Privacy Policy

1. Background

The website www.penaca.com and any of its associated mobile or web applications (collectively referred to as the “Platform”) are owned and managed by Penaca Private Limited, a company duly incorporated under the Companies Act, 2013, with its registered office in India (hereinafter referred to as “Penaca,” “we,” “our,” or “us”). The term “you” or “user” refers to any individual or entity accessing or using the Platform.

Our Platform may include links to websites, applications, or digital services operated by our partners or third parties. Please note that when you visit such external sites, you will be governed by their respective terms, policies, and practices. Penaca does not control, endorse, or make any representations regarding the accuracy, reliability, or data handling practices of third-party platforms and shall not be held responsible for any consequences arising from your interaction with them.

By accessing or using our Platform, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy (“Policy”). You may also review our Terms of Use available at www.penaca.com for further details regarding your use of our services.

Penaca is dedicated to maintaining the confidentiality, integrity, and security of your personal information. We adopt appropriate technical and organizational measures to safeguard the data we collect from you, in accordance with the applicable provisions of the Information Technology Act, 2000, and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”).

For the purpose of this Policy, terms such as ‘Information’, ‘Data’, ‘Personal Information’, and ‘Personal Data’ may be used interchangeably and carry the same meaning as prescribed under applicable data protection laws in India.

2. Meaning

For the purpose of this Privacy Policy, the following terms shall have the meanings ascribed below:

“Information” refers to any data or details that can directly or indirectly identify an individual, as defined under the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”). This includes, but is not limited to, personally identifiable details such as your name, gender, contact number, address, email ID, date of birth, or any government-issued identification such as Aadhaar, PAN, or other valid identity documents.

The term “Information” shall also encompass “Sensitive Personal Data or Information” (SPDI) as recognized under the SPDI Rules, which may include:

Passwords
Financial data such as bank account details, credit or debit card numbers, or other payment information
Physical, physiological, or mental health conditions
Sexual orientation
Medical history or records
Biometric identifiers
Details shared with Penaca in connection with availing our services
Any information received, processed, or stored by Penaca under a lawful contract or otherwise, including IP address, browser information, and ISP details

The term “Company,” “We,” “Our,” or “Us” shall refer to Penaca Private Limited.

The term “You,” “Your,” or “User” denotes any individual or entity accessing, browsing, or using the Penaca Platform (including its website or application), whether as a visitor, customer, or registered account holder.

The term “Person” includes any natural person, association of individuals, partnership, trust, company, limited liability entity, government body, or any other legal or artificial entity recognized under applicable law.

3. Applicability

This Privacy Policy applies exclusively to individuals and entities who access or use the Penaca Platform, including its website and associated digital services.

It outlines how Penaca Private Limited collects, utilizes, manages, stores, and protects your personal information. It also explains the rights and options available to you regarding how your information is handled and processed by us.

By continuing to use our Platform, you acknowledge and consent to the collection and use of your data in accordance with the terms set forth in this Policy.

4. General Consent

By accessing or using the Penaca Platform, you expressly consent to Penaca Private Limited collecting, processing, storing, sharing, and, where applicable, deleting the personal information that you voluntarily provide in accordance with this Privacy Policy.

Penaca reserves the right to modify or update this Policy periodically to reflect changes in legal requirements, business practices, or technological advancements. Any such revisions will be posted on our website, and your continued use of the Platform following these updates shall be considered as your acknowledgment and acceptance of the revised Policy.

You agree not to use any automated tools, software programs, bots, or data extraction techniques such as crawlers, scrapers, or spiders to access, harvest, or index any portion of www.penaca.com. Unauthorized attempts to collect or compile large volumes of data or to create derivative databases from our Platform content are strictly prohibited and may lead to legal action.

5. Protection of Minors’ Information

Penaca does not intentionally collect or solicit personal information from individuals below the age of 18 (eighteen). If you are a minor, you may access or use the Penaca Platform only under the supervision and consent of a parent or legal guardian.

In case it is brought to our attention that personal information has been provided by a user who does not meet the minimum age requirement, Penaca Private Limited reserves the right to delete such data from its records immediately and restrict access to its services without prior notice.

We strongly encourage parents and guardians to monitor their children’s online activities and ensure that no personal information is shared with us without proper authorization.

6. Information We Collect and How We Use It

To provide you with a seamless experience and access to the products and services offered through the Penaca Platform, Penaca Private Limited may collect information that can personally identify you, as described under this Privacy Policy. You are responsible for ensuring that any information you share with us is complete, accurate, and current.

Penaca does not collect personal data unless it is voluntarily provided by you. However, to access certain features, services, or communications, you may be required to share specific personal details. This may include, but is not limited to:

Creating or registering an account on our Platform;
Submitting a service inquiry or requesting to be contacted;
Signing up for newsletters, updates, or promotional offers;
Communicating with us through emails, messages, or feedback forms;
Participating in surveys, contests, or research activities;

If you post content, feedback, or queries through our communication channels (such as chat features, comment forms, or email), Penaca may retain such information as necessary to respond to inquiries, resolve disputes, improve customer service, or comply with legal obligations.

The information you share with Penaca will be treated as confidential and will be used solely for legitimate business and operational purposes, including but not limited to:

Facilitating, managing, and improving the services we provide;
Authenticating your access and enabling communication such as OTPs, alerts, or updates;
Personalizing your user experience and service recommendations;
Enhancing customer satisfaction and support quality;
Recording customer interactions (audio/video/telephonic) for training and quality monitoring;
Responding to feedback, complaints, or claims in a timely and appropriate manner;
Displaying verified user reviews or testimonials;
Sending relevant updates, product information, and service announcements;
Conducting analytics, research, and internal assessments to improve our offerings;
Maintaining backups or archives for operational and legal purposes;
Cooperating with legal, regulatory, or government authorities when required under applicable law;
Notifying you of potential security issues, policy violations, or fraudulent activities;
Sending marketing or promotional materials (where permitted by law) or requesting your participation in customer satisfaction initiatives.

Penaca adopts appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or misuse. While we take all legally mandated precautions, we cannot guarantee absolute protection from breaches that occur despite these safeguards.

By continuing to use our Platform, you acknowledge that you have read and understood this Policy and consent to the collection, processing, and use of your personal information for the purposes outlined herein and as permitted by law.

7. Data Sharing and Access

Penaca Private Limited respects your privacy and does not share, sell, or disclose your personal information for purposes unrelated to the services we provide. Your data is used strictly to facilitate, enhance, or maintain the functionality of our products and services.

However, in certain circumstances, Penaca may share your information with third parties, but only under controlled and lawful conditions, as outlined below:

With Affiliates and Successors: We may transfer or disclose your information to our affiliates, subsidiaries, or legal successors, with prior notice, where such transfer is necessary for the continuity of services or business operations, and as permitted under applicable law.
With Business Partners: On a need-to-know basis and with your explicit prior consent, your data may be shared with trusted business partners or service providers who assist us in delivering or improving our services. These partners are bound by confidentiality and data protection obligations consistent with this Policy.
For Legal and Regulatory Compliance: Penaca may disclose information to governmental, regulatory, or judicial authorities when required to do so by law, court order, or other lawful processes. Such disclosures are made only to the extent necessary to comply with applicable legal obligations.

Penaca ensures that all employees, contractors, and third parties handling personal data are regularly trained and made aware of their responsibilities regarding data protection and privacy best practices.

8. Data Transfer

As Penaca Private Limited continues to grow and evolve, there may be instances where parts of our business undergo restructuring, mergers, acquisitions, or transfers of ownership or control. In such cases, the personal information relevant to the transferred business operations may also be shared or transferred to the acquiring or succeeding entity.

Any recipient or new controlling entity shall be bound by this Privacy Policy and may use the transferred information solely for the purposes for which it was originally collected, unless otherwise required or permitted by law.

Penaca may also disclose limited information to potential investors, acquirers, or business partners as part of due diligence processes, provided that such disclosures are made under strict confidentiality and data protection obligations.

In certain cases, your data may be transferred across different jurisdictions where our partners, affiliates, or service providers operate. Whenever such transfers occur, Penaca ensures that appropriate safeguards and legal measures are in place to maintain the same level of data protection as required under applicable Indian laws and international standards.

9. Publicly Available Information

Any data or information that is already available in the public domain, or that has been disclosed under theRight to Information Act, 2005, or under any other applicable law currently in force, shall not be considered as personal or sensitive information for the purposes of the Information Technology Act, 2000or the SPDI Rules, 2011.

Penaca Private Limited shall not be held liable for any unauthorized access, misuse, or violation concerning such publicly available information, as it falls outside the scope of this Privacy Policy.

10. Data Retention and Storage

Penaca Private Limited retains your personal information only for as long as it is necessary to fulfill the purposes outlined in this Privacy Policy or as required by applicable laws and regulations. In general, data may be maintained for a period of up to seven (7) years, or longer if mandated by law or needed for legitimate business, accounting, or audit purposes.

If Penaca is unable to process or utilize the information provided by you for any reason, such data will be securely deleted or anonymized, unless its retention is required by law or for internal record-keeping and compliance reviews.

Penaca is fully committed to adhering to applicable data protection laws and employs appropriate technical and organizational safeguards to ensure that all information stored with us remains secure, confidential, and protected against unauthorized access or misuse.

11. Data Deletion and Disposal

Penaca Private Limited has established appropriate policies, systems, and tools to ensure that any personal information collected and stored is securely deleted once the purpose for which it was obtained has been fulfilled, unless its retention is required by law or for legitimate business or compliance reasons.

When data is no longer needed, Penaca ensures its removal or destruction is carried out safely and in accordance with industry best practices, so as to prevent unauthorized access, misuse, or recovery. All purging activities are performed using secure methods that maintain the confidentiality and integrity of your personal information.

12. Your Rights

Penaca Private Limited respects your rights regarding your personal information and is committed to ensuring transparency and control over how your data is used.

You may request corrections, updates, or modifications to your personal information at any time by submitting a written request to contact@penacacircular.com. Penaca will review and process such requests in accordance with applicable laws and internal verification procedures.

You also have the right to withdraw your consent or opt out of sharing your information with us. To exercise this right, you may contact us in writing at the above email address. Please note that withdrawing consent may affect your ability to access or use certain features or services provided through the Penaca Platform.

13. Data Security

Penaca Private Limited is committed to safeguarding your personal information and maintaining the integrity of its digital infrastructure. We employ appropriate technical, organizational, and administrative measures to prevent unauthorized access, misuse, alteration, or destruction of your data.

Penaca continuously monitors its systems to identify and address potential vulnerabilities, including by restricting access to suspicious IP addresses or users that may attempt to misuse the platform. In the event of any detected or suspected breach, our team acts promptly to investigate and implement corrective measures to protect user information.

We may also collect certain non-personal and technical data to enhance platform performance and ensure a secure user experience. This includes anonymous details such as server logs, web requests, IP addresses, browser type, language preferences, device identifiers, network connectivity information, timestamps, and diagnostic data.

Such information is gathered solely for analytical, troubleshooting, and security purposes. It does not personally identify users and is linked only to a unique device or session for internal monitoring and service optimization.

14. Limitation of Liability

Penaca Private Limited shall not be held responsible for any breach or violation arising under this Privacy Policy in situations where:

The information in question is already publicly accessible or has entered the public domain through lawful means;
The data has been obtained or disclosed through unauthorized, unlawful, or unethical methods by third parties; or
The information has been submitted by an individual who does not have the legal capacity or authorization to share such details.

Penaca’s responsibility shall be limited strictly to the extent permitted by applicable laws, and it shall not be liable for circumstances beyond its reasonable control or arising from external misuse of data.

15. Monitoring User Interaction

Penaca Private Limited may analyze user activity across its website and related digital platforms to understand how visitors engage with its content and services. This information helps Penaca identify popular sections, improve user experience, and provide content that aligns with visitor interests.

Any tracking or analytical tools used by Penaca are implemented in accordance with applicable data protection standards and are solely intended to enhance service quality not to identify individual users personally.

16. Updates and Amendments to This Policy

Penaca Private Limited reserves the right to revise or modify this Privacy Policy whenever necessary to comply with evolving legal requirements or to reflect changes in its operational practices.

Users are encouraged to review this page periodically to stay informed about any updates. In the event of significant revisions, Penaca will make reasonable efforts to notify users in advance either through email communication or by displaying a prominent notice on the website.

Your continued use of Penaca’s website or services following any modification shall be deemed as your acknowledgment and acceptance of the updated Privacy Policy.

17. Contact Information

If you have any questions, concerns, or feedback regarding this Privacy Policy or the way Penaca Private Limitedhandles your personal information, please feel free to reach out to us. You can contact us via email or by sending written correspondence to the address provided below:

Penaca Private Limited

Hyderabad, Telengana

Email: contact@penaca.in

Penaca will make all reasonable efforts to respond to your concerns and address your queries in a timely and transparent manner.

18. Grievance Redressal

Filing a Complaint:

If you have any concerns, complaints, or issues related to this Privacy Policy or the handling of your personal information, you may write to us at contact@penaca.in. We will acknowledge your grievance within 48 business hoursand aim to provide an initial response within the same period. Any additional clarification or follow-up will also be addressed within 48 business hours of receiving further correspondence. Our team is committed to resolving your concern promptly and effectively.

19. Use of Cookies

Cookies are small text files that are placed on your device to enhance your browsing experience and support the proper functioning of the Penaca website. These files help us remember your preferences, simplify navigation, and provide a more personalized experience each time you visit.

Our website may use cookies to store session information so that you don’t have to repeatedly enter your details during subsequent visits. These cookies also enable us to improve website performance and ensure a smooth, user-friendly experience tailored to your needs.

By continuing to browse or use the Penaca website, you acknowledge and consent to our use of cookies as outlined in this Policy. Please note that only essential cookies necessary for the functioning of our website are active by default. Other non-essential cookies, if introduced in the future, will be subject to your consent.

When you visit our website, our servers may automatically collect limited technical information such as your IP address, browser type, date and time of access, referring URLs, and domain details. This information helps us analyze site traffic, monitor user behavior trends, and enhance the security and performance of our platform. Importantly, this data does not contain personally identifiable information.

Cookies used by Penaca are secure and cannot install software, run programs, or transmit viruses to your system. Each cookie is uniquely associated with your browser and is returned to our website during subsequent visits to maintain continuity and improve usability.

20. Links to External Websites

The Penaca website may include links that direct you to third-party or external websites for your convenience or reference. Please note that such links are provided solely to enhance your browsing experience and do not imply any form of partnership, endorsement, or recommendation by Penaca.

Penaca does not have control over, nor does it assume responsibility for, the content, privacy practices, or policies of these third-party sites. Once you leave our website, the terms of this Privacy Policy no longer apply.

We strongly encourage you to review the privacy statements and terms of use of any external website that collects or handles personally identifiable information before sharing any data. This Privacy Policy is limited solely to the information collected through the official Penaca website.