Privacy Policy

The Sanduk mobile application and related digital services are operated by SHIVARYAA INNOVATIONS PRIVATE LIMITED, a company incorporated under the Companies Act, 2013, with its registered office at Ahmedabad, Gujarat 380015, India.

This Privacy Policy describes how Sanduk (“Sanduk”, “we”, “our”, or “us”) collects, stores, uses, discloses, and otherwise processes your personal information when you use the Sanduk mobile application, website (if any), in-app notifications, and any other channel through which Sanduk provides services to you (collectively, the “Platform”).

By downloading or using the Sanduk App, registering on the Platform, providing your information, or availing our products or services, you agree to this Privacy Policy and the applicable Terms of Use. We value your trust and aim to maintain appropriate standards for secure transactions and protection of your personal information.

This policy is published in accordance with the Information Technology Act, 2000, and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”). “Personal Information” means information that can identify you. “Sensitive Personal Data or Information” (“SPDI”) includes categories specified under applicable law (such as passwords, financial information, biometric data, and documents used for KYC). We do not offer products or services on the Platform to users outside India. If you do not agree with this policy, please do not use the Platform.

Information We Collect

We collect personal information that is relevant and necessary to provide Sanduk services, comply with law, prevent fraud, and improve the Platform. We may collect information when you register, complete KYC, buy or sell digital gold (or silver where offered), set up auto-save, SIP, or Sanduk goals, link UPI autopay, receive payouts, use rewards or referrals, or contact support.

Categories of information (including SPDI where applicable) may include:

1) Identity and profile: name, date of birth, gender, photograph or profile image, postal address, city, state, pincode, country, email address, mobile number, and nominee details (name, relationship, share percentage);
2) KYC and compliance: PAN, Aadhaar or other identity documents and verification data as required by Sanduk, SafeGold, payment partners, or regulators; Form 60 or equivalent where applicable;
3) Authentication: OTPs sent to your mobile, device identifier, session and login data;
4) Financial and transaction data: bank account details and UPI IDs for payouts or mandates; transaction history; wallet balances (cash, gold, silver); investment and savings plan details (auto-save, SIP, Sanduk goals); payment status; invoices; sell/payout and physical redemption records; limited payment instrument details processed by payment gateways (we do not store full card numbers on our servers);
5) Referrals and rewards: referral codes applied or shared, reward points (Sanduk Coins) balance and ledger history;
6) Technical and usage data: device model, operating system, app version, IP address, browser or app identifiers, cookies or similar technologies, log files, crash reports, and aggregated usage analytics;
7) Communications: support queries, feedback, and notifications you receive or interact with.

We and our service providers or business partners may also receive information from third parties where permitted by law—for example, payment gateways, bullion partners (including SafeGold), KYC or fraud-prevention service providers, banks, and credit or verification agencies—to validate transactions, complete KYC, prevent fraud, or comply with legal process. Such processing is subject to this policy and, where applicable, the third party’s terms and privacy notices.

When information may be collected

1) when you visit or browse the Platform;
2) when you register or maintain a Sanduk account;
3) when you transact or attempt to transact (buy, sell, fund wallet, autopay, SIP, Sanduk goals, redemption);
4) when you interact with emails, SMS, push notifications, or in-app messages from Sanduk;
5) when you participate in surveys or promotions, if offered;
6) when you deal with our business partners through the Platform;
7) if you apply for employment with Sanduk (only information you submit for recruitment, such as resume and employment history, on a separate basis).

Purpose and Use of Personal Information

We process your personal information for the following purposes:

1) creating and managing your account and verifying identity and access;
2) providing digital gold and related services (buy, sell, hold through partners, auto-save, SIP, Sanduk goals, rewards, referrals);
3) conducting KYC and ongoing compliance with applicable laws and partner requirements;
4) sharing KYC, nominee, or transaction information with intermediaries, bullion partners (including SafeGold), payment aggregators, banks, or regulators where necessary to provide services;
5) processing payments, UPI mandates, standing instructions, refunds, and payouts;
6) authenticating transactions and detecting fraud, money laundering, or suspicious activity;
7) communicating with you about transactions, account status, security alerts, and service updates;
8) improving user experience, troubleshooting, technical support, audits, and product development (including aggregated analytics);
9) sending offers, promotions, or personalised content where permitted by law and your preferences;
10) enforcing our Terms of Use and protecting rights, safety, and property of users and Sanduk;
11) responding to legal requests, court orders, or regulatory directions;
12) other legitimate purposes compatible with the above, with measures to minimise intrusion where possible.

Cookies and Similar Technologies

We use cookies and similar technologies on the Platform to enable login sessions, security, analytics, and performance. Cookies are small files stored on your device. They may not personally identify you by themselves but can be linked with account data when you are logged in.

We use cookies to: maintain sessions; reduce repeated password entry; measure usage and improve services; and support security. You may disable cookies through device or browser settings, but some features may not work properly. Third-party payment, analytics, or partner pages may set their own cookies; we do not control those technologies.

Information Sharing and Disclosures

We share personal information only as permitted by law, for the purposes in this policy, and where recipients are contractually required to protect data with standards no less protective than ours (where applicable).

Recipients may include:

1) Business partners such as SafeGold (bullion, vaulting, delivery), payment gateways, banks, and UPI service providers—to complete transactions you request;
2) Service providers for hosting, cloud storage, SMS/OTP, email, push notifications, analytics, customer support, and security;
3) Regulators, government authorities, or courts when required by law or to protect legal rights;
4) Professional advisers (auditors, lawyers) under confidentiality obligations;
5) Affiliated entities of SHIVARYAA INNOVATIONS PRIVATE LIMITED, if any, for internal operations consistent with this policy.

Sharing is on a need-to-know basis for purposes such as: enabling products or services you choose; KYC and regulatory compliance; fraud prevention and risk management; marketing and communication (where allowed); dispute resolution; and enforcement of our terms.

We do not sell your personal information. We are not responsible for privacy practices of third-party websites or apps you access via links on the Platform; please review their policies before sharing information.

Storage and Retention

To the extent applicable, we store personal information in India and retain it only as long as necessary for the purposes collected, or as required by law (including tax, anti-money laundering, or litigation holds). When retention ends, we delete or anonymise data per our internal retention policy, unless further retention is legally required.

Reasonable Security Practices

We implement reasonable security practices and procedures as required under applicable law, including access controls, encryption for data in transit and at rest where appropriate, firewalls, and restricted access to production systems. No method of transmission or storage is completely secure; you are responsible for keeping your OTP, device, and account credentials confidential.

Third-Party Products and Services

When you use services of partners on the Platform (for example SafeGold, payment providers), they may collect information directly under their privacy policies. We encourage you to read partner terms and privacy notices. Sanduk’s role is limited to facilitating access through the Platform.

Your Consent

By using the Platform and providing information, you consent to processing as described in this policy. Where law requires separate consent (for example certain marketing or SPDI), we will seek it separately. If you provide information about another person (such as a nominee), you confirm you have authority to do so and that they have been informed as appropriate.

Children

We do not knowingly collect personal information from anyone under 18. The Platform is intended for persons who can enter a legally binding contract under the Indian Contract Act, 1872. Users under 18 must use the Platform only with supervision of a parent or legal guardian.

Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be posted on the Platform with a revised effective date. Continued use after changes constitutes acceptance. We will not reduce protection of information already collected in a manner materially inconsistent with this policy without appropriate notice where required by law.

Grievance Officer

For grievances relating to the Platform or processing of your personal information under applicable Indian law, contact:

Name: Vikash Soni
Email: [email protected]

Contact Us

SHIVARYAA INNOVATIONS PRIVATE LIMITED
Ahmedabad, Gujarat, India
Email: [email protected]