This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy. This Privacy Policy has been created with the help of the Privacy Policy Generator.
You can access this Privacy Policy within the DownXtown app under the Settings menu.
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
This Privacy Policy complies with the Digital Personal Data Protection Act, 2023 (India), ensuring your data is processed lawfully with your consent, and you have rights to access, correct, or erase your data.
For the purposes of this Privacy Policy:
Account means a unique account created for You to access our Service or parts of our Service.
Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Application refers to DownXtown, the software program provided by the Company.
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to DownXtown.
Country refers to: Uttar Pradesh, India
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Personal Data is any information that relates to an identified or identifiable individual.
Service refers to the Application.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
Social Commerce Data refers to information generated through store interactions, chats, and social media integrations within the Service.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
Email address
First name and last name
Phone number
Address, State, Province, ZIP/Postal code, City
Usage Data
Messages and communication data exchanged between buyers and sellers via the chat feature, including text, timestamps, sender user IDs, and chat room details.
Information about stores you follow or interact with, including store name, username, logo, social media links (e.g., Instagram, YouTube), Google Maps link of the store’s physical location, and Razorpay linked account ID for payment processing.
Details of orders and payments made on our platform, including purchase history and transaction data.
Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Information Collected while Using the Application
While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:
Information regarding your location
We use this information to provide location-based store recommendations and enable nearby shopping features, with your consent. This data may be uploaded to the Company’s servers and/or a Service Provider’s server or stored on Your device. Location is taken from businesses at the time of their store creation, along with their address, whereas the location of personal users/buyers/customers is taken only when using the location-based store browsing feature. When personal users first use this feature, they are asked for location permission, which they can grant permanently, once, or never. If granted permanently, permission can be removed only from the device settings.
You can enable or disable access to this information at any time, through Your Device settings.
The Company may use Personal Data for the following purposes:
To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
We may share Your personal information in the following situations:
With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You. This includes Razorpay for payment processing and AppyFlow Technologies for GST verification. In the future, we may use Google Maps API for address input, subject to their privacy policies.
For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
With Other Users: When you interact with store owners or buyers (e.g., public comments or shared store profiles), this information may be viewed by all users and may be publicly distributed outside. However, chat messages and follow actions are private, visible only to the involved parties (e.g., the store being followed knows, but others do not).
With Your consent: We may disclose Your personal information for any other purpose with Your consent.
With Social Media Platforms: If you enter social media links (e.g., Instagram, YouTube) for your store, we neither access nor share data with those platforms; these links are provided for buyer reference only.
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Currently, there is no fixed retention period for chat messages or social interaction data, as we see no reason to delete them unless a user requests account deletion. The only way to delete data is if a user contacts us to delete their account, which can be done by reaching out via the help and support option (email: abdullahkidwai3@gmail.com or phone: 9651209308). We plan to add a self-service account deletion feature later.
Data Retention Schedule
Category of Data | Retention Period | Legal / Business Basis
User Account Information (name, email, phone, address, profile data) | Retained until account deletion + 180 days | IT Rules, 2021 (intermediaries must retain data for 180 days after deletion)
Order & Transaction Data (orders, payments, refunds, invoices, UPI/bank details used in payments) | 6 years from the end of financial year | Income Tax Act (record-keeping), RBI Guidelines (audit, fraud prevention)
Business Seller Data (store profiles, tax IDs, bank account details) | As long as seller operates on platform + 6 years after exit | Income Tax Act & audit requirements
Chat / Messaging Data | Retained as long as account is active, or until user deletes conversation | User functionality; no fixed law, DPDP requires purpose-based retention
Device & Log Data (IP addresses, login logs, activity logs) | 180 days from date of collection | IT Rules, 2021
Financial & Accounting Records (GST, invoices, payout records) | 6–8 years depending on audit and company law | Companies Act, Income Tax Act
Legal Disputes / Complaints Data | Until resolution of dispute + 3 years | Limitation Act, 1963 (general limitation period)
Deletion & Anonymization
After the retention period ends, data will be securely deleted or irreversibly anonymized. Users may also request deletion under the DPDP Act; however, data required for compliance (e.g., tax records) will be retained until legally allowed.
Exceptions
Data may be retained beyond the above periods if:
Required by law enforcement or regulators.
Needed for an ongoing legal claim or investigation.
Policy Review
This policy will be reviewed annually to ensure compliance with changes in law.
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. Location data is stored in a MongoDB database hosted on AWS servers.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.
Our Service may give You the ability to delete certain information about You from within the Service. As of now, there isn’t a self-service account deletion feature, but we plan to create it later. You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us via the help and support option (email: abdullahkidwai3@gmail.com or phone: 9651209308).
Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security. Chat data is stored securely but not end-to-end encrypted. We may review chats to prevent fraud or policy violations. Other than that, the security of our database is provided by MongoDB itself. We have plans to implement additional safeguards (e.g., two-factor authentication) for seller accounts in future updates beyond the MVP.
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.
There is currently no feature that restricts users below a specific age from using the app as a buyer or customer in the MVP version. However, as a seller, there is a restriction: one can only start selling if they have a GST number, which is issued by the government to individuals above 18, and its verification is required before allowing store creation.
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services. When sellers enter social media links (e.g., Instagram, YouTube) for their store profiles, these are provided for buyer reference only, and we neither access nor share data with those platforms.
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
If you have any questions about this Privacy Policy, You can contact us:
By email: abdullahkidwai3@gmail.com
By phone number: 9651209308
We will shift to a professional email (e.g., support@downxtown.com) and number as soon as possible after the MVP testing phase. We have purchased the domain name downxtown.com and plan to build a website for future use.
Google Compliance: The rephrased section should now pass Google’s scrutiny by framing chat monitoring as a fraud and policy enforcement measure, which is a standard practice in many apps. It avoids highlighting commission enforcement, reducing the risk of being flagged.
Review: Please confirm if the revised wording ("to prevent fraud or policy violations") accurately reflects your intent. If you’d like to adjust it further (e.g., specify types of fraud), let me know.
Submission: Host this updated policy at a public URL (e.g., downxtown.com/privacy) and link it in the Play Console under Store Listing > Privacy Policy URL. Submit with your app, expecting a 1-3 day review.
Future Considerations: As you move beyond the MVP (e.g., adding encryption or account deletion), update this section and notify users.
This adjustment maintains transparency while aligning with Google’s expectations. Let me know if you need further tweaks or assistance!