Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") sets out how BonV Technology Private Limited ("BonV", "Company", "we", "our", or "us"), a company incorporated under the Companies Act, 2013, having its registered office at HD-094, WeWork Latitude, 9th Floor, RMZ Latitude Commercial, Bellary Road, Hebbal, Bangalore, Karnataka, India - 560024, collects, uses, stores, processes, discloses, and protects the personal data of individuals ("Users", "you", or "your") who access or use our website at www.bonvaero.com, mobile applications, APIs, or other digital interfaces (collectively, "Platform"), our products, services, or otherwise interact with us.

BonV is committed to protecting the privacy and personal data of its Users in compliance with the Information Technology Act, 2000 ("IT Act"), the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("IT Rules"), the Digital Personal Data Protection Act, 2023 ("DPDPA"), and the rules and regulations framed thereunder ("DPDP Rules"), as applicable and in force from time to time. This Policy is made available in English and BonV shall endeavour to make it available in Kannada for users located in Karnataka, in accordance with the requirements of the DPDPA and applicable CCPA Guidelines 2021.

By accessing or using our Platform or Services, you acknowledge that you have read, understood, and agree to be bound by this Policy. If you do not agree with any provision of this Policy, please refrain from using our Platform or Services.

2. Definitions

"Data Fiduciary" means BonV Technology Private Limited, which alone or in conjunction with other persons determines the purpose and means of processing of personal data, as defined under Section 2(i) of the DPDPA.

"Data Principal" means the individual to whom the personal data relates, and in the case of a child (below 18 years of age), includes the parent or lawful guardian, as defined under Section 2(j) of the DPDPA.

"Data Processor" means any person who processes personal data on behalf of a Data Fiduciary, as defined under Section 2(k) of the DPDPA.

"Personal Data Breach" means any unauthorised processing of personal data or accidental disclosure, acquisition, sharing, use, alteration, destruction, or loss of access to personal data that compromises the confidentiality, integrity, or availability of personal data, as defined under Section 2(n) of the DPDPA.

"Personal Data" means any data about an individual who is identifiable by or in relation to such data, as defined under Section 2(t) of the DPDPA.

"Processing" means any operation or set of operations performed on digital personal data, including collection, recording, organisation, structuring, storage, adaptation, retrieval, use, alignment, combination, indexing, sharing, disclosure, restriction, erasure, or destruction.

"Sensitive Personal Data or Information" ("SPDI") as defined under the IT Rules, includes passwords; financial information such as bank account, credit card, or debit card details; physical, physiological, and mental health condition; sexual orientation; medical records and history; and biometric information. To the extent the DPDPA 2023 prescribes a different or broader category of sensitive data in rules framed thereunder, such categories shall also be treated as SPDI under this Policy.

3. Information We Collect

3.1 Information You Provide Directly

When you interact with our Platform, submit enquiry forms, request product demonstrations, subscribe to updates, apply for employment, or otherwise contact us, we may collect the following categories of personal data, each collected only to the extent necessary for the specific purpose for which it is sought (see Clause 4 for purpose linkage):

3.2 Information Collected Automatically

When you access our Platform, we automatically collect certain technical and usage information through cookies, server logs, and similar technologies, subject to your cookie consent preferences as described in Clause 7. IP addresses and device identifiers collected automatically may constitute personal data under the DPDPA. Analytics and preference cookies are placed only with your prior consent, including:

3.3 Sensitive Personal Data or Information (SPDI)

BonV does not intentionally collect Sensitive Personal Data or Information as defined under the IT Rules through its Platform. In the event that SPDI is collected in the course of business engagements (such as financial information for contractual payments or biometric data for facility access at our premises), such collection shall be subject to explicit prior consent, processed only for the specified purpose, and handled in strict compliance with Sections 5, 6, 7, and 8 of the DPDP Act.

4. Purpose of Collection and Use

We process your personal data only for lawful, specified, and clearly defined purposes, including:

We shall not process your personal data for any purpose beyond what is stated in this Policy or for which separate consent has been obtained.

5. Consent Framework

5.1 Obtaining Consent

Where processing is based on consent, BonV shall obtain your free, specific, informed, unconditional, and unambiguous consent prior to collecting and processing your personal data. Consent shall be sought through a clear affirmative action, with categories of personal data linked to the specified purposes of processing, as required under Section 6 of the DPDPA and the DPDP Rules, 2025. Each consent notice issued by BonV shall, in accordance with Section 5 of the DPDPA, contain: (a) a description of the personal data sought to be collected and the specific purpose of processing; (b) the manner in which you may exercise your rights under the DPDPA, including withdrawal of consent; and (c) the manner in which you may make a complaint to the Data Protection Board of India. Consent to this Privacy Policy does not itself constitute consent to any specific processing activity — separate, specific consent shall be sought for each purpose where consent is the legal basis.

5.2 Withdrawal of Consent

You have the right to withdraw your consent at any time by using the consent preference centre accessible from the Platform footer or by contacting our Grievance Officer at [email protected]. The mechanism for withdrawing consent shall be as easy to use as the mechanism by which consent was given, in accordance with Section 6(7) of the DPDPA. Withdrawal of consent shall not affect the lawfulness of processing carried out prior to such withdrawal. Upon withdrawal, BonV shall cease processing your personal data for the relevant purpose within thirty (30) days of receipt of withdrawal and, unless retention is required by law or legitimate business interest, shall erase or anonymise such data in accordance with Clause 10.

5.3 Legitimate Uses Without Consent

In accordance with Section 7 of the DPDPA, BonV may process personal data without consent for certain legitimate uses, including:

6. Disclosure and Transfer of Personal Data

6.1 Disclosure Practices

BonV does not sell, rent, trade, or lease your personal data to any third party for marketing purposes. We may disclose your personal data to the following categories of recipients, subject to appropriate contractual safeguards:

6.2 Handling of Sensitive Personal Data

Any disclosure of SPDI shall be made only with the prior consent of the Data Principal, unless such disclosure is required by law or is necessary for the performance of a lawful contract, in accordance with the IT Rules. SPDI shall not be published or made available in the public domain.

6.3 Cross-Border Transfer

Your personal data may be transferred to, stored, or processed outside India in connection with the use of third-party services (such as cloud hosting or analytics platforms). Such transfers shall be made only to countries or territories notified by the Central Government of India as permissible destinations for cross-border transfer of personal data under Section 16 of the DPDPA, once such notification is issued. Pending such notification, BonV shall implement appropriate safeguards including standard contractual clauses, data transfer agreements, or other mechanisms recognised under applicable Indian law to ensure an equivalent level of data protection. BonV shall monitor and update its cross-border transfer practices upon issuance of Government notifications under Section 16 of the DPDPA. BonV shall ensure that any Data Processor located outside India provides the same level of data protection as required under this Policy and applicable Indian law.

7. Cookies and Tracking Technologies

Our Platform uses cookies and similar tracking technologies to enhance your browsing experience and to gather analytical data. When you first visit our Platform, you will be presented with a cookie consent banner with non-essential cookies set to 'off' by default (privacy-by-default). You must affirmatively opt in to each category of non-essential cookies before they are placed on your device. Your preferences are recorded and respected across sessions.

7.1 Types of Cookies

7.2 Google Analytics

We use Google Analytics to collect pseudonymised or aggregated visitor data, including traffic sources, popular content, and device information. Google Analytics may set cookies on your device and process data in accordance with Google's privacy policy. Processing by Google Analytics may involve transfer of data outside India — BonV has implemented the Google Ads Data Processing Terms and applicable standard contractual clauses to address cross-border transfer obligations under Section 16 of the DPDPA. You may opt out of Google Analytics tracking by installing the Google Analytics opt-out browser add-on or by adjusting your cookie preferences.

7.3 Managing Cookies

You may manage, disable, or delete cookies at any time through your browser settings or through the cookie preference centre accessible from the Platform footer. Please note that disabling certain cookies may impair the functionality of our Platform.

8. Data Security

8.1 Security Measures

BonV implements reasonable security practices and procedures commensurate with the nature of the information being protected and the sensitivity of our business operations. In accordance with the IT Rules and the security requirements under the DPDPA, our security measures include but are not limited to:

8.2 Information Security Standards

BonV's information security programme is designed to implement reasonable security practices and procedures as contemplated under the IT Rules and the DPDPA. BonV's security practices are aligned with ISO/IEC 27001 (Information Security Management Systems) or an equivalent standard. BonV shall periodically review and update its security practices.

8.3 Limitations

While BonV employs commercially reasonable security measures, no method of transmission over the internet or method of electronic storage is completely secure. BonV cannot guarantee absolute security of your personal data. In the event of a security breach, BonV shall follow the incident response procedures set out in Clause 9 below.

9. Data Breach Notification

In the event of a personal data breach that compromises the confidentiality, integrity, or availability of personal data under BonV's control, BonV shall:

10. Data Retention and Deletion

BonV retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The indicative retention periods are as follows:

Upon expiry of the applicable retention period, or upon a valid request for erasure by the Data Principal, personal data shall be securely deleted or irreversibly anonymised. Deletion shall be carried out using methods compliant with recognised data sanitisation standards (such as NIST SP 800-88 or equivalent) appropriate to the storage medium. Notwithstanding the above, BonV shall retain system and access logs for a minimum of one hundred and eighty (180) days as required under CERT-In Directions 2022, which retention period shall override any shorter erasure request for such logs.

11. Rights of Data Principals

In accordance with the DPDPA and the IT Rules, you have the following rights in relation to your personal data:

To exercise any of the above rights, please contact our Grievance Officer using the details provided in Clause 14. BonV shall respond to all requests within thirty (30) days of receipt, or within such other period as may be prescribed under the DPDP Rules. BonV may extend this period by a further thirty (30) days where the complexity or volume of requests requires it, in which case BonV shall notify you of the extension and the reasons for it.

12. Children's Data

BonV's Platform and Services are not directed at individuals below the age of eighteen (18) years. BonV does not knowingly collect or process personal data of children without verifiable consent from a parent or lawful guardian. In accordance with Section 9(3) of the DPDPA, BonV shall not undertake tracking or behavioural monitoring of children and shall not target advertising at children. In the event that we become aware that personal data of a child has been collected without appropriate parental consent, we shall take immediate steps to delete such data. If you are a parent or guardian and believe that your child has provided personal data to BonV without your consent, please contact us at [email protected].

Verifiable parental consent shall be obtained through mechanisms specified under the DPDP Rules, 2025, including verification through existing account information, government-issued identification, or tokens issued by authorised entities.

13. Third-Party Services and Links

Our Platform may contain links to third-party websites, platforms, or services that are not operated or controlled by BonV. This Policy does not apply to such third-party services. BonV is not responsible for the privacy practices, content, or data handling of any third-party website or service. We encourage you to review the privacy policies of any third-party services before providing your personal data.

Note: third-party tools embedded within the Platform (such as analytics or CRM services) are Data Processors acting on BonV's instructions and are subject to data processing agreements as described in Clause 6.1. BonV remains responsible for their compliance with this Policy and applicable law.

14. Grievance Officer

In accordance with Rule 5(9) of the IT Rules and the requirements of the DPDPA, BonV has designated the following Grievance Officer to address your concerns regarding data privacy and this Policy:

The Grievance Officer shall acknowledge your complaint within a reasonable time and endeavour to resolve it within thirty (30) days of receipt, as required under applicable law. If you are not satisfied with the resolution, you may escalate your complaint to the Data Protection Board of India in accordance with the procedures prescribed under the DPDPA.

15. Changes to This Policy

BonV reserves the right to update or modify this Policy at any time. Any material changes will be communicated by posting the updated Policy on our Platform with a revised "Last Updated" date. Where material changes affect the processing of your personal data, BonV shall provide reasonable prior notice and, where required by law, obtain your renewed consent. Your continued use of the Platform or Services following the posting of changes constitutes your acceptance of the revised Policy to the extent that acceptance by continued use is valid under applicable law — certain changes will require your active, affirmative consent regardless of continued use.

16. Compliance with Indian Data Protection Regulations

BonV complies with the applicable requirements under the following legislation:

BonV shall continue to monitor and adapt its privacy practices to remain compliant with the evolving regulatory framework. BonV shall periodically assess whether it meets the criteria for designation as a Significant Data Fiduciary under Section 10 of the DPDPA, as prescribed by the Central Government from time to time, and shall implement any additional obligations applicable to Significant Data Fiduciaries upon such designation.

17. Governing Law

This Policy shall be governed by and construed in accordance with the laws of India. Any disputes arising from or in connection with this Policy shall be subject to the exclusive jurisdiction of the competent courts at Bhubaneswar, India, without prejudice to the jurisdiction of the Data Protection Board of India under the DPDPA.

18. Automated Decision-Making and Profiling

BonV may use artificial intelligence, machine learning algorithms, or other automated means to process your personal data, including for purposes such as routing enquiries, personalising content, detecting fraud, or evaluating suitability for partnerships or employment. Where such automated processing produces decisions that significantly affect you, BonV shall:

BonV shall not use automated processing as the sole basis for decisions that produce significant legal or similarly significant effects without human oversight.

19. Marketing and Promotional Communications

BonV will send marketing emails, SMS messages, or other promotional communications only with your prior, separate, and explicit consent, in accordance with Section 6 of the DPDPA. Consent for marketing communications is distinct from consent for other processing activities. For SMS and voice-based commercial communications, BonV complies with the Telecom Commercial Communications Customer Preference Regulations, 2018 (TRAI TCCCPR 2018). You may register your preferences (including DND status) on the TRAI preference portal.

You may opt out of marketing communications at any time by:

Opt-out requests will be processed within ten (10) business days.

20. Data Protection Impact Assessments

BonV conducts Data Protection Impact Assessments (DPIAs) for new or significantly changed processing activities that are likely to result in a high risk to the rights and freedoms of Data Principals, including:

Where BonV is designated as a Significant Data Fiduciary under Section 10 of the DPDPA, it shall conduct DPIAs and periodic audits as prescribed by the Central Government and submit reports to the Data Protection Board as required.

21. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or BonV's data handling practices, please contact us at:

Email: [email protected]

Address: HD-094, WeWork Latitude, 9th Floor, RMZ Latitude Commercial, Bellary Road, Hebbal, Bangalore, Karnataka, India – 560024

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