Privacy Policy

1. Introduction

Sarwagyna Pvt Ltd (“Sarwagyna”, “we”, “our”, or “us”) is a company incorporated in India under the Companies Act, 2013. We operate across AI & IT services, global trade (imports and exports), and strategic holdings. We also develop and offer SaaS products including SarwHub, SarwCal, and SarwBill.

This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you visit our websites, use our products, or engage with us in any capacity. It also describes your rights under applicable law, including India’s Digital Personal Data Protection Act, 2023 (DPDP Act) and, where applicable, the General Data Protection Regulation (GDPR).

By using our website or services, you consent to the practices described in this Privacy Policy. If you do not agree, please discontinue use of our services.

2. Information We Collect

2.1 Information You Provide Directly

• Contact and inquiry forms: name, email address, phone number, company name, designation, and message content
• Account registration: username, password (hashed), business details, and billing information
• Investor relations forms: full name, organization, investor type, investment range, and NDA acceptance
• Career applications: resume, cover letter, portfolio links, work history, and references
• Trade inquiries: product descriptions, quantities, origin and destination countries, shipping timelines
• Payment processing: billing address, GST number, and payment method details (handled by PCI-compliant processors; we do not store card data)

2.2 Information Collected Automatically

• Log data: IP address, browser type, device type, operating system, pages visited, and timestamps
• Cookies and tracking technologies: session cookies, preference cookies, analytics cookies, and marketing pixels
• Usage data: features used within SarwHub, SarwCal, and SarwBill; event and booking activity; invoice and billing patterns
• Location data: approximate geolocation based on IP address

2.3 Information from Third Parties

• Google, LinkedIn, or other OAuth providers if you use social sign-in
• Payment gateways (Razorpay, Stripe) for transaction verification
• Analytics platforms (Google Analytics 4, Mixpanel) for aggregated usage insights

3. How We Use Your Information

We process your personal data for the following purposes and on the following legal bases:

• Service Delivery: To provide, maintain, and improve our products and services (Legal basis: Contract performance)
• Lead Management: To respond to business inquiries and follow up on proposals (Legal basis: Legitimate interest)
• Investor Relations: To respond to investor inquiries, share information under NDA, and maintain IR records (Legal basis: Legitimate interest)
• Product Communications: To send product updates, feature announcements, and service notifications (Legal basis: Contract / Legitimate interest)
• Marketing: To send promotional emails and relevant content, where you have opted in (Legal basis: Consent)
• Security & Compliance: To detect, prevent, and investigate fraud, abuse, or legal violations (Legal basis: Legal obligation / Legitimate interest)
• Analytics & Improvement: To analyze user behavior and improve our platforms, UX, and business performance (Legal basis: Legitimate interest)
• Legal Requirements: To comply with Indian law, court orders, or regulatory requirements (Legal basis: Legal obligation)

4. Cookies and Tracking Technologies

We use cookies and similar technologies on our websites and products. You can manage cookie preferences via our cookie consent banner on your first visit.

Types of cookies we use:

• Strictly Necessary Cookies: Required for the website to function. Cannot be disabled.
• Performance Cookies: Collect anonymized usage data to help us improve our website (e.g., Google Analytics).
• Functional Cookies: Remember your preferences such as language settings or login state.
• Marketing / Advertising Cookies: Used to deliver relevant content and measure campaign effectiveness. Applied only with your consent.

You may withdraw cookie consent at any time by adjusting your browser settings or using our Cookie Preference Centre. Note that disabling certain cookies may affect functionality.

5. Data Sharing and Disclosure

We do not sell your personal data. We may share your information in the following limited circumstances:

• Service Providers: We engage trusted third-party vendors (cloud hosting, email delivery, payment processing, CRM, analytics) under Data Processing Agreements that require them to protect your data.
• Business Partners: Where you have engaged with us for trade or technology partnerships, relevant personnel may access inquiry data necessary to service your request.
• Legal Compliance: We may disclose data where required by Indian law, court order, or regulatory authority.
• Business Transfers: In the event of a merger, acquisition, or asset sale, your data may be transferred. We will notify you in advance and ensure equivalent privacy protections apply.
• With Your Consent: We may share data for purposes not listed here with your explicit consent.

6. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this Policy or as required by law.

• Contact and inquiry data: 3 years from last interaction
• Account data: Duration of account + 1 year post-closure
• Transaction and invoicing records: 7 years (as required under Indian tax law)
• Marketing preferences and consent logs: Until consent is withdrawn + 1 year
• Server logs: 90 days

Upon expiry of retention periods, data is securely deleted or anonymized.

7. Your Rights

Subject to applicable law, you have the following rights regarding your personal data:

• Right to Access: Request a copy of the personal data we hold about you
• Right to Correction: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data, subject to legal retention obligations
• Right to Restrict Processing: Request that we limit how we process your data in certain circumstances
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests or for direct marketing
• Right to Withdraw Consent: Where processing is based on consent, withdraw it at any time without affecting prior lawful processing

To exercise any of these rights, contact us at: privacy@sarwagyna.com. We will respond within 30 days. We may need to verify your identity before processing your request.

8. International Data Transfers

Sarwagyna is incorporated and headquartered in India. Your data may be processed or stored on servers located within India and, in certain cases, in other countries where our service providers operate (including the United States and the European Union).

When transferring data internationally, we implement appropriate safeguards, including Standard Contractual Clauses or equivalent mechanisms as required by applicable law.

9. Children’s Privacy

Our website and services are not directed to individuals under the age of 18. We do not knowingly collect personal data from minors. If you become aware that a minor has provided us with personal data, please contact us immediately at privacy@sarwagyna.com and we will take steps to delete it.

10. Security

We implement industry-standard technical and organizational security measures to protect your personal data, including:

• TLS/SSL encryption for all data in transit
• AES-256 encryption for sensitive data at rest
• Role-based access controls and least-privilege principles
• Regular vulnerability assessments and penetration testing
• reCAPTCHA and rate limiting on all public-facing forms
• SOC 2 Type II compliance roadmap in progress

No method of electronic transmission or storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last Updated” date and, for material changes, notify you by email or prominent notice on our website. Your continued use of our services after changes become effective constitutes acceptance of the updated Policy.

12. Contact Us

For privacy-related inquiries, data subject requests, or to reach our Data Protection Officer:

• Email: privacy@sarwagyna.com
• General: hello@sarwagyna.com
• Address: Sarwagyna Pvt Ltd, Registered Office, India
• Response time: Within 30 days for data subject requests; within 5 business days for general queries