Statutory Privacy Policy & Data Protection Disclosure - Jollyfer
Statutory Compliance Statement

Privacy Policy & Data Protection Disclosure

Comprehensive Notice Pursuant to the Digital Personal Data Protection Act, 2023 (DPDPA), Information Technology Act, 2000, and Associated Rules

Effective Date: April 1, 2025 Last Legislative Review: October 2025 Version: 3.0 (DPDPA Compliant)
Data Fiduciary Faceons Internet Private Limited
E-Commerce Marketplace Jollyfer.com
Corporate CIN U82990OD2025PTC048012
Statutory Jurisdiction Bhubaneswar, Odisha, India
Statutory Notice to Data Principals:

This Privacy Policy serves as an explicit, statutory notice issued under Section 5 of the Digital Personal Data Protection Act, 2023 (DPDPA). By accessing, browsing, registering, or booking independent lifestyle, salon, grooming, photography, or wellness services via Jollyfer.com or its mobile applications, you ("Data Principal", "Customer", "User") explicitly acknowledge that you have read, understood, and unconditionally consented to the collection, storage, processing, transfer, and disclosure of your Personal Data by Faceons Internet Private Limited ("Company", "Jollyfer", "Data Fiduciary") in accordance with the terms set forth herein.

1

Legislative Framework & Corporate Status

1.1 Legislative Foundation: Faceons Internet Private Limited is committed to protecting the privacy and personal data of its users in strict accordance with applicable statutory mandates of the Republic of India, including but not limited to:

  • Digital Personal Data Protection Act, 2023 (DPDPA) and rules promulgated thereunder;
  • Information Technology Act, 2000 (Sections 43A, 72A, and Section 79 Intermediary Safe Harbor);
  • Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011;
  • Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021;
  • Consumer Protection (E-Commerce) Rules, 2020.

1.2 Designation as Data Fiduciary: Under the DPDPA, Faceons Internet Private Limited acts as a Data Fiduciary regarding the Personal Data collected directly to facilitate account management, booking processing, and platform maintenance on Jollyfer.com. Independent Third-Party Service Partners listed on the platform who receive Customer data solely for executing booked services act as independent processors or joint fiduciaries within their own operational scope.

2

Categories of Personal Data Processed

The Company collects only such Personal Data as is strictly necessary, proportionate, and required for specified, lawful purposes associated with platform operations. The categories of Personal Data collected include:

Identity & Contact Data

Full legal name, mobile phone number, email address, physical delivery/service address, gender, date of birth, and government-issued ID details (where mandated for provider onboarding or verification).

Transaction & Payment Data

Booking history, service preferences, payment gateway transaction IDs, payment mode details, invoicing records, and payout account information (for Service Partners).

Technical & Telemetry Data

Internet Protocol (IP) address, device identifiers (IMEI, MAC address), operating system, browser type, device geolocation data, access timestamps, and app usage logs.

Voluntary Disclosures

Hair/skin preferences, allergen disclosures voluntarily provided for salon/spa services, customer support correspondence, reviews, and feedback submissions.

3

Lawful Grounds & Specific Purposes of Processing

In accordance with Section 4 of the DPDPA, Personal Data shall only be processed for specified, lawful purposes for which the Data Principal has given explicit consent, or for "Certain Legitimate Uses" as provided under Section 7 of the DPDPA.

4

Consent Mechanism, Duration & Right of Withdrawal

4.1 Provision of Consent: Consent requested from the Data Principal is itemized, specific, informed, unconditional, and unambiguous. Registration on Jollyfer.com or clicking "I Agree", "Book Now", or "Sign Up" constitutes legally valid affirmative action under DPDPA Section 6.

4.2 Right to Withdraw Consent: Pursuant to Section 6(4) of the DPDPA, the Data Principal possesses the absolute right to withdraw consent for processing Personal Data at any time. Withdrawal may be executed through account setting toggles or by issuing a written request to privacy@jollyfer.com.

Legal Effect of Consent Withdrawal:

Upon receipt of a valid consent withdrawal request, the Company shall cease processing the specified Personal Data within a reasonable timeframe, except where continued storage is mandatory under applicable laws (e.g., GST invoicing records, IT Act log retention mandates). Withdrawal of consent does not affect the lawfulness of processing undertaken prior to such withdrawal, and may result in immediate termination of user account access or service fulfillment impossibility.

5

Third-Party Data Sharing, Processors & Marketplace Disclosures

Jollyfer is an e-commerce marketplace platform. To enable service fulfillment, Personal Data must be shared with third parties under valid data processing contracts adhering to Section 8 of the DPDPA:

  • Independent Third-Party Service Partners: When a Customer books a service (e.g., personal stylist, beautician, photographer, tailor, massage therapist), necessary contact and location details are shared with the assigned Service Partner strictly to enable service execution.
  • Payment Aggregators & Gateways: Financial transactions are processed via RBI-authorized payment processors. Jollyfer does not directly store complete credit/debit card numbers or UPI PINs.
  • Cloud Infrastructure & Telephony Providers: Data is hosted on secure cloud infrastructure located within the territory of India or permissible jurisdictions, and masked communication APIs are utilized for customer-provider calling.
  • Statutory Authorities: Disclosures made to law enforcement, legal courts, or regulatory bodies upon receipt of lawful orders under Indian law.
6

Processing of Children’s Personal Data & Persons with Disabilities

6.1 Minors (< 18 Years): In strict compliance with Section 9 of the DPDPA, Jollyfer does not knowingly collect, process, or track the personal data of individuals under eighteen (18) years of age without verifiable consent from a lawful parent or legal guardian.

6.2 Prohibition of Targeted Ads & Tracking: Jollyfer shall not undertake tracking, behavioral monitoring, or targeted advertising directed toward minors on its platform.

6.3 Parental Rights: A parent or guardian who discovers that a minor under their care has submitted personal data without consent may request immediate erasure by contacting the Data Protection Officer.

7

Statutory Data Principal Rights under DPDPA

Every Data Principal interacting with Jollyfer.com is guaranteed the following statutory rights under Sections 11 through 14 of the Digital Personal Data Protection Act, 2023:

Right to Access (Sec 11)

Request a summary of Personal Data being processed, identity of third parties with whom data was shared, and associated processing details.

Right to Correction & Erasure (Sec 12)

Request correction of inaccurate data, completion of incomplete fields, updating out-of-date information, or permanent erasure of personal data.

Right of Grievance Redressal (Sec 13)

Access ready, transparent, and prompt grievance redressal mechanisms provided by the Data Fiduciary regarding data protection rights.

Right to Nominate (Sec 14)

Nominate any individual who shall, in the event of death or incapacity of the Data Principal, exercise statutory data protection rights.

8

Mandatory Statutory Duties of Data Principals

Pursuant to Section 15 of the DPDPA, every Data Principal using Jollyfer.com is bound by statutory duties. Failure to comply constitutes a violation of Indian law:

Statutory Duties & Penalties under DPDPA Schedule:
  • Prohibition of False Claims: Data Principals shall not register a false, frivolous, or vexatious grievance or complaint with the Company or the Data Protection Board of India.
  • Prohibition of Impersonation: Data Principals shall not suppress material information, impersonate any other person, or provide false identity credentials when providing Personal Data.
  • Duty of Truthfulness: Data Principals are under a statutory duty to furnish only authentic and verified information when exercising rights to data correction or updating.
  • Statutory Fine: Any Data Principal who violates the statutory duties under Section 15 of the DPDPA shall be liable to a penalty which may extend up to ₹10,000 (Rupees Ten Thousand) as specified under the DPDPA Schedule.
9

Data Security Safeguards & Retention Protocols

9.1 Reasonable Security Practices: In compliance with Section 8(5) of the DPDPA and Section 43A of the IT Act, 2000, the Company implements technical, physical, and administrative safeguards, including AES-256 bit data encryption at rest and in transit, multi-factor access authentication, intrusion detection systems, and periodic vulnerability assessments.

9.2 Data Retention Policy: Personal Data is retained only for as long as necessary to fulfill the specified purpose of collection, or as required under applicable statutory retention mandates (e.g., tax regulations, IT Act log preservation rules). Upon expiration of the retention threshold or valid erasure requests, data is securely anonymized or permanently deleted.

10

Absolute Exclusion of Platform Liability & Indemnity Shield

This Privacy Policy operates in conjunction with Section 79 of the Information Technology Act, 2000. Faceons Internet Private Limited explicitly disclaims all liability regarding third-party service provider interactions:

ABSOLUTE LIMITATION OF LIABILITY & RISK ASSUMPTION:

10.1 Direct Disclosures to Service Partners: If a Data Principal voluntarily discloses sensitive personal information, medical history, skin allergy data, physical address details, or financial credentials directly to an independent Third-Party Service Partner during service fulfillment (offline or through non-platform messaging), Faceons Internet Private Limited shall bear ZERO legal or financial liability for any subsequent breach, unauthorized disclosure, misuse, theft, or tortious conduct committed by such Service Partner.

10.2 External Hyperlinks: Jollyfer.com may contain links to external third-party websites or services. The Company does not control, endorse, or verify the privacy practices of external platforms, and users click such links strictly at their own risk.

10.3 Cap on Monetary Damages: Under no circumstances shall Faceons Internet Private Limited, its directors, officers, or employees be liable for any indirect, consequential, punitive, or special damages arising out of personal data processing. In any event, the total cumulative aggregate monetary liability of the Company shall be capped strictly at the facilitation fee retained by the Company for the specific transaction, or ₹1,000 (Rupees One Thousand), whichever is lower.

11

Personal Data Breach Management & Statutory Notification Protocol

11.1 Breach Management: The Company maintains an active Incident Response Strategy to detect, contain, and remediate cybersecurity threats or unauthorized data access events.

11.2 Mandatory Statutory Reporting: In the event of a confirmed Personal Data Breach as defined under Section 8(5) of the DPDPA, the Company shall, in the prescribed form and manner, intimate the statutory Data Protection Board of India (DPBI) and affected Data Principals with details regarding the nature of the breach, potential impact, and remedial measures deployed.

12

Governing Law, Consent Managers & Dispute Resolution

12.1 Consent Manager Integration: Data Principals may manage, review, or withdraw consent through registered Consent Managers licensed by the Data Protection Board of India as and when operationalized under DPDPA framework rules.

12.2 Governing Law & Exclusive Jurisdiction: This Privacy Policy, its interpretation, and any data privacy disputes arising hereunder shall be governed exclusively by the laws of the Republic of India. Subject to initial statutory escalation to the Grievance Officer, any unresolved legal disputes shall be referred to binding arbitration under the Arbitration and Conciliation Act, 1996 in Bhubaneswar, Odisha. Subject to arbitration, the competent courts at Bhubaneswar, Odisha shall hold sole and exclusive territorial jurisdiction.

13

Statutory Data Protection Officer (DPO) & Grievance Disclosures

In accordance with Rule 3(2) of the IT (Intermediary Guidelines) Rules, 2021 and Section 13 of the DPDPA, 2023, the details of the designated Data Protection Officer (DPO) / Grievance Officer for Faceons Internet Private Limited are published below:

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