of the authorisation, plus the period the relevant framework requires |
| Crash diagnostics and analytics | Up to 14 months |
| Push notification tokens | Removed when you sign out or uninstall |
8. How we protect it
- Your PIN is never stored in a form anyone can read, here or anywhere else — only a salted, deliberately slow one-way hash of it, which cannot be reversed to recover the PIN.
- Account details and balances held on your device are encrypted using the security hardware your phone provides.
- We ask the operating system to block screenshots and screen recording throughout the app, and to keep your balance out of the recent-apps preview. These protections rely on the device behaving normally and can be defeated on a device that has been modified.
- App lock uses your phone's own fingerprint, face, pattern or PIN, and the app re-locks after a short period in the background.
- Repeated wrong PIN entries temporarily lock payments.
- We do not receive your bank credentials — see section 2.2.
- Data is encrypted in transit.
- Access is scoped so that one user cannot reach another user's data, and the records our systems rely on for spending limits and payment integrity cannot be altered from a phone.
We review these protections and strengthen them over time. No security measure is absolute, and we do not claim otherwise.
9. Your rights, deletion and export
Under UK/EU GDPR you may access your data, have it corrected or erased, restrict or object to processing, receive it in a portable format, and withdraw consent where consent is the basis we rely on. Under India's DPDP Act 2023 you have equivalent rights of access, correction, erasure, nomination and grievance redressal.
To exercise any of these, email business@sapthan.com. We respond within one month, extendable where the law allows, and we will tell you if we need the extra time.
What deletion means, stated plainly. We erase your identity and profile data. We cannot erase records of completed transactions, because financial record-keeping and anti-money-laundering law requires us to retain them for a set period; they are kept restricted, used only to meet those obligations, and deleted when the period ends.
Clearing local data in the app removes what is stored on that phone. It is a convenience, not the exercise of an erasure right, and it does not by itself delete your account.
Complaints. You may complain to your supervisory authority — the Information Commissioner's Office in the UK, your national data protection authority in the EEA, or the Data Protection Board of India — and, in India, to our Grievance Officer named in section 1.1 first.
10. Cookies
The mobile app does not use cookies. Our website uses only what is necessary for it to work, and asks before setting anything else.
11. Accessibility
We aim to meet WCAG 2.1 level AA in the app and on our website. If any part is difficult for you to use, tell us at business@sapthan.com and we will help and prioritise a fix.
12. Children
Sapthan Pay is not intended for anyone under 18, and we do not knowingly collect data from children. If you believe a child has provided us data, contact business@sapthan.com and we will delete it.
13. Changes
We post changes on this page and update the version and date above. Material changes are notified in the app before they take effect.
14. Contact
Sapthan AI and IT Solutions Private Limited
H.No. 5-3-28/244, Plot-244, Sai Nagar Colony, Boduppal, Ghatkesar, Hyderabad, Telangana 500092, India
business@sapthan.com · sapthan.com