Last updated: 8 October 2026
This Privacy Policy explains how Bhagyashri Sunil Bhujbal, sole proprietor, trading as SUBHAGYA ORGANIC SKINCARE (“SUBHAGYA”, “we”, “us”) collects, uses, shares and protects your personal data when you visit subhagyaorganic.com, place an order, contact us on WhatsApp, or submit a form. It is written to comply with the Digital Personal Data Protection Act, 2023 and the rules made under it as they come into force, the Information Technology Act, 2000 and its rules, and the Consumer Protection (E-Commerce) Rules, 2020.
1. Who we are
- Data Fiduciary: Bhagyashri Sunil Bhujbal, sole proprietor, trading as SUBHAGYA ORGANIC SKINCARE, Flat No 102, X Wing, Omkar Bramha CHS, Adai, New Panvel, Panvel, District Raigad, Maharashtra 410206
- GSTIN: 27AVWPB8279M1ZJ
- Contact for privacy questions / Grievance Officer: Bhagyashree Bhujbal, Grievance Officer, sales@subhagyaorganic.com, +91 87795 35622
2. What we collect
| Category | Examples | When |
|---|---|---|
| Identity and contact | Name, phone/WhatsApp number, email | Orders, forms, WhatsApp chats |
| Delivery | Shipping and billing address, PIN code | Orders |
| Order | Products bought, order value, order history, invoices | Orders |
| Payment | Payment status and transaction reference. We do not store card, UPI PIN or net-banking details; these are handled by our payment gateway | Checkout |
| Communications | Messages you send us by WhatsApp, email or forms; reviews you submit | When you contact us |
| Business (distributors) | Business name, type, city, GSTIN, expected volumes | Distributor form |
| Technical | IP address, device and browser type, pages visited, cookies | When you browse (see §7) |
We do not intentionally collect sensitive data such as health records. If you mention a skin or health concern in a message, we use it only to reply to you. Please don’t send medical records.
3. Why we use it (purposes)
- To process, ship and support your orders, including returns and refunds.
- To reply to your questions on WhatsApp, email or phone.
- To handle distributor enquiries.
- To send order updates (transactional messages).
- With your consent only: offers and new-product messages. You can opt out at any time by replying “STOP” or emailing us.
- To publish your review, only with your explicit permission, showing your first name and city only.
- To prevent fraud, keep the website secure, and meet legal obligations (tax/GST, accounting, consumer law).
- To understand how the site is used and improve it (analytics, see §7).
4. Legal basis
We process your personal data on the basis of your consent (given when you place an order, submit a form, or opt in), and for legitimate uses permitted by law, such as fulfilling an order you asked for and complying with legal obligations. You may withdraw consent at any time (see §8). Withdrawal doesn’t affect processing already done, but we may be unable to complete an order without the data it needs.
5. Who we share it with
We share only what’s needed, with:
- Delivery partners: local courier services (name, phone, delivery address). When we dispatch, we send you a photo of your packed order on WhatsApp/email.
- Payment gateway: our online payment provider (order and payment details).
- Hosting and IT: Hostinger (website hosting), and secure backup storage.
- Spam protection: Cloudflare Turnstile checks that form submissions come from a person (it doesn’t receive your form answers).
- Communication: WhatsApp/Meta, when you message us; our email provider for sales@subhagyaorganic.com (Titan Mail, via Hostinger).
- Analytics: Google Analytics (aggregated usage data), if we enable it.
- Authorities: when required by law, court order or a government request.
We do not sell your personal data. Some providers may store data outside India. Where they do, we rely on their contractual safeguards, and on transfers permitted under Indian law.
6. How long we keep it
- Order and invoice records: as long as tax and accounting law requires (generally up to 8 years).
- Enquiries and chats: up to 24 months after the last interaction, unless you ask us to delete them sooner.
- Marketing consent: until you withdraw it.
- Reviews: while published, or until you ask for removal.
7. Cookies and analytics
The site uses essential cookies (cart, checkout, security) and, after we enable it, Google Analytics cookies to understand traffic. You can block or delete cookies in your browser settings. Essential cookies are needed for the cart to work.
7A. Consultation requests and the Routine Finder
- Routine Finder (
/routine-finder/): your answers (concern, skin/hair type, need) are processed in your browser and on our server only to show a routine. We do not store them with your name, and they are not linked to you unless you choose to send them to us. - Consultation form (
/consultation/): we collect your name, WhatsApp number and/or email, age range, concern, skin/hair type, current products, allergies, any notes you add and, only if you choose, up to 3 photos. We use this only to reply with a product suggestion. We don’t sell it or use it for ads, and we only send marketing if you tick the separate marketing box. - Who sees it: only the person answering consultations at SUBHAGYA (currently the proprietor). It is stored on our website server (Hostinger), with photos kept in a private folder that has no public link, and in our business email/WhatsApp when we reply.
- How long: consultation entries and photos are automatically deleted 90 days after submission. You can ask us to delete them sooner at any time.
- Withdrawing consent: reply “DELETE” on WhatsApp, email us, or use the link in our reply. We’ll delete your consultation data within 7 days and confirm when it’s done.
- Under 18: consultations are for adults only. We don’t knowingly accept consultation requests from anyone under 18.
- Not medical advice: consultations are product suggestions based on personal experience. They are not a diagnosis or medical treatment.
8. Your rights
Subject to applicable law, you can:
- ask what personal data we hold about you and how we use it;
- ask us to correct, complete or update it;
- ask us to erase it (where we don’t need to keep it by law);
- withdraw consent for marketing or other consent-based processing;
- nominate another person to exercise your rights in case of death or incapacity;
- raise a grievance with us. If you aren’t satisfied with our response, you may approach the Data Protection Board of India once it is operational.
To exercise any right, write to sales@subhagyaorganic.com or WhatsApp +91 87795 35622. We will acknowledge within 48 hours and respond within 30 days. We’re available Monday to Saturday, 10 AM to 8 PM IST.
9. Children
Our products and website are meant for adults. We don’t knowingly collect personal data from anyone under 18 without verifiable consent from a parent or guardian. If you think a child has given us data, contact us and we’ll delete it.
10. Security
We use HTTPS encryption, access controls, security plugins and regular backups. No method is 100% secure. If a personal data breach affects you, we will notify you and the authorities as required by law.
11. Changes
We may update this policy. We’ll post the new version here with a new “Last updated” date. Significant changes will be highlighted on the website.
12. Contact
Bhagyashri Sunil Bhujbal, sole proprietor, trading as SUBHAGYA ORGANIC SKINCARE · Flat No 102, X Wing, Omkar Bramha CHS, Adai, New Panvel, Panvel, District Raigad, Maharashtra 410206 · Email: sales@subhagyaorganic.com · WhatsApp: +91 87795 35622