Privacy Policy — Evolve Brands Pvt Ltd (DPDP 2023 Compliant)

Effective Date: 01-04-2026
Last Updated: 28-04-2026

1. Introduction

At Evolve Brands Pvt. Ltd. ("EBPL", "we", "us", "our"), your privacy is of utmost importance. This Privacy Policy explains how we collect, process, store, share, and safeguard your personal data, in accordance with the Digital Personal Data Protection Act, 2023 (DPDP Act, India) and other applicable laws.

By accessing, registering, or using our mobile applications, website, or loyalty reward services ("Services"), you acknowledge that you have read, understood, and consented to the practices described in this Privacy Policy.

2. Definitions

• Personal Data: Any data about an individual who is identifiable by such data.
• Data Principal: You, the individual whose data is being collected.
• Data Fiduciary: Evolve Brands Pvt Ltd, the entity determining the purpose and means of processing personal data.
• Data Processor: Any third party processing data on behalf of EBPL.
• Consent: A freely given, specific, informed, and unambiguous agreement for processing personal data.

3. Applicability

This policy applies to:

• All users of our services in India.
• Personal data collected via our mobile apps, website, loyalty platform, or any offline collection method.
• Processing activities done by EBPL or authorized third parties.

4. Data We Collect

4.1 Personal Data You Provide

We may collect and process:

• Full Name
• Date of Birth
• Gender
• Email Address
• Mobile Number
• Residential/Business Address
• Company Name and Position
• PAN / Aadhaar (only where legally permissible)
• GST( For firm Verification)
• Customer Interaction Data (purchase, participation, survey, etc.)
• Your consent records

4.2 Personal Data of End Users (If applicable)

If you provide us with your customer data (for example, during loyalty program management), we may collect:

• Customer Name
• Contact Details
• Purchase or Transaction History
• Loyalty Points Data

4.3 Data Collected Automatically

• IP Address
• Device Information
• Browser Type
• Cookies and Tracking Data
• Location Data
• App Usage Behavior
• Log Files

5. Purpose of Processing

We collect and process your data for:

• Registration, onboarding, and identity verification.
• Managing your participation in loyalty programs.
• Processing loyalty points, redemptions, and rewards.
• Customer support and grievance handling.
• Transaction monitoring and fraud prevention.
• Business analytics, reporting, and platform improvements.
• Legal and regulatory compliance.
• Sending transactional communications, promotional messages, and service updates.

6. Legal Basis for Processing

Under DPDP Act 2023, we collect and process data on the following grounds:

• Consent: For most data processing activities.
• Performance of Contract: When necessary to deliver services requested.
• Legal Obligation: Where mandated by law or government authority.
• Legitimate Interest: For internal operations, fraud detection, or legal defense.

7. Consent Management

• We obtain your explicit, informed, and voluntary consent before collecting personal data.
• You may withdraw your consent anytime by contacting us (see Section 14). Upon withdrawal, we may be unable to provide certain services.

8. Data of Children

• We do not knowingly collect personal data of individuals under the age of 18 years without verified parental consent.
• If you are under 18, do not provide personal data unless parental or guardian consent has been obtained.

9. Data Retention

• We retain personal data only as long as necessary to fulfill the purpose of collection, comply with legal obligations, and resolve disputes.
• Upon purpose completion or withdrawal of consent, your data will be deleted, anonymized, or archived as per retention policy.

10. Your Rights (Data Principal Rights)

Under the DPDP Act, you have the right to:

• Access: Know what personal data we process about you.
• Correction: Request correction of inaccurate or outdated data.
• Erasure: Request deletion after purpose is fulfilled.
• Grievance Redressal: Lodge complaints and seek timely resolution.
• Nominate: Appoint a nominee to exercise your rights in case of incapacity.

You may exercise these rights by contacting our Grievance Officer (see Section 14).

11. Data Sharing and Disclosure

We may share personal data only:

• With authorized third-party service providers for payment processing, IT support, cloud storage, analytics, and customer support.
• With affiliates and business partners under binding agreements ensuring data protection.
• As required by law, government agencies, or regulatory authorities.
• During corporate restructuring, merger, or acquisition, where data may be transferred with notification.

We DO NOT sell your personal data to any third party.

12. Cross-Border Data Transfer

We may transfer your personal data outside India to jurisdictions with adequate data protection as notified by the Indian government, subject to applicable laws. All such transfers will be subject to appropriate contractual safeguards ensuring protection of your data.

13. Data Security Measures

We implement appropriate technical, organizational, and security measures including:

• Encryption (TLS) for data transmission
• Access control & authentication
• Secure cloud storage
• Employee confidentiality agreements
• Periodic security audits
• Breach response plan

However, no system can be 100% secure. In case of any data breach, we shall notify affected data principals and authorities as mandated.

14. Grievance Officer

As per DPDP Act 2023, we have appointed a Grievance Officer:

Name/Designation: Seema Motwani/Associate Vice President
Email: seemam@evolvebrands.com
Response Time: Within 7 days of receiving the grievance

15. Automated Decision Making & Profiling

We do not use personal data for fully automated decision-making that affects your legal or personal rights. Any profiling is purely for service improvement or personalised offers, with your consent.

16. Updates to This Policy

We may update this policy from time to time. Changes will be notified through:

• Website announcements
• In-app notifications
• Email communications

You are requested to review the policy periodically. Continued use after updates implies your acceptance.

17. Contact Information

For any concerns or queries regarding this policy or data protection practices:

Evolve Brands Pvt Ltd
Registered Office: GS Tower, 112, 4th floor Udyog Vihar Phase 1 Sector 20, Gurugram Haryana 122015, India
Email: info@evolvebrands.com