ZUNIAR

1. SCOPE & DEFINITIONS

Term.	Meaning.
Personal Data	Data about an identified or identifiable individual, as defined under the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and other applicable law.
Child	An individual who has not completed the age of 18 years, as defined under the DPDP Act.
Account Data	Personal Data submitted by a registered user to create and operate an account, including name, contact details, delivery address and order history.
Personalisation Selection	A user's optional Boy / Girl / Expecting / Newborn selection used to tailor the homepage, collections and product recommendations.
Guest Data	Information generated for a user browsing the App without creating an account, held only on the user's device.
User Content	Photos, ratings and written reviews submitted by users through Story Review.
Data Fiduciary / Data Processor / Data Principal	Terms used in accordance with the DPDP Act and applicable data protection law.

2. INFORMATION WE COLLECT

Category.	Information and purpose.
Account Data	Collected on registration and while using the App, to create and administer an account, process orders and provide support.
Personalisation Selection	The Boy / Girl / Expecting / Newborn tile selected by the user, used solely to adjust homepage banners, collections and product pills. Selecting a category is optional; a user who skips it sees the unpersonalised homepage.
Order & Transaction Data	Product, payment and delivery information collected to fulfil and support an order.
User Content	Photos, star ratings and written reviews submitted for Story Review.
Device & Usage Data	Technical and interaction information generated through use of the App, for operation, security and service improvement.

3. THE BOY / GIRL / EXPECTING / NEWBORN SELECTION

Scenario.	How the selection is handled.
Registered user	The selection is saved to the user's profile and applied across the devices on which they are logged in.
Guest (not logged in)	The selection is stored only on the user's device. It is not transmitted to or held on our servers, and is removed if the user clears the App's data or uninstalls the App.
Guest converting to an account	A guest's device-stored selection is carried over to the new account on registration. The precise transfer mechanism is being finalised with our engineering team; this Policy will be updated once it is confirmed.
“Expecting” / “Newborn” selection	These categories can indicate a pregnancy or the presence of an infant in the household. We use this signal only to adjust on-App merchandising and do not use it to build behavioural or advertising profiles of any user who has identified, or whom we have reason to believe is, a child.
Tracking scope	The specific user activity generated by a Personalisation Selection that we log for analytics is under review with our data team; this Policy will be updated to describe it once finalised.

4. STORY REVIEW — USER-GENERATED CONTENT

Clause.	Requirement.
Licence to display	By submitting a photo, rating or review to Story Review, the user grants us a non-exclusive, worldwide, royalty-free licence to reproduce, display and feature that content on the App alongside brand and campaign content, for as long as the content remains published.
Content standards	Reviews must not present health, safety or medical claims about a product as fact, must not contain another individual's Personal Data without consent, and must not contain unlawful, obscene or infringing material.
Moderation	Submissions are reviewed before publication. Our moderation turnaround time is being finalised with the content team and will be published here once confirmed.
Takedown requests	A user may request removal of their own review, photo or rating, or flag another user's content, through the grievance contact in Section 10. We will assess and act on such requests within a reasonable time.

5. CONSENT & LAWFUL BASIS

Clause.	Requirement.
Basis for processing	We process Personal Data on the basis of consent, or another lawful ground recognised under the DPDP Act, such as performance of a contract with the user (for example, fulfilling an order).
Notice	Before or at the time of collecting Personal Data, we provide a notice describing the Personal Data collected and the purpose of processing, in accordance with the DPDP Act.
Withdrawal	A user may withdraw consent at any time through account settings or by contacting us. Withdrawal does not affect processing carried out before withdrawal, and may limit features that depend on the relevant data.

6. CHILDREN & TEENAGE USERS

Clause.	Requirement.
Application of this section	The App is used both by adults shopping for children and, in some cases, by teenagers directly. This section applies wherever we have actual knowledge, or reason to believe, that a user is a Child.
Verifiable parental consent	We do not process the Personal Data of a Child except with verifiable consent of the Child's parent or lawful guardian, obtained in accordance with the DPDP Act and applicable rules. Our verifiable-consent mechanism is under development; until it is live, features requiring an account are restricted for users identified as Children.
No tracking or behavioural monitoring	We do not undertake tracking or behavioural monitoring of a Child's activity on the App, including activity relating to the Boy / Girl / Expecting / Newborn selection or Story Review.
No targeted advertising to children	We do not serve advertisements targeted at a Child, and do not use a Child's Personalisation Selection, order history or Story Review activity to build an advertising profile.
No detrimental processing	We do not undertake processing of a Child's Personal Data that is likely to cause any detrimental effect on the well-being of the Child.
Parental rights	A parent or lawful guardian may exercise any right available to a Data Principal under this Policy on behalf of a Child, and may request access to, correction of, or erasure of the Child's Personal Data through the grievance contact in Section 10.
Exemptions	Where the Central Government has, by notification, exempted specified processing (including certain age-verification, safety or health-related processing) from some of the above requirements, we rely on such exemption only to the extent notified and applicable.

7. SHARING & DISCLOSURE

Recipient.	Purpose and limits.
Service providers	We share Personal Data with hosting, payment, logistics, communications and analytics providers as necessary to operate the App, subject to contractual safeguards.
Authorities	We may disclose Personal Data where required by law, court order, regulatory direction or other lawful process, limited to what is reasonably required.
Business transfers	Personal Data may be transferred as part of a merger, acquisition, restructuring or sale of business or assets, subject to applicable law.
No sale of data	We do not sell Personal Data to third parties, and do not, under any circumstance, sell a Child's Personal Data or make it available for targeted advertising or behavioural tracking.

8. RETENTION & DELETION

Principle.	Approach.
Retention period	We retain Personal Data only for as long as reasonably necessary for the purpose for which it was collected, or as otherwise required by applicable law.
Guest data	Device-stored Guest Data remains under the user's control and is removed when the user clears the App's data or uninstalls the App.
Deletion / anonymisation	When Personal Data is no longer required and no lawful retention obligation applies, we delete or irreversibly anonymise it.
Account erasure	A user may request erasure of their account and associated Personal Data through the grievance contact in Section 10, subject to any information we are required to retain by law.

9. YOUR RIGHTS & GRIEVANCE REDRESSAL

Right.	How it is exercised.
Access & correction	A user (or, for a Child, their parent or guardian) may request a summary of Personal Data processed and request correction of inaccurate or incomplete data.
Erasure	A user may request erasure of Personal Data that is no longer necessary for the purpose for which it was collected, subject to legal retention requirements.
Grievance redressal	Grievances relating to this Policy or our processing of Personal Data may be raised with our Grievance Officer (Section 10). We will acknowledge and address grievances within the timelines prescribed under the DPDP Act.
Right to nominate	A user may nominate another individual to exercise their rights under the DPDP Act in the event of death or incapacity, in the manner we make available.

10. SECURITY, UPDATES & CONTACT

Clause.	Requirement.
Security measures	We maintain reasonable technical and organisational safeguards appropriate to the nature of the Personal Data processed, including access controls and encryption in transit.
Incident response	If we become aware of a Personal Data breach, we will take reasonable containment and remediation measures and make notifications required under the DPDP Act.
Policy updates	We may update this Policy to reflect changes in law, App functionality or processing practices. Material changes affecting Children or the Personalisation Selection will be highlighted through reasonable means.
Contact	Zuniar Support: support@zuniar.com | WhatsApp: +91-9217995889. Grievance Officer and email: to be designated and published on the App.