Privacy Policy.

1. Fiduciary-Processor Relationship & Consent Representation

Under the Indian DPDP Act, 2023:

• The **Merchant** acts as the **Data Fiduciary** who determines the purpose and means of processing personal data.
• **NETRAFY** acts strictly as the **Data Processor**, processing personal data solely on behalf of, and under the instructions of, the Merchant.
• The end-customers of the Merchant are the **Data Principals**.
• Consent Representation: The Merchant represents and warrants that they have obtained free, specific, informed, unconditional, and unambiguous consent from their Data Principals (end-customers) as required under Section 6 of the DPDP Act, 2023, authorizing the transfer and processing of their personal data (names, phone numbers, addresses, and order histories) on our platform. The Merchant shall bear sole responsibility for any consent breaches.

2. Information We Process

To provide order management, agent routing, and verification services, we access and store the following customer details:

• Store Identifiers: Store domain, shop owner email, location, and currency settings.
• Order Attributes: Order ID, product titles, transaction value, payment gateway, checkout IP address, and customer notes.
• Data Principal Information: Name, phone number, shipping address, city, state, zip code, and email address.
• Website Visits: This website counts visits with our own self-hosted, cookieless analytics. If you accept the visit notice, your browser's local storage keeps two dates, your first and your most recent visit, so we can tell new visitors from returning ones. It also keeps where that first visit came from (the campaign tags in the link, the referring website and the first page you opened), which is sent with your registration if you sign up so we know which channel brought you. No cookie is set and no identifier is stored. Declining skips this entirely, and clearing this site's data in your browser removes the dates.

3. Purpose & Legal Basis for Processing

All personal data processed by us is for specified, lawful purposes linked directly to the Merchant’s e-commerce operations:

• Assigning incoming orders to the Merchant's designated telecallers and support staff.
• Verifying Cash-on-Delivery (COD) and high-value orders to reduce failed deliveries.
• Maintaining action logs, internal comments, and tag allocations to verify customer intent.
• Syncing order cancellation and confirmation statuses back to the Merchant's Shopify store.

4. Data Principal Rights & Erasure Protocol

We facilitate the compliance obligations of the Merchant (Data Fiduciary) under Chapter III of the DPDP Act, 2023:

• Right to Erasure (Right to be Forgotten): Upon receiving an erasure request or when a Merchant uninstalls the app, we cease processing and permanently delete all associated personal data from our live databases within 72 hours, except where retention is required by Indian law. Copies held in our encrypted backups are not used to restore erased records and are destroyed automatically as those backups age out of our 30-day retention cycle.
• Mandatory Compliance Webhooks: We strictly integrate with Shopify's mandatory privacy webhooks (customers/redact, customers/data_request, and shop/redact) to automate erasure and data portability requests triggered by merchants or customers.
• Access & Corrections: Merchants can edit customer profiles, shipping details, and notes directly on our dashboard.

5. Data Protection & Reasonable Security Practices

We implement comprehensive technical and organizational measures to prevent personal data breaches:

• We maintain reasonable security practices compliant with **Section 43A of the IT Act, 2000** and standard secure coding procedures.
• Data in transit is encrypted using Transport Layer Security (TLS 1.3), and our production database is encrypted at rest using LUKS2 (AES-XTS, 512-bit). Store access credentials are additionally encrypted at the application layer before storage, and all database backups are encrypted with AES-256 using a key held separately from the backups themselves.
• Strict logical tenant isolation ensures that data from one Merchant's organization is never visible or accessible to another.
• We maintain a documented security incident response procedure. In the event of a personal data breach, we notify affected Merchants and the relevant authorities without undue delay, and in any case within 72 hours of confirming the incident.
• The production database is backed up nightly in encrypted form, retained for 30 days, and the restorability of those backups is verified automatically every week.
• Every access to a customer's name, email, phone number, or address is recorded in an audit log identifying the staff member, the time, and the record accessed. These audit records are retained for 12 months and contain no personal data themselves.
• We do **not** sell, lease, rent, or monetize your store’s data or customer information to any third parties for advertising or profiling.

6. Limitation of Liability & Indemnification

7. Governing Law & Jurisdiction

This Privacy Policy, its validity, performance, and any dispute arising out of or in connection with it shall be governed by and construed in accordance with the laws of the **Republic of India**. Any legal action or proceeding relating to this policy shall be subject to the exclusive jurisdiction of the competent courts located in **Gujarat, India**.

8. Contact Us