PRIVACY POLICY

1. INTRODUCTION

1.1 This Privacy Policy describes how Matero Commerce Private Limited (“Site”, “we”, “us” or “our”) collects, uses, stores and discloses your personal information when you visit or use our Site, access or use our services, make a purchase from us, or otherwise communicate with us (collectively referred to as the “Services”).

1.2 For the purposes of this Privacy Policy, the terms “you” and “your” shall mean any individual who accesses or uses the Services, including a customer, website visitor, user, or any other individual whose personal information is collected by us in connection with the Services.

1.3 Please read this Privacy Policy carefully to understand our practices regarding your personal information. By accessing or using any of the Services, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use and disclosure of your information as described herein. If you do not agree with the terms of this Privacy Policy, please do not access or use the Services.

2. CHANGES TO THIS PRIVACY POLICY

2.1 We may update or modify this Privacy Policy from time to time to reflect changes in our business practices, Services, technologies, or for operational, legal, regulatory or other legitimate reasons.

2.2 Any revised version of this Privacy Policy shall be posted on the Site. We may also update the “Last Updated” date and take such additional steps as may be required under applicable law.

2.3 You are advised to review this Privacy Policy periodically to remain informed about how we collect, use and protect your personal information.

3. HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION

3.1 In order to provide and improve the Services, we collect and process personal information about you from various sources, depending upon the manner in which you interact with our Site and use our Services.

3.2 The nature and extent of information collected may vary depending upon your interaction with us, including whether you visit our Site, create an account, place an order, communicate with us, or otherwise use our Services.

3.3 In addition to the specific purposes described in this Privacy Policy, we may use the information collected from you for the following purposes:

(a) to communicate with you and respond to your queries or requests;
(b) to provide, operate, maintain and improve the Services;
(c) to process and fulfil orders and transactions;
(d) to comply with applicable legal and regulatory obligations;
(e) to enforce our applicable terms and conditions and other policies; and
(f) to protect, establish or defend the rights, property and interests of the Site, our users or other persons.

4. PERSONAL INFORMATION WE COLLECT

4.1 The type of personal information we collect depends upon how you interact with our Site and use our Services.

4.2 For the purposes of this Privacy Policy, “Personal Information” means information that identifies, relates to, describes, or can reasonably be associated with you.

4.3 The categories and specific types of Personal Information that we may collect are set out below.

5. INFORMATION COLLECTED DIRECTLY FROM YOU

5.1 We may collect Personal Information that you voluntarily provide to us when you use our Services, place an order, create an account, communicate with us, or otherwise interact with the Site.

5.2 Such information may include, without limitation:

(a) Basic Contact Details: Your name, residential or billing address, telephone number and email address;
(b) Order Information: Your name, billing address, shipping address, payment confirmation details, email address and telephone number;
(c) Account Information: Your username, password, security questions and other information required for creating or maintaining your account;
(d) Shopping Information: Information relating to products or items that you view, purchase, place in your shopping cart, save or add to your wishlist; and
(e) Customer Support Information: Information that you voluntarily provide while communicating with us or seeking customer support, including the contents of messages, enquiries, complaints or other communications submitted through the Services.

5.3 Certain features or functionalities of the Services may require you to provide specific Personal Information. You may choose not to provide such information; however, refusal to provide information that is necessary for a particular feature may prevent you from accessing or using such feature or functionality.

6. INFORMATION COLLECTED THROUGH COOKIES AND SIMILAR TECHNOLOGIES

6.1 We may automatically collect certain information regarding your interaction with our Services (“Usage Data”) through cookies, pixels and other similar technologies (collectively referred to as “Cookies”).

6.2 Usage Data may include information relating to the manner in which you access and use our Site and account, including information regarding your device, browser, operating system, network connection, Internet Protocol (“IP”) address and other information relating to your interaction with the Services.

6.3 Cookies and similar technologies may be used to remember your preferences and actions, understand how users interact with our Site, analyse usage patterns, improve the functionality of the Site and provide and optimise our Services.

7. INFORMATION OBTAINED FROM THIRD PARTIES

7.1 We may receive or obtain Personal Information about you from third parties, including vendors, service providers and other business partners who collect or process information on our behalf.

7.2 Such third parties may include:

(a) companies and service providers that support the operation of our Site and Services, including Shopify;
(b) payment processors and payment service providers who collect and process payment-related information, including bank account details, credit or debit card information and billing address, for the purpose of processing payments, fulfilling orders and providing products or services requested by you; and
(c) third-party service providers and partners who may automatically collect information when you visit our Site, open or click on emails sent by us, interact with our Services or advertisements, including through pixels, web beacons, software development kits, third-party libraries and Cookies.

7.3 Any information obtained from third parties shall be handled in accordance with this Privacy Policy, subject to applicable law.

7.4 To the extent permitted by applicable law, we are not responsible or liable for the accuracy, completeness or reliability of information provided by third parties, nor are we responsible for the privacy policies, practices or procedures of such third parties.

8. PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION

8.1 We may collect, use and process your Personal Information for the following purposes:

(a) Providing Products and Services: We use your Personal Information to provide and administer the Services and to perform our obligations in connection with transactions with you, including processing payments, fulfilling and delivering orders, sending notifications relating to your account, purchases, returns, exchanges or other transactions, creating and managing your account, arranging shipping, facilitating returns and exchanges, and enabling you to post reviews.

(b) Marketing and Advertising: We may use your Personal Information for marketing and promotional purposes, including sending marketing, advertising and promotional communications by email, text message or postal mail, and displaying advertisements relating to products or services. This may include using Personal Information to better tailor the Services and advertisements displayed on our Site or other websites.

(c) Security and Fraud Prevention: We may use Personal Information to detect, investigate, prevent or take appropriate action in relation to suspected fraudulent, illegal, unauthorised or malicious activities.

(d) Account Security: Where you create an account with us, you are responsible for maintaining the confidentiality and security of your account credentials. You should not share your username, password or other account access information with any third party. If you believe that your account or credentials have been compromised, you should contact us immediately.

(e) Communicating with You: We may use your Personal Information to communicate with you, provide customer support, respond to enquiries, resolve complaints and improve our Services and our relationship with you.

9. COOKIES

9.1 Like many websites, we use Cookies and similar technologies on our Site.

9.2 For specific information regarding the Cookies used in connection with Shopify-powered stores, you may refer to Shopify’s applicable cookie information and policies.

9.3 We use Cookies to operate and improve our Site and Services, including to remember your actions and preferences, conduct analytics and better understand how users interact with the Services.

9.4 We may also permit third-party service providers and other third parties to use Cookies on our Site for purposes including tailoring services, products and advertisements on our Site and other websites.

9.5 Most web browsers automatically accept Cookies by default. However, you may configure your browser settings to remove or reject Cookies.

9.6 Please note that removing or blocking Cookies may adversely affect your user experience and may cause certain features or functionalities of the Services to operate incorrectly or become unavailable.

9.7 Blocking Cookies may also not completely prevent the sharing or collection of information by third parties, including advertising partners, where such collection is otherwise permitted.

10. DISCLOSURE OF PERSONAL INFORMATION

10.1 In certain circumstances, and subject to applicable law and this Privacy Policy, we may disclose your Personal Information to third parties for legitimate business, operational, contractual, legal or other permitted purposes.

10.2 Such disclosures may include:

(a) Service Providers and Vendors: We may disclose Personal Information to vendors, contractors and third-party service providers who perform services on our behalf, including IT management, payment processing, data analytics, customer support, cloud storage, order fulfilment and shipping services;

(b) Business and Marketing Partners: We may disclose Personal Information to business and marketing partners, including Shopify, where necessary to provide Services and facilitate advertising or promotional activities. Such third parties may process your information in accordance with their respective privacy notices and policies;

(c) At Your Direction or With Your Consent: We may disclose certain Personal Information when you specifically direct or request us to do so, or where you otherwise provide consent, including for purposes such as shipping products or using social media widgets or login integrations;

(d) Affiliates and Corporate Group: We may share Personal Information with our affiliates or other entities within our corporate group where reasonably necessary for legitimate business purposes and the operation and management of our business;

(e) Business Transactions: We may disclose Personal Information in connection with an actual or proposed business transaction, including a merger, acquisition, restructuring, sale of assets, financing, bankruptcy or similar transaction;

(f) Legal and Regulatory Requirements: We may disclose Personal Information where required or permitted by applicable law, regulation, court order, legal process, subpoena, search warrant or other lawful request; and

(g) Protection of Rights and Interests: We may disclose Personal Information where reasonably necessary to enforce applicable terms and conditions, investigate suspected violations, or protect, establish or defend the rights, property, safety or interests of the Site, our users or other persons.

11. CATEGORIES OF PERSONAL INFORMATION DISCLOSED

11.1 During the preceding twelve (12) months, we may have disclosed certain categories of Personal Information and sensitive Personal Information, where applicable, for the purposes described under the sections titled “How We Collect and Use Your Personal Information” and “How We Disclose Personal Information.”

11.2 The categories of information disclosed may include information relating to contact details, order and transaction information, account information, shopping information, customer support communications, Usage Data and other information collected through Cookies and similar technologies, depending upon the nature of the interaction and the purpose for which such information was collected.

11.3 Any disclosure of Personal Information shall be undertaken subject to applicable law, contractual requirements and the terms of this Privacy Policy.

Category	Categories of Recipients
• Identifiers such as basic contact details and certain order and account information • Commercial information such as order information, shopping information and customer support information • Internet or other similar network activity, such as Usage Data	• Vendors and third parties who perform services on our behalf (such as Internet service providers, payment processors, fulfillment partners, customer support partners and data analytics providers) • Business and marketing partners • Affiliates

We do not use or disclose sensitive personal information for the purposes of inferring characteristics about you.

We have “sold” and “shared” (as those terms are defined in applicable law) personal information over the preceding 12 months for the purpose of engaging in advertising and marketing activities, as follows.

Category of Personal Information	Categories of Recipients
Identifiers such as basic contact details and certain order and account information	Business and marketing partners
Commercial information such as records of products or services purchased and shopping information	Business and marketing partners
Internet or other similar network activity, such as Usage Data	Business and marketing partners

12. USER-GENERATED CONTENT

12.1 The Services may enable you to post, submit or otherwise provide product reviews, comments, photographs and other user-generated content (“User-Generated Content”).

12.2 If you choose to submit or post User-Generated Content in any public or publicly accessible area of the Services, such content may be visible and accessible to the general public.

12.3 You acknowledge and understand that we do not control who may access, view, copy, use, share or otherwise process information that you voluntarily make available to others through public areas of the Services.

12.4 Accordingly, we cannot guarantee that any person who has access to such information will respect your privacy or maintain the confidentiality or security of such information.

12.5 To the maximum extent permitted by applicable law, we shall not be responsible or liable for the privacy or security of any information that you voluntarily make publicly available through the Services, or for the accuracy, use or misuse of information that you disclose to or receive from third parties.

13. THIRD-PARTY WEBSITES AND LINKS

13.1 Our Site may contain links to websites, applications, platforms or other online services operated or controlled by third parties.

13.2 If you choose to access or follow any link to a website or online platform that is not affiliated with or controlled by us, you should independently review the privacy policies, security policies, terms and conditions and other applicable policies of such third-party websites or platforms before providing any Personal Information or using their services.

13.3 We do not guarantee and, to the maximum extent permitted by applicable law, shall not be responsible or liable for the privacy, security, accuracy, completeness or reliability of any third-party website, application, platform or online service, or for any information, content, products or services available through such third-party websites or platforms.

13.4 Information that you voluntarily provide through public or semi-public forums, venues or platforms, including information shared through third-party social networking platforms, may be accessible to other users of the Services and/or users of such third-party platforms and may be used by us or third parties without limitation, subject to the applicable terms and privacy policies of such platforms.

13.5 The inclusion of any third-party links on our Site does not, by itself, constitute or imply any endorsement, sponsorship, recommendation or approval of the content, products, services, owners or operators of such third-party websites or platforms, except where expressly disclosed through the Services.

14. CHILDREN’S DATA

14.1 The Services are not intended for use by children, and we do not knowingly collect Personal Information from children.

14.2 If you are a parent or legal guardian and believe that a child has provided us with Personal Information without appropriate consent, you may contact us using the contact details provided in this Privacy Policy and request that such information be deleted, subject to applicable law.

14.3 As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we “share” or “sell”, as such terms may be defined under applicable privacy laws, the Personal Information of individuals under sixteen (16) years of age.

15. SECURITY AND RETENTION OF YOUR INFORMATION

15.1 We take reasonable and appropriate measures to protect the Personal Information in our possession or control against unauthorised access, use, alteration, disclosure, loss or destruction, subject to the nature of the information and applicable legal requirements.

15.2 However, you acknowledge that no security measures are completely secure or impenetrable, and we cannot guarantee the absolute or “perfect” security of your Personal Information.

15.3 Information transmitted to us through electronic or other communication channels may not be completely secure while in transit. Accordingly, we recommend that you do not use unsecured channels to communicate sensitive, confidential or highly personal information to us.

15.4 The period for which we retain your Personal Information may vary depending upon several factors, including whether such information is required to maintain your account, provide or improve the Services, process or fulfil transactions, comply with applicable legal or regulatory obligations, resolve disputes, prevent fraud, enforce our agreements, terms and policies, or otherwise fulfil legitimate business purposes.

15.5 We may retain Personal Information for as long as reasonably necessary for the purposes for which it was collected, or for such longer period as may be required or permitted by applicable law.

16. SPECIAL DISCLOSURE FOR MATERО COMMERCE PRIVATE LIMITED APP USERS

16.1 If you use the Matero Commerce Private Limited mobile application (“App”), we may collect and process additional information for the purpose of facilitating, managing and improving delivery-related Services.

16.2 In particular, the App may collect precise location information, including GPS and network-based location data, where required to enable core App functionalities.

16.3 Such location information may be collected and used for the following purposes:

(a) Order Dispatching: To identify and allocate delivery partners located near the relevant pickup location for the purpose of facilitating delivery;

(b) Live Tracking: To enable customers and our operations team to track the progress and status of an active delivery;

(c) Distance Calculation: To calculate delivery charges, delivery fees, payouts or other applicable amounts based on the distance travelled;

(d) Background Location Access: The App may collect location information while the App is closed or not actively in use, including in the background, where necessary to facilitate order assignment, delivery tracking and related functionalities. This enables delivery partners to receive order requests while the App is running in the background and allows customers and our operations team to receive continuous updates regarding an active delivery.

16.4 You may stop or restrict location tracking at any time by going offline within the App or by adjusting the location permissions or settings of your device. However, disabling location access or going offline may prevent you from receiving new delivery requests or from using certain delivery-related functionalities of the App.

16.5 Device Information: We may collect information regarding the mobile device used to access the App, including the device model, operating system version and other relevant technical information, for purposes including maintaining App stability, troubleshooting technical issues, providing customer or technical support and improving the App.

17. YOUR RIGHTS AND CHOICES

17.1 Depending upon your location and the applicable privacy laws, you may have some or all of the rights set out below in relation to your Personal Information.

17.2 These rights are not absolute and may apply only in certain circumstances. In certain cases, we may be permitted or required by applicable law to decline or limit your request.

17.3 Subject to applicable law, your rights may include:

(a) Right to Access / Know: You may have the right to request access to the Personal Information that we hold about you, including information concerning how we collect, use and disclose such information;

(b) Right to Delete: You may have the right to request deletion of Personal Information maintained by us, subject to applicable legal exceptions and retention requirements;

(c) Right to Correct: You may have the right to request correction or rectification of inaccurate or incomplete Personal Information maintained by us;

(d) Right to Data Portability: In certain circumstances, you may have the right to receive a copy of your Personal Information maintained by us and, where legally applicable, request that such information be transferred to another third party;

(e) Right to Opt Out of Sale, Sharing or Targeted Advertising: Depending upon applicable privacy laws, you may have the right to direct us not to “sell” or “share” your Personal Information, or to opt out of the processing of your Personal Information for purposes constituting “targeted advertising” under applicable law. Where applicable, if you visit our Site with the Global Privacy Control (“GPC”) opt-out preference signal enabled, we may treat such signal as a request to opt out of the “sale” or “sharing” of Personal Information for the relevant device and browser, subject to applicable law;

(f) Right to Limit or Opt Out of Use and Disclosure of Sensitive Personal Information: Where applicable, you may have the right to direct us to limit our use and/or disclosure of Sensitive Personal Information to purposes permitted under applicable privacy laws;

(g) Right to Restrict Processing: Where applicable, you may have the right to request that we restrict or limit the processing of your Personal Information;

(h) Right to Withdraw Consent: Where we rely upon your consent as the legal basis for processing your Personal Information, you may have the right to withdraw such consent, subject to applicable law and the consequences of such withdrawal;

(i) Right to Appeal: Where applicable, you may have the right to appeal our decision to decline or limit your request. Any such appeal may be submitted by responding to our communication denying or limiting your request or by contacting us using the details provided below; and

(j) Managing Communication Preferences: We may send you promotional or marketing communications. You may opt out of receiving such communications at any time by using the unsubscribe mechanism provided in the relevant communication. Please note that even if you opt out of promotional communications, we may continue to send you non-promotional communications relating to your account, orders, transactions, security, Services or other necessary matters.

18. EXERCISING YOUR RIGHTS

18.1 You may exercise any of the rights available to you under applicable law by using the relevant mechanism provided on our Site or by contacting us through the contact details provided in this Privacy Policy.

18.2 We will not discriminate against you for exercising any privacy rights available to you under applicable law.

18.3 In order to protect your Personal Information and prevent unauthorised access, we may require you to provide certain information to verify your identity before processing or providing a substantive response to your request. Such verification information may include your email address, account information or other information reasonably necessary for authentication.

18.4 Where permitted by applicable law, you may designate an authorised agent to submit a request on your behalf. Before processing a request submitted by an authorised agent, we may require appropriate evidence that you have authorised such person to act on your behalf and may also require you to independently verify your identity with us.

18.5 We shall endeavour to respond to valid requests within the time period prescribed by applicable law.

19. SHOPIFY ADVERTISING SERVICES

19.1 We may use advertising and related services provided by Shopify, including services such as Shopify Audiences, to assist in personalising and improving the advertising that may be displayed to you on third-party websites.

19.2 Where applicable, you may be able to restrict or opt out of the use of your Personal Information for such advertising services in accordance with the options and mechanisms made available by Shopify and/or applicable law.

19.3 You may also contact us using the details provided below if you have any questions regarding the use of your Personal Information for advertising or related purposes.

20. COMPLAINTS AND GRIEVANCES

20.1 If you have any complaint, concern or grievance regarding the manner in which we collect, use, disclose, store or otherwise process your Personal Information, you may contact us using the contact details provided in this Privacy Policy.

20.2 We shall endeavour to review and respond to your complaint within the time period prescribed by applicable law.

20.3 If you are not satisfied with our response, then, depending upon your location and applicable law, you may have the right to appeal our decision or lodge a complaint with the relevant data protection, privacy or regulatory authority.

21. INTERNATIONAL USERS AND CROSS-BORDER TRANSFERS

21.1 Depending upon the nature of the Services and the location of our service providers, business partners and other entities with whom we work, your Personal Information may be transferred to, stored in, or processed in a country other than the country in which you reside, including the United States.

21.2 Your Personal Information may also be processed by our employees, contractors, service providers, business partners and other authorised third parties located in such countries.

21.3 Where applicable law requires specific safeguards for the transfer of Personal Information across borders, we shall take reasonable steps to comply with such requirements.

21.4 Where Personal Information is transferred from the European Economic Area or the United Kingdom to a jurisdiction that has not been recognised as providing an adequate level of protection, we may rely upon legally recognised transfer mechanisms, including the European Commission’s Standard Contractual Clauses or equivalent contractual mechanisms issued or recognised by the competent authority of the United Kingdom, as applicable.

21.5 The safeguards applicable to any international transfer shall depend upon the jurisdiction from which the information is transferred, the jurisdiction to which it is transferred and the requirements of applicable law.

22. CONTACT INFORMATION

22.1 If you have any questions, concerns, requests or complaints regarding this Privacy Policy or our privacy practices, you may contact us using the information provided below.

22.2 Our contact information is as follows:

Trade Name: Matero Commerce Private Limited

Legal Name: ______________________________

Warehouse Address: ______________________________

Registered Address: ______________________________

Phone: ______________________________

Email: ______________________________

22.3 For privacy-related requests, complaints or grievances, please clearly mention the nature of your request or complaint and provide sufficient information to enable us to identify and appropriately respond to the same.

23. EFFECTIVE DATE

23.1 This Privacy Policy shall become effective from __________________ (“Effective Date”) and shall remain in effect until amended, replaced or withdrawn by us in accordance with applicable law.

23.2 The “Last Updated” date displayed on the Site shall indicate the date on which this Privacy Policy was most recently revised.