Privacy & Policy

Introduction

The described Privacy Policy applies to those who visit the of the website(s) and application(s), including www.cudel.in, mobile application(s), and online services (collectively, the “CuDel Platform"), (hereinafter collectively referred to as "visitors"), or whose data/information CuDel Platform otherwise receives in connection with its services such as contact information of individuals associated with CUDEL DELIGHT SOLUTIONS PRIVATE LIMITED or CDSPL (hereinafter collectively referred to as "users''), inclusive of but not limited to the individuals seeking services/products from the different categories CuDel Platform operates in (hereinafter collectively referred to as “customers”) and also all external parties offering such services to these customers through CuDel Platform (hereinafter collectively referred to as "service partners") or their internal/external linked associates (or independent parties) offering products to these customers through CuDel Platform (hereinafter collectively referred to as "product partners") and other internal/external logistics providers offering last mile delivery services of the products sought by customers from product partner location to customer location (hereinafter collectively referred to as “delivery partners”).

For the purposes of the Privacy Policy, "you" / "your'' / “they” / “their” / “them” shall mean the person(s) or entity/entities accessing the CuDel Platform. For the purposes of the Terms and Conditions, "we" / "our'' / “us” / “ours” / “ourselves” shall mean the person(s) or entity/entities offering their services to fulfil customer orders on the CuDel Platform.

CDSPL undoubtedly respects the online privacy and recognizes the pertinent need for an appropriate protection and management of any personally identifiable information shared by the visitors/users of CuDel Platform. This Privacy Policy details out how CDSPL, through CuDel Platform, collects, utilizes, transfers and discloses any personally identifiable information of the visitors/users/subscribers/customers of CuDel Platform.

Unless otherwise defined in this Privacy Policy, all terms used in this Privacy Policy have the same meanings as mentioned and explained in the Terms & Conditions of usage of CuDel Platform. In case of any ambiguity in understanding the usage of such terms, it is suggested to visit and carefully go through the Terms & Conditions of usage of CuDel Platform to understand the actual and intended meaning of such terms for complete clarity.

COLLECTION OF PERSONAL INFORMATION

Personal data/information refers to any information relating to an identified or identifiable natural person including but not limited to commonly used identifiers such as a name, contact details, any identification number (provided by the Government/authorized agency),data/information related to location, an online identifier or one or more factors specific to the physical, physiological, mental, genetic, cultural, economic, or social identity of that natural person and any other data/information that is so categorized by applicable laws.

CDSPL, through CuDel Platform, may collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data under law as it does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

CDSPL, through CuDel Platform, collects data/information about the visitors/users and/or their usage to provide them better offerings and services. The personal information that CuDel Platform collects, and how it is collected, depends upon how the visitors/users interact with CuDel Platform. CDSPL collects the here mentioned categories of personal information of the visitors/users in the following ways:

1. contact data such as name, mobile number, email(s), password, address, location, city, state and country, details pertaining to company/organization that they are associated with and their relevant official documentation for verification during the sign up process for alerts on the CuDel Platform
2. all relevant data/information related to identity and profile that is usually contained during registration and profile update, including name, username, photographs or similar identifiers, including email and mobile number, country, city, address details, company details, service / product offerings and their categories, description and prices, data relating to type of services, booking time slot availability, order payment details, service / product partner rating, feedback of delivery partner (if involved), order booking feedback with details, rescheduling / cancelling details with appropriate reasons etc. while registering on the CuDel Platform
3. personal information such as name, age, gender, contact details, preferences including but not limited to location, category type, work industry type etc. while filling different registration or profile related forms on CuDel Platform
4. data/information regarding the services that are used and the way they are used, including log information and location information, while being the user of the services through CuDel Platform
5. marketing and communications data/information, such as their address, email, information posted in service requests, offers, requests, feedback, comments, pictures and discussions in the blog and chat boxes, responses to user surveys and polls, their preferences in receiving marketing communications from CuDel Platform and linked third parties, and their communication preferences, chat and call records when they communicate with service professionals through CuDel Platform
6. technical data/information, which includes their IP address, browser type, internet service provider, details of operating system, access time, page views, device ID, device type, frequency and use of the CuDel Platform website and mobile application activity, clicks, date and time stamps, location data, and other technology on the devices that you use to access CuDel Platform or other related data/information from the user device including the device type and location when users access CuDel Platform through that device
7. transaction Data, such as details of the Services or Professional Services they have availed, a limited portion of their credit or debit card details for tracking transactions that are provided to CuDel Platform by payment processors, and UPI IDs for processing payments
8. allied data/information relating to physical status, work availability time, preference of days of work and information about eligibility or preference for any specific requirement(s) action related to service / product offerings, if it is provided and selected data/information and details provided on CuDel Platform during the communication made with other visitors/users of CuDel Platform or CDSPL
9. utilization of cookies to automatically collect, store and make further use of the technical information about the system used to access and interact with CuDel Platform and the services utilized after accessing CuDel Platform
10. transaction Data, such as details of the services customers have availed, details of the credit / debit card for tracking transactions that are provided to CuDel Platform by payment processors, and UPI IDs for processing payments required such data/information with any of the clients of CuDel Platform, their affiliates and partners that is necessary to access services offered by them on CuDel Platform. In case of reaching the any webpage/link or services of our affiliates that is external to CuDel Platform but through CuDel Platform, the users will be governed by the terms and privacy policy of such affiliates and are advised to go through their terms and privacy policy details to get cognizance of how the affiliates handle and process the personal data of users and they share personal data of the users with CuDel Platform
11. monitoring, saving and recording of all communications, including storing of SMSes and recording the mobile conversations through CuDel Platform, till the extent permitted by law, to ensure compliance with our legal and regulatory policies as well as other internal/ external obligations
12. provide consent to the way CDSPL, through CuDel Platform, manages collection, storage, and utilization of user data/information, in accordance with this Privacy Policy, of the information that the social media provider makes available to CuDel Platform through the social media interface in case they opt to register or sign in using any of their social media account to access CuDel Platform
13. advised to go through the terms and privacy policy details of the social media provider about how they share information with CuDel Platform, whose interface is being utilized to gain access to the account on CuDel Platform

USE OF PERSONAL INFORMATION

CDSPL, through CuDel Platform, will only utilize the personal data/information in a fair and reasonable manner, and only at the instance of having a valid reason to utilize the same. The use of personal data by CDSPL entirely rests on the purpose for which the visitors/users are interacting with or on CuDel Platform.

CDSPL, through CuDel Platform, may access, process or store the personal data/information of the visitors/users of CuDel Platform for the following purposes:

1. Protecting the rights of all users of CuDel Platform and offering them timely customer support at all times
2. Offering services of CuDel Platform to the visitors/users including but not limited to sending them relevant service / product offering search results, related searched service / product offering alerts, calendar alerts, recommended and/or relevant details of service / product seeking customers (as the case maybe) and other social media communication notices or links
3. Enhancing CuDel Platform and its content to offer better features and services
4. Using data/information collected from cookies and other technologies to improve the experience of the user on CuDel Platform and the overall quality of services
5. Conducting surveys for market research and feedback to improve CuDel Platform services
6. Sending information to visitors/users about CuDel Platform services, including those of our affiliate entities (service partners / product partners / delivery partners) for marketing and promotions
7. Thwarting, detecting, investigating and following up with proper closure on all suspected fraud and crimes (including but not limited to fraud, malpractices and financial misconducts), any other activities of illegal nature, or violations of CDSPL terms of use in any jurisdiction
8. Detection, screening and to the extent required for identity verification and other Government sanctions as well as necessary due diligence checks
9. Establishing, exercising or defending legal rights in connection any prospective or actual legal proceedings and seeking professional or legal advice related to such legal proceedings

GROUND FOR PROCESSING PERSONAL INFORMATION

CONSENT

Since all personal information of visitors/users is collected and processed by CuDel Platform on all the legal grounds based on its nature and the purpose for which it is processed, CDSPL, through CuDel Platform, requires consent of the visitors/users for collecting and processing their personal information in certain situations, in line with the guidelines under all applicable data protection laws, and such processing will be performed wherever consent is requested and consent is secured / provided by them.

DISCLOSURE AND SHARING OF INFORMATION

The access of personal information of visitors/users of CuDel Platform will be restricted to the employees / personnel who are reasonably believed to know or access this information to fulfil the objective of provisioning, operation, development or improvement of the services offered on CuDel Platform. CDSPL, through CuDel Platform, does not disclose, share or transfer the personal information with any other party except with:

1. Associates of CDSPL falling under the umbrella of Kutumbh Care Group, including Kutumbh Care Private Limited and all its affiliate organizations to the extent required for purposes of handling internal business, financial obligations, other administrative general corporate operations and provisioning of services related to fulfilment of all the objectives of CuDel Platform
2. Enrolled as well as potential service partners / product partners / delivery partners of CuDel Platform if it is determined that the customer order detail matches the service / product offering of a particular service or product partner or selection of a delivery partner by a product partner matches such a party. For successful implementation of this exercise, the visitors/users registering on CuDel Platform must provide consent to allow CDSPL, through CuDel Platform, to contact them or forward their order details or selection criteria to existing or potential service partners / product partners / delivery partners
3. All third parties including but not limited to judicial, regulatory, enforcement and other linked authorities if it is determined that disclosure of the personal information of visitors/users is mandatory in accordance to violation of any terms of use of CuDel Platform, to establish / exercise legal rights of CDSPL, or defend against any legal claims, or scrutinize, establish, prevent and take appropriate action on any illegal activity, potential fraud, situations involving potential threats to the physical safety of a person, or a response to a summon, court order or legal process, or any other requirement of law
4. Third party service providers, including but not limited to advertising and marketing partners, media agencies engaged with CuDel Platform to either provide their respective services on behalf of CuDel Platform, or maintain mailing lists, or communicate with visitors/users about services and offers on behalf of CuDel Platform. CDSPL, through CuDel Platform, will ensure that all such these third party service providers abide by the all the privacy policy protocols set by CuDel Platform, are obligated to protect the personal information of the visitors/users of CuDel Platform and are also subject to appropriate confidentiality / non-disclosure obligations with CuDel Platform during their partnership
5. Third party financial institutions, (including but not limited to payment gateways, banks, and insurance agents), non-financial institutions, (including but not limited to software service providers and additional services / products providers and other offer providers). These organizations may utilize data/information about the visitors/users of CuDel Platform and their visits on CuDel Platform to offer advertisements and services on CuDel Platform
6. All parties involved in the negotiation or such process in an event of transfer of some of all business assets of CDSPL, including merger, acquisition, financing or other such scenarios

CDSPL, through CuDel Platform, does not intend to share or transfer personal information of the visitors/users of CuDel Platform to any third parties who are not required / made to act on behalf of CuDel Platform (unless such data/information sharing is required legally) without their consent of the visitors/users. Although CDSPL, through CuDel Platform, does no

provide any personal information to advertisers when visitors/users of CuDel Platform view or interact with an advertisement, the advertiser could decipher certain personal information about these visitors/users in the process of making certain assumptions related to age, gender, demography, geography etc. during the process. CDSPL will ensure taking appropriate steps to protect the personal information of its visitors/users in adhering to all applicable data protection laws in case this information is getting shared or transferred outside India. The use and transfer of information by CuDel Platform to any other platform through Google APIs will adhere to the user data policy of Google API services and its limited use requirements.

THIRD PARTY CONTENT

CDSPL, through CuDel Platform, may partner with third party affiliates to offer additional services, including but not limited to service / product provisioning at customer location (either directly or through an external delivery partner) or at physical shop location of the service partner etc. to the visitors/users of CuDel Platform. In such cases, the personal information of the visitors/users of CuDel Platform will also be governed by the privacy policy of the involved third party affiliates. The privacy policy continues to apply to the extent the personal information of the visitors/users is retained by CuDel Platform. CDSPL, through CuDel Platform, provides no warranty regarding the storage, usage, handling and transfer of the personal information of visitors/users of CuDel Platform on third party servers. There could be a possibility of availability of web links on CuDel Platform that might not be governed by the privacy policy of CuDel Platform. The visitors/users of CuDel Platform could also be directed to third party websites (social networks, blogs, content sponsorships, advertisements and services offered by either partners or third party associates of CuDel Platform). The visitors/users of CuDel Platform are advised to refer to the applicable privacy policies of each third-party service provider linked to CuDel Platform to determine the use of their personal information by these affiliates.

MESSAGES AND NOTIFICATIONS

CDSPL, through CuDel Platform, may access the email address of the visitors/users of CuDel Platform to offer a variety of services, including but not limited to notifications, reminders, updates, recommendations, other communication, and to contact them on behalf of third party service partners in relation to the services offered on / through CuDel Platform.

CDSPL, through CuDel Platform, at times may notify the visitors/users of CuDel Platform by email about changes, updates, and other service relevant information. CDSPL, through CuDel Platform, never asks the visitors/users of CuDel Platform for their password or other personal information in those notifications and communication, or in any other communication from CuDel Platform.

CHILDREN

The visitors/users must agree to meet the minimum age of 18 years or over (established by CuDel Platform) or in adherence to the local laws, at the time of accessing CuDel Platform. CDSPL, through CuDel Platform, does not knowingly collect personal information from visitors/users under 18 years of age (henceforth referred to as “children”) for CuDel Platform. Such visitors/users categorized as children must access CuDel Platform under the supervision of parents, legal guardians or responsible adults.

If you are a child under the age of 18 years, do not submit any Personal data/information to us. If you are a parent or guardian, we encourage you to instruct your children not to disclose any Personal data/information without your consent. If the visitors/users categorized as children believe that CDSPL, through CuDel Platform, may have (unknowingly or otherwise) collected personal information from them without their parental consent, kindly email us at contact@cudel.in or contact us at the contact details provided in Contact Us section, so that appropriate measures are adopted to preserve this personal information and the issue is promptly address by removing the information from CuDel Platform.

RETENTION OF PERSONAL INFORMATION

CDSPL, through CuDel Platform, will not retain the personal information of the visitors/users of CuDel Platform any longer than required for storage and processing in accordance with the contractual, statutory, legal or regulatory obligations as applicable. CDSPL, through CuDel Platform, may retain the personal information of the visitors/users of CuDel Platform for as long as required to perform the purpose specified under this Privacy Policy. In case the visitors/users of CuDel Platform opt to delete their account, CuDel Platform shall retain their personal information for up to six months after which, their data/information will be deleted along with their personal information on CuDel Platform. When CDSPL, through CuDel Platform, will have no either ongoing legitimate business, or operational, legal or other statutory requirement to process the personal information of the visitors/users, CDSPL, through CuDel Platform, will either delete or anonymize the data/information, or, if this is not possible (for example, because the personal information has been stored in backup archives), then CDSPL, through CuDel Platform, will securely store the personal information of the visitors/users and isolate it from any further processing until its successful deletion.

CONTROL OF PERSONAL INFORMATION

The visitors/users of CuDel Platform hold the freedom to conjure their rights available to data principals or subjects in line with applicable regulations and guidelines on the storage, handling, processing and sharing of their personal information by CDSPL, through CuDel Platform. The visitors/users get the option to keep their personal information accurate, relevant and updated on CuDel Platform.

The visitors/users of CuDel Platform hold the freedom to conjure their rights available to data principals or subjects in line with applicable regulations and guidelines on the storage, handling, processing and sharing of their personal information by CDSPL, through CuDel Platform. The visitors/users get the option to keep their personal information accurate, relevant and updated on CuDel Platform.

The visitors/users of CuDel Platform may also be required to approach a designated appellate or concerning officer or relevant authority in line with the provisions of the applicable data protection laws in order to correctly exercise and execute certain rights. In certain scenarios, CDSPL, through CuDel Platform may charge a fee for fulfilment of such requests, especially in case of a clear unsubstantiated request, according to the provisions of applicable data protection laws. The visitors/users of CuDel Platform must acknowledge that all their rights are not absolute and are subject to limitations in adherence to the applicable data protection laws. The visitors/users have the right to delete their account on CuDel Platform in order to protect and preserve their personal information.