Privacy Policy

This Privacy Policy describes how Hatke Design Concepts Private Limited ("Company", "we", "us"), operating the Bharatayan platform ("Platform"), handles your personal data. It applies to all users of the Platform — registered, unregistered, and former — as well as commercial counterparties and anyone who contacts us through our support or grievance channels.

This Policy forms part of a two-document suite alongside our Terms and Conditions. On matters of personal data, this Policy prevails. By using the Platform, you accept this Policy. If you disagree, please discontinue use and request deletion of your data.

The Data Fiduciary responsible for your personal data is:

Hatke Design Concepts Private Limited

CIN: U46493MH2023PTC404130 | ROC: Mumbai

Registered Office: Chembur, Mumbai

Platform: www.bharatayan.com

Email: contact@bharatayan.com

"Bharatayan" is a brand name, not a separate legal entity. All obligations vest in Hatke Design Concepts Private Limited. The Platform is a private commercial platform with no affiliation to the Government of India or any public authority. Any alignment with initiatives such as "Vocal for Local" reflects our independent mission only.

The following terms carry specific meanings in this Policy:

• Bharatayan Score — the algorithmically generated indicator assigned to each User reflecting the degree to which their consumption patterns align with Indian brands, Indian companies, and products manufactured in India.
• Brand Classification — the Company's assessment of a brand or product against the three-tier framework of Indian Brand, Indian Company, and Made in India.
• Data Fiduciary — the entity that determines the purpose and means of processing personal data. The Company is the Data Fiduciary under this Policy.
• Data Principal — the individual to whom personal data relates.
• Data Processor — a third party that processes personal data on behalf of and under the instructions of the Data Fiduciary.
• Grievance Officer — the individual designated to receive and resolve grievances. Currently: Anil Thanwardas Jadwani, contact@bharatayan.com.
• Personal Data — any data about an individual who is identifiable directly or indirectly from that data.
• Platform — the Bharatayan web application and any future mobile application operated by the Company.
• Sensitive Personal Data — personal data warranting heightened protection. Gender data is treated as Sensitive Personal Data under this Policy.
• Working Days — any day other than a Saturday, Sunday, or public holiday declared by the Government of Maharashtra or the Government of India.

We collect only what is necessary for the Platform's operation. Data is collected directly from you and automatically through technical means.

• Registration Data — name, age, gender, and occupation.
• Contact Data — mobile number, email address, and WhatsApp number (where separately provided and consented to).
• Usage Data — Questionnaire responses, Bharatayan Score history, recommendation interaction data, and general interaction data.
• Technical Data — IP address, device and browser information, session and log data, and cookie data, collected from all Platform visitors including unregistered users.
• User-Generated Content — product reviews and ratings submitted by registered Users through the Platform's review feature. Reviews are publicly visible on the Platform.

We do not collect financial data, precise location, biometric data, health data, or government-issued identification numbers.

• Consent — for marketing communications, demographic personalisation, questionnaire-based scoring, and user-generated content.
• Performance of Contract — for account management, authentication, Score generation, and administrative communications.
• Legal Obligation — where required by applicable Indian law.
• Legitimate Interests — for Platform security, fraud prevention, and aggregate analytics only. Not relied on for marketing or commercial processing.

Gender is Sensitive Personal Data processed solely on explicit consent obtained through a separate consent request at registration, independent of general sign-up consent. Declining or withdrawing this consent will not restrict Platform access but may affect Score personalisation. Where we propose to process data for a new incompatible purpose, we will give prior notice and obtain any fresh consent required.

The Bharatayan Score is generated using your Questionnaire responses and registration data (age, gender, occupation). Products and brands are assessed against three criteria — Indian Brand, Indian Company, and Made in India — with points allocated per criterion.

The Score is indicative only. It is not a financial rating, credit assessment, legal certification, or government endorsement. No user is required to achieve any Score to access the Platform. No commercial, legal, or official reliance should be placed on the Score or any Platform recommendation.

Brand classifications are based on publicly available information and are made solely for the Platform's scoring purposes. They carry no legal or commercial weight. Classifications may not reflect subsequent changes in ownership or manufacturing and are not represented as definitive or error-free. Any brand disputing its classification may write to contact@bharatayan.com with subject line [CLASSIFICATION DISPUTE — BHARATAYAN] with supporting documentation. We will acknowledge within 5 Working Days and respond within 30 days.

If you believe your Score reflects inaccurate inputs, you may request clarification or correction at contact@bharatayan.com. Score-sharing on social media is user-initiated and falls outside this Policy. We bear no responsibility for how shared content is used by third parties.

We use three categories of cookies on the Platform:

• Essential — required for Platform operation. Cannot be disabled. No consent required.
• Analytics — collect aggregated usage data to improve the Platform. Placed only with consent.
• Preference — remember your settings. Placed only with consent.

We use [ANALYTICS PROVIDER — TO BE CONFIRMED] for Platform analytics under a Data Processing Agreement. We do not use advertising or targeting cookies. On first access, you will be presented with a cookie consent notice allowing you to set preferences by category. Preferences may be updated at any time through Platform settings or your browser. Essential cookies cannot be disabled.

• Service Delivery — account management, Score generation, recommendations, and publication of user reviews.
• Personalisation — tailoring content and question sets to your profile, on the basis of consent.
• Communications — Marketing Communications where you have provided explicit channel-specific consent; administrative communications on the basis of contract performance.
• Security — maintaining Platform integrity and detecting and preventing unauthorised access.
• Analytics — improving the Platform and calibrating the Bharatayan Score algorithm using aggregated and pseudonymised data.
• Legal Compliance — meeting applicable legal obligations and responding to lawful orders.
• Commercial and Affiliate Purposes — the Platform operates an active affiliate marketing and brand listing model. Certain product recommendations may be commercially promoted or may generate affiliate commissions for the Company when you interact with or purchase through them. All such recommendations are clearly identified as Partnered Recommendations or Affiliate Links at the point of display. The Company's commercial relationship with a brand does not affect the objectivity of the Bharatayan Score, which is generated solely on the basis of your inputs and the Brand Classification framework.

Subject to consent, we communicate via WhatsApp, email, and push notifications. Consent for each channel is independent and separately revocable. No channel is pre-selected at registration.

WhatsApp — Delivered via the WhatsApp Business Platform operated by Meta Platforms Inc., subject to Meta's Privacy Policy at https://www.whatsapp.com/legal/privacy-policy. The Company has entered into Meta's standard data processing terms as a condition of access to the WhatsApp Business Platform.

Email — All marketing emails include an unsubscribe link. Unsubscribing does not affect administrative communications.

You may withdraw marketing consent at any time via account settings, the unsubscribe link in any email, by sending STOP to any WhatsApp message from us, or by writing to us. Opt-outs are processed within 5 Working Days and apply prospectively. Withdrawal does not affect Platform access.

We do not sell your data. We share it only as necessary and only where a lawful basis exists. All third-party processors are bound by Data Processing Agreements.

• Cloud Provider — [CLOUD PROVIDER — TO BE CONFIRMED], hosting data on Indian servers.
• Analytics Providers — receive aggregated, pseudonymised usage data for analytics only.
• Communication Providers — receive contact data solely to deliver consented communications.
• Legal Authorities — data disclosed only in response to lawful orders or legal obligations.
• Brand and Affiliate Partners — the Company shares limited User data — including recommendation interaction data and consumption patterns — with brand partners and affiliate partners for the purpose of measuring referrals, delivering promoted content, and fulfilling commercial arrangements. Such sharing is limited to data necessary for the specific commercial purpose, is governed by Data Processing Agreements or equivalent contractual instruments, and is carried out on the basis of User consent obtained at registration. Users may withdraw consent for commercial data sharing at any time through account settings.

All processors are prohibited from onward transfer of your data without our prior written authorisation. Fully anonymised data is not personal data and may be shared without restriction.

All personal data is primarily stored on Indian servers. Certain third-party providers — including analytics and communication providers — may transiently process data outside India. Where this occurs, we ensure transfers are to permitted jurisdictions or are governed by appropriate contractual safeguards.

WhatsApp infrastructure operated by Meta Platforms Inc. may involve processing outside India. By consenting to WhatsApp communications, you acknowledge this. Your data rights apply regardless of processing location.

Registered Users may submit product reviews and ratings through the Platform's review feature. Reviews are publicly visible on the Platform and may be accessed by other Users and visitors. Your profile remains private and is not publicly attributed to your reviews unless you expressly consent to such attribution.

You are solely responsible for the accuracy, legality, and appropriateness of content you submit. You must not submit content that is false, defamatory, infringes intellectual property rights, contains third-party personal data without consent, is obscene or unlawful, or is submitted in exchange for undisclosed commercial consideration.

The Company reserves the right — but does not assume the obligation — to review, moderate, decline to publish, or remove any content that violates these standards or is the subject of a valid complaint or legal notice. Exercising moderation rights does not constitute editorial responsibility or a waiver of our intermediary status under applicable law.

We retain personal data only as long as necessary for the purpose of collection or as required by law. On expiry, data is securely deleted or anonymised.

• Registration and Contact Data — deleted within 45 days of account deletion. Consent records retained for 3 years for compliance.
• Usage and Score Data — deleted within 45 days of account deletion. Aggregate anonymised data may be retained indefinitely.
• Technical Data — retained for 6 months then deleted or anonymised.
• Grievance Records — retained for 3 years from resolution.

You may request account deletion at any time through account settings or at contact@bharatayan.com. We will cease all active processing immediately, delete your data within 45 days subject to legal obligations, and confirm in writing. Deletion is irreversible. Data required by law — including tax records and legal hold material — is retained under restricted access until the obligation expires.

We implement appropriate technical and organisational measures including encryption in transit and at rest, OTP-based authentication, need-to-know access controls, regular security monitoring, contractual security obligations on all processors, and periodic review of our practices. No system is completely secure. Protect your credentials and notify us immediately at contact@bharatayan.com if you suspect unauthorised access. In the event of a breach, we will contain it, notify the relevant authority, and inform affected Data Principals as required by law.

You may exercise the following rights by writing to contact@bharatayan.com with subject line [DATA RIGHTS REQUEST — BHARATAYAN]. We acknowledge within 48 Working Hours and respond within 30 days. Identity verification applies. No fee unless requests are excessive.

• Access — to confirm what data we hold, why, and with whom it is shared.
• Correction — to correct inaccurate or incomplete data.
• Erasure — to request permanent deletion through the account deletion mechanism in Section 13. Does not apply to legally retained or anonymised data.
• Withdraw Consent — to withdraw any consent-based processing at any time without reason. Withdrawal is prospective.
• Contest Automated Decisions — to seek clarification on and contest a Score generated on inaccurate inputs.
• Data Portability — to receive your data in a structured, machine-readable format within [X] days of request.
• Nomination — to designate another individual to exercise your rights in the event of death or incapacity.
• Grievance Redressal — to escalate unresolved complaints to the Data Protection Board of India or any competent regulatory authority.

The Bharatayan Platform is strictly available to individuals who are 18 years of age or older. Minors are not permitted to register or use the Platform under any circumstances, including under parental or guardian supervision. By registering on the Platform, you confirm that you are at least 18 years of age.

If the Company becomes aware that a User is below the age of 18, it will immediately suspend the account and permanently delete all associated personal data without notice.

Our designated Grievance Officer is:

Name: Anil Thanwardas Jadwani

Email: contact@bharatayan.com | Subject: [GRIEVANCE — BHARATAYAN]

Grievances may relate to data processing, unfulfilled data rights, Score disputes, Platform content, or any compliance concern. Include your name, registered email, description of the issue, remedy sought, and supporting documents. We acknowledge within 48 Working Hours, respond within 30 days, and for complex matters inform you of an extended timeline not exceeding 60 days. Takedown requests for unlawful content are processed per IT Rules 2021. Unresolved grievances may be escalated to the Data Protection Board of India or any competent authority.

This Policy is governed by Indian law, including the DPDPA and the IT Act. All disputes are subject to the exclusive jurisdiction of the courts of Mumbai, Maharashtra. Users accessing the Platform from outside India do so voluntarily and acknowledge that Indian law governs their data.

We may update this Policy at any time. Material changes — affecting data categories, processing purposes, third-party sharing, or user rights — require at least 30 days' prior notice by email and in-platform notification, and fresh consent where required. Non-material changes require 15 days' notice. Version history is maintained at [VERSION HISTORY URL]. Continued use after the notice period constitutes acceptance.

Hatke Design Concepts Private Limited

contact@bharatayan.com | www.bharatayan.com

Registered Office: Chembur, Mumbai

Data Rights: contact@bharatayan.com | [DATA RIGHTS REQUEST — BHARATAYAN]

Classification Disputes: contact@bharatayan.com | [CLASSIFICATION DISPUTE — BHARATAYAN]

General Queries: contact@bharatayan.com | [PRIVACY QUERY — BHARATAYAN]