Privacy Policy

SmartGreen Aquaculture · Privacy Policy

SMARTGREEN AQUACULTURE

PRIVACY POLICY

Effective date: 05 January 2026 · Version 1.0 · Previous update: not applicable (first version)

This Privacy Policy explains how we handle your personal data. It is aligned with India's Digital Personal Data Protection Act, 2023 (the "DPDP Act") and the Digital Personal Data Protection Rules, 2025, and, during the current transition period, with the applicable provisions of the Information Technology Act, 2000 and the rules made under it (including the SPDI Rules, 2011). Certain provisions of the DPDP Act and DPDP Rules are being brought into force in a phased manner; we will update our practices as they commence.

1. Who we are (Data Fiduciary)

1.1 SmartGreen Aquaculture Private Limited (brands *SmartGreen Aquaculture* and *RAS=FRESH*), registered office at 10 & 9/H.No 27-64/7/25/9, Aditya Nagar, Road No. 4, Krishna Nagar Colony, Neredmet Village, Malkajgiri, Hyderabad, Telangana 500056, is the Data Fiduciary for personal data processed through www.smartgreenaquaculture.com.

1.2 Privacy contact: Mr. Ajay Kumar, Admin Head — ajay@smartgreenaquaculture.com (you may also write to info@smartgreenaquaculture.com).

2. Scope

2.1 This Policy applies to personal data of customers and website visitors (each a "Data Principal") that we collect through the Website, ordering, delivery, payments and customer support. It does not cover third-party websites we link to.

3. Categories of personal data we collect

3.1 Identity and contact: name, mobile number, email, delivery and billing addresses. Account: login credentials (passwords stored securely hashed), preferences, saved addresses, order history. Transaction/order: products ordered, quantity, value, delivery instructions, payment status, invoice/GST details, refund and cancellation details. B2B: business name, contact person, GSTIN, billing and purchase-order details. Customer support: complaints, emails/messages, call records (where calls are recorded with notice), photos/videos you submit for complaints, product and batch details.

4. Data you provide directly

4.1 Data you give us when creating an account, ordering, paying, contacting support or submitting content.

5. Data collected automatically

5.1 When you use the Website we may collect: IP address, browser and device type, operating system, pages visited, session identifiers, referring website, cookie identifiers, approximate location inferred from IP, and visit date/time and duration. We name only the tools actually in use (clause 10).

6. Data from partners

6.1 We may receive limited data from our payment, logistics and technology providers (for example, payment status from Razorpay or delivery status from logistics partners) to fulfil and support your orders.

7. Location data

7.1 We use your delivery address and PIN code to check serviceability and deliver. We do not collect precise live GPS location unless you enable a clearly described delivery feature and grant permission.

8. Payment information

8.1 Payments are processed by our authorised gateway, Razorpay, using a hosted/tokenised flow. We do not store your full card number, CVV, UPI PIN or net-banking credentials. We retain payment status and invoice information needed for your order, tax and refunds. (This statement is being verified against our live payment integration.)

9. Purposes of processing

9.1 We process personal data to: create and manage your account; accept, process, pack and deliver orders; take payment and issue invoices; handle weight reconciliation, cancellations, refunds and complaints; provide customer support; maintain food-safety traceability and, where needed, recall communications; prevent fraud and secure the Website; meet legal, tax and regulatory obligations; and, with your separate consent, send marketing.

10. Cookies and similar technologies

10.1 We use essential cookies (for cart, checkout and security) and, subject to your choices, analytics and advertising cookies. Tools we use include Google Analytics 4, Google Ads, and Meta Pixel/advertising, together with search-engine conversion and remarketing tools. You can manage non-essential cookies through our cookie preference tool [COOKIE PREFERENCE TOOL NAME]. Non-essential advertising/remarketing cookies are not activated before you consent.

11. Consent and other lawful bases

11.1 We process your data on the basis of your consent and for other uses permitted by law (for example, to perform your order, meet legal obligations, and prevent fraud). Where we rely on consent, you may withdraw it at any time (clause 22); withdrawal does not affect processing already carried out.

12. Mandatory vs optional information

12.1 Some information (such as name, contact and delivery address) is necessary to fulfil an order; without it we cannot process or deliver your order. Other information (such as marketing preferences or optional profile details) is optional.

13. Consequences of not providing information

13.1 If you do not provide information we reasonably need to accept, process, deliver, invoice or support an order, we may be unable to complete it.

14. Order fulfilment and support

14.1 We use your data to fulfil orders and provide support, including delivery coordination, complaint handling and refunds.

15. Fraud prevention and security

15.1 We use limited data to detect and prevent fraud and to protect the Website and our customers.

16. Food-safety traceability and recalls

16.1 We maintain batch/lot traceability. If a product is recalled, we may use your order and contact details to notify you and arrange a remedy, as required under food-safety law.

17. Marketing communications

17.1 We send transactional messages (orders, payments, delivery, food safety, support) as part of our service. Promotional email, SMS or WhatsApp is sent only if you give a separate, unticked opt-in. Refusing marketing does not prevent you from ordering.

18. Withdrawing marketing consent

18.1 You can opt out of marketing at any time using the unsubscribe/STOP option in any message, your account preferences, or by contacting us. We keep a suppression record so we do not contact you again after opt-out.

19. Who we share data with

19.1 We share personal data, limited to what is necessary, with: our payment gateway (Razorpay); delivery and logistics partners; hosting/cloud and CRM providers (Hamara CRM [CONFIRM HOSTING PROVIDER / DATA LOCATION]); communication providers (Google for email; Jio for SMS/WhatsApp); analytics and advertising providers (Google, Meta); our professional advisers; and government or regulatory authorities where required by law (for example, tax or food-safety authorities). We do not sell your personal data.

20. Processors and safeguards

20.1 Our service providers act as our processors under contractual arrangements requiring them to use your data only for the purposes we specify and to protect it appropriately.

21. Cross-border transfers

21.1 We do not currently transfer your personal data to processors located outside India. If this changes, we will do so only in accordance with applicable Indian law and update this Policy.

22. Data retention

22.1 We keep personal data only as long as needed for the purpose collected or as required by law:

  • Account data: while your account is active and for a limited period afterwards where needed for legal claims, fraud prevention or records.

  • Order, invoice and tax records: for the periods required under GST, tax, accounting and food-traceability law (up to eight financial years where reasonably required).

  • Delivery and complaint records: approximately three years after closure, or longer where a claim, recall, regulatory matter or dispute exists.

  • Food-safety and traceability records: per applicable FSSAI requirements, product shelf life and our quality system.

  • Marketing records: until you withdraw consent or they are no longer needed, with a suppression record retained as needed.

  • CCTV: 30–90 days unless required for an incident, investigation or legal obligation.

  • Technical logs: a limited security/troubleshooting period.

23. Security

23.1 We use reasonable security safeguards appropriate to the data, which may include HTTPS/TLS, access controls and least-privilege access, secure password hashing, patching, firewalls and endpoint protection, restricted database access, secure backups, vendor due diligence, staff training and an incident-response process. No system can be guaranteed completely secure, and we do not represent that ours is. We do not claim any certification unless separately and accurately stated.

24. Personal-data breach

24.1 If a personal-data breach occurs, we will respond in line with applicable law, including giving any notice to affected Data Principals and the Data Protection Board of India that the law requires.

25. Your rights as a Data Principal

25.1 Subject to applicable law and its commencement, you may: access information about the personal data we process about you; correct or update it; request erasure where legally available; withdraw consent; opt out of marketing; raise a grievance; and exercise nomination rights to nominate another individual to exercise your rights in the event of death or incapacity.

26. How to exercise rights and identity verification

26.1 Contact ajay@smartgreenaquaculture.com or info@smartgreenaquaculture.com. We may reasonably verify your identity before acting. We will respond within the timelines required by law. We may retain data we are required to keep for tax, accounting, fraud-prevention, food-traceability, recall, legal-claim or regulatory reasons.

27. Your duties

27.1 Please provide accurate information and do not impersonate anyone or submit another person's data without authority.

28. Children's data

28.1 The Website is intended for persons aged 18 and above and is not directed at children. We do not intentionally collect personal data from persons under 18 for independent purchases. If we learn that a child has created an account or provided data without appropriate authorisation, we may restrict or delete it, subject to legal and retention requirements.

29. Automated decision-making and profiling

29.1 We do not use automated decisions that produce legal or similarly significant effects on you. Any personalised advertising or remarketing is used only where the relevant tools are active and disclosed, with appropriate consent and opt-out controls.

30. Third-party websites

30.1 Links to third-party websites are provided for convenience. We are not responsible for their content or privacy practices.

31. User-generated content

31.1 If you submit reviews or photos, they may be visible to others. Please do not include sensitive personal information you do not wish to share.

32. Changes to this Policy

32.1 We may update this Policy and will post the revised version with a new effective date.

33. Contact and complaints

33.1 For any privacy question or grievance, contact Mr. Ajay Kumar, Admin Head — ajay@smartgreenaquaculture.com / info@smartgreenaquaculture.com. If you are not satisfied, you may, where the law so provides, complain to the Data Protection Board of India or another competent authority.

SmartGreen Aquaculture Private Limited · CIN U15120TG2019PTC134882 · FSSAI 13622999000032 · www.smartgreenaquaculture.com