Privacy Policy for WINTOP

Effective Date: October 15, 2026  |  Last Updated: October 15, 2026  |  Applicable App: WINTOP (Android / Mobile Application)

WINTOP RISING PVT. LTD. is committed to protecting your personal privacy and safeguarding your personal information. This Privacy Policy describes how we collect, use, store, process, disclose, and protect personal and sensitive information when you download, install, access, or use the WINTOP mobile application (available on Google Play Store) or visit our website (www.wintopindia.com).

By using the WINTOP mobile application or accessing our online services, you confirm that you have read, understood, and consented to the collection and handling of your information as outlined in this Privacy Policy.

1. Overview & Scope

This Privacy Policy applies specifically to:

• The WINTOP Android Mobile Application published on Google Play.
• The official website located at https://www.wintopindia.com and associated online portal/APIs.
• Customers, distributors, registered members, retail buyers, and visitors interacting with our platforms.

This policy has been formulated in strict compliance with:

• Google Play Developer Program Policies (specifically including the User Data Policy, Permissions Policy, and Account Deletion Requirements).
• The Information Technology Act, 2000 and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (SPDI Rules).
• The Consumer Protection (Direct Selling) Rules, 2021.
• The Digital Personal Data Protection Act, 2023 (DPDPA).

2. Information We Collect

We collect only the minimum necessary information required to provide our retail, FMCG, grocery ordering, and distributor services efficiently and safely.

A. Information You Provide Voluntarily

• Personal Contact & Identity Details: Full name, gender, date of birth, mobile phone number, email address, postal address, district, state, and pin code.
• Distributor & Sponsor Details: Member ID, Sponsor ID, Upline ID, placement position (left/right) when registering for the direct selling/distributor program.
• Account Credentials: Login identifier (ID/Mobile Number) and password (securely stored in hashed/encrypted format).
• KYC & Statutory Identification (For Distributors/Sellers only): Permanent Account Number (PAN), Goods and Services Tax (GST) registration number, bank account details (account holder name, bank name, branch, account number, and IFSC code) required exclusively for statutory tax compliance (TDS deduction) and direct incentive/commission payouts in accordance with Indian regulatory requirements.
• Customer Support Communications: Messages, queries, or feedback submitted through our contact form, helpline (+91 6209086768), WhatsApp support, or email (info@wintopindia.com).

B. Information Collected Automatically

• Device & Technical Identifiers: Device manufacturer, model, operating system version, unique device identifiers (Android ID, Firebase Cloud Messaging token for push notifications), screen resolution, and network type (e.g., Wi-Fi, 4G, 5G).
• Log & Performance Data: IP address, browser type, app crash reports, system activity, and timestamps of app interactions to ensure app stability and debug crashes.
• Transaction & Order History: Products browsed, cart additions, items purchased, invoice totals, order fulfillment status, and payment confirmation status.

3. Device Permissions & Hardware Access

In order to provide core features, the WINTOP Android App may request access to certain device features. These permissions are requested on an as-needed basis with explicit user consent:

4. How We Use Your Information

We process your data only for genuine, legitimate business purposes and to fulfill legal/contractual commitments:

• Account Administration: Registering and maintaining your WINTOP distributor or customer account, verifying identity, and generating Permanent Member IDs.
• Order Processing & Delivery: Managing shopping carts, processing payments, printing GST invoices, packaging items, and shipping grocery/FMCG products to your specified doorstep address.
• Incentive Calculation & Payout: Tracking sales volume, calculating distributor commissions, applying statutory Tax Deducted at Source (TDS), and transferring authorized incentives directly to your verified bank account.
• Communication & Alerts: Sending critical order notifications, delivery status updates, account security alerts, and customer service responses via SMS, WhatsApp, or email.
• App Enhancement & Bug Resolution: Analyzing technical crash logs, diagnosing UI/UX issues, and releasing updates to improve app speed, performance, and reliability.
• Fraud Prevention & Legal Compliance: Safeguarding against identity theft, multi-account abuse, bot traffic, and complying with statutory directives issued by law enforcement or Indian courts.

5. Third-Party Sharing & Disclosures

We never sell, rent, lease, or trade your personal data to any third-party advertisers or data brokers for marketing purposes.

We disclose personal information only to the following specific, trusted service provider categories under strict confidentiality agreements:

• Payment Gateways & Banking Partners: Authorized payment processors and banking institutions (such as Axis Bank) solely to authenticate payments, verify bank accounts, and process commission disbursements.
• Courier & Logistics Partners: Delivery carriers receive your name, shipping address, and phone number exclusively to fulfill delivery of products to your address.
• SMS & Communication Providers: Certified telecom and cloud messaging gateways to deliver transactional OTPs, password recovery links, and service notifications.
• Cloud & Infrastructure Hosts: Secure database and hosting providers that maintain our IT infrastructure under strict access control and encryption standards.
• Statutory & Law Enforcement Authorities: When strictly required by applicable Indian law, court order, search warrant, government investigation, or to protect the safety, rights, and property of WINTOP, its users, or the public.

6. Account & Data Deletion Policy

How to Request Account & Data Deletion:

Users have multiple easy options to request account deletion:

Option 1: In-App Request (Recommended)

1. Open the WINTOP Mobile App on your device.
2. Log into your account using your Member ID and Password.
3. Navigate to Account / Profile > Settings > Security > Request Account Deletion.
4. Confirm your request. You will receive an immediate acknowledgment notification.

Option 2: Direct Email / Web Request

You can submit an account and data deletion request directly via email without needing to reinstall the app:

• Send an email to: info@wintopindia.com
• Use the subject line: Account and Data Deletion Request - [Your Member ID or Mobile Number]
• Include your registered Name, Mobile Number, and Member ID in the email body.
• You may also submit a request through our official contact page at Contact Us.

What Happens When You Request Deletion:

• Personal Identification Data: Your name, phone number, email address, profile picture, login credentials, and app preferences will be permanently erased or irreversibly anonymized from our active databases within 30 calendar days.
• Device Identifiers: Push notification tokens and device IDs linked to your account will be immediately disassociated and removed.
• Exceptions for Legal & Statutory Retention: In compliance with Indian commercial, taxation (GST, Income Tax TDS), and direct selling regulations, records of completed financial purchases, GST invoices, and tax audit trails will be preserved securely for the minimum statutory period required by Indian law (typically 7–8 financial years), after which they are destroyed. Such retained records are archived securely and never used for active marketing.

7. Data Retention Policy

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy:

• Active Accounts: We retain account data as long as your account remains active to provide continuous access to your dashboard, order history, and distributor benefits.
• Inactive Accounts: Accounts inactive for over 24 consecutive months without pending financial transactions may be flagged for archival or deletion after advance notification.
• Transactional Records: Transactional logs, purchase receipts, and tax records are retained strictly as required by Indian statutory laws.
• Crash & Diagnostic Logs: Anonymous telemetry and error logs are automatically deleted or aggregated within 90 days.

8. Security Practices & Measures

We have implemented reasonable, industry-standard physical, technical, operational, and administrative safeguards to protect your personal information against unauthorized access, alteration, disclosure, or destruction:

• Encryption in Transit: All communications between the WINTOP mobile app, website, and our servers are encrypted using modern Transport Layer Security (TLS/HTTPS).
• Credential Protection: Passwords are cryptographically hashed and never stored in plain readable text.
• Access Controls: Access to user data is strictly restricted on a need-to-know basis to authorized personnel bound by rigorous non-disclosure obligations.
• Network Security: Firewalls, intrusion prevention systems, and periodic security scans are deployed across our hosting infrastructure.

Please remember that no method of electronic storage or transmission over the internet is 100% impenetrable. We advise you to keep your login password confidential and never share it with anyone.

9. Children's Privacy (Google Play Families Policy & COPPA)

The WINTOP mobile application and website are designed and intended exclusively for general audiences aged 18 years of age or older. In compliance with the Indian Contract Act, 1872 and direct selling regulations, minors under the age of 18 are not eligible to register as distributors or enter into binding agreements with the Company.

We do not knowingly solicit, collect, or store personal information from children under the age of 13 (or under 18). If we become aware that we have inadvertently collected personal information from a minor without verifiable parental consent, we will promptly delete that data from our records. If a parent or guardian believes their child has provided personal information to us, please notify us immediately at info@wintopindia.com.

10. Your Privacy Rights

Subject to applicable laws (including the Digital Personal Data Protection Act, 2023), you hold the following rights regarding your personal information:

• Right to Access: You may review the personal data associated with your profile by logging into the app dashboard.
• Right to Rectification: You may request corrections to inaccurate, incomplete, or outdated personal contact details.
• Right to Erasure / Deletion: You have the right to request deletion of your account and data, as detailed in Section 6.
• Right to Withdraw Consent: You may revoke consent for non-essential communications or device permissions (camera, location, notifications) at any time via device settings.
• Right to Grievance Redressal: You have the right to register complaints regarding data privacy with our designated Grievance Officer.

11. Grievance Officer & Contact Information

In accordance with the Information Technology Act, 2000, the Rules made thereunder, and Google Play Developer Policies, the details of the designated Grievance Officer / Data Protection Contact for WINTOP are provided below:

Updates to This Privacy Policy

We reserve the right to revise or update this Privacy Policy periodically to reflect enhancements in our app, changes in technology, or statutory regulatory amendments. Any updates will become effective immediately upon posting the revised Privacy Policy on this page with an updated "Last Updated" date. We encourage you to review this page periodically.