Privacy of Policy
1. INTRODUCTION & SCOPE
FinkUP Entertainment Private Limited (“FinkUP”, “Company”, “we”, “us”, “our”) is a unified event technology platform offering ticketing, event discovery, expo & networking applications, access control systems, cashless payment solutions, marketing and communication tools, on-ground event infrastructure, and related digital and physical services (“Services”).,This Master Privacy Policy describes how FinkUP collects, uses, stores, shares, processes, and protects your information when you use:,FinkUP’s ticketing platform and mobile/web applications,Connect by FinkUP (expo, networking, matchmaking, exhibitor interactions),FinkCash (RFID/QR-based cashless payment system, top-ups, refunds),FinFace (facial recognition entry system),FinScan & on-ground scanning/turnstile devices,Box Office, POS and settlement systems,FinkUP’s Organiser/vendor dashboard,FinkUP-managed event websites, mini-sites and landing pages,Marketing automation, CRM, and communication features,Any hardware, software, devices, or APIs integrated with FinkUP,Any third-party systems used in conjunction with FinkUP’s ecosystem,This Policy applies to all users of our Services, including:,Event attendees / ticket buyers,Users of cashless payment systems,Participants at expos, conferences, trade shows,Exhibitors, vendors, sponsors, and partners,Event Organisers and their staff,Volunteers, contractors, production partners,Creators or influencers promoting events,Anyone interacting with FinkUP platforms or devices,This Policy covers all personal and sensitive information collected online or offline, explicitly including:,Data collected through mobile apps, websites, and SDKs,Data collected at entry gates via scanners, turnstiles, RFID/NFC,Facial recognition data where enabled,Cashless wallet and transaction-level data,CCTV feeds (if integrated with our systems),Customer support interactions,Payment-related information,Event experience and analytics data,Cookies, web beacons, device identifiers, and telemetry,Data shared with Organisers, vendors, payment partners, and third parties,If you do not agree with this Privacy Policy or any updated version of it, please discontinue using FinkUP’s Services.
1.1 Legal Basis & Compliance
This Privacy Policy is governed by and compliant with:,The Information Technology Act, 2000,Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011,Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021,Consumer Protection (E-Commerce) Rules, 2020,Applicable RBI/Payment Aggregator Guidelines (for cashless/payment services),Applicable event, venue, and entertainment regulations,While FinkUP is not currently subject to GDPR or CCPA, we maintain a privacy structure consistent with global standards for transparency and user rights.
1.2 Applicability to Integrated Partners & Ecosystem
This Policy applies to:,A. Event Organisers, Venues & Partners,When you use FinkUP’s dashboards or services as an Organiser, promoter, producer, venue, exhibitor, or sponsor.,B. On-ground Systems & Devices,Including:,RFID/QR wristbands,NFC cards,Face recognition terminals,Turnstiles,Handheld scanners,POS devices,Cashless kiosks,C. Third-Party Integrations,Such as:,Payment gateways,SMS/WhatsApp/email communication providers,Cloud hosting providers,Fraud detection and analytics partners,Marketing and advertising platforms,Use of these services may result in shared data processing responsibilities.
1.3 Children & Minors
Our Services are not intended for children under 13.,For minors:,Tickets may be purchased by parents/guardians,Parents/guardians are responsible for supervising use,Certain events may require age verification,Some events may explicitly prohibit minor participation,We do not knowingly collect data from children without lawful purpose.
1.4 Updates & Amendments
FinkUP may update this Privacy Policy periodically to integrate:,New products or features,Changes in law,Security enhancements,Operational requirements,Revised partner obligations,New device or biometric technologies,When updated:,The “Last Updated” date will change,Continued use of the Services indicates acceptance
1.5 Your Acceptance of This Policy
By using FinkUP’s Services, creating an account, attending an event, interacting with our hardware devices, or accessing our platforms, you consent to:,This Privacy Policy,The Terms & Conditions,Event-specific privacy notices,Organiser-level processing rules,Device-level data collection at events,Biometric data collection where consented,If you do not agree, do not use our Services.
2. INFORMATION WE COLLECT
FinkUP collects the following categories of information when You:,Use our apps, websites, or dashboards,Create an account,Purchase a ticket,Attend an event,Interact with our RFID/QR/FR devices,Use FinkCash cashless wallet,Use Connect expo app (attendee/exhibitor/vendor),Interact with Organisers, vendors or venues via FinkUP,Contact us for support,Participate in marketing, promotions, contests or surveys,Access on-ground infrastructure or hardware powered by FinkUP,Information is collected directly from You, automatically, from third parties, or via hardware devices at events.
2.1 Personal Identification Information
We collect personal information that You provide directly, including:,Full name,Phone number,Email address,Gender (optional or event-required),Date of birth / Age verification data,Residential address (if needed for delivery/verification),Identity verification details (for certain premium/VIP or restricted events),Photograph (profile picture, optional),Contact information of emergency contact (if required by Organiser),Language preferences,Nationality (for certain regulated events),When You use Connect (expo app):,Company name,Job title,Industry/sector,Professional interests,Exhibitor badges & QR interactions,Profile details visible to exhibitors and attendees
2.2 Sensitive Personal Information
Depending on the service:,Biometric data (facial templates, if FR-enabled),Government ID (Aadhaar*, PAN, passport; only when required by Organiser or law),Health declarations (if required for specific events or safety compliance),Disability or accessibility requirements (voluntary),Emergency information collected during incidents,(*Aadhaar is avoided unless absolutely mandatory; tokenised storage is used where legally required.)
2.3 Account, Login & Authentication Information
We collect:,Username,Password (hashed & encrypted),OTP verification logs,Multi-factor authentication data,Account linking details (Google, Apple, Facebook login-if enabled),Session tokens
2.4 Ticketing & Event-Related Information
When You book or attend events via FinkUP, We collect:,Event preferences,Ticket categories purchased,Number of tickets purchased,Booking history across events,Add-on purchases (merch, parking, VIP, F&B),Seat selection (for seated venues),Entry/exit logs from RFID/QR/FR scanners,Wristband ID mapping,Ticket transfer requests (if enabled),Guest list information (for private/VIP events),For Connect expo events:,Exhibitor interactions,Booth visits,Leads generated (if exhibitor),Networking connections,QR scans between attendees
2.5 Payment & Transaction Information
We collect:,Payment method used (cards, UPI, net banking, wallet),Transaction amount and timestamps,Partial card numbers as per PCI-DSS compliance,UPI transaction reference,Refund/chargeback logs,Wallet top-up details (FinkCash),Cashless purchase history at events,Settlement logs for POS and Box Office transactions,Billing address (if required by payment gateway),We do NOT store:,Full debit/credit card numbers,CVV codes,UPI PINs,These are handled securely by RBI-regulated payment partners.
2.6 Device, Technical & Network Information (Automatically Collected)
We collect the following from Your device:,Device model & manufacturer,Operating System & version,Browser type and version,Mobile carrier information,Device ID, advertising identifiers (IDFA/GAID), Firebase IDs,IP address & network information,Device language,Screen dimensions,App version & build number,Crash logs & performance diagnostics,Battery and signal strength (for device troubleshooting),Install/uninstall tracking,These are required for:,Fraud detection,Device security,Optimizing performance,Personalized recommendations,Debugging
2.7 Location Information
We collect:,A. Precise location (if You grant permission):,GPS coordinates,Bluetooth/Wi-Fi-based indoor positioning,Used for:,Venue navigation,Identifying nearest events,Reducing fraud at entry gates,On-ground crowd flow analytics (aggregated),B. Approximate location (through network/IP):,Used for:,City-based event recommendations,Regional pricing & content,Fraud detection,Localized notifications
2.8 Facial Recognition & Biometric Data (FinFace)
(Extremely important - not covered by BookMyShow; District uses similar concepts for CCTV),If FR-based entry is enabled by the Organiser and You consent, FinkUP collects:,Facial image for enrollment,Facial template (mathematical representation, not a photograph),Time and gate of FR entry,Match accuracy score,Fraud detection markers (duplicate identity attempts),We do NOT use FR for:,Marketing,Social profiling,Surveillance outside event zones,FR data is stored securely and deleted based on specified retention timelines.
2.9 RFID, NFC & QR-based Cashless & Access Data (FinkCash & FinScan)
We collect:,Wristband/chip/card ID,Top-up and spend logs,Vendor transaction logs,Gate-level access logs,Multiple-entry timestamps,Access zone permissions,Failed attempts & fraud flags,Device identifiers of scanners interacting with Your credential,This is essential for:,Enabling cashless payments,Preventing duplicate entry,Maintaining safety inside event zones,Vendor reconciliations
2.10 Expo, Exhibitor & Networking Data (Connect)
If You attend an expo or conference via Connect:,We collect:,Business card scans,QR lead interactions,Notes shared with exhibitors,Appointment scheduling data,Preferences for sessions/workshops,Matchmaking interest categories,Booth visit duration (if sensors installed),Exhibitor demos & downloads,Messages exchanged within the app,Exhibitors and Organisers may receive this data per event rules.
2.11 Communication & Interaction Data
We collect:,A. Messages & Chats,Messages sent to exhibitors,In-app chat logs (for Connect),Support chat transcripts,B. Calls & Recordings,When You contact customer support:,Call logs,Call recordings (for training, dispute resolution, fraud detection),C. Email, SMS & WhatsApp interactions,Open & delivery logs,Bounce logs,Unsubscribe preferences,Notification tokens
2.12 Cookies, Pixels, SDKs & Tracking Technologies
We use:,Cookies (session, persistent, secure, analytical),Web beacons,Pixel tags,Third-party SDKs (analytics, crash reporting, ads, attribution),Fingerprinting technologies (where legally permitted),Local storage,Used for:,Personalization,Measuring performance,Fraud prevention,Improving user experience,Attribution of marketing campaigns,District-style SDK disclosure will be added later in Section 7.
2.13 Third-Party Information Sources
We may receive information about You from:,Event Organisers,Venues and exhibitors,Payment gateways,Delivery/logistics partners,Advertising networks,Social media platforms (if login enabled),Data enrichment partners (permitted under law),Fraud prevention services,This helps us:,Verify identity,Prevent scalping and fraud,Personalize recommendations,Determine eligibility for events
2.14 CCTV, Photography, Videography & On-Ground Monitoring
At events where Organisers integrate FinkUP into venue infrastructure:,We may process:,CCTV feeds (metadata only unless FR is explicitly used),Photographs & videos captured at events,Crowd monitoring data (aggregated),Entry gate video snapshots for audit and safety,This is primarily for:,Security,Safety compliance,Crowd management,Event reporting,Not for marketing unless permitted.
2.15 Information Provided by Organisers, Exhibitors & Vendors
Organisers may upload:,Guest lists,VIP lists,Access-level permissions,Artist/crew/volunteer data,Vendor stall mapping and staff data,Exhibitors may upload:,Lead lists,Company representatives’ data,Vendors may upload:,Staff IDs,POS device operator logs,This data is governed by Organiser/vendor policies and shared with FinkUP solely for service delivery.
2.16 Optional Surveys, Contests & Experience Ratings
If You participate in:,Surveys,NPS feedback,Contest entries,Event ratings,Research initiatives,We collect:,Responses,Sentiment data,Feedback metadata,Photos/videos submitted voluntarily,Participation is always optional.
3. HOW WE USE YOUR INFORMATION
FinkUP uses Your information to operate, improve, secure, and enhance our Services.
Your data may be processed for the following purposes:
3.1 To Provide Ticketing & Event Access Services
We use Your information to:,Create and manage Your FinkUP account,Enable ticket purchasing and booking,Allocate seat categories (where relevant),Issue digital tickets, wristbands, QR/NFC credentials,Enable entry through RFID/QR/FR/turnstile devices,Validate Your ticket, zone permissions, and passes,Prevent fraudulent or duplicate ticket usage,Enable ticket transfers (if allowed by Organiser),Facilitate add-on purchases (parking, merch, VIP upgrades),We also share necessary booking information with the Organiser, Venue, or Artist Management, as they are responsible for hosting the event.
3.2 To Power Cashless Payments (FinkCash)
We use Your data to:,Create cashless wallet IDs linked to Your account,Enable top-ups via UPI, cards, net banking, and other methods,Process cashless transactions at vendor stalls and bars,Map Your wristband/QR to Your wallet balance,Reconcile transactions with vendors and Organisers,Facilitate refunds after the event (if applicable),Detect duplicate, suspicious, or unauthorized transactions,Allow You to check wallet balance in-app,Transaction analytics may be used to:,Prevent fraud,Improve vendor settlement,Optimize event-level cashless operations
3.3 To Power Facial Recognition Entry (FinFace)
(Only if enabled AND consent provided),We use biometric data to:,Enroll You for FR-enabled entry,Verify Your identity at gates,Speed up entry and reduce queue times,Prevent ticket misuse,Detect duplicate identities or fraudulent scans,Generate secure entry logs for audit and safety,Biometric data is never used for marketing, profiling, or surveillance beyond the event context.
3.4 To Provide Expo, Networking & B2B Event Services (Connect)
We use Your information for:,Attendees,Creating professional profiles,Matchmaking and recommendations,Scheduling meetings with exhibitors,Enabling QR-based lead exchanges,Tracking booth visits,Providing personalized event maps or schedules,Exhibitors,Accessing attendee leads (as per event rules),Managing representatives and team members,Sending follow-ups through permitted channels,Exporting lead data for CRM import,This mirrors District’s marketplace integrations but adapted to expo workflows.
3.5 To Process Payments & Financial Transactions
We use payment information to:,Accept and process ticket payments,Validate card/UPI transactions,Prevent fraudulent or unauthorized charges,Process refunds, cancellations, and settlements,Share payment success/failure with Organisers,Comply with tax and financial regulations,FinkUP does not store full card details.
3.6 To Provide Customer Support & Resolve Disputes
We use:,Account data,Booking history,Call recordings,Chat transcripts,Support logs,to:,Resolve queries,Troubleshoot device or ticketing issues,Provide technical assistance,Investigate fraud or disputes,Improve support quality,Support data is also used for:,Training models,Quality checks,Internal audits
3.7 To Improve Safety, Security & Fraud Prevention
We use data to:,Authenticate users and detect fake accounts,Prevent automated bot purchases and scalping,Prevent duplicate entry attempts,Identify suspicious wallet activity,Detect mass fraudulent sign-ups,Prevent ticket resale and counterfeiting,Maintain venue safety and audit trails,This includes analyzing:,Device fingerprints,IP anomalies,Entry logs,Payment correlation patterns,Expo QR interactions,Biometric mismatches,RFID error logs,This is similar to the anti-fraud systems described in District’s internal processes but extended for access control.
3.8 To Personalize User Experience & Recommendations
We use:,Browsing history,Event preferences,Booking patterns,Location data,Demographic info,to:,Show events relevant to Your interests,Recommend concerts, festivals, expos, workshops,Provide tailored notifications,Auto-fill forms for convenience,Suggest exhibitors or sessions (Connect app),Improve discovery based on popularity patterns,This mirrors BookMyShow’s personalization model but with deeper segmentation.
3.9 To Enable Communications & Notifications
We use Your data to send:,Ticket confirmations,OTP and authentication messages,Event updates, time changes, venue changes,Safety alerts & emergency notifications,Wallet updates (low balance, top-up success, refund status),Expo meeting reminders,Organiser announcements,Marketing promotions (only with opt-in),Communication may occur via:,Email,SMS,WhatsApp,Push notifications,In-app messages
3.10 To Conduct Analytics, Research & Event Reporting
We use aggregated, anonymized or pseudonymized data for:,Event-level analytics,Heatmaps (crowd movement, if sensors used),Cashless spending insights,Booth traffic analysis (Connect),Feature performance measurement,A/B testing new designs or flows,Audit logs for operational improvements,We may share aggregated insights with Organisers, sponsors, and venues.
3.11 To Ensure Legal Compliance & Respond to Law Enforcement
We may use data to:,Comply with IT Act, income tax, GST, and other legal requirements,Maintain audit logs for regulated payment services,Conduct KYC (if required for certain events or payouts),Respond to lawful governmental requests,Investigate complaints (security, fraud, harassment, safety incidents),Comply with event safety regulations and reporting requirements
3.12 To Operate On-Ground Devices & Infrastructure
We use data collected via:,Turnstiles,Handheld scanners,RFID/NFC readers,POS systems,FR cameras,to:,Process entry and re-entry,Control zone-level access,Prevent unauthorized movement,Log and reconcile cashless transactions,Enforce event safety protocols,Monitor gate performance and congestion,This is a function unique to FinkUP compared to District and BookMyShow.
3.13 To Record and Improve App & Device Performance
We use telemetry data to:,Fix bugs and crashes,Optimize performance for specific devices,Improve app compatibility,Detect harmful or unauthorized modifications,Improve battery consumption,Refine UI/UX flows,Improve SDK reliability
3.14 To Run Marketing, Advertising & Personalization Campaigns
(Only with consent or legally permitted basis),We use:,Browsing patterns,Location,Interests,Device identifiers,Past purchases,to:,Show personalized ads,Retarget You across platforms,Measure advertising effectiveness,Avoid showing irrelevant promotions,Recommend events You may enjoy,We may use partner ad networks following their policies.,Users may opt-out of marketing communications at any time.
3.15 For Surveys, Feedback & User Research
We use Your responses to:,Understand event satisfaction,Improve event flow and onboarding,Improve cashless experience,Enhance exhibitor interactions,Measure NPS and feature adoption,Participation is optional.
3.16 To Prevent, Detect & Respond to Safety Incidents
We may use your data to:,Record emergency incidents,Coordinate with event safety teams,Assist medical or security staff in emergencies,Investigate safety-related complaints,Provide post-event reports to Organisers,If CCTV or FR detection is used, this will be clearly disclosed.
4. HOW WE SHARE YOUR INFORMATION
We may share Your information with certain third parties to provide, improve, secure, and operate our Services.
We never sell Your personal information.,Sharing may occur with:,Event Organisers,Venue operators,Exhibitors/vendors,Service partners,Payment processors,Law enforcement (where required),Infrastructure providers,Cloud providers,Marketing partners (only with consent),Below is the complete breakdown.
4.1 Sharing with Event Organisers, Promoters & Venues
We share relevant information with the Organiser, Promoter, Venue, and Artist Management for:,Ticket validation,Entry management,Crowd control,Cashless wallet settlement,Refund and cancellation decisions,Communication of event updates,Lost & found or safety purposes,VIP or guest list management,Exhibitor/attendee mapping (in Connect events),Shared data may include:,Name, phone, email,Booking details, ticket category,Add-ons purchased (parking, VIP, meals),Entry/exit logs (RFID/QR/FR),Cashless spending summary,Age verification status,Expo booth interactions (Connect),Organisers are separate data controllers responsible for their own privacy practices.
4.2 Sharing with Exhibitors, Vendors & Sponsors (Connect Expo Events)
For expo events using Connect by FinkUP:,Exhibitors receive:,Lead scans from attendees,Contact information shared by attendee consent,Notes, preferences, meeting requests,Company and profile information,Vendors at Events (Food, Merch, Bars) receive:,Wallet or wristband transaction details,Purchase logs (item-level, where applicable),Sponsors may receive:,Aggregated, anonymized engagement insights,Contest participants’ information (if user opted in),We do not share sensitive or biometric data with exhibitors/sponsors.
4.3 Sharing with Payment Gateways, Banks & Financial Partners
We share necessary information with:,Payment processors,Banks,UPI apps,Card networks,Settlement partners,For purposes of:,Processing payments,Validating transactions,Fraud detection,Settlement and refunds,Chargeback investigations,Shared data includes:,Name,Phone/email,Transaction ID,Partial card details (as per PCI-DSS),IP/device information (for fraud prevention),We never share full card numbers or CVV codes.
4.4 Sharing with Third-Party Service Providers (Operational Partners)
These include:,Cloud hosting providers,SMS/WhatsApp/email delivery partners,Customer support vendors,Ticket scanning device partners,RFID/NFC hardware suppliers,FR technology partners (if applicable),Analytics providers,Communication automation partners,Logistics & shipping providers (for merch/wristbands),We share only the minimum data required for service delivery.,Example:
Shipping partner only receives name, address, and phone.
4.5 Sharing for Facial Recognition (FinFace) Processing
If FR-enabled entry is used:,We may share facial template data with FR technology processors solely for:,Enrollment,Matching,Fraud detection,Access control,We will never share FR data with:,Advertisers,Exhibitors,Sponsors,Unauthorized third parties,FR data is strictly confined to access control purposes.
4.6 Sharing with RFID/QR/NFC Device Partners
For FinkCash and access control systems, we may share:,Wristband ID,Access permissions,Transaction logs,Time-stamped gate logs,Only with authorized:,Hardware device vendors,Operational staff,Organiser security teams,These partners access data only for operational execution.
4.7 Sharing with Marketing & Advertising Partners (Opt-In Only)
Where permitted:,We may share:,Device advertising identifiers,Event preferences,City-level location,Browsing data,For:,Personalizing ads,Measuring campaign effectiveness,Re-targeting (only with user opt-in),No sensitive, biometric, or payment data is ever shared.
4.8 Sharing with Logistics, Delivery & Courier Partners
If You order:,Merchandise,Wristbands (pre-event),Printed materials (special cases),We share:,Name,Phone,Delivery address,Tracking-related metadata,Only for completing delivery.
4.9 Sharing with Customer Support & Call Center Partners
Support partners may access:,Booking history,Issue logs,Chat transcripts,Call recordings,Solely for:,Issue resolution,Quality assurance,Fraud checks
4.10 Sharing with Legal Authorities & Compliance Requests
We may disclose information to:,Government authorities,Law enforcement agencies,Regulatory bodies,Courts,If required for:,Criminal investigations,Fraud prevention,National security,Anti-money-laundering laws,Court orders or subpoenas,Compliance with Indian law,We ensure that lawful and due processes are followed.
4.11 Sharing to Enforce Terms, Protect Safety & Prevent Misconduct
We may share information to:,Prevent fraud or unauthorized access,Investigate suspicious activities,Protect users, staff, and event attendees,Respond to safety incidents at events,Manage crowds and emergency situations,Prevent ticket scalping, resale, and counterfeiting,This may involve:,Organiser security teams,Venue authorities,Internal fraud teams,FR or RFID system logs
4.12 Sharing Aggregated & Anonymized Data
We may share anonymized or aggregated data that does not identify You, such as:,Event attendance statistics,Cashless spending heatmaps,Session popularity metrics,Expo booth visit analytics,App engagement patterns,Demographic summaries,With:,Organisers,Sponsors,Advertisers,Research partners,Media partners,Aggregated reports never contain personal identifiers.
4.13 Sharing Within the FinkUP Ecosystem
We may share data internally across:,FinkUP ticketing,FinkCash,Connect,FinFace,FinScan,Box Office and POS systems,Marketing automation modules,To:,Provide a seamless user experience,Maintain security and consistency,Improve cross-product performance,Enable unified customer support,Internal access is strictly controlled and permission based.
5. HOW WE STORE & PROTECT YOUR INFORMATION
FinkUP is committed to protecting Your information through industry-standard technical, administrative, and physical security measures.,We implement multiple layers of security across:,Data collection,Data transmission,Data storage,Access control,Device-level processing,Biometric and RFID systems,Payment and wallet infrastructure,However, no system can guarantee absolute security.
5.1 Secure Data Storage
Your information is stored on secure servers that may be located:,Within India,In other jurisdictions where FinkUP or its trusted partners operate (in compliance with applicable law),We use:,Encrypted databases,Secure cloud infrastructure,Redundant backups,Segmented environments (for sensitive data),Role-based access control (RBAC),Critical categories like biometrics, payment tokens, and wallet logs are stored in isolated encrypted vaults.
5.2 Encryption & Data Transmission Security
We use advanced encryption to protect Your data:,While storing:,AES-256 encryption,Tokenization for FR templates,Hashing (salted) for passwords,PCI-DSS compliant masking for card data,While transmitting:,TLS 1.2/1.3 encryption,HSTS enforcement on web routes,Certificate pinning (in specific modules),Secure API gateways,All communication between FinkUP apps, devices, dashboards, and servers is encrypted.
5.3 Role-Based Access Control (RBAC)
Access to Your data is strictly limited to authorized personnel who require it for operational purposes.,We enforce:,Multi-factor authentication (MFA) for admin access,Principle of least privilege (PoLP),Logged and monitored data access,Privileged access reviews,Employee background verification,Sensitive data categories (e.g., biometrics, wallet logs) have restricted admin access.
5.4 Biometric (Facial Recognition) Data Storage & Protection
If You use FinFace for entry:,Facial images are converted into mathematical templates (not stored as raw images unless operationally required briefly),Templates are encrypted using industry-grade cryptographic standards,Stored in isolated biometric vaults with time-bound retention,Not used for marketing or profiling,Not shared with Organisers, vendors, or advertisers,Automatically deleted after the retention period unless legally required,Strict access controls ensure only authorized biometric processors can access this data.
5.5 RFID/QR/NFC Cashless & Access Control Data Protection
We securely store:,Credential IDs (wristband, QR, NFC),Transaction logs,Access logs,These are protected through:,Tokenization,Device-level encryption,Secure key rotation,Anti-tampering protocols in scanners,FinkCash wallet logs are treated with the same levels of security as payment transaction logs.
5.6 Payment Information Security (PCI-DSS Compliance)
FinkUP complies with applicable PCI-DSS guidelines via its payment partners.,We do NOT store:,Full card numbers,CVVs,Expiry dates in recoverable form,UPI PINs,Payment processors and banks handle sensitive financial information.
5.7 Data Segmentation Between Products
Data for:,FinkUP ticketing,Connect expo networking,FinkCash wallet,FinFace biometric entry,FinScan access logs,POS systems,is stored in separate logical or physical environments with restricted cross-access, ensuring:,Minimized risk of unauthorized correlation,Reduced attack surface,Compliance with least-privilege principles
5.8 Monitoring, Logging & Threat Detection
We maintain:,Intrusion detection systems (IDS),Threat monitoring,Real-time anomaly detection,Fraud detection models,Device-level tampering alerts,Anti-abuse systems for bots & scalpers,All access logs and system events are retained for investigation & audit purposes.
5.9 Physical Security Controls
Where applicable, our cloud and on-ground infrastructure follow:
24/7 monitored facilities
Hardware security modules (HSMs),Access badge controls,CCTV surveillance,Restricted server room entry,Tamper-resistant device packaging,Devices deployed at events (POS, scanners, turnstiles) use tamper-evident hardware and encrypted firmware.
6. DATA RETENTION, ARCHIVAL & DELETION
FinkUP retains Your information only for as long as necessary to:,Fulfil the purposes described in Section 3,Comply with legal, regulatory, and tax obligations,Support operational, safety, and audit requirements,Resolve disputes and enforce agreements,When data is no longer required, it is securely deleted or permanently anonymized.,Below is the complete lifecycle policy.
6.1 General Retention Principles
We determine retention durations based on:,Type and sensitivity of the data,Statutory/regulatory obligations,Purpose of processing,Fraud prevention and audit requirements,Organiser/vendor/venue obligations,Safety and incident management requirements,Dispute resolution timelines,Where applicable, we follow minimum retention required under Indian law such as:,Income Tax Act,GST and financial audit regulations,Payment settlement rules,IT Act (intermediary obligations)
6.2 Ticketing & Booking Data Retention
We retain:,Ticket history,Booking confirmations,Seat and add-on data,Event access logs,Cancellations and refunds,for as long as required for accounting, audit, and legal compliance, typically 3–7 years depending on financial regulations.,Organisers may maintain separate retention schedules.
6.3 Payment & Transaction Data Retention
We retain:,Payment logs,Settlement details,Wallet top-ups and spend logs,Chargeback and dispute details,for durations required by:,RBI,Payment processors,Income tax rules,Financial reporting norms,This is typically 7–10 years in accordance with applicable regulations.,We do not store full card details at any point.
6.4 Cashless Wallet (FinkCash) Retention
We retain:,Wristband/account ID mapping,Wallet balances,Vendor settlement logs,Transaction history,Retention varies:,Transaction logs: 7 years (financial compliance),Wristband-to-account mapping: until event reconciliation + audit window,Unused balance records: per Organiser refund policy,After the required period, wallet identifiers are either deleted or anonymized.
6.5 Facial Recognition & Biometric Data Retention
If You consent to FinFace:,Facial images (if captured) are retained only until processed into templates, then deleted unless required for fraud/audit investigations.,Facial templates (mathematical representations) are stored for short-term, event-specific periods only.,Default Retention Window:,Enrollment & match templates: up to 48–72 hours post-event, unless shorter period is defined.,Audit logs (non-biometric): may remain for longer (e.g., 30 days–6 months) depending on safety obligations.,Biometric data is:,Stored separately,Highly encrypted,Not reused across events,Never shared for marketing,After expiry, biometric data is permanently deleted using cryptographic erasure.
6.6 RFID/QR/NFC Access Control Data Retention
We retain:,Wristband ID mappings,Gate entry/exit timestamps,Attempted and failed scans,Multi-zone access logs,Retention periods:,Event operations: until event ends,Reconciliation: event completion + 30–180 days,Safety/audit logs: 6–12 months (depending on Organiser requirements),Afterward, logs are anonymized or deleted.
6.7 Expo, Exhibitor & Attendee Networking Data Retention (Connect)
Attendee data:,Profile data: retained until account deletion,Exhibitor interactions: retained as long as event rules require,Session preferences: 12–36 months for personalization,Exhibitor lead data:,Shared with exhibitors; they become independent data controllers,FinkUP retains lead logs for 6–36 months depending on Organiser contract,All expo interaction logs may be anonymized after event reporting obligations.
6.8 Communications, Chat Logs & Call Recordings
We retain:,Customer support chat logs,Email interactions,Call recordings,WhatsApp/SMS logs (metadata only),Retention varies:,Support logs: 6–24 months,Call recordings: 90–365 days,Fraud-related cases: until investigation closure + legal compliance window,Call recordings may be retained longer if involved in disputes.
6.9 Cookies, Pixels, SDKs & Analytics Data
We retain:,Cookie identifiers,Advertising identifiers,Analytics identifiers,for durations defined by:,Cookie expiry,SDK provider policies,Regulatory obligations,Typically:,Essential cookies: session or short-term,Analytics/ad cookies: up to 12–24 months,Users may clear cookies or withdraw consent where applicable.
6.10 Device, Log & Telemetry Data Retention
We retain:,Error logs,Crash reports,Device diagnostics,IP-based metadata,for:,Performance optimization,Fraud detection,Security investigations,Typical retention: 6 months – 2 years.
6.11 CCTV, Photography & Event Safety Data Retention
If integrated with FinkUP:,CCTV:,Metadata or snapshots: up to 30–180 days,Video feeds: governed by Organiser/venue policy,Event photography/videography:,Retained as long as required for marketing or operational archives,Personal removal requests handled based on legal allowances,Safety incident logs:,Retained indefinitely or per law enforcement requirements.
6.12 Technical Device Logs (Access Devices, POS, Turnstiles)
We retain:,Device authentication logs,Firmware logs,Scan activity,Connectivity logs,Typical retention: 6 months – 3 years, depending on audit requirements.
6.13 Organiser/Vendor Dashboard Data
We retain:,Organiser onboarding documents,KYC/KYB documents (if required),Event-level operational logs,Settlement records,Retention follows business and legal compliance up to 7–10 years.
6.14 Deletion Upon Account Closure
When You delete Your account:,Most personal data is deleted or anonymized,Legal and financial records may be retained,Expo lead data already shared with exhibitors cannot be deleted retroactively,Biometric data (if any) is deleted immediately or per FR TTL,Ticketing and payment logs are retained per law,Access control logs are anonymized after audit window,Cookies are cleared on next use/device action,You may refer to Section 10 for detailed user rights and deletion requests.
6.15 Conditions That May Extend Retention
Retention may be extended if:,Required by law,Needed for dispute resolution,Under fraud or misconduct investigation,Necessary for insurance or claims,Requested by law enforcement,When extended, data is isolated and restricted.
7. COOKIES, TRACKING TECHNOLOGIES & THIRD-PARTY SDKS
FinkUP uses cookies, pixels, tags, SDKs, device identifiers, and other tracking technologies across our websites, mobile applications, POS software, expo tools, and access-control systems (“Tracking Technologies”). These technologies help us:,Deliver our Services,Authenticate users,Prevent fraud,Improve performance,Personalize content,Analyze user behaviour,Support advertising (where allowed),Enable cashless and access control features,Enhance user experience across events,This section explains how these technologies work and how You can manage them.
7.1 Cookies (Website & Web App)
Cookies are small text files stored on Your device. FinkUP uses:,A. Strictly Necessary Cookies,To:,Enable website core functions,Maintain sessions,Process transactions,Prevent fraud,Load ticketing flows,These cannot be turned off.,B. Functional Cookies,Used for:,Remembering preferences,Auto-fill features,Language & location settings,Persistent login (where allowed),C. Analytics & Performance Cookies,Used to:,Measure traffic,Monitor conversion flows,Track errors,Improve A/B experiments,Optimize UI/UX,D. Advertising / Retargeting Cookies (Only with consent),Used to:,Show relevant event promotions,Optimize marketing campaigns,Track ad performance across platforms,No sensitive or biometric data is used for advertising.
7.2 Web Beacons, Pixel Tags & Script Trackers
We use:,Web beacons in emails,Pixel tags embedded in pages,JavaScript trackers,These help:,Measure email opens & link clicks,Track page load performance,Attribute conversions,Detect fraudulent behaviour,Monitor scroll depth & engagement,Pixels may also be used by:,Facebook Ads,Google Ads,Instagram,LinkedIn,TikTok (if integrated),Only with user consent where legally required.
7.3 Device Identifiers (Mobile App)
Our mobile apps collect:,IDFA (iOS),GAID (Android),Firebase Installation IDs,Vendor IDs (for Apple),Custom hashed device fingerprints,Used for:,Login authentication,Preventing duplicate or fraudulent accounts,Identifying bot traffic,Crash diagnostics,Personalization,Advertising attribution (opt-in),These identifiers may be shared with analytics or attribution partners.
7.4 Third-Party SDKs Integrated in FinkUP Apps
FinkUP uses third-party SDKs for:,Analytics,Crash reporting,Communication (SMS/WhatsApp/email),Payment processing,Push notifications,Fraud detection,Advertising attribution,Heatmaps & behaviour analytics,Sign-in integrations (Google/Apple/Facebook),Examples may include (subject to change):,Firebase / Google Analytics,AppsFlyer / Branch / Adjust,Mixpanel / Amplitude,Razorpay / Paytm / Stripe SDKs,CleverTap / MoEngage (CRM & engagement),Meta SDK (login or attribution),OneSignal / FCM (push notifications),Each SDK may collect:,Device identifiers,App usage data,Technical performance data,Location (approximate),Attribution data (referral source),We ensure SDKs operate under contractual restrictions and security protocols.
7.5 Access-Control & On-Ground Device Tracking Technologies
Access-control devices (handheld scanners, turnstiles, RFID/NFC readers) may store:,Device ID,Firmware version,Scan logs,Timestamp data,Error logs,Connectivity diagnostics,Used for:,Fraud prevention,Entry validation,Operational optimization,Audits and safety compliance,These logs are retained for limited periods as defined in Section 6.
7.6 Cashless (FinkCash) Device Tracking
Cashless devices (POS terminals, vendor kiosks) may collect:,Terminal ID,Transaction timestamps,Wallet token identifiers,Vendor mapping,Hardware performance logs,NFC/RFID interaction metadata,This supports reconciliation, fraud detection, and vendor settlements.
7.7 Expo & Exhibitor Tracking Technologies (Connect)
Expo features may include:,QR lead scanning,Beacon or Bluetooth-based booth tracking (if enabled),Session attendance scanning,Heatmap tracking in expo halls (aggregated only),We do not collect audio or microphone data except where explicitly required for features You opt into.
7.8 Fraud Detection & Security Trackers
To prevent misuse, we use:,Fingerprinting technologies,Anti-bot systems,Behavioural analytics,Velocity checks (rapid activity detection),Emulator/rooted device detection (mobile),Suspicious login pattern monitoring,These ensure safety across events, cashless, ticketing, and expo experiences.
7.9 Location-Based Trackers
If enabled by You:,GPS,Wi-Fi,Bluetooth,IP-based geolocation,are used to:,Suggest nearby events,Assist onsite navigation,Detect fraud (e.g., bookings from inconsistent locations),Improve expo matchmaking,Provide location-specific notifications,Location permissions can be disabled at any time.
7.10 Browser Storage & Local Storage
We may use:,LocalStorage,SessionStorage,IndexedDB,to store:,Temporary ticketing flows,Expo profiles,Cashless wallet session tokens,Performance data,These are cleared when You log out, clear browser data, or upon TTL expiry.
7.11 How You Can Manage Cookies & Trackers
You may:,Adjust browser settings to block cookies,Opt out of advertising cookies (where supported),Reset device advertising identifiers,Disable location access,Manage notification permissions,Use in-app privacy settings (where available),Delete or reinstall the app to remove local storage,Blocking essential cookies may break core ticketing or access-control functionality.
7.12 Do Not Track (DNT) Signals
Most browsers allow DNT requests.
At this time, FinkUP does not respond to DNT signals due to the lack of standardized implementation, similar to global norms.
8. LEGAL BASES FOR PROCESSING YOUR INFORMATION
While Indian law does not mandate classification of legal bases in the same manner as GDPR, FinkUP follows globally accepted best practices for transparency. We rely on one or more of the following legal bases when processing Your information:
8.1 Consent
We process Your information when You provide explicit consent, including but not limited to:,Creating a FinkUP account,Opting into marketing communications,Allowing access to location data,Enabling notification permissions,Using Connect expo networking features,Opting into Facial Recognition (FinFace) entry systems,Uploading photos, videos, or reviews,Participating in surveys or promotions,Scanning QR codes for lead sharing in expos,You may withdraw consent at any time (Section 10).
8.2 Performance of a Contract
We process Your information when necessary to:,Deliver purchased tickets,Allow You to attend events,Facilitate entry via QR/RFID/FR systems,Enable cashless payments (FinkCash),Provide networking & expo services (Connect),Process refunds or cancellations,Offer customer support,Settle transactions with vendors,Provide Organiser dashboards and operational tools,Without this data, FinkUP cannot fulfill its contractual obligations to You or the Organiser.
8.3 Legitimate Interests
We process information to support FinkUP’s legitimate business interests, provided they do not override Your rights. These include:,A. Fraud prevention & security,Preventing duplicate or fake accounts,Detecting ticket scalping or resale abuse,Monitoring unauthorized entry attempts,Securing RFID/QR/FR devices,Protecting users and event attendees,B. Improving and optimizing our Services,Analytics,Crash diagnostics,A/B testing,UX refinement,Personalization,Predictive recommendations,Improving expo matchmaking algorithms,C. Operational efficiency,Ticketing reconciliation,Vendor settlements,Event safety reporting,Managing large-scale entry flows,D. Protecting FinkUP and the event ecosystem,Enforcing Terms & Conditions,Investigating misconduct or policy violations,Preventing financial loss,These activities are required for the platform to operate effectively.
8.4 Compliance with Legal Obligations
We may process and retain certain categories of data to:,Comply with tax and financial reporting laws,Satisfy IT Act intermediary obligations,Respond to court orders or law enforcement,Conduct KYC/KYB where required,Adhere to anti-money-laundering (AML) requirements,Meet safety and incident documentation requirements,Maintain required records for audits,We do so strictly in accordance with applicable Indian regulations.
8.5 Protection of Vital Interests
We may process data to protect:,Your vital interests,The safety of other attendees,Public welfare during emergencies,Examples:,Communicating urgent safety alerts,Coordinating with event medical teams,Sharing incident details with venue security,Assisting law enforcement in time-sensitive cases,This applies especially during events with large crowds.
8.6 Public Interest & Safety Obligations
For certain events or venues, we may process data to:,Support public safety directives,Comply with government-mandated checks,Assist with crowd management,Support safety infrastructure (CCTV metadata, access logs),This processing is limited to lawful requirements.
8.7 Processing for Organiser, Venue & Exhibitor Contractual Requirements
Organisers and venues may require FinkUP to process data for:,Ticket validation,Entry control,Safety compliance,Vendor settlements,Expo exhibitor lead delivery,Health or age verification for restricted events,FinkUP processes personal data as a processor when acting under Organiser instructions.
8.8 Processing for Event-Day Infrastructure & Operational Requirements
We process data collected from:,RFID wristbands,QR/NFC credentials,Turnstiles,Handheld scanners,Cashless POS systems,FR devices,because it is essential for:,Safe entry flow,Real-time access management,Operational reporting,Fraud prevention,Vendor settlement,Crowd safety compliance
9. YOUR RIGHTS & CHOICES
Depending on applicable laws and FinkUP’s internal policies, You may have certain rights regarding Your personal data.
These rights allow You to access, control, and manage how Your information is collected and processed.,Please note:,Some rights apply only to specific types of data,Some rights may not apply due to legal, financial, operational, or safety obligations,Verification may be required before fulfilling any request,Rights that affect event security or regulatory requirements may be restricted,Below is the complete list of Your rights and choices.
9.1 Right to Access Your Information
You may request:,A summary of the information we hold about You,Categories of data we process,Sources from which Your data was collected,Purposes for collecting or sharing the data,Third parties with whom Your data is shared,We may refuse or limit access where:,It compromises event security,It exposes proprietary fraud detection systems,It conflicts with legal restrictions,It may violate another person’s rights
9.2 Right to Correct or Update Your Information
You may request correction of:,Your name,Email or phone number,Date of birth (with proof),Profile details on Connect,Communication preferences,Corrections cannot be made to:,Historical ticketing or payment logs,Event access logs,Wallet or transaction history,FR/RFID logs once processed,Records maintained to comply with legal obligations
9.3 Right to Delete Your Information (Right to Erasure)
You may request deletion of:,Your FinkUP account,Personal profile data,Photos or content uploaded by You,Expo networking details (unless already shared with exhibitors),Deletion cannot apply to:,Completed ticket purchases,Financial and tax-related records,RFID/FR access logs required for safety audits,Wallet transaction histories,Ongoing fraud investigations,Expo leads that have already been shared externally,Data required under applicable law (audit, compliance, or settlement),This protects FinkUP against legal, operational, and safety liabilities.
9.4 Right to Withdraw Consent
You may withdraw consent for:,Marketing communications,Push notifications,Location access,Expo matchmaking features,Biometric (Facial Recognition) enrollment (future use),Cookies and advertising trackers,Certain optional permissions (camera, Bluetooth, etc.),Withdrawal does not affect processing that already occurred.,For facial recognition:,Withdrawal stops future scans,Past entry logs cannot be modified,Biometric templates will be deleted unless required for fraud investigations or safety audits
9.5 Right to Opt-Out of Marketing Communications
You may opt out of receiving:,Emails,SMS,WhatsApp updates,Push notifications,Promotional notifications,Methods include:,Clicking “unsubscribe” links,Using in-app settings,Updating browser/device notification settings,Requesting directly via support,Transactional communications cannot be opted out of (e.g., ticket confirmations, safety alerts).
9.6 Right to Manage Cookies & Tracking Technologies
You may:,Block cookies in browser settings,Disable advertising identifiers on mobile,Opt out of retargeting (where supported),Withdraw permission for location access,Clear cookies or local storage,Manage permissions for Bluetooth/Camera/Microphone,Essential cookies cannot be disabled, as they are required for ticketing, entry, and event flows.
9.7 Right to Object to Processing (Where Applicable)
You may object to:,Profiling for marketing,Behavioural advertising,Certain analytics,Expo matchmaking algorithms,Non-essential tracking,However, You cannot object where processing is required for:,Contract performance,Fraud prevention,Critical operational functions,Safety and compliance,Ticketing workflow,Access control (QR/RFID/FR logs)
9.8 Right to Restrict Processing
You may request limited processing of Your data while:,A correction request is pending,A deletion request is being validated,A dispute or investigation is ongoing,FinkUP may deny restriction where data is needed for:,Event entry,Cashless wallet reconciliation,Safety monitoring,Legal obligations,Fraud prevention
9.9 Right to Data Portability (Where Feasible)
You may request certain personal data in a structured format.,However:,Event-specific access logs,FR biometrics,Cashless transaction logs,Financial settlement logs,Expo interaction events,are not portable due to:,Legal restrictions,Security risks,Proprietary system formats,We may offer portability for:,Name, email, phone,Basic profile information,Connect professional profile (where technically feasible)
9.10 Rights Related to Automated Decision Making
Certain features (expo matchmaking, fraud detection, personalized recommendations) use automated processing.,You may:,Request clarification on how automated decisions affect You,Request review in cases where automated fraud flags impact Your account,Opt out of non-essential personalization features,Automated decisions that ensure safety or prevent fraud cannot be disabled.
9.11 Rights Related to Facial Recognition (Special Category)
You may:,Decline enrollment in FR-based entry,Opt for alternative entry (QR/RFID),Withdraw future use of FR,Request deletion of biometric templates (subject to audit windows),Limitations:,If FR is mandatory for certain high-security events, alternative entry may be controlled by the Organiser,Past FR scans cannot be retroactively erased from safety logs
9.12 Rights Related to RFID/QR Cashless Systems
You may:,Request wristband unlinking (before or after event where applicable),Request manual correction of transaction errors,Request deletion of wristband mapping after settlement is complete,Wallet transaction history cannot be deleted due to financial compliance obligations.
9.13 How to Exercise Your Rights
You may submit a request by contacting:,Grievance Redressal Officer
(Details in Section 29),You must provide:,Proof of identity,Account details,Description of request,Supporting evidence where required,We will respond within timelines defined by law or internal policy.,Requests may be refused where:,They are excessive or abusive,They impact other users’ rights,They compromise safety or security,They conflict with legal obligations,They seek deletion of legally protected logs
10. YOUR DATA SECURITY OBLIGATIONS
To protect Your account, wallet, ticket purchases, and event experience, You must take reasonable steps to safeguard Your own information. By using FinkUP’s Services, You agree to comply with the following obligations.,Failure to follow these obligations may result in:,Account compromise,Wallet misuse,Unauthorized entry attempts,Loss of funds,Denied claims,Suspension or termination of Your account,FinkUP shall not be responsible for security issues caused due to Your negligence.
10.1 Responsibility for Your Account & Login Credentials
You are solely responsible for:,Keeping Your password confidential,Securing OTPs sent to Your phone or email,Ensuring Your device is not accessible to unauthorized persons,Logging out of shared or public devices,Not sharing Your account with others,You must notify FinkUP immediately if:,Your device is lost or stolen,Your SIM card is compromised,You suspect unauthorized access to Your account
10.2 Responsibility for Your Device Security
You must ensure:,Your device is free of malware, spyware, or harmful modifications,Your OS and apps are updated,You do not use rooted/jailbroken devices,You maintain strong screen lock or password protection,You allow only trusted apps to access Your notifications,FinkUP is not responsible for:,Data theft due to compromised devices,Fraud caused by installed malware,Attackers intercepting OTPs or notifications on Your device
10.3 Responsibility for QR Tickets, RFID Wristbands & Access Credentials
You must:,Keep Your digital or physical tickets confidential,Protect Your QR code and ticket PDF from screenshots or forwarding,Not share, post, or publish ticket codes on social media,Not hand over Your RFID/NFC wristband or card to others,Follow instructions for wearing or using wristbands,FinkUP is not responsible for:,Unauthorized entry caused by You sharing Your QR code,Misuse of wristbands transferred without authorization,Lost, stolen, or damaged RFID wristbands or cards,Denied entry due to tampered or duplicated access credentials,Organisers may charge a fee for replacing wristbands/cards.
10.4 Responsibility for Cashless Wallet (FinkCash) Security
You must:,Keep Your wristband/QR/phone secure as it represents Your wallet,Report loss of wristband immediately,Not share OTPs used for wallet top-ups,Verify transaction details before payment,Review transaction history promptly,Not allow others to link their wristband to Your wallet,FinkUP is not responsible for:,Wallet misuse caused by You sharing Your credentials,Unauthorized spends before the loss is reported,Incorrect top-up amounts entered by You,Disputes raised after the reconciliation window closes,Wallet refund timelines depend on Organiser policies.
10.5 Responsibility for Facial Recognition Enrollment (FinFace)
If You choose to enroll in Facial Recognition:,You must:,Provide accurate, real-time facial capture,Not attempt to spoof or deceive the system,Comply with FR zone instructions,FinkUP is not responsible for:,Denied entry due to poor lighting or improper face capture,Matching failures caused by hats, masks, or accessories,Incorrect enrollment performed by You,Alternate entry may be allowed depending on Organiser policy.
10.6 Responsibility for Expo & Networking Data (Connect)
If You use Connect:,You must:,Review Your profile before sharing,Not share confidential company data unintentionally,Verify exhibitor authenticity before exchanging leads,Understand that any lead You scan will be shared with the exhibitor,FinkUP is not responsible for:,Misuse of Your contact details by exhibitors,Incorrect information shared by You,Exposure of business data due to Your profile settings,Once shared, lead data cannot be revoked from exhibitors.
10.7 Responsibility for Safe Use of Communication Channels
You must:,Verify links before clicking,Not share OTPs, account details, or wallet balance screenshots,Beware of impersonation attempts,Use only official FinkUP contact channels for support,FinkUP is not liable for:,Scams conducted outside its platform,Messages from fake accounts impersonating FinkUP,Social engineering attacks caused by user negligence
10.8 Responsibility for Event-Day Compliance & Safety
You must:,Follow entry procedures,Wear RFID wristbands correctly,Adhere to safety instructions provided by Organisers,Comply with mandatory checks (age, ID, security screening),Maintain behavior appropriate for event participation,FinkUP is not liable for:,Denied entry due to non-compliance,Safety risks created by user misconduct,Event removal due to violation of rules,Safety rules are enforced by Organisers, not FinkUP.
10.9 Responsibility to Provide Accurate Information
You must ensure all information You provide is:,True,Accurate,Current,Complete,This includes:,Name,Phone,Email,Age,Identity documents (when required),Connect business details,Payment information,FinkUP is not responsible for:,Delivery failures due to incorrect information provided by You,Failed entry due to wrong name on tickets,Wallet refunds sent to incorrect accounts due to user error
10.10 Responsibility to Report Issues Promptly
You must report:,Lost wristbands,Fraudulent transactions,Unauthorized logins,Payment failures,Ticket delivery issues,Wrong event details,Safety concerns,Delay in reporting may affect FinkUP’s ability to help or reverse transactions.
11. CHILDREN’S PRIVACY
FinkUP does not knowingly collect personal information from children under the age of 13, except as permitted under applicable laws and only with parental or guardian involvement.
Our Services are primarily designed for adults and individuals above the age required for attending events, concerts, conferences, nightlife activities, and certain entertainment experiences.
11.1 Minimum Age Requirements
A. For general platform use,Users must be at least 13 years old to create or manage a FinkUP account.,B. For events with age restrictions,Some events may require Users to be:
15+
16+
18+
21+
depending on Organiser and venue rules.,FinkUP displays these age restrictions as provided by the Organiser.
Organisers are solely responsible for enforcing them.
12. THIRD-PARTY LINKS, SERVICES & INTEGRATIONS
Our Services may contain links to, integrate with, rely upon, or allow You to interact with third-party websites, applications, tools, SDKs, payment processors, vendors, exhibitors, and services (“Third-Party Services”).
These Third-Party Services operate independently and may have their own privacy policies and data collection practices.,FinkUP is not responsible for the content, security, or privacy practices of any Third-Party Services.
12.1 Third-Party Payment Gateways & Financial Partners
FinkUP uses third-party payment processors for:,Card payments,UPI transactions,Net banking,Wallet top-ups,Refund settlement,Chargeback handling,These partners may collect:,Name, phone, email,Card details (masked/tokenized),UPI Virtual Payment Address (VPA),IP address,Device information,Transaction identifiers,FinkUP does not control the policies of these gateways.,You must review their separate privacy and security practices.
12.2 Third-Party Authentication Providers
If You sign in through:,Google,Apple,Facebook,PhonePe Login (example),These providers may collect:,Basic profile information,Device and login metadata,Authentication logs,FinkUP receives only the data You authorize.,These platforms are responsible for their own data handling.
12.3 Third-Party Communication & Messaging Services
We use external vendors for:,SMS & OTP delivery,WhatsApp notifications,Email sending,Push notification routing,These providers may independently collect:,Phone numbers,Delivery reports,Device tokens,Metadata about communication success/failure,FinkUP is not responsible for:,Delayed OTPs,SMS delivery failures,WhatsApp downtime,Email spam filtering by your provider
12.4 Third-Party Analytics, Attribution & SDK Providers
Our apps integrate with analytics and engagement SDKs such as:,Firebase / Google Analytics,AppsFlyer / Adjust / Branch,Mixpanel / Amplitude,Crashlytics,Marketing automation providers (MoEngage, CleverTap, etc.),These may collect:,Device IDs,Crash logs,App usage data,Attribution data,Behavioral analytics,Their processing is governed by their own privacy policies.
12.5 Third-Party Advertising Partners (If Enabled)
If You opt into marketing personalization, certain Third-Party Services may process:,Device advertising identifiers,Cookie IDs,Event interests,Location (approximate),These may include:,Google Ads,Meta Ads (Facebook/Instagram),TikTok Ads,LinkedIn Ads,Advertising providers may track interactions both inside and outside FinkUP.
12.6 Third-Party Event Organisers, Venues & Exhibitors
For events hosted through FinkUP:,Organisers and venues receive necessary booking data,Exhibitors may receive Your profile information if You interact with them,Vendors receive only essential transactional data,Once data is shared:,Organisers become independent data controllers,Exhibitors & vendors follow their own privacy practices,FinkUP is not responsible for misuse by Organisers, exhibitors, or vendors.
12.7 Third-Party Facial Recognition Technology Providers
For FR-enabled events:,Only authorized biometric processing partners receive facial templates,They operate under strict contractual obligations,They do not use data for advertising or unrelated purposes,FinkUP is not responsible for:,Software bugs in third-party FR engines,Recognition failures due to third-party algorithms,Any security breach within third-party FR infrastructure (unless required by law)
12.8 Third-Party RFID/NFC Hardware Providers
FinkUP relies on hardware components from approved vendors.,These may collect:,Device diagnostics,Firmware logs,Failed scan attempts,Access error metadata,FinkUP is not responsible for:,Hardware malfunction,Firmware-level vulnerabilities,Service interruptions caused by device providers
12.9 Third-Party POS & Settlement Tools
Vendors at events may use POS systems integrated with:,Payment aggregators,Settlement partners,Banking APIs,These systems may collect transactional or operational data independently of FinkUP.
12.10 Third-Party Cloud Providers & Hosting Partners
We use reliable cloud partners for:,Data storage,Backup,Performance optimization,Content delivery,Redundancy & uptime assurance,These providers operate their own infrastructure and policies.,FinkUP ensures contractual safeguards but is not responsible for failures originating on third-party cloud platforms.
12.11 Third-Party Logistics, Shipping & Courier Partners
If merchandise or wristbands are shipped:,Delivery partners receive limited personal data,They follow their own privacy policies,They may collect tracking metadata,FinkUP is not responsible for:,Delays,Damage,Misdeliveries,Theft in transit
12.12 Third-Party Websites & External Links
FinkUP may contain links to:,Event partner websites,Artist merchandise stores,Sponsor pages,Social media pages,Hotel or travel recommendations,Third-party ticketing or promotional platforms,Clicking these links may allow those websites to collect Your data.,FinkUP is not responsible for:,Content on these websites,Their privacy or security practices,Their handling of Your personal data
12.13 Third-Party APIs & Integrations Used by Organisers
Organisers may integrate third-party tools into their FinkUP dashboards or event workflows, such as:,CRM systems,Lead management solutions,Marketing platforms,Ticket scanning devices from their vendors,These are not controlled by FinkUP, and any data shared through such integrations is subject to the Organiser’s policies.
12.14 Limitation of Liability for Third-Party Services
FinkUP is not responsible or liable for:,Data breaches by third parties,Unauthorized access on third-party servers,Failures in third-party SDKs or tools,Misuse of data by Organisers, exhibitors, vendors,Payment gateway downtime or errors,Inaccuracies in third-party analytics,Security incidents caused by user interactions outside FinkUP,Your use of Third-Party Services is at Your own discretion and risk.
13. INTERNATIONAL DATA TRANSFERS
FinkUP primarily stores and processes personal information within India.
However, certain services, features, integrations, or operational requirements may involve transferring Your information to servers or partners located outside India.
These data transfers are necessary to deliver a seamless global experience, provide technical reliability, and support international event Organisers, exhibitors, or vendors who use FinkUP.,By using our Services, You acknowledge and consent to such international data transfers.
13.1 Why Your Data May Be Transferred Internationally
Your data may be transferred to other countries for the following purposes:,Cloud hosting or backup storage,Content delivery (CDN networks),Fraud detection and security systems,Biometric or access-control processing (when applicable),Analytics and attribution services,Communication services (email, SMS, WhatsApp),Payment processing systems,Customer support operations,Expo and networking tools used by international exhibitors,Settlement systems linked to global partners,Third-party integrations where their servers are located abroad,Such transfers are essential for FinkUP’s operational performance, global availability, and system security.
13.2 Countries Where Data May Be Transferred
Depending on the services and integrations You use, Your data may be transferred to:,United States,Singapore,Europe / EU regions,United Arab Emirates,United Kingdom,Any other jurisdiction where our trusted service partners operate,These partners are carefully selected and bound by privacy and security obligations.
13.3 Safeguards Used During International Transfers
To protect Your data during cross-border transfers, FinkUP implements:,A. Contractual Safeguards,Data Processing Agreements (DPAs),Confidentiality obligations,Security commitments from third parties,Standard Contractual Clauses (where applicable internationally),B. Technical Safeguards,Encryption in transit and at rest,Access control restrictions,Segmented storage for sensitive data,Tokenization for biometric or payment-related data,C. Organizational Safeguards,Restricted-access systems,Privacy-by-design protocols,Vendor audits and risk assessments,We ensure data is transferred only when necessary and with adequate protection.
13.4 Transfers for Payment, Logistics & Event Operations
In some cases, international transfers may be necessary to:,Verify payments through global card networks,Process transactions through international gateways,Provide support for international exhibitors or Organisers,Enable ticket sales for global or cross-border events,Support delivery or logistics partners working outside India,Facilitate FR services delivered by global biometric vendors,These partners may process personal information independently under their own privacy policies.
13.5 Transfers Initiated by You (Voluntary Actions)
Certain actions triggered by You may cause Your data to be shared with or accessed by international partners, such as:,Using Connect to network with international exhibitors,Scanning QR codes from foreign vendors or partners,Registering for international conferences hosted via FinkUP,Interacting with global sponsors,Using social login services (Google, Apple, Facebook),Using global payment services or cards issued abroad,In these cases, the transfer is voluntary and initiated by You.
13.6 Transfers for Customer Support & Issue Resolution
If You interact with FinkUP through:,International customer support teams,Cloud ticketing systems hosted abroad,Integrated communication systems,Your information may be processed in those jurisdictions.
13.7 Storage & Backup Redundancy Across Multiple Regions
To ensure:,Reliability,Uptime,Load balancing,Disaster recovery,System optimization,FinkUP may store encrypted backups or temporary replicas in foreign data centers offered by cloud providers (such as AWS, Google Cloud, or Azure).,These do not contain unencrypted sensitive or biometric data unless required by strict operational constraints and always under isolated protection.
13.8 Compliance With Local & International Law
International transfers comply with:,Indian IT Act & SPDI Rules,Intermediary Guidelines 2021,Contractual and security requirements of hosting partners,Global privacy standards followed by our vendors,Even when data is transferred outside India, FinkUP ensures that it remains protected with adequate safeguards.
13.9 Continued Application of This Privacy Policy
Regardless of where Your data is processed:,This Privacy Policy continues to apply,FinkUP remains responsible for protecting Your information,Our security measures (Section 5) continue to govern data protection,Third-party services also remain bound by their contractual obligations.,Bottom of Form
14. DATA BREACH NOTIFICATION & INCIDENT RESPONSE
FinkUP takes data breaches, unauthorized access, misuse, and security incidents extremely seriously.
Although no platform can guarantee absolute security, FinkUP maintains an internal Incident Response Framework to detect, investigate, mitigate, and respond to potential breaches affecting personal data, biometric data, RFID/QR identifiers, wallet information, or any other sensitive logs.,This Section explains our commitments and what You should expect if a breach occurs.
14.1 What Constitutes a Data Breach
A “Data Breach” may include, but is not limited to:,Unauthorized access to personal data,Theft, loss, or exposure of stored information,System intrusion or hacking attempts,Compromise of RFID/QR/FinkCash credentials,Misuse of biometric templates or FR logs,Access to wallet-related transaction identifiers,Accidental data disclosure or leakage,Unauthorized modification or deletion of records,Breach of third-party systems integrated with FinkUP,A breach can occur due to:,Malicious attacks,Technical vulnerabilities,Insider misuse,Device tampering,Third-party failures,Human error
14.2 FinkUP’s Incident Response Commitments
Upon becoming aware of a potential or confirmed breach, FinkUP will:,A. Immediately Investigate,Activate internal incident response protocol,Identify affected systems and data categories,Determine source, scope, and severity,Engage internal security teams and external specialists (if required),B. Contain & Mitigate,Isolate compromised systems,Rotate access keys or invalidate tokens,Disable affected services temporarily,Patch vulnerabilities or update firmware,Revoke compromised QR/RFID/FR credentials,C. Assess Impact,Identify whether personal or sensitive data was accessed,Determine if financial, biometric, or wallet data is affected,Evaluate risk to Users, Organisers, or Vendors,D. Document the Incident,Maintain audit logs, forensic reports, remediation notes,Retain evidence for legal or operational follow-up
14.3 When & How We Will Notify Users
FinkUP will notify affected Users and/or Organisers if required by law or if the incident is likely to result in a material risk to their:,Personal information,Wallet balances,Biometric templates,Access credentials,Financial transactions,Notifications may be sent via:,Email,SMS,Push notification,In-app alerts,Website banners,We will explain:,Nature of the breach,What information was affected,Steps taken by FinkUP,Recommended actions for You,Customer support contact points,FinkUP retains discretion on the timing and format of notifications as allowed by law and security considerations.
14.4 Notification to Organisers, Exhibitors, Vendors & Partners
If the breach affects:,Organisers’ dashboards,Vendor POS terminals,Exhibitor lead systems,Event access systems,Cashless vendor settlements,FinkUP may notify relevant partners to ensure coordinated mitigation.
Partners may also be required to notify affected individuals based on their own policies.
14.5 Notification to Authorities (Where Applicable)
FinkUP may notify:,Law enforcement,Cybercrime authorities,CERT-In (India),Relevant regulatory bodies,Payment partners (if financial data involved),Notifications may be:,Mandatory (per law),Recommended (per best practice),Voluntary (to protect safety)
14.6 User Responsibilities in a Breach Scenario
You must:,Review notifications received,Change passwords immediately,Secure Your device or SIM if compromised,Report fraudulent wallet activity urgently,Deactivate lost wristbands or credentials,Follow recommended steps provided by FinkUP,Delays in user action may worsen impact, and FinkUP is not responsible for damages caused by failure to act promptly.
14.7 No Liability for Third-Party Breaches
FinkUP is not responsible for breaches originating in:,Third-party payment gateways,Cloud or hosting providers,SMS, email, or WhatsApp partners,FR technology vendors,POS hardware providers,Exhibitor CRM systems,Organiser-operated systems,User devices or accounts,Social login platforms,FinkUP will assist where feasible but does not assume liability for third-party failures.
14.8 No Guarantee of Absolute Security
While we implement industry-standard security measures (Section 5), You acknowledge:,No platform can guarantee absolute data security,RFID/QR/FR systems may face attempts of misuse,On-ground devices may face tampering risks,Internet-based systems can suffer breaches despite safeguards,Your continued use of the platform constitutes acceptance of these inherent risks.
14.9 Post-Breach Remediation
Following a breach, FinkUP may:,Reset affected user credentials,Force logout from all devices,Reissue wristbands or QR codes,Disable compromised wallet features temporarily,Reverify identity for high-risk accounts,Update policies, systems, and safeguards,Remediation may require temporary service disruptions.
14.10 Internal Monitoring, Forensics & Recordkeeping
All incidents undergo:,Forensic logging,Internal audits,System health review,Data integrity checks,Root cause analysis (RCA),Mandatory archival of investigation reports,These records may be retained for compliance (Section 6).
15. USER-GENERATED CONTENT, REVIEWS & PUBLIC INFORMATION
Some features of the FinkUP Platform may allow You or event partners to upload, submit, send, store, publish, display, share, or distribute content (“User-Generated Content” or “UGC”), including but not limited to:,Reviews and ratings,Comments,Photos, videos, or media uploads,Profile information (attendee or exhibitor),Company details (for Connect exhibitors),Booth descriptions, brochures, or marketing material,Messages exchanged with exhibitors or other attendees,QR-coded business card data shared at expos,Event tags, bios, or user profiles,Uploaded documents for verification or onboarding,This Section explains how FinkUP handles such content and Your obligations.
15.1 Your Responsibility for Content You Upload
You are solely responsible for all UGC You post or share through the FinkUP Platform.
By uploading any content, You confirm that:,You own the rights to the content OR You have permission to use it,The content does not violate privacy, confidentiality, copyright, trademark, or any law,The content is accurate, not misleading, and not fraudulent,The content does not impersonate or misrepresent another person,The content does not harm, defame, or harass any individual or organization,FinkUP does not verify user submissions and is not responsible for UGC posted by You or others.
15.2 Public Visibility of Certain Information
Depending on how You use the Platform:,A. Event Reviews & Ratings,Your review, star rating, and name (or display name) may be publicly visible.,B. Connect Expo Networking,Your:,Profile photo,Name,Company,Designation,Interests,Booth or attendee status,may be visible to other attendees or exhibitors.,C. Exhibitor Booth Pages,Information uploaded by exhibitors:,Company description,Sales material,Contact details,Brochures,Product photos,is publicly visible to attendees within the event context.,D. Public Leaderboards or Participation Lists (If applicable),Some event types may show participation metrics publicly (e.g., hackathons, gaming zones, contests).
15.3 Content Shared with Exhibitors or Other Users
If You scan an exhibitor QR code or share leads via Connect:,Exhibitors receive Your shared profile data,Exhibitors may export the data to their CRM,Exhibitors become independent controllers of the received data,FinkUP is not responsible for:,Exhibitors contacting You,Exhibitors using Your information,Exhibitors sharing Your data within their organizations,Any misuse of Your data after You voluntarily share it,FinkUP cannot revoke data already shared with exhibitors.
15.4 Permission You Grant to FinkUP
By submitting UGC, You grant FinkUP:,A worldwide,Non-exclusive,Royalty-free,Transferable,Sub-licensable,Right and license,to use, reproduce, modify, publicly display, distribute, and adapt the content solely for the purposes of operating and improving the Platform, including:,Showing Your review on event pages,Displaying Connect profiles to exhibitors,Generating aggregated insights,Powering AI-based personalization (if applicable),Moderating or removing harmful content,You may revoke permissions for future content, but not for content already processed or shared.
15.5 FinkUP’s Right to Remove Content
FinkUP may remove or disable any UGC that:,Violates law,Violates this Privacy Policy,Violates Terms & Conditions,Contains harmful or offensive material,Infringes intellectual property rights,Exposes personal or sensitive data of others,Poses a security or safety risk,Is fraudulent or misleading,Is reported by Organisers, exhibitors, or users,FinkUP has full discretion to moderate or remove content.
15.6 Uploaded Documents & Verification Materials
Documents uploaded for:,Age verification,Identity checks,Organiser onboarding,Exhibitor listings,Vendor accounts,Safety compliance,are not considered public UGC and will be kept confidential as per Section 5 (security) and Section 6 (retention).
15.7 Messaging, Chat & Communication Features
If You use chat or messaging tools (e.g., Connect):,Messages may be stored,Messages may be visible to exhibitors (if You choose to message them),Messages may be monitored for fraud or abuse,Messages may be used to resolve disputes,Messages may be retained per retention policy,You must not use messaging features to:,Spam attendees or exhibitors,Send abusive, harmful, or inappropriate messages,Solicit illegal activity,Share confidential or proprietary information unless intended
15.8 FinkUP’s Liability for User-Generated Content
To the maximum extent permitted by law:,FinkUP is not liable for UGC uploaded by Users, attendees, exhibitors, Organisers, or vendors,FinkUP does not endorse any UGC,FinkUP does not verify the accuracy, completeness, or legality of UGC,FinkUP is not responsible for damages resulting from UGC shared publicly or privately,FinkUP does not mediate disputes arising from UGC (except where required by law)
15.9 Reporting Inappropriate or Unauthorized Content
You may report inappropriate content via:,In-app/report features,Email to the Grievance Officer,Customer support,FinkUP may:,Remove the content,Suspend the user,Restrict features,Notify Organisers or exhibitors,Cooperate with law enforcement
15.10 Deletion of User-Generated Content
You may request deletion of Your UGC, unless:,It has already been shared with exhibitors or other users,It is required for legal compliance,It is part of access or safety logs,It has been anonymized for research or analytics,Third parties have already copied or downloaded it,Connect interactions (lead scans) cannot be retroactively erased.,Top of Form
16. DATA OF ORGANISERS, EXHIBITORS, VENDORS & BUSINESS PARTNERS
FinkUP provides technology and infrastructure services to event Organisers, exhibitors, vendors, venues, creators, promoters, agencies, production companies, and other business partners (“Business Partners”).,This section explains how we collect, use, store, and share information belonging to Business Partners and their authorized personnel.
16.1 Information We Collect from Business Partners
We may collect the following categories of information:,A. Business & Organizational Information,Company name,Legal entity details,GST, PAN, CIN, or registration documents,Business address,Contact details of authorized signatories,Contracts, agreements, NDAs, SOWs,B. Authorized Personnel Data,Name,Role / designation,Business email & phone,ID proof (if required by venue security),KYC/KYB documentation (where required),Staff lists (volunteers, crew, exhibitors, POS operators),C. Event & Operational Data,Event details, schedules, and layouts,Vendor lists and access permissions,Cashless vendor mapping & POS assignments,Crew and staff access zones,Exhibitor booth setup and lead preferences,Performer, speaker, and artist management data,D. Financial & Settlement Data,Bank account information,Invoices & billing records,Vendor settlement logs,POS reconciliation data,TDS/GST documentation,E. Platform Usage Data,Dashboard login logs,Activity trails for audit (e.g., ticket updates, guest list uploads),Export logs for leads or reports,API usage logs,Support ticket histories,F. Uploaded Content & Documents,Event banners & media,Booth brochures & marketing materials,Intro videos, files, presentations,SOPs or event protocols
16.2 How We Use Business Partner Information
We use Business Partner data to:,A. Provide FinkUP Services,Create Organiser, exhibitor, and vendor accounts,Enable event creation, ticketing, check-in, and access control,Allow Connect expo tools (leads, booth interactions, matchmaking),Facilitate cashless wallet settlement & POS management,Provide dashboards, analytics, and real-time insights,Assign crew/staff access zones in RFID/QR/FR systems,B. Verify & Onboard Partners,Conduct KYC/KYB verifications,Authenticate official representatives,Validate event eligibility and compliance,Prevent fraudulent Organiser/vendor accounts,C. Support Event Operations,Manage guest lists,Configure access and permissions,Issue staff wristbands or FR credentials,Enable exhibitor lead capture,Generate event reports and analytics,D. Allow Financial Processing,Process payouts & settlements,Handle deductions, refunds, or adjustments,Maintain statutory compliance and financial records,E. Improve Platform Quality,Analyze dashboard usage,Improve B2B workflows,Enhance exhibitor/Organiser tools,Debug operational issues
16.3 Sharing of Business Partner Information
We may share Business Partner information with:,A. Event Attendees (Limited, Controlled Exposure),For expos and conferences using Connect:,Exhibitors’ company names,Booth information,Contact details authorized for public viewing,Profiles and brochures,Session or workshop host information,B. Vendors & Service Operators,Crew lists for staff accreditation,POS operator details for settlement reconciliation,Wristband/FR/QR assignments,C. Third-Party Systems Used by Organisers,Organisers may connect external tools (CRM, analytics, settlement partners).
When data flows through such integrations, they become separate controllers.,D. Payment Partners,Banking or settlement details may be shared with payment processors for:,Payouts,Refunds,Compliance,Chargebacks,E. Law Enforcement or Authorities,If required for:,Event licensing,Safety compliance,Legal investigations,Fraud prevention
16.4 Responsibilities of Organisers, Exhibitors & Vendors
All Business Partners agree that:,They must handle personal data shared with them in compliance with applicable laws,They are independently responsible for privacy practices on their own platforms,Any misuse of attendee or lead data is the responsibility of the Business Partner,Exhibitors must not spam attendees or misuse networking data,Organisers must not export or sell user data outside permitted purposes,Vendors must protect POS terminals and hardware devices from tampering,FinkUP is not liable for data handled outside the FinkUP Platform.
16.5 Attendee Lead Sharing (Connect Expo)
When attendees scan exhibitor QR codes:,Exhibitors receive the attendee’s shared profile,Exhibitors may export lead lists,Exhibitors become independent controllers of the exported data,FinkUP cannot delete or revoke shared data after export,Attendees must understand that lead-sharing is voluntary.
16.6 Uploaded Documents by Business Partners
Documents uploaded for:,KYC/KYB,Venue approval,Contracting,Vendor onboarding,Staff management,are stored securely but may be retained for legally mandated periods (Section 6).
16.7 Business Partner Account Activity & Audit Logs
We maintain logs of:,Dashboard logins,Permission changes,Guest-list uploads,Ticket allocations,Report exports,API usage,Staff access mapping,This is necessary for:,Fraud detection,Dispute resolution,Operational audits,Security compliance
16.8 No Ownership Over User Data
Business Partners acknowledge:,FinkUP users are not the property of any Organiser/exhibitor,User data is managed under this Privacy Policy,Organisers may access only the minimum required for event execution,Exhibitors may access only leads voluntarily shared by attendees,Selling or redistributing user data is strictly prohibited.
16.9 Termination of Business Partner Accounts
Upon termination:,Access to dashboards will be revoked,FinkUP will retain records required for financial and legal compliance,Content uploaded by Business Partners for past events may remain for audit or archival purposes,Lead data already exported cannot be revoked
16.10 Liability Limitations for B2B Data Handling
FinkUP is not responsible for:,Misuse of attendee data by Organisers/exhibitors/vendors,Violations of privacy by third-party integrators used by Business Partners,Inaccurate or outdated information uploaded by partners,Security failures in partner-managed systems,Unlawful lead usage by exhibitors,Loss of business caused by incorrect exhibitor submissions,Business Partners must ensure compliance with all applicable laws.
17. CROSS-CONTEXT BEHAVIORAL ADVERTISING & MARKETING
FinkUP may use certain categories of information to provide personalized recommendations, promotional communications, event suggestions, retargeting, and advertising across different contexts, platforms, and channels (“Cross-Context Behavioral Advertising”).,This section explains:,What data is used,How marketing works,What You can opt out of,What You cannot opt out of (transactional communications),FinkUP does not sell user data, and does not use biometric or sensitive data for advertising.
17.1 What Data May Be Used for Advertising or Marketing
We may use the following categories of information only with Your consent or where allowed by law:,A. Profile & Demographic Data,Name (for personalized communication),Age group (not exact DOB unless needed),Gender (if provided),Preferences selected by You,B. Behavioral & Engagement Data,Events viewed or searched,Categories of events You engage with,Past purchases,Time-of-day activity patterns,Clicks on emails or push notifications,C. Technical Data,Device identifiers (IDFA/GAID),Cookie identifiers,Browser or app activity,IP-based approximate location,D. Location (Optional),City-level location for event recommendations,Precise location only if You consent (for nearby event discovery),E. Expo Data (Connect) - Limited,Only if You consent or engage with expo-related content:,Session preferences,Exhibitors You view,Topics You follow,Strictly excluded from advertising use:,Facial Recognition data,Biometric templates,RFID/NFC transaction data,Cashless wallet activity,Payment history,Sensitive personal information,Event access logs
17.2 Types of Marketing & Advertising We May Use
A. In-App Personalization,Recommended events,Suggested categories,Personalized banners,Tailored expo recommendations,B. Email, SMS & Push Notifications,Event reminders,Special offers,Early access promotions,Personalized suggestions,C. Retargeting / Remarketing,If You consent, Your anonymized identifiers may be used by:,Meta (Facebook/Instagram),Google Ads,YouTube,LinkedIn,TikTok (if integrated),to show You ads related to:,Events You viewed,Artists You follow,Categories You browse,Uncompleted purchases,D. Lookalike Audiences (Where Supported),We may use hashed identifiers to allow platforms like Meta or Google to identify users similar to You for advertising.,No sensitive or biometric information is used.,E. Sponsored Events, Exhibitors or Organisers,Event promoters may sponsor placements within FinkUP.,Personal data is not shared with sponsors unless You explicitly engage with their content.
17.3 No Use of Sensitive Data for Advertising
FinkUP will never use the following for marketing, profiling, or ad targeting:,Biometric data (FR),CCTV or face-related metadata,RFID/NFC access logs,Wallet top-up or spending activity,Payment method or history,Age verification documents,ID proofs,Expo lead exchanges,This ensures compliance with India’s developing data rules and global privacy standards.
17.4 How Targeted Advertising Works
If You consent:,FinkUP may assign You to interest categories,Cookies, SDKs, and device identifiers may track browsing patterns,Third-party networks may receive pseudonymized identifiers,These platforms may show You tailored ads on their networks,You can withdraw consent at any time (see Section 9).
17.5 Opting Out of Marketing & Advertising
You may opt out of:,A. Marketing Communications,Email,SMS,WhatsApp,Push notifications,B. Behavioral Advertising,By:,Managing cookie preferences,Using device “Limit Ad Tracking” settings,Resetting device advertising IDs,Using in-app privacy settings (where available),Following opt-out links included in ads,Opting out does not affect:,Ticket confirmations,Safety alerts,Mandatory event updates,Transactional communications,Refund or wallet notifications,These are essential for event participation.
17.6 Data Shared for Advertising Partners (If User Consents)
Advertising partners may receive:,Cookie IDs,IP-based location,Device identifiers,Browsing patterns,Interests inferred from usage,They do not receive:,Names,Phone numbers,Email addresses,Biometric templates,RFID/NFC identifiers,Wallet or payment data,Unless You explicitly allow such sharing (rare and highly regulated).
17.7 Marketing by Event Organisers, Exhibitors & Vendors
Organisers or exhibitors who receive Your data (e.g., via expo QR scans) may contact You for:,Post-event follow-ups,Marketing offers,Lead nurturing,Event announcements,FinkUP is not responsible for their marketing communications.
You must contact them directly to unsubscribe.
17.8 Personalized Recommendations Inside FinkUP (Non-Advertising)
Even if You opt out of ads, FinkUP may still personalize the app for:,Event suggestions,Category ranking,Artist-based recommendations,Exhibitor or session suggestions (Connect),Recently viewed content,This is based on legitimate interests and enhances core User experience, not advertising.
17.9 No Automated Decisions with Legal Impact
Any personalization or segmentation:,Does NOT affect Your legal rights,Does NOT deny You access to services,Does NOT alter Your price or eligibility,Does NOT use biometric data for advertising or profiling
18. GOVERNING LAW, DISPUTE RESOLUTION & JURISDICTION
This Privacy Policy is governed by, interpreted under, and enforced in accordance with the laws of India.
By using FinkUP’s Services, You agree that any dispute arising out of or relating to this Policy shall be handled exclusively under Indian legal frameworks and through the mechanisms described below.
18.1 Governing Law
This Privacy Policy is governed by the following Indian statutes, rules, and guidelines, as amended from time to time:,The Information Technology Act, 2000,Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011,Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021,Consumer Protection (E-Commerce) Rules, 2020,Applicable Indian contract laws,Applicable digital privacy and cybersecurity regulations,Where FinkUP operates internationally or uses cross-border services, international frameworks may apply only to the extent required by applicable law.
18.2 Jurisdiction
You agree that:,Courts located in [City, State - e.g., Jaipur, Rajasthan or Bengaluru, Karnataka] shall have exclusive jurisdiction over all privacy-related disputes,No other court or jurisdiction may be invoked unless required by Indian law,You waive any objections to the jurisdiction, venue, or convenience of these courts,This ensures a unified legal venue for all privacy disputes involving FinkUP.,(We can update the city once you confirm your preferred corporate jurisdiction.)
18.3 Dispute Resolution Mechanism
Before initiating legal action, You agree to follow the steps below:,A. Step 1: Submit a Complaint to the Grievance Officer,As per Section 29 (Grievance Redressal),FinkUP will acknowledge within 24–48 hours,Resolution will be attempted within 15–30 days,B. Step 2: Attempt Informal Resolution,You agree to attempt good-faith resolution through:,Email communication,Meetings (virtual or physical),Document review,Clarifications from FinkUP,C. Step 3: Arbitration (If Applicable),If the Privacy Policy or Terms & Conditions specify binding arbitration, then:,The dispute will be referred to a single arbitrator,The arbitrator will be appointed per the Arbitration and Conciliation Act, 1996,Proceedings may be conducted virtually,Arbitration seat and venue: [City, India],Arbitration language: English,D. Step 4: Courts of Jurisdiction,If arbitration is not applicable or fails, the matter will proceed to the courts specified in Section 18.2.
18.4 International Users
If You access FinkUP from outside India:,You are responsible for complying with local privacy laws,You consent to the transfer of Your data to India,You agree that Indian laws govern any dispute,You agree that Indian courts have exclusive jurisdiction,FinkUP is not responsible for violations of foreign privacy laws caused by user actions.
18.5 Limitation on Class Actions & Consolidated Claims
To the maximum extent permitted by law:,You may bring claims only in Your individual capacity,You may not bring claims as part of a class, collective, or representative action,Consolidated claims by multiple users are not permitted,This protects FinkUP from large-scale, group litigation.
18.6 Limitation of Claims Period
Any privacy-related claim must be brought within:,One (1) year from the date the issue first occurred or,One (1) year from when You reasonably should have known about the issue,Claims raised after this period shall be permanently barred, unless otherwise required under applicable law.
18.7 Language of Proceedings
All legal notices, arbitration proceedings, and court actions relating to this Privacy Policy shall be conducted in English, unless otherwise required by law.
19. LIMITATION OF LIABILITY (Privacy-Specific)
To the fullest extent permitted by applicable law, FinkUP, its affiliates, directors, employees, agents, partners, licensors, vendors, and service providers (“FinkUP Parties”) shall not be liable for any losses, damages, claims, or liabilities arising from or related to the collection, storage, processing, use, disclosure, or handling of personal data under this Privacy Policy, except as expressly required by law.,This section supplements - and does not replace - the broader limitation of liability defined in the Terms & Conditions.
19.1 No Liability for User Negligence
FinkUP is not responsible for any privacy breach or misuse arising from:,You sharing Your OTP, password, or QR ticket,You losing Your phone, wristband, RFID/NFC card, or device,You granting permissions to malicious apps,You using rooted/jailbroken devices,You failing to log out of shared devices,You posting screenshots of tickets or wallet balances,You sharing Connect expo leads voluntarily,You misconfiguring privacy settings in Your device,All such incidents are solely the user’s responsibility.
19.2 No Liability for Organiser, Exhibitor, Vendor, or Partner Actions
FinkUP is not responsible for misuse or mishandling of Your data by:,Event Organisers,Artists or performer managers,Venues,Exhibitors at expos,Vendors operating POS or stalls,Sponsors,Agencies or production companies,Third-party integrators used by Organisers/exhibitors,Once data is shared according to event or expo rules, these entities are independent controllers of that data.
19.3 No Liability for Third-Party Services, Tools, or SDKs
FinkUP is not liable for:,Breaches originating from third-party systems,Unauthorized access in payment gateways,Failures or data misuse by cloud providers,SDK vulnerabilities or tracker misuse,Issues arising from social login providers,Expo exhibitor CRM systems,Communication partners (SMS, WhatsApp, email),FR or RFID technology processors operated by third parties,Such systems operate under their own privacy and security frameworks.
19.4 No Liability for Voluntary Data Sharing by Users
FinkUP is not responsible for privacy risks arising from:,Users sharing personal data with exhibitors via QR scans,Users posting or uploading UGC publicly,Users sharing information with strangers at events,Users contacting exhibitors, vendors, or Organisers directly,Users opting into third-party marketing or surveys,Once data is voluntarily shared, FinkUP cannot control further use.
19.5 No Liability for Device, Network, and Environmental Failures
FinkUP is not liable for:,Internet failure or network downtime,Delay in OTP delivery,Poor mobile network reception at events,Phone battery failure affecting QR/FR entry,Malfunction caused by device incompatibility,Hardware tampering by third parties,RFID/NFC interference due to environmental factors,These are outside FinkUP’s reasonable control.
19.6 No Liability for Access Control or FR-Related Issues Caused by Users
FinkUP is not liable for:,FR failure due to improper face capture (masks, hats, lighting),RFID wristband damage due to user mishandling,QR codes shared or leaked by users,Duplicate access caused by users forwarding tickets,Incorrect or inconsistent enrollment details,Users refusing mandatory ID checks at events,These issues are not privacy breaches caused by FinkUP.
19.7 No Liability for Attendee or Public Interaction Risks
At events, expos, or conferences, FinkUP is not responsible for:,Conversations between attendees,Business card or QR lead exchanges,Photos/videos taken by other attendees,Public exposure in event livestreams or recording zones,Publicly displayed attendee profiles (Connect),Interactions initiated by exhibitors,Event environments inherently involve interpersonal sharing.
19.8 No Liability for UGC Posted by Users or Partners
FinkUP is not liable for:,Inaccurate, offensive, misleading, or illegal UGC,UGC that contains third-party personal data,UGC uploaded or posted by Organisers or exhibitors,“Screenshots” or “screen recordings” shared externally,Data exposure caused by UGC published publicly,UGC moderation is discretionary, not guaranteed.
19.9 No Liability for Consequential or Indirect Damages
FinkUP shall not be liable for:,Loss of profits,Loss of business opportunities,Emotional distress or reputational harm,Loss of enjoyment of an event,Financial loss due to delayed refunds by Organisers,Indirect, incidental, or special damages,This applies to all privacy-related claims.
19.10 Maximum Liability Cap (Privacy-Specific)
To the maximum extent allowed by law:,FinkUP’s total cumulative liability for any privacy-related claim shall not exceed the total amount You paid to FinkUP for the specific booking or service related to the dispute.,If the claim is not related to a booking, the liability cap is INR 1,000 (one thousand rupees).,This cap applies even if:,User alleges negligence,Third-party caused the breach,Damages claimed exceed direct losses
19.11 No Guarantee of Error-Free or Bug-Free Operation
You acknowledge:,Software and hardware systems may experience bugs,Apps and devices may fail under certain network or environmental conditions,Zero-risk systems do not exist,Privacy protections are best-effort and industry-standard,FinkUP does not guarantee uninterrupted platform availability.
20. CHANGES TO THIS PRIVACY POLICY
FinkUP may update, modify, amend, or replace this Privacy Policy from time to time to reflect changes in:,Our business operations,New features or services,Technological advancements,Legal or regulatory requirements,Security practices,Third-party integrations,Industry standards,Event ecosystem needs,We encourage You to review this Privacy Policy periodically.
20.1 Right to Modify the Privacy Policy
FinkUP reserves the right, at its sole discretion, to:,Update existing sections,Add new sections,Remove outdated or redundant clauses,Modify data collection practices,Expand sharing or processing categories (within legal limits),Adjust retention timelines,Introduce or discontinue features (e.g., FR, RFID, expo tools),Updates may occur with or without prior notice, depending on the nature of the change.
20.2 When We Will Notify You About Changes
We may notify You about material changes via:,Email,SMS,Push notification,In-app banners,Notifications inside dashboards,Updates posted on the website,A change is considered “material” when it:,Affects how Your personal data is used,Expands sharing with new categories of third parties,Introduces new biometric or sensitive data processing,Significantly alters Your rights or obligations,Non-material changes (formatting, clarifications, UI updates) may not trigger direct notifications.
20.3 Continued Use Constitutes Acceptance
Your continued use of:,FinkUP ticketing,Connect expo platform,FinkCash wallet,FinFace biometric entry,POS or scanning systems,Organiser or vendor dashboards,Any related FinkUP services,after the effective date of the updated Privacy Policy constitutes Your acceptance of the revised terms.,If You do not agree with the revised Privacy Policy, You should:,Stop using the Services immediately,Request account deletion as per Section 9,Contact our Grievance Officer for clarifications
20.4 Versioning & Effective Date
FinkUP may maintain version numbers or update the “Last Updated” date at the top of the Privacy Policy.,The updated policy becomes effective on:,The date identified in the document, OR,The date communicated through official notices,whichever is earlier.
20.5 Retroactive Effect of Changes
Unless legally required:,Changes will not apply retroactively,Previously collected data will continue to be processed under the terms applicable at the time of collection, unless You consent to new uses,For compliance or safety reasons, retention policies may apply retroactively.
20.6 Situations Requiring Immediate Policy Changes
FinkUP may immediately update this Policy if required by:,Law enforcement,Government directives,CERT-In guidelines,Industry standards,Payment or banking partners,Biometric processing regulations,Security vulnerabilities requiring urgent adjustments,Such updates may occur without prior user notification where legally mandated.
20.7 Responsibility of the User to Review Changes
It is Your responsibility to:,Review this Privacy Policy periodically,Stay informed about updates,Understand how changes may impact Your data,Evaluate whether You wish to continue using the Services,FinkUP will not be liable for any misunderstanding resulting from failure to review updated terms.
21. CONTACT INFORMATION & PRIVACY QUERIES
If You have questions, concerns, or requests related specifically to this Privacy Policy or to FinkUP’s data processing practices, You may contact our designated Privacy Team.,Please note:
This section is not for dispute resolution, legal notices, fraud complaints, refund issues, or service grievances.
Those are handled separately under Section 29 (Grievance Redressal Officer).
21.1 Privacy Contact Information
For all privacy-related questions, you may reach us at:,Email: [email protected]
Subject Line: “Privacy Query – [Your Name]”,You should contact this address for:,Clarifications about how we handle your data,Questions about data practices, retention, or access,Requests for copies of the Privacy Policy,Queries about third-party sharing,Questions about biometric, RFID, or expo data,Understanding how consent or opt-out works,Questions regarding specific privacy features,Do not send grievances or legal notices to this address.
21.2 Types of Queries Accepted Through This Channel
We will assist you with:,A. Understanding the Policy,What data we collect,Why we collect it,How long we keep it,How we use cookies, trackers, SDKs,B. Understanding consent,How to withdraw consent,Managing permissions,Understanding facial recognition opt-in/opt-out,C. Understanding Your rights,Access,Correction,Deletion (where applicable),Restriction,Portability (where applicable),D. General privacy concerns,How biometric data is protected,How wristband or RFID data is handled,How expo lead-sharing works,How tickets and wallets interact with personal data,This mailbox is for education, clarification, and procedural understanding.
21.3 What This Channel Does NOT Handle
This privacy contact point does not process:,Fraud or security incidents,Event entry problems,Ticket delivery issues,Wallet refund requests,Exhibitor lead misuse complaints,Payment disputes,Data breach notifications,Formal privacy grievances,Legal notices,These are handled exclusively through the Grievance Redressal Officer (Section 29).
21.4 Verification Requirements for Certain Requests
For privacy-related requests that involve:,Accessing Your data,Editing Your profile,Deletion requests,Restriction of processing,Withdrawal of consent,We may require You to provide:,Identity verification,Account ownership confirmation,Additional details for authentication,Specific clarity on the scope of the request,This ensures the security of Your data.
21.5 Typical Response Timelines
FinkUP will:,Acknowledge privacy inquiries typically within 3–7 business days,Provide a detailed response within a reasonable time, depending on complexity,Requests that overlap with formal grievance criteria will be redirected to the GRO (Section 29).
21.6 Language, Accessibility & Assistance
You may send queries in:,English (preferred, fastest processing),Hindi,Any other language supported by our team at the time,We aim to provide privacy information in an accessible and user-friendly manner.
22. SPECIAL CATEGORIES OF DATA PROCESSING
FinkUP may process certain categories of information that are considered sensitive, special, or require enhanced protections due to their nature, purpose, or potential privacy impact.,These categories are processed strictly for operational, safety, fraud-prevention, and experience-enhancing purposes, and never for marketing, cross-selling, resale, or profiling beyond what is essential for the functioning of the Services.
22.1 Biometric Data (Facial Recognition – FinFace)
If You enroll in Facial Recognition, we may collect and process:,Facial maps or vectors,Biometric templates (mathematically encrypted representations),Liveness detection frames,One-time capture images (discarded post-processing),Purpose of processing:,Event entry verification,Queue reduction,Fraud prevention,Authorized zone access,We DO NOT:,Sell, share, or disclose biometric data to third parties,Use biometric data for marketing or advertising,Use biometric data for behavioral analytics,Store raw face images unnecessarily,Allow exhibitors, Organisers, or vendors to access biometric data,Biometric templates are encrypted, segregated, access-controlled, and deleted as per retention rules (Section 6).
22.2 RFID / NFC Wristband Data & Access Logs
When You use RFID or NFC wristbands for:,Entry,Access control,Cashless transactions,Queue management,Zone or session validation,We may process:,Wristband ID,Timestamped scans,Access permissions & zone allocations,Device ID of scanning hardware,Staff/operator ID linked to the scan,We DO NOT:,Track continuous movement,Build personal movement profiles for marketing,Share wristband logs with exhibitors or sponsors,Store wristband data indefinitely,Access logs are used ONLY for operational & safety purposes.
22.3 Cashless Wallet Metadata (FinkCash)
FinkUP processes:,Wallet ID,Load, refund, and spend metadata,Vendor/POS operator ID,Timestamped wallet actions,Reconciliation logs,We DO NOT:,Profile users based on spending for advertising,Sell purchase patterns to sponsors or exhibitors,Share individual transaction logs with third parties (except the Organiser, as required),Store financial-sensitive information such as card numbers,Wallet settlements & reconciliations follow strict access control.
22.4 QR Code/Data Identifiers
QR codes used for:,Ticket entry,Session access,Wristband linking,Exhibitor lead scans,may contain encoded identifiers (not personal data directly).,Scanning a QR voluntarily (e.g., exhibitor QR) may share Your profile, but this is:,Opt-in,User-initiated,Limited to expo context,Controlled by exhibitor policies,FinkUP is not responsible for misuse of data voluntarily shared through expo QR scans.
22.5 Identity Documents (Age, KYC, Staff Verification)
FinkUP may collect or process:,Government-issued IDs,Age verification documents,Staff onboarding documents,KYC/KYB documents for Organisers/exhibitors/vendors,Purpose:,Event compliance,Restricted access zones (18+, backstage, VIP, crew),Fraud prevention,Legal/regulatory requirements,We DO NOT:,Use ID documents for marketing,Share ID documents with exhibitors or sponsors,Retain ID documents beyond required retention periods,Where possible, only essential fields (e.g., date of birth) are extracted.
22.6 CCTV Footage (Event Integrations)
If an event integrates CCTV feeds with FinkUP systems for:,Security,Access control,Lost & found,Crowd flow management,FinkUP may process metadata such as:,Location of camera,Timestamp,Zone identifiers,FinkUP does not own CCTV footage.
CCTV is controlled by the Organiser or Venue and governed by their policies.,FinkUP may assist only in system integration-not in storage, retention, or access to raw video feeds.
22.7 Access Control & Movement Logs
For safety and operational management, we may process:,Zone entry/exit timestamps,Session check-ins,Wristband/QR/FR validations,Attempts of unauthorized entry,Staff/operator activity logs,Purpose:,Evacuation management,Fraud detection,Compliance & safety reporting,Crowd management,We DO NOT:,Track real-time personal routes,Build behavioral maps for advertising,Share access logs with exhibitors,Logs are retained only as required (Section 6).
22.8 Special Data for Organisers, Exhibitors & Vendors
We may process:,Staff lists,Crew photos,Emergency contact info,Vendor settlement documents,Sponsorship contracts,Exhibitor lead mapping,These are processed strictly for operational, backstage, safety, and settlement purposes.,FinkUP does not expose this data to attendees or unauthorized third parties.
22.9 Processing Required by Law
We may process special categories of data if required by:,Law enforcement,Government agencies,Venue-level safety compliance,Regulatory bodies,Court orders,All such processing is done with strict legal oversight.
22.10 Additional Protective Measures
Special category data at FinkUP is protected through:,Encryption (rest + transit),Segregated storage,Access control & tiered permissions,Dual-key or multi-factor operational access,Audit trails,Time-bound retention,Secure deletion policies,Vendor DPIAs (Data Protection Impact Assessments)
23. COOKIES, SDKs, TRACKING TECHNOLOGIES & DEVICE PERMISSIONS
FinkUP uses cookies, mobile SDKs, device permissions, beacons, pixels, scripts, and similar tracking technologies to enable core functionality, improve performance, enhance security, personalise experiences, and deliver our Services across web and mobile platforms.,This section explains what these technologies are, what they collect, and how You can control them.
23.1 Cookies & Web Tracking Technologies
Cookies are small data files stored on Your browser or device.,FinkUP uses the following types:,A. Essential / Strictly Necessary Cookies,Used for:,Login sessions,Ticket booking and checkout,Basket management,Payment redirection,Fraud and security,Load balancing,These cannot be disabled because the platform will not function without them.,B. Functional Cookies,Used for:,Remembering preferences (language, region, theme),Saving event filters,Improving UI/UX experience,Disabling them may reduce usability.,C. Analytics & Performance Cookies,Used for:,Understanding traffic patterns,Identifying app crashes,Measuring performance across devices,Behavioral analytics to improve navigation,These may come from third parties such as:,Google Analytics,Mixpanel,Amplitude,Hotjar,FinkUP internal analytics tools,D. Advertising & Retargeting Cookies (If You Consent),Used for:,Event recommendations,Targeted advertising,Re-engagement campaigns,Providers may include:,Meta (Facebook/Instagram),Google Ads,YouTube,LinkedIn,TikTok,Other ad networks,No biometric, payment, wallet, or RFID/FR data is used for advertising.,E. Third-Party Cookies,Placed through:,Embedded payment gateways,Video players,Social logins,Expo partner links,Sponsorship or promotional content,These providers maintain their own policies.
23.2 Mobile SDKs (App Tracking Technologies)
The FinkUP mobile apps may include SDKs from:,Firebase / Crashlytics,AppsFlyer / Branch / Adjust,Mixpanel / Amplitude,MoEngage / CleverTap / OneSignal,Google Play Services / Apple SDKs,Payment gateway SDKs,QR/Scanner libraries,Bluetooth/NFC frameworks,Expo/Connect tools,SDKs may collect:,Device information,App usage patterns,Attribution data,Crash logs,Push notification tokens,Approximate location (if permitted),QR scan events,SDKs do NOT collect:,Biometric templates,Wallet numbers,Sensitive identity documents,Facial recognition data
23.3 Web Beacons, Pixels & Server Logs
We may use:,Email tracking pixels,Conversion pixels,Server logs for fraud detection,Invisible 1x1 pixel tags,These help measure engagement, prevent abuse, and improve performance.
23.4 Device Permissions (Mobile & Web)
FinkUP may request the following permissions:,A. Camera Access,Required for:,QR code scanning,Wristband linking,Expo lead scanning,FR enrollment (if You opt in),We do not access Your gallery unless You explicitly upload a file.,B. Location Access,Used for:,Finding events nearby,Venue mapping,Enhancing expo or festival navigation,Optional personalization,Location is not mandatory for ticket booking.,You may allow:,Precise location,Approximate location,No location,C. Bluetooth / NFC,Used for:,RFID/NFC cashless wristband pairing,Scanning contactless credentials,Access control features,Disabled Bluetooth/NFC may limit some event features.,D. Notifications,Used for:,Ticket delivery,Event reminders,Safety alerts,Wallet-related updates,Queue movement notifications (if supported),Promotional notifications require opt-in/opt-out control.,E. Photo Gallery Access,Used ONLY when:,You upload a profile photo,You upload documents (KYC, ID),You upload exhibitor media,We never access your gallery automatically.,F. Microphone (Rare Cases),Used only for:,In-app support or voice search (if implemented),Not required by default.,G. Contacts (Optional),Used only if You explicitly allow:,Referrals,Inviting friends,Networking features,This is always optional and never auto-enabled.
23.5 How You Can Control Cookies & Tracking Technologies
You may:,Adjust browser cookie settings,Reject non-essential cookies,Use browser extensions to block trackers,Manage device “Limit Ad Tracking” settings,Reset mobile advertising IDs,Disable Bluetooth/NFC at any time,Deny location permissions,Disable personalized ads on partner platforms,Manage app permissions in device settings,Some features may not function properly if certain permissions are denied.
23.6 Do Not Track (DNT) Signals
Most browsers allow DNT settings.,FinkUP currently:,Does NOT respond to DNT signals universally,Follows industry standards,Continues essential tracking regardless of DNT (for security),Where legally required, we will update compliance accordingly.
23.7 Third-Party Tracking Limitations
FinkUP:,Does NOT control how third-party SDKs independently process data,Ensures all partners contractually follow privacy safeguards,Monitors third-party libraries for compliance,May disable or replace SDKs that violate policies,Users must review third-party privacy practices independently.
24. TRANSFERS IN THE EVENT OF MERGER, ACQUISITION OR CORPORATE RESTRUCTURING
FinkUP may, in the future, undergo internal organisational changes or participate in transactions such as mergers, acquisitions, reorganisations, consolidations, asset sales, investment events, joint ventures, or transfers of business units, technology platforms, or product verticals.
In such scenarios, Your personal data may be transferred to another entity, subject to the protections described in this Privacy Policy.,This Section explains how Your data will be handled in such situations.
24.1 Transfer of Data as Part of Corporate Transactions
If FinkUP or any of its business units (such as Ticketing, Connect, FinkCash, FinScan, FinFace, or POS Services) is:,sold or acquired (fully or partially),,merged with another entity,,restructured internally,,spun off as a separate product line,,transferred as part of asset sale,,or engaged in a strategic partnership where data portability is required,,then Your information may be transferred to the acquiring or successor entity.,Such transfer will occur solely for legitimate business purposes and under confidentiality and security obligations that are at least as protective as this Privacy Policy.
24.2 Categories of Data That May Be Transferred
Depending on the nature of the transaction, we may transfer:,A. User Data,Profile details,Ticketing history,Wallet metadata,Event interactions,B. Organiser, Vendor & Exhibitor Data,Business profiles,Contracts & billing records,Event operational data,C. Technical & Operational Data,Logs,Analytics,System configurations,API integrations,D. Special Category Data (Strict Controls),Biometric templates, RFID logs, and ID proofs will only be transferred if:,legally permitted,,encrypted and access-controlled,,required for continuity of services,,or necessary for legal compliance.,No acquiring entity may use such special data beyond legitimate operational purposes.
24.3 Successor Entities Must Honor This Privacy Policy
Any entity that acquires, merges with, or absorbs FinkUP (or any of its units) will be required to:,Honor the commitments made in this Privacy Policy, OR,Provide privacy protections equal to or greater than those outlined here, OR,Notify You of any changes where required by law.,Your data will not be used in a manner inconsistent with this Privacy Policy without proper legal or user consent mechanisms.
24.4 Notice to Users Upon Significant Transactions
Where required by law or where the transaction materially affects how Your data is handled, FinkUP may notify You via:,Email,SMS,Push notification,In-app banners,Updated Privacy Policy notice on the website,Notification needs may vary depending on the legal nature of the transaction.
24.5 User Choices During Corporate Change
In some cases, You may be given choices such as:,Continuing to use services with the new entity,Deleting Your account,Opting out of specific services,Withdrawing from optional data uses,However, certain data must be retained if:,Required for legal, regulatory, or financial compliance,Required for fraud detection or safety logs,Required for settlement, reconciliation, or audit compliance
24.6 No Sale of Personal Data
FinkUP does not sell Your personal data for monetary gain.,If personal data is transferred during a corporate event:,It is transferred as part of the business assets,,Under strict contractual protections,,And ONLY for legitimate operational continuity.
24.7 Continuity of Services Through Corporate Changes
In case of a merger, acquisition, or restructuring:,Your account may automatically transfer,Your tickets and purchases remain valid,Wallet balances and refunds will be honored,Connect profiles and expo leads remain intact,POS, access, and RFID functionalities remain operational,The intent is zero disruption to users and partners.
25. ADDITIONAL RIGHTS FOR SPECIFIC JURISDICTIONS
FinkUP’s Services may be accessed by users residing outside India.
Certain countries provide additional privacy rights to their residents.
This Section outlines those rights and how they may apply.,If any provision in this Section conflicts with earlier parts of this Privacy Policy, the provision that offers greater user protection shall apply - but only for residents of that jurisdiction.
25.1 European Union (EU) & European Economic Area (EEA) - GDPR Rights
If You are located in the EU/EEA, You may have the following rights under the General Data Protection Regulation (GDPR):,A. Right to Access,You may request a copy of the personal data FinkUP holds about You.,B. Right to Rectification,You may request correction of inaccurate or incomplete data.,C. Right to Erasure (“Right to be Forgotten”),You may request deletion of Your data where:,Processing is no longer necessary,You withdraw consent,Processing is unlawful,Certain exceptions apply (e.g., legal requirements, fraud logs).,D. Right to Restrict Processing,You may request temporary restriction of processing.,E. Right to Data Portability,You may request Your data in a structured, commonly used, machine-readable format.,F. Right to Object to Processing,You may object to:,Direct marketing,Profiling,Legitimate-interest-based processing,G. Right to Withdraw Consent,You may revoke consent at any time without affecting prior lawful processing.,H. Right Not to Be Subject to Automated Decision-Making,FinkUP does not use automated decisions that create legal effects.,I. Cross-Border Transfers,We ensure safeguards such as:,Standard Contractual Clauses (SCCs),Encryption,Vendor due diligence
25.2 United Kingdom (UK GDPR)
If You are located in the United Kingdom, You enjoy rights similar to EU GDPR.,Processing complies with:,UK GDPR,Data Protection Act 2018,Your rights mirror those listed above.
25.3 United Arab Emirates (UAE)
(Recommended for FinkUP’s future UAE expansion),Residents of the UAE (including DIFC/ADGM zones) may have rights under UAE data protection laws.,These may include:,Right to information,Right to access,Right to correction or deletion,Right to restrict processing,Right to withdraw consent,Right to complain to the UAE Data Office or local regulator,If FinkUP launches UAE operations, we will revise this Policy to meet region-specific regulations.
25.4 United States (California + Other States)
(Generalized wording - applies only if users from relevant states access FinkUP),If You are a resident of California or states with similar privacy laws, You may have rights such as:,Right to know categories of data collected,Right to request access to personal data,Right to deletion (with exceptions),Right to opt out of “sale” of personal data,Right to know categories of third parties receiving data,Right to non-discrimination for exercising privacy rights,FinkUP does not sell personal data.,State-specific rights (CPRA, Colorado, Virginia, etc.) may apply depending on user residence.
25.5 Singapore (PDPA)
Users in Singapore may have rights under the Personal Data Protection Act (PDPA), including:,Right to access,Right to correction,Right to withdraw consent,Right to be informed of purposes,FinkUP will comply with PDPA as applicable.
25.6 Other Regions
Users from other jurisdictions may have rights under local data protection laws.
Where required, FinkUP will:,Respect lawful requests,Provide necessary disclosures,Align processing practices with local norms
25.7 How to Exercise These Rights
Requests from regions with special rights must be sent to:,Email: [email protected]
Subject: “International Privacy Rights Request – [Your Country]”,We may require:,Proof of residency,Proof of identity,Details of Your relationship with FinkUP,Certain rights may be limited due to:,Legal obligations,Fraud prevention,Operational requirements,Safety and security protocols
26. ADDITIONAL PROVISIONS FOR ORGANIZERS, EXHIBITORS, VENDORS & STAFF
This Section outlines additional obligations and expectations for all organisers, Exhibitors, Vendors, Staff, Agencies, and Crew Members (“Event Partners”) who use FinkUP’s B2B tools, dashboards, APIs, devices, or operational systems.,These provisions apply in addition to the general Privacy Policy and Section 16 (B2B Data).,Event Partners are independently responsible for complying with all applicable privacy and data protection laws.
26.1 Data Access Responsibilities of Event Partners
Event Partners receive access to certain data strictly for the purpose of:,Managing event operations,Conducting ticket validations,Providing attendee services,Running cashless POS operations,Managing crew & staff access,Operating exhibitor booths,Managing guest lists,Issuing wristbands & QR credentials,Event Partners must:,Access only the data needed for their role,Restrict access internally to authorized staff only,Use data solely for event-related purposes,Protect data from unauthorized disclosure,Follow all FinkUP security guidelines
26.2 Prohibited Uses of Attendee Data
Event Partners may NOT:,Sell attendee data,Rent or trade attendee data,Build external marketing databases using FinkUP data,Contact attendees outside the scope of the event,Add attendees to generic sales pipelines,Share data with external vendors without attendee consent,Use FinkUP data for competitor research,Export biometric, FR logs, or access logs,Violations may result in:,Permanent account suspension,Legal action,Reporting to authorities
26.3 Restrictions for Exhibitors (Connect Expo)
Exhibitors may receive attendee data ONLY when:,An attendee scans an exhibitor QR code,An attendee explicitly shares their profile,The attendee engages with the booth voluntarily,Exhibitors MUST NOT:,Harvest leads using unauthorized QR codes,Use shared leads for spam or cold marketing,Sell or transfer lead data to third parties,Attempt to collect biometric or FR data,Attempt to track attendee movement,Combine FinkUP data with external datasets for profiling,FinkUP is not responsible for an exhibitor’s misuse of voluntarily shared attendee leads.
26.4 Responsibilities for POS Vendors & On-Ground Operators
POS vendors and staff who handle FinkUP cashless payments must:,Protect POS terminals from tampering,Maintain device security,Keep operator credentials confidential,Prevent unauthorized refunds or top-ups,Use POS data only for settlement purposes,Not access attendee identities unnecessary,FinkUP may audit POS logs to ensure compliance.
26.5 Responsibilities for Crew, Staff & Volunteers
Crew and staff may handle:,Access lists,Wristband assignments,Security queues,Lost & found management,Operational data,They must:,Not photograph or record attendee lists,Not share backstage or VIP access data,Not disclose staff logs or access zones,Not misuse attendee information for personal gain,Any misuse may result in:,Event banning,Blacklisting,Legal consequences
26.6 Organizer Responsibilities for Data Uploaded to FinkUP
Organizers must ensure:,Data uploaded (guest lists, staff lists, artist details) is accurate,No unnecessary personal data is uploaded,Sensitive information is avoided unless required,They obtain consent where required by law,They comply with local regulations (e.g., age-restricted events),Organizers are responsible for the privacy of information uploaded by them.
26.7 Restrictions on Viewing or Exporting Data
Event Partners may only export:,Reports,Logs,Lead lists,Guest lists,POS settlements,which they are explicitly authorized to access.,They may NOT export:,Biometric or FR templates,Wristband identifiers,Raw access logs,Wallet transaction logs tied to identity,User behavioral profiles,Device-level metadata
26.8 Vendor Agreements & Contractual Controls
Certain Event Partners (e.g., cashless vendors, RFID operators, security agencies, hardware vendors) may sign additional agreements covering:,Confidentiality obligations,Data protection controls,Technical access restrictions,Data disposal guidelines,Device handling protocols,Breach notification obligations,These agreements override this Privacy Policy where stricter obligations apply.
26.9 Data Retention Obligations for Event Partners
Event Partners must:,Delete exported attendee data after completing event operations unless legally required,Not store biometric or FR-related information,Not retain wristband mappings,Not retain POS logs beyond statutory requirements,Follow FinkUP’s deletion or disposal guidelines,FinkUP may request proof of deletion.
26.10 Liability & Indemnification
Event Partners agree that:,They are solely liable for misuse of data accessed through FinkUP,FinkUP is not responsible for partner-side security breaches,Event Partners must indemnify FinkUP for damages caused by their misuse,This ensures accountability and protects FinkUP legally.
27. CALIFORNIA / U.S.-SPECIFIC DISCLOSURES
This Section applies only to Users who are residents of the State of California, United States, and is provided in accordance with the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).,If You are not a California resident, this Section does not apply to You.
27.1 Categories of Personal Information Collected (Past 12 Months)
California law requires companies to list, by category, the types of information collected.,Below is a CPRA-style disclosure table:,FinkUP does not collect:,Social Security Numbers,Financial account numbers,Government ID numbers (unless You submit for age/staff verification),Highly sensitive U.S.-specific identifiers
27.2 Categories of Personal Information Disclosed for Business Purposes
Under CPRA, companies must disclose whether personal information is shared for legitimate operational uses, not “sold.”,FinkUP shares:,We do not share biometric data with third parties except the FR processor operating strictly under contract.
27.3 No “Sale” of Personal Information
Under CCPA/CPRA:,“Sale” = disclosing personal data for monetary or other valuable consideration.,FinkUP does not sell personal information.,If in the future FinkUP ever engages in advertising practices that may be interpreted as “sharing” under CPRA:,A “Do Not Sell or Share My Personal Information” link will be provided.,As of now, this does not apply, because FinkUP does not participate in data resale or third-party behavioral advertising without consent.
27.4 Right to Know (Access)
California residents may request:,The categories of personal information collected,The specific pieces of data collected,The categories of sources,The categories of third parties to whom data was disclosed,The business purposes for data collection
27.5 Right to Request Deletion
You may request deletion of Your personal information, except where data must be retained for:,Fraud prevention,Safety & access logs,Wallet settlement records,Legal or accounting obligations,Dispute resolution,Event compliance requirements
27.6 Right to Correct Inaccurate Information
You may request correction of inaccurate personal data held by FinkUP.
27.7 Right to Opt Out of “Sharing” for Cross-Context Behavioral Advertising
Even though FinkUP currently does not share data for targeted third-party advertising:,You still have the right to opt out of such sharing if implemented in the future.,We will honor such requests proactively.
27.8 Right to Restrict Use of Sensitive Personal Information
California residents may restrict the use of:,Biometric data,Precise location data,ID documents,Access logs,FinkUP already limits sensitive processing to essential operational purposes only.,No sensitive data is used for marketing or personalization.
27.9 Right to Non-Discrimination
FinkUP will not:,Deny services,Charge different prices,Provide lower-quality services,Impose penalties,for exercising privacy rights.
27.10 How California Residents Can Exercise Their Rights
Email:,[email protected]
Subject: “California Privacy Rights Request – CCPA/CPRA”,We may request:,Identity verification,Proof of California residency,Details of the request
27.11 Authorized Agents
California residents may designate an authorized agent to make requests on their behalf.,We may require:,Power of attorney OR,Written permission and identity verification
27.12 Data Retention Disclosures (California Requirement)
Under CPRA, companies must disclose retention timelines:,Billing & payment data → retained per financial compliance laws,Access logs → retained for safety/fraud duration only,FR biometric templates → short-term, event-limited retention,Expo leads → retained as long as You maintain a Connect profile,Ticketing history → retained for dispute, audit & compliance,Wallet logs (FinkCash) → retained per statutory accounting requirements,Full retention details are in Section 6.
28. MISCELLANEOUS PROVISIONS
This Section contains additional provisions necessary for the interpretation, enforceability, and consistency of this Privacy Policy.
These provisions apply to all Users, Organisers, Exhibitors, Vendors, and Partners using any part of the FinkUP ecosystem.
28.1 Entire Privacy Agreement
This Privacy Policy constitutes the entire and exclusive statement of FinkUP’s privacy practices.
It supersedes any:,Prior statements,Verbal assurances,Marketing materials,FAQs,UI-based hints,Emails or communications,relating to privacy or data handling.
28.2 Relationship with Terms & Conditions
This Privacy Policy should be read in conjunction with FinkUP’s Terms & Conditions.,If both documents address the same subject, the document providing greater privacy protection to the User will prevail.,For operational or contractual matters, the Terms & Conditions prevail.,Both documents are binding upon all Users and Event Partners.
28.3 Interpretation & Headings
Headings and formatting in this Policy are for convenience only.,They do not affect meaning, scope, or legal interpretation.,Words importing the singular include the plural, and vice versa.,“Including” means “including but not limited to.”
28.4 Severability
If any provision of this Privacy Policy:,is found unlawful,,becomes invalid,,is deemed unenforceable, or,is disallowed under applicable law,,such provision shall be severed from the Policy.,The remaining provisions shall continue in full force and effect.
28.5 Waiver
Failure by FinkUP to enforce any right or clause in this Privacy Policy does not constitute a waiver.,Any waiver must be in writing and signed by an authorized representative of FinkUP.
28.6 Assignment
FinkUP may:,assign, transfer, or delegate,any of its rights, responsibilities, or obligations,under this Privacy Policy to any:,Affiliate,Subsidiary,Successor entity,Acquiring company,Strategic partner,Organizational restructure,without requiring User consent, subject to Section 24 (Corporate Transfers).,Users may not assign their rights or obligations under this Policy.
28.7 Survival of Provisions
Certain provisions survive account deletion, including:,Data Retention (Section 6),User Rights (Section 9) where ongoing legal obligations apply,Liability Limitations (Section 19),Governing Law & Jurisdiction (Section 18),Corporate Transfers (Section 24),Special Data Handling Rules (Section 22),FinkUP’s rights to store anonymized or aggregated data,These remain enforceable even after You stop using FinkUP.
28.8 No Third-Party Beneficiaries
Except as expressly stated, nothing in this Privacy Policy:,creates rights in favor of third parties,grants third parties authority to enforce provisions,Organisers, Exhibitors, Vendors, and Partners must abide by their separate agreements with FinkUP.
28.9 Language of the Policy
This Policy is drafted in English, which shall control in all interpretations.
Translations, if provided, are for convenience only.
In case of conflict, the English version shall prevail.
28.10 Conflicts with Local Laws
If any provision of this Privacy Policy conflicts with:,laws applicable in Your region,,mandatory local requirements, or,government directives,,the relevant legal requirement shall apply only to the extent needed to resolve the conflict.,The rest of the Policy remains valid.
28.11 Force Majeure (Privacy-Relevant Events)
FinkUP is not liable for failure to perform obligations relating to privacy or data protection due to events beyond reasonable control, including:,Natural disasters,Acts of terrorism,War, strikes, or riots,Network outages,Failures of cloud providers,Denial-of-service attacks,Government orders,During such events, FinkUP may temporarily suspend or modify data processing operations.
28.12 Relationship with Users & Partners
Nothing in this Privacy Policy creates:,Employment,Agency,Partnership,Fiduciary relationship,FinkUP acts solely as a technology service provider.
29. GRIEVANCE REDRESSAL OFFICER (GRO)
In compliance with applicable Indian laws, including the Information Technology Act, 2000, the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, and the Consumer Protection (E-commerce) Rules, 2020, FinkUP has appointed a designated Grievance Redressal Officer (“GRO”) to address complaints related to:,Privacy practices,Personal data processing,Misuse or unauthorised access,Sensitive data concerns,User rights requests (Section 9),Violations of this Privacy Policy,Safety, security, or data breach concerns,This Section outlines how Users can escalate privacy grievances.
29.1 Contact Details of the Grievance Redressal Officer
Name: Naveen Lawaniya
Designation: Grievance Redressal Officer, FinkUP
Email: [email protected]
Postal Address:
4th Floor, 501, Jan Path, Rani Sati Nagar, Nirman Nagar, Brijlalpura, Jaipur, Rajasthan 302019
India
29.2 Filing a Privacy Grievance
Your complaint must include:,Your full name,Registered phone number & email,Description of the issue,Relevant screenshots or documents,Booking ID or transaction ID (if applicable),Date & time of the incident,Incomplete complaints may delay resolution.
29.3 Acknowledgement Timeline
The Grievance Officer will:,Acknowledge the complaint within 24–48 hours,Initiate review within a reasonable timeframe,Provide resolution within 15–30 days, depending on complexity,Certain cases involving fraud, regulatory queries, or external partners may take longer.
29.4 Issues Handled by the GRO
The GRO handles:,Privacy and data protection issues,Sensitive data misuse,Unauthorised access complaints,Violations of this Privacy Policy,Rights requests escalation (if unresolved by privacy@),Compliance-related matters,Concerns regarding biometric, RFID, or FR data
29.5 Issues Not Handled by the GRO
The GRO does not resolve:,Ticket refunds or cancellations,Event quality complaints,Entry-related operational issues,Organiser/vendor behavioural disputes,POS errors or wallet refund issues,Delivery or merchandise issues,Those are managed by customer support or Organisers directly.
29.6 Resolution Outcomes
Depending on the issue, the GRO may:,Request clarification or documentation,Conduct internal investigation,Suspend user accounts if misuse is confirmed,Notify affected users (if required under law),Recommend policy changes,Escalate cases to authorities (in severe incidents)
29.7 Escalation to Authorities (Where Applicable)
If required by law, the GRO may:,Report the matter to CERT-In,Assist law enforcement or cybercrime authorities,Comply with government directives,Provide data under lawful requests,Such escalations follow legal protocols.
29.8 Finality of GRO Decision
The determination of the Grievance Redressal Officer shall be:,Considered final for administrative handling,Without prejudice to Your right to pursue additional remedies under applicable law,Bottom of Form
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