- 1. Who we are
- 2. What we collect
- 3. How we use it
- 4. Who we share it with
- 5. Storage, security and retention
- 6. Your rights
- 7. Cookies and local storage
- 8. Children
- 9. Grievance officer
- 10. Changes to this policy
1. Who we are
Arrow Infra Structure Private Limited ("we", "us"), the company behind Velora Universal, decides how and why your personal data is processed. This policy covers this website and its member portal, and follows the Digital Personal Data Protection Act, 2023 and the Information Technology Act, 2000 and the rules made under them.
2. What we collect
Customers and website visitors
- Name, phone number, email address and delivery address.
- Order details, invoices, and messages you send to customer care.
- Details you enter in the enquiry form: name, business, email, phone, city and message.
- Basic technical data that our servers log automatically, such as IP address, browser type and pages requested.
We do not collect or store card numbers, CVVs, UPI PINs or net banking passwords.
Direct sellers (members)
- Name, date of birth, photograph, phone, email and address.
- Identity and address proof, and PAN.
- Bank account or UPI details, to pay commissions.
- Your signed direct seller agreement, team and sponsor details, sales records, commission statements and tax (TDS) records.
- Your member portal login and activity, kept to secure your account.
3. How we use it
- To process, deliver and support your orders, returns and refunds.
- To handle complaints and grievances, and to keep records we must keep by law.
- To verify direct sellers' identity and address, maintain the register of direct sellers, and issue ID cards, as required by the Consumer Protection (Direct Selling) Rules, 2021.
- To calculate and pay direct seller commissions, deduct and deposit tax, and issue statements.
- To reply to trade enquiries.
- To prevent fraud and keep the website and member portal secure.
We process your data with your consent, which you give when you place an order, submit a form, or sign up as a direct seller, and where the law allows us to process it without consent, such as to meet a legal obligation. We do not use your data for marketing unless you have agreed to it, and we never sell it.
4. Who we share it with
- Cashfree Payments India Private Limited, our payout service provider, to verify direct sellers' bank accounts and pay commissions to them.
- [[Name and contact details of the payment service provider for customer payments, if any]], for customer payments.
- Courier and logistics partners, to deliver orders.
- Our IT and cloud hosting providers, including those that run this website and the member portal. They process data only on our instructions.
- Auditors, accountants and legal advisers.
- Government authorities, regulators and courts, where the law requires it. This includes the Income Tax Department for TDS, and authorities monitoring direct selling.
- A customer who bought from a direct seller may ask us, in writing, for that direct seller's name, address, email and phone number for resolving a dispute. The Direct Selling Rules require us to provide it.
5. Storage, security and retention
Your data is stored with [[e.g. Amazon Web Services, Mumbai region, India]]. We use reasonable security safeguards, including encrypted connections (HTTPS), access controls and permissions in the member and office portals, and limiting access to staff who need it.
We keep personal data only as long as we need it for the purposes above. Order, invoice, tax and direct seller records are kept for [[e.g. 8 years]], or longer if the law requires. After that, we delete or anonymise them.
6. Your rights
Under the Digital Personal Data Protection Act, 2023, you can:
- ask for a summary of the personal data we hold about you and how we use it;
- ask us to correct, complete, update or erase your data;
- withdraw your consent at any time (this does not affect processing already done, and we may still keep data the law requires us to keep);
- nominate another person to exercise your rights if you die or become unable to;
- raise a grievance with us, and then with the Data Protection Board of India if you are not satisfied.
To use any of these rights, write to our grievance officer (below). We may need to verify your identity first.
7. Cookies and local storage
We do not use advertising or analytics cookies. We set one cookie to remember your language. The member and office portals store your sign-in session and preferences, such as light or dark mode, in your browser so you stay signed in. If we add analytics in future, we will update this policy first.
8. Children
Our website and products are meant for adults. We do not knowingly collect personal data from anyone under 18. Direct sellers must be at least 18.
9. Grievance officer
For privacy questions, requests and complaints:
- Name
- [[Grievance officer name]]
- Designation
- [[Designation]]
- Phone
- [[Grievance officer phone]]
Postal address: Arrow Infra Structure Private Limited, B1, First Floor, Signature Apartment, Rajarhat Main Road, near Indian Petrol Pump, Raigachi, New Town, North 24 Parganas, Kolkata, West Bengal 700135.
10. Changes to this policy
We may update this policy. The date at the top shows when it last changed. If a change is significant, we will tell customers and direct sellers by email or on this website.