1. Introduction

This Privacy Policy explains how Jewelxy Marketplace Pvt. Ltd. (“Jewelxy”, “we”, “us”), CIN: U74999GJ2016PTC093592, No 316, Vraj Valencia, S.G. Highway, Sola, Ahmedabad, Gujarat 380060, India, collects, uses, shares, and protects your personal data when you use www.jewelxy.com, our apps, and tools (the “Platform”).

We are the data fiduciary under India’s Digital Personal Data Protection Act, 2023 (“DPDP Act”) and the data controller under the EU/UK GDPR for personal data processed via the Platform.

Contact: support@jewelxy.com Grievance Officer / Data Protection contact: Mr. Dhaval Soni, support@jewelxy.com (subject: “Privacy”)

Jewelxy is a discovery platform: we do not process buyer payments and do not collect financial card details from buyers. Purchases happen on Jewellers’ own websites or channels, governed by their own privacy policies.

2. Data we collect

You provide: name, email, phone number, address/city, account credentials; for Jewellers: business name, registered address, licences/verification documents, product listings, pricing, and social/website links; reviews, ratings, photos, enquiries, and messages you post or send; communications with our support team.

Sign-in with Google, Apple, or Facebook (SSO): You can create an account and sign in using a third-party identity provider such as Google (and, when available, Apple ID or Facebook). When you do, we receive limited profile information from that provider — typically your name, email address, and profile picture — as authorised by you on the provider’s consent screen. We do not receive your password for that provider. Your use of the provider’s sign-in service is subject to that provider’s own terms and privacy policy, and you can manage or revoke Jewelxy’s access at any time in your Google/Apple/Facebook account settings. If you revoke access, you may lose the ability to sign in until you set up an alternative login. Note that Jewelxy may not offer OTP-based (email/SMS) login; SSO may be the primary sign-in method.

Collected automatically: device type and identifiers, IP address, browser type, pages viewed, links clicked, referral URLs, approximate location (from IP), and app permissions data where you grant them (location for “jewelers near me”, camera/storage for uploading photos, contacts only if you explicitly opt in to invite features). You can withdraw app permissions in your device settings at any time.

From third parties: limited profile data from your chosen SSO provider (above); payment confirmation status (not card details) from Razorpay/PayPal for Jeweller subscriptions; analytics data from service providers; publicly available business information used to verify Jeweller listings.

We do not knowingly collect data from children under 18. If you believe a minor has provided us data, contact us and we will delete it.

3. How and why we use your data (legal bases)

• To provide the service (contract): create and authenticate your account (including via SSO), operate accounts, display listings, route buyer enquiries to Jewellers (including via WhatsApp click-to-chat), process Jeweller subscriptions, provide dashboards and lead reports, customer support.
• Legal obligation: tax/GST records for Jeweller subscriptions, responding to lawful requests, grievance redressal.
• Legitimate interests (balanced against your rights): securing the Platform, preventing fraud and fake reviews, improving features, measuring performance, service communications.
• Consent: marketing emails/SMS/push (opt-out anytime), optional contact sync, precise location, non-essential cookies and analytics, and any new purpose we introduce. You may withdraw consent at any time without affecting prior processing.

We do not sell your personal data. We do not make automated decisions producing legal or similarly significant effects about you.

4. How buyer enquiries reach Jewellers

When you contact a Jeweller through the Platform (e.g., a WhatsApp lead, quote request, or profile enquiry), we share your name and contact details with that specific Jeweller only, for the purpose of responding to your enquiry. Jewellers may only use your details to respond to your enquiry and may not add you to marketing lists without your consent. We do not broadcast your personal details to other members.

5. Who we share data with

• The specific Jeweller you choose to contact (Section 4).
• Service providers under contract: hosting and CDN, analytics (Google Analytics), email/SMS delivery, customer support tools — limited to what they need, prohibited from using it for their own purposes.
• SSO providers (Google, and when available Apple/Facebook): authentication requests are exchanged with your chosen provider to sign you in; their processing is governed by their own policies.
• Payment gateways (Razorpay, PayPal) for Jeweller subscription billing, fraud prevention, and dispute handling, under their own privacy policies.
• AI and search visibility: Jeweller business profiles (business name, location, categories, ratings) are public listings and may be indexed by search engines and AI assistants; this is inherent to the listing service. Buyers’ personal data is never included.
• Legal: law enforcement, regulators, or courts where required by law, or to protect rights, safety, or property; disclosures limited to what is relevant.
• Business transfers: in a merger or acquisition, data may transfer to the successor, who must honour this policy; we will notify you of any change in purposes.

6. International transfers

Our primary servers are located in South Asia, and we use a global content delivery network (CDN) which may cache non-sensitive content at edge locations worldwide to serve pages faster. If you access the Platform from outside India, your personal data will be transferred to and processed in India. For EU/UK personal data we rely on appropriate safeguards, including Standard Contractual Clauses where required. Details are available on request at support@jewelxy.com.

7. Retention

• Account data: for the life of the account plus up to 90 days after deletion (backup purge cycle).
• Jeweller billing and tax records: 8 years (Indian tax law).
• Enquiry/lead records: 24 months.
• Analytics data: up to 26 months, aggregated or anonymised thereafter.
• Reviews: retained while the listing exists; anonymised if you delete your account (or deleted on request).

When data is no longer needed, we delete or anonymise it securely.

8. Your rights (India and EU/UK)

Depending on your jurisdiction (DPDP Act for India; GDPR/UK GDPR for EU/UK residents), you have the right to: access a summary of your personal data; correct or update it; erase it; withdraw consent; nominate a person to exercise your rights in case of death or incapacity (DPDP); data portability, restriction, and objection to processing based on legitimate interests, including direct marketing (GDPR); and lodge a complaint — with the Data Protection Board of India, or (EU/UK) your local supervisory authority such as the UK ICO.

To exercise rights: email support@jewelxy.com (subject “Privacy Request”) or use your account settings. We respond within the timelines required by applicable law. Grievances under the DPDP Act / IT Rules will be acknowledged within 24 hours and resolved within 15 days by our Grievance Officer, Mr. Dhaval Soni.

8A. United States

If you are a resident of California or another US state with a comprehensive privacy law, you have the right to know/access, correct, and delete your personal information, and the right to non-discrimination for exercising these rights. Jewelxy does not sell your personal information and does not share it with third parties for cross-context behavioural advertising. Submit requests to support@jewelxy.com (subject “Privacy Request”); we will verify your identity and respond within the statutory period. Authorized agents may submit requests with proof of authorization.

8B. Canada

We process personal information in accordance with PIPEDA. You may access and correct your personal information and withdraw consent (subject to legal or contractual restrictions), and you may complain to the Office of the Privacy Commissioner of Canada.

8C. Australia

We handle personal information consistently with the Australian Privacy Principles. You may request access and correction, and complain to us first and then to the Office of the Australian Information Commissioner (OAIC) if unresolved. Note that your data is held outside Australia (India/South Asia) as described in Section 6.

9. Marketing preferences

You can opt out of marketing anytime via the unsubscribe link in emails, replying STOP to SMS, or your account’s communication preferences. Service messages (billing, security, grievance responses) will still be sent.

10. Cookies and similar technologies

We use cookies, pixels, and similar technologies for: (a) strictly necessary functions (login and SSO session management, security, preferences) — no consent needed; (b) performance/analytics (Google Analytics); (c) functionality; and (d) advertising/measurement. For users in jurisdictions requiring it (EU/UK), non-essential cookies load only after you opt in via our cookie banner, and you can change your choice anytime via the “Cookie Settings” link in the footer. You can also opt out of Google Analytics via Google’s opt-out browser add-on, and control cookies in your browser settings; blocking all cookies may break login and other features.

11. Security

We protect data using SSL/TLS encryption in transit, firewalls, access controls, and secure hosting. SSO sign-in adds provider-level protections (e.g., Google’s account security). No system is 100% secure; if a breach affects your personal data, we will notify you and the relevant authorities as required by law (including the Data Protection Board of India under the DPDP Act).

12. Changes to this policy

We may update this policy. Material changes will be notified by email or in-app notice at least 15 days before taking effect, with the “Last updated” date revised. Where a new purpose requires consent, we will ask for it.

13. Contact

Jewelxy Marketplace Pvt. Ltd. CIN: U74999GJ2016PTC093592 No 316, Vraj Valencia, S.G. Highway, Sola, Ahmedabad, Gujarat 380060, India Email: support@jewelxy.com Grievance Officer: Mr. Dhaval Soni