PLEASE READ THESE TERMS AND CONDITIONS (“TERMS”) CAREFULLY BEFORE PLACING AN ORDER OR USING THIS WEBSITE. BY ACCESSING THIS WEBSITE OR COMPLETING A PURCHASE, YOU AGREE TO BE LEGALLY BOUND BY THESE TERMS. IF YOU DO NOT AGREE, DO NOT USE THIS WEBSITE.

 

By accessing, browsing, using, or transacting on the website and online platform of Dumbphones India / Dumbphone India (hereinafter referred to as the “Website”), it shall be irrevocably and unconditionally deemed that you have read, understood, consented to, and agreed to be bound by these Terms and Conditions (hereinafter referred to as the “Terms”). If you do not agree to these Terms in their entirety, you must immediately cease all access and use of this Website and refrain from purchasing any products therefrom.

These Terms, along with the Privacy Policy, Shipping Policy, Return, Refund, and Cancellation Policy, and any other policies published on the Website, constitute a legally binding agreement between you (the User) and Dumbphones India, a sole proprietorship, governing your use of the Website, your purchase of products, and all related services and interactions.

1)  DEFINITIONS

For the purposes of these Terms, unless the context otherwise requires:

 

• “Dumbphones India”, “Dumbphone India”, “we”, “us”, “our” shall mean the sole proprietorship concern conducting business under the name and style of “Dumbphones India / Dumbphone India”, registered and operating in India in accordance with applicable laws, including but not limited to the provisions of the Indian Contract Act, 1872, the Information Technology Act, 2000, the Consumer Protection Act, 2019, and the Consumer Protection (E-Commerce) Rules, 2020.
• “Website” shall mean the e-commerce platform and website operated by Dumbphones India, accessible at https://dumbphones.co.in/, including all its pages, sub-pages, content, features, functionalities, and services offered thereon.
• “User”, “you”, “your”, “Customer” shall mean any natural or legal person who accesses, visits, browses, or uses the Website in any manner, including any person who registers an account, places an order, or intends to purchase products from the Website.
• “Products” shall mean, keypad-based mobile phones and any other related products, accessories, or merchandise listed for sale on the Website from time to time, which are intentionally designed to deliver essential communication functions.
• “Order” shall mean any formal request or order placed by a User for the purchase of one or more Products through the Website’s checkout process.
• “Applicable Law” shall mean all statutes, enactments, acts of legislature or parliament, ordinances, rules, bye-laws, regulations, notifications, policies, guidelines, directions, directives, and orders of any governmental authority, tribunal, court, or other statutory authority in India as may be applicable from time to time.
• “Force Majeure Event” shall have the meaning ascribed to it in Clause 16
• “Grievance Officer” shall mean the designated officer appointed in accordance with the Information Technology Act, 2000 and the Consumer Protection (E-Commerce) Rules, 2020, whose details are provided in Clause 21.
• “ADR Mechanism” shall mean the alternative dispute resolution mechanisms, including negotiation, mediation, and arbitration, as stipulated in Clause 20.
• “Delivery Partner” means any third-party courier or logistics service engaged by Dumbphones India for the fulfilment of orders.

2)  BUSINESS DESCRIPTION AND PHILOSOPHY

• Dumbphones India is an e-commerce enterprise established with the objective of addressing the growing concerns of excessive digital dependency in modern society. The platform primarily offers touch screen + keypad-based mobile phones that are intentionally designed to deliver only essential communication functions, thereby minimizing unnecessary digital engagement and distractions.

 

• The core philosophy of Dumbphones India revolves around digital minimalism. By encouraging consumers to shift away from feature-heavy smartphones to simpler devices, the company aims to help individuals reclaim control over their time, attention, and mental well-being.
• By using the Website or purchasing our Products, you explicitly acknowledge, understand, and agree that the Products are curated with the specific objective of limiting digital features.

3) ELIGIBILITY AND ACCEPTANCE

• Use of the Website is available only to persons who can form legally binding contracts under the Indian Contract Act, 1872. Persons who are “incompetent to contract” within the meaning of the Act, including minors, un-discharged insolvents, etc., are not eligible to use the Website.
• You represent and warrant that you are at least eighteen (18) years of age and possess the legal authority to enter into this agreement. If you are a minor, i.e., under the age of 18 years, you may use the Website only with the involvement and under the supervision of a parent or legal guardian who agrees to be bound by these Terms. The parent or legal guardian shall be solely responsible for all acts and omissions of the minor.
• You further represent and warrant that all information provided by you during registration or any transaction on the Website is true, accurate, and complete. Any misrepresentation or false information provided by you may lead to the suspension or termination of your account and/or cancellation of your
• These Terms, together with the Privacy Policy, Return & Refund Policy, and any other policy published on the Website, constitute the entire agreement between Dumbphones India and you with respect to the subject matter hereof. In the event of any conflict between these Terms and any other communication, these Terms shall prevail.
• Dumbphones India reserves the right to refuse service, cancel orders, or terminate accounts at its sole discretion without prior notice, particularly in cases of misuse, fraud, or suspected fraudulent activity.

4)  AMENDMENT OF TERMS

• Dumbphones India reserves the absolute and unconditional right to modify, amend, update, or revise these Terms at any time, in its sole discretion, without any prior specific notice to
• Any amendments or modifications shall be effective immediately upon being posted on the Website. Your continued use of the Website and/or placement of Orders following the posting of revised Terms shall constitute your conclusive acceptance of such You are advised to periodically review these Terms for any updates.

5)  WEBSITE ACCESS, CONTENT, AND USE

• Dumbphones India grants you a limited, non-exclusive, non-transferable, and revocable license to access and make personal, non-commercial use of this Website. This license does not include any resale or commercial use of this Website or its contents; any collection and use of any product listings, descriptions, or prices; any derivative use of this Website or its contents; any downloading or copying of account information for the benefit of another merchant; or any use of data mining, robots, or similar data gathering and extraction tools.
• All content included on the Website, such as text, graphics, logos, button icons, images, audio clips, digital downloads, data compilations, and software, is the property of Dumb Phones India or its content suppliers and is protected by Indian and international intellectual property laws.
• You agree not to use the Website for any unlawful purpose or in any manner that could damage, disable, overburden, or impair any Dumbphones India server, or the network(s) connected to any Dumb Phones India server, or interfere with any other party’s use and enjoyment of the Website.
• Prohibited Activities: You are expressly prohibited from: Engaging in any activity that interferes with or disrupts the Website or the servers and networks connected to the Website.

1. Attempting to gain unauthorized access to any portion or feature of the Website, or any other systems or networks connected to the Website or to any Dumbphones India server, by hacking, password “mining” or any other illegitimate means. c. Probing, scanning or testing the

 

vulnerability of the Website or any network connected to the Website, nor breaching the security or authentication measures on the Website or any network connected to the Website.

1. Making any unsolicited or unauthorized advertising, promotional materials, email, junk mail, spam, chain letters, or any other form of solicitation. e. Impersonating any person or entity, or falsely stating or otherwise misrepresenting your affiliation with a person or entity. f. Uploading or transmitting any computer viruses, worms, trojan horses, or any other malicious code or programs designed to interrupt, destroy, or limit the functionality of any computer software or hardware or telecommunications equipment.

• User-Generated Content: If the Website allows for user comments, reviews, or other content submissions (“User Content”), you agree that you are solely responsible for your User Content. By submitting User Content, you grant Dumbphones India a worldwide, non-exclusive, royalty-free, perpetual, irrevocable, and fully sublicensable right to use, reproduce, modify, adapt, publish, translate, create derivative works from, distribute, and display such User Content throughout the world in any media. You represent and warrant that you own or otherwise control all of the rights to the User Content that you post; that the User Content is accurate; that use of the User Content you supply does not violate this policy and will not cause injury to any person or entity; and that you will indemnify Dumbphones India for all claims resulting from User Content you Dumbphones India has the right but not the obligation to monitor and edit or remove any User Content. Dumbphones India takes no responsibility and assumes no liability for any User Content posted by you or any third party.

6)  REGISTRATION, ACCOUNT, AND REGISTRATION DATA

• To place an Order, you may be required to create an account and provide certain information, including but not limited to your full name, email address, mobile number, billing address, and shipping address (“Registration Data”).
• You agree to provide true, accurate, current, and complete information about yourself as prompted by the Website’s registration You are also obligated to maintain and promptly update the Registration Data to keep it true, accurate, current, and complete.
• You are solely responsible for maintaining the confidentiality of your account password and for all activities that occur under your account. You agree to immediately notify Dumbphones India of any unauthorized use of your account or any other breach of security. Dumbphones India shall not be liable for any loss or damage arising from your failure to comply with this section.
• Dumbphones India reserves the right to suspend or terminate your account and refuse any and all current or future use of the Website if Dumbphones India has reasonable grounds to suspect that the Registration Data is untrue, inaccurate, not current, or incomplete, or that you have violated any of these Terms.

7)  PRODUCT LISTINGS, DESCRIPTIONS, AND AVAILABILITY

• We strive to be as accurate as possible in the description of the Products. However, Dumbphones India does not warrant that Product descriptions, images, specifications, or other content of this Website is accurate, complete, reliable, current, or error-free. The actual colors, appearance, and dimensions of the Products may vary slightly from those displayed on your screen due to monitor settings, photographic lighting sources, or other factors.
• All Products are offered for sale subject to availability. We reserve the right to limit the quantity of Products supplied to any customer, household, or order. We may fulfill only part of an Order, divide an Order into multiple shipments, or cancel or refuse any Order if a Product becomes unavailable after Order confirmation. In the event that we are unable to fulfill all or part of your Order, we will notify you promptly and, where applicable, issue a refund for any amount paid for the unavailable Product(s).
• The prices for Products are described on the Website and are incorporated into these Terms by All prices are in Indian Rupees (INR). Prices, Products, and services may change at Dumbphones India’s discretion without prior notice.
• In the event a Product is listed at an incorrect price or with incorrect information due to typographical error or error in pricing or product information received from our suppliers, Dumbphones India shall have the right, at our sole discretion, to refuse or cancel any orders placed for that Product, whether or not the order has been confirmed and your credit card charged. If your credit card has already been charged for the purchase and your order is cancelled, we will issue a credit to your credit card account in the amount of the charge.
• Dumbphones India shall not be liable for any loss or damage arising from the unavailability of a Product after an Order is placed. In such cases, the Company shall issue a full refund to the Customer.

8)  PAYMENT TERMS

 

• You agree to pay the price for the Products as listed on the Website at the time of placing the All payments must be made in full before the dispatch of the Products. An Order is considered confirmed only upon successful receipt of payment.
• We offer various payment options, including but not limited to credit/debit cards, net banking, and third-party payment By providing payment information, you represent and warrant that you are authorized to use the designated payment method.
• We use secure PCI-DSS compliant third-party payment gateways to process payments. Dumbphones India does not store, log, or retain any card or banking credentials of We are not responsible for any loss or damage to you arising directly or indirectly out of the decline of authorization for any transaction, on account of the cardholder having exceeded the preset limit mutually agreed by us with our acquiring bank from time to time.
• In the event of payment failure, the Company shall not be responsible for any double debit, reversal delays, or other banking errors. Customers must contact their bank or payment provider directly for       resolution  of   such          

9. SHIPPING AND DELIVERY1. Dumbphones India aims to ensure timely delivery of Products. Dumbphones India aims to provide delivery of all products, the order for which has been placed before 6pm within the next 48 hours from the placement of order. However, delays may occur due to unforeseen circumstances, logistical issues, or Force Majeure Events.
   • All shipping and delivery terms, including estimated delivery times, shipping charges, and areas of service, are governed by our separate Shipping Policy, which is available on the Website and forms an integral part of these By placing an Order, you agree to be bound by the Shipping Policy.
   • You are advised to review the Shipping Policy carefully before making any purchase. By placing an Order, you acknowledge and agree to abide by the terms and conditions set forth in the said policy.

 

 

10. RETURN, REFUND, AND CANCELLATION POLICY

 

• Dumbphones India is committed to providing a satisfactory shopping experience. Our policies regarding returns, refunds, and cancellations are detailed in our separate Return, Refund, and Cancellation Policy, which is available on the Website and forms an integral part of these Terms.
• You are advised to review the Return, Refund, and Cancellation Policy carefully before making any purchase. By placing an Order, you acknowledge and agree to abide by the terms and conditions set forth in the said policy.

9)  RIGHT TO CANCEL THE ORDER BY DUMBPHONES INDIA

• Dumbphones India reserves the right, at its sole discretion, to refuse or cancel any Order for any reason whatsoever, including but not limited to: a. Limitations on quantities available for b. Inaccuracies or errors in product or pricing information. c. Problems identified by our credit and fraud avoidance department. d. Technical errors or glitches on the Website.

1. Non-compliance with these Terms or any other policies of Dumbphones India. f. Suspicion of fraudulent or unlawful activity. g. Unavailability of the Product or inability to deliver to the specified address.

• We may also require additional verifications or information before accepting any We will contact you if all or any portion of your Order is cancelled or if additional information is required to accept your Order. If your Order is cancelled after your payment has been processed, the said amount will be reversed back to your original mode of payment within a reasonable timeframe.

 

12)  WARRANTY AND PRODUCT LIABILITY

 

• Products sold by Dumbphones India may carry the original manufacturer’s warranty as applicable. Dumbphones India does not provide any additional warranty over and above the manufacturer’s warranty unless expressly stated.
• Warranty claims must be directed to the original manufacturer or its authorised service centres Dumbphones India shall not be responsible for warranty services, replacement parts, or repair of Products.
• Dumbphone India’s liability as a seller under applicable product liability provisions of the Consumer Protection Act, 2019 is limited to:
• Ensuring authenticity of Products sourced from authorized channels;
• Passing on manufacturer warranties where applicable;
• Facilitating the return/refund process under its Return & Refund
• Dumbphones India shall not be liable for circumstances including but not limited to :
• Any defect arising from normal wear and tear;
• Physical damage, liquid damage, or misuse by the Customer;
• Modification, rooting, unlocking, or software alteration of the device;
• Loss of data stored on the device;

Incompatibility    of    the    device    with    any    third-party    applications     or    services.13 INTELLECTUAL PROPERTY RIGHTS

• The trademark “Dumbphones India”, its logo, and any other product or service name or slogan contained in the Website are trademarks of Dumbphones India and its suppliers or licensors, and may not be copied, imitated or used, in whole or in part, without the prior written permission of Dumbphones India or the applicable trademark holder.
• All other trademarks, registered trademarks, product names and company names or logos mentioned on the Website are the property of their respective owners. Reference to any products, services, processes or other information, by trade name, trademark, manufacturer, supplier or otherwise does not constitute or imply endorsement, sponsorship or recommendation thereof by us.
• All intellectual property rights in the Products, including but not limited to designs, software, and technology, are owned by Dumbphones India or its licensors. Your purchase of a Product does not grant you any intellectual property rights in the Product itself, other than the right to use the Product for its intended purpose.
• Customers are prohibited from:
• Copying, reproducing, distributing, or commercially exploiting any content from the Website;
• Reverse engineering, decompiling, or disassembling any software or technology used on the Website;
• Framing or mirroring any part of the Website without prior written consent from Dumbphones India.

• Violation of intellectual property rights may result in immediate account termination and civil and/or criminal action.

 

 

14) ELECTRONIC COMMUNICATIONS

• When you use the Website or send emails or other data, information or communication to us, you agree and understand that you are communicating with us through electronic records and you consent to receive communications via electronic records from us periodically and as and when required.
• We may communicate with you by email or by such other mode of communication, electronic or otherwise. You agree that all agreements, notices, disclosures, and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing.

15)  THIRD-PARTY LINKS

The Website may contain links to third-party websites or services that are not owned or controlled by Dumbphones India. Dumbphones India has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any third-party websites or services. You further acknowledge and agree that Dumbphones India shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such websites or services. We strongly advise you to read the terms and conditions and privacy policies of any third-party websites or services that you visit.

15  ​DISCLAIMER OF WARRANTIES

• The Website and all information, content, materials, products (including software) and services included on or otherwise made available to you through the Website are provided by DumbPhones India on an “as is” and “as available” basis, without any representations or warranties, express or implied, except otherwise specified in writing.
• Dumbphones India makes no representations or warranties of any kind, express or implied, as to the operation of the Website or the information, content, materials, products (including software) or services included on or otherwise made available to you through the Website, unless otherwise specified in writing.
• To the full extent permissible by Applicable Law, Dumbphones India disclaims all warranties, express or implied, including, but not limited to, implied warranties of merchantability and fitness for a particular purpose. Dumbphones India does not warrant that the Website; information, content, materials, products (including software) or services included on or otherwise made available to you through the Website; their servers; or electronic communications sent from Dumbphones India are free of viruses or other harmful

16) FORCE MAJEURE

Dumbphones India shall not be liable for any failure to perform or delay in performance of any of its obligations under these Terms that is caused by a Force Majeure Event. A “Force Majeure Event” shall mean any event that is beyond our reasonable control and includes, without limitation, acts of God, fire, flood, explosion, storm, civil commotion, riots, insurrection, war, terrorism, sabotage, acts of government, strikes, lock-outs or other industrial disputes, or failure of telecommunications or transport networks, epidemics, pandemics, or any other event that renders performance impossible or impracticable.

17)  LIMITATION OF LIABILITY

To the maximum extent permitted by Applicable Law, in no event shall Dumbphones India, its proprietor, employees, agents, or affiliates be liable for any indirect, punitive, incidental, special, consequential, or exemplary damages, including without limitation damages for loss of profits, goodwill, use, data, or other intangible losses, arising out of or relating to the use of, or inability to use, the Website or the Products. The aggregate liability of Dumbphones India, if any, in connection with any Order shall be limited to the value of the Product(s) purchased by the User under such Order. This limitation of liability shall apply regardless of the form of action, whether in contract, tort, strict liability, or otherwise.

18)    INDEMNIFICATION

You agree to indemnify, defend, and hold harmless Dumbphones India, its proprietor, officers, directors, employees, agents, licensors, and suppliers from and against all losses, expenses, damages, and costs, including reasonable attorneys’ fees, resulting from any violation of these Terms, any breach of your representations and warranties hereunder, your use of the Website,

 

or any activity related to your account (including negligent or wrongful conduct) by you or any other person accessing the Website using your account.

19)  APPLICABLE LAW AND JURISDICTION

These Terms shall be governed by and construed in accordance with the laws of India without reference to conflict of laws principles. Subject to the arbitration clause below, the courts in Mumbai, Maharashtra, shall have exclusive jurisdiction in any proceedings arising out of this agreement.

20)  DISPUTE RESOLUTION AND ARBITRATION

• It is the firm intention of the parties to amicably settle any dispute, claim, or controversy arising out of or relating to these Terms, including the determination of the scope or applicability of this agreement to arbitrate (hereinafter, a “Dispute”). The parties shall attempt to resolve any Dispute through an Alternative Dispute Resolution (ADR) Mechanism.
• In the event of a Dispute, the aggrieved party shall first attempt to resolve the Dispute through good faith negotiation with the other party.
• If the Dispute is not resolved through negotiation within thirty (30) days of the commencement of such negotiation, the parties agree to submit the Dispute to mediation before a neutral, third-party mediator in Mumbai.
• If the Dispute is not resolved through mediation within sixty (60) days of the appointment of a mediator, the Dispute shall be finally and exclusively resolved by arbitration conducted in accordance with the provisions of the Arbitration and Conciliation Act, 1996, as amended from time to time.
• The arbitration shall be conducted by a sole arbitrator appointed by mutual consent of the parties. If the parties fail to agree on a sole arbitrator within fifteen (15) days of the request for arbitration, the arbitrator shall be appointed in accordance with the provisions of the Arbitration and Conciliation Act, 1996.
• The seat and venue of the arbitration shall be Mumbai, Maharashtra,
• The language of the arbitration shall be
• The award of the arbitrator shall be final and binding on the parties, and judgment on the award may   be   entered   in   any   court   having   jurisdiction  

 

 

21)  GRIEVANCE        REDRESSAL        MECHANISM

In accordance with the Information Technology Act, 2000 and the rules made thereunder, and the Consumer Protection (E-Commerce) Rules, 2020, the name and contact details of the Grievance Officer are provided below:

Name: Abdullah                                                                     Designation: Customer Associate Email:  Support@dumbphones.co.in                                                         Phone: +91 8104112273 Address: 1st floor, Regal Diamond Centre, Office No-114, Charni Road, Opera House, Mumbai, Maharashtra 400004

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.

 

 

22) WAIVER

The failure of Dumbphones India to exercise or enforce any right or provision of these Terms shall not constitute a waiver of such right or provision. Any waiver of any provision of these Terms by Dumbphones India must be in writing and signed by an authorized representative of Dumb Phones India to be valid.

23)  SEVERABILITY

If any provision of these Terms is determined to be unlawful, void, or for any reason unenforceable, then that provision shall be deemed severable from these Terms and shall not affect the validity and enforceability of any remaining provisions.

24) ENTIRE AGREEMENT

These Terms, together with the Privacy Policy, Shipping Policy, Return, Refund, and Cancellation Policy, and any other legal notices or policies published by us on the Website, shall constitute the entire agreement between you and Dumbphones India concerning the Website and supersede all prior or contemporaneous communications and proposals, whether electronic, oral or written, between you and Dumbphones India with respect to the Website.

 

25)  CONTACT INFORMATION

For any queries, concerns, or communications, please contact us at:

 

Email: dumbphonesindia@gmail.com      Phone: +91 9136112273

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

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.