Privacy Policy

1. Introduction

Avernac Enterprises Private Limited, referred to throughout this document as "Avernac," "the Company," "we," "our," or "us," is a professionally incorporated export company operating under the laws of India, engaged in the international trade of agricultural commodities, food products, and related goods. We conduct our business with a strong commitment to transparency, accountability, and the responsible handling of all personal and business data that passes through our operations.

We recognize that the individuals and entities who interact with us, whether as prospective buyers, established importers, logistics partners, or casual website visitors, place a significant degree of trust in us when they share their information. This Privacy Policy has been drafted to honour that trust by clearly explaining the nature of the data we collect, the legitimate purposes for which we use it, the technical and organizational safeguards we have put in place to protect it, and the rights that data subjects are entitled to exercise under applicable law.

This Policy is fully aligned with India's Digital Personal Data Protection Act (DPDP Act), 2023, and reflects best practices in international data governance. It applies across all digital and communication channels through which Avernac interacts with the outside world, including but not limited to our official website, email communications, WhatsApp business interactions, customer relationship management (CRM) systems, and any affiliated digital platforms.

By visiting our website at www.avernac.com, submitting an inquiry through our contact form, downloading a product catalogue, communicating with us via WhatsApp or email, or engaging with our services in any other way, you acknowledge that you have read and understood this Privacy Policy and you consent to the practices described herein. If you do not agree with any part of this Policy, we respectfully ask that you refrain from using our services or submitting your personal information to us.

2. Definitions and Key Terminology

For the purposes of this Privacy Policy, the following terms carry the meanings set out below. Understanding these definitions will help you better interpret your rights and our obligations under this document.

Personal Data: Any information that, alone or in combination with other data, can be used to identify a natural person. This includes, without limitation, a person's name, email address, phone number, business details, location, and IP address.

Data Principal: The individual to whom the personal data relates, i.e., you, the person providing your data when interacting with Avernac.

Data Fiduciary: The entity that determines the purpose and means by which personal data is processed. In the context of this Policy, the Data Fiduciary is Avernac Enterprises Private Limited.

Processing: Any operation or set of operations performed on personal data, whether automated or manual, including collection, recording, organization, storage, retrieval, use, disclosure, transmission, erasure, or destruction.

Consent: A freely given, specific, informed, and unambiguous indication of a Data Principal's agreement to the processing of their personal data for a stated purpose.

Data Processor: A third-party entity that processes personal data on behalf of Avernac, acting under our instructions and subject to confidentiality obligations.

DPDP Act: India's Digital Personal Data Protection Act, 2023, which governs the processing of digital personal data within India and, in certain circumstances, outside India.

Sensitive Personal Data: A category of personal data that warrants a higher degree of protection, including financial information, health data, biometric data, and government-issued identification numbers such as Aadhaar and PAN.

3. Scope and Applicability of This Policy

This Privacy Policy applies to all individuals and legal entities who interact with Avernac through any of the following capacities:

• Visitors who browse our official website at www.avernac.com
• Buyers, importers, and distributors who contact us to request quotations or product information
• Suppliers, vendors, and sourcing partners who engage with us in connection with product procurement
• Freight forwarders, shipping agents, customs brokers, and logistics partners involved in our export operations
• Individual professionals who submit inquiries, fill out contact forms, or download content from our website
• Any party who communicates with us via email, WhatsApp, telephone, or any other digital communication channel

This Policy covers all data collection and processing activities conducted on or through the following platforms and touchpoints:

• Our official website: www.avernac.com
• All official company email addresses registered under the avernac.com domain
• Our WhatsApp Business account used for buyer and supplier communication
• Our CRM system and any associated sales or inquiry management tools
• Any third-party platforms used by Avernac solely for facilitating business communication or documentation

This Policy does not apply to third-party websites, platforms, or services that may be linked from our website. We encourage you to review the privacy policies of any external websites you visit, as we have no control over or responsibility for their data practices.

4. What Personal Data We Collect and How We Collect It

Avernac collects only the personal data that is strictly necessary for the purposes of conducting our export business, communicating effectively with our stakeholders, and fulfilling our legal obligations. We do not collect data speculatively, and we are committed to the principle of data minimization at every stage of our operations.

4.1 Data Provided Directly by You

When you choose to contact us, submit an inquiry, or fill out any form on our website or via a communication platform, you may provide us with some or all of the following categories of information:

• Your full name and the name of your company or organization
• Your professional email address and WhatsApp or telephone number
• Your country of residence or business, city, and shipping port preferences
• Details of the products you are interested in, including product specifications, quantity requirements, and packaging preferences
• Your preferred payment terms, delivery timelines, and any other trade requirements
• Business credentials or trade documents such as importer registration details, in cases where these are requested during advanced stages of a business relationship
• Any additional notes, comments, or instructions you choose to include in your communication with us

4.2 Data Collected Automatically Through Our Website

When you visit www.avernac.com, certain technical data is collected automatically by our website infrastructure and analytics tools. This information is used exclusively for the purpose of understanding how our website is used and improving the experience for our visitors. The following types of data may be collected automatically:

• Your IP address and approximate geographic location as inferred from that IP address
• The type of web browser you are using and the version of that browser
• The type of device you are accessing the website from, including whether it is a desktop, laptop, tablet, or mobile device
• Your operating system and its version
• The pages you visit on our website, the sequence in which you visit them, and the time you spend on each page
• The source that directed you to our website, such as a search engine, a social media platform, or a direct link
• Technical session data, including timestamps of your visit and session duration

4.3 Data Collected in the Course of Business Operations

Once a business relationship progresses beyond an initial inquiry, Avernac may collect additional data that is necessary for the execution of export transactions. This may include:

• Shipping addresses for goods to be delivered
• Tax identification numbers, GST registration details, VAT numbers, or other tax-related identifiers required for customs or invoicing
• Export license details or import permit numbers, where legally required
• Bank details for the purpose of receiving or facilitating payment, handled through secure and regulated banking channels only
• Product certification or testing documentation relevant to the transaction

We explicitly confirm that we do not collect, store, or process the following categories of data under any circumstances:

• Credit card numbers, debit card information, or any other payment card details
• Biometric data of any kind, including fingerprints or facial recognition data
• Sensitive health or medical information
• Government identification numbers such as Aadhaar or PAN, except where collection is explicitly required by applicable law for regulatory compliance
• Passwords, security codes, or any form of authentication credentials

5. The Purposes for Which We Process Your Data

Avernac processes personal data only for specific, clearly defined, and legitimate business purposes. We do not use your data for any purpose that has not been disclosed in this Policy, and we do not process data in a manner that is incompatible with the purposes stated below.

5.1 Business Communication and Inquiry Management

The most immediate purpose for which we collect your contact information is to enable timely, professional, and accurate communication with you. This includes responding to your inquiries about our products, sharing product catalogues, providing price quotations, clarifying technical specifications, and discussing the logistical and regulatory aspects of potential trade. We maintain records of this communication to ensure continuity and consistency in our interactions with you over time.

5.2 Order Processing and Trade Execution

When a business relationship progresses to the stage of an active transaction, we process your data to confirm and execute the order. This involves coordinating product sourcing, quality testing, packaging, documentation, and shipping. The export process requires the exchange of information with freight forwarders, customs agents, shipping lines, and other parties who are integral to the movement of goods across international borders. All such sharing is conducted under strict confidentiality obligations.

5.3 Legal and Regulatory Compliance

As an export company, Avernac is subject to a wide range of legal and regulatory requirements at both the domestic and international levels. These include obligations under the Foreign Trade (Development and Regulation) Act, rules administered by the Directorate General of Foreign Trade (DGFT), phytosanitary and food safety regulations, customs laws, and applicable international trade agreements. We process and retain certain records for the duration required by these legal frameworks, which may extend beyond the period of active business engagement.

5.4 Website Performance and User Experience

The technical data we collect automatically through our website is used to monitor the performance and accessibility of the site, identify and resolve technical errors, and understand how visitors engage with our content. This enables us to continuously improve the quality and relevance of the information we publish and to ensure that the website remains functional and accessible across devices and browsers.

5.5 Business Development and Relationship Management

We may use contact information provided during an inquiry to follow up on previously expressed interest in our products, where doing so is consistent with your expectations and our legitimate business interests. We do not use your data for unsolicited mass marketing, and you retain the right at all times to indicate that you do not wish to receive further communication from us.

6. Legal Basis for Processing Under the DPDP Act, 2023

Avernac processes personal data on the basis of one or more of the following legal grounds as recognized under the Digital Personal Data Protection Act, 2023:

Consent: When you voluntarily submit your personal information to us through our website contact form, by email, or through WhatsApp, you provide your explicit consent to our processing of that data for the purposes set out in this Policy. You have the right to withdraw this consent at any time, subject to the conditions described in Section 13 of this document.

Legitimate Business Interest: As an internationally operating export company, we have a genuine and proportionate business interest in processing personal data for the purposes of facilitating trade, responding to buyer and supplier inquiries, and maintaining records that support the continuity of our operations. This interest is always balanced against the rights and expectations of the individuals whose data we process.

Contractual Necessity: Where a business relationship has progressed to the point of a transaction or agreement, the processing of your data becomes necessary for the performance of that contract. This includes the generation of export documentation, coordination of shipping, and all associated communications required to fulfil our obligations.

Legal Obligation: Certain processing activities are mandated by the applicable laws of India and international trade regulations. We are required by law to generate, retain, and in some cases submit specific records related to our export transactions. Processing conducted for these purposes is not subject to withdrawal of consent.

7. Data Storage, Security, and Infrastructure

The security of your personal data is a matter we take seriously and invest in continuously. We have implemented a layered, multi-tiered approach to data security that encompasses both technical infrastructure and organizational practices.

From a technical standpoint, all data transmitted between your browser and our website is protected by SSL/TLS encryption, ensuring that information cannot be intercepted in transit. Our servers, which are hosted on reputable infrastructure within India and, where necessary, with internationally recognized cloud service providers, are protected by firewalls, intrusion detection systems, and regular security audits. Data stored on our systems is encrypted at rest using industry-standard encryption protocols.

Access to personal data within Avernac is governed by a strict need-to-know principle. Only those members of our team who require access to specific data in order to perform their professional responsibilities are granted that access. All such individuals are bound by confidentiality obligations and undergo training on our data handling practices.

We conduct periodic reviews of our security practices and update our infrastructure in response to emerging threats and evolving industry standards. Our systems are subject to regular vulnerability assessments, and we maintain encrypted backups to ensure that data can be recovered in the event of a technical failure.

While we take all reasonable and practicable steps to protect the personal data in our care, it is important to acknowledge that no method of electronic storage or transmission is entirely without risk. In the unlikely event of a security incident, we will respond in accordance with the protocol described in Section 15 of this Policy.

8. Data Retention Periods

Avernac retains personal data for no longer than is necessary for the specific purpose for which it was collected, or as required by applicable law. The following retention periods apply to the main categories of data we hold:

Inquiry and Contact Data: Information submitted through website contact forms, WhatsApp messages, or email inquiries, where the inquiry has not progressed to an active business relationship, is retained for a period of twelve to twenty-four months. This period allows us to respond effectively to follow-up inquiries and maintain an accurate record of our communications.

Active Business Correspondence: Data related to ongoing business relationships, including communications, quotations, and negotiation records, is retained for the duration of the business relationship and for a reasonable period thereafter, generally not exceeding twenty-four months following the conclusion of the relationship.

Export and Transaction Documentation: Records related to completed export transactions, including invoices, shipping documents, certificates of origin, phytosanitary certificates, and customs documentation, are retained for a minimum of three years and up to seven years, as required by Indian tax law, export regulations, and international trade compliance requirements.

Supplier and Partner Data: Information pertaining to suppliers, freight forwarders, and other operational partners is retained for the duration of the business relationship and for a period not exceeding three years following its conclusion, unless a longer retention period is mandated by law.

Website Analytics Data: Anonymized and aggregated website usage data is retained for up to twenty-four months for the purpose of trend analysis and website performance improvement.

Upon the expiry of the applicable retention period, personal data is securely deleted or anonymized in a manner that ensures it can no longer be attributed to any individual. You may request early deletion of your data at any time, subject to our legal obligations as described in Section 12.

9. Disclosure of Your Data to Third Parties

Avernac does not sell, rent, barter, or trade your personal data to any third party for their own purposes, under any circumstances. The sharing of data that does occur is strictly limited to what is necessary for the execution of our legitimate business activities and is always governed by appropriate safeguards.

We may share your data with the following categories of trusted third-party service providers and operational partners:

• Freight forwarders and shipping line agents responsible for the physical movement of goods
• Customs clearance agents and trade documentation specialists
• Warehousing and cold storage facilities involved in the handling of goods
• Accredited testing and quality assurance laboratories that certify product compliance
• Packaging and processing vendors involved in the preparation of export-grade goods
• Banking institutions through which trade finance, letters of credit, or payment processing are facilitated
• Insurance providers who underwrite cargo or trade credit insurance for our shipments
• Email service providers, WhatsApp Business API operators, and CRM platforms that support our communication infrastructure
• Legal and compliance advisors who assist us in meeting our regulatory obligations

All third-party service providers with whom we share personal data are required to handle that data in accordance with applicable privacy laws and are bound by contractual confidentiality obligations. We take reasonable steps to verify that third parties maintain appropriate data security practices before engaging them in any capacity that involves access to personal data.

In addition to the above, we may disclose your data if we are required to do so by a court order, regulatory directive, or any other legally binding obligation imposed by a competent authority in India or, where applicable, in another jurisdiction.

10. International Transfer of Personal Data

Given the inherently international nature of our export business, it is sometimes necessary for us to transfer personal data to parties located in countries other than India. Such transfers occur strictly within the scope of our operational requirements and include situations such as:

• Sharing buyer contact details with international freight agents or shipping lines responsible for a specific trade lane
• Transmitting export documentation to customs authorities or port agents in the destination country
• Coordinating with international banking institutions in connection with letters of credit or trade finance instruments
• Communicating product specifications or certifications to regulatory bodies in the importing country

All such international transfers are conducted under appropriate safeguards, including contractual obligations on the receiving party to maintain standards of data protection that are comparable to those required under Indian law. We do not transfer personal data to jurisdictions that we have reason to believe lack adequate data protection frameworks, unless such a transfer is necessary to fulfil a contractual obligation or legal requirement that cannot be met through other means.

Where we are required by the DPDP Act or any associated rules to seek additional approvals or implement specific safeguards in connection with international transfers, we will do so in a timely and compliant manner.

11. Cookies and Website Tracking Technologies

Our website uses a limited and carefully considered set of cookies and tracking technologies. A cookie is a small text file placed on your device by a website for the purpose of remembering information about your visit. The cookies used on www.avernac.com are classified as follows:

Essential Session Cookies: These cookies are necessary for the basic functioning of our website. They enable core features such as page navigation and access to secure areas of the site. Without these cookies, the website cannot function as intended.

Performance and Analytics Cookies: These cookies collect information about how visitors interact with our website, including which pages are visited most frequently and whether users encounter any error messages. The data collected by these cookies is aggregated and anonymized, meaning it cannot be used to identify any individual visitor. We use this data solely to improve the performance and relevance of our website.

We do not use advertising cookies, behavioral tracking cookies, or any third-party cookies designed to track you across multiple websites for the purpose of building a profile of your interests. We do not participate in any advertising networks or retargeting programs.

You have the right to manage your cookie preferences through your browser settings. Most modern browsers allow you to refuse cookies, delete existing cookies, or receive a notification before a cookie is placed. Please note that disabling certain categories of cookies may affect your ability to use some features of our website. Instructions for managing cookies can be found in the help section of your browser.

12. Your Rights as a Data Principal Under the DPDP Act, 2023

The Digital Personal Data Protection Act, 2023 grants individuals a comprehensive set of rights with respect to their personal data. As a Data Principal, you are entitled to exercise the following rights in relation to any personal data that Avernac holds about you:

Right of Access: You have the right to request information about whether Avernac holds personal data about you, and if so, to request a summary of that data and a description of the purposes for which it is being processed.

Right to Correction: If you believe that any personal data we hold about you is inaccurate, incomplete, or outdated, you have the right to request that we correct it. We will process such requests promptly and update our records accordingly.

Right to Erasure: You have the right to request the deletion of your personal data, subject to any overriding legal obligations that require us to retain specific records. Where deletion is not possible due to legal requirements, we will inform you of this and explain the basis on which retention is mandatory.

Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of any processing that took place before the withdrawal. The consequences of withdrawal, including any limitation on services, are described in Section 13.

Right to Information about Third-Party Sharing: You have the right to request information about the identities of any third parties to whom your personal data has been disclosed in the preceding twelve months.

Right to Grievance Redressal: If you are dissatisfied with how we have handled your personal data or with our response to any rights request, you have the right to lodge a complaint with the Data Protection Board of India, once constituted under the DPDP Act.

To exercise any of the rights described above, please contact our designated privacy contact using the details provided in Section 19 of this Policy. We will acknowledge your request within a reasonable period and endeavor to respond fully within thirty days. In cases involving complex or high-volume requests, we may require additional time, in which case we will notify you of the anticipated timeline.

13. Withdrawal of Consent and Its Consequences

You may withdraw your consent to the processing of your personal data at any time by contacting us using the details set out in Section 19 of this Policy. Upon receipt of a withdrawal request, we will cease processing your data for the purpose to which that consent related, within a reasonable timeframe.

It is important to understand that the withdrawal of consent does not have retroactive effect. It does not affect the lawfulness of any processing that was carried out prior to the date on which you withdrew your consent. Furthermore, withdrawal of consent does not release Avernac from any legal obligation to retain certain records that we are required by law to keep, regardless of your preferences.

If you withdraw your consent at a point when an active business transaction is already in progress, some or all of the services associated with that transaction may no longer be capable of being delivered. In such circumstances, we will inform you of the practical consequences of withdrawal before taking any action, so that you are in a position to make an informed decision.

14. Protection of Children's Data

Avernac's services, website, and business communications are directed exclusively at adults engaged in professional trade and commerce. We do not knowingly collect, solicit, or process any personal data from individuals who are under the age of eighteen years. Our website contains no content specifically designed to attract or engage children.

In the event that we become aware, through any means, that we have inadvertently collected personal data from an individual under the age of eighteen, we will take immediate steps to permanently delete that data from our systems without any further use or disclosure. If you are a parent or guardian and you have reason to believe that your child has submitted personal information to us without your consent, we encourage you to contact us immediately so that we can investigate and take appropriate action.

15. Data Breach Response Protocol

Despite the robust technical and organizational security measures we have implemented, no digital system can be guaranteed to be entirely immune from unauthorized access or security incidents. In the event that Avernac experiences a data breach or security incident that poses a risk to the rights and interests of individuals whose data we hold, we will respond in accordance with the following protocol:

• We will immediately activate our incident response procedures to contain the breach and prevent further unauthorized access or disclosure.
• We will conduct a thorough investigation to determine the nature, scope, and cause of the incident, including which categories of data were affected and which individuals may be impacted.
• We will notify the relevant regulatory authorities as required by the DPDP Act and any other applicable legal obligations, within the timeframes prescribed by law.
• Where the breach is likely to result in a high risk to the rights or interests of affected individuals, we will communicate with those individuals in a clear, transparent, and timely manner, providing them with information about what happened and what steps they can take to protect themselves.
• We will document all findings, remediation steps taken, and lessons learned, and use this information to further strengthen our data protection practices and prevent future incidents.

16. Links to Third-Party Websites and Platforms

Our website may from time to time contain hyperlinks to external websites, industry portals, certification bodies, government trade platforms, or shipping line portals. These links are provided for your convenience and informational purposes only. Avernac does not exercise any control over the content, privacy practices, or data handling policies of these external websites.

The inclusion of a hyperlink on our website does not constitute an endorsement of the linked website or any products, services, or information it contains. We strongly encourage you to review the privacy policy of any third-party website you visit before submitting any personal information to that site. Avernac accepts no responsibility or liability for the privacy practices of any external website.

17. Email, WhatsApp, and Business Communication Policy

By choosing to contact Avernac through any of our official communication channels, including our corporate email addresses, our WhatsApp Business account, or any web-based contact form, you acknowledge and agree that we may use those same channels to communicate with you for the following purposes:

• Responding to the inquiry or request that you have submitted to us
• Sharing product catalogues, specification sheets, price lists, or other trade documentation relevant to your inquiry
• Providing formal price quotations and commercial proposals
• Sending order updates, shipping notifications, or documentation related to an active transaction
• Following up on previously expressed interest in our products, where appropriate and proportionate
• Requesting any additional business information necessary to progress a transaction

Avernac does not engage in the sending of unsolicited promotional messages, newsletters, or bulk commercial communications to individuals who have not explicitly invited such contact. All commercial communications we send are directly related to the inquiry, transaction, or business relationship that prompted your contact with us.

If at any point you wish to stop receiving communications from us, you may notify us in writing using the contact details in Section 19, and we will respect your preference promptly.

18. Amendments and Updates to This Policy

Avernac reserves the right to review and update this Privacy Policy at any time in response to changes in applicable law, developments in our business operations, changes in the technical landscape, or evolving best practices in data protection. We are committed to ensuring that this Policy remains accurate, current, and reflective of how we actually handle personal data.

Whenever we make material changes to this Policy, we will update the "Last Updated" date at the top of the document and, where appropriate, we will take additional steps to draw the changes to the attention of individuals who are likely to be affected. These steps may include publishing a notice on our website, sending a communication to individuals with whom we have an active business relationship, or both.

Your continued interaction with our website or services following the publication of an updated Policy constitutes your acknowledgment of the revised terms. If you do not accept the revised Policy, we ask that you cease using our website and contact us to discuss the implications for any ongoing business relationship.

19. Contact Information and Grievance Redressal

Avernac is committed to addressing any questions, concerns, or requests relating to this Privacy Policy in a transparent and timely manner. If you wish to exercise any of your rights as a Data Principal, if you have a question about how we handle your data, or if you wish to raise a concern or complaint, please contact us using the following details:

Company Name: Avernac Enterprises Private Limited
Registered Office: Chhatrapati Sambhajinagar, Maharashtra, India
Website: www.avernac.com

We will endeavour to acknowledge all privacy-related communications within five business days and to provide a substantive response within thirty calendar days. For complex requests, we may require additional time, in which case we will keep you informed of the expected timeline.

If you are not satisfied with our response to your concern or complaint, you have the right to escalate the matter to the Data Protection Board of India once it has been formally constituted under the Digital Personal Data Protection Act, 2023.

20. Governing Law and Jurisdiction

This Privacy Policy is governed by and shall be construed in accordance with the laws of India, including without limitation the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000, and any rules or regulations made thereunder. Any disputes arising out of or in connection with this Policy shall be subject to the exclusive jurisdiction of the competent courts located in India.

Where Avernac conducts business with parties located in jurisdictions outside India, we will endeavor to comply with any additional privacy obligations applicable in those jurisdictions to the extent required by law and operationally feasible.

Avernac Enterprises Private Limited  |  Privacy Policy  |  Last Updated: 2025  |  www.avernac.com