1. INTRODUCTION

FINDERNATE ECOM PRIVATE LIMITED ("we," "us," "our," or "Company") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you use our platform, which combines social networking features with eCommerce functionality and an escrow system for secure transactions.

By accessing or using our platform, you agree to the terms of this Privacy Policy. If you do not agree with the terms of this policy, please do not access or use our services. This policy complies with the Information Technology Act, 2000, Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the Digital Personal Data Protection Act, 2023 (DPDPA).

2. INFORMATION WE COLLECT

2.1 Personal Information

We collect personal information that you provide directly to us, including:

• Account Information: Name, email address, phone number, date of birth, gender, profile picture, username, and password
• Business Information: Business name, registration details, tax identification numbers (such as GST, PAN), and business verification documents
• Financial Information: Bank account details, payment card information, UPI IDs, and transaction history
• Identity Verification: Government-issued identification documents (such as Aadhaar, PAN card, passport, driving license) for KYC compliance
• Communication Information: Messages, posts, comments, reviews, ratings, and other content you share on the platform

2.2 Transaction and Escrow Information

For transactions conducted through our platform, including those using our escrow system:

• Purchase and sale history, including product/service details, prices, and transaction dates
• Escrow transaction details, including deposit amounts, release conditions, and dispute information
• Shipping and delivery information, including addresses and tracking details
• Payment method details and transaction receipts

2.3 Social Networking Information

As a social network, we collect:

• Profile information and preferences
• Connections, followers, and social relationships on the platform
• User-generated content including posts, photos, videos, and stories
• Interactions with other users, including likes, shares, and comments
• Groups, communities, and interests you join or follow

2.4 Automatically Collected Information

When you access our platform, we automatically collect:

• Device Information: IP address, browser type, operating system, device identifiers, and mobile network information
• Usage Information: Pages viewed, features used, time spent on the platform, search queries, and click patterns
• Location Information: General location based on IP address and, with your permission, precise location from your device
• Cookies and Similar Technologies: Data collected through cookies, web beacons, and similar tracking technologies

2.5 Information from Third Parties

We may receive information about you from third-party sources, such as social media platforms (if you link your account), payment processors, identity verification services, and business partners. This information may be combined with information we collect directly from you.

3. HOW WE USE YOUR INFORMATION

We use the collected information for the following purposes:

• Account Management: To create and manage your account, authenticate your identity, and provide customer support
• Transaction Processing: To facilitate buying and selling of products, services, and businesses, including processing payments and managing the escrow system
• Escrow Services: To hold funds securely, verify transaction conditions, resolve disputes, and release payments according to agreed terms
• Social Networking Features: To enable social connections, content sharing, messaging, and community interactions
• Business Plans and Content Visibility: To provide differentiated services based on your subscription plan (Free Business, Small Business, or Corporate). Users on paid plans (Small Business and Corporate) receive enhanced visibility for their product, service, or business posts in the social media home feed. Content visibility and ranking are determined by a combination of factors including subscription level, user engagement, relevance, and our proprietary algorithms
• Premium Features: To provide paid users with exclusive features including audio and video calling capabilities through our third-party service provider Stream
• Platform Improvement: To analyze usage patterns, improve our services, develop new features, and enhance user experience
• Communication: To send transactional emails, notifications about your account, updates about transactions, and respond to your inquiries
• Marketing: To send promotional materials, personalized recommendations, and advertisements (with your consent where required)
• Security and Fraud Prevention: To detect and prevent fraudulent transactions, protect against unauthorized access, and maintain platform security
• Legal Compliance: To comply with applicable laws, regulations, legal processes, and government requests
• Trust and Safety: To verify user identities, enforce our terms of service, investigate violations, and maintain a safe marketplace

4. ESCROW SYSTEM AND DATA PROTECTION

Our escrow system is designed to protect both buyers and sellers. When you use our escrow service:

• Your payment information is encrypted and securely stored
• Transaction details are maintained in our secure database for the duration of the transaction and as required by law
• Funds are held in a segregated escrow account with our banking partners
• Transaction records are maintained for audit, dispute resolution, and regulatory compliance
• Communication between buyers and sellers within escrow transactions is monitored for security and fraud prevention
• Dispute resolution processes may require additional information and documentation from both parties

5. INFORMATION SHARING AND DISCLOSURE

We may share your information with:

5.1 With Other Users

Your profile information, listings, posts, and public content are visible to other users of the platform. When you engage in transactions, necessary contact and shipping information is shared with transaction counterparties.

5.2 Service Providers

We share information with third-party service providers who perform services on our behalf, including:

• Razorpay for payment gateway and escrow services
• Stream (https://getstream.io/) for audio and video calling features available to paid users
• Mailchimp for email communication and marketing services
• Zoho for official business email communications
• Cloud hosting providers, analytics providers, identity verification services, and customer support tools

These service providers are contractually obligated to protect your information and use it only for the purposes we specify. When you use audio/video calling features through Stream, your communications data is processed by Stream in accordance with their privacy policy available at https://getstream.io/privacy/. Email communications are handled by Mailchimp (privacy policy: https://www.intuit.com/privacy/statement/) and Zoho (privacy policy: https://www.zoho.com/privacy.html).

5.3 Financial and Banking Partners

For escrow and payment processing, we use Razorpay as our payment gateway and escrow service provider. We share necessary financial information with Razorpay, banking partners, and financial institutions. This includes information required for fund transfers, KYC compliance, and anti-money laundering checks. Your use of Razorpay's services is also subject to Razorpay's privacy policy, which can be found at https://razorpay.com/privacy/

5.4 Legal Requirements

We may disclose your information when required by law, court order, or government regulation, or when we believe disclosure is necessary to protect our rights, enforce our terms of service, investigate fraud, or respond to legal requests from law enforcement agencies.

5.5 Business Transfers

In the event of a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred to the acquiring entity as part of the business assets.

5.6 With Your Consent

We may share your information with third parties when you provide explicit consent for such sharing.

5.7 Business Plans and Subscription Tiers

FINDERNATE offers different business subscription plans that affect how your content is processed and displayed:

• Free Business Plan: Basic features with standard visibility in social media feeds
• Small Business Plan (Paid): Enhanced visibility for product, service, and business posts in the social media home feed, along with additional promotional features
• Corporate Plan (Paid): Premium visibility, priority placement in feeds, and access to exclusive features including audio/video calling capabilities

Paid subscription users receive preferential algorithmic treatment, meaning their posts about products, services, and business offerings are more likely to appear prominently in other users' home feeds. This enhanced visibility is a core benefit of paid subscriptions. Our feed algorithms consider multiple factors including subscription tier, content quality, user engagement, relevance, and recency. We collect and analyze data about subscription status and content performance to optimize this tiered visibility system.

6. DATA SECURITY

We implement comprehensive security measures to protect your information:

• Encryption: All sensitive data is encrypted in transit using TLS/SSL protocols and at rest using industry-standard encryption algorithms
• Access Controls: Strict access controls limit employee access to personal information on a need-to-know basis
• Regular Audits: We conduct regular security audits and vulnerability assessments
• Secure Infrastructure: Our servers are hosted in secure, certified data centers with physical and logical security controls
• Payment Security: We comply with Payment Card Industry Data Security Standards (PCI DSS) for handling payment information
• Monitoring: Continuous monitoring for suspicious activities and potential security breaches
• Incident Response: Established procedures for responding to security incidents and data breaches

Despite our security measures, no system is completely secure. You are responsible for maintaining the confidentiality of your account credentials and should immediately notify us of any unauthorized access to your account.

7. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law. Specifically:

• Account information is retained while your account is active and for a reasonable period thereafter for legal and business purposes
• Transaction records, including escrow transactions, are retained for 7 years as required by Indian tax and financial regulations
• Communication and social networking content may be retained based on your account settings and legal requirements
• Security logs and fraud prevention data are retained for a period necessary to protect the platform and comply with legal obligations
• After the retention period, personal information is securely deleted or anonymized

8. YOUR RIGHTS AND CHOICES

Under Indian data protection laws, you have the following rights:

8.1 Right to Access

You have the right to access and obtain a copy of your personal information that we hold. You can request this by contacting us at infofindernate@gmail.com.

8.2 Right to Correction

You can update or correct your personal information through your account settings or by contacting us. We will make reasonable efforts to ensure your information is accurate and current.

8.3 Right to Deletion (Right to be Forgotten)

You may request deletion of your personal information, subject to legal and regulatory retention requirements. Please note that deletion of your account will also remove your access to the platform and any associated content. Transaction records may be retained as required by law.

8.4 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller.

8.5 Right to Withdraw Consent

Where we process your personal information based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

8.6 Right to Object

You have the right to object to processing of your personal information for direct marketing purposes or when processing is based on legitimate interests.

8.7 Right to Nominate

Under the Digital Personal Data Protection Act, 2023, you may nominate another individual who can exercise your rights in the event of your death or incapacity.

To exercise any of these rights, please contact us at infofindernate@gmail.com. We will respond to your request within 30 days as required by law.

9. COOKIES AND TRACKING TECHNOLOGIES

We use cookies, web beacons, and similar tracking technologies to:

• Remember your preferences and settings
• Authenticate your login and maintain your session
• Analyze usage patterns and improve our services
• Deliver personalized content and advertisements
• Detect and prevent fraud

You can control cookies through your browser settings. However, disabling cookies may limit your ability to use certain features of our platform. We also use analytics services like Google Analytics, which may use cookies to collect information about your use of the platform.

10. THIRD-PARTY SERVICES AND LINKS

Our platform may contain links to third-party websites, plugins, or applications. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information. We integrate with several third-party service providers:

• Razorpay (https://razorpay.com/privacy/) for payment gateway and escrow services
• Stream (https://getstream.io/privacy/) for audio and video calling features available to paid users
• Mailchimp (https://www.intuit.com/privacy/statement/) for marketing emails
• Zoho (https://www.zoho.com/privacy.html) for business email communications

When you use these services, you will be subject to their respective terms of service and privacy policies. Other third-party services integrated into our platform, such as social media integrations and analytics tools, are governed by their respective privacy policies.

11. CHILDREN'S PRIVACY

Our platform is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you believe a child has provided personal information to us, please contact us immediately at infofindernate@gmail.com, and we will take steps to delete such information. Parents and guardians are responsible for monitoring their children's online activities.

12. INTERNATIONAL DATA TRANSFERS

While our primary operations are based in India, we may transfer your personal information to service providers located in other countries for processing and storage. When we transfer personal data internationally, we ensure appropriate safeguards are in place through standard contractual clauses, adequacy decisions, or other legally approved mechanisms to protect your information in accordance with Indian data protection laws.

13. GRIEVANCE OFFICER

In accordance with the Information Technology Act, 2000, and rules made thereunder, we have appointed a Grievance Officer to address your concerns regarding data protection and privacy:

The Grievance Officer shall respond to all grievances within 24 hours of receipt and resolve the grievance within one month from the date of receipt.

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make material changes, we will notify you by email or through a prominent notice on our platform prior to the changes taking effect. Your continued use of the platform after such modifications constitutes your acceptance of the updated Privacy Policy. We encourage you to review this policy periodically.

15. DATA PROTECTION AUTHORITY

If you are not satisfied with our response to your privacy concerns or believe we are processing your personal data in violation of applicable laws, you have the right to lodge a complaint with the Data Protection Board of India or other relevant regulatory authority.

16. CONTACT INFORMATION

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

We are committed to working with you to obtain a fair resolution of any privacy concerns.

17. ACKNOWLEDGMENT

By using the FINDERNATE platform, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with any part of this policy, you should discontinue use of our services immediately.