Privacy Policy
Subharambh.com and the Subharambh Android app (com.subharambh.app)
Effective: 17 October 2026 · Version 1.0
Subharambh is a group-buying platform for India. People post a requirement, gather buyers with the same need, and go to sellers as one group; merchants post deals and advertise. This policy explains what personal data we collect, why, who sees it, how long we keep it, and what you can do about it. It applies to the website and the app. By creating an account you confirm you have read it.
1. Who we are
The service is run by [legal name of the business / proprietor], [registered address], India (“Subharambh”, “we”). We decide why and how your personal data is used, so we are the “Data Fiduciary” under India’s Digital Personal Data Protection Act, 2023 (the “DPDP Act”). Contact for anything in this policy: support@subharambh.com.
2. What we collect
| What | Details | When |
|---|---|---|
| Account details | Name, email address, mobile number, date of birth, country, password (stored only as a one-way hash), role (for example buyer or merchant), optional profile photo | When you sign up or edit My Profile |
| Business details | If you link your account to a business: its name and GSTIN / PAN, and the documents you submit with the request | When you ask to be linked to a company |
| Location | Your chosen country, state, district and current city; an approximate state worked out from your IP address when you first open the site; an exact latitude and longitude only if you press “Use my current location” or drop a pin on the map, and your device allows it | Browsing, filling in a posting or deal |
| What you post | Group-buying postings, deals, bids, advertisements, photos and videos you upload, specifications, quantities, prices, contact details you choose to show on a deal | When you create or edit them |
| Chats | Messages and files you send in posting chats, and who sent them and when (see section 6) | When you chat |
| AI assistant | What you type to the assistant and its replies, and the text you give “Draft with AI” (contact details such as phone numbers and emails in drafting text are scrubbed) | When you use the assistant |
| Preferences | Saved searches, unsent form drafts, notification choices, and (only if you opt in) your WhatsApp number for alerts | When you set them |
| Feedback and support | What you write when you send feedback or report a message or posting | When you send it |
| Payments | Invoice details (for example for advertising). Card, UPI or bank details are entered on our payment provider’s page and are never stored by us | When you pay an invoice |
| Technical data | IP address, device and browser type, app version, sign-in and security logs, error reports, and records of what happened to a posting, deal or advertisement (an audit trail) | Automatically |
Browsing public pages needs no account. We do not collect your contacts, SMS, call logs or photo gallery. The Android app asks only for internet access and, on newer Android versions, permission to show notifications. Files you upload are the ones you pick.
3. Why we use it
- to create and secure your account, sign you in and recover your password;
- to run the service: show postings and deals near you, form groups, pass bids and messages between the right people, and send the alerts and emails you asked for;
- to review postings, deals and advertisements, prevent fraud and abuse, and resolve disputes;
- to issue invoices and keep accounts, as the law requires;
- to show advertisements (section 5), and to improve and measure the service;
- to send you occasional updates and tips only if you ticked that box; you can switch it off in My Profile;
- to meet legal duties and answer lawful orders.
We rely on your consent (for example, location and WhatsApp alerts), on what is needed to provide the service you asked for, and on legal obligations. You can withdraw consent at any time; that does not affect what was done before.
4. Who we share it with
We do not sell your personal data. We share it only as follows.
- Other users. A posting shows what you wrote to people who can see that posting. Members of a group and the sellers who bid on it see the details they need to take part. Public pages show only limited information: buyers’ names and commercial terms are not published. A live deal shows the merchant, the offer, the place and the contact details the merchant entered.
- Service providers who act on our instructions:
- cloud hosting and database in India [hosting provider and region];
- email delivery for sign-up, password reset and notifications [SMTP provider];
- Razorpay, to collect payments for invoices;
- Meta (WhatsApp Business), only if you opt in to WhatsApp alerts — your number and the alert text are sent to it;
- an AI provider [name, for example OpenRouter and the model it routes to], which receives what you type to the assistant or “Draft with AI” so it can reply. Do not type secrets into it.
- OpenStreetMap. Opening a map sends your IP address and the area you are viewing to openstreetmap.org; a place search sends what you type to nominatim.openstreetmap.org. Nothing about your account is sent. Maps can be switched off by an administrator.
- Authorities and legal. When a written order or law requires it, or to protect rights, safety or against fraud. Chats are disclosed only as described in section 6.
- Business changes. If the business is sold or merged, your data may move to the new owner, who must honour this policy.
5. Advertising, cookies and similar technology
Some pages show advertisements placed by merchants on Subharambh and, where an administrator has switched it on, ads served by Google AdSense. Google and its partners may use cookies or device identifiers to show ads and measure them. You can manage ad personalisation at adssettings.google.com. We also use browser storage that the website needs to keep you signed in and remember simple choices such as filters. We do not use your chats or uploaded files to target ads.
6. Chats and messages
- Messages and files in posting chats are encrypted (AES-256) before they are stored, with a separate key per conversation. This is encryption on our servers; it is not end-to-end encryption.
- They are shown to the people in that conversation. Subharambh staff do not browse them. We open a conversation only (a) when a member reports a message, (b) to resolve a dispute or investigate fraud, after recording a reason, or (c) when an order under Indian law requires it. Every such access is logged.
- You can delete your own messages; they disappear for everyone in the conversation, unless they are under a legal hold.
7. Where it is stored and how it is protected
Your data is stored on servers in India [confirm hosting region]. We protect it with encrypted connections (HTTPS), hashed passwords, role-based access so staff see only what their job needs, encrypted chats and provider secrets, rate limiting, audit logs and regular backups. No system is perfectly secure; if a personal data breach affects you, we will tell you and the authorities as the law requires.
8. How long we keep it
- Account details: until you delete your account.
- Postings, deals, bids, advertisements and chats: while they are live, and afterwards as needed for the people who took part and for our records.
- Invoices and payment records: as long as tax and accounting law requires [number] years.
- Security and audit logs: [number] months.
- Unsent form drafts: removed after 30 days.
9. Your choices and rights
You can see and correct most of your details in My Profile. Under the DPDP Act you may also ask us for a summary of your data and who it was shared with, ask for correction or erasure, withdraw consent, and nominate someone to exercise these rights for you if you die or cannot act. Write to support@subharambh.com and we will reply within [30] days.
Delete your account yourself at any time from the app or the website. See how to delete your account for the steps and for what is erased and what is kept. In short: your name, contact details, photo, location, saved searches, drafts and assistant conversations are erased; postings, deals and chat messages that other people rely on stay, shown as written by “Deleted User”, as do records we must keep by law.
You can turn off notifications in your device settings, WhatsApp alerts and marketing updates in My Profile, and location by denying the permission in your browser or device.
10. Complaints
Please write first to our Grievance Officer: [name], [designation], Subharambh, [address], support@subharambh.com. We will acknowledge within [48 hours] and resolve within [15 days]. If you remain unsatisfied, you may complain to the Data Protection Board of India.
11. Children
Subharambh is for people aged 18 and over and is not directed at children. We do not knowingly collect data of children. If you think a child has an account, tell us and we will delete it.
12. Changes to this policy
If we change this policy in a way that matters, we will show a notice in the app or on the website before the change applies and update the date above. The latest version is always at subharambh.com/privacy.