PRIVACY POLICY
This Privacy Policy (“Privacy Policy”) explains how Cmunity Innovations Private Limited, operating the brand Saudaking (“Cmunity”, “we”, “us or “our”), collects, uses, stores, discloses and otherwise processes information relating to users of the Saudaking website, mobile application and related digital services (collectively, the “Platform”). Saudaking is a B2B wholesale platform operated by Cmunity for facilitating the sale and supply of Products to eligible business customers.
Cmunity may amend or update this Privacy Policy from time to time to reflect changes in the Platform, Services, applicable law, regulatory requirements, technology or Cmunity’s data practices. The updated Privacy Policy shall be made available on the Platform with the revised “Last Updated” date. Where required under Applicable Law, Cmunity shall provide appropriate notice of material changes. Users are encouraged to periodically review this Privacy Policy to remain informed about how their information is processed. Continued use of the Platform after an updated Privacy Policy becomes effective shall be subject to the revised Policy, to the extent permitted under Applicable Law.
By accessing, browsing, registering on or otherwise using the Platform, or by providing information to Cmunity through the Platform or other authorised channels, you acknowledge that you have read and understood this Privacy Policy and that this constitutes a legally binding contract between you and the Company under Section 8 of the Indian Contract Act, 1872, read along with Section 10A of the Information Technology Act, 2000. Where processing of personal data requires consent under Applicable Law, Cmunity shall obtain such consent in the manner prescribed by Applicable Law.
1. INFORMATION WE COLLECT
1.1.Depending upon the manner in which you access or use the Platform, Cmunity may collect information that you voluntarily provide to us, information generated through your use of the Platform and information received from third parties or other lawful sources. The information collected may include your name, mobile number, email address, business name, business address, billing address, delivery address, contact details, PAN, GSTIN, business registration details, licences, KYC documents, authorised representative details and other information required for business verification and Account creation.
1.2.Where you place an Order or otherwise transact through the Platform, we may collect transaction-related information, including Order details, Products purchased, quantities, prices, invoices, payment status, delivery details, return and refund information, transaction history, communications relating to Orders and other information necessary to process and fulfil the relevant transaction. Payment information may be processed through third-party payment service providers, and Cmunity may not directly store complete card, banking or other sensitive payment credentials where such information is processed and retained by the relevant payment service provider.
1.3.We may also collect information relating to your use of the Platform, including IP address, browser and device information, operating system, device identifiers, login information, access times, pages or Products viewed, search activity, interaction with Platform features, referring websites and other technical or usage information generated through your interaction with the Platform.
1.4.Where you contact Cmunity through customer support, telephone, email, WhatsApp or other communication channels, we may collect and retain information relating to the communication, including your contact details, the nature of your query or complaint, Order details, documents, photographs, recordings or other information voluntarily provided by you for resolving the relevant issue.
2. PURPOSES FOR WHICH WE USE INFORMATION
2.1.Cmunity processes the information collected through the Platform for purposes connected with providing and administering the Platform and Services. This includes creating and managing Accounts, verifying the identity and business details of Users, conducting KYC and other verification processes, processing and fulfilling Orders, arranging delivery, processing payments, issuing invoices, administering returns and refunds, providing customer support and communicating with Users regarding their Orders and Accounts.
2.2.We may also process information for fraud prevention, security, risk management, transaction monitoring, detection of suspicious or unauthorised activity, prevention of misuse of the Platform, enforcement of our Terms and Conditions and protection of Cmunity, its Users, service providers and other stakeholders.
2.3.Information may further be processed for complying with Applicable Law, including tax, accounting, audit, regulatory, legal and governmental requirements, responding to lawful requests from competent authorities, establishing, exercising or defending legal claims, resolving disputes and maintaining appropriate business and transaction records.
2.4.Subject to Applicable Law and your applicable preferences, Cmunity may use your contact information to send promotional communications, offers, discounts, Product information, marketing communications and other commercial messages that may be relevant to your business or use of the Platform.
2.5.Cmunity may use aggregated, anonymised or otherwise non-identifiable information for purposes including analytics, understanding purchasing and usage patterns, improving Products and Services, developing new features, improving Platform performance and conducting internal business analysis. Such information will not be used to identify you except where permitted by Applicable Law.
3. BASIS FOR PROCESSING
3.1.Cmunity shall process personal data in accordance with Applicable Law and only for lawful purposes. Depending upon the nature of the processing, processing may be undertaken on the basis of the User’s consent or another lawful basis recognised under Applicable Law.
3.2.Information Shared at Your Request or with Your Consent - In certain circumstances, you may be provided with an opportunity to request or consent to the sharing of your Personal Data with a third party, including for receiving information, services, offers or other communications from such third party. Where you expressly authorise or request such sharing, we may disclose the relevant information to the third party in accordance with your instructions and Applicable Law. Once your Personal Data has been shared with such third party, its subsequent collection, use, storage and processing may be governed by that third party’s own privacy policy and practices. Cmunity shall not be responsible for the independent privacy practices, policies or systems of a third party where such third party processes your Personal Data independently and not on our behalf. If you subsequently wish to withdraw your consent or stop receiving communications directly from such third party, you may be required to contact the relevant third party in accordance with its applicable policies and procedures.
3.3.Withdrawal of consent shall not affect the lawfulness of processing undertaken before such withdrawal. Further, Cmunity may continue processing information where such processing is otherwise permitted or required under Applicable Law, including where necessary for compliance with legal obligations, completion of transactions already initiated, fraud prevention, dispute resolution or establishment or defence of legal claims.
3.4.Cmunity recognises that information provided by Users in connection with their use of the Platform may include confidential or commercially sensitive information, including business information, contact details, KYC and registration documents, GSTIN, PAN, transaction records, purchase history, pricing information, Order details, credit-related information, business correspondence and other information that is not ordinarily available to the public (“Confidential Information”). Cmunity shall maintain the confidentiality of such information and shall not knowingly disclose or use such information except as necessary for providing, administering, securing or improving the Platform and Services, processing and fulfilling Orders, carrying out the purposes described in this Privacy Policy, complying with Applicable Law or otherwise as expressly permitted under this Privacy Policy.
3.5.Cmunity shall take reasonable measures to ensure that access to Confidential Information is limited to its employees, affiliates, representatives, professional advisers, contractors and service providers who have a legitimate need to access such information for authorised business purposes. Where appropriate and required under Applicable Law, Cmunity shall require such persons to maintain the confidentiality and security of the information accessed by them.
3.6.Confidential Information may be disclosed where such disclosure is required or permitted under Applicable Law, pursuant to a valid order, notice or request from a court, governmental authority, regulator, law enforcement agency or other competent authority, or where Cmunity reasonably considers such disclosure necessary to prevent fraud, investigate unlawful activity, protect its rights or property, protect the safety or security of any person, enforce its Terms and Conditions or establish, exercise or defend legal claims.
3.7.The confidentiality obligations under this Clause shall not apply to information that is publicly available other than as a result of a breach of confidentiality, was lawfully in Cmunity’s possession before being provided by the User, is independently developed by Cmunity without reference to the User’s Confidential Information, or is lawfully received from a third party without an obligation of confidentiality.
3.8.Nothing in this Clause shall restrict Cmunity from processing, storing, using or disclosing Personal Data or Confidential Information in accordance with this Privacy Policy, the Saudaking Terms and Conditions, the User’s instructions, applicable contractual arrangements or Applicable Law. Where the disclosure of information is required by law, Cmunity shall, where legally permissible and reasonably practicable, limit the disclosure to the information required for the relevant purpose.
4. COOKIES AND SIMILAR TECHNOLOGIES
The Platform may use cookies, pixels, SDKs, log files and similar technologies to enable essential Platform functionality, remember preferences, maintain sessions, understand Platform usage, improve performance, detect security issues and analyse traffic and engagement. Certain cookies may be necessary for the Platform to function properly, while others may be used for analytics, personalisation or marketing purposes. Where consent is required under Applicable Law, Cmunity shall obtain such consent through appropriate mechanisms. You may also manage certain cookie preferences through your browser or device settings, although disabling certain cookies may affect the availability or functionality of parts of the Platform.
5. SHARING AND DISCLOSURE OF INFORMATION
5.1.Cmunity may disclose or share personal and business information collected through the Platform with its employees, affiliates, group entities, contractors, agents, professional advisers, consultants and third-party service providers where such disclosure is reasonably necessary for operating, maintaining, securing or improving the Platform, providing the Services, processing and fulfilling Orders or otherwise carrying out the purposes described in this Privacy Policy. Such recipients may include payment gateways and processors, banks and financial institutions, logistics and delivery partners, transporters, warehouses and fulfilment providers, technology and cloud service providers, hosting providers, communication and messaging service providers, customer support providers, analytics and reporting providers, KYC and identity verification agencies, fraud prevention and risk assessment providers, auditors, accountants, legal advisers and other persons engaged by Cmunity for legitimate business or operational purposes. Cmunity shall seek to ensure that information shared with such parties is limited to what is reasonably necessary for the relevant purpose and is handled in accordance with Applicable Law and appropriate contractual or other safeguards, where required.
5.2.Cmunity may disclose personal or business information where such disclosure is required or permitted under Applicable Law or is necessary to comply with a valid legal, judicial, regulatory or governmental requirement. This may include responding to requests, notices, orders or directions issued by courts, tribunals, governmental authorities, regulators, law enforcement agencies, tax authorities or other competent authorities. Cmunity may also disclose information where reasonably necessary to detect, prevent or investigate fraud, unauthorised transactions, unlawful activity, security incidents or misuse of the Platform; protect the rights, property, security or safety of Cmunity, its Users, employees, service providers or other third parties; enforce these Terms and applicable policies; investigate or resolve disputes; or establish, exercise or defend Cmunity’s legal rights or claims.
5.3.Cmunity may disclose or transfer relevant personal and business information in connection with an actual or proposed corporate transaction involving Cmunity or its business, including a merger, acquisition, amalgamation, restructuring, financing, investment, sale or transfer of assets or business, joint venture, corporate reorganisation or similar transaction. Such information may be shared with prospective or existing investors, purchasers, acquiring entities, affiliates, professional advisers, auditors, financial advisers, legal advisers and other persons involved in evaluating, negotiating or completing the relevant transaction, subject to Applicable Law and appropriate confidentiality and data-protection safeguards where required.
5.4.We may engage third-party companies, consultants, contractors and individuals to facilitate, support, operate or improve the Platform and Services or to perform services on our behalf. Such third parties may include payment gateways and processors, banks and financial institutions, logistics and delivery providers, transporters, warehouses and fulfilment partners, cloud and hosting providers, communication and messaging service providers, customer support providers, analytics and reporting providers, KYC and identity verification agencies, fraud prevention and risk assessment providers, technology service providers, auditors, professional advisers and other operational service providers. Such third parties may have access to Personal Data to the extent reasonably necessary to perform the services for which they have been engaged and shall process such information in accordance with Applicable Law and, where applicable, their contractual obligations to Cmunity.
5.5.Legal, Regulatory and Investigative Purposes - Cmunity may disclose Personal Data where required or permitted under Applicable Law or in response to a valid request, order, notice, summons or other legal process issued by a court, tribunal, governmental authority, regulator, law enforcement agency, tax authority or other competent authority. We may also disclose information where we reasonably believe that such disclosure is necessary or appropriate to comply with legal or regulatory obligations, respond to lawful requests from public authorities, investigate or prevent fraud, unauthorised transactions, unlawful activity or misuse of the Platform, protect the rights, property or security of Cmunity, its Users, employees, service providers or other third parties, or establish, exercise or defend legal claims. Cmunity may cooperate with governmental authorities, law enforcement agencies, regulators and other competent authorities in connection with such matters.
5.6.Cmunity may share aggregated, statistical or anonymised information that does not reasonably identify an individual User with third parties, including business partners, analytics providers, advisers and other stakeholders, for purposes such as research, analytics, business planning, market analysis, service improvement and understanding Platform usage. Such information shall not be treated as personal data where it has been irreversibly anonymised in accordance with Applicable Law.
5.7.Cross Border Data Transfer - Cmunity is an entity incorporated and operating in India. In connection with the operation of the Platform and provision of Services, Cmunity may engage third-party technology, cloud, hosting, analytics, communication, payment or other service providers that may process or store Personal Data outside India. Accordingly, your Personal Data may be transferred to, stored in or processed in a jurisdiction other than the jurisdiction from which the information was originally collected.
5.8.Where Personal Data is transferred outside India, Cmunity shall undertake such transfer in accordance with Applicable Law and any restrictions, requirements or directions applicable to cross-border processing from time to time. Where required, Cmunity shall take reasonable steps to ensure that the relevant recipient is subject to appropriate contractual, technical and organisational safeguards designed to protect Personal Data against unauthorised or unlawful processing, accidental loss, destruction, alteration, disclosure or access. By using the Platform, you acknowledge that such transfers may occur where reasonably necessary for providing the Platform and Services or for other lawful purposes described in this Privacy Policy, subject to Applicable Law.
5.9.Any disclosure or sharing of personal information under this Clause shall be undertaken in accordance with Applicable Law. Cmunity shall not disclose personal information beyond what is reasonably necessary for the relevant lawful purpose, except where a broader disclosure is required or permitted by Applicable Law or otherwise authorised by the User.
6. THIRD-PARTY SERVICE PROVIDERS
6.1.The Platform may integrate with, use or provide access to services, applications, platforms, systems and technologies operated by independent third-party service providers for purposes connected with the operation and provision of the Platform and Services. Such third-party service providers may include payment gateways and processors, banks and financial institutions, logistics and delivery providers, transporters, warehouses and fulfilment partners, cloud and hosting providers, communication and messaging platforms, customer support providers, analytics and reporting providers, mapping and location service providers, KYC and identity verification agencies, fraud prevention and risk assessment providers, technology vendors and other operational or professional service providers. Depending upon the nature of the service, such providers may receive or process information relating to Users, Accounts, Orders, payments, delivery, communications or Platform usage for the specific purposes for which their services have been engaged.
6.2.Where a third-party service provider processes personal information on behalf of Cmunity, Cmunity shall take reasonable steps, as required under Applicable Law, to ensure that such processing is undertaken only for authorised and legitimate purposes and that appropriate confidentiality, security and data-protection safeguards are maintained. The information shared with such service providers shall, where reasonably practicable, be limited to the information necessary for the relevant service or purpose. Such service providers may process information in accordance with Cmunity’s instructions, applicable contractual arrangements and Applicable Law.
6.3.Certain third-party services may independently collect and process information when a User accesses or uses their services through or in connection with the Platform. Such processing may be governed by the third party’s own privacy policy, terms of use and other applicable conditions, and may not be within Cmunity’s direct control. For example, payment providers may process payment and transaction information in accordance with their own regulatory and security requirements, while communication, analytics, mapping or other technology providers may process technical or usage information in accordance with their applicable policies. Users are encouraged to review the relevant third party’s privacy policy and terms before using such services.
6.4.Cmunity may add, replace, suspend or discontinue third-party service providers or integrations from time to time for operational, commercial, technical, security, legal or regulatory reasons. The use of a particular third-party provider at any given time shall not create any entitlement in favour of the User to continued use of that provider or service. Where a change materially affects the manner in which personal information is processed and notice or consent is required under Applicable Law, Cmunity shall provide such notice or obtain such consent as may be applicable.
6.5.Cmunity shall not be responsible for the independent acts, omissions, privacy practices, policies, security measures, systems, content or processing activities of third parties where such third parties process information independently and not on behalf of Cmunity. This includes circumstances where a User voluntarily provides information directly to a third-party service provider, accesses an external website or application through the Platform, or uses a third-party service subject to that provider’s own terms and privacy policy. Any concerns relating to such independent processing may need to be addressed directly with the relevant third-party provider.
6.6.The Platform may contain links, references, integrations or access points to websites, applications, platforms or services operated by third parties. If you choose to access such third-party websites or services, you will be directed to or connected with the relevant third party’s platform. The inclusion of any such link, integration or reference does not constitute an endorsement, authorisation, recommendation or representation by Cmunity regarding the third party, its products, services, privacy practices, security measures or policies, nor does it necessarily indicate any affiliation between Cmunity and such third party.
6.7.Cmunity does not control and is not responsible for the privacy practices, content, security, terms or information-handling practices of third-party websites, applications or services. Such third parties may independently collect Personal Data, use cookies or other tracking technologies, store information on your device or request information from you in accordance with their own policies. We encourage you to review the applicable privacy policy, terms of use and other policies of any third-party website, application or service before providing Personal Data or otherwise interacting with it. Any information voluntarily provided by you directly to a third party shall be subject to that third party’s applicable policies and practices and not this Privacy Policy.
7. DATA SECURITY AND DATA RETENTION
7.1.Cmunity shall implement and maintain reasonable technical, organisational and administrative safeguards designed to protect personal information processed through or in connection with the Platform against unauthorised access, collection, use, disclosure, alteration, loss, destruction, misuse or other unlawful processing. The nature and extent of such safeguards may vary depending upon the nature and sensitivity of the information, the purposes for which it is processed, the applicable technology and the risks associated with the relevant processing activity. Cmunity shall periodically review its security practices and may update or modify such measures where reasonably necessary to address changing technological, operational or security risks and Applicable Law.
7.2.Depending upon the nature of the information and the relevant processing activity, Cmunity’s security measures may include appropriate access controls and restrictions, user authentication and authorisation mechanisms, password and Account security measures, encryption or equivalent safeguards where appropriate, secure data storage, system monitoring, logging, network and application security controls, internal access restrictions, backup and recovery procedures, employee and service-provider controls, incident management procedures and other reasonable technical and organisational measures. Access to personal information shall, where reasonably practicable, be restricted to persons and service providers who require such access for legitimate and authorised purposes.
7.3.While Cmunity shall take reasonable measures to protect personal information, no electronic transmission, communication network, website, application, database or storage system can be guaranteed to be completely secure or immune from all risks. Accordingly, Cmunity does not guarantee the absolute security of information transmitted to, stored on or processed through the Platform. Users acknowledge that information transmitted over the internet may be exposed to risks beyond Cmunity’s reasonable control, including network failures, cyber-attacks, malware, phishing, unauthorised interception or other security incidents.
7.4.Users are responsible for maintaining the confidentiality and security of their Account credentials, passwords, OTPs, registered mobile numbers, authentication information and other security credentials used to access the Platform. Users shall not share such information with unauthorised persons and shall promptly notify Cmunity if they become aware of any suspected unauthorised access, Account compromise, fraudulent activity or security incident. Cmunity shall not be responsible for unauthorised access, use or disclosure resulting from the User’s failure to maintain the security of its credentials or from the User’s acts or omissions, except to the extent liability is imposed upon Cmunity under Applicable Law.
7.5.In the event Cmunity becomes aware of a personal data breach or security incident affecting personal information, Cmunity shall take such reasonable measures as may be appropriate to investigate, contain, mitigate and address the incident and shall make such notifications or disclosures as may be required under Applicable Law. Where required, Cmunity may also cooperate with relevant authorities, service providers and affected stakeholders in connection with the investigation and remediation of the incident.
7.6.Cmunity shall retain personal information only for so long as is reasonably necessary to fulfil the purposes for which such information was collected or processed, or for such longer period as may be required or permitted under Applicable Law. The applicable retention period may vary depending upon the nature and sensitivity of the information, the purpose for which it was collected, the duration of the User’s relationship with Cmunity, the status of the User’s Account, the completion of Orders and transactions, applicable tax, accounting and regulatory requirements, fraud prevention and security requirements, dispute resolution requirements and the need to establish, exercise or defend legal rights or claims.
7.7.Certain information may be retained after closure or termination of an Account where necessary to comply with legal, tax, accounting, regulatory or contractual obligations, prevent fraud or misuse, maintain transaction records, resolve disputes, enforce contractual rights or establish, exercise or defend legal claims. Such information shall continue to be handled in accordance with Applicable Law and applicable security measures for the period for which it is retained.
7.8.Where personal information is no longer required for the purpose for which it was collected and there is no continuing legal, regulatory, contractual or legitimate business requirement to retain it, Cmunity shall take reasonable steps to delete, anonymise, aggregate or otherwise dispose of such information in accordance with Applicable Law and its applicable data-retention practices.
7.9.Where information has been irreversibly anonymised such that it can no longer reasonably be used to identify an individual, Cmunity may retain and use such anonymised information for legitimate purposes, including analytics, research, business planning, service improvement, statistical analysis and understanding Platform usage, subject to Applicable Law.
8. GOVERNING LAW
These Terms shall be governed by and construed in accordance with the laws of India. Subject to any mandatory statutory remedy or jurisdiction available to the User under Applicable Law, the courts at Gurugram, Haryana shall have exclusive jurisdiction over disputes arising out of or relating to these Terms, the Platform or transactions conducted through the Platform.
9. GRIEVANCE REDRESSAL
9.1.Subject to Applicable Law, Users may have certain rights in relation to their personal data, including the right to obtain information regarding the processing of their personal data, request correction, completion or updating of inaccurate or incomplete information, request erasure or deletion where legally permissible, withdraw consent where processing is based on consent, and exercise such other rights as may be available under Applicable Law.
9.2.Any request for exercising such rights or any question, concern or complaint regarding the collection, use, storage, disclosure or other processing of personal data may be submitted to Cmunity through the contact details provided below. Cmunity may take reasonable steps to verify the identity and authority of the person making the request before processing it and may request additional information where reasonably necessary to authenticate the request, protect personal data or prevent unauthorised access.
9.3.Cmunity shall endeavour to address valid requests and grievances within the timelines prescribed under Applicable Law and may refuse, restrict or defer a request where permitted or required by Applicable Law, including where compliance with the request would adversely affect the rights of another person, conflict with a legal obligation, compromise security or fraud-prevention measures, or require Cmunity to retain the relevant information. Where consent is withdrawn, such withdrawal shall not affect the lawfulness of processing undertaken before the withdrawal and Cmunity may continue to process the relevant information where otherwise permitted or required under Applicable Law.
9.4.Similarly, deletion or erasure of personal data may affect the User’s ability to access certain features or Services where such information is necessary for maintaining an Account, processing or completing an Order, providing Services, resolving disputes, preventing fraud or complying with Applicable Law.
9.5.Requests and grievances may be addressed to:
9.6.Grievance Officer / Data Protection Contact: Ravinder;
9.7.Email: Ravinder@saudaking.com;
9.8.Address: 12th Floor, Imperia Mindspace, Golf Course Ext Rd, Sector 62, Gurgaon, Haryana, 122001
9.9.Contact Number: 8929753927.