Privacy Policy

Thoughts Refilling Digital Marketing Agency & Training Center Korba, Chhattisgarh, India info@thoughtsrefilling.com

Effective Date: June 11, 2025 Last Updated: June 11, 2025

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1. Introduction

Thoughts Refilling (“We”, “Us”, “Our”, or “Company”) is committed to protecting the privacy and personal data of every individual who interacts with our business. This Privacy Policy explains how we collect, use, store, share, and protect your information when you visit our website, enroll in our training programs, purchase merchandise, or acquire digital products from us.

By using any of our services, you consent to the practices described in this Privacy Policy. If you do not agree with any part of this policy, please discontinue use of our services.

This Privacy Policy is in compliance with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the Digital Personal Data Protection Act, 2023 (DPDPA).

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2. Information We Collect

We collect information in the following ways:

2.1 Information You Provide Directly

• Full name, email address, phone number, and billing/shipping address when you register, enroll, or make a purchase.
• Payment information (processed securely through third-party payment gateways; we do not store full card details).
• Business name, GST number, and related details when engaging us for professional services.
• Messages, queries, or feedback submitted through contact forms or email.
• Portfolio, work samples, or other content shared during onboarding for digital marketing services.

2.2 Information Collected Automatically

• IP address, browser type, device type, and operating system when you visit our website.
• Pages visited, time spent on pages, and referring URLs through cookies and analytics tools.
• Approximate geographic location based on IP address.

2.3 Information from Third Parties

• Social media profile information if you interact with our social media pages or connect your accounts.
• Information shared by business partners or referral sources to facilitate service delivery.

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3. How We Use Your Information

We use the information we collect for the following purposes:

• To process and fulfill orders for merchandise and digital products.
• To deliver training programs, issue certificates, and communicate course-related updates.
• To provide, manage, and improve our digital marketing services for clients.
• To send transactional emails such as order confirmations, invoices, and receipts.
• To respond to your inquiries, support requests, or feedback.
• To send promotional communications, newsletters, or updates about our services — only where you have given consent or where permitted by law.
• To analyse website usage and improve our online experience.
• To detect, prevent, and address fraud, security incidents, or technical issues.
• To comply with legal obligations under applicable Indian law.

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4. Legal Basis for Processing

We process your personal data on the following lawful grounds:

• Consent — where you have explicitly agreed to the processing of your data for a specific purpose.
• Contractual Necessity — where processing is necessary to fulfill a service agreement, order, or enrollment.
• Legal Obligation — where we are required by law to process your data (e.g., tax, GST compliance).
• Legitimate Interest — where processing is necessary for our business operations and does not override your rights (e.g., improving our services, preventing fraud).

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5. Cookies & Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience and gather analytical data.

Types of cookies we use:

• Essential Cookies — necessary for the website to function correctly.
• Analytics Cookies — help us understand how visitors interact with our website (e.g., Google Analytics).
• Marketing Cookies — used to deliver relevant advertisements and track campaign performance (e.g., Meta Pixel, Google Ads).

You can manage or disable cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of our website. By continuing to use our website without changing your cookie settings, you consent to our use of cookies.

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6. Sharing of Your Information

Thoughts Refilling does not sell your personal information to any third party. We may share your data with:

• Payment Gateways — to securely process transactions (e.g., Razorpay, PayU, or similar services). These providers operate under their own privacy policies.
• Shipping & Logistics Partners — to deliver merchandise orders. Only the information necessary for delivery (name, address, phone number) is shared.
• Email & Communication Platforms — to send transactional and marketing communications (e.g., Mailchimp, WhatsApp Business API, or similar tools).
• Analytics Providers — to understand website traffic and user behaviour (e.g., Google Analytics, Meta Insights).
• Legal & Regulatory Authorities — when required by law, court order, or government regulation.
• Professional Advisors — such as lawyers or accountants, under strict confidentiality obligations.

In all cases, we only share the minimum information necessary and require third parties to maintain appropriate data security standards.

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7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law.

• Client & service data — retained for the duration of the engagement and up to 5 years thereafter for legal and tax compliance purposes.
• Training & enrollment records — retained for 3 years from the date of program completion.
• Order & purchase records — retained for 7 years in compliance with Indian accounting and GST regulations.
• Marketing communications data — retained until you withdraw consent or unsubscribe.
• Website analytics data — retained for up to 26 months as per standard analytics platform limits.

Upon expiry of the applicable retention period, your data will be securely deleted or anonymised.

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8. Your Rights Under the DPDPA 2023

Under the Digital Personal Data Protection Act, 2023, you have the following rights as a Data Principal:

• Right to Access — You may request a summary of the personal data we hold about you and how it is being processed.
• Right to Correction — You may request correction of inaccurate or incomplete personal data.
• Right to Erasure — You may request deletion of your personal data where it is no longer necessary for the purposes it was collected, subject to legal retention obligations.
• Right to Grievance Redressal — You have the right to raise a complaint or concern regarding our handling of your personal data.
• Right to Withdraw Consent — Where processing is based on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
• Right to Nominate — You may nominate an individual to exercise your rights in the event of your death or incapacity.

To exercise any of the above rights, please write to us at info@thoughtsrefilling.com. We will respond to your request within a reasonable timeframe and in accordance with applicable law.

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9. Data Security

Thoughts Refilling implements reasonable and appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Secure storage of data on password-protected and encrypted systems.
• Restricted access to personal data on a need-to-know basis among our team.
• Use of HTTPS and SSL encryption on our website.
• Secure payment processing through PCI-DSS compliant payment gateways.

While we take all reasonable precautions, no method of data transmission or storage is 100% secure. In the event of a data breach that is likely to affect your rights, we will notify you as required by applicable law.

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10. Children’s Privacy

Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected data from a person under 18 without verifiable parental or guardian consent, we will take prompt steps to delete such information. If you believe a minor has provided us with their data, please contact us at info@thoughtsrefilling.com.

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11. Third-Party Links

Our website and communications may contain links to third-party websites, social media platforms, or partner portals. Thoughts Refilling is not responsible for the privacy practices or content of those third-party sites. We encourage you to review their privacy policies before providing any personal information.

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12. Marketing Communications

We may send you promotional emails, WhatsApp messages, or SMS communications about our services, offers, and training programs if you have consented to receiving them. You may opt out of marketing communications at any time by:

• Clicking the “Unsubscribe” link in any email we send.
• Replying “STOP” to any SMS or WhatsApp message.
• Writing to us at info@thoughtsrefilling.com with a request to be removed from our mailing list.

Please note that opting out of marketing communications will not affect transactional messages related to orders, services, or legal obligations.

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13. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time to reflect changes in our practices, services, or applicable law. The updated policy will be posted on our website with a revised effective date. We encourage you to review this policy periodically. Continued use of our services after any update constitutes your acceptance of the revised policy.

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14. Grievance Officer

In accordance with the Information Technology Act, 2000 and the DPDPA 2023, we have designated a Grievance Officer to address any concerns or complaints regarding our handling of personal data.

Grievance Officer Thoughts Refilling Korba, Chhattisgarh, India Email: info@thoughtsrefilling.com

We will acknowledge your complaint within 72 hours and aim to resolve it within 30 days of receipt.

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15. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy, please contact us:

Thoughts Refilling Korba, Chhattisgarh, India Email: info@thoughtsrefilling.com

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By using our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your information as described herein.