Cookies Policy

1. INTRODUCTION

This Cookies Policy (“Policy”) explains how Erupaiya, a brand owned and operated by Innoplix IT Private Limited (“Company”, “we”, “our”, or “us”), uses cookies and similar tracking technologies when you access or use our platform, website, applications, APIs, dashboards, or related services (collectively, the “Platform”).

Erupaiya provides business-to-business (B2B) financial and payment facilitation services including:

• Domestic Money Transfer (DMT)
• Aadhaar Enabled Payment System (AEPS)
• Micro ATM (mATM) services
• Mobile Point of Sale (mPOS)
• Bharat Bill Payment System (BBPS) for utility payments

This Policy must be read in conjunction with our Privacy Policy and Terms of Use.

2. WHAT ARE COOKIES

Cookies are small text files placed on your device (computer, mobile device, tablet) when you visit or interact with our Platform. These cookies enable us to recognize your device, store preferences, enhance functionality, and improve user experience.

Cookies may be:

• Session Cookies – deleted when you close your browser
• Persistent Cookies – remain on your device for a defined period
• First-party Cookies – set by us
• Third-party Cookies – set by external service providers

3. LEGAL BASIS UNDER DPDP ACT, 2023

In accordance with the Digital Personal Data Protection Act, 2023, we process personal data collected via cookies based on:

3.1 Consent (Section 6 of DPDP Act)

We obtain free, specific, informed, unconditional and unambiguous consent before placing non-essential cookies on your device.

3.2 Legitimate Uses (Section 7 of DPDP Act)

Certain cookies are deployed without explicit consent where permitted for:

• Compliance with legal obligations
• Prevention of fraud and cyber threats
• Ensuring network and information security
• Provision of services requested by the user

4. TYPES OF COOKIES WE USE

4.1 Strictly Necessary Cookies

These cookies are essential for the functioning of our Platform and cannot be disabled.

Examples:

• Authentication and login sessions
• Secure transaction processing
• Fraud detection and prevention
• Load balancing

4.2 Functional Cookies

These cookies enhance usability and remember your preferences.

Examples:

• Language settings
• User interface customization
• Saved preferences

4.3 Performance and Analytics Cookies

These cookies help us understand how users interact with the Platform.

Examples:

• Page visit tracking
• Error logging
• Usage statistics

4.4 Security and Compliance Cookies

Given the fintech nature of our services, these cookies are critical.

Examples:

• Transaction monitoring
• Device fingerprinting
• Suspicious activity detection
• Regulatory audit logs

4.5 Third-Party Cookies

We may allow trusted third-party partners (e.g., analytics providers, payment gateways) to place cookies.

These entities are contractually bound to comply with:

• Applicable Indian laws
• Data protection standards
• Confidentiality obligations

5. PURPOSE OF COOKIE USAGE

The Company uses cookies and similar tracking technologies for the following lawful and operational purposes, in compliance with applicable laws including the Digital Personal Data Protection Act, 2023 and regulatory frameworks issued by the Reserve Bank of India:

• Secure Enablement of Financial Transactions: To facilitate and ensure the integrity, confidentiality, and successful execution of B2B financial transactions across services such as Domestic Money Transfer (DMT), AEPS, mATM, mPOS, and BBPS, including session continuity, transaction validation, and encryption support mechanisms.
• User Authentication and Access Control: To verify user identity, manage authenticated sessions, enforce access controls, and prevent unauthorized or fraudulent access to the Platform, including multi-factor authentication support and device recognition.
• Regulatory Compliance and Reporting: To comply with applicable statutory, regulatory, and supervisory requirements, including guidelines, circulars, and directions issued by the Reserve Bank of India and other competent authorities, including maintenance of logs, traceability of transactions, and audit readiness.
• Platform Performance and Optimization: To monitor system performance, diagnose technical issues, analyze user interaction patterns, and improve functionality, reliability, and user experience of the Platform.
• Fraud Detection, Risk Mitigation, and Security Monitoring: To identify, prevent, and investigate suspicious activities, unauthorized transactions, cyber threats, or misuse of services, including behavioral analytics, anomaly detection, and risk scoring mechanisms.
• Audit Trails and Legal Compliance: To maintain comprehensive records and audit trails necessary for internal governance, statutory audits, dispute resolution, forensic analysis, and compliance with legal obligations under applicable laws.

6. CONSENT MECHANISM

In compliance with the DPDP Act, we implement:

• Cookie consent banners/pop-ups upon first access
• Granular consent options (accept/reject categories)
• Ability to withdraw consent at any time

You may manage cookie preferences through:

• Browser settings
• Platform cookie management tools

7. DATA COLLECTED THROUGH COOKIES

Cookies may collect:

• IP address
• Device identifiers
• Browser type and version
• Operating system
• Transaction metadata
• Session identifiers
• Usage behavior

Where such data qualifies as personal data under the DPDP Act, it is processed in accordance with applicable legal obligations.

8. DATA RETENTION

We retain cookie data only for as long as necessary to:

• Fulfill the purpose for which it was collected
• Comply with legal and regulatory obligations
• Resolve disputes and enforce agreements

Retention periods vary depending on the type of cookie and applicable laws.

9. YOUR RIGHTS UNDER DPDP ACT

As a Data Principal under the Digital Personal Data Protection Act, 2023, you have the right to:

• Access information about your personal data
• Request correction or erasure
• Withdraw consent at any time
• Grievance redressal
• Nominate another individual in case of incapacity

To exercise your rights, contact us using the details below.

10. THIRD-PARTY DISCLOSURES

We may share cookie-derived data with:

• Payment processors
• Regulatory authorities
• Technology service providers
• Fraud detection agencies

Such disclosures are made:

• Under contractual safeguards
• In compliance with applicable laws
• On a need-to-know basis

11. CROSS-BORDER DATA TRANSFERS

Where cookie data is transferred outside India:

• Transfers are made in compliance with DPDP provisions
• Adequate safeguards are implemented
• Transfers are restricted to permitted jurisdictions

12. SECURITY MEASURES

We implement appropriate technical and organizational measures including:

• Encryption protocols
• Access controls
• Network security systems
• Continuous monitoring and auditing

13. CHANGES TO THIS POLICY

We reserve the right to update this Policy periodically.

Changes will be:

• Posted on this page
• Notified via Platform or email where required

Continued use of the Platform constitutes acceptance of the updated Policy.

14. GRIEVANCE REDRESSAL & CONTACT DETAILS

In accordance with the DPDP Act, we have appointed a Grievance Officer.

Grievances will be acknowledged and resolved within the timelines prescribed under applicable law.

15. GOVERNING LAW

This Policy shall be governed by and construed in accordance with the laws of India, including but not limited to the provisions of the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000, and rules and regulations framed thereunder, as may be amended from time to time.

Subject to any dispute resolution mechanism specified in the Company’s Terms of Use, the courts and tribunals having competent jurisdiction at Pune, Maharashtra, India shall have exclusive jurisdiction over all matters arising out of or in connection with this Policy.

16. ACKNOWLEDGEMENT

By accessing, browsing, or using the Platform, you expressly acknowledge that you have read, understood, and agree to be bound by this Cookies Policy and consent to the use of cookies and similar tracking technologies as described herein, in accordance with applicable laws including the Digital Personal Data Protection Act, 2023.

Such acceptance shall constitute a valid and informed consent for the processing of personal data, where applicable, for the purposes specified under this Policy. If you do not agree with the terms of this Policy, you are advised to discontinue use of the Platform and disable cookies through your browser settings, except for those cookies that are strictly necessary for the functioning of the Platform.

Continued use of the Platform following any updates or modifications to this Policy shall be deemed to constitute your irrevocable acceptance of such revised terms.