Privacy Policy

At a glance. We collect limited contact and enquiry information to respond to business enquiries, maintain appropriate business records, operate and secure the Website, and comply with law. We do not sell personal data or use it for third-party advertising.

This Privacy Policy explains how ETHICAA TRADING LLP ("ETHICAA", "we", "us" or "our") collects, uses, stores, discloses and otherwise processes personal data when an individual visits the corporate website on which this Privacy Policy is published (the "Website"), submits a business enquiry, or communicates with us in connection with the Website.

For personal data covered by this Privacy Policy, ETHICAA determines the purposes and means of processing and is the relevant data fiduciary or equivalent responsible entity under applicable data-protection law. Please read this Privacy Policy before providing personal data to us.

1. Scope

This Privacy Policy applies to personal data processed through the Website and to related communications arising from a Website enquiry. The Website is an informational, business-to-business corporate website. It does not currently enable user accounts, online orders, online payments, document uploads, public comments or other user-generated content.

This Privacy Policy does not govern a third party’s website, platform or service, even if the Website links to it. It also does not replace any more specific privacy notice that we may provide for a particular relationship, transaction, event, recruitment process or service.

2. Personal data we collect

2.1 Information you provide

When you use the contact form or communicate with us about an enquiry, we may collect:

Contact details: your name, email address and phone number.
Enquiry details: the message you submit and any company, role, product, service or business-interest information you choose to include.
Correspondence records: subsequent emails or other communications, our responses, and any information or attachments you voluntarily provide during follow-up.
Communication preferences: whether you have chosen to receive promotional or business updates and any later opt-out request.

If you provide personal data about another person, you should have lawful authority to do so and, where required, should make this Privacy Policy available to that person.

2.2 Information collected automatically

When you visit the Website, our hosting, security or technical service providers may automatically create limited technical records. Depending on the Website configuration, these records may include your internet protocol address, browser and device type, operating system, referring page, pages requested, date and time of access, approximate location derived from an IP address, diagnostic data and security events. We use such information to deliver the Website, diagnose errors, protect it from misuse and understand general performance.

The Website may also use cookies or similar technologies. Any analytics or non-essential tracking technology that is enabled will be described in the applicable Cookie Policy or consent settings made available on the Website.

2.3 Information we do not intentionally request

The Website is not intended to collect passwords, payment-card or bank-account details, government identifiers, biometric data, medical or health information, or other sensitive information through the contact form. Please do not include such information, confidential third-party data or unnecessary personal data in the message field. If such information is sent to us without being requested, we may delete it or restrict its use unless retention is reasonably necessary and lawful.

3. Sources of personal data

We obtain personal data:

directly from you when you submit an enquiry or contact us;
automatically from the Website and its technical infrastructure;
from service providers acting on our behalf, such as hosting, email, security or analytics providers; and
from public or professional sources where it is lawful and reasonably necessary to verify or respond to a business enquiry.

4. How and why we use personal data

We may process personal data for the following specified purposes:

Enquiry handling: to receive, assess, route and respond to your message; communicate with you; provide requested company, product or service information; and follow up on a potential business opportunity.
Business records: to maintain an accurate history of enquiries and correspondence, identify previous communications, manage relationships and support internal administration.
Website operations: to provide, maintain, troubleshoot, test and improve the availability, usability and performance of the Website.
Security and misuse prevention: to detect, investigate, prevent and respond to spam, abuse, fraud, malware, unauthorised access and other security or technical incidents.
Analytics: if an analytics service is enabled, to understand aggregated Website traffic and content performance and to support search-engine optimisation and business planning.
Legal and compliance purposes: to comply with applicable law, lawful requests and recordkeeping duties; to obtain professional advice; and to establish, exercise or defend legal rights and claims.
Optional marketing: to send promotional communications or business updates only where you have chosen to receive them or where another lawful basis expressly permits the communication.

We will not use personal data for a new purpose that is incompatible with the purpose for which it was collected unless we provide appropriate notice and obtain consent or rely on another ground permitted by applicable law.

Where consent is required, we will seek consent through a clear affirmative action and provide information that enables the consent to be free, specific, informed, unconditional and unambiguous. Submitting an enquiry authorises us to process the information necessary to receive and respond to that enquiry, subject to the notice presented at the point of collection.

Depending on the circumstances, we may also process personal data where applicable law permits or requires processing without consent, including to comply with a legal obligation, respond to a lawful request, protect the security of the Website, or establish, exercise or defend legal claims.

You may withdraw consent for future processing by contacting us. Withdrawal does not affect processing already lawfully carried out and does not require us to erase information that we must or may lawfully retain. If information reasonably required to handle an enquiry is not provided, we may be unable to respond fully.

6. Promotional communications

Responding to an enquiry and sending information you requested are not treated as unrelated promotional marketing. If we offer promotional emails or similar updates, we will keep that choice separate from the contact-form submission wherever consent is required. We will not treat silence, inactivity or a pre-selected box as consent.

You may opt out of promotional communications at any time by using the unsubscribe method in the communication, where available, or by emailing info@ethicaa.in. We may retain a limited suppression record so that we can respect the opt-out. Even after a marketing opt-out, we may send non-promotional communications that are reasonably necessary to respond to an active enquiry or comply with law.

7. When we disclose personal data

We do not sell, rent or trade personal data. We also do not disclose an enquiry to manufacturers, suppliers, principals, logistics providers or overseas counterparties merely because the enquiry was submitted. We may disclose limited personal data only where reasonably necessary in the following circumstances:

Service providers: to providers of Website hosting, business email, storage, backup, information technology, cybersecurity, analytics or similar support that process information for us or provide technical infrastructure.
Professional advisers: to lawyers, accountants, auditors, insurers and other advisers subject to professional duties or appropriate confidentiality obligations.
Law and protection: to a court, regulator, government authority, law-enforcement body or other person where disclosure is required by law, made in response to valid legal process, or reasonably necessary to protect rights, safety, property or the integrity of the Website.
Corporate change: to an actual or proposed successor, investor or professional adviser in connection with a restructuring, merger, transfer of business or assets, insolvency or similar corporate event, subject to appropriate confidentiality and lawful-use restrictions.
At your request: where you ask us to communicate or share information with a specified third party and the disclosure is lawful.

If handling a future enquiry requires us to share personal data with a commercial counterparty, we will provide appropriate information and seek consent where required before doing so. We require service providers to handle personal data consistently with their role, our instructions and applicable law, but they may process limited information for their own legal compliance and security obligations.

8. Storage and processing locations

Website enquiries are recorded in our Website enquiry database and ordinarily delivered to and retained in our business email system and associated backups or business correspondence records. Website hosting, email and technical providers may process data in India or in another country, depending on their infrastructure.

Where personal data is processed outside India, we will take the steps required by applicable Indian law and use appropriate contractual, organisational or technical safeguards having regard to the nature of the processing. Such processing remains subject to lawful access requirements in the relevant jurisdiction. We will observe any transfer restriction or government requirement that becomes applicable.

9. Retention and deletion

We retain enquiry information only for as long as the specified purpose remains served or as retention is otherwise reasonably necessary and lawful. Relevant considerations include:

the time needed to respond to and follow up on the enquiry;
whether an ongoing or reasonably anticipated business relationship exists;
the value of retaining an accurate business correspondence history and avoiding duplicate or inconsistent communications;
applicable legal, regulatory, tax, accounting, audit or cybersecurity requirements;
the limitation period for, or reasonable anticipation of, a legal claim or dispute; and
the need to investigate or remediate a security incident.

We periodically review retained information. When the relevant purpose is no longer served, consent has been withdrawn where consent is the basis, and no lawful reason for continued retention applies, we will take reasonable steps to erase, anonymise or securely restrict the information. Data in backups may remain until the applicable backup cycle expires, subject to access restrictions and non-restoration except for legitimate continuity, security or legal purposes.

A request for erasure does not override a retention duty imposed by law and does not require deletion of information that is reasonably necessary to establish, exercise or defend legal rights or to maintain a record of a privacy preference such as a marketing opt-out.

10. Security

We use reasonable technical and organisational safeguards appropriate to the nature and volume of the personal data we process. These may include limiting access to authorised persons, account authentication, security updates, malware protection, backups, logging and monitoring, service-provider controls and incident-response procedures.

No website, email system, transmission method or storage system is completely secure. We therefore cannot guarantee absolute security. You should avoid sending sensitive or unnecessary information through an unencrypted contact form or ordinary email. If we become aware of a personal-data breach, we will investigate and make notifications to affected individuals and competent authorities when and as required by applicable law.

11. Your privacy rights and choices

Subject to applicable law and the status of the relevant statutory provisions, you may ask us to:

provide information about personal data we process about you and, where applicable, a summary of the processing and disclosures;
correct, complete or update personal data that is inaccurate or incomplete;
erase personal data when the purpose is no longer served and no lawful retention ground applies;
withdraw consent for future consent-based processing;
stop promotional communications;
raise a grievance about our handling of personal data; and
exercise any additional right that becomes available under applicable law, including a right to nominate another individual where and when that right applies.

To make a request, email info@ethicaa.in using the subject line "Privacy Request" and describe the request. Please contact us from the email address associated with your enquiry where possible. We may request information reasonably necessary to verify identity, locate the relevant record and protect other persons.

We will endeavour to resolve a complete, verifiable privacy request within 30 days, or within any different period required or permitted by applicable law. A request may be limited or refused where the law allows, including where identity cannot reasonably be verified, the request would adversely affect another person’s rights, the data cannot reasonably be located, or retention is required or permitted by law. Where appropriate, we will explain the reason.

If you are not satisfied, you may first ask our Privacy and Grievance Contact to review the matter. Where applicable law gives you that right, and after completing any required internal grievance process, you may approach the competent authority, including the Data Protection Board of India when the relevant provisions apply.

12. Children’s personal data

The Website is intended for business audiences and is not directed to individuals under 18 years of age. We do not knowingly seek to process a child’s personal data through the Website. A child should not submit the contact form. If you believe a child has provided personal data to us, contact us so that we can assess and take appropriate action. Where processing a child’s personal data is necessary, we will obtain verifiable parental consent and comply with applicable restrictions unless a lawful exception applies.

The Website may contain links to third-party websites or social-media platforms, including LinkedIn and Instagram. Clicking a link may allow that third party to collect data from your browser or account. The third party, not ETHICAA, determines its own processing and privacy practices. We encourage you to review the third party’s privacy notice and settings. A link does not make us responsible for that third party’s security, content or privacy practices.

14. Automated decisions and profiling

We do not currently use information submitted through the Website to make decisions based solely on automated processing that produce legal or similarly significant effects, and we do not use Website enquiry data for third-party advertising profiles. If this changes, we will update this Privacy Policy and provide any additional notice or choice required by law.

15. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes in the Website, our practices, service providers or applicable law. The revised policy will be posted on the Website. Where a change materially affects how we process personal data, we will provide additional notice or seek fresh consent where required. An update to this Privacy Policy does not by itself convert a previously specified purpose into an unrelated purpose.

16. Applicable law

This Privacy Policy is intended to be interpreted consistently with applicable laws of India, including the Information Technology Act, 2000 and rules currently in force under it, and the Digital Personal Data Protection Act, 2023 and Digital Personal Data Protection Rules, 2025 as and when the relevant provisions apply. Nothing in this Privacy Policy limits any right or remedy that cannot lawfully be limited.

17. Contact and grievance redressal

For a privacy question, request or grievance, contact:

ETHICAA TRADING LLP

Privacy and Grievance Contact

Email: info@ethicaa.in

Registered office: the address displayed on the Contact page of the Website