1. Introduction
Sharpy Innovations Private Limited ("we," "our," or "us"), operating the brand REYVO and its website reyvo.in (the "Website"), is committed to protecting the personal data of every individual who interacts with us. This Privacy Policy explains what data we collect, why we collect it, how we use it, and what rights you have over it.
By visiting our Website, joining our waitlist, or placing an order with us, you agree to the practices described in this Policy.
This Policy is governed by the Digital Personal Data Protection Act, 2023 (DPDP Act) of India and other applicable Indian laws.
2. Who We Are
Data Fiduciary (Controller): Sharpy Innovations Private Limited, Office No. 906, 9th Floor, Solus Business Park, Hiranandani Estate, Ghodbunder Road, Patlipada, Thane West, Maharashtra - India - 400607
Brand: REYVO - Functional Performance Beverage
Contact for Privacy Matters: hello@reyvo.in
3. What Personal Data We Collect
We collect only the data that is necessary and proportionate to the purpose for which it is collected.
3a. Coming Soon / Waitlist Page
When you register your interest on our pre-launch page, we collect:
- Full name
- Email address
- Phone number
3b. E-Commerce Website (upon launch)
When you browse or purchase on our full website, we may collect:
- Identity data: Full name
- Contact data: Email address, phone number
- Delivery data: Shipping address, including city, state, and PIN code
- Transaction data: Order history, purchase amounts, product preferences
- Preference data: Your preferred REYVO drink variant/flavour, when asked
- Payment data: We do not store your card or banking details directly. Payment is processed securely by our third-party payment gateway(s). We only receive a transaction confirmation and reference ID.
- Device and technical data: IP address, browser type, device type, operating system, pages visited, time spent on the Website - collected automatically via cookies and analytics tools
- Marketing interaction data: Whether you opened our emails, clicked our ads, or interacted with our social media campaigns
4. How We Collect Your Data
We collect data in the following ways:
- Directly from you - when you fill in our waitlist form, place an order, or contact us
- Automatically - through cookies, pixels, and similar tracking technologies when you visit our Website
- From third parties - analytics platforms, advertising networks, payment gateways, and email marketing tools that we use to operate our business
5. Why We Collect Your Data (Purpose and Legal Basis)
Under the DPDP Act, 2023, we process your personal data on the basis of your consent and for legitimate uses as described below:
You may withdraw your consent at any time by contacting us at hello@reyvo.in. Withdrawal of consent will not affect the lawfulness of processing prior to withdrawal, but may affect our ability to provide certain services to you.
6. Cookies and Tracking Technologies
We use cookies and similar technologies, such as pixels and tags, to enhance your experience and support our marketing activities.
Types of cookies we use:
- Essential cookies - required for the Website to function. Cannot be disabled.
- Analytics cookies - help us understand how visitors use our Website, such as Google Analytics or similar tools.
- Marketing cookies - used to show you relevant advertising on platforms such as Google and Meta, such as Meta Pixel or similar tools.
- Preference cookies - remember your choices and settings on the Website.
When you first visit our Website, you will be shown a cookie consent banner that allows you to accept or decline non-essential cookies. You can also manage cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Website.
7. Third-Party Service Providers (Data Processors)
To operate our business, we share your data with carefully selected third-party service providers who process data on our behalf. These may include:
- Payment gateway(s) - to securely process transactions
- Email and SMS/WhatsApp marketing platforms - to send transactional and promotional communications
- Analytics platforms - to measure Website performance and user behaviour, such as Google Analytics or equivalent
- Advertising networks - to run performance marketing campaigns, such as Google Ads and Meta Ads
- Logistics and delivery partners - to fulfil and ship your orders
- Cloud hosting and infrastructure providers - to host and operate our Website and databases
All third-party processors are contractually obligated to handle your data only for the specified purpose, maintain confidentiality, and implement appropriate security measures. We do not sell your personal data to any third party.
8. Data Sharing
We do not sell, rent, or trade your personal data. We may share your data only in the following circumstances:
- With our service providers as described in Section 7, strictly for operational purposes
- With government or regulatory authorities if required by law, court order, or to protect our legal rights
- In the event of a business transfer - if REYVO or Sharpy Innovations Private Limited undergoes a merger, acquisition, or sale of assets, your data may be transferred to the successor entity, and you will be notified accordingly
9. Data Retention
We retain your personal data only for as long as is necessary for the purposes outlined in this Policy, or as required by applicable law.
- Waitlist data - retained until the launch of the e-commerce website and for a reasonable period thereafter, or until you unsubscribe
- Order and transaction data - retained for a minimum of 7 years as required under Indian financial and tax regulations
- Marketing preferences and communication data - retained until you opt out or withdraw consent
- Technical/device data - typically retained for 26 months in line with analytics platform standards
Once data is no longer required, it is securely deleted or anonymised.
10. Data Security
We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it from unauthorised access, disclosure, alteration, or destruction. These measures include:
- Secure HTTPS encryption on our Website
- Access controls restricting data to authorised personnel only
- Secure data handling protocols with our third-party providers
- Regular reviews of our security practices
While we take all reasonable precautions, no method of transmission over the internet or electronic storage is 100% secure. In the event of a data breach that is likely to affect your rights and interests, we will notify you and the relevant authorities as required under applicable law.
11. Your Rights Under the DPDP Act, 2023
As a Data Principal, meaning an individual whose data we process, you have the following rights under the Digital Personal Data Protection Act, 2023:
- Right to access - you may request information about what 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 purpose for which it was collected, subject to legal retention obligations.
- Right to grievance redressal - you have the right to a prompt and effective resolution of any grievance regarding the processing of your data.
- Right to nominate - you may nominate another individual to exercise your rights in the event of your death or incapacity.
- Right to withdraw consent - you may withdraw consent for processing at any time, without affecting the lawfulness of prior processing.
To exercise any of these rights, please write to us at hello@reyvo.in with your request. We will respond within a reasonable timeframe and in accordance with the DPDP Act.
12. Communications and Marketing Opt-Out
By submitting your details on our waitlist or placing an order, you consent to receiving communications from us including:
- Order confirmations and delivery updates, which are transactional and cannot be opted out of
- New product launches, offers, and brand news, where marketing opt-out is available at any time
You can opt out of marketing communications by:
- Clicking the "Unsubscribe" link in any email we send
- Sending an opt-out request to hello@reyvo.in
- Replying "STOP" to any SMS/WhatsApp message from us
We will process your opt-out request promptly. Please allow up to 7 business days for changes to take effect across all platforms.
13. Children's Privacy
Our Website and products are not directed at individuals under the age of 18 years. We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected data from a person under 18, we will delete such data promptly.
If you believe a minor has provided us with their personal data, please contact us at hello@reyvo.in immediately.
Note: The DPDP Act, 2023 imposes additional obligations with respect to processing data of children. We will comply with these obligations fully as our platform scales.
14. Links to Third-Party Websites
Our Website may contain links to third-party websites, social media platforms, or partner pages. This Privacy Policy applies only to our Website. We are not responsible for the privacy practices of any third-party site and encourage you to read their respective privacy policies.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or business operations. When we do, we will:
- Update the "Last Updated" date at the top of this page
- Post the revised Policy on our Website
- Notify you by email or prominent notice on the Website if the changes are material
Your continued use of the Website after any update constitutes your acceptance of the revised Policy. We encourage you to review this page periodically.
16. Grievance Officer
In accordance with the Information Technology Act, 2000 and the DPDP Act, 2023, we have designated a Grievance Officer to address any concerns or complaints regarding the processing of your personal data.
Grievance Officer: Vishwesh Warulkar
Designation:
CEO
Company: Sharpy Innovations Private Limited
Email: hello@reyvo.in
Address: Office No. 906, 9th
Floor, Solus Business Park, Hiranandani Estate, Ghodbunder Road, Patlipada, Thane West, Maharashtra
- India - 400607
We will acknowledge your grievance within 48 hours and resolve it within 30 days of receipt.
17. Governing Law and Jurisdiction
This Privacy Policy shall be governed by and construed in accordance with the laws of India. Any disputes arising in connection with this Policy shall be subject to the exclusive jurisdiction of the courts located in Thane, Maharashtra, India.
This Privacy Policy was prepared for REYVO, a brand of Sharpy Innovations Private Limited, and is intended for use on the REYVO website (reyvo.in). It should be reviewed by a qualified legal professional before publication.