Privacy Policy

(Compliant with India’s Digital Personal Data Protection Act, 2023)

Effective Date: ______________

Last Updated: ______________

Netsurf Communications Private Limited ("we", "our", or "us") values the privacy and data rights of our internal distributors, employees, and authorized users. This Privacy Policy explains how we collect, use, store, disclose, and protect your personal data in accordance with the Digital Personal Data Protection Act, 2023 ("DPDP Act").

1. Scope and Applicability

This Privacy Policy applies to all personal data collected through the internal distributor portal used by employees, agents, and distributors of Netsurf Communications Private Limited, a Direct selling Company for healthcare, home care, personal care, colour cosmetics and bio-fertilizer products in India.

2. Definitions

Under the DPDP Act:

Personal Data: Any data about an individual who is identifiable by or in relation to such data.
Data Principal: You, the individual to whom the personal data relates.
Data Fiduciary: We, Netsurf Communications Private Limited, who determine the purpose and means of processing your data.

3. Categories of Personal Data Collected

We may collect the following:

Basic identifiers: Full name, phone number, email address, employee/distributor ID, PAN/Aadhaar (if required for onboarding or compliance).
Business data: Orders, sales performance, regional data.
Device and usage data: IP address, location (approximate), browser/device information.
Login data: User ID, password (encrypted), timestamps of logins.

4. Legal Basis for Processing

We process your personal data based on:

Your consent, where explicitly obtained (e.g., account creation).
Contractual necessity, to manage your relationship as a distributor or employee.
Legal obligations, such as tax, labor, and regulatory compliance.
Legitimate interest, such as fraud prevention, auditing, and analytics.

5. Purpose of Collection and Processing

We use your data to:

Authenticate access to the platform.
Enable communication and coordination between company and distributors.
Process orders, manage inventory, and track sales performance.
Generate analytics and internal reports.
Maintain system security and compliance with applicable law.

6. Consent Management

Consent is taken wherever required under the DPDP Act and is free, specific, informed, and unambiguous.
You have the right to withdraw your consent at any time via email to ____________.
Withdrawal may affect your access to the platform or our ability to provide services.

7. Data Sharing and Transfer

We may share data:

Internally with company departments.
With trusted third-party service providers (e.g., hosting, IT, logistics), under Data Processing Agreements.
With government authorities as mandated by Indian law.

No cross-border data transfers occur unless permitted under DPDP rules and with adequate safeguards.

8. Rights of the Data Principal

As per the DPDP Act, you have the right to:

Access your personal data.
Correct inaccurate or outdated data.
Withdraw consent, subject to contractual/legal limitations.
Grievance redressal, via our designated Data Protection Officer (DPO).

To exercise these rights, contact us at:

Email: ______________________

Grievance Officer: _______________________

9. Data Retention & Security

Personal data is retained only as long as necessary for the stated purposes, or as required under applicable laws.
We implement reasonable technical and organizational measures to ensure data protection:
- Encryption
- Role-based access
- Firewalls and antivirus protections
- Periodic audits

10. Children’s Data

This platform is not intended for use by individuals under the age of 18. No personal data of children is knowingly collected.

11. Updates to This Policy

We may update this policy from time to time to reflect legal, operational, or technological changes. You will be notified of material changes via the portal.

12. Grievance Redressal

In compliance with Section 13 of the DPDP Act, grievances can be addressed by contacting our Grievance Officer:

Name: __________________

Email: ______________________

Phone: _______________________

If unresolved, complaints can be escalated to the Data Protection Board of India.

Terms of Use

1. Eligibility:

Only verified employees, distributors, and partners of Netsurf Communications Private Limited in India are authorized to use the portal.

2. Platform Use:

Users must not share credentials or data with unauthorized individuals.
The platform must not be used for unlawful or unethical practices.

3. Intellectual Property:

All content, trademarks, and data belong to Netsurf Communications Private Limited .
Unauthorized copying or redistribution is prohibited.

4. Violation of Terms:

Misuse will lead to access termination and may result in disciplinary/legal action.

Confidentiality Policy

All business, operational, and personal data accessed through the portal must be treated as strictly confidential.

Responsibilities:

Users must not share or leak reports, pricing, or personal data externally.
Breaches must be immediately reported to the DPO.

Data Protection & Handling Policy

Aligned with DPDP Act:

Collection Limitation: Only data necessary for business purposes is collected.
Purpose Limitation: Data is used strictly for defined internal business functions.
Access Control: Role-based access to ensure only authorized users can view specific data.
Security Measures: Platform uses secure servers, MFA, audit logs, and encryption.
Training: Employees and distributors are sensitized about data protection compliance.

Distributor Code of Conduct

All distributors using the platform must:

Comply with Indian laws, including DPDP and Drugs & Cosmetics Act.
Maintain transparency in inventory and sales reporting.
Avoid black marketing, product misrepresentation, or IP infringement.
Use the portal only for authorized, company-approved operations.