Effective Date: The effective date shall be deemed to be the date the app is downloaded and signed up for.
Last Updated: 18th November, 2025

Vartul (“App”, “Platform”, “we”, “us”, “our”) is operated by Circular Suite Solutions Private Limited (referred to as Vartul- brand name of the software/app). This Privacy Policy explains how we collect, use, store, protect, and share your information when you use the Vartul application and related services.

We are committed to complying with:

• Indian IT Act 2000 & SPDI Rules 2011

• Digital Personal Data Protection Act (DPDP), 2023

• Digital Personal Data Protection Act (DPDP), 2023

• Google Play User Data Policy

• GDPR (EU)

• CCPA (California)

• Other globally recognized privacy frameworks

Using the App indicates your consent to the practices described below.

1. INFORMATION WE COLLECT

We may collect the following:

1.1 Personal Information (User-Provided)

• Name, business name

• Phone number

• Email address

• Billing and transaction details

• Business KYC documents (optional, where applicable)

1.2 Automatically Collected Data

• Device information (model, OS, IP address, device identifiers)

• App usage data and log data

• Location information (only if you grant permission and only used for delivery, pick-up or logistics features)

1.3 Business & Operational Data

• Inventory data

• Inwards and dispatch records

• Item details

• Billing and invoicing details

• Any documents uploaded (invoices, POs, product photos, delivery challans, purchase orders, e-way bill etc.)

• Vendor and customer details entered by you in the app

• All other business data you enter in the app.

1.4 Sensitive Personal Data

We do not intentionally collect SPDI unless required for onboarding (e.g., GST details, business KYC). If collected, consent is explicitly obtained.

2. HOW WE USE YOUR INFORMATION

Your data is used strictly for legitimate business purposes, including:

• App setup, functionality, and feature delivery

• Inventory and operations management

• Transaction processing and billing

• Analytics to improve performance

• Customer support and troubleshooting

• Legal and compliance purposes

• Fraud prevention and security
  
  

3. LEGAL BASIS FOR PROCESSING (GDPR & GLOBAL COMPLIANCE)

Depending on jurisdiction, data is processed based on:

• Consent (EU GDPR Art. 6(1)(a), DPDPA)

• Contractual necessity (to provide the App)

• Performance of a contract (e.g., providing app services)

• Legitimate interests (improving app functionality and security)

• Legal obligation (tax, audit, anti-fraud laws)
  
  

4. CONSENT & USER RIGHTS (GLOBAL)

You have rights consistent with global privacy regulations, including:

Right to access your data

Right to correct inaccurate data

Right to delete / erase your data (“Right to be Forgotten”)

Right to withdraw consent at any time

Right to portability (GDPR)

Right to restrict processing (GDPR)

Right to opt-out of sale/sharing of data (CCPA/CPRA)

Right to lodge a complaint with local authorities

(e.g., EDPB in EU, DPA in India, ICO in UK)

To exercise these rights, email team.vartul@vartul.io

5. DATA SHARING & DISCLOSURE

We do NOT sell your personal data.

We may share information only with:

• Service providers (hosting, analytics, payment gateways)

• Regulatory authorities (when required by law)

• Logistics or operational partners (ONLY when necessary for app functionality)
  
  

All third parties are bound by confidentiality and data-protection obligations.

6. DATA RETENTION

Data is retained only for:

• The duration of your account

• Legal and tax compliance needs

• Business record-keeping as mandated by local laws
  
  

Once retention periods expire:

• Personal data is securely deleted or anonymised.

• You may also request deletion at any time (unless prohibited by law).
  
  

7. DATA SECURITY

We use industry-standard security measures:

• Encryption (in transit & at rest)

• Restricted access control

• Secure servers and firewalls

• Regular audits and vulnerability assessments
  
  

No system is 100% secure, but we take all reasonable steps to protect your data.

8. YOUR RIGHTS

Depending on your jurisdiction, you may have rights to:

• Access your data

• Correct or update data

• Delete or deactivate your account

• Withdraw consent

• Request data portability

• Object to processing
  
  

Email team.vartul@vartul.io for any rights-based request.

9. CHILDREN’S PRIVACY

The app is not intended for individuals below 18 years.
We do not knowingly collect children’s data.

10. INTERNATIONAL DATA TRANSFERS

Your data may be stored or processed outside India.
When transferred, we ensure compliance with:

• Standard Contractual Clauses (SCCs)

• DPDP Act requirements

• Adequate safeguard rules
  
  

11. COOKIES & TRACKERS

Used only on the web interface for:

• Login authentication

• Fraud prevention

• Performance optimisation
  
  

You can disable cookies through browser settings.

12. CHANGES TO THIS POLICY

We may update this Policy occasionally.
Continued use of the App indicates acceptance of the revised terms.

13. CONTACT US

Data Protection Team
Email:team.vartul@vartul.io
Company name: Circular Suite Solutions Private Limited (referred to as Vartul- brand name of the software/app).
Address: 141/5 New Aashirwad Industrial Estate, Ram Mandir Road, Goregaon West Mumbai 400104