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Reward Points Application Privacy Notice
This Privacy Policy constitutes a legally binding document governing the collection,
processing, storage, use, disclosure, and protection of Personal Data when a user
accesses or uses the reward points application and related services operated by the
technology platform provider for participating jewellers.
By downloading, accessing, registering on, or using the Application,
the User expressly consents to the practices described in this Policy and agrees
to be bound by its terms.
- This Policy applies to all Users who access or use the Application for enrolling in or participating in reward programs offered by participating Jewellers.
- This Policy sets out the categories of Personal Data collected, the purposes and lawful basis for processing, the manner of storage and protection, the circumstances under which data may be disclosed, and the rights and choices available to Users.
- This Policy is intended to ensure transparency and compliance with applicable Indian laws, including data protection and information technology laws.
- Personal Data means any information relating to an identified or identifiable natural person.
- Sensitive Personal Data shall have the meaning ascribed under applicable law and may include financial information, authentication data, or other sensitive categories as notified.
- Processing means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, transfer, or deletion.
- Applicable Law means all laws, rules, and regulations in force in India relating to data protection, privacy, and information technology.
3.1 Information Provided by You
- Full name
- Mobile number
- Email address (if provided)
- Date of birth (optional, for promotional benefits)
- Basic profile details
- Reward points account and transaction history
3.2 Information Collected Automatically
- Device information such as model, operating system, and device identifiers
- Application usage data and logs
- Date, time, and duration of access
- IP address, where applicable
- Error logs and diagnostic data
3.3 Information Not Collected
- Bank account details
- Credit or debit card details
- UPI IDs
- Digital wallet balances
- Passwords, PINs, or authentication credentials for financial accounts
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Purpose and Lawful Basis of Processing
- Onboarding and registration into the Program
- Maintenance of User accounts and reward points ledger
- Enabling redemption and utilisation of reward points
- Communication of transactional and program-related information
- Fraud detection, prevention, and audit trails
- System security, analytics, and performance improvement
- Compliance with legal and regulatory obligations
- Processing is based on User consent and/or legitimate business purposes, as permitted under applicable law
- Personal Data shall not be used for unrelated purposes without obtaining additional consent
- The Platform Provider acts as a data processor and technology facilitator.
- The Jeweller acts as the data controller for customer data relating to commercial transactions.
- The Platform Provider does not sell jewellery, issue invoices, process payments, or determine commercial terms of sale.
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Disclosure and Sharing of Data
- Personal Data may be disclosed strictly on a need-to-know basis to the relevant participating Jeweller.
- Data may also be shared with authorised service providers bound by confidentiality obligations.
- Data may be disclosed to governmental, statutory, or regulatory authorities where required by law.
- Personal Data shall not be sold, rented, or commercially exploited.
- All disclosures shall be limited to the minimum data necessary for the intended purpose.
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Data Storage and Retention
- Personal Data shall be stored in secure electronic systems with reasonable safeguards.
- Data shall be retained for the duration of User participation in the Program and/or for such period as required under Applicable Law.
- Upon termination, withdrawal, or deletion request, Personal Data shall be deleted or anonymised, subject to legal retention requirements.
- Reasonable administrative, technical, and organisational safeguards are implemented to protect Personal Data against unauthorised access, misuse, unlawful processing, alteration, destruction, accidental loss, or disclosure.
- Users acknowledge that no system is completely secure and accept inherent risks associated with digital platforms.
- Right to access Personal Data
- Right to request correction of inaccurate or incomplete data
- Right to request deletion or anonymisation, subject to legal obligations
- Right to withdraw consent for non-essential processing
- Right to opt-out of promotional communications
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Consent and Withdrawal
- By using the Application, the User provides free, informed, specific, and unambiguous consent to the processing of Personal Data.
- Withdrawal of consent may restrict access to certain features or result in termination of participation in the Program.
- The Application may use limited cookies or similar technologies strictly for functionality, performance, and security.
- No third-party behavioural advertising or tracking cookies are used.
- The Application is not intended for individuals below eighteen (18) years of age without lawful parental or guardian consent.
- The Platform Provider does not knowingly collect Personal Data of minors without valid consent.
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Data Breach Management
- In the event of a data breach, the Platform Provider shall take reasonable steps to investigate and mitigate the breach.
- The Platform Provider shall also comply with applicable legal notification obligations.
- This Policy may be amended from time to time.
- Updated versions shall be made available on the Application.
- Continued use of the Application after such updates shall constitute deemed acceptance.
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Limitation of Liability
- To the maximum extent permitted under applicable law, the Platform Provider and Jeweller shall not be liable for indirect, incidental, consequential, or punitive damages arising from lawful processing of Personal Data.
- Liability, if any, shall be limited to direct damages proven and attributable to gross negligence or wilful misconduct.
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Governing Law and Jurisdiction
- This Policy shall be governed by the laws of India.
- Subject to applicable dispute resolution mechanisms, courts at Rajkot, Gujarat shall have exclusive jurisdiction.
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User Declaration and Consent
“I hereby confirm that I have read, understood, and agreed to this Privacy Policy and consent
to the collection, processing, storage, and use of my Personal Data in accordance with its terms.”