Privacy Policy

1. Who we are

Yungly Pay is an early-stage fintech concept founded by Adhil Rahman A, based in Kerala, India. The product is currently in prototype and partnership exploration stage, focused on building a teen-first prepaid UPI wallet through licensed banking/PPI partners.

We operate the Yungly Pay website (yunglypay.in). When the product launches through a licensed partner, the Yungly Pay mobile application will be the primary interface for Indian teenagers.

For the purposes of the Digital Personal Data Protection Act, 2023 (DPDP Act) and the Information Technology Act, 2000 (IT Act), the data fiduciary will be confirmed upon formal company registration and partner onboarding.

2. Data we collect

When the product launches through a licensed partner, we plan to collect the following categories of personal data:

• Identity data: name, date of birth, gender, photo ID (for KYC)
• Contact data: mobile number, email address
• Guardian data: parent/guardian name, mobile number, and consent record (required for users under 18)
• Financial data: wallet balance, transaction history, linked bank account or UPI details
• Device data: device type, OS version, IP address, app version
• Usage data: features used, time spent in app, click patterns
• KYC data: Aadhaar number (masked), PAN (where applicable), selfie for liveness check

We will never ask for your school grades, social media passwords, or location unless strictly required for a feature you have opted into.

3. Why we collect it

• To provide the service: create your wallet, process payments, send money
• To verify your identity: as required by RBI guidelines on prepaid payment instruments (PPIs)
• To keep you safe: fraud detection, transaction monitoring, account security
• To communicate with you: transaction alerts, support responses, important updates
• To improve the product: understand how users use the app so we can make it better
• To comply with law: RBI regulations, DPDP Act 2023, IT Act 2000, PMLA requirements

4. How we share data

We do not sell your personal data. When the product launches, data will be shared only in these cases:

• Banking/PPI partners: to process transactions and maintain your wallet (bound by strict data processing agreements)
• KYC providers: third-party verification partners to authenticate your identity as required by RBI
• Payment networks: NPCI/UPI infrastructure to process transactions
• Legal authorities: if required by law, court order, or to prevent fraud or harm
• Partner merchants: only aggregated, anonymised data — never your personal details — to enable discount programmes

All third parties we work with will be contractually required to protect your data and use it only for the purpose we share it for.

5. Children & minor users

Yungly Pay is designed for users between the ages of 13 and 17. We will require verifiable parental/guardian consent before any minor can create an account.

• A parent or guardian must approve account creation for users under 18
• Parents/guardians will be able to view their child's transaction history via the guardian dashboard
• Parents/guardians can set spending limits or freeze the account at any time
• We will not show targeted advertising to minors
• We will collect only the minimum data necessary for minors to use the service safely
• Guardian consent can be withdrawn at any time, which will result in account closure

If we discover that data has been collected from a child under 13 without proper consent, we will delete it immediately.

6. Your rights

Under the DPDP Act 2023, you (and your guardian, if you are a minor) will have the following rights:

• Right to access: request a copy of all personal data we hold about you
• Right to correction: ask us to fix inaccurate or incomplete data
• Right to erasure: request deletion of your data (subject to legal retention requirements)
• Right to withdraw consent: withdraw consent for data processing at any time
• Right to grievance redressal: raise a complaint with our grievance officer
• Right to nominate: nominate someone to exercise your rights in case of death or incapacity

To exercise any of these rights, email us at privacy@yunglypay.in. We will respond within 30 days.

7. Data security

We plan to use industry-standard measures to protect your data:

• End-to-end encryption for all financial transactions
• AES-256 encryption for data at rest
• TLS 1.3 for data in transit
• Multi-factor authentication for account access
• Regular security audits and penetration testing
• Access controls — only authorised personnel can access user data, on a need-to-know basis

Despite these measures, no system is 100% secure. If a data breach occurs that affects you, we will notify you and relevant authorities as required by law.

8. Data retention

We will retain your personal data for as long as your account is active and for up to 5 years after account closure, as required by RBI and anti-money laundering regulations.

Usage and analytics data will be retained for a maximum of 2 years. You can request earlier deletion where legally permissible.

9. Cookies

Our website (yunglypay.in) uses essential cookies only — to keep you logged in and remember your preferences. We do not use advertising or tracking cookies. You can disable cookies in your browser settings, though some features may not work correctly.

10. Changes to this policy

We may update this policy from time to time. If we make significant changes, we will notify you via the app or email at least 14 days before the changes take effect. Continued use of Yungly Pay after that date means you accept the updated policy.

11. Contact us

• Privacy queries: privacy@yunglypay.in
• General enquiries: info@yunglypay.in
• Address: Yungly Pay, Kerala, India

If you are not satisfied with our response, you may approach the Data Protection Board of India once operational under the DPDP Act 2023.