Privacy Policy
Effective Date: [Insert Date]
Introduction
This Privacy Policy (“Policy”) constitutes a legally binding agreement between You (“User”, “You”, or “Your”) and Sylonow Vision Private Limited (“Company”, “We”, “Us”, or “Our”), governing the collection, use, processing, storage, transfer, disclosure, and protection of Personal Data and Sensitive Personal Data in connection with Your access to and use of the Sylonow platform, including its website, mobile applications, APIs, integrations, and associated services (“Platform”).
By accessing or using the Platform, You irrevocably and unconditionally consent to all terms set forth herein.
1. Scope and Applicability
1.1 This Policy applies to all Users accessing the Platform within India and globally.
1.2 This Policy shall be read in conjunction with:
- Information Technology Act, 2000
- SPDI Rules, 2011
- Digital Personal Data Protection Act, 2023
- Any other applicable laws, rules, or regulations
1.3 In case of conflict, the Company reserves the right to interpret provisions in a manner most favorable to its operational and legal interests.
2. Categories of Data Collected
The Company may collect, process, store, and use the following categories of data:
2.1 Personal Identification Data
- Full name, phone number, email address
- Profile details, preferences, and interactions
2.2 Authentication & Verification Data
- OTP records, login timestamps
- Device fingerprints, session tokens
- Authentication logs and metadata
2.3 Device & Technical Data
- IP address, browser type, OS version
- Device identifiers, network information
- Crash logs, diagnostics, performance data
2.4 Behavioral & Usage Data
- Clickstream data, browsing behavior
- Interaction patterns, session duration
- Feature usage analytics
2.5 Financial & Transactional Data
- Payment references (handled via third-party providers)
- Transaction IDs, order history
- Billing metadata (not storing full card details)
2.6 Location Data
- Approximate or precise location (if permitted)
- Geo-coordinates for service optimization
2.7 Vendor & Business Data
- Business details, listings, service catalogs
- Pricing, availability, and operational data
2.8 Derived & Inferred Data
- Preferences, interests, predictive analytics
- Behavioral scoring and segmentation
3. Mode of Collection
Data may be collected through:
- Direct user input
- Automated tracking (cookies, SDKs, pixels)
- Third-party integrations (payment gateways, analytics, SMS providers like MSG91)
- Publicly available or legally obtained datasets
The Company may combine multiple data sources to create enriched datasets.
4. Purposes of Processing
The Company reserves the unrestricted right to process data for:
- Platform functionality and service delivery
- OTP authentication and identity verification
- Fraud detection, abuse prevention, and risk mitigation
- Personalization and recommendation systems
- Business intelligence, analytics, and machine learning
- Marketing, retargeting, and user engagement campaigns
- Vendor-user matchmaking and lead distribution
- Legal compliance, enforcement, and dispute resolution
The Company may also process data for future features not yet launched, without requiring additional consent where legally permissible.
5. Legal Basis of Processing
Processing shall be based on:
- User consent (explicit or implied)
- Legitimate business interests
- Contractual necessity
- Legal obligations
Where multiple bases apply, the Company may rely on any applicable basis at its discretion.
6. Data Sharing and Disclosure
The Company may disclose data to:
- Affiliates, subsidiaries, and group companies
- Vendors, partners, and service providers
- Cloud infrastructure providers
- Analytics and marketing platforms
- Payment processors and financial institutions
- Telecom providers and SMS gateways
- Government authorities, regulators, law enforcement
Such disclosure may occur:
- Without prior notice where legally required
- For internal restructuring, mergers, or acquisitions
- For enforcing rights or preventing fraud
7. Cross-Border Data Transfer
Data may be transferred to jurisdictions outside India.
You expressly consent to such transfers, even if such jurisdictions may have differing data protection standards.
8. Data Retention
The Company may retain data:
- For as long as necessary for business purposes
- To comply with legal obligations
- To resolve disputes and enforce agreements
The Company may retain anonymized, aggregated, or derived data indefinitely.
9. User Rights (Limited)
Subject to applicable law, Users may request:
- Access to their data
- Correction of inaccurate data
- Deletion of data
However, the Company may refuse requests if:
- Required for compliance
- Necessary for business continuity
- Technically infeasible
- Disproportionate effort involved
10. Security Disclaimer
The Company implements reasonable safeguards.
However:
- No system is completely secure
- The Company disclaims liability for unauthorized access
- The Company disclaims liability for data breaches beyond reasonable control
- The Company disclaims liability for third-party failures
- The Company disclaims liability for force majeure events
Users transmit data at their own risk.
11. Third-Party Services
The Platform integrates with third-party services.
The Company:
- Does not control third-party data practices
- Shall not be liable for third-party misuse
Users are advised to review third-party policies independently.
12. Automated Decision-Making
The Company may use algorithms and automated systems for:
- Recommendations
- Lead distribution
- Fraud detection
Such decisions may occur without human intervention.
13. Children and Minors
The Platform is not intended for users under 18.
If data of minors is collected inadvertently:
- The Company reserves the right to delete it without notice
14. Limitation of Liability
To the maximum extent permitted by law, the Company shall not be liable for:
- Indirect, incidental, or consequential damages
- Loss of data, profits, or goodwill
- Unauthorized access or misuse
Total liability, if any, shall not exceed INR 1,000.
15. Indemnity
You agree to indemnify and hold harmless the Company from:
- Claims arising from misuse of the Platform
- Violation of this Policy
- Breach of applicable laws
16. Policy Modifications
The Company may update this Policy at any time without prior notice.
Continued usage constitutes acceptance.
17. Governing Law
This Policy shall be governed by Indian law.
Jurisdiction: Courts of Bangalore, Karnataka.
18. Grievance Officer
As per applicable laws:
- Grievance Officer: [Insert Name]
- Email: [Insert Email]
- Address: [Insert Address]
19. Explicit Consent
By using the Platform, You:
- Acknowledge reading and understanding this Policy
- Provide explicit, informed, and unconditional consent
- Waive any claims arising from data processing within this scope
End of Policy.
Sylonow Vision Private Limited · info@sylonow.com