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Privacy policy

Last updated: [DATE]

Draft — to be approved by TWG legal counsel. This text is a working draft prepared for review and is not yet in force. Bracketed items are to be completed by TWG.

1. Who we are

This website is operated by [Registered legal entity name] (“The Water Garage”, “TWG”, “we”, “us”), [Registered office address]. For the purposes of the Digital Personal Data Protection Act, 2023 (“DPDP Act”), TWG is the Data Fiduciary for personal data collected through this website. This notice explains what we collect, why, who we share it with, how long we keep it and how you can exercise your rights.

2. Personal data we collect

We collect only what we need to respond to you:

  • Details you give us in forms — name, mobile number, email, company or organisation, city, site address, pincode, GSTIN (optional), and enquiry details such as products, system information, service needs and preferred dates.
  • Files you upload — photos of parts, drawings, water reports, catalogues and CVs.
  • Phone verification — for Home RO bookings we send a one-time password (OTP) to confirm your mobile number.
  • Job applications — your CV and the details in it.
  • Technical and usage data — pages visited, referring page and campaign (UTM) parameters, and, only if you accept analytics cookies, Google Analytics data. See our cookie policy.

Please do not upload documents that contain personal data of other people unless you are entitled to share it.

3. Why we use it (purposes and legal basis)

We process personal data on the basis of your consent, given when you submit a form, or for legitimate uses permitted by section 7 of the DPDP Act. We use it to:

  • respond to your enquiry, quotation, service booking, spares, AMC, partner or contact request — we aim to reply within 24 hours;
  • create and manage your enquiry or service ticket in our CRM and send acknowledgements and status updates by email, SMS or WhatsApp;
  • verify your mobile number for Home RO bookings and check whether we serve your pincode;
  • assess job applications;
  • send product updates and offers — only if you tick the marketing checkbox (it is unticked by default);
  • keep the site secure, prevent spam and abuse, and comply with law.

4. Who we share it with

We do not sell personal data. We share it only with service providers (Data Processors) who act on our instructions, and only as needed:

  • CRM — Zoho CRM (Zoho Corporation), where enquiries and tickets are stored and assigned;
  • messaging — SMS/OTP provider (MSG91), WhatsApp Business provider [provider name] and email provider [provider name];
  • website hosting and content management — [hosting provider] and Sanity (content only, no form data);
  • analytics — Google Analytics, only after you accept analytics cookies;
  • TWG service partners and technicians assigned to your area, for Home RO and on-site service visits;
  • authorities, where required by law or to protect our rights.

5. Where your data is processed

Our providers may store or process data in India or abroad. Any transfer outside India is made in line with section 16 of the DPDP Act and any restrictions notified by the Central Government. [TWG to confirm data-centre regions for Zoho CRM and hosting.]

6. How long we keep it

We keep enquiry and lead records for 3 years from your last interaction, unless a longer period is required by law (for example tax or accounting records for customers) or you ask us to erase them earlier. Unsuccessful job applications are kept for [12 months]. OTPs expire within minutes and are not stored. When data is no longer needed it is deleted or anonymised.

7. Your rights

Under the DPDP Act you have the right to:

  • obtain a summary of the personal data we hold about you and how it is processed;
  • have inaccurate or incomplete data corrected, completed or updated;
  • have your data erased, unless we must keep it for a legal purpose;
  • withdraw consent at any time — as easily as you gave it. Withdrawal does not affect processing already carried out;
  • nominate another person to exercise your rights in case of death or incapacity;
  • have a grievance addressed by us, and then, if you are not satisfied, complain to the Data Protection Board of India.

To make a request, email [privacy email] or write to the Grievance Officer below with your name, mobile number and the reference ID of your enquiry (if any). We may need to verify your identity. We aim to respond within [30] days. To stop marketing messages, use the unsubscribe link or reply STOP.

8. Children

This website is meant for adults. We do not knowingly collect personal data of children (under 18) without verifiable consent of a parent or lawful guardian.

9. Security

We use reasonable security practices, including HTTPS, access controls and rate limiting on forms, and require our processors to do the same. No system is completely secure; if a personal data breach occurs we will notify the Data Protection Board and affected people as the law requires.

10. Grievance Officer

[Grievance Officer name], Grievance Officer, [Registered legal entity name], [Registered office address]. Email: [grievance email]. Phone: [phone].

11. Changes to this policy

We may update this notice. The “last updated” date shows the current version; significant changes will be highlighted on this page.