Data Security Policy

Policy Objective and Scope

This policy defines how PAYOTRIX ensures protection of data—including personal, merchant, system, and infrastructure data—across all platforms: website, dashboards, APIs, backup systems, and archives. It applies to all employees, contractors, subprocessors, and third-party vendors. It meets requirements under ISO 27001, SOC 2, IT Act SPDI Rules, RBI Guidelines, and GDPR protocols.

Data Classification Framework

All data handled by PAYOTRIX is classified based on sensitivity:

• Public: marketing content

• Internal: configuration files, non-sensitive logs

• Confidential: KYC, personal identifiers

• Restricted: metadata tied to redirection events
  Security controls vary per classification, applying stricter measures on sensitive data. Classification is reviewed bi-annually or when new systems are added.

Encryption in Transit

All communications—including web dashboards, APIs, backend services, inter-datacenter transfers—are protected using TLS 1.2 or higher. Strong cipher suites such as AES‑GCM are enforced. Self-signed certificates are disallowed. Expiration and certificate integrity are monitored via Certificate Transparency services.

Encryption at Rest

All stored data—database dumps, KYC files, logs—is encrypted using AES‑256 with unique keys per storage unit. Encryption is managed by key management services with automatic rotation every 90 days. Old keys are archived securely and destroyed per the deprecation schedule.

Access Control and IAM

PAYOTRIX uses Role-Based Access Control (RBAC). Employees and systems are granted least privilege access. Admin credentials are stored using hardware-secured modules and rotated every quarter. Temporary access tokens expire within 12 hours.

Multi-Factor Authentication (MFA)

MFA is mandatory for all administrative, developer, and privileged accounts. MFA is via TOTP or OTP-based outbound channels. All login attempts are logged, with repeated failures triggering temporary blocking and login throttling.

Secure Password Management

All user accounts must meet password complexity standards: 14+ characters including mixed case, symbols, and numbers. Passwords are hashed using Argon2 or PBKDF2. Users are prompted to change passwords every 90 days, and the reuse of the last 5 passwords is prevented.

Network Security and Firewalls

PAYOTRIX's environments are segmented by VLANs, with web, app, database, and backup layers separated. Firewalls are configured to allow only necessary ports. Regular port scans and pentests verify isolation and ward off unauthorized access.

Intrusion Detection & Prevention Systems (IDS/IPS)

Real-time IDS/IPS monitors for anomalies, rate limits, brute force, and payload patterns. Alerts are escalated to security teams within 5 minutes. Signature libraries update daily, and behavioral anomaly detection is active.

Vulnerability Management

PAYOTRIX conducts weekly vulnerability scans and semi-annual penetration tests by accredited firms. Patches are applied within 48 hours for high severity and 7 days for medium severity. All updates are documented with remediation logs.

Secure Software Development Lifecycle (SDLC)

All development follows secure code practices. Code commits undergo static analysis, peer code reviews, and dynamic testing. Third-party libraries are assessed for vulnerabilities, and open-source components are limited to verified sources.

Data Backup and Recovery

Full backups occur nightly, stored encrypted off-site. PAYOTRIX regularly simulates recovery to meet RPO < 15 mins and RTO <24 hrs. Backup integrity is validated during each backup cycle.

Incident Response Plan

In the event of breach or anomaly:

1. Incident is detected via IDS.

2. The containment plan is initiated.

3. Communication with stakeholders within 72 hrs.

4. Forensics and remedial patching.

5. Post-incident review for future prevention.
   All steps are recorded in an incident log, reviewed quarterly.

Business Continuity Management

PAYOTRIX maintains an operations continuity plan, including alternate hosting readiness, DNS fallback routing, and communication templates. Simulated drills are conducted twice a year, and success metrics are evaluated.

Physical Security of Infrastructure

Infrastructure resides in Tier-IV compliant data centers with multi-factor entry, biometric access, CCTV, and mantraps. Staff must use ID badges, and access logs are audited monthly. Data center access is limited to pre-approved personnel only.

Data Retention and Disposal

PAYOTRIX follows a strict retention schedule:

• User metadata: retained for 5 years after account closure

• Audit logs: retained for 7 years as per regulatory norms

• Temporary cache & debug logs: deleted within 30 days

• KYC & compliance documents: retained per RBI mandates (min. 5 years post-deactivation)

Upon expiration, data is securely wiped using DoD 5220.22-M or equivalent protocols. Backups are deleted in sync. Paper records (if any) are cross-shredded.

Vendor and Third-Party Risk Management

All vendors used by PAYOTRIX (e.g., hosting providers, KYC processors) must:

• Sign Data Protection Addendums (DPAs)

• Be vetted for ISO 27001, PCI-DSS, or SOC2 compliance

• Undergo annual risk review and penetration testing

If a vendor fails security assessments or suffers a breach, PAYOTRIX may immediately suspend or terminate the contract and notify users if impacted.

API Security Standards

All public and private APIs on PAYOTRIX are:

• Secured via OAuth2 or signed requests

• Throttled to avoid misuse (rate limiting enforced)

• Monitored for abnormal patterns

• Versioned and sandboxed before release

All deprecated API versions are decommissioned with public notice and retired securely to avoid misuse.

Secure Logging and Monitoring

Logging systems track all critical events, including:

• Login attempts

• Data modification

• API activity

• Permission escalations

• Backend failures

Logs are immutable (write-once-read-many), encrypted, and stored across multiple regions to maintain integrity and availability for audits and breach investigations.

Endpoint Protection and Device Security

All internal systems used by PAYOTRIX employees are protected by:

• Anti-malware/EDR software

• Full-disk encryption

• OS-level sandboxing

• Remote wipe capability

USB and external device ports are disabled on secure workstations. Employees must only access data from approved devices.

Data Access Reviews and Privilege Audits

Access permissions are reviewed:

• Monthly for privileged/admin accounts

• Quarterly for standard users

• Immediately on role change or offboarding

Inactive accounts are auto-deactivated within 30 days. Admin privileges must be re-authorized every 60 days by the CISO or Compliance Head.

Cloud Security Controls

PAYOTRIX’s cloud infrastructure (if used) adheres to:

• Shared responsibility model

• Least privilege IAM roles

• Security group hardening

• Auto-remediation of misconfigurations

• Storage bucket privacy enforcement

All infrastructure changes are routed via CI/CD pipelines with logging and approval layers.

Zero Trust Architecture Implementation

PAYOTRIX follows zero-trust principles:

• No user or service is trusted by default

• Each request is evaluated for identity, context, and privilege

• Microsegmentation and real-time monitoring isolate breaches

• Devices must authenticate independently

This reduces lateral movement risk in case of intrusion.

User Consent and Privacy Settings

Users must explicitly consent before:

• Data is stored in a persistent form (cookies/logs)

• Communications are sent (marketing/transactional)

• Third-party integrations are authorized

Consent is logged with a timestamp and IP for auditing. Users may modify consent through the dashboard.

Data Masking and Anonymization

Before logging or sharing data (e.g., with third-party tools or analytics), PAYOTRIX applies:

• Data masking for email, phone, and IP

• Tokenization of user IDs

• Redaction of sensitive fields from dashboards and logs

No real PII is exposed in operational analytics or support tools.

Email and Notification Security

Transactional emails are sent using verified DKIM, SPF, and DMARC standards to prevent spoofing. In-app notifications are encrypted at rest and sent via secure sockets. Notifications containing sensitive data are tokenized and expire within 24 hours.

User Education and Awareness

All registered merchants are provided:

• Security best practices guides

• Warning labels for high-risk actions

• Step-by-step KYC/document upload instructions

• Phishing education during account setup

These documents are accessible via the dashboard or the help center.

Change Management Controls

Any code, infrastructure, or logic change must go through:

• Peer review (via version control)

• Automated test suite

• Staging/QA approval

• Manual security checklist validation

High-impact changes require CISO signoff and rollback plans. All change logs are archived.

Security Breach Disclosure Policy

If a breach affects user data:

• PAYOTRIX will notify affected users within 72 hours

• Provide impact analysis and mitigation actions

• Notify CERT-IN, RBI, or DSCI, where applicable

• Temporarily suspend compromised systems and services

Breach reports are published where required by regulation or user demand.

Employee Access Logging and Tracking

All employee activity on user data is logged:

• Time, IP, location, activity type

• Limited to authorized roles only

• Random spot audits by the internal compliance team

• Repeat violations trigger disciplinary action or termination

Employees must agree to data confidentiality and usage policies before system access is granted.

Regulatory Compliance and Legal Obligations

PAYOTRIX adheres to data protection laws, including:

• Information Technology Act, 2000 & SPDI Rules (India)

• RBI Master Directions for digital platforms

• GDPR (for EU-based users)

• ISO/IEC 27001:2013 & SOC2 compliance controls
  All data handling practices are documented and reviewed to ensure regulatory conformity. Legal compliance officers oversee updates and audits.

Data Portability and Export Controls

Users can request their data export in a machine-readable format (JSON, CSV, or XML). PAYOTRIX will:

• Verify the user’s identity

• Sanitize logs before packaging

• Process the request within 10 working days

• Log the export for compliance records

Data exports are encrypted with a one-time password shared separately via email.

Biometric and Sensitive Personal Data Handling

Though PAYOTRIX does not collect financial or biometric data, in case of future compliance integrations (e.g., Aadhaar verification), any biometric or highly sensitive personal information will:

• Be encrypted using hardware security modules

• Never be stored permanently

• Be used solely for session-based verification

• Be logged for consent and deleted immediately after validation

This ensures zero long-term retention of biometric identifiers.

Protection Against Ransomware and Malware

To prevent malware infiltration:

• All systems use real-time ransomware detection tools

• Files are scanned before being uploaded or processed

• Suspicious file types are quarantined and blocked

• Admin and endpoint devices are sandboxed

Backup systems are isolated from live environments to prevent cascading ransomware attacks.

Platform Integrity Monitoring

PAYOTRIX performs checksum verification and file integrity monitoring across:

• Application codebases

• Database schema and indexes

• Web assets and plugin dependencies

Any unauthorized code alteration triggers immediate alerts, and systems can auto-revert to the last known good configurations.

Monitoring of Data Exfiltration Risks

Data Loss Prevention (DLP) mechanisms are deployed to:

• Detect unauthorized downloads, copy-paste actions, or large outbound data packets

• Log device behavior anomalies

• Block access to unsanctioned third-party storage (e.g., Dropbox, Google Drive)

Any violation is flagged, and the associated user account is immediately restricted until cleared by the security team.

Audit Trail and Forensics Capabilities

All user and admin actions are logged in audit trails, capturing:

• Timestamps, user ID, source IP

• Activity type and outcome

• Related object IDs (e.g., user record, document, setting)

Forensics logs are retained for 7 years and analyzed in case of a breach, fraud, or regulatory investigation.

Remote Employee Security Standards

Employees working remotely must:

• Use VPNs and firewall-protected connections

• Authenticate with MFA

• Use company-authorized encrypted devices

• Avoid accessing sensitive environments on mobile phones or public Wi-Fi

Remote access is logged and flagged if it originates from geolocations outside approved regions.

Monitoring of Third-Party Embedded Services

Any embedded third-party services (e.g., analytics, chatbots) on PAYOTRIX undergo:

• Source code review

• Data collection policy check

• Cookie behavior inspection

• Periodic penetration testing

Only services with minimal data exposure and proven GDPR/Indian compliance are permitted.

Incident Reporting and Whistleblower Support

If an employee, vendor, or user detects a data risk, they may report incidents confidentially to:
📧 support@payotrix.com
All reports are logged and reviewed within 48 hours by the Chief Security Officer. Whistleblowers receive protection under PAYOTRIX's internal integrity framework and will not face retaliation.

Children’s Data Protection

PAYOTRIX is not designed for children under 18. The platform:

• Does not knowingly collect data from minors

• Flags KYC attempts with child-based documents

• Deletes any such data immediately upon detection

• Advises parents or guardians to monitor digital access
  If discovered, accounts are suspended pending age verification.

Periodic Security Training for Staff

All PAYOTRIX staff undergo:

• Mandatory quarterly security awareness training

• Social engineering and phishing simulation tests

• Legal compliance workshops

• Device-level hygiene audits

Completion of training is mandatory for retaining access privileges, and non-compliance results in role-level restrictions.

🔄 Amendment Clause

PAYOTRIX reserves the right to revise this Data Security Policy at any time without prior notice. It is the user’s responsibility to review the policy periodically. Continued use of PAYOTRIX implies acceptance of the most recent version.