Xflow Payments India Private Limited and its affiliates (collectively, "Xflow", "we", "us", or "our") is committed to protecting the privacy and security of individuals who interact with the Xflowpay MCP App (the "App"). This Privacy Policy ("Policy") sets out the basis on which any data — including Personal Data, processed through or in connection with the App will be handled by Xflow.
This Policy is issued in accordance with the applicable data protection laws of India, including Information Technology Act, 2000, read along with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (the "SPDI Rules").
Please read this Policy carefully. By using or invoking the App, you acknowledge that you have read and understood this Policy.
1. Scope and Application
This Policy applies to all persons ("Users", "you", or "your") who invoke or interact with the Xflowpay MCP App through any compatible artificial intelligence client platform, including but not limited to ChatGPT, Claude, and similar AI services.
This Policy governs only the data processing activities of Xflow in connection with the App. It does not govern the data processing practices of any third-party AI platform through which you access the App. Those platforms operate under their own privacy policies.
2. Definitions
In this Policy, the following terms shall have the meanings assigned to them below:
a. "Act" means the Information Technology Act, 2000 (as amended from time to time), and the rules and regulations framed thereunder.
b. "App" means the Xflowpay MCP App, a read-only software integration that enables AI client platforms to retrieve foreign exchange rate and forecast data from Xflowpay.
c. "FX Data" means live foreign exchange rates, currency codes, currency amounts, and AI-inferred three-day FX forecasts returned by the App in response to a tool invocation.
d. "Personal Data" means has the meaning assigned to the term "personal data" under the SPDI Rules, and includes any data about a natural person who is directly or indirectly identifiable. For the purposes of this Policy, and given the nature of the App, Xflow does not collect personal data as part of standard tool invocations.
e. "Sensitive Personal Data or Information (SPDI)" means has the meaning assigned to it under Rule 3 of the SPDI Rules, and includes passwords, financial information, physical/physiological/mental health conditions, sexual orientation, medical records, and biometric information. Xflow does not collect SPDI through the App.
f. "Tool Invocation" means the act of a User causing the App to be called through an AI client platform, which may include passing optional parameters such as a currency code or USD amount.
g. "Tool Parameters" means the optional inputs a User may provide when invoking the App, such as a USD amount or target currency code.
h. "Xflow / We / Us / Our" means Xflow Payments India Private Limited, a company incorporated under the Companies Act, 2013, and its affiliates.
3. Nature of the App - Read-Only
The App is strictly read-only. It is important for Users to understand the following:
a. The App does not initiate, process, or authorise any payment, remittance, or financial transaction.
b. The App does not open, modify, or operate any bank account, wallet, or financial account on behalf of any User.
c. The App does not alter any settings, preferences, or configurations within any platform or service.
d. The App only retrieves and returns FX Data in response to a Tool Invocation.
Forecast insights provided through the App are AI-inferred and are intended for general informational purposes only. They do not constitute financial advice, investment advice, or any form of regulated financial communication under applicable law, including the Securities and Exchange Board of India Act, 1992, or the Foreign Exchange Management Act, 1999.
4. Information We Collect
4.1 Tool Parameters
When you invoke the App, we may receive only the optional parameters you choose to pass as part of the Tool Invocation — for example, a USD amount or a target currency code. Such parameters are transactional in nature and are used solely to retrieve and return the relevant FX Data.
4.2 Information We Do Not Collect
Xflow does not collect, store, or process any of the following through the App:
a. Your name, email address, postal address, phone number, or any other contact information;
b. Any payment instrument details, bank account numbers, credit or debit card information, or other financial account identifiers;
c. Account credentials, passwords, PINs, or authentication tokens;
d. Any part of your conversation with an AI platform — including your messages, prompts, queries, or chat history;
e. Device identifiers, IP addresses, or browser metadata;
f. Aadhaar numbers or other government-issued identification.
If you do not pass optional Tool Parameters, Xflow may still process a minimal request to return default rate or forecast information.
4.3 No Sensitive Personal Data or Information
Xflow does not collect Sensitive Personal Data or Information (as defined under the SPDI Rules) through the App. Users should not transmit SPDI through Tool Parameters.
5. Purpose of Processing
Tool Parameters received through a Tool Invocation are processed for the following purpose only:
a. To call the relevant Xflowpay API(s) in order to retrieve live FX rate or forecast data corresponding to the parameters provided;
b. To return the retrieved FX Data to your AI client platform in response to the Tool Invocation.
Xflow does not use Tool Parameters for any of the following purposes:
a. Targeted advertising or marketing;
b. Profiling of Users;
c. Sale or transfer of data to data brokers or third-party advertisers;
d. Any purpose unrelated to delivering the FX Data requested through the App.
6. Data Retention
Xflow does not store Tool Parameters or FX Data outputs on its servers after a Tool Invocation is complete. Each Tool Invocation is processed in memory and the associated data is discarded upon delivery of the response to your AI client.
Xflow does not maintain:
a. A user database or user registry in connection with the App;
b. A history or log of your Tool Invocations;
c. Any persistent record of Tool Parameters submitted through the App.
To the extent any data is temporarily processed in connection with a Tool Invocation, such data is retained only for the duration necessary to complete that Tool Invocation and is not retained thereafter.
7. Sharing and Disclosure
7.1 Data Flow
When you invoke a Tool, data flows in the following manner:
a. Your AI client sends the Tool Invocation request, including any Tool Parameters you provide, to the App.
b. The App transmits the relevant parameters to Xflowpay APIs and services to retrieve the applicable FX rate or forecast data.
c. The App returns the retrieved FX Data to your AI client.
7.2 No Sharing with Unrelated Third Parties
Xflow does not disclose Tool Parameters to:
a. Third-party analytics or advertising platforms;
b. Social media platforms;
c. Data brokers or data aggregators;
d. Any entity unrelated to the delivery of FX Data through the App.
7.3 Disclosure Required by Law
Xflow may disclose information as required under applicable law, including if directed to do so by a court of competent jurisdiction, a statutory authority, or any government or regulatory body in India — including but not limited to the Reserve Bank of India, the Financial Intelligence Unit - India (FIU-IND), or the Enforcement Directorate — for the purposes of verification of identity, or prevention, detection, or investigation of an offence.
7.4 AI Platform Providers
Your AI platform provider (e.g., Anthropic, OpenAI) may process your conversations and tool usage under its own privacy policy and terms of service. Xflow is not responsible for the data practices of AI platform providers. Users are encouraged to review the privacy policies of their respective AI platform providers.
8. Security
Xflow implements reasonable security practices and procedures as required under Rule 8 of the SPDI Rules and in accordance with the DPDPA. In connection with the App, these include:
a. Encryption of all data in transit between your AI client, the App, and Xflowpay APIs using HTTPS (TLS 1.2 or higher);
b. The App does not maintain a persistent database and does not store Tool Parameters or FX Data outputs after a Tool Invocation is complete;
c. The App operates in read-only mode and is technically incapable of initiating payments or modifying any account or service.
Notwithstanding the above, no method of transmission over the internet or electronic storage is completely secure. While Xflow strives to use commercially acceptable means to protect your data, we cannot guarantee absolute security.
9. Your Rights
Given the nature of the App, which does not collect or store personal data, the practical exercise of these rights may be limited. Nonetheless, Xflow acknowledges the following rights:
a. Right to information about Personal Data being processed;
b. Right to correction and erasure of Personal Data;
c. Right to grievance redressal;
d. Right to nominate another individual to exercise rights in the event of death or incapacity.
To exercise any of these rights, or if you have questions about how your data is handled in connection with the App, please contact us using the details in Section 11 below.
As no Xflowpay account is required to use the App, you may also discontinue use of the App at any time by removing or disconnecting it within your AI client platform settings. Upon disconnection, no further Tool Invocations will be processed.
10. Changes to This Policy
Xflow reserves the right to amend this Policy from time to time to reflect changes in law, regulatory requirements, or our data processing practices in connection with the App. The "Effective Date" at the top of this Policy will be updated to reflect the date of the most recent revision.
We encourage Users to review this Policy periodically. Continued use of the App following the publication of a revised Policy constitutes your acceptance of the revised Policy for all subsequent Tool Invocations. We will not be responsible for a User's failure to remain informed of such changes.
11. Grievance Officer
In accordance with the Information Technology Act, 2000, and the rules made thereunder, Xflow has designated a Grievance Officer for the purposes of this Policy. If you have any concerns, complaints, or queries regarding this Policy or the handling of data in connection with the App, you may contact the Grievance Officer at:
Grievance Officer: Ashwin Bhatnagar, Xflow Payments India Private Limited
Email: support@xflowpay.com
Website: www.xflowpay.com
Disclaimer
FX rate and forecast data provided through the App is for informational purposes only and does not constitute financial, investment, or legal advice. Xflow does not warrant the accuracy, completeness, or fitness for purpose of any FX Data returned through the App. Users should independently verify all FX Data before making any financial decisions.
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