Privacy Policy

This Privacy Notice for Pathrika Tech Solutions (doing business as Pathrika) ("we", "us", or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at http://www.pathrika.in or any website of ours that links to this Privacy Notice.
• Download and use our mobile application (Pathrika), or any other application of ours that links to this Privacy Notice.
• Engage with us in other related ways, including any marketing, billing, or SMS communication events.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@pathrika.in.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you register on the Services. The personal information we collect depends on whether you are a Newspaper Agent (Subscriber) or a Customer (End-User).

Information collected from Agents:

• Name
• Profile photos or images (used to help agent's customers recognize and verify them)
• Phone numbers and email addresses
• Address
• Bank account information for payment settlements (This Sensitive Personal Data is encrypted at the application level using AES-256 before being stored in our database)
• Pathrika Credit balances, purchase history, and ledger usage data

Information processed on behalf of Agents (Customer Data):

As a SaaS platform, we process data entered by Agents regarding their customers. This includes Customer names, delivery addresses, phone numbers, and subscription details. Pathrika acts as a Data Processor for this information.

• Sensitive Information: We do not process sensitive information (such as racial origins, religious beliefs, health data, or government identification numbers like PAN or Aadhaar).
• Payment Data (Customers): We facilitate online invoice payments primarily via UPI. We do not collect, capture, store, or process any sensitive payment information (such as UPI PINs, bank passwords, or debit/credit card numbers). When an end-customer pays an invoice, the transaction is handled directly and entirely by our secure third-party payment gateway partner. The payment gateway securely processes the transaction on their end, and we only receive the payment status and the transaction details to update the Agent's ledger. You may refer to the payment gateway's privacy notice on their website for details on how they handle financial data.

Application Data:

If you use our application(s), we may collect the following information:

• Mobile Device Data: We automatically collect device information (such as mobile device ID, model, operating system) to maintain security and troubleshoot bugs.
• Push Notifications & SMS: We request permission to send push notifications and DLT-registered SMS/WhatsApp messages regarding account billing and features.

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation: To allow Agents to log in and manage their ledger.
• To process manual payouts: To securely facilitate the transfer of collected funds from our platform to the Agent's designated bank account.
• To build customer trust and verify identity: To display the Agent's profile photo to customers when sending subscription requests or billing links.
• To deliver services: To generate invoices, calculate subscription dues, manage Pathrika Credit balances, and facilitate online UPI payments.
• To send administrative information: To send bill links, payment receipts, and policy updates to Agents and Customers via WhatsApp, SMS, or transactional email (as a fallback).
• To protect our Services: For fraud monitoring and prevention.
• To comply with legal obligations: To comply with Indian taxation, telecom (TRAI/DLT), and financial regulations.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We do not sell your personal data to third-party advertisers or data brokers. We only share information with specific third parties necessary to run the Pathrika platform:

• Cloud Infrastructure Partners: We use Amazon Web Services (AWS) for secure cloud hosting, database management, and transactional email delivery. These services process and store data securely under our direction.
• Financial Service Providers: We share necessary transaction data with our payment gateway strictly to process UPI payments from customers, and we utilize banking partners solely to manually settle collected funds to the Agent's bank account.
• Telecom & Messaging Partners: We share phone numbers and billing amounts with telecom operators and messaging API providers solely to deliver DLT-compliant billing SMS, WhatsApp messages, and payment links.
• Business Transfers: We may share or transfer your information in connection with any merger, sale of company assets, or financing.
• Legal Compliance: We may disclose data if required by Indian law enforcement or regulatory bodies.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. These technologies help us maintain the security of your account, prevent crashes, and save your login preferences.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required by Indian law (such as tax, accounting, or IT laws). In compliance with Indian taxation and financial laws, banking transaction records and associated account details may be retained for a period of up to 7-8 years. When we have no ongoing legitimate business need to process your personal information, we will securely delete or anonymise it.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

Data Residency: All personal information and service data are stored on secure servers located within the Republic of India (Amazon Web Services - Mumbai Region) to ensure compliance with local data residency requirements.

Security Measures: We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. Financial data, including bank account details, is encrypted at the application level using industry-standard AES-256 encryption before being stored in our databases. We maintain strict internal access controls to ensure that banking information is only accessible to authorized personnel for the purpose of fund settlement.

Disclaimer: Despite our safeguards, no electronic transmission over the Internet can be guaranteed to be 100% secure. Transmission of personal information to and from our Services is at your own risk.

7. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly collect data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and delete such data.

8. WHAT ARE YOUR PRIVACY RIGHTS?

Under the Digital Personal Data Protection (DPDP) Act, 2023 and other applicable Indian laws, Pathrika Tech Solutions acts as the Data Fiduciary for Agent registration data, and as a Data Processor for customer information entered by Agents. You have the right to:

• Request access to the personal data we hold about you.
• Request correction of inaccurate data.
• Request deletion of your data (subject to legal and accounting retention requirements).
• Withdraw your consent to data processing.

To exercise these rights:

• Agents: Log in to your account settings to update your profile, or email us.
• Customers: Please contact your Newspaper Agent directly to update your delivery or subscription details. For platform-specific data requests, you may email us at support@pathrika.in.

9. DO WE MAKE UPDATES TO THIS NOTICE?

Yes, we will update this notice as necessary to stay compliant with relevant Indian laws. The updated version will be indicated by an updated "Revised" date at the top of this document. We encourage you to review this Privacy Notice frequently.

10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at support@pathrika.in or contact us by post at: