Privacy Policy

We are Achyut Labs Pvt Ltd (doing business as Pratham POS) (ABN 63 674 531 557). We collect personal information to operate our services and run our Partner Program. We don't sell your data. We use it to deliver services, process payments, verify your identity, and communicate with you. You have rights to access and correct your information. If you have concerns, contact us at support@achyutlabs.com.

This Privacy Policy applies to all individuals who interact with Pratham, including:

• Customers and prospective customers of Pratham's products and services;

• Partners and prospective partners in the Pratham Partner Program;

• Visitors to our website at prathampos.com;

• Employees, contractors, and job applicants (to a limited extent).

By using our services or submitting a partner application, you agree to the collection and use of information as described in this Policy.

We collect personal information:

• Directly from you — when you complete an application form, register an account, contact us, or sign an agreement;

• Automatically — when you use our website or services (via cookies, logs, and analytics tools);

• From third parties — such as identity verification providers, credit bureaus (where permitted), and referral partners;

• From public sources — such as ASIC and ABR for business verification purposes.

Pratham acts as a data controller in relation to personal information collected for its own business purposes (account management, marketing, partner program administration).

Where Pratham processes personal information on behalf of its business customers (e.g., point-of-sale transaction data), Pratham acts as a data processor. Business customers are responsible for ensuring their use of Pratham's platform complies with applicable privacy laws.

Service Delivery

To operate our platform, process applications, manage accounts, and provide customer support.

Partner Program Administration

To process partner applications, calculate commissions, issue RCTIs, and manage payout schedules.

Identity Verification

To verify the identity of applicants and comply with AML/CTF obligations.

Legal Compliance

To comply with tax laws, anti-money laundering legislation, court orders, and regulatory requirements.

Communications

To send transactional emails (application status, payment confirmations), product updates, and marketing communications (where you have consented).

Improving Our Services

To analyse usage patterns, identify bugs, and improve the performance and features of our products.

Security

To detect, prevent, and investigate fraud, unauthorised access, and other illegal activities.

Your personal information is stored on servers located in Australia (AWS Asia Pacific — Sydney region). We do not transfer personal information outside Australia without your consent or unless required to by law, except where our third-party service providers (as listed in section 7) process data in accordance with their applicable privacy commitments.

We implement technical and organisational measures to protect personal information from unauthorised access, disclosure, alteration, and destruction, including:

• Encryption in transit (TLS/SSL) and at rest (AES-256);

• Role-based access controls limiting who can access personal information;

• Multi-factor authentication for staff with access to sensitive systems;

• Regular security assessments and penetration testing;

• Staff training on privacy and security obligations.

No method of transmission or storage is 100% secure. If you believe your information has been compromised, please contact us immediately at support@achyutlabs.com.

Under the Privacy Act 1988 (Cth) and the Australian Privacy Principles, you have the right to:

• Access: request a copy of the personal information we hold about you;

• Correction: request correction of inaccurate or incomplete information;

• Complaints: lodge a complaint about our handling of your information;

• Opt-out: unsubscribe from marketing communications at any time.

To exercise these rights, contact us at support@achyutlabs.com. We will respond within 30 days. There is no charge for access requests unless the request is manifestly unreasonable or requires significant resources to fulfil.

If we refuse a request, we will explain our reasons in writing. You may then complain to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

Our website uses cookies and similar tracking technologies to:

• Remember your preferences and login session;

• Measure website traffic and usage patterns;

• Provide personalised content and advertisements.

Essential cookies (required for the website to function) cannot be disabled. Analytics and marketing cookies can be managed through your browser settings or our cookie preference centre.

We use Google Analytics with IP anonymisation enabled. You can opt out of Google Analytics tracking at tools.google.com/dlpage/gaoptout.

If you believe we have handled your personal information in breach of the Privacy Act 1988 (Cth), please:

1. Contact us first at support@achyutlabs.com — we will acknowledge your complaint within 3 business days and aim to resolve it within 30 days.

2. If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC): oaic.gov.au or 1300 363 992.

Privacy Officer

Achyut Labs Pvt Ltd (doing business as Pratham POS)

Email: support@achyutlabs.com

Web: prathampos.com

For general enquiries: support@achyutlabs.com

For partner enquiries: support@achyutlabs.com

This Privacy Policy is designed to comply with Australian privacy law. If you are accessing our services from outside Australia, please note that your information may be transferred to and stored in Australia. By using our services, you consent to this transfer.

For visitors from the European Union or United Kingdom, we acknowledge the requirements of the GDPR/UK GDPR. Where we act as a data controller for EU/UK residents, we rely on the following lawful bases: (a) contract performance (processing necessary to fulfil our agreement with you); (b) legal obligation; (c) legitimate interests. You may contact support@achyutlabs.com to exercise your GDPR rights.