Privacy Policy


Affiliates” in relation to the Firm shall mean any Person that controls, is controlled by or is in common control with the Firm. For purposes of this definition, “control” means the power to direct the management or policies, whether through the ownership of over fifty percent (50 %) of the voting power, or through the power to Websiteoint more than half of the members of the board of directors or similar governing body, through contractual arrangements or otherwise;

Online Sugandhalay” refers to having its office at Pune, Maharashtra. Firm can be address as We, Us Ours, in this Privacy Policy;

Data” shall same meaning as assigned to it under Section 2 (1) (o) of Information Technology Act, 2000;

Website” shall refer to our Website having link and its sub-domains. This Website is owned and operated by the Firm;

Person” means and includes any natural person and legally recognised entity;

Personal Information” (PI) shall mean the following:

  1. Name, address, email ID, phone number of the User;
  2. User ID of the User;
  3. Geo-location of the User;
  4. Photo of the User;

Sensitive Personal Information” (SPID)  shall have the same meaning as assigned to it under Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011,

Service Provider” is a third party unrelated to the Firm who provides services related to incorporation and running of various businesses and has agreed to provide these services to the Users of the Firm. The Firm itself does not indulge in any selling activity of the Service Providers;

Third Party” shall mean and include any Person apart from the User who is agreeing to this Privacy Policy;

User” shall refer to all Persons, whether registered or unregistered, who access our Website in any way. A User may be addressed as You and Your;


By accessing, using and/or registering on our Website, you explicitly accept, without limitation or qualification, the collection, use and transfer of the Personal Information  in the manner described in this Privacy Policy. If you do not accept the Privacy Policy stated herein or disagree with the way the Firm collects and processes Personal Information collected on the Website, please do not use the Website. The Firm also sends you promotional and administrative emails, notifications and pop-ups.

You agree that we have an unconditional right to amend, modify and change the Privacy Policy at any time. The amended, modified, changed Privacy Policy shall be effective from the date of their publication on our Website, with or without any specific notification regarding modification, amendment or change on our Website. You agree that your continued usage of our Website will be considered as acceptance of modified, amended, changed Privacy Policy.

Collection and Use

We collect Personal Information from you through your use of our and its sub-domains.

Our servers also collect information such as the name of the domain and host from which you access the internet; the Internet Protocol (IP) address of the computer you are using; the date and time of your access.

If you authorise us to collect information via Gmail, Facebook, Twitter, we do so, however you may revoke this authorisation at any time by visiting the respective website through which you had granted authorisation.

We use the Personal Information for internal recording keeping, data analysis (without revealing your identity), improving our services, improving user experience and user interface, verifying your identity and authority to use our Services, and to otherwise enable you to use our Mobile App and our Services, to process billing and payment, including sharing with third party payment gateways in connection with Mobile App and/or our and Services, to resolve disputes, to protect ourselves and other users of our Mobile App and Services, and to enforce our Terms of Service;

  • We use the Personal Information to contact you via email, telephone, facsimile or mail, or, where requested, by text message, to deliver certain services or information you have requested
    • We also use your information and send it to our servers and used in fraud prevention efforts.
    • We use the Personal Information to periodically send promotional emails about new products, special offers or other information which we think may improve your experience with our Mobile App.
    • Our Mobile App users can voluntarily choose to electronically forward a link, page, or document to someone else by clicking “the appropriate links” To do so, the user must provide his or her email address, as well as the email address of the recipient. The user’s email address is used only in the case of transmission errors and, of course, to let the recipient know who sent the email. The information is not used for any other purpose
    • From time to time, we may use personal information for new and unanticipated uses not previously disclosed in our Privacy Policy. If our information practices change regarding information previously collected, we shall make reasonable efforts to provide notice and obtain consent of any such uses as may be required by law
  • We operate only within geographical territory of India and do not conduct operations in other countries and hence do not transfer your Personal Information to other countries, however the service provider of our server may transfer the server content to other countries for maintenance of backup or such other general practices. You agree to such cross-border transfers of Personal Information and the risk associated with it.
  • We collect Personal Information while you place an order, and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, name, email address, mailing address, phone number. Users may, however, visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities.

Storage, Retention and Transfer

  • We collect Personal Information from you along with username and password registered by you on our Mobile App. Some portion, but not all, may be shared by us with Third Parties under the terms and conditions of our contractual obligation towards them. The firm, while providing no guarantee but acting to the best of its ability, avoids unauthorized access, loss, misuse, disclosure, alteration, and destruction, in accordance with the sensitivity of the Personal Information. The firm further, on best effort basis, takes assurance from the Third Parties regarding taking measures for safe storage and handling of Data by them. The firm to the best of it’s ability takes care that Personal Information is stored and transferred in the encrypted, secured form and is accessible by authorised persons only.
  • We do not share, sell, trade or rent your Personal Information to Third Parties for unknown reasons. To the best of our ability, we retain complete anonymity in all analytics.

Information not treated as Personal Information

The information shared by the Users and/or Service Providers in feedback, surveys, chatrooms is not Personal Information and hence is not treated by the Firm as Personal Information. Such information is non-confidential and is treated as publicly available information by the Firm. The Firm to the best of it’s ability takes care that Personal Information is transferred in the encrypted, secured form and is accessible by authorised persons only.

Request for correction, updating, deletion of Personal Information

If you wish to correct, update, delete Personal Information, you may do so by emailing us on with subject line ‘Correction/Updation/Deletion of Personal Information’. The Personal Information is retained by the Firm for a period of _30 years__ post which the Firm ensures proper destruction of the in de-identified manner. Deletion of account or registration with us does not guarantee automatic destruction of the Personal Information. The Firm doesn’t intend to infringe the privacy of any person or entity and hereby declares that Personal Information collected by it shall remain the property of the truthful owner, possessor, holder of the PI and that the Firm shall not use PI for any purpose, other than the one mentioned in this clause, without providing an intimation in this regard.

SPID - Collection, Storage, Retention and Transfer

We are not collecting, storing, retaining and/or transferring SPID at the time of publishing of this Privacy Policy.

Collection and Storage of Personal Information from Social Networking sites

  • We provide a facility of logging into our Website through your Facebook Account. We ask you to grant us permission to access and collect your Facebook basic information (this includes your name, profile picture, gender, networks, user IDs, list of friends, date of birth, email address, and any other information you have set to public on your Facebook account). If you allow us to have access to this information, then we will have access to this information even if you have chosen not to make that information public.
  • We store the information that we receive from Facebook with other information that we collect from you or receive about you.
  • Facebook controls the information it collects from you. For information about how Facebook may use and disclose your information, including any information you make public, please consult Facebook’s privacy policy. We have no control over how any third party site uses or discloses the personal information it collects about you.

Privacy of Third Party data

The Firm doesn’t intend to infringe the privacy of any person or entity and hereby declares that Third Party data collected by it shall remain the property of the truthful owner, possessor, holder of the Third Party data and that the Firm does not use this Third Party data, for any purpose which would reveal the specific Personal Information of the said Third Party, without providing an intimation in this regard to that Third Party.

Privacy of Data Collected by Third Party

The Firm is not privy to nor is responsible for storage, retention, transfer of data collected from Users through the use of Website functionalities by Third Parties. The Users are requested to read respective Service Providers and Third Parties’ Privacy Policy prior to sharing any Data or Personal Information. Although the data passes the Mobile Website functionalities, the Firm neither collects, stores, retains or transfers this data.

Third Party Advertisements

You agree and authorize the firm to use and share your information with its contractors and other third parties, in so far as required for joint marketing purposes/offering various services/report generations and/or to similar services to provide you with various value-added services, in association with the Services selected by you or otherwise. You agree to receive communications through emails, telephone and/or sms, Firm’s contractors or its third-party vendors regarding the Services/ancillary services updates, information/promotional emails and/or product announcements. In this context, you agree and consent to receive all communications at the mobile number provided, even if this mobile number is registered under DND/NCPR list under TRAI regulations, and for such purpose, you further authorize firm to share/disclose the information to its contractors or any Third-Party service provider.

Under contractual obligation, we allow Third Parties to serve advertisements and/or collect certain portion of Personal Information in non-identifiable and statistic form from our Mobile App. These companies may use non-identifiable Personal Information to improve your experience regarding viewing of advertisements about goods and services.

Links to other websites

Our website may contain display of links and/or hyperlinks by clicking on which you could be directed outside our website and onto the website or Mobile Applications of Third Parties. We do not control these links and hyperlinks and wish to make you aware that you shall be responsible for results of click on any such links and hyperlinks; you are further advised to read the privacy practices and/or policies of any such other website. We are not responsible for any consequence of clicking on links and hyperlinks present on our Website.


The Firm cannot ensure and provides no guarantee that the Personal Information will never be disclosed in any way to any Third Party, Affiliates, Government Authority in the manner otherwise than described in this Privacy Policy. You acknowledge that entire part and parcel of your Personal Information will not always remain private and you assume the risk associated with use of Website, the internet generally and the documents you post or access and for your conduct on and off the Website.

Disclosure for legal purposes; on account of change in constitution of the Firm

If an appropriate Government authority  requests or order to disclose information or if we believe in good faith after considering your privacy interests and other factors that such action is necessary to:

  • conform to legal requirements or comply with legal process; 
  • protect our rights or property or our Affiliates; 
  • prevent a crime or protect national security; or 
  • protect the personal safety of users or the public

We will disclose the entire or such portion of your Personal Information.

If the Firm’s constitution changes on account of merger, acquisition, transfer of business, incorporation of a subsidiary Firm or in such other way and it is necessary to effect change of constitution to disclose such Personal Information, then we will do so, after considering on best effort basis, your privacy interests and such other interests, to a Third Party, Government Authorities or to our Affiliates, as the case may be. Once the constitution has changed, the Personal Information will become property of the newly constituted entity.

Important Information


You are responsible for ensuring that your log-in credentials (your username and password) are kept confidential from Third Parties.

We, on best effort basis, ensure that your log-in credentials are kept confidential and are shared with Third Parties under the same security as maintained by us.

  • We also use cookies, web beacons, and Java Script to administer our Website and deliver a personalized experience. For additional detailed information on each of these, please see below.

Cookies and other Tracking Technologies

  • We use “cookies” and other tracking technologies on our Website to record information such as internet domain, host names, internet protocol addresses, clickstream patterns, dates and time of access, operating system types, browser software, etc. These cookies help us in improving our Website and user experience. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them.
  • Please note that if you choose to erase or block your cookies, you will need to re-enter your original user ID and password to gain access to certain parts of the Website.

Grievances Officer

  • In terms of the Information Technology (Intermediaries Guidelines) Rules, 2011 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, any grievance or complaint may be intimated to ________________________, Grievance Officer, who may be reached at __________________________________________________________, India. The complaint shall be redressed within a period of 1 (one) month.