This Privacy Policy describes how Pluckwalk Technologies Private Limited, a company incorporated under the Companies Act, 2013 and operating under the brand name “The Heavenly Group” (“Company”, “we”, “us” or “our”), collects, uses, stores, discloses, and protects Personal Data of users in accordance with the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and applicable Indian laws.

By accessing or using our website, mobile application, or services (collectively, the “Services”), you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your Personal Data as described herein.

DEFINITIONS

“Data Principal” means the individual to whom the Personal Data relates.

“Data Fiduciary” means Pluckwalk Technologies Private Limited.

“Data Processor” means any third party that processes Personal Data on behalf of the Company.

“Personal Data” means any data about an individual who is identifiable by or in relation to such data.

“Consent” means a freely given, specific, informed, unconditional and unambiguous indication of the Data Principal’s agreement to the processing of their Personal Data.

COLLECTION OF PERSONAL DATA

We may collect Personal Data through the following lawful sources:

Directly from you, when you register on our platform, submit forms, communicate with us, or use our Services.

From Channel Partners, contractors, brokers, or other business partners with whom we have entered into valid arrangements such as referral agreements, provided that such parties represent and confirm that they have obtained the necessary consent or lawful authority to share such Personal Data with us.

Automatically, through cookies, analytics tools, and similar technologies when you interact with our website or platform.

Third-Party Data Disclaimer

Where Personal Data is received by the Company from third parties such as channel partners, referral partners, or other intermediaries, the Company relies on such third parties to have collected and shared the Personal Data in compliance with applicable data protection laws. The Company shall not be responsible for any unauthorised, excessive, or unlawful collection of Personal Data by such third parties prior to receipt by the Company. Upon receipt, the Company shall process such Personal Data in accordance with this Privacy Policy and applicable law.

PURPOSE AND LAWFUL BASIS OF PROCESSING

We process Personal Data strictly in accordance with the DPDP Act on the basis of:

Consent provided by the Data Principal; and/or

Legitimate uses permitted under the DPDP Act, including but not limited to:

Performance of a contract or provision of requested services

Compliance with legal or regulatory obligations

Prevention of fraud, misuse, or unlawful activity

Responding to queries, grievances, or customer support requests

Personal Data shall not be processed for purposes that are incompatible with those stated above.

CONSENT MECHANISM

Consent is obtained through clear affirmative action such as selecting a checkbox, submitting forms, or continued use of Services after being presented with a consent notice.

You may withdraw your consent at any time by writing to us at info@TheHeavenlyGroup.com. Withdrawal of consent shall not affect the lawfulness of processing prior to such withdrawal.

DISCLOSURE AND DATA PROCESSORS

We may share Personal Data with:

Service providers and Data Processors, including technology partners, analytics providers, customer engagement platforms, and communication service providers, engaged to perform services on our behalf.

Auditors, consultants, and professional advisors for compliance, governance, financial reporting, and audit purposes.

Regulatory or government authorities where required under applicable law

Successors or assignees in the event of a merger, acquisition, restructuring, or transfer of business.

Such Data Processors may have limited access to Personal Data solely for performing services on our behalf and are contractually bound to process such data strictly in accordance with applicable data protection laws and our instructions.

All Data Processors are required to implement appropriate technical and organisational safeguards and shall not use Personal Data for any purpose other than providing services to the Company.

DATA RETENTION

We retain Personal Data for as long as it is necessary to fulfil the purposes for which it was collected, including for the lifetime of the Company, subject to applicable legal, regulatory, audit, accounting, and compliance requirements.

Personal Data may be retained beyond the active business relationship for purposes such as:

Statutory, regulatory, or tax compliance

Internal or external audits

Legal proceedings or dispute resolution

Prevention of fraud and misuse

Maintenance of historical business records

Where retention is no longer required under applicable law, such data shall be securely deleted, anonymised, or archived in accordance with our internal data retention policies.

DATA SECURITY

We implement reasonable security safeguards, including technical and organisational measures, to protect Personal Data from unauthorised access, disclosure, alteration, or destruction.

However, no system is completely secure and we do not guarantee absolute security.

CHILDREN’S DATA

Our Services are not directed at individuals below the age of 18. Personal Data of children shall be processed only with verifiable consent of a parent or lawful guardian, in accordance with the DPDP Act. We do not engage in tracking, profiling, or targeted advertising directed at children.

DATA PRINCIPAL RIGHTS

Subject to applicable law, you have the right to:

Obtain information about processing of your Personal Data

Seek correction or erasure of your Personal Data

Withdraw consent

Register a grievance with the Company

Nominate another individual to exercise your rights in the event of death or incapacity

Requests may be submitted to info@TheHeavenlyGroup.com.

GRIEVANCE REDRESSAL

In accordance with the DPDP Act, grievances may be addressed to:

Grievance Officer
Name: Mr. Jayant Choudhury
Email: info@TheHeavenlyGroup.com.

CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. Material changes shall be communicated through the website or other appropriate means. Continued use of the Services shall constitute acknowledgment of the updated Policy.

CONSENT NOTICE

By clicking “I Agree”, submitting your details, or using our Services, you consent to the collection and processing of your Personal Data by Pluckwalk Technologies Private Limited for the purposes stated in the Privacy Policy.

You may withdraw your consent at any time by writing to info@TheHeavenlyGroup.com.