Privacy Policy — 3pmCIRCLE

SUN CONSULTATION ("we", "us", "our") operates the 3pmCIRCLE platform (the "Platform"), a B2B marketplace and service ecosystem for the Ayurvedic industry. This Privacy Policy explains how we collect, use, disclose, store and protect personal and business data of users of the Platform — including Ayurvedic Doctors, Entrepreneurs, Ayurvedic Manufacturers, and Product Marketers (collectively, "you", "your", "User", "Seller"). This Policy is to be read together with our Terms of Use. By using the Platform you accept the practices described here.

1. Scope & Applicability

This Privacy Policy applies to all information collected when you: register or create an account on 3pmCIRCLE; browse, list, buy, sell, or sample products through the Platform; use Platform features such as messaging, escrow, custom-formulation tools, webinars, or process coordination services; and interact with our customer support or promotional communications.

It covers information collected online, via email, telephone interactions initiated through the Platform, and data provided to our service providers acting on our behalf.

2. Categories of Information We Collect

• A. Identity & Account Information: Full name, professional designation (e.g., BAMS), organization name, registration/license numbers (AYUSH/GMP/FSSAI/etc.), date of birth (where required), and photograph (profile).
• B. Contact Information: Email address, telephone/mobile number, postal address, delivery/shipping address, and billing address.
• C. Business & Transactional Information: Company details, product listings and descriptions, pricing, invoices, purchase histories, order details, sample request records, escrow instructions, shipment and delivery confirmations, and tax/GST information.
• D. Financial & Payment Data: Payment instrument metadata and transaction records handled through our escrow/payment partners (we do not store full card numbers or bank passwords). We retain transaction receipts, escrow releases and settlement records for compliance and audit.
• E. Communications & Support Data: Messaging/chat logs between Users & Sellers, email correspondence, webinars participation records and recordings (where applicable), and support tickets.
• F. Technical & Usage Data: IP address, device identifiers, browser and operating system, login timestamps, pages visited, clickstream and analytics data, cookies and similar tracking technologies, and error logs.
• G. Sensitive Information: We do not intentionally collect sensitive personal data (e.g., health data of private individuals) except professional medical registration identifiers required for verification of Ayurvedic doctors and necessary compliance documents. If you provide any other sensitive data, you consent to our processing for the stated purpose.

3. How We Collect Data

• Directly from you: when you register, update your profile, list products, place orders, request samples, upload documents, participate in webinars, or contact support.
• Automatically: through cookies, server logs, and analytics when you use the Platform.
• From third parties: verification providers, payment/escrow service providers, logistics partners, marketing service providers, and publicly available sources (e.g., business registries) for due diligence and verification.

4. Purposes of Processing & Legal Basis

We process personal and business data to:

• provide and operate the Platform and its features (account management, product listings, order processing, escrow facilitation, sample management, messaging).
• verify identity, professional credentials and compliance (AYUSH, GMP, FSSAI, etc.).
• manage payments, escrow, settlements, refunds and tax compliance.
• communicate transactional messages, updates, and support responses.
• provide business services such as liaisoning, process coordination, and custom formulation project facilitation.
• improve and personalize our services, perform analytics and technical diagnostics.
• detect, prevent and investigate fraud, abuse, security incidents and illegal activity.
• comply with legal obligations or respond to lawful requests from authorities.
• send marketing and promotional communications (with your consent where required).

Under applicable Indian law, our lawful bases include your consent, necessity for performance of contract, compliance with legal obligations, and our legitimate interests (for platform security, fraud prevention, service improvement and direct marketing where not overridden by your rights).

5. Use of Escrow & Third-Party Service Providers

We use third-party providers to process payments, hold escrow funds, host the Platform, provide analytics, send emails/SMS, and assist with logistics and compliance. Examples of categories of recipients:

• Payment gateways and escrow agents (for payment processing and holding funds)
• Logistics and fulfillment partners (for shipping/delivery)
• Identity/credential verification vendors (for license and registration checks)
• Cloud hosting and infrastructure providers
• Customer relationship management (CRM) and email/SMS service providers
• Analytics and audit service providers
• Legal and professional advisors where necessary

We share only the minimum data necessary for these providers to perform their services and ensure contractual safeguards are in place. These providers may process your data in or transfer it to jurisdictions outside India; in such cases we require them to provide appropriate safeguards.

6. Disclosure to Regulators, Law Enforcement & Legal Process

We may disclose your information if required by law, to comply with legal process, or in response to lawful requests from public authorities (e.g., courts, tax authorities, police) or to enforce our Terms. We will disclose data to protect our rights, property, safety of users or the public, and to investigate fraud or other wrongdoing.

7. Cookies, Tracking & Analytics

We use cookies and similar technologies to operate the Platform, remember preferences, analyze usage, provide features, and deliver marketing (where applicable). Types include:

• Essential/session cookies (required for Platform operation)
• Performance and analytics cookies (to improve UX)
• Functional cookies (to remember preferences)
• Advertising/marketing cookies (to deliver relevant promotions; applied only where permitted)

You can control cookies through browser settings and opt-out tools. Blocking cookies may limit Platform functionality.

8. Marketing Communications & Opt-Out

With your consent (or under our legitimate interest where permitted), we may send you newsletters, event invites, and promotional offers. You may unsubscribe at any time via the "unsubscribe" link in emails or by contacting us. Opting out will not affect transactional communications necessary for Platform operations (order confirmations, escrow notices, security alerts).

9. Data Retention

We retain data for as long as reasonably necessary for the purposes described and in compliance with legal and regulatory obligations. Typical retention periods:

• Account and profile data: for the duration your account is active + 7 years after deactivation for legal, tax and audit purposes.
• Transaction & escrow records: retained for at least 7 years (or longer if required by law).
• Messaging and support logs: retained for 2–5 years for dispute resolution and compliance.
• Analytics and log data: retained in aggregated or anonymized form; raw logs retained for 1–3 years.
• Marketing consent & preferences: until you withdraw consent or request deletion.

We periodically review retention needs and delete or anonymize data no longer required.

10. Data Subject Rights & How to Exercise Them

Depending on applicable law and subject to verification and legal limitations, you may have rights to:

• access the personal data we hold about you;
• correct or update inaccurate or incomplete information;
• request deletion (subject to legal retention obligations);
• object to or restrict certain processing (including direct marketing);
• request portability of your data in a commonly used electronic format; and
• withdraw consent where processing is based on consent.

To exercise rights, contact our Grievance Officer (details in Section 15). We will respond within a reasonable time-frame and in accordance with applicable law. We may require identity verification and will inform you if a request cannot be honored (e.g., due to legal obligations).

11. Security & Data Protection Measures

We implement reasonable technical, administrative and organizational measures to protect data against unauthorized access, disclosure, alteration or destruction. Measures include:

• access controls and least privilege principles;
• encryption of sensitive data in transit and at rest where applicable;
• network and application security (firewalls, intrusion detection);
• periodic security assessments and audits;
• internal policies, employee training, and NDA obligations for service providers.

No method of transmission or storage is 100% secure. We cannot guarantee absolute security; if a data breach affecting your personal data occurs, we will notify you and relevant authorities as required by law.

12. Children & Minors

The Platform is intended for business users and is not directed to children under 18. We do not knowingly collect personal information from minors. If you are under 18, do not register for an account without parental or guardian consent. If we learn that we have collected data from a child without consent, we will take steps to delete it.

13. International Transfers

As a cross-border B2B platform, your data may be transferred to and stored in countries other than India. Where transfers occur, we take steps to ensure appropriate safeguards (contractual clauses, security measures) are in place. By using the Platform you consent to such transfers.

14. Links to Other Sites

The Platform may link to third-party sites or services. This Privacy Policy does not apply to third parties. We encourage you to read the privacy policies of sites you visit through links. We are not responsible for third-party privacy practices.

15. Grievance Officer & Contact Information

16. Changes to this Policy

We may modify this Privacy Policy from time to time. Material changes will be posted on the Platform with the updated effective date. Continued use after posting constitutes acceptance of the updated policy. We encourage you to check this page periodically.

17. Remedies, Dispute Resolution & Governing Law

Any privacy-related dispute or claim arising from or in connection with this Privacy Policy shall be governed by Indian law. Jurisdiction for disputes will be the courts of Jamnagar, Gujarat, India, consistent with our Terms of Use.

18. Miscellaneous

• No sale of personal data: We do not sell personal data to third parties.
• Anonymization: Where practical, we aggregate or anonymize data for analytics and product improvement.
• Data portability & export: We will provide portable copies in a commonly used format where technically feasible and permitted by law.

19. How to Contact Us

For privacy queries, requests, or complaints, please contact: