PRIVACY POLICY

Pawtrition India
(A Brand of Prime Lands Asia LLP)

Effective Date: 25/11/2025

1. Introduction and Acceptance

This Privacy Policy (“Policy”) governs the collection, use, storage, disclosure, and protection of personal information by Pawtrition India, a brand of Prime Lands Asia LLP (“Company”, “We”, “Us”, “Our”), a limited liability partnership registered under the Limited Liability Partnership Act, 2008, with registered office in Ghaziabad, Uttar Pradesh, India.

By accessing, browsing, or using our website, mobile application, or any related services (collectively, the “Platform”), you (“User”, “You”, “Your”) irrevocably consent to and accept all terms of this Privacy Policy. If you do not agree with any provision herein, you must immediately cease all use of the Platform.

This Policy complies with:

The Information Technology Act, 2000 (https://indiacode.nic.in/handle/123456789/1999)
The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011
The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (as amended by GSR 275(E), 2023) (https://egazette.nic.in/WriteReadData/2021/225464.pdf)
All applicable laws of the Republic of India

2. Definitions

“Personal Information” means any information that relates to a natural person which, either directly or indirectly, in combination with other information available, is capable of identifying such person, including but not limited to name, email address, phone number, address, payment information, device identifiers, and usage data.
“Sensitive Personal Data or Information” (SPDI) means passwords, financial information (bank account, credit/debit card details), biometric information, medical records, and other data as defined under IT Rules, 2011.
“Platform” refers collectively to the website, mobile application, and all associated digital services operated by Pawtrition India.
“Services” means all services offered through the Platform, including e-commerce, order processing, customer support, and related functionalities.

3. Information We Collect

3.1 Personal Information Collected

We collect the following categories of Personal Information:

A. Identity and Contact Data:

Full name, email address, phone number, billing and shipping addresses, date of birth, gender.

B. Account and Authentication Data:

Username, password (encrypted), account preferences, security questions and answers, login activity logs.

C. Payment and Transaction Data:

Payment method details (credit/debit card information, UPI ID, bank account details as processed through authorized payment gateways), transaction history, order details, purchase history, billing information.

D. Device and Technical Data:

IP address, device type, device ID, operating system, browser type and version, user-agent string, time zone settings, geographical location data (approximate or precise, with consent), cookies and tracking identifiers.

E. Usage and Interaction Data:

Pages visited, products viewed, search queries, click-stream data, time spent on Platform, interaction with Platform features, referral sources.

F. Communication and User-Generated Content:

Customer support inquiries, feedback, reviews, ratings, comments, photos or videos uploaded, grievance submissions, correspondence with the Company.

G. Pet-Related Information (Optional):

Pet name, species, breed, age, dietary preferences, health conditions (if voluntarily provided for product recommendations).

3.2 Automatic Data Collection

We automatically collect certain information through cookies, web beacons, pixels, and similar tracking technologies when you access the Platform. This includes technical and usage data as described in Section 3.1(D) and (E) above.

3.3 Information from Third Parties

We may receive information about you from third-party sources, including:

Payment service providers and gateways.
Delivery and logistics partners.
Social media platforms (if you link your account).
Marketing and analytics service providers.
Fraud prevention and security services.

3.4 Children’s Information

We do not knowingly collect Personal Information from children under the age of 18 years. If we become aware that a User is below 18 years of age, we reserve the right to immediately delete such data without notice or liability. Parents or guardians who believe their child has provided Personal Information to us should contact us immediately at pawtritionindia@gmail.com.

4. Purpose and Legal Basis for Data Collection

We collect, use, process, and retain Personal Information for the following legitimate business purposes:

4.1 Core Business Functions

To process, accept, fulfill, and deliver orders and Services.
To verify User identity and authenticate account access.
To process payments and prevent payment fraud.
To communicate order status, delivery updates, and transactional notifications.
To provide customer support and respond to inquiries.

4.2 Platform Functionality and Improvement

To operate, maintain, and improve the Platform’s functionality, performance, and user experience.
To personalize content, recommendations, and product offerings.
To conduct analytics, research, and statistical analysis.
To develop new features, products, and services.

4.3 Security and Fraud Prevention

To detect, prevent, and investigate fraud, security breaches, unauthorized access, and illegal activities.
To enforce our Terms and Conditions and other policies.
To protect the rights, property, and safety of the Company, Users, and third parties.

4.4 Legal and Regulatory Compliance

To comply with applicable laws, regulations, court orders, and government directives.
To respond to lawful requests from law enforcement, regulators, tax authorities, and judicial bodies.
To maintain records as required under GST, tax laws, and other statutory obligations.
To comply with Know Your Customer (KYC) and anti-money laundering requirements.

4.5 Marketing and Communication (with Consent)

To send promotional offers, newsletters, updates, and marketing communications (only with explicit User consent).
To conduct surveys, contests, or promotional campaigns.
Users may opt-out of marketing communications at any time by contacting pawtritionindia@gmail.com or using the unsubscribe link in emails.

4.6 Grievance Redressal

To address and resolve User grievances, complaints, and disputes as required under IT Rules, 2021.

Legal Basis: We process Personal Information based on:

Contractual necessity (to fulfill our agreement with Users).
Legitimate business interests (Platform operation, security, fraud prevention).
Legal obligations (compliance with Indian law).
User consent (for marketing and optional data collection).

5.1 No Sale or Rental of Data

We do NOT sell, rent, lease, or trade User Personal Information to any third party for commercial purposes.

5.2 Permitted Disclosure

We may disclose Personal Information to the following categories of recipients, strictly on a need-to-know basis and under confidentiality obligations:

A. Service Providers and Business Partners:

Payment gateways and processors (for transaction processing).
Delivery and logistics partners (for order fulfillment).
Cloud storage and hosting providers (for data storage).
Technology and IT service providers (for Platform maintenance).
Marketing and analytics service providers (for business intelligence).
Customer support service providers.

B. Government Authorities and Legal Entities:

Law enforcement agencies, police, courts, tribunals, and regulatory authorities, when required by law or lawful order.
Tax authorities and GST departments for tax compliance and audits.
Government bodies under applicable statutes, including Section 69 and Section 79 of the Information Technology Act, 2000.

C. Internal Personnel:

Employees, officers, directors, and agents of Prime Lands Asia LLP, strictly on a need-to-know basis under confidentiality agreements.

D. Corporate Transactions:

In connection with any merger, acquisition, sale of assets, reorganization, or business transfer (with notice to affected Users).

E. Consent-Based Disclosure:

Any third party explicitly authorized by the User in writing.

5.3 Data Transfers

Domestic Storage: User data is primarily stored on servers located within India.
International Transfers: We do not routinely transfer Personal Information outside India. However, if such transfer is necessary for order fulfillment, technology operations, or compliance, we will ensure adequate safeguards and comply with applicable Indian law.
Users consent to such transfers by using the Platform.

5.4 Third-Party Links and Services

The Platform may contain links to third-party websites, applications, or services (“Third-Party Services”). Pawtrition India is not responsible for the privacy practices, content, or security of Third-Party Services. Users access such services at their own risk and are subject to the third party’s privacy policy. We disclaim all liability for Third-Party Services.

6. Cookies, Tracking Technologies, and Analytics

6.1 Use of Cookies

We use cookies, web beacons, pixels, local storage, and similar tracking technologies to:

Facilitate user login and session management.
Remember user preferences and settings.
Analyze Platform usage and performance.
Personalize content and advertisements.
Prevent fraud and enhance security.

6.2 Types of Cookies

Essential Cookies: Necessary for Platform functionality (e.g., authentication, security).
Performance Cookies: Collect anonymous usage data for analytics.
Functional Cookies: Remember user preferences and settings.
Marketing Cookies: Track user behavior for targeted advertising (with consent).

6.3 User Control

Users may disable or delete cookies through their browser settings. However, disabling essential cookies may impair Platform functionality and user experience. For more information on managing cookies, refer to your browser’s help documentation.

6.4 Analytics and Third-Party Tools

We may use third-party analytics tools (e.g., Google Analytics, Firebase Analytics) to analyze Platform usage. These tools may collect information such as IP address, device type, and usage patterns. Such tools are governed by their respective privacy policies.

7. Data Retention and Deletion

7.1 Retention Period

We retain Personal Information for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law.

Specific Retention Periods:

Active User Data: Retained for the duration of the User’s account and active engagement with the Platform.
Inactive Accounts: Retained for 180 days following account deletion or last activity, unless required by law.
Transaction and Financial Records: Retained for a minimum of 7 years as required under GST, Income Tax Act, and other financial regulations.
Legal and Dispute Records: Retained indefinitely if required for ongoing litigation, dispute resolution, or legal defense.
Grievance Records: Retained as required under IT Rules, 2021 (typically 180 days or longer if mandated).

7.2 Data Deletion

Users may request deletion of their Personal Information by submitting a written request to pawtritionindia@gmail.com. We will process such requests within 30 days, subject to:

Verification of User identity.
Legal or regulatory obligations requiring retention.
Ongoing disputes, investigations, or legal proceedings.
Legitimate business interests (e.g., fraud prevention, contract enforcement).

We reserve the right to deny deletion requests if retention is mandated by law or necessary for legal defense.

7.3 Anonymization

Where deletion is not feasible, we may anonymize Personal Information such that it can no longer identify an individual.

8. Data Security Measures

8.1 Security Practices

We implement reasonable technical, organizational, and physical security measures to protect Personal Information from unauthorized access, disclosure, alteration, or destruction, in accordance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

Security measures include:

Encryption: SSL/TLS encryption for data transmission; encryption of Sensitive Personal Data at rest.
Access Controls: Role-based access controls; authentication and authorization mechanisms; password policies.
Network Security: Firewalls, intrusion detection systems, secure network architecture.
Regular Audits: Periodic security audits, vulnerability assessments, and penetration testing.
Employee Training: Confidentiality agreements and security training for personnel with data access.
Incident Response: Procedures for detecting, reporting, and responding to data breaches.

8.2 Payment Security

Payment information is processed by third-party payment gateways certified under PCI-DSS (Payment Card Industry Data Security Standard). Pawtrition India does not directly store or process full credit/debit card details. Payment data is encrypted and transmitted securely to authorized payment processors.

8.3 Limitation of Liability for Security Breaches

Despite our best efforts, no method of transmission or storage is 100% secure. Pawtrition India disclaims all liability for any unauthorized access, hacking, data breach, or security incident that is:

Beyond our reasonable control.
Caused by third-party actions, including hackers, cybercriminals, or malicious actors.
Resulting from User negligence (e.g., sharing passwords, using insecure networks).
Occurring due to force majeure events (e.g., natural disasters, cyberattacks on third-party infrastructure).

Users acknowledge and accept the inherent risks of internet-based transactions and agree to hold Pawtrition India harmless from any loss arising from security breaches not caused by our gross negligence.

In the event of a data breach affecting Sensitive Personal Data, we will notify affected Users and the relevant authorities as required under applicable law, in accordance with IT Rules.

9. User Rights and Controls

9.1 Access and Correction

Users have the right to:

Access: Request a copy of their Personal Information held by us.
Correction: Request correction of inaccurate or incomplete Personal Information.

To exercise these rights, Users must submit a written request to pawtritionindia@gmail.com with proof of identity. We will respond within 30 days, subject to verification.

9.2 Data Portability

Users may request their Personal Information in a structured, commonly used, and machine-readable format, subject to technical feasibility and legal limitations.

9.3 Withdrawal of Consent

Users may withdraw consent for non-essential data collection (e.g., marketing communications) at any time by:

Clicking the “unsubscribe” link in emails.
Contacting pawtritionindia@gmail.com.

Note: Withdrawal of consent for essential data processing may result in inability to use the Platform or Services.

9.4 Account Deletion

Users may request deletion of their account and associated Personal Information by contacting pawtritionindia@gmail.com. Deletion is subject to the retention requirements outlined in Section 7.

9.5 Opt-Out of Marketing

Users may opt-out of promotional communications by:

Using the unsubscribe link in marketing emails.
Adjusting notification settings in the mobile app.
Contacting pawtritionindia@gmail.com.

Opting out of marketing does not affect transactional or service-related communications (e.g., order confirmations, account notifications).

9.6 Limitations on User Rights

We may decline requests that are:

Manifestly unfounded, excessive, or repetitive.
Prohibited by law or required for legal defense.
Technically infeasible or disproportionately burdensome.

10. Sensitive Personal Data or Information (SPDI)

10.1 Collection of SPDI

We collect Sensitive Personal Data or Information (as defined under IT Rules, 2011) only when:

Required for order processing and fulfillment (e.g., payment information).
Voluntarily provided by the User (e.g., health information for pet dietary needs).
Mandated by law (e.g., KYC compliance).

We do NOT collect biometric information, medical records, or sexual orientation data unless explicitly required by law.

10.2 Security of SPDI

SPDI is subject to enhanced security measures, including encryption, restricted access, and regular audits. Payment information is processed exclusively by PCI-DSS compliant payment gateways.

10.3 Disclosure of SPDI

SPDI is disclosed only:

With explicit User consent.
To authorized service providers under strict confidentiality obligations.
As required by law or government authorities.

11. Grievance Redressal Mechanism

11.1 Grievance Redressal Officer

In accordance with Rule 3(11) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, we have appointed a Grievance Redressal Officer to address User complaints and privacy concerns.

Grievance Redressal Officer:
Prime Lands Asia LLP — Pawtrition India
Ghaziabad, Uttar Pradesh, India
Email: pawtritionindia@gmail.com
Support Hours: 9:00 AM to 9:00 PM IST, Seven Days a Week

11.2 Filing a Grievance

Users may file grievances regarding privacy or data protection by submitting a written complaint to pawtritionindia@gmail.com containing:

Full name and contact information.
Detailed description of the grievance or complaint.
Specific relief sought.
Supporting documentation or evidence (if applicable).

11.3 Response Timeframe

Acknowledgment: We will acknowledge receipt of the grievance within 5 business days during Support Hours.
Resolution: We will make good faith efforts to resolve the grievance within 30 calendar days of receipt.

However, we make no guarantee of resolution and reserve the right to reject or dismiss any grievance deemed invalid, frivolous, or outside the scope of this Policy or applicable law.

11.4 Escalation

If unsatisfied with the resolution, Users may escalate the matter to the Designated Nodal Officer in writing. Escalation does not create any additional obligation or liability on Pawtrition India and is purely a courtesy measure.

12. Policy Updates and Amendments

12.1 Right to Amend

Pawtrition India reserves an absolute and unconditional right to amend, modify, supplement, or revise this Privacy Policy at any time, in its sole discretion, without prior notice or User approval.

12.2 Notification of Changes

Material changes to this Policy will be notified by:

Posting the updated Policy on the Platform with a revised “Last Updated” date.
Sending notification via email or in-app message (at our discretion).

Continued use of the Platform following any amendments constitutes binding acceptance of the revised Policy.

12.3 User Responsibility

It is the User’s responsibility to review this Policy periodically. Users who do not agree to any amendments must immediately cease using the Platform.

13. Limitation of Liability and Disclaimer

13.1 General Disclaimer

TO THE FULLEST EXTENT PERMITTED UNDER APPLICABLE INDIAN LAW, INCLUDING THE INFORMATION TECHNOLOGY ACT, 2000:

Pawtrition India shall NOT be liable for any loss, damage, claim, or injury arising from:
- Unauthorized access, hacking, or data breaches beyond our reasonable control.
- Third-party actions, including payment processors, delivery partners, or service providers.
- User negligence (e.g., sharing passwords, using insecure devices or networks).
- Force majeure events (e.g., natural disasters, cyberattacks, government actions).
- Errors, omissions, or inaccuracies in data processing.
- Delays in responding to grievances or data requests.

13.2 No Guarantee of Security

While we implement reasonable security measures, we make no guarantee or warranty that the Platform or Personal Information is completely secure from all risks. Users acknowledge and accept the inherent security risks of internet-based services.

13.3 Third-Party Liability

Pawtrition India is not responsible for the privacy practices, data security, or conduct of third-party service providers, payment gateways, delivery partners, or linked websites. Users interact with third parties at their own risk.

13.4 Limitation of Damages

Pawtrition India’s aggregate liability for any privacy-related claim shall not exceed INR 1,000 (One Thousand Indian Rupees) or the amount paid by the User for the specific transaction in dispute, whichever is lower.

13.5 Indemnification by User

Users shall indemnify, defend, and hold harmless Prime Lands Asia LLP, its affiliates, officers, directors, employees, and agents from and against all claims, damages, losses, liabilities, and expenses (including legal fees) arising from:

User’s breach of this Policy.
User’s violation of applicable law.
User’s negligence or willful misconduct.
Unauthorized use of User’s account credentials.

14. Governing Law and Jurisdiction

14.1 Governing Law

This Privacy Policy shall be governed by and construed exclusively in accordance with the laws of the Republic of India, without regard to conflict of law principles.

Applicable statutes include:

The Information Technology Act, 2000 (https://indiacode.nic.in/handle/123456789/1999)
The Information Technology (Reasonable Security Practices) Rules, 2011
The Information Technology (Intermediary Guidelines) Rules, 2021 (as amended)
All applicable laws of Uttar Pradesh State
All applicable central and state regulations

14.2 Exclusive Jurisdiction

Any dispute, claim, or controversy arising from or related to this Privacy Policy or the collection, use, or disclosure of Personal Information shall be subject to the exclusive jurisdiction of the competent courts located in Ghaziabad, Uttar Pradesh, India.

Users irrevocably consent to and submit to such jurisdiction and waive any objection to venue or claim of inconvenient forum.

15. Contact Information

For any questions, concerns, or requests regarding this Privacy Policy or your Personal Information, please contact:

Prime Lands Asia LLP — Pawtrition India
Registered Office: Ghaziabad, Uttar Pradesh, India
Email: pawtritionindia@gmail.com
Grievance Email: pawtritionindia@gmail.com
Phone: +91-XXXXXXXXXX
Website: www.pawtritionindia.com

Support Hours: 9:00 AM to 9:00 PM IST, Seven Days a Week, Including Weekends and National Holidays

For legal notices, notices must be sent via registered mail with acknowledgment due or email with read receipt to the above addresses.

BY CLICKING “I AGREE,” CREATING AN ACCOUNT, ACCESSING THE PLATFORM, OR PLACING AN ORDER, YOU ACKNOWLEDGE AND CONSENT THAT:

You have read, understood, and agree to be bound by this Privacy Policy in its entirety.
You consent to the collection, use, storage, disclosure, and processing of your Personal Information as described herein.
You acknowledge the security risks inherent in internet-based services and agree to hold Pawtrition India harmless from losses beyond our reasonable control.
You understand that customer support and grievance redressal are available only during Support Hours (9:00 AM to 9:00 PM IST, seven days a week).
You accept exclusive jurisdiction of courts in Ghaziabad, Uttar Pradesh, and consent to be bound by Indian law.
You have had adequate opportunity to seek independent legal counsel regarding this Policy.
You waive all claims against Pawtrition India except as strictly permitted under applicable law.