1. Identity of the Data Fiduciary

Panchtatvam Global Solutions Private Limited ("Company", "we", "us", or "our") is the Data Fiduciary as defined under the Digital Personal Data Protection Act, 2023 ("DPDP Act") and is responsible for the personal data collected through this website and our services.

2. Scope of This Policy

This Privacy Policy applies to all personal data collected through:

• Our website at www.panchtatvam.co.in
• Our mobile applications (if any)
• Our trade enquiry, RFQ, and financial application forms
• Email, telephone, and WhatsApp communications with our team
• Registration as a buyer, supplier, or partner

3. Personal Data We Collect

3.1 Information You Provide Directly

• Identity data: Full name, designation, company name
• Contact data: Email address, phone number, WhatsApp number, postal address
• KYC data: PAN number, Aadhaar number (for individuals), Certificate of Incorporation number (for companies), GST number
• Financial data: Bank account details provided for payment processing, trade finance requirements
• Trade data: Product requirements, quantities, destination countries, Incoterms preferences
• Account credentials: Email address and password (stored in encrypted form)

3.2 Information Collected Automatically

• IP address and approximate geographic location
• Browser type, operating system, and device information
• Pages visited, time spent, and navigation patterns
• Referring URLs and search terms
• Cookie identifiers (see our Cookie Policy)

4. Purposes of Processing

We process your personal data for the following purposes:

• Service delivery: Processing trade enquiries, RFQs, financial applications, and orders
• Account management: Creating and maintaining your user account
• Communication: Responding to enquiries, sending quotations, order updates, and notifications via email and WhatsApp
• KYC & compliance: Verifying identity as required under applicable laws including PMLA, FEMA, and RBI guidelines
• Legal obligations: Maintaining records required by tax authorities, regulators, and law enforcement
• Security: Detecting and preventing fraud, unauthorised access, and other security threats
• Analytics: Understanding how our website is used to improve our services
• Marketing: Sending relevant trade updates and service information (with your consent, which you may withdraw at any time)

5. Legal Basis for Processing

We process personal data on the following legal bases under the DPDP Act, 2023:

• Consent: Where you have given explicit consent (e.g., marketing communications)
• Contractual necessity: Where processing is necessary to perform a contract with you or take pre-contractual steps
• Legal obligation: Where processing is required to comply with applicable law
• Legitimate interests: Where processing is necessary for our legitimate business interests, provided these are not overridden by your rights

6. Data Sharing and Disclosure

We do not sell, rent, or trade your personal data. We may share your data with:

• Service providers: Email delivery services, cloud hosting providers, payment processors, and logistics partners who process data on our behalf under data processing agreements
• Banking and financial partners: Where required to process trade finance, letters of credit, or payment transactions
• Regulatory authorities: Government agencies, tax authorities, RBI, SEBI, DGFT, and law enforcement where required by law
• Professional advisors: Lawyers, auditors, and consultants bound by confidentiality obligations
• Business transfers: In the event of a merger, acquisition, or sale of assets, subject to appropriate confidentiality protections

7. International Data Transfers

As a global trading company, we may transfer personal data to countries outside India in connection with trade transactions. Such transfers are made in compliance with applicable data protection laws and with appropriate safeguards in place, including contractual protections with receiving parties.

8. Data Retention

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, including:

• Account data: For the duration of your account plus 3 years after closure
• Transaction records: 8 years (as required under the Income Tax Act and GST laws)
• KYC records: 5 years after the end of the business relationship (as required under PMLA)
• Communication records: 3 years
• Legal claims: For the duration of any legal proceedings plus applicable limitation periods

9. Your Rights

Under the DPDP Act, 2023, you have the following rights:

• Right to access: Obtain a summary of 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 grievance redressal: Lodge a complaint with our Grievance Officer
• Right to nominate: Nominate another person to exercise rights on your behalf in the event of death or incapacity
• Right to withdraw consent: Withdraw consent for marketing communications at any time

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

10. Data Security

We implement appropriate technical and organisational measures to protect your personal data, including:

• Encryption of data in transit (TLS/SSL) and at rest
• Access controls limiting data access to authorised personnel
• Regular security assessments and vulnerability testing
• Employee training on data protection obligations
• Incident response procedures for data breaches

In the event of a personal data breach that is likely to result in harm to you, we will notify you and the Data Protection Board of India as required by law.

11. Cookies

We use cookies and similar tracking technologies on our website. Please refer to our Cookie Policy for detailed information.

12. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected data from a minor, please contact us immediately at [email protected].

13. Grievance Officer

If you are not satisfied with our response, you may approach the Data Protection Board of India once it is constituted under the DPDP Act, 2023.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified via email or a prominent notice on our website. The date of the last update is shown at the top of this document. Continued use of our services after changes constitutes acceptance of the updated policy.

15. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy, please contact: