Privacy Policy

Effective Date: April 01, 2026

1. Introduction

Excellent Finserv Private Limited ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (the "App"). Our App provides digital financial services, mobile recharge, utility bill processing, digital gold investments, and digital payments, including wallet features and automated referral reward programs.

2. Information We Collect

We may collect information about you in a variety of ways, including:

• Personal Data: Name, email address, mobile number, date of birth (if required for verification), profile photo (optional), and demographic information.
• Financial & KYC Data: Government-issued identification numbers (e.g., PAN, Aadhaar, or other government-issued ID) and bank account details required strictly for KYC compliance, UPI transactions, and payout processing. We also collect verification status and documents submitted by the user.
• Financial & Payment Information: Wallet balance and transaction history; payment records, recharge history, withdrawals, and transfers; bank account or UPI details (stored securely and only where required). Note: We do not store complete debit/credit card numbers on our servers.
• Referral Information: Referral codes and relationships, downline/upline structure data, and history of commissions, rewards, incentives, and earnings.
• Device Information: IP address, operating system, and device ID for security and fraud prevention.
• Usage Data: Pages visited and features used within the App, date, time, and duration of usage, and interaction logs for fraud detection and system improvement.

3. App Permissions & Justifications

To provide specific features, our App may request the following permissions. We only access this data with your explicit consent:

• Contacts List: Accessed strictly to facilitate mobile recharges, utility payments, and to allow users to invite friends to our referral and matrix network programs. We do not sell or share your contact list with unauthorized third parties.
• Camera & Storage: Required to capture and upload KYC documents, profile pictures, and transaction receipts.
• Location: Accessed to prevent fraudulent transactions, ensure secure logins, and comply with regulatory guidelines (such as NPCI regulations for payment processing).
• SMS: Read-only access to auto-fill OTPs for seamless and secure login verification.

4. How We Use Your Information

We use your data to:

• Create, verify, and manage user accounts.
• Enable wallet services, payments, withdrawals, and transfers.
• Process transactions, automated payouts, and utility bill payments.
• Manage your digital gold investments and SIPs.
• Operate referral reward systems, and calculate and distribute matrix commissions, incentives, and payouts.
• Perform KYC checks and ensure compliance with legal, tax, anti-money laundering (AML), and regulatory requirements.
• Detect, prevent, and investigate fraud, misuse, or technical server issues.
• Improve app functionality, performance, and overall user experience.
• Send important updates, alerts, and service notifications.

5. Disclosure of Your Information

We do not sell or rent your personal data. Your information may be shared only with:

• Payment & Banking Partners: Service providers (e.g., BBPS, NPCI) for transaction processing.
• Third-Party Service Providers: Digital asset partners (e.g., Augmont) and cloud/technology service providers (hosting, analytics, security).
• Internal Audit Teams: Internal compliance teams to ensure operational integrity.
• By Law: Regulatory or legal authorities if required to respond to legal process or to protect the rights, property, and safety of others.

6. Data Security

We use administrative, technical, and physical security measures to protect your personal information. Your sensitive data is encrypted and stored securely on robust cloud infrastructure.

7. Data Retention and Account Deletion

We keep your personal information only as long as necessary for business purposes and legal obligations.

• User Deletion Rights: You have the right to request the deletion of your account and personal data. Users can navigate to Profile > Settings > Delete Account within the App, or contact our support team. We will delete your data except for information required for regulatory compliance.

8. Third-Party Services

The App may integrate third-party services such as payment gateways, analytics tools, or login providers. Their data practices are governed by their own respective privacy policies.