Privacy policy
1. Who we are and what this policy covers
Red Otter Farms Private Limited, a company incorporated under the Companies Act, 2013 (CIN: U01100DL2019PTC350161), with its registered office at 146B, Shahpur Jat, New Delhi-110049, India ("Red Otter Farms", "ROF", "we", "us", "our"), operates the website redotterfarms.health, our WhatsApp ordering and support channel, and the programmes offered through them: store orders, subscriptions, OtterPass, Nutrition Meter, the Loyalty Program, the ROF Otterbalance and the FibreFirst Club.
This policy explains what personal data we collect, how we use, share, store and protect it, and the rights you have. For the purposes of the Digital Personal Data Protection Act, 2023 ("DPDP Act"), ROF is the Data Fiduciary for your personal data.
Please read this policy carefully. By creating an account, placing an order, joining a programme or joining a waitlist, you consent to the processing described here. You can withdraw consent at any time (see Section 8). If you do not agree with this policy, please do not use the site.
2. Personal data we collect
| Category | What it includes | When we collect it |
|---|---|---|
| Identity and contact | Name, mobile number (including the WhatsApp number you log in with), email address | Account creation, WhatsApp login, orders, waitlists |
| Delivery | Billing and shipping addresses, pincode, city or delivery zone you select, delivery instructions | Orders, subscriptions, memberships |
| Orders and subscriptions | Products ordered, quantities, delivery preferences, subscription plan, skips and pauses, order history | Each order or change |
| Payment | Transaction ID, amount, payment method type and status. Card, UPI and bank details are handled by our payment gateway; we do not store complete card numbers or UPI PINs | Payment |
| Programme data | ROF Otterbalance and transactions; Loyalty Program tier and cumulative annual spend; OtterPass and Nutrition Meter status | While you use these programmes |
| FibreFirst Club | Membership number, joining and renewal dates, Founding Member status, referral code, orders per order window, milling batch | Club membership and orders |
| Household preferences (optional) | Household size, dietary preferences, products or grains you want to try | Only if you choose to share them |
| Communications | Messages, calls, WhatsApp chats, emails, feedback, and photos or videos you send about an order | When you contact us |
| Referral data | Name and mobile number of a person you refer | When you refer someone |
| Device and usage | IP address and approximate location, browser type and version, device type and operating system, pages visited and time spent, referring website and search terms, cookie identifiers | Automatically, when you use the site |
Nutrition Meter: the meter adds up the calories, protein and fibre of the products in your cart, using our product data. It does not collect health records, diet plans or medical information.
We do not knowingly collect health records, medical diagnoses or government ID numbers. Please do not send us such information.
Referrals: if you share another person's details with us, you confirm that they have agreed to it. We use their details only to send one invitation and delete them within 90 days if they do not join.
3. How we use your personal data
- Order processing: to process, harvest or mill, pack and deliver your orders, communicate about your purchases and provide customer support.
- Account and programme management: to create and manage your account, save your preferences, maintain order history, and run subscriptions, OtterPass, Nutrition Meter, the Loyalty Program, the ROF Otterbalance and FibreFirst Club memberships.
- Payments and accounts: to collect payments, issue GST invoices, process refunds and Otterbalance credits, and maintain statutory books of account.
- Service messages: order confirmations, delivery updates, subscription and renewal reminders, FibreFirst order window openings and milling updates, and changes to our terms, by WhatsApp, SMS or email.
- Referral and loyalty benefits: to track referrals and spend thresholds and apply the benefits you have earned.
- Planning and improvement: to plan harvests and milling against confirmed demand, plan sowing and procurement with our farmer network, and analyse usage to improve our website, products and services. We use aggregated or de-identified data for this wherever possible.
- Marketing: to send news about new products and special offers. You can opt out at any time without affecting your orders or memberships.
- Legal compliance and protection: to comply with tax, food safety, consumer protection and other laws, and to protect our rights and prevent fraud or misuse.
We do not use your personal data for automated decisions that have legal or similarly significant effects on you.
4. Who we share it with
We do not sell or rent your personal data. We share it only as needed for the purposes above:
| Recipient | Why |
|---|---|
| Payment gateway (Razorpay) | To process payments and refunds |
| Delivery and courier partners | To deliver your orders (name, phone and address only) |
| Messaging and email providers (WhatsApp by Meta, Gmail, MSG91) | To send WhatsApp, SMS and email messages |
| Cloud hosting and database providers (Amazon AWS) | To host the website and store account data |
| Analytics and advertising providers (Meta, Google) | To measure site performance and, with consent, show relevant ads |
| Professional advisers (auditors, lawyers) | For accounting, audit and legal advice |
| Government and regulators | Where required by law, court order or lawful request, or to protect our rights and safety |
| A successor business | In connection with a merger, acquisition or sale of assets, subject to this policy |
| Anyone else, with your consent | Where you have given us permission |
All service providers act on our instructions under contracts that require them to keep your data confidential and secure.
5. Where your data is stored
Your data is stored on servers located in India. Where a service provider stores or processes data outside India, we transfer it only to countries not restricted by the Government of India under the DPDP Act, and with appropriate safeguards.
6. How long we keep it
- Account and programme data: while your account is active and for 7 years after it is closed or your membership ends, so we can handle queries and disputes.
- Order, invoice and payment records: for the period required under tax, GST and company law (generally up to 8 years).
- Waitlist data (non-members): until the waitlisted programme opens and for 60 months after, unless you join.
- Marketing consent records: until you withdraw consent, plus the period needed to prove the consent was obtained.
When we no longer need your data, we securely delete or anonymise it.
7. How we protect it
We use appropriate technical and organisational measures, including SSL encryption for data in transit, secure payment processing through certified third-party providers, regular security audits and updates, access logs, regular backups, and access limited to authorised personnel who need it. If a personal data breach occurs, we will inform affected users and the Data Protection Board of India as required by law.
8. Your rights
Under the DPDP Act you have the right to:
- Access: get a summary of the personal data we hold about you and how we process it.
- Correction: correct inaccurate or incomplete data, or update it.
- Erasure: ask us to delete your data, subject to our legal obligations (for example, invoices).
- Withdraw consent and opt out: withdraw consent for marketing or any consent-based processing, as easily as you gave it. Withdrawing consent for data needed to run your account or membership means we cannot continue that service.
- Nominate: nominate another person to exercise your rights in case of death or incapacity.
- Grievance redressal: complain to our Grievance Officer and, if unresolved, to the Data Protection Board of India.
To exercise these rights, email privacy@redotterfarms.in or WhatsApp +91 93548 08527. We may need to verify your identity first.
9. Cookies and tracking
We use essential cookies to keep you logged in and run the cart, and analytics and advertising cookies (such as the Meta Pixel and Google Analytics) to analyse site traffic and understand where visitors come from. Non-essential cookies are used only with your consent through our cookie banner. You can change your choice at any time or control cookies through your browser settings; disabling cookies may affect how the site works.
10. Children
Our website, accounts and programmes are for people aged 18 or over. We do not knowingly collect personal data of children. If you believe a child has shared data with us, contact us and we will delete it.
11. Third-party sites
Our site links to third-party sites such as Instagram, Facebook, LinkedIn and WhatsApp. Their own privacy policies apply when you use them.
12. Changes to this policy
We may update this policy from time to time. We will post the new version on this page with a new "Last updated" date, and notify account holders of material changes by WhatsApp or email. Please review this policy periodically.
13. Grievance Officer and contact
In accordance with the Information Technology Act, 2000 and rules made under it, the Consumer Protection (E-Commerce) Rules, 2020 and the DPDP Act:
- Privacy questions: privacy@redotterfarms.in
- Company: Red Otter Farms Private Limited • CIN: U01100DL2019PTC350161 • Registered office: 146B, Shahpur Jat, New Delhi-110049, India
- Customer support: support@redotterfarms.in • WhatsApp +91 93548 08527 • Monday–Saturday, 9 AM–6 PM IST
- Grievance Officer: Brij Satija, Co-Founder • brij.satija@redotterfarms.in • Mobile: +91 92666 82688
Complaints are acknowledged within 48 hours and resolved within one month. Privacy grievances under the DPDP Act will in any case be resolved within 90 days.