PRIVACY POLICY

Last Updated on 24 Apr 2025

  1. GENERAL

  1. We, XNEETI TECH PRIVATE LIMITED, a company registered under the laws of India, with registered office located at 965, 100 Feet, Road, Chawla Colony, Ballabgarh, Faridabad, Haryana, India – 121004 (hereinafter referred to as the “Company”, “Xneeti”, “We”, “Us” or “Our”) are committed to protecting privacy of Our users and grant importance to the confidentiality of user data over the internet.

  1. This privacy policy (“Privacy Policy”) is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000 and the rules made thereunder and the amended provisions pertaining to electronic documents/records under various statutes as amended by the Information Technology Act, 2000. This Privacy Policy does not require any physical, electronic or digital signature and is a legally binding document between the User and Us. This document is published in accordance with the relevant provisions of the Information Technology Act, 2000, the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 and the Information Technology (Reasonable Security Practices & Procedures & Sensitive Personal Data or Information) Rules, 2011, which mandate an intermediary (such as Xneeti) to publish a privacy policy to provide for relevant information pertaining to collection, use, storage, transfer/disclosure of Personal Information. 

  1. The Privacy Policy together with other relevant terms available on Our website located at www.xneeti.com (the “Platform”) and any other agreements which Xneeti may conclude with any User(s) (as defined hereinafter) are collectively applicable to the Users of the Platform (hereinafter also referred to as “You”, “Your”, “Yourself”). The User acknowledges that this Privacy Policy along with such other terms and policies as may be framed by Us from time to time (as available at Our Platform) as well as the relevant agreements entered into between the User and the Company (as may be applicable) shall form Our collective agreement (“Agreement”) with You in relation to Your use of Our Services and Platform.

  1. This Privacy Policy governs and sets forth the understanding in relation to the collection, usage, processing, storage, and disclosure of information that You may provide to Us electronically in connection with Your use or access of any of the services (including resources, tools, functionalities, and other facilities that the Company may provide or make available to You through the Platform from time to time (“Services”).

  1. Xneeti collects various types of the Information (as defined hereinafter) such as Personal Information (as defined hereinafter), and User Data (as defined hereinafter) from the User in various ways (as detailed herein below) as per the applicable laws in India during and as a result of Your use or access of Our Platform and Services. We collect and process the Information Collected subject to the Agreement and User’s consent for the purposes mentioned in this Privacy Policy.

  1. By visiting or using Our Platform and/or Services in any manner, You acknowledge and accept the practices and policies outlined in this Privacy Policy and hereby consent to Our collection and processing of Information Collected in accordance with the terms herein and the Agreement. You further acknowledge and accept that You are lawfully authorized to provide Your information to Us and have the legal capacity to do so and to give Your legal consent for the collection and processing of such information by Us. You further agree that such collection and processing of Your Information Collected in accordance with this Privacy Policy shall not cause any loss to any other person. You acknowledge that anything done, caused to be done, whether expressly or impliedly in contravention of this Privacy Policy may render You liable for legal action. We shall not be held liable in any manner whatsoever if there is any error or deficiency by Us in Our business transaction with You due to any information You provide Us which is incorrect or provided in a manner contrary to this Privacy Policy or due to any withdrawal of Your consent. You acknowledge and agree to indemnify and hold Us and/or Our employees, consultants, directors, representatives and/or associates, etc. harmless from any complaints, legal proceedings or claims filed or initiated by any third party against Us due to any breach by You of the terms of this Privacy Policy through any act or omission attributable to You.

  1. The Information Collected is used by Us strictly in line with Our business purposes and to provide You with useful features, including for provision and enhancement of Services, the operation of the Platform and to respond to Your requests/queries in an efficient manner. If You are not agreeable to this, please do not use this Platform and/or Services provided by Us. If You proceed to use this Platform and/or Services provided by Us, You hereby consent to Our collection and processing of Your Information Collected in the manner described in this Privacy Policy.

  1. For the purpose of the this Privacy Policy, it is clarified that “User(s)’,‘You’, ‘Your’, ‘Yourself’ shall mean an individual who is resident in India and a user of the Platform, who avails and/or is availing the Services provided by the Platform from Xneeti and/or has access to/uses the features and functionalities of the Platform and who in connection with the Services may access or avail, share, transact, view, display, download or browse any information on the Platform.

  1. Further, for the purpose of this Privacy Policy, reference to the term “Personal Information” shall mean the Personal Information or data of a User available with Us in electronic form (as elaborated below) and includes information through which a User is capable of being identified, whether directly or indirectly (in combination with other information available or likely to be available with Us in electronic form). Personal Information will not include anonymized information that has been appropriately processed to make it non-identifiable in order to irreversibly prevent its identification.

  1. Further, reference to the term ‘Business Partner(s)’ shall mean any natural and legal person(s) with which Xneeti has a business arrangement or collaboration under a definitive agreement, in relation to the functioning of the Platform and its Services, such as for facilitating, providing and/or delivering certain functionalities on the Platform including any features or aspects of any Services provided to User(s) on the Platform; Xneeti’s Business Partners include Our payment facilitation partner, sponsorship and advertising partners, and hosting service provider and similar  vendors.

  1. PROCESSING OF INFORMATION

  1. Users should note that the Information Collected, including Personal Information, shared with the Company shall be primarily processed in India but may be processed in such other jurisdictions where a third-party is engaged by the Company to process the data on Company’s behalf in accordance with applicable laws. We will on commercially reasonable basis require Our Business Partners and any other third-parties We engage and license to process the Information Collected that they adopt reasonable security standards to safeguard Your information/data in accordance with this Privacy Policy equivalent to the security standards maintained by Us under applicable laws. By agreeing to this Privacy Policy, You provide the Company with Your explicit consent to collect, share and process Your Information Collected for the purpose(s) defined in this Privacy Policy. Further, You acknowledge and accept that data protection regulations in India or such other jurisdictions mentioned above may differ from those of Your country of residence.

  1. In case You have any concerns in the processing of Your Personal Information, please reach out to Our Grievance Officer (as defined hereinafter) in the manner specified in clause 10 in this Privacy Policy.

  1. INFORMATION COLLECTED

  1. In the course of providing Services to You through the Platform and through Your use of the Platform, You acknowledge and accept that We may collect User Data, Personal Information, and other types of information listed below (collectively the “Information Collected”) from the User in the following ways: (i) as information supplied by Users, including User information fetched from third-party marketplace / e-commerce platform(s) (such as Amazon) via application programming interface (API) with Your consent in accordance with the terms herein; (ii) as information automatically tracked during Users navigation on the Platform; and/or (iii) as communicated directly to Us by User(s) via e-mail or other electronic mode. You consent to Our collection and processing of that information.

  1. We may collect Personal Information such as Your name (including Your first and last name) and other contact information (including phone number or email address or both) along with Your business documents and details (including Your GST certificate) at the time You register on the Platform. This type of information is primarily used for the purpose of creation of Your account with Xneeti for the Services (including for ancillary communication and support functions in relation to the Services). In connection, We utilize Your business documents and details to verify the authenticity of Your enterprise, to determine Your eligibility for the Services and to generate an agreement (where applicable) between You and Xneeti governing Our provision of Services.

  1. Further, We collect information and technical data from and about Your devices with Your permission automatically when You access or register on the Platform. For example, when You utilize Our Platform, We may collect technical data and information about the type of browser You use to access Our Platform, Your geographic region or location, the date and time at which You access Our Platform, Your internet protocol (IP) address and internet service provider (ISP) along with information regarding the relevant webpage/weblink from which You visit/access the Platform and the one from which You exit.  We may also collect information about Your activity on the Platform, such as information about Your use of Our Services or Platform as well as information about how You interact with the same (collectively, “User Data”). We may combine this User Data with other information, including Personal Information We have collected about You in order to provide or enhance the Services and to offer features and functionalities on the Platform.

  1. We collect communications between You and the Company, and related information such as contact details. If the User communicates with Us, via e-mail or other means, such as by sharing suggestions, comments and requests or other feedback with Us regarding Our Services and/or Platform or by reaching out to Our Grievance Officer for registering Grievances (as defined hereinafter), any information provided in such communication by User may be collected by Us. We collect and process such information principally for the purpose of responding to the User, for resolving Your queries and rendering Services and/or offering or improving use of the Platform and Services.

  1. User’s having business account(s) on third-party marketplace / e-commerce platform(s) (such as Amazon, Walmart etc.) have the option to link the same to their account with Xneeti for the purpose of the Services in accordance with the Agreement. If You choose to exercise such option and link Your Amazon account(s), We may fetch and process Your available business and profile data from the same (including information about Your listings, inventory, payouts, sales and advertisements) with Your consent for the purpose of the Services. We also collect any further Personal Information and data that You transmit to or choose to share or submit to Us for the purpose of the Services accordance with the Privacy Policy. This type of information is primarily used by Us to generate business insights, provide You with reports, information regarding business optimization, and other operational support.

  1. We utilize and process Your Information Collected, including Your Personal Information, strictly in accordance with the Privacy Policy and solely for the purpose of the Services. In connection, You understand and acknowledge that We may utilize and process Your Personal Information to maintain security, optimize performance and operation of Our Platform along with Our internal analytics and reporting purposes. 

  1. We use the Information Collected for the Platform and Services in the manner mentioned in the Privacy Policy. Except for the disclosures mentioned in the Privacy Policy, We do not disclose or share Your Personal Information in any manner.

  1. You acknowledge and accept that We are not responsible for the authenticity of any Information Collected, including the Personal Information that You provide to Us. You are solely and exclusively responsible for providing Us information about You that is true, authentic, and correct in all aspects and particulars. If You provide inaccurate or false information to Us, You shall be liable to indemnify and hold harmless the Company (and its officers, directors, contractors or agents and any third party relying on the information provided by You) in the event You are in breach of this Privacy Policy.

  1. Correction, Update and Amendment of Information Collected: You shall have the sole responsibility to intimate Us and request correction of inaccurate Personal Information maintained by the Company about You. You may intimate Us in this regard by reaching out to Our relevant personnel (coordinating with You for the Services) through electronic communication via the email address of such personnel at grievance@xneeti.com. Upon receipt of a verifiable request from You, We will use commercially reasonable efforts to correct the inaccurate Personal Information taking into account the nature of the information and the purposes of the processing and in accordance with applicable laws and regulations.        

  1. TRANSFER AND DISCLOSURE OF INFORMATION

  1. While We have implemented commercially reasonable physical, managerial, operational and technical security measures (as detailed herein below) to protect the loss, misuse and alteration and to preserve the security of the Personal Information in Our care, the User acknowledges and accepts that Information Collected on the Platform may be transmitted to third-party data servers for the purposes mentioned herein below and processed subject to the terms and policies of such data server.

  1. We may disclose Your information as We may deem necessary by sharing such information with third parties, such as Our Business Partners who are responsible for fulfilling various components (such as payments) in connection with Services requested by Users on the Platform, in the manner and for the purposes described herein below. The transfer or disclosure of Your Personal Information to any third parties in the manner mentioned will only be done once it is ensured that the third party receiving such information has implemented the same level of security practices as We have in the manner mentioned herein.

 

  1. Other than as specifically stated in this Privacy Policy, We will only disclose Your Personal Information in the event it is required to do so by applicable law, rule, regulation, law enforcement agency, governmental official, legal authority or similar requirements applicable to Us or if We, per Our sole discretion, deem it necessary in order to protect its rights or the rights, property or personal safety of others; respond to claims, to prevent harm to persons or property, to fight fraud and credit risk, or to enforce or apply the Privacy Policy or Agreement, as and when deemed necessary. All transfers or disclosures will be for lawful purposes only.

  1. PROCESSING OF INFORMATION COLLECTED

  1. We may use, process and store the Information Collected, including Your Personal Information and User Data and other information as shared and allowed to be stored by You along with the information as available in or linked with Your account with Xneeti, to facilitate Your use of Our Services and to enable You to complete Your transactions on the Platform expeditiously. In particular, We (and Our Business Partners including third-party data processors, hosting partners and vendors who may be engaged and authorized by Us and acting on Our behalf) may collect, store and process Information Collected for the following reason(s):

  1. to register the User, create Your account and send verification message(s) or email(s);
  2. to provide You with the Services;
  3. to undertake billing and raise invoices for the Services;
  4. to send confirmations regarding Services either via e-mail, SMS or WhatsApp or telephone or any other messaging service including sending any updates or changes thereto;
  5. to allow Our customer service to contact You, if necessary;
  6. to request for feedback, testimonials or reviews of Our Platform and/or Services or any other improvements thereto;
  7. to validate/authenticate Your account with us and to prevent any misuse;
  8. to analyze data about Your activity on Our Platform;
  9. to help diagnose problems with Our data server, and to administer Our Platform.
  10. for responding to the judicial process and providing information to law enforcement agencies or any government agency in connection with a query/investigation on matters as permitted by law;
  11. to allow third parties to contact with You in relation to any availed/requested by You in course of Services or through third party links;
  12. to identify security breaches and attacks, investigating, preventing and taking action on illegal or suspected fraud or money laundering activities and conducting forensic audits as part of internal or external audit or investigation by Us or government agencies located within India or outside jurisdictions;
  13. for sharing, disclosing and transfer of data in case of any major event such as merger, acquisition, sale or transfer of assets in case of any force majeure event to any third party with prior intimation to You;
  14. for data processing, statistical or risk analysis and for analytics and review for improvement of the Services;
  15. for designing and marketing Our Services and business;
  16. to resolve disputes; troubleshoot problems; help promote a safe service; collect payment; measure consumer interest in Our Services or detect and protect Us against error, fraud and other criminal activity; enforce the Agreement; and as otherwise described to You at the time of collection or as part of the Agreement.

  1. Further, We may use, store and process the Information Collected for the following reason(s):

  1. for fulfillment of the Services, including to make the Services this Platform customized; to provide Services tailored to individual requirements; to understand Your needs and provide You with improved Services;
  2. to maintain any registered accounts that You may hold with Us and to provide You with updates or notifications of changes to Your account;
  3. for Our internal record keeping requirements including collection of anonymized details about visitors to Our Platform to compile aggregate statistics or produce internal reports;
  4. to communicate with You and to share with You additional and/ or upcoming information regarding the Services offered by Us on the Platform;
  5. to better understand how the Users access and use Our Services; and
  6. for any purposes related to the above or where We have a legal right or duty to use, process or store Your Personal Information (including for abuse, crime and fraud prevention and related purposes);

  1. We do not knowingly seek any information, including Personal Information and information qualifying as ‘sensitive personal data and information’ under the Information Technology Act, 2000 (read with rules issued thereunder) from a person who has not attained the age of majority (under applicable laws in the jurisdiction such person is resident in). If You are a parent or guardian and You are aware that a minor (being an individual less than eighteen years in India) in Your care has provided Us with such information, without Your knowledge and consent, please contact Our Grievance Officer in the manner provided in this Privacy Policy. If We become aware that We may have collected Personal Information from such persons, We will take steps to remove that information from Our servers and/or to deactivate the relevant account associated with such persons as soon as reasonably practicable.

  1. We may disclose Your Personal Information as part of any merger, sale of Our business and assets or acquisition, as well as in the event of insolvency, bankruptcy or receivership upon prior written intimation to You.

  1. Our Platform may contain links to third party websites or applications. The User agrees and understands that these website(s) and application(s) are not under Our control and subject to additional and separate terms and policies. The User acknowledges and accepts that once the User leaves Our servers, use of any information provided by the User will be governed by the privacy policy and terms of the operator of these website(s) and application(s).

  1.    SHARING OF INFORMATION

  1. You acknowledge and accept that Your Information Collected may be shared with the parties mentioned below who are responsible for fulfilling Services (and relative payments) requested by Users on the Platform. You further acknowledge and accept that while making use of Our Platform with the Company, You authorize Us to share Your Information Collected with the said parties in the manner described below.

  1. We share the Information Collected with Our Business Partners and other relevant third parties for purpose(s) defined under this Privacy Policy in the course of Your transactions. Your information may be shared with Business Partners that We work with for the Services and other business activities such not limited to billing, payments, communication, marketing, data and information storage, transmission, security, analytics, audit, investigation, forensics, fraud detection, risk assessment in the manner permitted under law on a need-to-know basis.

  1. We do not share Your Personal Information with Business Partners for any other purpose(s) except as maybe required for fulfilling their part of Services or as mentioned in this Privacy Policy. The User accepts and acknowledges that the said parties use/process Personal Information shared with them for their own services as independent data controllers, and such services may be subject to separate terms and privacy policies. If You choose to avail any such services offered by said parties, the services so availed will be governed by the privacy policy of the respective party providing such service.

  1. In the interests of improving personalization and service efficiency, We may, under controlled and secure circumstances, share Your Personal Information with Our Business Partners to enable Us to provide You with information which might interest You in relation to the Services, to display relevant advertisements on the Platform, based on Your preferences or help Us address Your questions and requests in relation to Your use of the Platform.

  1. If assets of Xneeti are acquired, Our customer information may also be transferred to the acquirer depending upon the nature of such acquisition in accordance with this Privacy Policy. In relation, as part of business expansion/development/restructuring or for any other reason whatsoever, if We decide to sell/transfer/assign Our business, any part thereof, then as part of such restructuring exercise Our customer information including the Personal Information collected herein shall be transferred accordingly in accordance with this Privacy Policy.

  1. We do not sell User’s Personal Information to any advertisers or any third party. We do not sell or rent individual customer names or other Personal Information of Users to third parties, save and except sharing of such information with Business Partners.

  1. We may use non-identifiable Personal Information of Users in aggregate or anonymized form to build higher quality, more useful online services on the Platform by performing statistical analysis of the collective characteristics and behavior of Our customers and visitors, and by measuring demographics and interests regarding specific areas of the Platform. Further, We may provide anonymous statistical information based on this data to current and potential Business Partners. Any Personal Information which We collect and which We may use in an aggregated format is Our property. We may use it, in Our sole discretion and without any compensation to You, for any legitimate purpose.

  1.    STORAGE AND SECURITY

  1.  The security of Your Personal Information is important to Us. All Personal Information collected on Our Platform is securely transmitted to Our internal computer servers and to AWS cloud servers to ensure secure storage of data and/or securely stored on the AWS server. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited. We implement commercially reasonable physical, managerial, operational and technical security measures to protect the loss, misuse and alteration of the Personal Information in Our possession. We take necessary precautions to protect Your Personal Information both online and off-line and implement reasonable security practices and measures that are commensurate with respect to the information being collected and the nature of Our business in accordance with legal and industry standards and the applicable laws.

  1.  Although We make best possible efforts to store Your Personal Information in a secure operating environment that is not open to the public, the User acknowledges and agrees that there is no such thing as complete security, and We cannot guarantee safety or security of Your information as events beyond Our control can also occur, both during transmission of Your information and once We receive it. If We become aware that there has been any unintended disclosure of Your Personal Information in a manner which is not in accordance with this Privacy Policy, We will use reasonable efforts to notify such User of the nature and extent of such disclosure as soon as reasonably possible and as permitted by law. We encourage the User to follow certain security measures on their part, including: if using a computer in a public location, to always log out and close the website browser when You complete Your online session; keep Your account details and passwords private; frequently change Your password; and avoid using the same password for multiple online accounts.

  1.  Tenure of Storage and Retention of Information Collected: We retain Your Information Collected for as long as is reasonably necessary to fulfill the purposes listed in this Privacy Policy so as to provide You with access to Our Services and Platform. You acknowledge, accept and understand that Xneeti will retain Your Information Collected on its servers for as long as is reasonably necessary for the purposes listed in this Privacy Policy. In some circumstances We may retain Your Personal Information (including Sensitive Personal Information) for longer periods of time, for instance where We are required to do so in accordance with any legal, regulatory, tax or accounting requirements.

  1. The User acknowledges and understands that the third-party storage servers utilized by Us are subject to additional and separate terms and policies of their operators which may be applicable to the User. You acknowledge and agree that We may retain Your Personal Information in the manner mentioned in this Privacy Policy for the purpose of the Services and in accordance with any legal, regulatory, tax or accounting requirements.

  1.  CONSENT AND WITHDRAWAL OF PERMISSIONS

  1.  Users are encouraged to communicate any concerns regarding User’s Personal Information to Our Grievance Officer in writing by using the applicable contact details set out at clause 10 of this Privacy Policy. In case the User opts to decline to provide consent or withdraw any consent granted to Us in respect of collection or processing of the User’s Personal Information or request deletion of any of the Information Collected, the User acknowledges and agrees that such action may interfere with or render it impossible for Us to offer any further Services to the User and We may be forced to limit, suspend or terminate Your access to the Platform and/or the Services.

  1.  User hereby agrees and acknowledges that We shall not be held liable in any manner whatsoever if We are unable to perform Our Services or if there is a deficiency in the Services provided by Us due to User’s Information which is incorrect or due to any withdrawal of consent. User acknowledges and agrees to indemnify and hold Us and/or Our employees, consultants, directors, representatives and/or associates, etc. harmless from any complaints, legal proceedings or claims filed or initiated by any third party against Us due to any breach by the User of the terms of this Privacy Policy.

  1.  We provide Users with the opportunity to opt-out of receiving non-essential (promotional, marketing related) communications from Us (on behalf of Our Business Partners, and from Us in general) after setting up an account by sending an email to the following email address: grievance@xneeti.com. To the extent We use Your Personal Information to market to You, We will provide You the ability to opt-out of such uses. In case, You choose to do so then Your access to the Platform may be limited, or We might not be able to provide the Services to You.

  1.  We re-iterate that in case You have any concerns in the collection and processing of Your Personal Information or any relative consent or permission You have granted Us in this regard, please reach out to Our Grievance Officer in the manner provided in this Privacy Policy.

  1. CHANGES TO PRIVACY POLICY

  1. You acknowledge and accept that Xneeti may update this Privacy Policy at any time, with or without advance notice. In the event there are changes in the way Xneeti treats User’s Personal Information, or in the Privacy Policy itself, We will display a notice on the Platform or send Users an email, as mentioned above, so that You may review the changed terms prior to continuing to use the Services.

  1. If You object to any of the changes to Our Privacy Policy, and You no longer wish to avail the services, You may contact Us at grievance@xneeti.com to deactivate Your account or may contact in the manner specified in clause 10 herein for any other Grievances or issues related to the collection of Your Personal Information under this Privacy Policy. Unless stated otherwise, Our current Privacy Policy applies to all information that Xneeti has about You and Your account. If a User uses the Platform, after a notice of change is published on the Platform, such User hereby consents to the changed terms.

  1. GRIEVANCE REDRESSAL

In case You have any queries, complaint or grievance pertaining to the Privacy Policy or breach thereof, or in respect of the use and processing of Your Personal Information by Xneeti (‘Grievance(s)’), You can direct such Grievances to Our designated Grievance Officer in writing via e-mail or post using the contact details mentioned herein below. Any communication pertaining to any discrepancies, points of concern or grievances as regards the Privacy Policy and any complaints, abuse or concerns with regards to content and/or breach of the terms herein must be immediately informed to Our Grievance Officer (using the contact information mentioned below) in writing. The Company shall not be responsible in the event that You address any communication to any non-designated person in this regard.

Name: Prateek Goyal

Office Address: Xneeti Tech Private Limited, 965, 100 Feet, Road, Chawla Colony, Ballabgarh, Faridabad, Haryana, India – 121004

Email Address: grievance@xneeti.com

You are expected to provide the abovementioned officer (the “Grievance Officer”) with all necessary information and/or documents to enable the Grievance Officer to resolve the issue. The grievances received under this paragraph shall be dealt with in adherence to the timelines specified under the Information Technology Act, 2000 and the applicable rules notified thereunder.

While We will investigate and attempt to resolve any queries regarding the use or disclosure of Your Personal Information as soon as possible, occasionally it may take Us longer to respond to You, if Your request is particularly complex or You have made a number of requests. In this case, We will notify You and keep You updated.