Privacy Policy

This privacy policy will explain how our organisation, Vay Network Services Pvt. Ltd. (referred to here as “Vayana”), uses the personal data we collect from you when you use our services. Please note that Vayana provides several products and services, each with their own personal data processing needs, some of which are more extensive than others. The personal data we collect from you is limited to the specific products and services you have signed up for, and therefore, some clauses in this privacy policy may not be applicable to you.

Topics:

  1. What data do we collect?
  2. How do we collect your data?
  3. How will we use your data?
  4. How do we store your data?
  5. Marketing
  6. What are your data protection rights?
  7. What are cookies?
  8. How do we use cookies?
  9. What types of cookies do we use?
  10. How to manage your cookies
  11. Privacy policies of other websites
  12. Changes to our privacy policy
  13. How to contact us

What data do we collect?

It is important to note that this privacy policy covers the processing of personal data only, and not business data. Personal data refers to information that is related to an identifiable individual. This may include information such as name, address, contact details, and other identifying information. Personal data is typically used to identify, contact, or locate an individual, or to provide personalized services to that individual. Business data, on the other hand, refers to information that is related to a business or organization. This may include information such as financial data, sales data, customer data, inventory data, and other information related to the operations of the business. Business data is typically used to understand the performance of the business, make informed decisions, and improve operations.

The main difference between personal data and business data is that personal data is related to individuals, while business data is related to the operations of a business. Personal data is typically subject to more stringent privacy regulations, as it is often sensitive and can be used for malicious purposes if mishandled. Business data, while also important, is typically less sensitive and may be subject to different regulations and standards.

To provide our services, Vayana Network collects the following personal data:

Information you provide:

  • Personal information (name, email address, physical address, phone number)
  • Unique identification number, which includes a permanent account number (PAN), Goods and Services Tax Identification Number (VAT), or Taxpayer Identification Number (TIN). Note that unique identification numbers related to business entities are not personal data.
  • Sensitive personal information (your password, financial information that includes account details, credentials and transaction data)

Your usage:

  • Information on how you use our products and services, such as pages visited and average time spent on Vayana’s platform.
  • Information from and about the computers, phones, or other devices you use to access our products and services, and we combine this information across different devices you use. This information includes device attributes (such as the operating system, hardware and software versions, and browser type), device identifiers (such as unique identifiers and device IDs), network and connections (such as your mobile phone number and IP address) and cookie data (such as information on your preferences and cookie ID).

Transaction information:

  • To provide our products and services, Vayana accesses and collects information on the status of the fulfilment of transactions, including your payment history information.

Information from partners:

  • Trading partners, banks and other financial institutions can send us your information, allowing Vayana to provide our products and services to you.

How do we collect your data?

You directly provide Vayana with most of the data we collect. We collect data and process data when you:

  • Register online or sign up for any of our products or services
  • Voluntarily complete a customer survey or provide feedback by contacting us via email or phone.
  • Use or view our platform via your browser’s cookies or web beacons.

Vayana may also receive your data indirectly from the following sources:

  • Our trading partners with whom Vayana is doing business
  • Partners such as banks and financial institutions that provide a range of financing services to corporates and enterprises in the area of domestic trade finance.
  • Third-party service providers that help us analyse certain online activities, such as measuring the performance of Vayana’s online campaigns or visitor activity.

How will we use your data?

Vayana will not sell or rent your data to any other party, for any reason, at any time. Vayana collects your data so that we can:

  • Provide you with our products or services and manage your account.
  • Share marketing communications and newsletters, contact you with special offers on other products and services we think you might like and let you know about our policies and terms. We also use your information to respond to you when you contact us.
  • Provide you with the following products and services:
    • payment aggregation, by digitising and automating financial transactions and managing incoming and outgoing payments;
    • transaction platform, tracking financial transactions, automating transaction workflows and providing end-to-end supply chain financing services;
    • a loan management system, that includes smart underwriting and monitoring tools such as account setup and monitoring, GST analytics, the Vayana Good Business Score, interest and fee calculation and a funds settlement service;
    • international trade finance services platform that includes a transparent bidding mechanism using know your customer (KYC), due diligence and anti-money laundering (AML) checks;
  • Analyse your usage of Vayana’s products and services
  • Deliver any administrative notices, alerts and communications to you that are relevant to your use of our products or services
  • Fulfil your requests for certain products and services.
  • Enforce Vayana’s terms of use.
  • Use the information we have to develop, test and improve our products and services, including by conducting surveys and research and testing and troubleshooting new products and services.

Your information is shared with others in the following ways:

  • To operate our products and services, we work with trading partners, banking partners, and a Credit Bureau established under the rules and regulations of the country, and therefore share your personal information with these entities to the extent necessary.
  • We also work with third-party contractors providing Vayana services to operate our products and services. We share your personal information with these third-party contractors to operate our products and services and require them to be bound by the same privacy restrictions described in this privacy policy.
  • We may use third-party service providers to provide advertising, measurement, marketing and analytics services to Vayana, and these providers may use cookies to provide those services to us. We do not share any personal information about our customers with these third-party service providers, and these service providers do not collect any personal information on Vayana’s behalf.

Information sharing required by law:

  • Vayana reserves the right to disclose your personal information when: it is necessary and appropriate to enforce our rights against you or in connection with a breach of this privacy policy or with Vayana’s terms of use; to prevent prohibited or illegal activities; or when required by any applicable law, rule, regulation, subpoena, or any other legal process or request. Vayana retains sole discretion in determining whether such disclosure is necessary or appropriate.

Transfer of ownership:

  • If the ownership or control of all or parts of our products and services or their assets changes, we may transfer your information to the new owner.
  • In case of a sale, acquisition, merger, re-organisation or other transfer involving Vayana, your information may be transferred to a third party upon your authorisation which will not be unreasonably withheld. This is to ensure the continuation of the processing of transactions.
  • Should such a transfer occur, Vayana will use its best efforts to require that the new combined entity will follow this privacy policy with respect to your personal information, as and to the extent required by applicable law, and to require that you receive prior notice if your data could be used in a manner that is contrary to this privacy policy.

How do we store your data?

Vayana stores your data in a secure third-party facility. Our databases are protected from general employee access, both physically and logically. We store a salted digest for your password so that it cannot be recovered even by Vayana. All backup storage devices are encrypted.

Vayana uses a combination of firewall barriers, encryption techniques and authentication procedures, among others, to maintain your online session’s security and protect accounts and systems from unauthorised access. When you register for our products and services, Vayana requires you to set a password for your privacy and security. To access your account, we also generate a pseudonymous username to protect your privacy.

From the time you submit your login information, including your username and password, the communication between your device and Vayana is encrypted using secure socket layer (SSL) technology. SSL enables you and our systems to communicate in a way that is designed to prevent eavesdropping, tampering and message forgery. In addition, SSL encryption protects data transmissions between your browser and Vayana’s servers, such as your registration information for our products and services and your account credentials.

Vayana will keep your personal information and transaction data until it is no longer necessary to provide our products and services. This is a case-by-case determination that depends on the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. Vayana stores all transaction data and identifiable information related to those transactions separately. Once the case-by-case determination has been made, or upon your request to delete your data, whichever is earlier, we will delete your data by permanently expunging all identifiable information from Vayana’s primary production servers, and further access to your account will not be possible. As part of Vayana’s “privacy by design” strategy, we will also promptly disconnect any connection Vayana had established to your account information and delete all account credentials. Once this process is complete, anonymised data, consisting of aggregated data and any remaining transactional or other data that has been stripped of any identifiable information, may remain on Vayana’s production servers indefinitely.

Separately, in order to improve our products and services, Vayana also stores pseudonymised and anonymised data derived from the data we collect from you. Data pseudonymisation is the process of replacing personal information with a pseudonym or code. This makes it much harder for anyone who may see the data to identify the actual person behind the data. Pseudonymisation helps to protect privacy while still allowing the data to be used for research or analysis purposes.

Data anonymisation is the process of removing or obscuring personally identifiable information from a dataset so that the individuals represented in the data cannot be identified. This is typically done by replacing or removing any direct identifiers, such as names, addresses, or social security numbers, and aggregating or generalizing the remaining data so that it cannot be linked back to any specific individual. The purpose of data anonymisation is to protect the privacy and confidentiality of individuals while still allowing the data to be used for research, analysis, or other purposes. Anonymised data can be used to identify trends or patterns in a population without revealing any personal information about the individuals in that population.

Vayana takes specific technological measures, such as salting and data masking, and organisational measures, such as restricting general employee access, to ensure that any anonymised or pseudonymised data cannot be attributed to a particular individual or business entity without requiring additional information.

Your data may also remain on a backup server or other storage media. We keep these backups to ensure Vayana’s continued ability to provide our products and services in the event of malfunction or damage to Vayana’s primary production servers. Vayana will also keep audit data on its servers to comply with our legal obligations.

However, it is important to understand that these precautions apply only to Vayana’s products, services, websites and systems. While Vayana will have contractual agreements with third parties around data security, we do not exercise any control over how your information is stored, maintained or displayed by third parties or on third-party sites.

Marketing

Vayana would like to send you information about our products and services that we think you might like.

If you have agreed to receive marketing, you may always opt-out at a later date.

You have the right at any time to stop Vayana from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please click here.

What are your data protection rights?

Vayana would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request Vayana for copies of your personal data. We may charge you a small fee for this request

The right to rectification – You have the right to request that Vayana correct any information you believe is inaccurate. You also have the right to request Vayana to complete the information you believe is incomplete. Vayana shall not be responsible for the authenticity of the personal information or sensitive personal data or information supplied by you.

The right to not provide information – You have the option not to provide data or information that Vayana seeks to collect. In such a situation, Vayana shall have the option not to provide products or services for which we sought to collect your information.

The right to withdraw consent for processing – You have the right to request that Vayana restrict the processing of your personal data by withdrawing your consent given earlier to us, with certain conditions. You must send such a withdrawal of consent to Vayana in writing. In case of your withdrawal of consent, Vayana shall have the option not to provide products or services for which your consent was sought.

The right to data portability – You have the right to request that Vayana transfer the data that we have collected to another organisation or directly to you under certain conditions.

The right to erasure – You have the right to request that Vayana erase your personal data under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: legal@vayana.com

Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies or similar technology. Our cookies are encrypted so that only Vayana can interpret the information stored in them.

For more general information on how cookies work, visit allaboutcookies.org.

Our websites do not allow cookies of third parties.

How do we use cookies and web beacons?

Vayana uses cookies and web beacons in a range of ways to improve your experience on our websites, including:

  • Keeping you signed in.
  • Understanding how you use our website.
  • Track and store preferential information about you.
  • To personalise the content shown to you through our website, for example, by limiting the number of times you see certain information or to help determine the information or preference settings that help us serve you better.

What types of cookies do we use?

There are a number of different types of cookies; however, our website uses:

  • Functionality – Vayana uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and the location you are in. Only first-party cookies are used.

How to manage cookies

You can set your browser not to accept cookies, and the above website (allaboutcookies.org) tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

Privacy policies of other websites

Vayana’s websites and platforms contain links to other websites. Our privacy policy applies only to our websites, products and services, so if you click on a link to another website, you should read their privacy policy.

Changes to our privacy policy

Vayana keeps its privacy policy under regular review and places any updates on this webpage. This privacy policy was last updated on 7-March-2024.

How to contact us

If you have any questions about Vayana’s privacy policy or the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us. Email us at: legal@vayana.com