Terms of Use

These Terms of Use ("Terms") are a legally binding agreement between you ("you", "your", or "the user") and DialPay ("DialPay", "we", "us", or "our") governing your use of the DialPay Android application (the "App"), the website https://www.dialpay.in (the "Site"), and all related features, content, and services (together, the "Service"). DialPay is a pre-launch, Bharat-focused "offline-first UPI" convenience tool. Please read these Terms carefully. They contain important information about how DialPay works, what it is and is not, the risks involved, and your rights and responsibilities. By using the Service, you agree to these Terms. If you do not agree, please do not use the Service. These Terms are written in plain English so that first-time UPI users can understand them; nothing here takes away any right you have under Indian consumer or data-protection law.

1. Acceptance and 18+ Eligibility

By accessing or using the Service, joining the waitlist, installing the App, or enabling any feature, you confirm that you have read, understood, and agree to be bound by these Terms and by our Privacy Policy, which is incorporated by reference.

You must be at least 18 (eighteen) years of age and competent to enter into a contract under the Indian Contract Act, 1872 to use the Service. The Service is not directed at children, and we do not knowingly collect data from anyone under 18. If you are not 18 or older, you may not use the Service or submit any information to us.

You also represent and warrant that you hold a valid bank account in India linked to UPI, that the SIM/mobile number you use is registered to you, and that you will use the Service only for your own lawful payments. These are your representations to us. DialPay does not verify your identity, your SIM registration, or your bank account, and does not check whether any of these statements is true; we rely on what you tell us.

2. Operator and Definitions

DialPay is an unincorporated, founder-operated, pre-launch venture. It is not a registered company. Where these Terms need to refer to a natural person, that person is the founder-operator of DialPay. All references to "we", "us", "our", or "DialPay" mean this venture and its founder-operator. All contact is through hello@dialpay.in.

In these Terms:

• "*99#" / "NUUP" / "USSD service" means the National Unified USSD Platform offered by NPCI and your mobile carrier, which lets you make UPI payments over the normal cellular network without internet or mobile data.
• "UPI" means the Unified Payments Interface operated by the National Payments Corporation of India ("NPCI").
• "UPI PIN" means the secret personal identification number you set with your bank to authorise a UPI transaction.
• "VPA" / "UPI ID" means a payee's virtual payment address (for example, name@bank).
• "Assistance Service" means DialPay's deterministic, rule-based Android Accessibility service described in Section 8.
• "Carrier" means your mobile network operator (Airtel, Vi, or BSNL).
• "On-device history" means the transaction records stored locally on your phone as described in Section 6 and our Privacy Policy.

3. What DialPay Is and Is NOT

What DialPay is. DialPay is an independent convenience tool that helps you use India's existing *99# (USSD) service more easily. It automates only the non-sensitive steps of *99# so that you can send money, scan and pay (QR), and check your balance without internet or mobile data. It is a helper layer on top of a service that already exists; it does not replace it.

What DialPay is NOT. DialPay is not a bank, and it is not:

• a Payment Service Provider (PSP), a Third-Party Application Provider (TPAP), a UPI member, a payment aggregator, a payment gateway, a prepaid wallet, or a payment system;
• a holder, custodian, pooler, router, or settler of money. DialPay never touches, holds, or moves your funds. When you make a payment, money moves directly bank-to-bank over the NPCI/UPI rails. DialPay is non-custodial as to funds;
• affiliated with, licensed by, authorised by, endorsed by, or sponsored by NPCI, the Reserve Bank of India ("RBI"), any bank, or any mobile carrier;
• a user of NPCI's Common Library; DialPay does not use NPCI's Common Library and does not integrate with it.

Because DialPay does not handle funds, it does not require authorisation as a payment-system operator under the Payment and Settlement Systems Act, 2007. See Section 9 for the full regulatory disclosure.

4. Non-Affiliation and Trademarks

DialPay is an independent tool. It is not affiliated with, authorised by, endorsed by, or sponsored by NPCI, RBI, any bank, or any carrier.

"UPI", "BHIM", "*99#", and "NUUP" are trademarks of NPCI. "Airtel", "Vi", and "BSNL" are trademarks of their respective owners. These names are used only nominatively — that is, to describe truthfully which existing services DialPay works with. No ownership of these marks is claimed, and no affiliation, partnership, or endorsement is implied. All trademarks belong to their respective owners.

5. Platform and Network Requirements

DialPay works only under specific conditions, which are set by NPCI and the carriers, not by us:

• Android only. The App runs on Android. It is not available on iOS (iPhone/iPad).
• Supported SIMs only. The Service depends on the *99# USSD channel, which is available on Airtel, Vi, and BSNL SIMs. It does not work on Jio, because Jio does not support the *99# USSD channel.
• Cellular network required. *99# runs over your carrier's normal cellular network. You need carrier signal, but you do not need internet or mobile data to make a payment.

If your device, operating system, or SIM does not meet these requirements, the Service will not work, and that is outside our control.

6. How Payments Work

It is important that you understand exactly what DialPay does and does not do during a payment. The flow is as follows:

1. You enter the details. In the DialPay App, you enter the non-sensitive details of your payment — the payee's UPI ID/VPA (or scan a QR code), the amount, and an optional remark.
2. You start the *99# session; then DialPay assists. With your explicit in-app consent, you initiate your carrier's own *99# session (the App may dial *99# for you as a non-credential convenience, exactly as if you had typed *99# yourself). The Assistance Service then auto-fills only the non-sensitive fields you already entered (payee VPA, amount, remark) and confirms the ordinary, non-credential menu steps. It does not perform, initiate, or complete the authentication step.
3. You enter your UPI PIN yourself. When the carrier's screen asks for your UPI PIN, the Assistance Service steps back and disengages. You type your UPI PIN yourself, directly into your carrier's own *99# on-screen dialog — exactly as if you had dialled *99# manually. There is no PIN field anywhere in the DialPay App.
4. DialPay reads only the result. After you authorise the payment, the Assistance Service reads only the carrier's final result frame (success, failure, and any reference number) — a screen that contains no PIN and no credential prompt — so it can show you the outcome and save it to your on-device history.
5. Funds move bank-to-bank. Money moves directly between your bank and the payee's bank over the NPCI/UPI rails. DialPay never receives, holds, or routes your money.

Your transaction history (payee VPA, payee name if known, amount, optional note, the carrier's result text, and timestamp) is stored only on your device, in a database encrypted at rest (SQLCipher) whose key is protected by your device's hardware-backed keystore. This on-device encryption protects your history at rest, but it cannot protect a rooted, jailbroken, or otherwise compromised device, where the keystore's protection can be undermined. No UPI PIN is ever stored. You can delete any single entry or clear all history at any time, and history is kept only for a limited retention period. The only data that ever leaves your device to our servers is two anonymous running totals — a transaction count and a total value, on one shared document — with nothing about you, the recipient, any single amount, time, or device in the payload. These totals are stored in India. They increment only when the carrier's result frame is read at the end of a transaction (a completed or attempted payment) — never at, or tied to, PIN entry. Note that the network request that carries the increment necessarily exposes your device's IP address (and a Firebase app-instance identifier) to our hosting provider, even though the increment payload itself contains no other information about you; this is explained further in our Privacy Policy.

7. Your UPI PIN — You Enter It Yourself; DialPay Never Handles It

This is the most important promise in these Terms, and it is true because of how the App is built — not because of a bare guarantee.

You enter your UPI PIN yourself, in your mobile carrier's own *99# screen. DialPay's Assistance Service disengages while that screen is shown and is designed and built so that it does not receive your PIN. Specifically:

• DialPay never sees, captures, reads, stores, logs, or transmits your UPI PIN.
• There is no PIN field in the DialPay App and no code path that handles a PIN. Your PIN never reaches our servers, because there is simply no code that could send it.
• The Assistance Service does not subscribe to keystroke events, and it disengages from the carrier's secure PIN/credential prompt — that is, any masked or password-type input shown in an authentication context. This skip rule is scoped to that credential prompt; it does not apply to the ordinary non-sensitive menu fields (payee VPA, amount, remark) that you asked it to auto-fill.
• DialPay never autonomously enters your PIN or completes authentication. Only you can authorise a payment, by typing your PIN into your carrier's secure prompt.

Honest limits of this design. The safeguard above is best-effort. It works by recognising the carrier's PIN screen as a standard secure/credential field and disengaging from it. If a particular carrier or device renders the PIN prompt in a non-standard, unlabeled, or unusual way (for example, a custom OEM dialer or a modified Android build), that recognition could, in theory, fail. The Assistance Service is built to fail safe: where it is uncertain whether a screen is a credential prompt, it disengages rather than acting. We cannot, however, promise that screen-classification will be perfect on every device. Keeping your device free of malware, custom ROMs, and tampered builds of the App is part of keeping your PIN safe.

Your responsibilities regarding your PIN and device:

• Never share your UPI PIN with anyone — not with DialPay, not with our founder-operator, not with any person claiming to be from a bank, NPCI, or support. No legitimate party will ever ask for your UPI PIN.
• Enter your PIN only into the carrier's own *99# dialog, and only when you yourself have chosen to make a payment.
• Keep your device, SIM, and PIN secure. The *99# channel itself is an unencrypted cellular channel operated by your carrier, the bank, and NPCI — not by DialPay. We cannot secure that channel for you.

8. The Assistance (Accessibility) Service — Scope and Consent

To auto-fill the non-sensitive fields for you, DialPay uses an Android Accessibility service (the "Assistance Service"). We disclose its scope here clearly and prominently so you can give informed consent. This section is also intended to serve as the prominent in-app disclosure of our use of the Accessibility API.

8.1 What it reads

The Assistance Service reads the visible on-screen text of the dialer/USSD windows shown during a *99# session — but it never reads the carrier's PIN-entry screen. The text it reads is limited to the payee VPA, amount, and remark you already entered, and the carrier's final result frame (success/failure/reference). It is limited to the carrier/dialer apps used for the *99# session.

8.2 What it does

It performs deterministic, rule-based automation: it auto-fills the non-sensitive fields you entered and confirms the ordinary menu steps, then reads only the carrier's final result frame. It does not perform any autonomous credential entry or authentication.

8.3 What it never reads or does

It never reads the carrier's PIN-entry screen. It does not subscribe to keystrokes, and it disengages from any masked/password-type credential prompt shown in an authentication context (this skip rule is limited to that credential prompt and does not apply to the non-sensitive fields it auto-fills). It does not collect, transmit, or store your UPI PIN. It does not read content from any app other than the carrier/dialer apps involved in the *99# session, and nothing it reads is sent to our servers.

8.4 How it is scoped — and the honest limits of that scoping

Android accessibility services, by default, receive events from across the system. DialPay configures its Assistance Service to filter by package name, so that it requests and processes window content only from the carrier/dialer apps used for the *99# session, and is built to act only during an active, user-initiated *99# flow. You should understand honestly that this is a configuration and design choice — a deliberate narrowing — and not an absolute technical impossibility: an accessibility permission is, by its nature, a powerful permission. This is also why you should install DialPay only from the official source, keep it updated, and review the Assistance Service's behaviour; a malicious app abusing the accessibility permission, or a tampered or unofficial build of DialPay, could misuse the same permission. We also remind you here, at the point you grant this permission, that DialPay is an independent tool and is not a PSP, TPAP, payment aggregator, or payment system, and is not authorised, licensed, or endorsed by NPCI, RBI, any bank, or any carrier.

8.5 Itemised notice for your consent

Before you enable the Assistance Service, we present this itemised notice (also shown on the in-app consent screen), so you know exactly what is processed and why:

• Data the service reads/saves: the payee VPA, the payee name (if known), the amount, your optional note/remark, the carrier's result text, and a timestamp.
• Purpose: to auto-fill those non-sensitive fields for you during a *99# session, to show you the outcome of the payment, and to save that outcome to your on-device history.
• Not collected: your UPI PIN (never read, captured, stored, or transmitted).

8.6 Your consent

The Assistance Service is off by default. You must explicitly consent in-app and enable it yourself through Android's settings before it can operate. Your consent is free, specific, informed, and withdrawable: you can withdraw consent and disable the service at any time through your device settings or the App. Enabling an accessibility service is a powerful permission and may affect how some other apps behave on your device; you accept this trade-off when you choose to enable it.

9. Independent Tool — Regulatory Disclosure

We want you to be fully informed before you use DialPay:

• DialPay is an independent tool. It is not a PSP, TPAP, UPI member, payment aggregator, or payment system.
• DialPay does not use NPCI's Common Library and is not authorised or licensed by NPCI, RBI, any bank, or any carrier.
• DialPay automates only the non-sensitive parts of the *99# service that already exists on your phone. Choosing to use this automation is your decision. You can always use *99# manually by dialling it yourself; DialPay simply makes the non-sensitive steps faster.
• NPCI rules require that the UPI PIN be entered only into an authorised, secure channel (for *99#, the carrier/bank USSD session) and that third parties must not capture or store the UPI PIN. DialPay is designed to honour this principle: you enter your PIN in the carrier's own dialog, and DialPay never handles it.
• Nothing in the Service is legal, financial, tax, or investment advice. DialPay is a convenience tool, not an advisor.

10. Transaction Outcomes, Limits and Third-Party Charges

Several limits and charges apply to *99# transactions. These are set by NPCI, your bank, and your carrier — not by DialPay:

• Per-transaction cap. *99# transactions are typically capped at around Rs. 5,000 per transaction. The exact limit is set by NPCI/your bank and may change.
• Carrier session charge. Your carrier may charge approximately Rs. 0.50 per *99# session. This charge is levied by your carrier, not DialPay; DialPay charges you nothing for a transaction.
• Network dependence. A transaction can fail, time out, or be delayed for reasons outside our control, including weak signal, carrier outages, bank downtime, NPCI downtime, or incorrect details.
• You verify the payee and amount. It is your responsibility to verify the payee's UPI ID/VPA and the amount before you authorise a payment with your PIN. QR codes and UPI IDs can be altered, spoofed, or malicious. DialPay only auto-fills the details you provided; it cannot know whether the payee is who you intend or whether the amount is correct.

DialPay shows you the outcome reported by the carrier. The two anonymous totals we keep increment only when the carrier's result frame is read at the end of a transaction — that is, off a completed or attempted payment — and are never tied to, or triggered by, your PIN entry or the authorisation step. The authoritative record of any payment is held by your bank, the payee's bank, and NPCI.

11. Responsibility of Banks, NPCI and Carriers

The actual payment is carried out by your bank, the payee's bank, NPCI, and your carrier over the *99#/UPI rails. DialPay does not control and is not responsible for their systems, availability, decisions, charges, fraud-handling, or outcomes.

To the maximum extent permitted by law, you agree to hold DialPay harmless for the acts, omissions, failures, downtime, errors, or charges of any bank, NPCI, or carrier. Nothing in these Terms waives, limits, or affects any statutory right or claim you have against your own bank, NPCI, or your carrier — including under RBI's customer-protection and grievance-redress frameworks. Those rights remain fully yours.

12. Licence and Intellectual Property

Subject to these Terms, DialPay grants you a limited, personal, non-exclusive, non-transferable, revocable licence to install and use the App on a device you own or control, solely for making your own lawful payments. We retain all rights, title, and interest in the App, the Site, our name and logo, and all related software, content, and design, except for the third-party trademarks referred to in Section 4, which belong to their respective owners.

You may not copy, modify, reverse-engineer, decompile, redistribute, sublicense, or create derivative works of the App, except to the limited extent that applicable Indian law expressly permits and cannot be excluded by contract.

13. Acceptable Use and Prohibited Uses

You agree to use the Service lawfully and responsibly. You must not:

• use the Service for any unlawful, fraudulent, money-laundering, terrorist-financing, or otherwise prohibited purpose;
• use the Service to make payments you are not authorised to make, or with a bank account, SIM, or device that is not your own;
• attempt to make DialPay capture, store, or transmit a UPI PIN, or otherwise tamper with the Assistance Service's design;
• use a modified, tampered, repackaged, or unofficial build of the App;
• circumvent or attempt to circumvent any limit, security feature, or restriction imposed by DialPay, the carriers, the banks, or NPCI;
• use the Service to harass, defraud, or harm any other person, or to make unauthorised, abusive, or spam payments;
• introduce malware, interfere with the Service, or attempt unauthorised access to any system.

We may suspend or terminate your access if we reasonably believe you have breached this section, as described in Section 22.

14. Pre-Launch and Waitlist Status

DialPay is pre-launch and is expected to launch in 2026. As of today, the App is not yet live. The only thing currently available is the Site, which collects a waitlist email address (along with a timestamp, a fixed "website-waitlist" label, and your browser's user-agent string) so we can tell you when the App launches. These Terms describe how the App will behave once it is live; certain features described here are not yet active. We will make the App available, and update these Terms and our Privacy Policy as needed, before the App begins collecting or processing payment-related data.

15. Beta / Early-Stage Software and Assumption of Risk

The App is early-stage software. When it launches, it may contain bugs, errors, or interruptions, and it may change. By using the Service, you knowingly accept the following risks, to the extent the law allows you to assume them:

15.1 Telecom and channel risks

The *99# channel is an unencrypted cellular channel operated by carriers, banks, and NPCI — not by DialPay. We do not claim it is encrypted. It is exposed to risks inherent in cellular/USSD communication, including SIM-swap fraud, base-station/IMSI-catcher spoofing, interception, signalling attacks, and network outages. These risks exist whether you dial *99# manually or use DialPay, and they are outside our control.

15.2 Verify-the-payee risk

QR codes and UPI IDs/VPAs can be altered, spoofed, or malicious. You alone are responsible for confirming the payee and amount before authorising with your PIN. A payment you authorise to the wrong or a fraudulent payee may be irreversible.

15.3 Device-security risk

Your device's security is your responsibility. Risks include malware, rooted or otherwise compromised devices, custom ROMs, clipboard hijacking, and tampered or unofficial builds of the App. On such devices, the safeguards described in Sections 6 and 7 — including on-device encryption of your history and the Assistance Service's disengagement from the PIN screen — can be undermined. Enabling an accessibility service is a powerful permission that may affect how some other apps behave on your device, and could be abused by a malicious or tampered app; install DialPay only from the official source and review its behaviour.

You accept these risks as the price of a convenience tool that runs on top of an existing, third-party-operated channel. If you are not comfortable with these risks, do not use the Service.

16. Your Non-Excludable Consumer and Data-Protection Rights Come First

Nothing in these Terms — including the disclaimers, limitations, and indemnities below — excludes, restricts, or modifies any right, guarantee, warranty, or remedy that you have under mandatory Indian law that cannot lawfully be excluded, including the Consumer Protection Act, 2019 and the Digital Personal Data Protection Act, 2023. Where any provision of these Terms conflicts with such a non-excludable right, that right prevails, and the rest of these Terms continues to apply to the fullest extent permitted. In particular, no limitation of liability in these Terms limits or affects any statutory liability we may have for a personal-data breach, or any remedy available to you, under the Digital Personal Data Protection Act, 2023 or the Consumer Protection Act, 2019.

17. Disclaimer of Warranties (As-Is / As-Available)

Except for rights that cannot be excluded under Section 16, the Service is provided on an "as is" and "as available" basis, without warranties of any kind, whether express or implied. To the maximum extent permitted by law, DialPay disclaims all implied warranties, including merchantability, fitness for a particular purpose, accuracy, reliability, and non-infringement.

We do not warrant that the Service will be uninterrupted, error-free, secure, or that any transaction will succeed. We do not control and do not warrant the *99# channel, the carrier networks, the banks, or NPCI. We make no claim that the *99# channel is encrypted; it is not.

18. Limitation of Liability

To the maximum extent permitted by law, and subject to Section 16:

• DialPay and its founder-operator will not be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, or for any loss of profits, goodwill, data, or funds, arising out of or relating to the Service;
• DialPay and its founder-operator will not be liable for losses caused by banks, NPCI, carriers, the unencrypted *99# channel, SIM-swap or interception attacks, a payee you failed to verify, your own device's compromise, a tampered build, your sharing of your PIN, or any other event outside our reasonable control;
• given that DialPay touches no funds and (during its pre-launch, free phase) charges you no fees, our total aggregate liability to you for all claims relating to the Service is limited to the greater of (a) the total amount you actually paid to DialPay for the Service in the three (3) months before the event giving rise to the claim, or (b) Rs. 1,000.

This cap does not, and is not intended to, limit any liability that cannot be limited or excluded under mandatory Indian law — including any statutory liability for a personal-data breach under the Digital Personal Data Protection Act, 2023, or any remedy under the Consumer Protection Act, 2019. Your rights and remedies under those laws are unaffected by this Section.

19. Indemnity

To the extent permitted by law, you agree to indemnify and hold harmless DialPay and its founder-operator from and against any claims, losses, liabilities, damages, costs, and reasonable expenses arising out of (a) your breach of these Terms, (b) your misuse of the Service, (c) your violation of any law or any third party's rights, (d) payments you authorised (including to a payee you failed to verify), or (e) your failure to keep your device, SIM, or PIN secure. This indemnity does not require you to cover losses caused by DialPay's own breach of mandatory law.

20. Third-Party Services and Links

The Service depends on, and the Site uses, third-party services that DialPay does not control. These include your bank, NPCI, your carrier, and, for the Site and waitlist, Google Firebase/Firestore (waitlist storage and the two anonymous in-app totals), Resend (email delivery, based in the United States), and Cloudflare (hosting and security). When your device sends the two anonymous totals, the request necessarily exposes your IP address and a Firebase app-instance identifier to these providers, as explained in Section 6 and our Privacy Policy. Your use of these third-party services is subject to their own terms and privacy policies. DialPay is not responsible for the acts, omissions, content, availability, or policies of any third party or any linked website.

21. Waitlist Data and Communications Consent

If you join the waitlist, you consent to DialPay storing your email address (with a timestamp, the fixed "website-waitlist" label, and your browser user-agent) and to receiving launch-related and confirmation emails about DialPay. We send a confirmation to you and an internal notice to our own team. We do not sell your email or send unrelated marketing.

You can unsubscribe at any time, and every email gives you all three of these options:

• click the one-click unsubscribe link in the email;
• simply reply with the word "unsubscribe"; or
• email us at hello@dialpay.in.

How we handle your data is described in full in our Privacy Policy.

22. Modification, Suspension and Termination

We may update these Terms from time to time, for example to reflect changes in the Service or the law. When we make material changes, we will update the "last updated" position and, where appropriate, notify you. Your continued use of the Service after changes take effect means you accept the updated Terms.

We may suspend, restrict, or discontinue the Service (in whole or in part), or terminate your access, where we reasonably believe you have breached these Terms, where required by law, or for legitimate operational or security reasons. You may stop using the Service at any time by uninstalling the App and, if you wish, clearing your on-device history and unsubscribing from the waitlist. Sections that by their nature should survive termination (including Sections 11, 12, 16–19, and 24) will continue to apply.

23. Force Majeure

DialPay is not liable for any failure or delay in the Service caused by events beyond our reasonable control, including carrier or network outages, bank or NPCI downtime, *99#/USSD unavailability, changes in NPCI/RBI/carrier rules, internet or hosting failures, acts of God, natural disasters, pandemics, war, civil unrest, governmental action, or failures of third-party services.

24. Governing Law, Jurisdiction and Dispute Resolution

These Terms are governed by and construed in accordance with the laws of India, without regard to conflict-of-law rules.

Subject to your non-excludable consumer rights (which you may pursue as the law allows), the courts at Ahmedabad, Gujarat have exclusive jurisdiction over any dispute arising out of or relating to these Terms or the Service.

The parties will first try in good faith to resolve any dispute amicably by writing to hello@dialpay.in. If a dispute is not resolved within thirty (30) days, it may be referred to arbitration by mutual written agreement of both parties, conducted by a sole arbitrator under the Arbitration and Conciliation Act, 1996, seated in Ahmedabad, Gujarat, in the English language. Arbitration is optional and only by mutual agreement; nothing here forces you into arbitration or removes your access to courts or consumer forums where the law gives you that right.

25. General

• Entire agreement. These Terms, together with the Privacy Policy, are the entire agreement between you and DialPay regarding the Service.
• Severability. If any provision is held invalid or unenforceable, the rest remain in full force, and the invalid provision will be applied to the maximum extent permitted.
• No waiver. Our failure to enforce any provision is not a waiver of it.
• Assignment. You may not assign these Terms. We may assign them to a successor entity (for example, if DialPay is later incorporated), on notice to you.
• Headings. Headings are for convenience only and do not affect interpretation.
• Language. These Terms are written in English; an English version prevails in case of any translation difference.

26. Grievance and Contact

If you have any question, complaint, or grievance about the Service or these Terms, please contact us:

• Email: hello@dialpay.in
• Operator: the founder-operator of DialPay
• Place: Ahmedabad, Gujarat, India

We will acknowledge and address grievances within the timelines required by applicable Indian law. For matters involving your personal data, you also have the rights and grievance routes set out in our Privacy Policy, including the ability to escalate to the Data Protection Board of India.