Privacy Policy

1. About this Privacy Notice

The Privacy Notice herein shall be applicable to Spyfoxx Technologies Private Limited (“Zwitto”, “the Company”, “We”, “Us” or “Our”), a private limited company incorporated under the Companies Act, 2013, having its registered office at Bhatti Road, Bathinda, Punjab, India - 151001, along with its subsidiaries, holding company and affiliates.

The Company owns and operates the Website www.Zwitto.com and Mobile Application “Zwitto” (collectively, the “Platform”). The term “You”, “Your”, “Yourself” or “User” includes any user of the Platform.

This Notice describes the policies and procedures relating to the collection, use, storage, disclosure, transfer and security of your information in connection with your use of the Platform.

By visiting the Platform or creating an Account, you agree to be bound by this Privacy Notice. This Notice forms part of the Terms of Use.

2. Collection of Information

Zwitto collects information when you visit the Platform, register or create an account, or use its services.

a. Personal Information

This may include your full name, mobile phone number, email ID, date of birth, gender, age, address details, KYC information, financial information, occupational information, verification documents, health and lifestyle information voluntarily furnished, IP address, web requests, operating system, browser, connection information, device type and telephone number of the device.

b. Sensitive Personal Information

This includes passwords; financial information including bank account, credit card and debit card information; physical, physiological and mental health condition; sexual orientation; medical records and history; biometric information; and other information specified under applicable law.

c. Transactional Information

Zwitto may collect transaction status, order history, number of transactions, order details, behaviour and preferences. SMS messages stored on devices may also be collected for registration, OTP and security purposes.

d. Location-based Information

Location data, IP address, internet bandwidth, device model, browser plug-ins and unique device identifiers may be used for location-based search, serviceability, delivery ETA, nearby local stores, pickup locations and personalized content. Exact location may be accessed when permission is granted and the Platform is running in the foreground or background.

e. Non-Personal Information and Cookies

Zwitto may gather anonymous data such as URLs, ISP data, aggregated user data, device characteristics, requested pages and cookie data. Cookies may authenticate users, remember preferences, measure promotions, foster trust and safety, analyse traffic and understand online behaviour and interests.

f. Gift Recipient Information

For Gift Orders, Zwitto collects recipient details such as name, delivery address and contact number solely to fulfil the order and related communications. By providing these details, you confirm that you have the recipient’s consent to share them.

g. Additional Information

Zwitto may obtain information voluntarily shared through social media channels, surveys, feedback, account creation, telephone, chat and other interactions.

3. Use of Information

Zwitto uses information in accordance with law for purposes including:

• Registering accounts, verifying identity and controlling access permissions.
• Providing Products and services, including Zwitto Dark Stores, sellers, local partner stores and business partners.
• Warehousing, delivery, pickup, IT and data analytics services.
• Resolving disputes, processing requests and complaints, administering services and diagnosing technical issues.
• Maintaining safety, security and integrity of the Platform and Users.
• Designing and improving products, services and CRM practices.
• Processing payments and operating rewards, referrals, coupons and loyalty programs including Zwitto Coins.
• Detecting and preventing errors, fraud and illegal or prohibited acts.
• Communicating service updates, offers, promotions and marketing materials where permitted.
• Personalising the user experience, suggestions, curated lists and content.
• Complying with legal requirements and reporting obligations.
• Carrying out research, legitimate business, marketing, advertising and promotional activities.
• Other purposes where consent is obtained at the time of collection.

Marketing communications

Zwitto may personalize offers and newsletters and send them through email, WhatsApp, SMS, RCS, push notifications or other channels. You may unsubscribe from marketing communications at any time, but not from administrative or transactional communications.

4. Sharing of Information

a. Business Partners

Zwitto may share Personal Information with third-party sellers, local partner stores, service providers, merchants, delivery partners, marketing or advertising partners, consultants, research partners and other service providers for service delivery, payment processing, marketing, analytics, audits and fraud prevention.

b. Compliance with Law

Information may be disclosed as necessary to comply with laws, regulatory requirements, lawful requests, legal processes or investigations; protect rights and property; prevent unlawful activity; or protect personal safety and assets.

c. Acquisition, Sale or Merger

Subject to applicable law, Personal Information may be shared in connection with a merger, sale, reorganisation, amalgamation, joint venture, assignment, restructuring or transfer of business.

d. Group Entities, Third Parties and Transfers Outside India

Subject to applicable law, Personal Information may be shared with group or affiliated entities or third parties that maintain appropriate data protection standards, including entities located outside India.

5. Security Precautions and Measures

The Platform uses adequate security procedures and controls intended to protect Personal Information against loss, misuse, unauthorized access, disclosure, destruction and alteration as required by applicable law.

Account information must be kept confidential. Users should immediately report unauthorized use or security breaches and log out after each session.

Payment information transmitted through the Platform is protected by encryption technology. However, Zwitto cannot guarantee that transmissions will always be secure or that unauthorized third parties will never defeat security measures.

6. Retention of Your Personal Information

Personal Information is retained only for as long as necessary for the stated purposes or as required by applicable law. Where possible, Zwitto strives to ensure Personal Information and Sensitive Personal Information are stored within India. Deletion requests will be complied with except where retention is permitted or required by law.

7. Links to Third-Party Sites and Collection of Information

The Platform may provide links to third-party platforms that may collect Personal Information. Zwitto is not responsible for the security, privacy policy or content of those Third-Party Sites. Users are encouraged to read the privacy policy of a Third-Party Site before providing information.

Third-party advertising companies may also use information about visits to the Platform and Third-Party Sites to serve relevant advertisements, subject to the terms described in the Privacy Notice.

8. Public Posts

Feedback, reviews and testimonials submitted through the Platform, including through the Zwitto Review Programme, may be publicly accessible. Posts are subject to the Terms and may be deleted or reused by Zwitto as permitted by the Notice and applicable law.

9. Your Consent, Rights and Choices

Your Consent

Information shared by you is considered voluntary and is processed based on your consent in accordance with this Notice. By using the Platform or providing Personal Information, you agree to its processing as described here.

Right to Withdraw Consent and Right to Erasure

You may revoke consent through Home → Settings → Profile in the mobile application. If consent is revoked, Zwitto will stop supplying the Services, Content and Features and will delete or anonymize data, subject to lawful retention requirements.

Access, Rectification and Modification

You may view, amend, add, upgrade, delete, update and modify information through Home → Settings → Profile, subject to identity verification and applicable legal restrictions.

Other Rights

• Right to designate a representative.
• Right to object to or request limitations on data processing.
• Right to complain to the relevant supervisory authority, after making use of Zwitto’s grievance redressal process where appropriate.

10. Children's Information

Zwitto states its commitment to protecting the privacy of minors and to complying with laws governing the gathering and processing of Personal Information of minors. The Platform is intended for users legally able to contract under applicable law, subject to the conditions stated in the Privacy Notice.

11. Changes to this Privacy Notice

Zwitto reserves the right to modify or add to this Notice. Amendments become effective immediately when notified. Users are encouraged to review the Notice periodically. Continued use of the Platform after modifications implies consent to the changes.

12. Grievance Officer

Zwitto has appointed a Grievance Officer for addressing grievances and complaints concerning the processing of Personal Information. Suspected misuse, loss or unauthorized access should be reported promptly.

13. Questions and Data Storage

Please write to legal@Zwitto.com for queries regarding this Privacy Notice. Zwitto will make reasonable efforts to provide an expeditious response.

The Notice states that the Platform stores data using the cloud platform of [Cloud Provider, e.g. Amazon Web Services], with data stored on servers outside India. The cloud provider has its own security measures and privacy policy.

In Short