1. Introduction
Dev Marketing ("TOP10 RETAILS PRIVATE LIMITED","Top-10", "we", "us", "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose and safeguard your information when you visit www.top10retails.in or use our Android/iOS applications (collectively, the "Platform"). Please read this policy carefully. By accessing or using the Platform you consent to the practices described below.
2. Scope & Governing Framework
These Terms are published in compliance with—
Information Technology Act 2000 & Information Technology (Reasonable Security Practices & Procedures and Sensitive Personal Data or Information) Rules 2011.
Information Technology (Intermediary Guidelines & Digital Media Ethics Code) Rules 2021.
Digital Personal Data Protection Act 2023 (DPDPA 2023) – once in force.
Consumer Protection (E-commerce) Rules 2020.
Apple App Store & Google Play policy requirements. Where applicable to overseas users we also align with the principles of the EU GDPR and California CCPA.
3. Data ctWe Colle
Category | Examples | Mandatory? |
|---|---|---|
Contact & Identity | Name, mobile number, e-mail address | Yes (for account creation) |
Authentication | OTP codes, hashed passwords | Yes |
Transaction | Order ID, product details, payment instrument, GST IN (if provided) | Yes |
Payment | Tokenised card/UPI IDs via Paytm (we never store raw card data) | Yes |
Location | PIN code, lat/long via Google Maps API (while app in use) | Only for delivery |
Device & Usage | IP address, device model, OS, app version, crash logs | Automatically collected |
Communication Logs | Push-notification tokens (OneSignal), WhatsApp message IDs | Automatically collected |
Cookies & Similar Tech | Session cookies, analytics pixels | Website only |
We do not collect biometric, health, or government-ID numbers.
4. How We Collect Data
Directly from you – when you register, place an order, select delivery location, contact support or participate in promotions.
Automatically – through SDKs, cookies and server logs.
From third parties – payment processors, logistics partners, social-login providers (if enabled).
5. Why We Process Your Data & Legal Basis
Purpose | Legal Basis under Indian Contract Act & DPDPA | Details |
|---|---|---|
Account creation & authentication | Consent & Contractual necessity | Verify identity & provide login |
Order processing & delivery | Contractual necessity | Pick, pack, ship, arrange in-store pick-up |
Payment collection & fraud prevention | Compliance with RBI & IT Act 2000 | Route through approved gateways (Paytm) |
Push / WhatsApp notifications | Consent (opt-in) | Order updates, marketing (separate opt-in) |
Customer support & grievance redressal | Legitimate interest | Resolve queries & returns |
Analytics & service improvement | Legitimate interest | Diagnose crashes, improve UI/UX |
Legal & regulatory compliance | Legal obligation | Accounting, tax, consumer-law obligations |
You may withdraw consent for non-essential processing at any time via in-app settings or by writing to us (see §14). Withdrawal may limit certain features.
6. Data Sharing & Recipients
We never sell your personal data. We share it only with:
Payment Processors: Paytm, banks, card networks for secure payment execution.
Logistics & Store Staff: To fulfil delivery or in-store pick-up.
Notification Services: OneSignal (push), Meta Platforms (WhatsApp Business API).
Mapping Providers: Google Maps for geolocation & route optimisation.
Analytics & Crash Reporting: Google Firebase Crashlytics.
Regulators / Law Enforcement: Where required by law or lawful request.
All service providers are bound by confidentiality and data-processing agreements.
7. International Transfers
Top-10 stores all primary data on servers located in India. Where data is processed outside India (e.g., OneSignal servers in the US) we ensure comparable safeguards through contractual clauses consistent with DPDPA 2023 § 16 and, where applicable, GDPR standard contractual clauses (SCCs).
8. Security Measures
TLS 1.3 encryption in transit; AES-256 at rest.
Industry-standard PCI-DSS compliant payment flow (via Paytm).
OWASP ASVS guidelines for application security.
Role-based access control & least-privilege principle for staff.
Annual vulnerability assessments & penetration tests.
9. Data Retention
Data Type | Retention Period |
|---|---|
Transactional invoices & GST records | 8 years (Indian tax law) |
Account data | While account is active + 3 years after last activity |
Push tokens / analytics logs | 24 months rolling window |
Complaint & grievance files | 5 years or till dispute resolution |
Post-retention, data is anonymised or securely deleted.
10. Cookies & Tracking Technologies
Our website uses first-party session cookies (essential) and analytics cookies (optional). You can manage cookie preferences via browser settings or website banner. The mobile apps rely on device identifiers (IDFA/GAID) which can be reset in OS settings.
11. Your Rights
Subject to local laws you have the right to:
Access your personal data held by us.
Correct / update inaccurate information.
Delete data no longer necessary (subject to legal retention).
Withdraw consent to non-essential processing.
Data portability (machine-readable copy).
Lodge a complaint with our Grievance Officer or the Data Protection Board (once operational under DPDPA).
To exercise these rights email us (see §14). We will respond within 15 days.
12. Children's Privacy
We do not knowingly collect personal data from children under 13. Parents who believe their child has provided us data may contact us to delete it.
13. Links to External Sites
The Platform may contain links to third-party websites or apps. We are not responsible for their privacy practices. Please review their policies separately.
14. Changes to This Policy
We may update this Policy from time to time. Material changes will be notified via e-mail, in-app alert or website banner at least 7 days before the revision takes effect. Continued use of the Platform after the effective date constitutes acceptance.
15. Contact Us
For privacy questions or requests:
Legal Department – TOP10 RETAILS PRIVATE LIMITED
Phone: +91
By using our Platform you acknowledge that you have read and understood this Privacy Policy.