1. WHO IS WIBMO AND HOW DOES THE WIBMO PRIVACY STATEMENT WORK?

PayU Digital Lab, ("Wibmo", "we", "our", "us") is a company incorporated in India having its registered office at No 3/1, Ground Floor, Kothari Adonis, Sarvagna Nagar, Ward No. 85, Binnamangala, Bengaluru, Karnataka - 560038, India, with CIN no. U72200KA2000PTC028279.

Wibmo provides digital technology solutions to banks, financial institutions, and merchants ("Clients"), including authentication services, payment gateway solutions, fraud and risk management tools, pre-paid product technology solutions, and digital platforms ("Services"). Wibmo belongs to the PayU group of companies. PayU belongs to the Prosus Group of companies.

This Wibmo Privacy Statement explains how Wibmo collects, stores, uses, discloses, transfers, and processes Personal Information (including Sensitive Personal Information) when you create an account, perform a transaction, or raise a request with Clients to whom Wibmo provides Services ("Transaction").

By entering into a direct arrangement with Wibmo, or by making a Transaction through a Client, directly or indirectly, you confirm that you have read, understood, and agreed to this Wibmo Privacy Statement and consent to the processing described in it.

Wibmo may act as a data controller or as a data processor depending on the context and the contract with the Client. When acting as a processor, Wibmo processes data under the Client's instructions, and the Client remains responsible for required disclosures and lawful data collection.

We recommend that you revisit this page periodically to review the latest version of this Wibmo Privacy Statement.

2. WHAT IS PERSONAL INFORMATION AND WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT OR RECEIVE ABOUT YOU?

"Personal Information" means any information that relates to an individual, which directly or indirectly, in combination with other information available or likely to be available, can identify such individual.

"Sensitive Personal Information" includes data such as financial details (bank account, card details, payment instrument details), passwords, biometric information, sexual orientation, health conditions, and medical records/history. Information freely available in the public domain is not treated as Sensitive Personal Information.

Depending on your role and how you interact with us (directly or through Clients), we may collect, use, receive, store, analyze, combine, transfer, or otherwise process different categories of Personal Information (including Sensitive Personal Information).

We may also process non-personal/anonymized information, such as statistical or demographic data. Wibmo does not control third-party websites/plugins linked through Services and is not responsible for their privacy practices.

3. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

How we collect Personal Information (including Sensitive Personal Information) depends on the context:

1. Where information is provided to a merchant, bank, or other user of Wibmo Services, information may be collected:
   1. directly from you, under contract, or from public sources as permitted by law;
   2. from financial institutions and fraud prevention agencies for risk/fraud analysis;
   3. through cookies and web beacons while using our website/platforms.
2. Where Wibmo processes information on behalf of a Client (as data processor), information may be collected:
   1. directly from you through websites, applications, platforms, or service flows;
   2. from Clients and authorized third parties, including business partners and service providers:
      1. where Client has contractual/legal basis to share data;
      2. for identity verification, fraud prevention, and anti-money laundering checks.
   3. from publicly available sources as permitted by law;
   4. through cookies and similar technologies during Transactions.

4. WHAT ARE THE LAWFUL GROUNDS THAT WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

As a data controller, Wibmo processes your Personal Information (including Sensitive Personal Information) based on your consent and the contract you enter into with us, subject to applicable laws in India.

As a data processor for Clients, Wibmo processes data under Client authorization and contract. The Client is responsible for obtaining approvals and providing disclosures to you as required by law.

If you decline to provide certain information, Wibmo may be unable to provide some or all Services or features that depend on such data.

5. THE PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL INFORMATION.

We process Personal Information (including Sensitive Personal Information) for purposes such as:

1. enabling Clients to provide their services, including transaction processing and card issuance;
2. providing contracted Services such as verification/authentication of Transactions, KYC, and due diligence on behalf of Clients.

6. WHEN AND TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?

Wibmo discloses Personal Information only to personnel with a strict business need and confidentiality obligations. Wibmo may share information with:

1. sub-processors, service providers, or vendors under contract;
2. authorized financial institutions, banking partners, and service providers involved in payment processing and settlement;
3. entities involved in merger/acquisition/restructuring, subject to required notifications and safeguards;
4. government/regulatory/law enforcement agencies where required by law.

7. INTERNATIONAL DATA TRANSFERS

Your Personal Information (including Sensitive Personal Information) may be processed in India or other jurisdictions where permitted by applicable law. Wibmo follows PayU's Global Privacy Program.

If data is transferred outside India, we ensure service providers maintain equivalent or higher levels of data protection as required by applicable law.

8. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

Wibmo retains Personal Information (including Sensitive Personal Information) as required by contract and applicable law. As a processor, Wibmo acts per Client instructions for return or deletion. As a controller, Wibmo retains information for as long as necessary for legal, compliance, and business requirements.

9. WHAT ARE YOUR RIGHTS?

You may exercise privacy rights under applicable data protection laws. When Wibmo acts as controller, Clients can exercise rights as per contract and policy terms. When Wibmo acts as processor, requests should be addressed to the Client (controller), and Wibmo acts on Client instructions.

10. SECURITY: HOW WE PROTECT & STORE PERSONAL INFORMATION

Wibmo maintains physical, technical, managerial, and operational safeguards to protect Personal Information and Sensitive Personal Information. Wibmo follows payment industry security standards and regularly reviews its security controls and procedures.

Wibmo has breach-response procedures in place and will notify relevant parties and authorities where required by law.

11. COOKIES AND OTHER TECHNOLOGIES

Wibmo uses cookies, web beacons, and similar technologies on its websites/platforms. Cookies are small text files stored on your device to remember information and improve services.

We may use: Targeting Cookies (ad relevance), Performance Cookies (analytics and optimization), and Strictly Necessary Cookies (core functionality).

For browser-specific cookie controls, refer to your browser support pages. For more information, visit www.allaboutcookies.org.

12. MINORS

Wibmo does not knowingly collect Personal Information (including Sensitive Personal Information) of minors. Where required, the Client must obtain prior consent from parents/guardians. If minor data is processed without required consent, please contact the relevant Client.

13. CHANGES TO THE WIBMO PRIVACY STATEMENT

This Wibmo Privacy Statement may change over time. The latest version is published on Wibmo's website. Your continued use of services confirms acceptance of the updated statement.

14. HOW TO CONTACT US

The controller of this privacy statement is PayU Digital Lab, (Wibmo), with registered office at No 3/1, Ground Floor, Kothari Adonis, Sarvagna Nagar, Ward No. 85, Binnamangala, Bengaluru, Karnataka - 560038, India, CIN no. U72200KA2000PTC028279.

For any query or concern related to information processing, write to us at dpo@wibmo.com.

Grievance Officer
PayU Digital Lab, (Wibmo),
No 3/1, Ground Floor, Kothari Adonis,
Sarvagna Nagar, Ward No. 85, Binnamangala,
Bengaluru, Karnataka - 560038, India,