Effective Date:

 

Dumbphones India (“Company”, “we”, “us”, “our”) operates the e-commerce platform for the sale of mobile phones and accessories through the website https://dumbphones.co.in/ (“Website”).

 

We are deeply committed to protecting your privacy and safeguarding your personal information with the utmost diligence and in strict compliance with all applicable Indian laws. This Privacy Policy comprehensively outlines our practices concerning the collection, use, disclosure, retention, and protection of your personal information. We believe in transparency and empowering our users with control over their data.

 

By accessing or using the Website, creating an account, placing an order, or otherwise providing your personal information to us, you signify your explicit agreement to the terms and conditions stipulated in this Privacy Policy. We urge you to read this document carefully to understand our data handling practices.

 

1.  SCOPE AND APPLICABILITY

• This Privacy Policy applies to all personal information collected by Dumbphones India from:
• Visitors and users of the Website;
• Customers who register an account or place an Order;
• Individuals who contact customer support or interact with the Company through any communication channel.
• This Policy is governed by and complies with:
• The Information Technology Act, 2000 (“IT Act”) and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”);
• The Consumer Protection Act, 2019 and the Consumer Protection (E-Commerce) Rules, 2020;
• Any other applicable data protection laws in India as may be enacted or amended from time to time.

 

 

1.3. Commitment to Data Ethics:

Beyond mere compliance, Dumbphones India is committed to upholding the highest ethical standards in data handling. This includes fostering a culture of privacy awareness among our employees and continuously evaluating our practices against global best standards, while remaining rooted in Indian legal principles. We believe that respecting user privacy is fundamental to building trust and ensuring a sustainable e-commerce ecosystem.

 

 

 

2.  INFORMATION WE COLLECT

Dumbphones India collects the following categories of personal information:

 

• Information You Provide to Us
  • Account Information: Full name, email address, phone number, date of birth, and login credentials when you create an account.
  • Order and Transaction Information: Billing address, delivery address, order history, and payment method details (partial card/UPI details only; full card details are NOT stored by us).
  • Communication Data: Queries, complaints, or feedback submitted via email, chat, or
  • KYC/Verification Data: Government-issued ID details where required for verification under Applicable Law.

 

• Information Collected Automatically
  • Device and Technical Data: IP address, browser type, operating system, device identifier, and referring URL.
  • Usage Data: Pages visited, time spent, click patterns, search queries on the Website, and purchase behavior.

• Cookies and Tracking Technologies: Session cookies, persistent cookies, pixel tags, and web beacons as described in Clause 8 below.

 

• Information from Third Parties
  • Payment Gateways: Transaction confirmation data (not card credentials).
  • Logistics Partners: Delivery status, delivery address confirmation, and delivery attempt
  • Social Media Platforms: If you access the Website via a social media login (e.g., Google, Facebook), basic profile information as permitted by your social media settings.

 

 

2.4.Data Minimization Principle:

We strictly adhere to the principle of data minimization. This means we collect only that personal information which is directly relevant, adequate, and absolutely necessary for the specific purposes outlined in this Privacy Policy. We avoid collecting superfluous data and regularly review our data collection practices to ensure they remain aligned with this principle.

 

 

 

3.  PURPOSE OF COLLECTION AND USE OF INFORMATION

Dumbphones India processes your personal data for the following purposes:

 

Purpose	Legal Basis
Processing and fulfilling Orders	Performance of contract
Managing your account	Performance of contract
Sending Order confirmations and updates	Performance of contract
Processing payments and fraud prevention	Legitimate interest / Legal obligation
Providing customer support and grievance redressal	Legal obligation (CPA, SPDI Rules)
Sending marketing emails, offers, and promotions	Consent (you may opt out anytime)
Improving Website functionality and user experience	Legitimate interest
Complying with legal and regulatory obligations	Legal obligation
Detecting and preventing fraudulent activity	Legitimate interest / Legal obligation
Conducting analytics and market research	Legitimate interest

 

 

• Dumbphones India shall not use your personal data for any purpose other than those listed above without obtaining your prior consent.

 

4.  SENSITIVE PERSONAL DATA OR INFORMATION (SPDI)

• Pursuant to the SPDI Rules, 2011, the following constitutes Sensitive Personal Data:
• Passwords;
• Financial information such as bank account or payment instrument details;
• Physical, physiological, or mental health condition;
• Biometric

• Dumbphones India collects SPDI only to the extent strictly necessary for transaction processing or legal compliance. Such data is encrypted and stored securely. We shall not share SPDI with any third party without your explicit consent, except as required by law or to perform the transaction you have requested.
• Enhanced Security for SPDI: In addition to the general security measures, SPDI is subject to enhanced security protocols, including multi-factor authentication for access, regular encryption key rotations, and stringent access controls that limit access only to authorized personnel on a strictly need-to-know This layered security approach provides an additional safeguard for your most sensitive information.

5.  SHARING AND DISCLOSURE OF INFORMATION

• Dumbphones India does not sell, rent, or trade your personal information to any third party for commercial purposes.
• We may share your information with the following categories of parties:
• Logistics and Delivery Partners: Name, address, and phone number solely for the purpose of Order delivery.
• Payment Processors and Banks: For transaction completion and fraud
• Technology Service Providers: Cloud hosting, website analytics, customer support tools, and similar platforms which are all bound by data processing agreements.
• Legal and Regulatory Authorities: Where disclosure is mandated by Applicable Law, a court order, or a request from a government authority with jurisdiction.
• Successor Entities: In the event of a merger, acquisition, or sale of business assets, personal data may be transferred to the successor entity, subject to the same privacy protections.

• Dumbphones India shall ensure that all third-party service providers who receive personal data are contractually obligated to maintain adequate security standards and use the data only for the specified purpose.
• Due Diligence and Data Processing Agreements: Before engaging any third-party service provider, Dumbphones India conducts thorough due diligence to assess their data security and privacy practices. All third-party service providers who process personal data on our behalf are required to enter into legally binding Data Processing Agreements (DPAs). These DPAs explicitly outline their obligations regarding data protection, confidentiality, security measures, and compliance with Applicable Law, ensuring that your data receives the same level of protection as if we were processing it ourselves.
• No International Data Transfers (Currently): As of the effective date of this policy, Dumbphones India does not intentionally transfer your personal data outside the territorial limits of India. Should there be a future requirement for international data transfers, we will ensure that such transfers comply with all provisions of Applicable Law, including obtaining your explicit consent where necessary, and implementing adequate safeguards as prescribed by law.

6.  SHARING AND DISCLOSURE OF INFORMATION

• Dumbphones India does not sell, rent, or trade your personal information to any third party for commercial purposes.
• We may share your information with the following categories of parties:
• Logistics and Delivery Partners: Name, address, and phone number solely for the purpose of Order delivery.
• Payment Processors and Banks: For transaction completion and fraud
• Technology Service Providers: Cloud hosting, website analytics, customer support tools, and similar platforms which are all bound by data processing agreements.
• Legal and Regulatory Authorities: Where disclosure is mandated by Applicable Law, a court order, or a request from a government authority with jurisdiction.
• Successor Entities: In the event of a merger, acquisition, or sale of business assets, personal data may be transferred to the successor entity, subject to the same privacy protections.

• Dumbphones India shall ensure that all third-party service providers who receive personal data are contractually obligated to maintain adequate security standards and use the data only for the specified purpose.
• Due Diligence and Data Processing Agreements: Before engaging any third-party service provider, Dumbphones India conducts thorough due diligence to assess their data security and privacy practices. All third-party service providers who process personal data on our behalf are required to enter into legally binding Data Processing Agreements (DPAs). These DPAs explicitly outline their obligations regarding data protection, confidentiality, security measures, and compliance with Applicable Law, ensuring that your data receives the same level of protection as if we were processing it ourselves.
• No International Data Transfers (Currently): As of the effective date of this policy, Dumbphones India does not intentionally transfer your personal data outside the territorial limits of India. Should there be a future requirement for international data transfers, we will ensure that such transfers comply with all provisions of Applicable Law, including obtaining your explicit consent where necessary, and implementing adequate safeguards as prescribed by law.

7.  SHARING AND DISCLOSURE OF INFORMATION

• Dumbphones India does not sell, rent, or trade your personal information to any third party for commercial purposes.
• We may share your information with the following categories of parties:
• Logistics and Delivery Partners: Name, address, and phone number solely for the purpose of Order delivery.
• Payment Processors and Banks: For transaction completion and fraud
• Technology Service Providers: Cloud hosting, website analytics, customer support tools, and similar platforms which are all bound by data processing agreements.
• Legal and Regulatory Authorities: Where disclosure is mandated by Applicable Law, a court order, or a request from a government authority with jurisdiction.
• Successor Entities: In the event of a merger, acquisition, or sale of business assets, personal data may be transferred to the successor entity, subject to the same privacy protections.

• Dumbphones India shall ensure that all third-party service providers who receive personal data are contractually obligated to maintain adequate security standards and use the data only for the specified purpose.
• Due Diligence and Data Processing Agreements: Before engaging any third-party service provider, Dumbphones India conducts thorough due diligence to assess their data security and privacy practices. All third-party service providers who process personal data on our behalf are required to enter into legally binding Data Processing Agreements (DPAs). These DPAs explicitly outline their obligations regarding data protection, confidentiality, security measures, and compliance with Applicable Law, ensuring that your data receives the same level of protection as if we were processing it ourselves.

No International Data Transfers (Currently): As of the effective date of this policy, Dumbphones India does not intentionally transfer your personal data outside the territorial limits of India. Should there be a future requirement for international data transfers, we will ensure that such transfers comply with all provisions of Applicable Law, including obtaining your explicit consent where necessary, and implementing adequate safeguards as prescribed by law.

 

8.  SHARING AND DISCLOSURE OF INFORMATION

• Dumbphones India does not sell, rent, or trade your personal information to any third party for commercial purposes.
• We may share your information with the following categories of parties:
• Logistics and Delivery Partners: Name, address, and phone number solely for the purpose of Order delivery.
• Payment Processors and Banks: For transaction completion and fraud
• Technology Service Providers: Cloud hosting, website analytics, customer support tools, and similar platforms which are all bound by data processing agreements.
• Legal and Regulatory Authorities: Where disclosure is mandated by Applicable Law, a court order, or a request from a government authority with jurisdiction.
• Successor Entities: In the event of a merger, acquisition, or sale of business assets, personal data may be transferred to the successor entity, subject to the same privacy protections.

• Dumbphones India shall ensure that all third-party service providers who receive personal data are contractually obligated to maintain adequate security standards and use the data only for the specified purpose.
• Due Diligence and Data Processing Agreements: Before engaging any third-party service provider, Dumbphones India conducts thorough due diligence to assess their data security and privacy practices. All third-party service providers who process personal data on our behalf are required to enter into legally binding Data Processing Agreements (DPAs). These DPAs explicitly outline their obligations regarding data protection, confidentiality, security measures, and compliance with Applicable Law, ensuring that your data receives the same level of protection as if we were processing it ourselves.
• No International Data Transfers (Currently): As of the effective date of this policy, Dumbphones India does not intentionally transfer your personal data outside the territorial limits of India. Should there be a future requirement for international data transfers, we will ensure that such transfers comply with all provisions of Applicable Law, including obtaining your explicit consent where necessary, and implementing adequate safeguards as prescribed by law.

 

9.  DATA RETENTION

• Dumbphones India shall retain your personal data only for as long as is necessary for the purposes set out in this Policy or as required under Applicable Law.
• Indicative retention periods:
• Account data: For the duration of the account, plus 3 years after account
• Transaction/Order data: 7 years, as required for tax and statutory
• Marketing preferences: Until you opt
• Customer support communications: 2 years from

• Upon expiry of the applicable retention period, personal data shall be securely deleted or

 

10. YOUR RIGHTS

As a data principal, you have the following rights with respect to your personal data:

 

• Right to Correction: Request correction of inaccurate or incomplete
• Right to Withdrawal of Consent: Withdraw consent for processing (where consent is the basis), without affecting lawfulness of prior processing.
• Right to Deletion: Request deletion of your personal data, subject to our legal retention
• Right to Grievance Redressal: Lodge a complaint with our Grievance Officer regarding the processing of your personal data.
• Right to Object to Processing: Where we process your personal data based on our legitimate interests (as outlined in Clause 3), you have the right to object to such processing. We will cease processing your data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.
• Right to Review and Update: You have the right to review the personal information you have provided to us and ensure its You can update your account information directly

 

through your user profile on the Website. For any other data that cannot be updated directly, you may contact our Grievance Officer.

• Right to Data Portability: Where technically feasible and not infringing on the rights and freedoms of others, you have the right to receive your personal data in a structured, commonly used, and machine-readable format and transmit that data to another data fiduciary.

 

 

7.1. To exercise any of the above rights, please write to our Grievance Officer at the contact details provided in Clause 13. Your request should clearly specify the right you wish to exercise and provide sufficient information to allow us to verify your identity. We are committed to facilitating the exercise of your rights in a timely and efficient manner, responding within a period of thirty (30) days from the date of receiving your verifiable request.

11.     COOKIES POLICY

 

• The Website uses cookies and similar tracking technologies to enhance user experience, remember preferences, and analyse traffic.
• Types of cookies used:

 

Cookie Type	Purpose
Essential Cookies	Necessary for Website functionality (e.g., shopping cart, login sessions)
Performance Cookies	Analytics to understand how users interact with the Website
Functional Cookies	Remembering preferences such as language or region
Marketing/Targeting Cookies	Delivering relevant advertisements and tracking campaign effectiveness

 

• You may configure your browser settings to reject or delete Note that disabling certain cookies may impair the functionality of the Website.

 

12.      SECURITY OF YOUR INFORMATION

 

• Dumbphones India implements reasonable security practices and procedures as mandated under Rule 8 of the SPDI Rules, 2011, including:
  • SSL/TLS encryption for all data transmitted to and from the Website;
  • Secure, encrypted storage of passwords and payment data;
  • Restricted internal access to personal data on a need-to-know basis;
  • Regular security audits and vulnerability
• Not withstanding the above, no security system is impenetrable. Dumbphones India does not guarantee absolute security of your personal data against all threats. In the event of a data breach, we shall notify affected users and regulatory authorities in accordance with Applicable Law.

9.3. Accountability and Governance: Dumbphones India maintains a robust internal data governance framework. This includes:

• Internal Policies: Comprehensive internal policies and procedures for data handling, access control, and incident management.
• Employee Training: Mandatory and regular training for all employees who handle personal data, ensuring they are aware of their responsibilities and best practices for data
• Incident Response Plan: A well-defined data breach incident response plan to promptly detect, assess, contain, and remediate any potential security incidents, including timely notification to affected users and regulatory authorities as required by Applicable Law.
• Regular Audits: Periodic internal and external security audits and vulnerability assessments are conducted to identify and mitigate potential risks and ensure the continuous effectiveness of our security measures.

9.4. User Responsibility: While Dumbphones India implements stringent security measures, the overall security of your personal data also depends on your actions. We urge you to:

• Use strong, unique passwords for your account and change them
• Keep your login credentials confidential and do not share them with
• Log out of your account after each session, especially when using a shared or public
• Be vigilant against phishing attempts and suspicious

 

13.  CHILDREN’S PRIVACY

• The Website is not directed at individuals below the age of 18 years. Dumbphones India does not knowingly collect personal data from minors.
• If a parent or guardian becomes aware that their minor child has provided personal data without consent, they should contact us immediately at support@co.in. We shall delete such data promptly upon verification.

 

14.  LINKS TO THIRD-PARTY WEBSITES

• The Website may contain links to external websites not operated by Dumbphones India. This Policy does not apply to such external websites. Dumbphones India is not responsible for the privacy practices or content of any third-party website.
• Customers are encouraged to review the privacy policies of third-party websites they

 

15.  CHANGES TO THIS PRIVACY POLICY

• Dumbphones India reserves the right to update this Policy at any Updated versions shall be posted on the Website with a revised Effective Date.
• Continued use of the Website after the effective date of a revised Policy constitutes acceptance of the revised Policy. We encourage you to review this Policy periodically.

 

16.  GRIEVANCE OFFICER — PRIVACY COMPLAINTS

In accordance with the IT Act, 2000 and SPDI Rules, 2011, Dumbphones India has designated a Grievance Officer to address privacy-related complaints Name: Abdullah Email: Support@dumbphones.co.in Address: 1st floor, Regal Diamond Centre, Office No-114, Charni Road, Opera House, Mumbai, Maharashtra-400004, India Working Hours: Monday to Saturday, 11:00 AM – 7:00 PM IST (excluding public holidays) The Grievance Officer shall acknowledge your complaint within forty-eight (48) hours of receipt and shall endeavor to resolve it expeditiously, typically within a period of thirty (30) days from the date of its receipt. We are committed to providing a fair and transparent mechanism for grievance redressal.

 

17.  USER’S RESPONSIBILITY FOR ACCURATE INFORMATION:-

 

 

 

• You are responsible for ensuring the accuracy, completeness, and currency of the personal information you provide to DumbPhones India. We rely on the information provided by you to fulfill our obligations and provide services.
• Please promptly update your personal information through your account settings or by contacting our Grievance Officer if there are any changes. Dumbphones India shall not be liable for any consequences arising from inaccurate or incomplete information provided by you.

 

 

 

18. SEVERABILITY:-

 

15.1. If any provision of this Privacy Policy is held to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be severed from this Policy, and the remaining provisions shall remain in full force and effect.

 

 

 

19. NO WAIVER:-

 

16.1. No failure or delay by Dumbphones India in exercising any right, power, or privilege under this Privacy Policy shall operate as a waiver thereof, nor shall any single or partial exercise thereof preclude any other or further exercise thereof or the exercise of any other right, power, or privilege.

 

 

 

20. GOVERNING LAW AND JURISDICTION:-

 

This Policy is governed by the laws of the Republic of India. Any disputes arising from this Policy shall be subject to the exclusive jurisdiction of courts in Mumbai, Maharashtra, India, without prejudice to your rights under the Consumer Protection Act, 2019.

 

Email: Support@dumbphones.co.in

Address: 1st floor, Regal Diamond Centre, Office No-114, Charni Road, Opera House, Mumbai, Maharashtra-400004, India

Working Hours: Monday to Saturday, 11:00 AM – 7:00 PM IST

 

The Grievance Officer shall acknowledge your complaint within 48 hours and resolve it within 30 days.

 

17. GOVERNING LAW

This Policy is governed by the laws of the Republic of India. Any disputes arising from this Policy shall be subject to the exclusive jurisdiction of courts in Mumbai, Maharashtra, without prejudice to your rights under the Consumer Protection Act, 2019.