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This Privacy Policy describes how [Company Legal Name] (“Company,” “we,” “us,” “our”) collects, uses, discloses, and protects personal data when you visit our Website or use our Service, in accordance with the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and the Digital Personal Data Protection Rules, 2025, the Information Technology Act, 2000, and other applicable rules made thereunder. This Policy should be read together with our Terms of Service.
1. Scope of This Policy
1.1 This Policy applies to the limited personal data we collect through the Website, during booking, and in the course of delivering the Service.
1.2 This Policy does NOT apply to, and we expressly do not collect, access, or process, any data you transfer, upload, or store using the Device to your own Cloud Account. Please see Section 4 below, which explains this in detail.
2. Data Fiduciary and Contact Person
2.1 For the purposes of the DPDP Act, [Company Legal Name] is the Data Fiduciary in respect of the limited personal data described in Section 3. You may contact our designated contact person for privacy-related queries at, [Name], [Email], [Contact].
3. Personal Data We Collect
We follow the principle of data minimisation and collect only what is necessary to deliver the Service:
3.1 Contact and delivery data: your name, mobile number, and delivery/service address, to schedule and fulfil the Service.
3.2 Booking and transaction data: Booking date and time, service type, and payment status. Payment instrument details (such as card or UPI numbers) are collected and processed directly by our third-party payment gateway and are not stored on our systems.
3.3 Communication data: Any information you provide when contacting customer support or our Grievance Officer.
3.4 Website usage data: Standard technical data such as IP address, browser type, device type, and pages visited, collected automatically via cookies and analytics tools for site functionality and improvement (see Section 10).
3.5 We do not collect any government-issued identity numbers (such as Aadhaar or PAN), biometric data, financial account numbers, or any “sensitive” category of data, unless independently required for a specific, disclosed purpose (such as GST invoicing) and with your explicit consent.
4. What We Do NOT Collect or Access
4.1 We do not collect, access, view, copy, transmit, store, or in any way process the photographs, documents, videos, contacts, or any other data or files that you transfer or upload using the Device to your Cloud Account.
4.2 We do not collect, request, or store your Cloud Account username, password, or one-time password (OTP).
4.3 The Device supplied to you carries no pre-installed monitoring, tracking, spyware, or remote-access software, and we do not remotely access the Device during your use of it. Our Field Agent remains present during the process for assistance and device-security purposes, but does not view your screen, credentials, or data (see Terms of Service, Clause 8).
4.4 Consequently, your uploaded data is at no point “personal data processed by us” for the purposes of the DPDP Act. It is governed instead by the privacy policy of your chosen Cloud Account provider (for example, Google’s Privacy Policy for a Google Drive account), which we encourage you to independently review.
5. Legal Basis and Purpose of Processing
Under the DPDP Act, we process your personal data on the basis of your free, specific, informed, and unambiguous consent, given through an affirmative action at the time of booking, for the following specified purposes only:
- i.scheduling, delivering, and completing the Service;
- ii.communicating with you regarding your booking (confirmations, Field Agent arrival, support);
- iii.processing payment and issuing invoices;
- iv.complying with our legal and regulatory obligations, including tax, consumer protection, and grievance redressal laws; and
- v.improving the safety, quality, and functionality of the Website and Service.
5.1 We do not use your personal data for any purpose beyond what is disclosed in the consent notice provided to you at collection, and we do not use it for marketing communications unless you separately opt in, consent which you may withdraw at any time.
6. How We Share Your Information
We may share your limited personal data (name, address, mobile number) only with:
- i.our logistics/courier partners, solely to enable delivery and collection of the Device;
- ii.our payment gateway/processor, solely to process your payment;
- iii.our Field Agents, solely to the extent necessary to identify you and complete the visit;
- iv.professional advisors, such as auditors or legal counsel, under confidentiality obligations, where necessary; and
- v.government or regulatory authorities, law enforcement, or courts, where required under Applicable Law or in response to a valid legal process.
6.1 We do not sell, rent, or trade your personal data to any third party for their own marketing purposes.
7. Cross-Border Transfer
7.1 We do not ordinarily transfer your personal data outside India. If any service provider we engage (such as a cloud-hosting or analytics provider for the Website) processes data outside India, such transfer will be carried out in accordance with the DPDP Act, save in respect of countries restricted by the Central Government from time to time.
8. Data Retention
8.1 We retain your name, address, and mobile number only for as long as necessary to fulfil the purposes described in Section 5, complete the Service, resolve any dispute or grievance, and comply with statutory retention obligations under tax, consumer protection, or other Applicable Law (typically not exceeding [….] years from the date of your last booking, unless a longer period is required by law). On expiry of this period, we will erase or anonymise your personal data.
9. Data Security
9.1 We implement reasonable security safeguards proportionate to the limited personal data we hold, including access controls restricting data to authorised personnel on a need-to-know basis, encryption of data in transit on our Website, and secure storage of booking records.
9.2 In the unlikely event of a personal data breach affecting you, we will notify the Data Protection Board of India and you, without undue delay, as required under the DPDP Act.
10. Cookies and Tracking Technologies
10.1 We use essential and analytics cookies to operate the Website and understand usage patterns. You can control or disable cookies through your browser settings; disabling some cookies may affect Website functionality. We do not use cookies to track your activity on your Cloud Account or any third-party service.
11. Your Rights as a Data Principal
Under the DPDP Act, you have the right to:
- i.obtain a summary of the personal data we hold about you and the processing activities undertaken;
- ii.request correction, completion, or updating of your personal data;
- iii.request erasure of your personal data, unless retention is required for a legal purpose;
- iv.withdraw your consent at any time, with the withdrawal being as easy as giving consent (this does not affect the lawfulness of processing prior to withdrawal, and may affect our ability to complete a Service already booked);
- v.nominate another individual to exercise these rights on your behalf in the event of your death or incapacity; and
- vi.file a grievance with us in the first instance, and thereafter with the Data Protection Board of India, if unsatisfied with our response.
11.1 To exercise any of these rights, please contact us using the details in Section 2. We will respond within the timelines prescribed under the DPDP Act and its rules.
12. Children's Privacy
12.1 The Service is not directed at, and shall not knowingly be provided to, individuals under 18 years of age. We do not knowingly collect personal data of children. If we become aware that we have inadvertently collected such data, we will delete it promptly.
13. Grievance Officer
13.1 In accordance with the Information Technology Act, 2000 and rules made thereunder, our Grievance Officer is, [Name], [Email], [Contact Number].
13.2 Complaints will be acknowledged within 48 (forty-eight) hours and resolved within 1 (one) month, or such other period as prescribed under Applicable Law.
14. Changes to This Policy
14.1 We may update this Privacy Policy periodically to reflect changes in our practices or Applicable Law. Material changes will be notified via the Website or email at least 7 (seven) days before they take effect. The “Last Updated” date at the top reflects the most recent revision.
15. Contact Us
[Company email], [Phone], [Address (optional)]