Background

Corporate Social Responsibility (CSR) is strongly connected with the principles of Sustainability; an organization should make decisions based not only on financial factors, but also on the social and environmental consequences. Corporates must recognize that their business activities have wide impact on the societies in which they operate.

This policy shall apply to all CSR initiatives and activities taken up at the various work‐centres and locations of Paytm Payments Services Limited (hereinafter referred to as “PPSL or the Company”), for the benefit of different segments of the society, specifically the deprived, underprivileged and differently abled persons.

Definitions

• ActAct means Companies Act, 2013 read with Companies (Corporate Social Responsibility Policy) Rules, 2014 (including any statutory modification(s) or re-enactment(s) for the time being in force).
• Corporate Social Responsibility (CSR)CSR means and include but not limited to the activities as specified in this policy pursuant to Schedule VII of the Act, but contribution directly or indirectly to the political party, business done by the Company in its normal course, activities only for the benefit of employees and activities done outside India will not be considered as CSR activity.
• Net profitNet profit means the net profit of the Company as per its financial statement prepared in accordance with the applicable provisions of the Act, but shall not include the following namely:
  • Any profit arising from any overseas branch or branches of the Company, whether operated as a separate company or otherwise; and
  • Any dividend received from other companies in India which are covered under and complying with the provisions of section 135 of the Act.
• CSR ExpenditureCSR Expenditure shall include all expenditure including contribution to corpus, or on projects or programs relating to CSR activities specified in this policy as approved by Board on recommendation of CSR Committee.
• CSR CommitteeCSR Committee means the committee constituted under the provisions of Section 135 of the Act.

CSR Activities

The followings are the wide categories of the activities under which the Company may work to undertake CSR activities:

• Eradicating hunger, poverty and malnutrition, promoting health care including preventive health care and sanitation including contribution to the Swatch Bharat Kosh set-up by the Central Government for the promotion of sanitation and making available safe drinking water.
• Promoting education, including special education and employment enhancing vocation skills specially among children, women, elderly, and differently abled and livelihood enhancement projects;
• Promoting gender equality, empowering women, setting up homes and hostels for women and orphans, setting up old age homes, day care centers and such other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups;
• Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agro-forestry, conservation of natural resources and maintaining quality of soil, air and water including contribution to the Clean Ganga Fund set-up by the Central Government for rejuvenation of river Ganga;
• Protection of national heritage, art and culture including restoration of building and sites of historical importance and works of art: setting up public libraries; promotion and development of traditional arts and handicrafts:
• Measures for the benefit of armed forces veterans, war widows and their dependents, Central Armed Police Forces (CAPF) and Central Para Military Forces (CPMF) veterans, and their dependents including widows;
• Training to promote rural sports, nationally recognized sports, paralympic sports and Olympic sports;
• Contribution to the Prime Minister’s National Relief Fund or Prime Minister’s Citizen Assistance and Relief in Emergency Situations Fund (PM CARES Fund) or any other fund set up by the Central Government for socio-economic development and relief and welfare of the Schedule Castes, the scheduled tribes, other backward classes, minorities and women;
• (a) Contribution to incubators or research and development projects in the field of science, technology, engineering and medicine, funded by the Central Government or State Government or Public Sector Undertaking or any agency of the Central Government or State Government; and (b) Contributions to public funded Universities; Indian Institute of Technology (IITs); National Laboratories and autonomous bodies established under Department of Atomic Energy (DAE); Department of Biotechnology (DBT); Department of Science and Technology (DST); Department of Pharmaceuticals; Ministry of Ayurveda, Yoga and Naturopathy, Unani, Siddha and Homoeopathy (AYUSH); Ministry of Electronics and Information Technology and other bodies, namely Defense Research and Development Organization (DRDO); Indian Council of Agricultural Research (ICAR); Indian Council of Medical Research (ICMR) and Council of Scientific Industrial Research (CSIR) , engaged in conducting research in science, technology, engineering and medicine aimed at promoting Sustainable Development Goals (SDGs).;
• rural development projects;
• Slum area development, declared as such by the Central Government or any State Government or any other competent authority under any law for the time being in force;
• disaster management, including relief, rehabilitation and reconstruction activities;
• Any other funds or activities as may be notified by the Central Government, from time to time, as contribution towards CSR expenditure.

Execution process

The Company may undertake its CSR activities, as approved by the CSR Committee, directly by the Company or through a registered trust or a registered society or a company established by the Company or its holding or Subsidiary or associate company under section 8 of the Act or otherwise.

The Company may also undertake CSR activities through any trust, society or section 8 company which is not established by the Company or its holding or subsidiary or associate company, if such trust, society or section 8 company shall be having an established track record of three years in undertaking similar programs or projects or where the corpus is created exclusively for a purpose directly relatable to a subject covered in Schedule VII of the Act.

The Company may also collaborate with other companies for undertaking projects or programs or CSR activities in such a manner that the CSR Committees of respective companies are in a position to report separately on such projects or programs.

The Board/ CSR Committee should ensure that the above mentioned entities with which it undertakes CSR activity has registered itself with the Central Government in the manner as given under the Act

Utilization of fund

The Company shall utilize at least 2 percent of the average net profit made during the last three (3) immediately preceding financial years in the CSR activities as enumerated above in this policy. In any case, if in any year the Company fails to spend such amount on CSR, the Board will, in its report made under section 134 (3) (o) of Companies Act, 2013, specify the reasons for not spending the amount and, unless the unspent amount relates to any ongoing project, as described in Section 135 (6) of the Companies Act, 2013, transfer such unspent amount to a Fund specified in Schedule VII, within a period of six months of the expiry of the financial year.

Further, if the Company spends an amount in excess of the requirements as provided in Section 135 of the Act, Company may set off such excess amount against the requirement to spend under Section 135 of the Act, under the heading ‘Utilization of fund’, for up to immediate succeeding three financial years or for such time in such manner, as may be prescribed under the Act.

Surplus arising from CSR activity

The surplus arising from CSR projects, programs or activities shall not form part of the business profit of the Company.

Monitoring Mechanism

To ensure effective implementation of the CSR programmes undertaken a monitoring mechanism will be put in place by the Company. The CFO would place a monitoring report of the CSR projects under implementation to the CSR Committee. The progress of CSR programmes under implementation will be reported to Board of Directors on a regular basis. The CSR Committee will conduct impact studies on a periodic basis, about effectiveness of CSR activities on the society.

Reporting Mechanism

CSR Committee will obtain feedback from beneficiaries about the programmes and report to the Board of Directors, the feedback received from the beneficiaries of CSR Activity. Appropriate documentation of the Company’s CSR Policy, annual CSR activities, executing partners, and expenditure entailed will be undertaken on a regular basis and the same will be available on the website of the Company. CSR initiatives of the Company will also be reported in the Annual Report of the Company.

Budget monitoring:

The Company establish an accounting system to ensure proper accounting of CSR spends.

CSR Committee:

• Composition of the CSR Committee: The composition of the CSR Committee of the Board shall be as constituted by the Board of Directors from time to time in terms of the provisions of Section 135 of the Act
• Responsibility of the CSR Committee:
  • formulate and recommend the CSR Policy to the Board for approval
  • monitor the Policy from time to time and recommend changes to the Board
  • recommend the amount of expenditure to be incurred on CSR projects
  • constitute a transparent monitoring mechanism for ensuring effective and efficient implementation of the CSR projects.
• The Committee will meet atleast once in a year to discuss and review CSR activities and Policy. A quorum of two members is required to be present for the proceedings to take place. The Committee members may attend the meetings physically or via such audio-visual means as permitted under the Act.
• A member of the CSR Committee may resign by a written notice stating the reasons for such resignation, addressed to the Board of Directors of the Company. The resignation shall be effective from the date of acceptance of the resignation in the meeting of the Board of Directors or after 30 days from the date of the resignation, whichever is earlier.
• In case of the resignation of any member of the CSR Committee, the Board of Directors shall appoint a new member to fill the vacancy created as such within reasonable time. The new member shall be appointed in keeping with the constitution requirements of the CSR Committee.
• The CSR Committee will review the philanthropic activities of the Company and will provide progress update to the Board of Directors at such intervals as it deemed fit.
• The CSR Committee shall have the authority to obtain professional advice from external sources and have full access to information contained in the records of the Company as well as the powers to call such employee(s), senior official(s), Representative of CSR Partners, external consultant or such other persons and for such purpose as may be deemed expedient for the purpose of accomplishments of overall CSR Objectives laid down under the Act.

AMENDMENTS

The Board of Directors on its own and/or as per the recommendations of CSR Committee can replace or amend this policy, as and when required as deemed fit. Any or all the provisions of the CSR Policy would be subject to revision/amendment in accordance with the Regulations on the subject as may be issued from relevant statutory authorities, from time to time.

Introduction

Paytm Payment Services Limited (“PPSL”) is a payment aggregator / payment gateway that helps merchants collect payments from their end-customers.

Objective

This policy outlines a structured grievance redressal mechanism available to customers for escalating their complaints with PPSL. PPSL will ensure to deal with all complaints in a transparent and timely manner.

Governance Structure

Oversight Framework: The Board of Directors of PPSL will be responsible for the overall compliance to this Policy and Compliance Team will act as a custodian to this policy. Each line of businesses are responsible for their respective processes as detailed in this policy.

Terms of Reference

• “Complaint” means a representation in writing or through other modes as specified in this policy, alleging deficiency in service on the part of PPSL and seeking relief thereto. Further, complaints shall not include enquiries or request received from the customers.
• “Complainant” can be a customer lodging complaint with PPSL.
• “Customer / Merchant” refers to the merchant on boarded by PPSL on platform to use PPSL’s payment solution to collect payments from end-customers.

Redressal Mechanism

Level 1: Merchant Care Executive

If the Complainant has a grievance, they can connect with the support team via the Paytm merchant application or the Paytm merchant dashboard.

Alternatively, complainant can also reach via email at pg.support@paytmpayments.com

Resolution Time*:

Provide a response within 4 working days of PPSL receiving the complaint.

Level 2: Grievance Officer

If timely resolution is not provided at Level 1 or Complainant is not satisfied with the resolution provided, the customer may escalate the complaint to the Nodal Officer.

The Nodal Officer shall ensure that an effective resolution* is provided to the customer within 15 working days from the date of escalation of grievance.

The details of Nodal Officer are as under:

Name of the Principal Nodal Officer: Mr. Anubir Singh Anand

Email id: nodal.officer@paytmpayments.com

*Resolution time does not include time taken by the Complainant to provide required information/ documentation.

Grievance Redressal Policy

If any case / transaction is related to a third party or outside the PPSL, then the TAT will be dependent on the respective Partner Banks/Network Providers etc. Resolution time will include this TAT along with the PPSL’s internal resolution time.

In exceptional circumstances, where PPSL is unable to reach a conclusion within 15 working days, PPSL will respond with a rationale and indication as to when a final response can be expected, which will be within 30 business days of PPSL receiving the complaint.

The Complainant must approach Level 2 with a previous Service Request Number on which the PPSL did not respond or satisfactory response was not provided. This is to ensure that the Complainant gets correct resolution in a timely manner.

Acknowledgement and Tracing of Complaints:

The PPSL shall provide an automated ticket number (Service Request Number) at each level to enable the complainant to track status.

PPSL aims to acknowledge the complaints promptly post receiving the complaint.

Your privacy is of utmost importance to us and protection of your Personal Data as disclosed by you to us is a key commitment for us. During your usage of our platform, we may collect and generate various data points about you as elaborated below. In this, we are governed by the provisions of applicable law in India including the Information Technology Act 2000 and the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 to maintain the privacy of your Personal Data. We collect and process your Personal Data only to the extent necessary for us to process your requirement(s) and in the manner as detailed hereinafter below in section II and III, and in accordance with such applicable law. In case you choose not to share your Personal Data as required, with us, we may not be able to carry out your transaction.

"Personal Data" means data relating to you that is directly or indirectly identifiable, having regard to any characteristic, trait, attribute or any other feature of your identity or any combination of such features with any other information. Personal Data does not mean information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force. Personal Data includes Sensitive Personal Data, which relates to password, financial information such as bank account or credit card or debit card or other payment instrument details, physical, physiological and mental health condition, sexual orientation, medical records and history, biometrics or any other data categorised as sensitive under applicable law in India.

Types of Information we collect

We may collect following information from you, as you have disclosed to us:

• Personal details (e.g. name, contact details including, residential address, date of birth, documents such as identity card / passport details / Aadhaar details / PAN / Voter ID / driving license, and/or education details) provided by you to us to avail various products/services from us.
• Your details including transaction history, balances, payment details, for effecting transfer of monies through various payment channels provided by us.
• Financial details (e.g. income, expenses, and/or credit history) needed as part of request for some of our products/services;
• Images of documents/ photos required to avail any of our products/services.
• voice recordings of our conversations with our customer care agent with you to address your queries/grievances;
• employment details (e.g. occupation, positions held, employment history, salary and/or benefits) as part of our record retention for credit/various product evaluations or required under applicable law including Prevention of Money Laundering (Maintenance of Records) Rules, 2005
• specimen signature(s) for processing of your instructions received by us through our various payment and delivery channels;
• opinions provided by you to us by way of feedback or responses to surveys;
• Information obtained from your mobile device by way of using our app like device location, communication information including phone number, SIM Serial Number, contacts and call logs, device information (including storage, model, IMEI, Network Carrier information), transactional and promotional SMS/app notifications;
• Access to your mobile camera device for the functioning of many in-app functionalities for recording video including, but not limited to video KYC process and scan & pay etc.;
• Access to the microphone to record audio for carrying out video KYC process and voice typing etc.;
• Access to files from your mobile device such as audio, video files for the functioning of many in-app functionalities including, but not limited to in-app chat;
• Access to WiFi details through SSID information from your device, to notify users about the security of WiFi network;
• Access to the Near field Communication (NFC) chip on device to enable tap to pay functionality (only for NFC enabled devices).

Sharing and Storage of your Personal Data

Any Personal Data that we have access to shall never be shared without your consent.

In various processes / submission of applications / availment of product / service offerings, we even seek your explicit consent to use / share your Personal Data.

In our business and operational processes, we only share the data on a partial and “need-to-know” basis to designated personnel or partners or service providers.

We may process, store and retain your Personal Data on our servers where the data centers are located, and/or on the servers of third parties having contractual relationships with us. All Sensitive Personal Data is stored in India. We will retain your data for the period that you continue to be our customer and for such period as required to comply with any obligation under any law for the time being in force.

We will share your data with competent / legal / statutory / regulatory agencies / authorities or partners / service providers acting on our behalf (as the case may be) in following cases:

• For enabling the provision of the products / services availed by you, strictly on a “need to know” basis and subject to applicable laws.
• Where it is directed or required by legal / regulatory / statutory / governmental authorities / judiciary under any applicable laws / regulations or judicial pronouncement though a legally obligated request.

When you make purchases through our services, we may collect and store information about you to process your requests and automatically complete forms for future transactions, including (but not limited to) your phone number, address, email, billing information and payment preferences. This information may be shared with third-parties which assist in processing and fulfilling your requests, including Payment Card Industry (PCI) compliant payment gateway processors, and for providing you with products / services to better serve your needs and interests. Such sharing shall be in accordance with your instructions and subject to appropriate confidentiality and security requirements.

Usage of Your Personal Data

We use your Personal Data in our business activities for providing our partners’ products / services and to perform, among other actions, the following:

• To facilitate the transactions or report on these transactions;
• To undertake research and analytics for offering or improving our products / services and their security and service quality;
• To check and process your requirements submitted to us for products / services and / or instructions or requests received from you in respect of these products / services;
• To share with you, updates on changes to the products / services and their terms and conditions including platform’s terms and conditions;
• To take up or investigate any complaints / claims / disputes;
• To respond to your queries or feedback submitted by you;
• To verify your identity for us to provide products / services to you;
• To carry credit checks, screenings or due diligence checks as lawfully required by us;
• To monitor and review products / services from time to time;
• To undertake financial / regulatory / management reporting, and create and maintain various risk management models;
• To conduct audits and for record keeping purposes;
• To enable us to show you advertisements which are relevant to you and your interests, selective offers and promotions, search results, location-based services;
• To auto populate such third party pages basis your click on advertisement instances on our website and your proceeding to such pages;
• To comply with the requirements of applicable laws / regulations and / or court orders / regulatory directives received by us;
• To undertake any measure to provide medical treatment or health services to you during an epidemic, outbreak of disease or any other threat to public health or to ensure your safety, or to provide assistance or services to you during any disaster or any breakdown of public order.

Purging of your Personal Data

You may choose to delete your account at any point of time by making such choice in One97’s desktop website, mobile WAP site or mobile application. With this we will no longer provide your data for external processing as mentioned above. However, we retain your Personal Data as long as the purpose for its usage exists, after which the same is disposed off by us except for any record retention required as per applicable law. The provisions of various laws require your transaction logs to be stored for longer periods post the deletion of an account. Further, in the event of the pendency of any legal / regulatory proceeding or receipt of any legal and / or regulatory direction to that effect, we may be required by the law of the land to retain your Personal Data for longer periods.

Cookie Policy

• Please note that a “cookie” is a small piece of information stored by a web server on a web browser so it can be later read back from that browser.
• We may use cookie and tracking technology depending on the features offered.
• No Personal Data will be collected via cookies and other tracking technology; however, if you previously provided Personal Data, cookies may be tied to such information.

Links to other websites

Our website may contain links to other websites which are not maintained by us. This privacy policy only applies to us. You are requested to read the other websites’ privacy policies when visiting these websites.

Reasonable Security Practices and Procedures

We take various steps and measures to protect the security of your Personal Data from misuse, loss, unauthorised access, modification or disclosure. We use latest secure server layers encryption and access control on our systems. Our safety and security processes are audited by a third party cyber security audit agency from time to time.

We have provided multiple levels of security to safeguard your app by Login / Logout option, and App Lock feature for payments, that can be enabled by you. We also ensure the device binding so that the same login cannot be used on different device without any additional authentication / OTP. Please do not share your Account’s login, password and OTP details with anybody.

When you submit credit or payment card information, we encrypt the information in compliance with Payment Card Industry (PCI) data security standards.

While we observe reasonable security measures to protect your Personal Information on all our digital platforms, security risks may still arise for reasons outside of our control such as hacking, virus dissemination, force majeure events, breach of firewall etc. Please note that the above mentioned measures do not guarantee absolute protection to the Personal Information.

Contact us

You may contact us on any aspect of this policy or for any discrepancies / grievances with respect to your Personal Data, by writing to our Grievance Officer as per the details provided below:

Name: Binu Varghese Designation: Vice President - Legal Email ID: privacy.grievanceofficer@paytm.com One97 Communications Limited Skymark One, Sector 98, Noida - 201304.

Policy Review & Updates

This policy will be reviewed by us as and when required and the same may be subject to change at any point in time. The latest & most updated policy can always be found at https://paytm.com/company/terms-and-conditions

While we will make reasonable efforts to keep you posted on any updates to this privacy policy, to make sure that you are aware of any changes, we recommend that you review this policy periodically.

This Privacy Policy shall apply uniformly to One97’s desktop website, mobile WAP site & mobile applications.

One97 reserves the right to modify/update this Privacy Policy. We will post the changes to our Privacy Policy, if any, on this page. Please check the “Last updated” legend at the bottom of this page to see when this Privacy Policy was last updated. We encourage you to check the same to be informed of how One97 is committed in protecting your information and providing you with the improved content.

In this policy, the words “we”, “ours” and/or “us” refer to One97 Communications Limited and “you” and/or “your” refer to our customers.

Governing Law & Jurisdiction

This policy will be governed by and construed in accordance with the laws of India and subjected to the exclusive jurisdiction of Courts of New Delhi.

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