Privacy Policy

Tlupana India Investments IFSC Private Limited (hereinafter referred to as “Tlupana,” “we”, “our”, or “us”) is committed to maintaining trust with the visitors of our website www.tlupana.in (“Website”).

By accessing or using this Website, you acknowledge that the terms set out in this privacy policy (“Policy”) will apply to our collection, storage, use and disclosure of your personal data as a user or visitor of our Website. If you do not accept this Policy, you must not access or use the Website.

This Policy sets out details of the personal data we collect from you, how we use it and your rights in relation to such data, in accordance with the Digital Personal Data Protection Act, 2023 and the Digital Personal Data Protection Rules, 2025, as updated from time to time (“DPDP Framework”).

1. What personal data do we collect from you?

When you visit our Website, we may collect the following personal data:

• Information you provide to us – You are not required to register an account, fill out contact forms or provide personal identity credentials to browse this Website.
  Information we automatically collect – Through your use and navigation of our Website, we may automatically collect – through cookies or otherwise – certain technical identifiers. We make no attempt to link this information with the identities of individuals visiting our Website, unless an attempt to damage the Website has been detected. Such information includes:

   

  • Server log data collected through standard internet communication protocols;
  • Internet Protocol (IP) address and approximate location derived from them; and
  • Unique device and browser identifiers, including device type, operating system, screen resolution and browser version.

2. What do we do with the personal data we collect?

We process the personal data described above only for the following purposes:

• To operate and improve our Website – We use the technical data we automatically collect to monitor the performance and security of our Website, understand how visitors use it, improve the user experience, and ensure that the Website remains accessible, functional and properly rendered; and
• To ensure security and fraud prevention – We may use technical identifiers such as IP addresses to detect and investigate attempts to damage or misuse our Website.

If we wish to use your personal data for any purpose other than those set out above, we will obtain your consent before doing so.

3. Who has access to your personal data?

We may provide your technical and personal data to our affiliates and authorized third-party service providers solely for the purposes set out in this Policy, including those who assist us in hosting, securing, and maintaining our Website. Other than those who act on our behalf under strict contractual data protection terms, personal data is not sold, rented or transferred to unrelated third-parties, unless we have a legal basis to do so.

4. Where is your personal data stored and processed?

The personal data collected through the Website may be transferred to, stored and processed on servers located outside India, including in Canada and other jurisdictions where our parent entity, cloud hosting providers and technical infrastructure operate. All cross-border transfers of personal data are conducted in compliance with applicable laws, subject to appropriate organizational, technical and contractual safeguards to ensure data security and confidentiality.

5. How long do we retain your personal data?

We retain personal data only for as long as necessary to fulfil the specific processing purpose for which it was collected, or to comply with statutory legal requirements. When the relevant retention period ends, or when we receive a valid request from you to erase your personal data, we will delete it from our active systems and instruct our service providers to do the same. We may keep some information for longer where the law requires it, such as records of how we processed your data and security logs that must be kept for a minimum period, or where it is needed to establish, exercise or defend legal claims. We keep that information only as long as necessary, use it only for those purposes, and delete it once it is no longer needed.

6. Who should access our Website?

Our Website is strictly intended for individuals who are at least 18 years of age. Individuals under the age of 18 are discouraged from accessing or browsing this Website.

7. What rights do you have with respect to your personal data?

We respect your right to access and control your personal data. Under the DPDP Framework, you have rights with respect to the personal data we collect, including the right to:

• obtain information about the personal data we hold about you, the purposes for which it is processed and the entities with whom such personal data has been shared;
• correct inaccurate or incomplete personal data, or update your personal data;
• withdraw consent for processing where we rely on consent as a ground for processing your personal data;
• raise a grievance with us in respect of our processing of your personal data; and
• nominate another individual to exercise your rights on your behalf in the event of your death or incapacity.

Where we request personal data for the purposes outlined in this Policy, you may choose to decline.

To exercise any of your rights in respect of your personal data, please reach out to us using the contact details set out below.

8. Third-Party Links

Our Website may contain links to third-party websites. This Policy does not apply to those websites and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party websites you visit, as your use of those websites is at your own risk.

9. Changes to this Policy

We may update this Policy from time to time and post an updated version on the Website. Your continued use of the Website on or after the ‘Last Updated’ date constitutes your acceptance of the modified Policy. If you do not agree to any change, you must stop using the Website.

10. Contact Us

If you have any questions or concerns about your privacy in connection with our Website or relating to the collection, storage, use or disclosure of personal data by us, please contact:

Contact: info@tlupana.in

You also have the right to lodge a complaint with the Data Protection Board of India if you are not satisfied with how we have handled your personal data.