Privacy Policy

1. Introduction

This Privacy Policy explains how Pamphlet Box ("we", "us", "our") collects, uses, shares, and protects personal data when you use our website (pamphletbox.com) and mobile application (together, the "Platform"). This Policy is intended to align with the Digital Personal Data Protection Act, 2023 and the Digital Personal Data Protection Rules, 2025, and other applicable Indian law.

By creating an account or otherwise using the Platform, you consent to the practices described in this Policy.

2. Who This Policy Applies To

• Businesses that create advertising campaigns on the Platform ("Advertisers")
• Individuals who subscribe to campaigns and post content to their WhatsApp Status ("Promoters")
• Visitors to our website

3. Information We Collect

3.1 Information you provide directly

• Name, phone number, email address
• Business details (Advertisers): business name, address, GST registration number
• Government ID and KYC information (Promoters, required before first payout): PAN, Aadhaar where applicable, and bank account or UPI details
• Payment details, processed directly by our licensed Payment Aggregator partners — we do not store full card numbers
• Campaign content, creatives, and budget information (Advertisers)
• Screenshots submitted as proof of Status posting and views (Promoters)

3.2 Information collected automatically

• Device information (device identifier, operating system, app version)
• Approximate or precise location — used only to match Promoters with campaigns available in their area, and to let Advertisers define a campaign radius
• Usage data (features used, campaign interactions, app performance)

3.3 A note on screenshots and third-party data

Screenshots submitted for view verification may incidentally contain information about third parties — for example, names or numbers visible in a "viewed by" list. We ask Promoters to avoid submitting screenshots that expose more information than necessary for verification. Screenshots are used solely for verification purposes and are not shared outside that process.

4. How We Use Your Information

• Create and manage your account
• Match Advertiser campaigns with eligible Promoters based on declared or device location
• Verify campaign views and process payouts
• Deduct and remit applicable taxes (GST, TDS) as required by law
• Communicate with you about your account, campaigns, or payouts
• Detect and prevent fraud, including coordinated activity between linked accounts
• Comply with legal and regulatory obligations
• Improve and maintain the Platform

5. Legal Basis and Consent

We collect and process personal data on the basis of your explicit, informed, and specific consent for each stated purpose, as required under the DPDP Act, 2023. Consent is collected separately for distinct purposes. You may withdraw consent at any time, subject to Section 9; withdrawal does not affect the lawfulness of processing carried out before withdrawal.

6. How We Share Your Information

• Licensed Payment Aggregators (for example, Razorpay or Cashfree) to process payments and payouts
• Licensed BBPS and voucher redemption partners, only if and when a Promoters chooses a non-bank payout option
• Government and tax authorities, as required for GST and TDS compliance
• Service providers supporting our operations (hosting, analytics, customer support), bound by contractual data protection obligations
• Law enforcement or regulators, where required by law

We do not sell personal data to third parties.

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable law (for example, financial records required under tax law).

8. Data Security

We implement reasonable security safeguards, including encryption in transit, access controls, and security requirements for vendors, to protect personal data against unauthorized access, loss, or misuse.

9. Your Rights

• Access the personal data we hold about you
• Correct or update inaccurate or incomplete data
• Request erasure of your data, subject to our legal retention obligations
• Withdraw consent
• Nominate another individual to exercise your rights in the event of death or incapacity
• Register a grievance with our Grievance Officer, and if unresolved, escalate to the Data Protection Board of India

To exercise these rights, contact us at thepamphletbox@gmail.com.

10. Age Requirement

The Platform is intended for users who are 18 years of age or older. We do not knowingly collect personal data from anyone under 18. If we learn that we have collected data from a minor, we will delete it promptly.

11. Cookies and Analytics

We use Google Analytics 4, via Google Tag Manager, to understand how visitors use our website — which pages are viewed, how people arrive at the site, and which links or buttons are used. This is done through cookies and similar technologies that collect information such as your approximate location (derived from IP address), device and browser type, and pages visited. This data is pseudonymous and is used in aggregate to improve the website; it is not used to identify you individually.

Google acts as a data processor for this analytics data. You can review Google's own privacy practices at policies.google.com/privacy, and opt out of Google Analytics tracking across websites using the Google Analytics Opt-out Browser Add-on.

You can disable cookies generally through your browser settings, though some parts of the website may not function as intended if you do.

12. Grievance Officer

Name: [to be appointed]
Address: Greater Noida, India
Email: thepamphletbox@gmail.com

We will acknowledge grievances within 48 hours and aim to resolve them within one month of receipt.

13. Changes to This Policy

We may update this Policy from time to time. Material changes will be notified to you through the Platform or via email before they take effect.

14. Contact Us

Pamphlet Box
Greater Noida, India
Email: thepamphletbox@gmail.com