Data Privacy Policy

1 Introduction and Scope

This Privacy Policy constitutes a legally binding agreement between the User (including Retailers, registered users, and visitors) and Totely India Pvt Ltd ("Totely," "We," "Our," or "Us"), the operating company and legal entity providing the Retail Ordering platform.

1.1 Organizational Clarity

It is expressly clarified that:

• Totely India Pvt Ltd is the business entity providing this service and holds all legal responsibility for data processing and privacy compliance.
• Retail Ordering is the product/platform offered by Totely India Pvt Ltd for managing digital retail operations.
• Trelliso is the dashboard interface through which Retailers access and manage the Retail Ordering platform.
• This Privacy Policy applies to all data collected through the Retail Ordering platform accessed via the Trelliso dashboard at retailordering.com.

1.2 Important Notice

1.3 Registered Address of Totely India Pvt Ltd

Desk 115, Level 3, NSL Centrum, Kukatpally, Hyderabad – 500072, Telangana, India

1.4 Legal Framework

This Privacy Policy is governed by the following Indian laws:

• Information Technology Act, 2000
• Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011
• Digital Personal Data Protection Act, 2023
• Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021
• Consumer Protection Act, 2019

This is an electronic record formed under the Information Technology Act, 2000 and does not require any physical, electronic, or digital signature.

2 Information We Collect

Totely collects and processes the following categories of data to provide platform services, facilitate commerce, comply with legal obligations, and improve user experience.

2.1 Information You Directly Provide

2.2 Information Collected Automatically

• Technical Information: IP address, browser type, device type, operating system
• Usage Information: Pages visited, time spent, clicks, scroll behavior, features used
• Location Information: Geographic location (inferred from IP address)
• Session Data: Login times, logout times, session duration, activities performed
• Device Information: Device model, screen size, mobile network provider

2.3 Cookies and Tracking Technologies

We use cookies and similar tracking technologies to remember preferences, analyze usage, and provide personalized experiences. You can control cookie settings in your browser, but some features may not work properly if cookies are disabled.

3 How We Use Your Information

3.1 Core Service Delivery

• Creating and maintaining your Retailer account
• Processing and fulfilling orders
• Providing access to platform features via the Trelliso dashboard
• Facilitating transactions between Retailers and customers
• Processing payments and settlements
• Generating invoices and billing statements

3.2 Security and Fraud Prevention

• Detecting and preventing fraudulent activity
• Protecting against cyber-attacks and unauthorized access
• Verifying identity during high-risk transactions
• Monitoring platform security and compliance
• Investigating security incidents and breaches

3.3 Legal Compliance and Regulatory Obligations

• Complying with court orders and legal process
• Fulfilling tax and regulatory reporting requirements
• Verifying business legitimacy and KYC compliance
• Maintaining audit trails and records
• Responding to government notices and inquiries

4 Data Security and Protection

4.1 Security Measures

Totely implements industry-standard security measures to protect your data:

• Encryption in Transit: SSL/TLS encryption (HTTPS)
• Encryption at Rest: AES-256 encryption for sensitive data
• Access Controls: Role-based access control (RBAC)
• Authentication: Two-factor authentication (2FA) and OTP verification
• Firewalls: Network firewalls and intrusion detection systems
• Regular Audits: Periodic security audits and penetration testing

4.2 Payment Security

All payment processing is handled by third-party payment gateways in compliance with PCI-DSS standards. Totely does NOT store credit card numbers, CVV details, or expiry dates on the Retail Ordering platform or Trelliso dashboard.

4.3 Data Breach Notification

In the event of a confirmed data breach affecting your personal information:

• We will notify you without unreasonable delay (typically within 72 hours)
• Notification will be via email to your registered email address
• We will provide information about the breach and recommended actions
• We will report to applicable regulatory authorities as required by law

5 Data Retention

5.1 Retention Policy

6 Your Rights and Choices

6.1 Access Your Data

You have the right to request access to all personal data Totely holds about you. To request data access:

• Email legal@retailordering.com with the subject "Data Access Request"
• Provide your full name, email, and account ID
• We will provide a copy of your data within 30 days in a standard digital format

6.2 Correct Inaccurate Data

If your personal information is inaccurate or incomplete, you may:

• Log into your account and update information directly
• Email legal@retailordering.com requesting correction of specific data
• Submit a formal correction request to the Grievance Officer

Response Time: We will correct inaccurate data within 15 business days.

7 Governing Law and Dispute Resolution

7.1 Governing Law

This Privacy Policy is governed by the laws of India, specifically applicable in Telangana.

7.2 Dispute Resolution Process

• Step 1 – Internal Resolution (15 Days): Contact the Grievance Officer (grievances@retailordering.com) to attempt informal resolution.
• Step 2 – Arbitration: If unresolved, disputes may be referred to arbitration under the Arbitration and Conciliation Act, 1996.
• Step 3 – Judicial Review: You may also pursue remedies through Indian courts.

8 Grievance Officer and Contact Information

8.1 Designated Grievance Officer and Legal Contact

8.2 Submitting a Grievance

To file a formal privacy grievance, email grievances@retailordering.com with:

• Your full name and contact information
• Your Retailer account ID or email
• Detailed description of the privacy issue
• Specific data affected
• Desired resolution

Response Timeline: Acknowledge within 3 business days; Investigate and respond within 30 days (60 days for complex issues).

9 Policy Modifications

Totely reserves the right to modify this Privacy Policy at any time. We will notify you of material changes via email notification to your registered email address and platform notification banner on the Trelliso dashboard. Your continued use of the Retail Ordering platform after notification constitutes your binding acceptance of the updated Privacy Policy.