Privacy Policy

Effective Date: 11 November 2025

Introduction

At HALPPY (Exfresh Retail Private Limited), we value your trust and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, share, and safeguard your information in compliance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”) and the Information Technology Act, 2000.

Information We Collect

1. Personal Information (PI)

We collect the following PI when you register, book a service, or contact us:

• Name, email address, mobile number, billing address, and precise service address details.
• KYC Information: For high-value transactions or large projects, we may be legally required to collect additional KYC documentation (e.g., PAN, Aadhar details) to comply with Indian anti-money laundering and tax laws.

2. Service Usage Data

Booking history, payment history, and operational data (location for Service Providers, project SOW details).

3. Device and Browser Information

IP address, cookies, browser type, and operating system.

4. Sensitive Personal Data or Information (SPDI)

We do not store your SPDI, such as bank account or payment card details. This information is securely handled by our PCI-compliant payment processor (Razorpay) and is encrypted during transmission.

How We Use and Share Your Information

We use your information solely for the following purposes:

1. Service Fulfillment

To process your bookings, manage the service, and deliver essential updates.

2. Transaction Processing

To facilitate payment processing, manage Escrow accounts (for Custom Projects), manage recurring Retainer billing (for Concierge), and generate invoices/receipts.

3. Aggregator Function (Disclosure)

Your PI (Name, Contact, and Service Address) will be disclosed to the specific third-party Service Provider assigned to your booking. This disclosure is mandatory for the execution of the contract (the service booking).

4. Legal Compliance

To comply with all applicable Indian laws, including KYC, GST, and anti-money laundering regulations.

5. Confidentiality and Data Handling for Premium Services

This section outlines our heightened commitment to data security and discretion for clients engaging with Custom Projects and the Concierge Desk & Lifestyle Management service.

5.1 Enhanced Confidentiality

Halppy and its Relationship Managers commit to the utmost discretion and confidentiality regarding the nature of services requested under the Concierge Desk. The scope and details of specialized, private, or high-value assignments will not be disclosed to any third party outside of the necessary service provider chain (Tasker) and regulatory requirements.

5.2 Project and Financial Data

For Custom Projects, all details contained within the Statement of Work (SOW), project budget, and milestone payment schedules are treated as confidential business information and are secured on restricted access servers.

5.3 Data Sharing for Management

In cases where Halppy acts as the Project Manager (Custom Projects) or Relationship Manager (Concierge), PI may be shared with vetted legal, financial, or logistics consultants engaged by Halppy on your behalf, strictly for the purpose of fulfilling your instructed work. Such disclosure is covered under Halppy’s internal NDAs with its consultants.

6. Data Security

We implement reasonable security practices and procedures as prescribed under the SPDI Rules to protect your data from unauthorized access, disclosure, or modification. This includes using encryption, secure servers, strict access controls, and enhanced security protocols for servers storing high-value client data (SOWs, SLAs).

7. Data Retention

We retain your information as long as you maintain an account, as required by law (e.g., tax records, KYC data), and for legitimate business purposes (e.g., project history for warranty claims).

8. Your Rights

You have the right to access and update your information, request data deletion (subject to legal retention requirements), and opt-out of marketing communications.

9. Cookies and Tracking

We use cookies to enhance your experience. By using our platform, you consent to cookie usage.

10. Grievance Officer

In accordance with the Information Technology Act, 2000 and the SPDI Rules, any concerns regarding privacy or data security should be addressed to the designated Grievance Officer:

11. Governing Law

This policy is governed by the laws of India, and all disputes shall be subject to the exclusive jurisdiction of the Courts in Surat, Gujarat, India.

By using HALPPY’s services, you acknowledge and agree to this Privacy Policy.