Privacy Policy.

Introduction

This Privacy Policy explains how SureLocal Technologies Private Limited (“SureLocal Technologies,” “Company,” “we,” “us,” or “our”), operating under the brand name ePatang, collects, uses, discloses, and protects information obtained from visitors to our website (the “Website”) and clients who engage our marketing technology consulting and agency services (the “Services”). By using the Website or engaging our Services, you agree to the practices described in this Policy.

Company Information

Information We Collect

3.1 Information you provide directly: name, designation, company name, email address, phone number, billing and invoicing details, bank account details for refunds, and any content shared with us during an engagement (briefs, brand assets, campaign data, and access to advertising or analytics platforms you grant us).

3.2 Information collected automatically: IP address, browser type, device information, pages visited, referral source, and cookies (see Section 7).

3.3 Information from third parties: confirmations from payment processors or banks regarding receipt of funds, and publicly available information relevant to a campaign.

We do not collect full card numbers or CVV codes. International payments to us are made by direct bank wire transfer; any card-based payment option we introduce in the future will be processed by a PCI-DSS compliant third-party gateway that does not share full card data with us.

How We Use Information

• To deliver, manage, and invoice our Services
• To communicate about projects, deliverables, and support
• To comply with tax, accounting, foreign exchange, and other legal obligations, including GST export-of-services documentation and RBI/FEMA reporting handled through our bank
• To improve the Website and our Services
• For marketing communications, only where you have opted in, with an unsubscribe option in every email

Legal Basis and Applicable Law

We process personal data in accordance with the Information Technology Act, 2000; the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011; and the Digital Personal Data Protection Act, 2023 together with the Digital Personal Data Protection Rules, 2025 (collectively, “Indian Data Protection Law”). Where you are located in the European Economic Area, the United Kingdom, or another jurisdiction with its own data protection law, we will additionally honor applicable rights under that law (such as the GDPR) to the extent it applies to our processing of your data.

Disclosure of Information

We do not sell personal data. We may share information with:

• Our employees, contractors, and sub-processors, strictly on a need-to-know basis, to deliver the Services
• Our bank and payment/foreign-exchange partners, solely to process and reconcile international payments
• Our accountants, auditors, and legal advisors
• Government or regulatory authorities where required by law (for example, GST, RBI/FEMA, or a valid legal order)

We require every third party we share data with to protect it under confidentiality obligations at least as strict as this Policy.

Cookies and Tracking

The Website may use cookies and similar technologies to remember preferences, understand usage, and support analytics (for example, Google Analytics). You can control cookies through your browser settings; disabling cookies may affect some Website functionality.

International Data Transfers

Because our clients and vendors are located outside India, personal data may be transferred to, stored, and processed in countries other than your own, including India. We take reasonable steps to ensure such transfers are protected consistent with this Policy and applicable law.

Data Retention

We retain personal and project data for as long as needed to provide the Services, meet contractual commitments, and satisfy legal, tax (including statutory retention periods under GST law and the Companies Act, 2013), and accounting record-keeping requirements, after which it is securely deleted or anonymized.

Data Security

We use reasonable security practices and procedures, including access controls, encryption in transit, and restricted internal access, to protect data against unauthorized access, alteration, disclosure, or destruction. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Your Rights

Subject to applicable law, you may have the right to: access the personal data we hold about you; correct or update it; request erasure; withdraw consent where processing is based on consent; object to or restrict certain processing; and raise a grievance with us or, where applicable, the Data Protection Board of India or another supervisory authority. To exercise these rights, contact our Grievance Officer below.

Children's Privacy

Our Website and Services are intended for businesses and professionals. We do not knowingly collect personal data from individuals under 18 years of age.

Grievance Officer

In accordance with the Information Technology Act, 2000, the rules made thereunder, and the Consumer Protection (E-Commerce) Rules, 2020, the Grievance Officer for SureLocal Technologies Private Limited (ePatang) is:

The Grievance Officer will acknowledge complaints within 48 hours and resolve them within one month of receipt.

Changes to This Policy

We may update this Policy periodically. The “Effective Date” above reflects the latest revision. Continued use of the Website or Services after changes take effect constitutes acceptance of the revised Policy.

Contact Us

For questions about this Privacy Policy, contact: hello@epatang.com

SureLocal Technologies Private Limited (ePatang) — Confidential Draft