Privacy Policy

Privacy Policy for Phonewin Private Limited

Version: 1.0  Last Updated: February 12, 2026

This Privacy Policy ("Privacy Policy" or "Policy") applies to Phonewin Private Limited (hereinafter referred to as "Phone Win" or "the Company"), a private limited company incorporated under the Companies Act, 2013, having its Corporate Identification Number (CIN) U58203RJ2025PTC103282 and its registered office at 9, Vaishali Estate, Block A, Gandhi Path West, Vaishali Nagar, Jaipur, Rajasthan, 302021, India.

The Company is the owner of the mobile application 'Phone Win' (collectively, the "Platform").

This Privacy Policy describes the policies and procedures applicable to the collection, use, storage, disclosure, and protection of Your information shared with Us while You use the Platform. For the purpose of this Privacy Policy, "We", "Us", or "Our" refers to Phonewin Private Limited and its affiliates, and the terms "You", "Your", "Yourself" or "User" refer to the user of the Platform.

We value the trust You place in Us. That is why We maintain reasonable security standards for securing Your transactions and Your information. Please read this Privacy Policy carefully prior to using or registering on the Platform.

1. COLLECTION OF INFORMATION

We collect various types of information from You when You access or visit the Platform, register or set up an Account on the Platform, or use the Platform. This Privacy Policy applies to the following information collected about You:

a. Personal Information You may provide certain information to Us voluntarily while registering on the Platform for availing services, including but not limited to:

• Identity & Login Data:

  • Social Login: Your name, profile picture, and email address (collected via Google or Apple Sign-In).

  • Email OTP Login: Your Email Address provided directly by You for the purpose of passwordless authentication. We verify this email by sending a 4-digit One-Time Password (OTP) to ensure the account belongs to You.

• Contact Details: Your mobile number (+91) for additional account security.

• Delivery Details: Your complete postal address (House/Flat No., Floor, Landmark, City, State, Pincode) specifically for the delivery of physical rewards (e.g., mobile phones, accessories).

• Verification Data: Information required to verify task completion, such as time spent on third-party websites.

• Tax & Identity Data (Winners Only): If You win a high-value prize (e.g., iPhone, Laptop) worth more than ₹10,000, We may request Your PAN Card and Government ID copies. This is strictly to comply with Section 194B of the Income Tax Act, 1961 (TDS on Winnings) and will not be used for any other purpose.

b. Technical & Device Information (Non-Personal Information) We automatically track certain information about You based upon Your behavior on the Platform to prevent fraud and improve services. This includes:

• Device Identifiers: We collect Your Firebase Instance ID to identify Your unique installation. (Note: We DO NOT collect hardware identifiers like IMEI, Serial Number, or SIM Card details).

• Network Data: IP Address, internet service provider, and connection type.

• App Usage: Crash reports, session duration, and interaction logs (e.g., "Task Started", "Task Completed").

c. Location-Based Information When and if You use the Platform, We may receive information about Your location.

• Foreground Only: We request access to Your precise location (GPS) only when You are actively using the "Select Address" feature on the map to pinpoint Your delivery location.

• No Background Tracking: We do not track Your location when the App is closed or running in the background.

2. USE OF INFORMATION

We use the information in accordance with the law for the following specific purposes ("Purposes"):

a. Service Provision & Authentication

• To authenticate Your identity: We use Your Email Address to send a 4-digit OTP code for secure, passwordless login.

• To create Your account and manage Your profile.

• To process Your requests for rewards and deliver products to Your doorstep via our logistics partners.

b. Platform Integrity & Fraud Prevention

• To detect, prevent, and protect Us from errors, fraud, and other criminal or prohibited activity on the Platform.

• Anti-Cheat Policy: We actively monitor for the use of bots, emulators, automated scripts, or unauthorized tools. If suspicious activity is detected, We reserve the right to suspend Your account (Temporary or Permanent) and forfeit any pending rewards without prior notice.

• Contest Administration: To manage the Giveaway, verify Your eligibility (e.g., age, location), and ensure the "One User, One Entry" rule is followed during the random draw.

c. Communication

• To contact You via email, SMS, push notifications, or WhatsApp regarding delivery updates, service changes, or account security (e.g., Resending OTPs).

• To respond to Your queries raised to our Grievance Officer.

d. Legal Compliance

• To conform to legal requirements, compliance/reporting to regulatory authorities, and to comply with applicable laws (such as the Digital Personal Data Protection Act, 2023).

e. Lawful Basis for Processing: In accordance with the DPDP Act 2023, We process Your personal data based on the following lawful bases:

• Consent: For account registration, participating in giveaways, and location-based delivery services.

• Legal Obligation: For collecting Tax & Identity data (PAN) to comply with Section 194B of the Income Tax Act.

• Legitimate Use: For fraud detection, anti-cheat monitoring, and ensuring the security of the Platform.

3. SHARING OF INFORMATION

We do not sell Your Personal Information. We share information only with trusted third parties ("Data Processors") as described below:

a. Logistics & Delivery Partners We share Your Name, Address, and Mobile Number with logistics aggregators (specifically Nimbus Post and Shipbuddy) and their associated courier partners (e.g., Delhivery, BlueDart, Shadowfax) solely for the purpose of delivering Your rewards.

b. Technology Service Providers We may disclose Your information to third-party service providers who assist strictly with our business operations:

• Cloud Storage: Data is securely stored on Google Firebase and Amazon Web Services (AWS).

• Authentication: We use Google Firebase Auth to manage secure logins.

c. Compliance with Law We may disclose Your information including Personal Information, to the extent necessary: (a) to comply with laws, regulatory requirements and to respond to lawful requests and legal process; (b) to protect Our rights and property, the users, and others; and (c) in an emergency to protect personal safety.

d. Public Winner Announcements To ensure transparency and trust, if You win a prize, You grant Us the right to publish Your First Name, Initial of Last Name, and City (e.g., "Aditya M. from Jaipur") on the App, Our website, and social media channels as proof of the Giveaway results. We will never publish Your full address or phone number.

If You wish to opt-out of this public announcement, You may contact Us at legal@phonewinprivatelimited.com prior to the prize draw.

e. International Data Transfers: To provide Our services, Your data may be stored and processed on secure servers located outside India (e.g., Google Firebase or AWS regions). We ensure that such transfers comply with applicable data protection laws and that Your data remains protected under the same security standards required within India.

4. LINKS TO THIRD-PARTY SITES

The Platform may link You to other third-party platforms ("Third-Party Sites") as part of the "Tasks" feature (e.g., visiting a website to earn a reward).

• We are not in any manner responsible for the security of such information or their privacy practices or content of those Third-Party Sites.

• This Privacy Policy does not govern any information provided to, stored on, or used by these Third-Party Sites.

• We recommend that when You enter a Third-Party Site, You review the Third-Party Site's privacy policy.

5. DATA RETENTION

We maintain records of Your Personal Information only till such time it is required for the Purposes, or for as long as required by applicable law.

• Active Accounts: Data is retained for as long as necessary to provide services while Your account is active.

• Deleted Accounts: If You request to delete Your account via Settings > Delete Account, Your data enters a "Soft Delete" state for 30–90 days for fraud prevention. After this period, it is permanently deleted from our servers.

• Delivery Records: Address and shipping data for delivered rewards may be retained for up to 3 years for tax and audit purposes.

6. SECURITY PRECAUTIONS

The Platform has reasonable security measures and safeguards in place to protect Your privacy and Personal Information from loss, misuse, unauthorized access, disclosure, destruction, and alteration.

• We use SSL/TLS encryption for data transmission.

• We do not store financial information (Credit/Debit Card details) as the Platform is free-to-use.

• User Responsibility: You are responsible for maintaining the confidentiality of Your login credentials.

7. YOUR RIGHTS (DPDP ACT 2023) By using the Platform, You consent to the collection and use of the information You disclose on the Platform in accordance with this Privacy Policy. As a Data Principal, You have the following rights:

• Right to Access: You have the right to request a summary of the personal data (e.g., Your saved address and task history) We hold about You. Since the current App version does not have a profile review screen, You may request this summary by emailing Our Grievance Officer.

• Right to Correction: Currently, the App does not support direct editing of Your profile or address once submitted. If You need to update Your delivery address or fix an error, please contact Us at legal@phonewinprivatelimited.com, and We will update it for You in our backend system.

• Right to Erasure: You can request the deletion of Your account and all associated data at any time. This option is available directly in the App under Settings > Delete Account.

• Right to Grievance Redressal: You have the right to file a complaint with Our Grievance Officer if You believe Your data is being misused.

• Right to Nominate: You have the right to nominate an individual to act on Your behalf in case of Your death or incapacity.

• Right to Withdraw Consent: You have the right to withdraw Your consent for data processing at any time by deleting Your account through the App settings or by contacting Our Grievance Officer. Please note that withdrawing consent may limit Your access to certain App features.

• Data Breach Notification: In the event of a data breach affecting Your personal data, We will notify affected users and relevant authorities as required under the Digital Personal Data Protection Act, 2023.

8. CHILDREN INFORMATION

We do not intentionally gather or request Personal Information from individuals under the age of 18. The Platform is intended only for users aged 18 and above. If We become aware that a child under the age of 18 has given their Personal Information, We reserve the right to delete such information and terminate the account immediately.

9. GRIEVANCE OFFICER

In accordance with the Information Technology Act, 2000 and the Digital Personal Data Protection Act, 2023, the contact details of the Grievance Officer are provided below:

• Name: Aditya Mehra

• Designation: Grievance Officer

• Company: Phonewin Private Limited

• Address: 9, Vaishali Estate, Block A, Gandhi Path West, Vaishali Nagar, Jaipur, Rajasthan, 302021, India

• Email: legal@phonewinprivatelimited.com

We are committed to answering Your questions within a reasonable time limit. Any delay in the resolution time shall be proactively communicated to You.

10. CHANGES TO THIS PRIVACY POLICY

We reserve the unconditional right to change, modify, add, or remove portions of this Privacy Policy at any time. Any changes or updates will be effective immediately. You should review this Privacy Policy regularly for changes. Your continued use of the Platform shall signify Your acceptance of the amended Privacy Policy.