Effective Date: 01-11-2025

1. Introduction
Welcome to Fwezo, a brand owned and operated by Minutra Private Limited (“we,” “us,” or “our”). We are committed to protecting your privacy and handling your personal data responsibly. This Privacy Policy explains how Minutra Private Limited, through its brand Fwezo, collects, uses, stores, discloses, and protects your personal information when you access or use our platform— including our website, mobile application, and any other related services (the “Platform”). It also outlines your rights regarding your personal information.

By using or accessing the Platform, you agree to the collection and use of your personal data as described in this Privacy Policy. If you do not agree with this policy, please do not access or use the Platform.

2. Definitions

• “User”, “you”, “your” means any individual or entity using or interacting with the Platform (customers, sellers, visitors).
• “Personal Data” or “Personal Information” means any information relating to an identified or identifiable individual.
• “Non-Personal Data” means data that is aggregated, anonymized or does not identify a specific person.
• “We”, “us”, “our”, “Fwezo” refers to Fwezo (the legal entity operating the Platform).

3. Information We Collect

We may collect the following categories of personal data:

3.1 Information You Provide Voluntarily

• Registration / account info: name, username, email, mobile number, password, address, gender, date of birth, etc.
• Profile information, preferences, interests
• Payment and billing information (payment instrument, bank account, UPI, etc.)
• Order & purchase information (order history, transaction details)
• Communications & feedback: responses to surveys, support requests, reviews, ratings
• KYC / identity verification data (PAN, Aadhaar, ID proofs) if required
• Marketing preferences

3.2 Information Collected Automatically

• Usage & analytics: pages visited, time spent, click patterns, searches, session logs, device information
• Device & connection info: IP address, browser type, OS version, mobile device identifiers, advertising IDs
• Location data: GPS, WiFi, cell tower data (with consent)
• Cookies, web beacons, logs

3.3 Information From Third Parties
We may get data from third parties such as payment gateways, credit bureaus, analytics providers, social media platforms, advertising networks, marketing partners, publicly available sources.

4. Use of Information

We use your personal data for the following purposes:

• To create and manage your account, authenticate, and provide access to the Platform
• To process your orders, payments, refunds, cancellations, returns
• To facilitate delivery, logistics and shipping
• To communicate with you: notifications, updates, customer support
• To personalize your experience, show relevant products, recommendations
• To conduct analytics, business intelligence, usage metrics, trend analysis
• To detect and prevent fraud, security, abuse
• For marketing, promotions, offers (subject to your consent / opt-out)
• To comply with legal, regulatory, tax and audit requirements
• For business operations, improving the Platform, product development

5. Legal Basis for Processing
Depending on the nature of processing, we rely on one or more legal bases (under applicable law) such as:

• Consent (you provide explicit consent)
• Performance of contract (to fulfill your orders, service)
• Legitimate interests (e.g. fraud detection, improving service)
• Compliance with legal obligations

6. Sharing & Disclosure

We may share or disclose personal data in the following circumstances:

• With sellers, vendors, delivery partners, logistics, for order fulfillment
• With payment processors, banks, financial institutions
• With service providers, technology partners, analytics providers
• With advertisers, marketing partners (in anonymized / aggregated form)
• In the event of a business transfer, merger, acquisition
• To comply with law, legal process, government / regulatory requests
• To protect our rights, safety, or rights of others

We will not sell your personal data to third parties for their own independent use, unless you explicitly consent.

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes in this policy, unless a longer retention period is required or permitted by law. After such time, we may aggregate, anonymize, or delete data.

8. Security

We follow industry-standard security measures (encryption, access controls, secure servers) to protect your personal data from unauthorized access, disclosure, alteration or destruction. We also perform periodic audits, vulnerability scans, and maintain strict internal policies.

9. Your Rights

Depending on applicable law, you may have the following rights:

• Right to access your personal data
• Right to correct or update your data
• Right to erase (“right to be forgotten”)
• Right to restrict or object to processing
• Right to data portability
• Right to withdraw consent
• Right to lodge complaint with authority

To exercise your rights, contact us using the details at the end of this policy. We may subject your request to verification.

10. Children’s Privacy

Our Platform is not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that personal data of a child has been collected, we will take steps to delete it.

11. International Transfers

If your data is transferred to or processed in other jurisdictions, we ensure that appropriate safeguards are in place (e.g. standard contractual clauses, data protection agreements).

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will indicate the effective date. We encourage you to review this periodically. Your continued use of the Platform after updates implies your acceptance of the updated policy.

13. Contact Information

If you have any questions, complaints or requests, please contact:

Team Fwezo