Privacy Policy | LotusPay

Purpose
1. LotusPay Solutions Private Limited (“LotusPay”, “we”,”our” or “us”) enables businesses to collect recurring payments via NACH Debit physical mandates and eMandates (eNACH) (collectively, the “Services”). Lotuspay respects the privacy of all individuals (“Users”) whose Personal Data is collected through its merchants using its Services or through website www.lotuspay.com (“Website”) and collected Personal Data shall be governed by this privacy policy (“Privacy Policy”). By using Lotuspay Services, You acknowledge that You have read, understood and agree to be bound by this Privacy Policy. This Privacy Policy establishes the general framework for data processing. However, separate explicit consent will be obtained from You for specific data processing activities as stated under this Privacy Policy. You can also withdraw your consent by writing to LotusPay as specified in the Privacy Policy. Such withdrawal will affect our ability to provide Services for which such Personal Data is required.
2. This Privacy Policy provides the kind of Personal Data collected, use of such information, retention, handling, processing and disclosure of such Personal Data by LotusPay. This Privacy Policy aims to inform you how we collect and process your Personal Data. Additionally, it is important that you read this privacy notice to fully understand how and why we are using your data. It is important that the Personal Data we hold about you is accurate and correct. Please keep us informed if your Personal Data changes during your relationship with us.
3. “Personal Data” means any information that relates to a natural person, which, either directly or indirectly, in combination with other information is capable of identifying such a person, that we may collect from you either directly, or through our customers/ merchants or any other third parties, as applicable.
4. The terms ‘you' or 'your' refer to any individual who accesses, uses, or interacts with our Services, website or applications, including customers, visitors, and anyone who communicates with us. This includes individuals who apply for employment with us/ submit Personal Data through LotusPay’s merchants, inquiries, feedback, or any other means of communication, such as emails or contact forms.
Change in Privacy Policy
1. LotusPay is committed to comply with the extant applicable laws of India. LotusPay reserves the right to amend, modify, add or remove any portion of this Privacy Policy as required at any time for any reason or under any applicable law or if required to enhance and improve its Services to its merchants. Usage of your Personal Data shall be governed by the last updated or revised Privacy Policy which shall be available on the Website.
Information we collect:
1. When Lotuspay is acting as a Data Fiduciary:
  1. Profile data (username, password, preferences, feedback);
  2. Marketing & communications data (name, email, phone, marketing preferences);
  3. Recruitment Data (CVs, employment history, qualifications, and other details submitted as part of a job application);
  4. Technical data/online identifiers (IP address, MAC ID, IMEI, browser/device info, geolocation)
2. When Lotuspay is acting as a Data Processor: For any information processed on behalf of a merchant (as data fiduciary), LotusPay acts as a data processor and processes Personal Data as per the agreement between Lotuspay and the respective merchant or partner bank.
  1. Financial data- Bank account numbers, account holder names, account types, IFSC codes, branch details, Mandate amounts (fixed/variable), frequency, and duration, Transaction amounts, dates
  2. Customer Identity & Contact Data: Names, addresses, phone numbers, email addresses, Customer identification numbers/references provided by merchant, Demographic information as shared by merchant
  3. Technical & Operational Data: API transaction logs and technical metadata, System timestamps and processing data, Error logs and troubleshooting information related to payment processing
  4. Transaction & Mandate Data: NACH mandate registration details, Payment schedules and instruction data, Transaction success/failure status and reasons, Payment history and audit trails.
3. Obligations as a Data Processor: For Personal Data mentioned in Clause 3.2, LotusPay processes Personal Data strictly in its capacity as a Data Processor on behalf of the Data fiduciary. In this role, LotusPay undertakes the following obligations:
  1. Process personal data only on documented instructions received from merchants i.e. Data fiduciary.
  2. Not process personal data for its own purposes.
  3. Implement appropriate technical and organizational security safeguards to protect personal data.
  4. Assist the Data fiduciary, wherever reasonably possible, in responding to requests from Data Principals exercising their rights under applicable data protection laws.
  5. Notify the Data fiduciary of any personal data breach as per applicable laws
  6. Delete or return personal data, at the choice of the Data fiduciary, upon termination of the processing Services or upon request, unless retention is required under applicable law.
Third Party Links
1. LotusPay is only responsible for the privacy statement and content of this Website. We are not responsible for the privacy practices or the use of cookies on Websites that you may have accessed from this Website, or the privacy policies adopted by our partners/merchants.
Legal Basis & Purposes of Processing
1. We have set out below, in a table format, a description of all the ways we may process your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our Legitimate Uses are where appropriate.

Purpose/Activity	Type of Data	Lawful basis for processing	Disclosure to third Party
Onboarding and registration of merchants	Your name, business email, phone number, company name, and website	When you sign up for LotusPay Services or get onboarded as a vendor, we require this information for vendor due diligence and performance of the Services.	We may share this information with local payment providers, other third-party service providers, depending on the Services acquired.
Enabling LotusPay products and Services	Account name, account type, account number, mandate amount, Credit/ debit card details, contact information, transaction amount, date and time of transaction	We collect this information for the purpose of providing our products and Services	To cloud service providers for data storage, to partner banks for enabling LotusPay Services.
Marketing and promotional activities	Identity, contact and any communication information shared by you	Necessary for our Legitimate Uses (i.e., to study how customers use our products/ Services, to develop them and grow our business), we share this data with our third parties for the purpose of outreach	We disclose this information with our customer relationship management (“CRM”) service providers along with third party email aggregators so they can reach out and further build a relationship
To process your job application to work with us	Identity, contact, identification proof and other such details/ documents voluntarily disclosed by you to process the applications	Legitimate Uses.To conduct due diligence of candidates and undertake the onboarding process	We may disclose this information with a third party for background verification
Merchant service and support	Name, email-id, mobile number	Consent	Third party email aggregators for merchant support
Improvement of Services	Statistical data, usage data	Legitimate Uses	Not applicable
Constitutional changes to LotusPay’s business through mergers or acquisitions	All personal data	Legitimate Uses	To our advisers and those of any prospective purchaser or partner, and the new owners or partners may use your Personal Data in the same way as set out in this privacy notice

5.2 LotusPay processes digital personal data in compliance with relevant data protection laws including DPDP Act, 2023 and its rules (on the date it becomes effective and applicable). Users can review their Personal Data held by LotusPay by sending a mail to LotusPay at business@lotuspay.com and if their Personal Data is inaccurate or deficient then they can update their Personal Data available with LotusPay by writing a mail to LotusPay on the above-mentioned email. If you contact any of our customer service representatives, LotusPay may record such conversations for service quality purposes.

Minors
1. LotusPay and/or any available products or Services provided by LotusPay are not directed at or intended for minors, according to minimum age equivalent under applicable laws in India or the jurisdiction your Company is registered. You are responsible for ensuring that you are of minimum age before accessing LotusPay and its Service. However, LotusPay recognizes that children under the age of 18 may potentially access the website and/or the Services, products, or merchant platform. If We learn that We collected the Personal information of a minor, without first receiving a verifiable parental consent, We will take reasonable steps to delete the information in a manner consistent with Applicable Data Protection Laws as soon as possible. LotusPay prohibits any form of behavioral monitoring, tracking, or targeted advertising directed at minors.
‍Cookies
1. We use cookies to ensure our users receive a seamless experience. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
Your legal Rights
1. You may have the following rights in relation to the personal data processed by us:-
  1. Right of Access: You may have the right to request a confirmation of whether we process your personal data and obtain a copy of such data
  2. Right to Correction and Erasure: You may have the right to request the correction, completion, updating and erasure of your data.
  3. Right to Grievance Redressal. You may have the right to seek grievance redressal with respect to the personal data we process.
  4. Right to Nominate: You may have the right to nominate any other individual, who shall, in the event of death or incapacity, exercise the rights on your behalf.
2. In cases where LotusPay acts as a Data Processor, if you wish to exercise your rights, any requests should be directed to LotusPay’s merchants. Any requests made to us through the contact details provided in Section 15 will be forwarded to LotusPay’s merchants. If you are not satisfied with how we process your request or are otherwise aggrieved by the manner in which we process your personal data, you may have a right to appeal our decision or make a complaint to the Data Protection Board of India.
Conduct of Users
1. Users must abide by the Privacy Policy and terms of use available on the Website.
2. Users must keep their user ID and password of LotusPay account confidential and shall not share it with others.
3. Users shall ensure that they log out of their LotusPay account on the Website when not in use so that any other person using the same system do not get access to your account.
‍Security
1. We are committed to ensure that your Personal Data is secure with us. To ensure the security and protection from any unauthorized access or disclosure we have in place appropriate physical, electronic and managerial procedures to safeguard and secure the Personal Data we collect on the Website. We do not retain any Personal Information collected from you for any longer than reasonably required by us for the purpose of our Services or such period as may be required by applicable laws in India.
Data Breach Handling and Incident Response
1. If LotusPay becomes aware of a Personal Data breach as defined under applicable law, it shall notify merchant and affected Users within seventy-two (72) hours of becoming aware of the breach, including:
  1. A description of the nature of the breach,
  2. The consequences relevant to You that may arise from the breach,
  3. Remedial actions taken,
  4. Safety measures that You can take to protect Your interests,
  5. Contact details for assistance.
2. Reports may also be submitted to the Data Protection Board of India and other regulatory authorities if required, as per applicable laws.
Data localisation and retention
1. All payment system data including transaction details, payment sensitive data, and NACH mandate information is stored exclusively within India in compliance with regulatory requirements.
2. LotusPay retains Personal Data only for as long as is necessary to fulfill the purposes for which We collected it or as instructed by the data fiduciary i.e. merchant. The retention of Personal information by LotusPay is determined by considering compliance with legal (contractual, statutory or regulatory requirements), accounting and compliance reporting requirements or as required under applicable law. We may periodically review the Personal information We hold and take reasonable steps to delete or anonymize any data that is no longer necessary for the purposes for which it was collected, as per the instructions of data fiduciary or to comply with legal or regulatory obligation.
Governing Law
1. This Privacy Policy shall, in all respects, be governed by and construed in all respects in accordance with the laws of India. The Parties agree to submit to the exclusive jurisdiction of the courts in Bangalore in connection with any dispute arising out of or in connection with these terms. If you have questions, comments or suggestions about this Privacy Policy or practices of LotusPay, send LotusPay an e-mail at business@lotuspay.com.
Disclaimer
1. When we act as a Data Processor and process data on behalf of our merchant, any request you submit regarding your data will be forwarded to the respective merchant(s).
Grievance Officer

In case you have any grievance with respect to the Privacy Policy, you may contact the designated Grievance Officer of LotusPay at:

Name: Abhinav

Address: First Floor, Indiqube Grape Garden, Sy No. 130, 18th Main, 1, A Cross, 6th Block, Kormangala, Koramangala VI Bk,Bangalore South, Bangalore- 560095, Karnataka, India

Email address: business@lotuspay.com.

Last updated: 8^th January 2026 (Version 3)

Lotuspay Privacy Policy