PRIVACY POLICY KINMIN a brand of Subhanshu Food Products LLP Effective Date 01-09-2026 Last Updated 01-09-2026 Applicable Law Digital Personal Data Protection Act, 2023 & Rules, 2025; Information Technology Act, 2000 Table of Contents 1. Scope of this Policy 2. Personal Data We Collect 3. How We Collect Your Personal Data 4. Purposes for Which We Use Your Personal Data 5. Consent 6. Other Lawful Grounds for Processing 7. Children's Personal Data 8. Cookies and Similar Technologies 9. Disclosure and Sharing of Personal Data 10. Cross-Border Transfer of Personal Data 11. Data Retention 12. Data Security 13. Data Breach Notification 14. Your Rights as a Data Principal 15. How to Exercise Your Rights 16. Grievance Redressal Mechanism 17. Third-Party Links 18. Changes to this Policy 19. Governing Law and Jurisdiction 20. Contact Us Subhanshu Food Products LLP (“Company”, “KINMIN”, “we”, “us”, or “our”), a limited liability partnership incorporated under the Limited Liability Partnership Act, 2008, having its registered office at New Balajee colony, Opp Nayan Bharti School,Vishnupuri Hazaribagh, Jharkhand, India (“Company”), operates the KINMIN brand and is committed to protecting the privacy of individuals who visit or interact with our website at www.kinmin.co.in (the “Website”). This Privacy Policy (“Policy”) explains what personal data we collect, why we collect it, how we use, share, and safeguard it, and the rights available to you as a Data Principal. This Policy is framed in accordance with the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and the Digital Personal Data Protection Rules, 2025 made thereunder, read together with the applicable provisions of the Information Technology Act, 2000 and the rules framed thereunder, including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, to the extent applicable. By accessing or using the Website, you agree to the collection, use, and disclosure of your personal data in accordance with this Policy. If you do not agree with this Policy, please do not access or use the Website. This Policy should be read together with our Terms and Conditions of Use. In the event of any conflict between the two documents on any matter relating to the processing of personal data, this Policy shall prevail. 1. Scope of this Policy This Policy applies to personal data collected through the Website, including through our contact, enquiry, distributor/vendor, and career forms, newsletter sign-up, contests or promotional campaigns, and customer support correspondence that references this Policy. This Policy does not apply to. (a) personal data collected by us offline, other than where such data is subsequently linked to your use of the Website; or (b) any third-party website, application, or social media platform that may be linked to or from the Website, even if it displays the KINMIN brand, please see Section 17 (Third-Party Links). 2. Personal Data We Collect Depending on how you interact with the Website, we may collect the following categories of personal data. • Identity and contact data. your name, email address, phone number, postal/delivery address, and, if you choose to share it (for example, for birthday offers), your date of birth. • Account data. where the Website offers account registration, your username and password (stored in encrypted/hashed form), and your order or enquiry history. • Transaction data. details of any order placed and the payment confirmation/transaction reference number generated by our payment gateway. We do not collect or store your full card number, CVV, or net-banking credentials; these are handled directly by our PCI-DSS compliant payment gateway partner(s). • Enquiry and communication data. the content of any message you send us through a contact form, email, phone call, live chat, or social media. • Business enquiry data. where you submit a distributor, vendor, or franchise enquiry. your business name, GSTIN/PAN, and business address. • Technical and usage data. your IP address, browser type and version, device type, operating system, pages viewed, time spent on the Website, referring/exit pages, and an approximate location derived from your IP address. • Marketing preferences. your newsletter subscription status and any consents you have given for promotional communication. • Contest and promotion data. entries you submit (such as photographs, captions, or social media handles) if you participate in a contest or promotional campaign run by the Company. We do not intentionally collect sensitive personal data, such as health records, biometric data, financial account details, or information revealing caste, religion, or sexual orientation, through the Website. If a future feature requires such data, we will provide a separate, specific notice and obtain your explicit consent before collecting it. 3. How We Collect Your Personal Data • Directly from you. when you register an account, place an order, fill in a contact/enquiry/careers/distributor form, subscribe to our newsletter, participate in a contest, or contact our customer care team. • Automatically. through cookies and similar tracking technologies when you browse the Website (see Section 8, Cookies). • From third parties. for example, confirmation of a successful transaction from our payment gateway (without receiving your card details), aggregate insights from our analytics providers, and, where a “sign in with” facility is offered, basic profile information from that third-party provider. 4. Purposes for Which We Use Your Personal Data We use your personal data to. • process and fulfil your orders and provide related customer support; • create and manage your account, where applicable; • respond to your enquiries, feedback, and complaints; • send order confirmations, shipping updates, and other service-related communications; • send promotional and marketing communications where you have opted in, and allow you to opt out at any time; • conduct contests, surveys, and promotional campaigns that you choose to participate in; • improve the Website, our products, and your overall experience, including through analytics; • detect, prevent, and investigate fraud, unauthorised transactions, and misuse of the Website; • comply with our obligations under applicable law, including tax, accounting, and consumer-protection requirements; and • evaluate distributor, vendor, or career enquiries submitted through the Website. 5. Consent Where we rely on your consent to process personal data, we will, in accordance with Section 5 of the DPDP Act, give you clear notice describing the personal data being collected and the purpose of processing, in English and, where feasible, in any of the languages listed in the Eighth Schedule to the Constitution of India, before or at the time of collection. In accordance with Section 6 of the DPDP Act, your consent will be free, specific, informed, unconditional, and unambiguous, given through clear affirmative action (such as ticking a checkbox), and limited to the personal data necessary for the specified purpose. You may withdraw your consent at any time, and the process for doing so will be as simple as the process by which you gave it, as required under Section 6(4) of the DPDP Act. To withdraw consent, please write to our Grievance Officer using the contact details in Section 20. Withdrawing consent will not affect the lawfulness of any processing already carried out, and may affect our ability to provide you with certain features, products, or services. 6. Other Lawful Grounds for Processing In addition to consent, in accordance with Section 7 of the DPDP Act, we may process your personal data without separate consent where. (a) you have voluntarily provided your personal data to us for a specified purpose and your action indicates consent to its use for that purpose (for example, sharing your phone number so that we can call you back); or (b) processing is necessary to comply with any judgment, decree, or order of a court or tribunal, or with any other law for the time being in force. 7. Children's Personal Data We recognise the special protections owed under Section 9 of the DPDP Act to the personal data of a “child”. any individual below the age of 18 years. Where personal data appears to have been submitted by a child without the verifiable consent of a parent or lawful guardian, we will take reasonable steps to verify such consent and, where it cannot be verified, to delete the child's personal data. We do not knowingly carry out tracking, behavioural monitoring, or targeted advertising directed at children, and we do not process children's personal data in any manner likely to cause detriment to their wellbeing. 8. Cookies and Similar Technologies The Website uses cookies and similar tracking technologies. We use the following broad categories. • Strictly necessary cookies. required for core functionality of the Website, such as maintaining your session or shopping cart. • Functional/preference cookies. remember choices you make (such as language) to personalise your experience. • Analytics/performance cookies. help us understand how visitors use the Website (for example, through Google Analytics), so we can improve it. • Advertising/targeting cookies. where used, help us and our advertising partners show you more relevant advertisements on other websites. You can control or disable cookies at any time through your browser settings, or through any cookie-preference banner presented on the Website. Disabling certain cookies may affect the availability or functioning of some features. The Website does not currently respond differently to browser “Do Not Track” signals. 9. Disclosure and Sharing of Personal Data We do not sell your personal data. We may share your personal data with. • our service providers and processors who perform functions on our behalf, such as logistics and courier partners, payment gateways, IT hosting providers, analytics providers, and email/SMS service providers, each bound by confidentiality and data-protection obligations; • our professional advisors, such as auditors and legal counsel, where necessary; • government, regulatory, or law-enforcement authorities, where required under applicable law or in response to a valid legal process; • a prospective buyer or successor, in connection with a merger, acquisition, restructuring, or sale of business assets, subject to equivalent protections; and • any other third party, where you have given us your specific consent to do so. 10. Cross-Border Transfer of Personal Data We may store or process your personal data on servers located outside India, including through cloud-hosting or analytics providers. Any such transfer is carried out in accordance with Section 16 of the DPDP Act, which permits the transfer of personal data to any country or territory outside India, except where the Central Government has, by notification, restricted transfer to that country or territory. We will comply with any such restriction as may be notified from time to time. 11. Data Retention We retain your personal data only for as long as necessary to fulfil the purposes described in this Policy, or for as long as required under applicable law (for example, retention of transaction records under applicable tax, accounting, and company/LLP law), whichever is longer. Once the purpose has been served and retention is no longer legally required, we will securely erase or anonymise your personal data, in accordance with Section 8(7) of the DPDP Act. 12. Data Security We implement reasonable security safeguards, including access controls, encryption of passwords and payment references, restricted internal access on a need-to-know basis, and periodic review of our security practices, to protect your personal data against unauthorised access, use, alteration, or disclosure, in accordance with Section 8(5) of the DPDP Act. However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security. 13. Data Breach Notification In the event of a personal data breach, we will notify the Data Protection Board of India and the affected Data Principals in the manner and within the timelines prescribed under the DPDP Rules, 2025, including providing a detailed notification to the Board as soon as possible, and in any event within seventy-two (72) hours of our becoming aware of the breach (or such longer period as the Board may permit), describing the nature of the breach, its likely consequences, and the measures taken or proposed to mitigate the risk. 14. Your Rights as a Data Principal Under the DPDP Act, you have the following rights in relation to your personal data. • Right to access information (Section 11). to obtain a summary of the personal data we hold about you and the processing activities we have undertaken. • Right to correction and erasure (Section 12). to have inaccurate or incomplete personal data corrected, and to request erasure of personal data no longer necessary for the purpose for which it was collected. • Right of grievance redressal (Section 13). to have a readily available means of registering a grievance with us regarding the processing of your personal data. • Right to nominate (Section 14). to nominate another individual to exercise these rights on your behalf in the event of your death or incapacity. Once the relevant provisions of the DPDP Act relating to Consent Managers come into force, you may also be able to exercise your rights and manage your consents through a Consent Manager registered with the Data Protection Board of India. 15. How to Exercise Your Rights To exercise any of the rights described in Section 14, please write to our Grievance Officer at the contact details in Section 20, describing your request. We may ask you to verify your identity before acting on your request, and we will endeavour to respond within thirty (30) days of receiving a valid request. 16. Grievance Redressal Mechanism In accordance with the Information Technology Act, 2000, the Consumer Protection Act, 2019, and the DPDP Act, we have designated a Grievance Officer to address complaints regarding this Policy or the processing of your personal data. Grievance- Connect us at info@kinmin.co.in The Grievance Officer will acknowledge your complaint within forty-eight (48) hours and endeavour to redress it within thirty (30) days of receipt. If you are not satisfied with our response, you may also approach the Data Protection Board of India. 17. Third-Party Links The Website may contain links to third-party websites, such as our payment gateway, social media platforms, or distributor websites. This Policy does not apply to any such third-party website, and we encourage you to review their privacy policies separately. We are not responsible for the content or privacy practices of any linked third-party website. 18. Changes to this Policy We may update this Policy from time to time to reflect changes in our practices or in applicable law. The updated Policy will be posted on this page with a revised “Last Updated” date. Where a change is material, we will provide additional notice, such as a banner on the Website or an email, before the change takes effect. We encourage you to review this Policy periodically. 19. Governing Law and Jurisdiction This Policy is governed by, and shall be construed in accordance with, the laws of India. Subject to the DPDP Act and the jurisdiction of the Data Protection Board of India, the courts at Hazaribagh, Jharkhand shall have exclusive jurisdiction over any dispute arising out of or in connection with this Policy, without prejudice to your right to approach an appropriate consumer forum. 20. Contact Us For any questions about this Privacy Policy or how we handle your personal data, please contact. Subhanshu Food Products LLP Registered Office. New Balajee colony, opp Nayan Bharti School, Gali 2B, Vishnupuri, Hazaribag, Jharkhand, 825301 Email. subhanshufoodproduct@gmail.com
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Privacy Policy
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