Introduction:
Dharampal Satyapal Foods Limited (together with its subsidiaries, controlled entities, and affiliates, hereinafter referred to as “we,” “our,” “us,” or “the Company”) is engaged in the business of manufacturing, sale and marketing of confectionary products under several brands owned by the Company.
As part of this Durga Puja festive engagement activity (running from 1st September 2025 to 31st December 2025 ), through the Company’s WhatsApp Business Account (“Pulse by DS Group”), the Company may request users to share their photograph and name on a voluntary basis on the Account. The photograph shared by users will be used solely for the purpose of creating a caricature-style image with a Pulse-branded festive frame and the image created shall be shared back with the respective user whose photograph has been used. The personal data/photograph shared by the user will be used by the Company only for this running the aforesaid program during the Durga Puja festive season (during the dates indicated above).
Please note that in its capacity as a Data Fiduciary under the Digital Personal Data Protection Act, 2023 (“the Act”), the Company processes personal data in a lawful, fair, and transparent manner. We collect and use personal data of customers, vendors and other stakeholders (hereinafter referred to as “you”, “your”, “yourself” or “Data Principal”) strictly for legitimate purposes limited to the purpose indicated in the preceding paragraph.
All personal data is processed in line with the principles of purpose limitation, data minimization, storage limitation, and security safeguards under the Act. Where required, personal data is processed based on the free, informed, specific, and unambiguous consent of the Data Principal, or under other legitimate uses as defined under Section 7 of the Act.
Scope:
This Notice applies to all individuals whose personal data/photograph is collected via the Company’s Whatsapp Business Account, including but not limited to customers, prospective buyers, service providers, and business partners. It specifically covers users who visit our Whatsapp Business Account.
The purpose of this Notice is to inform you, as a Data Principal, about how We collect, use, store, share, and protect your personal data when you interact with us through our digital interfaces, including but not limited to the Account. We recognize the importance of maintaining your privacy. We value your privacy and appreciate your trust in us. This policy describes how we treat information we collect from you, the types of information that we collect and matters related thereto. By visiting and/or using the Account, you agree to the terms of this Privacy Policy and provide us with your consent to collect, store, handle and process such personal information/photograph.
Information We collect:
Dharampal Satyapal Foods Limited, in its role as a Data Fiduciary, collects and processes only such personal data that is voluntarily provided by the Data Principal and is necessary for the performance of specific, lawful purposes as outlined below.
We collect personal data only when voluntarily submitted by the Data Principal while interacting with our WhatsApp Business Account. The types of data we collect include:
1. During Account Registration and usage
- Mobile Number – collected at the time of account login
- Name and Photo – collected if voluntarily shared by the user upon consenting to the present Privacy Policy
2. Communication Records
When you voluntarily contact us (e.g., through email, customer service, or phone), we may retain the communication and your contact details (email and/or phone) solely for resolving your query or future reference, as permitted under the Act.
- Information we collect automatically:
We collect –
Mobile number – On registration
We do not use this information to identify individuals unless required under law or for security investigations.
- Device and Log information:When you access our Account or Website, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information.
- Usage information: We collect information about your usage of our Account. We also collect information about what happens when you use our Account along with information about your Supported Device (e.g., mobile device manufacturer). We use this information to supply our Account to you, get insights on how people use our Account so that we can make our Account better, and understand and make predictions about user retention and interest highlighted.
We may collect, hold, use, and show information for the following purposes including but not limited to the following:
- Provide you with our Account’s core features and services by legal & contractual obligations. Occasionally we may need to contact you administrative and/or operational reasons.
- Enable you to customize or personalize your experience of our Account.
- Contact and communicate with you.
- Following laws, regulations, and statutory compliances.
- Investigating and responding to complaints, feedback, and suggestions.
- For any other purpose disclosed by us, when you provide it.
- To any other successors in title to our business undertaking.
- Personal Data will not be further processed in a manner that is incompatible with these purposes.
- Share data with government authorities, legal successors, vendors, and partners only as permitted by law and under strict data protection agreements.
- Process personal data solely for the above purposes and avoid incompatible further processing, in line with the principle of purpose limitation under the Act.
COMMUNICATIONS FROM THE WEBSITE:
We may use your email address/phone number to send you newsletters and/or marketing communications. If you no longer wish to receive these communications, you can opt out at any time by following the unsubscribe instructions included in the email you receive or by contacting us at dsfoods@dsgroup.com. However, we may also send you important service related announcements, when it is necessary to do so. For instance, we may send you essential service-related communications, such as notices about maintenance, outages, or policy updates. These are not promotional and are necessary for service delivery; therefore, you cannot opt out of them unless you delete your account or unsubscribe from the services.
We collect email address to communicate with them for the orders status and delivery purposes. There is no online marketing tool integrated.
MINOR/DISABLED PERSON’S DATA:
We do not knowingly collect personal information from individuals under the age of 18 without the consent of a parent or guardian. If you believe we have collected such information, please contact us at dsfoods@dsgroup.com and we will promptly delete it. We also do not allow users under 18 to use our service without parental or legal guardian’s consent.
We do not knowingly collect personal information from disabled persons without the consent of a parent or guardian. If you believe we have collected such information, please contact us at dsfoods@dsgroup.com and we will promptly delete it. We also do not allow disabled persons to use our service without parental or legal guardian’s consent.
HOW LONG WE KEEP YOUR PERSONAL DATA:
We uphold the principle of retaining your Personal Data only for the duration necessary to fulfil its intended purpose, as outlined in this Privacy Policy. For instance, if you have provided Personal Data while using the Account, we may retain this data if your account still is active on our system.
Nevertheless, there are certain circumstances where we may need to keep your Personal Data for legitimate business or legal reasons or provide substantial evidence of record. These may include obligations related to compliance with applicable laws, accounting or reporting requirements, statistical analysis, which also includes case studies etc. Additionally, certain data may be kept for extended periods to fulfil purposes such as ensuring security, preventing fraud and abuse, or keeping financial records.
CONSENT AND WITHDRAWAL:
By using the Account and/or by providing us your information, you give the consent to collect, handle, process and use of the information you disclose on the Account in accordance with this Policy, including but not limited to your consent for sharing your information as per this Policy. We collect your consent to process your personal data in a manner that is free, specific, informed, unconditional, and unambiguous. Your consent is obtained through a clear affirmative action and is strictly limited to the personal data necessary for the stated purpose.
Additionally, we provide contact details of our Data Protection Officer or authorized representative to address any queries regarding your personal data.
You have the right to withdraw your consent at any time. You need to send a written request regarding the same to us dsfoods@dsgroup.com. On receipt of your application, we will promptly cease processing your personal data, unless continued processing is required or permitted by law. Please note that withdrawing consent will not affect the legality of any processing conducted prior to withdrawal.
To facilitate easy management of your consent preferences, you may also utilize a Consent Manager who acts on your behalf to review, manage, or withdraw consent. The Consent Manager remains fully accountable to you in accordance with the obligations prescribed under the Act.
Data Principals can exercise the following rights as provided under the Digital Personal Data Protection Act (DPDPA) 2023:
- Right to Access Information about Personal Data: The right to obtain confirmation of whether personal data is being processed and, if so, to access that data.
- Right to Correction: The right to request the correction or amendment of inaccurate or incomplete personal data at any time.
- Right to Erasure: The right to request the deletion or removal of personal data under certain circumstances.
- Right to Grievance Redressal: The right to easily access grievance resolution mechanisms against any action or failure on the part of Company related to their responsibilities concerning the personal data.
- Right to Nominate: The right to appoint another person, to act on your behalf in case of mortality or incapacity. In this context, “incapacity” refers to the inability to exercise rights due to mental unsoundness or physical infirmity.
Should you wish to exercise any of the the abovementioned rights, please contact at dsfoods@dsgroup.com.
DUTIES OF THE DATA PRINCIPAL:
You, as the Data Principal are bound by certain duties, and must ensure:
- Not to impersonate another person while providing your personal data for a specified purpose.
- Not to suppress any material information while providing your personal data for any document, unique identifier, proof of identity or proof of address issued by the State or any of its instrumentalities.
- Not to register a false or frivolous grievance or complaint with us or the Data Protection Board of India.
- Give only such information as is verifiably authentic, correct, current and updated while exercising the right to correction or erasure under this notice.
- Compliance with the provisions of all applicable laws for the time being in force while exercising rights under DPDP Act.
SECURITY OF YOUR PERSONAL DATA:
We give utmost importance to the security of your data. We take extensive measures to safeguard the information you provide, ensuring protection against loss, unauthorized access, disclosure, and misuse. These measures are designed to align with the sensitivity of the data we collect, process, and store, as well as the current advancements in technology.
However, it is important to note that due to the inherent nature of communication and information processing technology, we cannot guarantee absolute security against external intrusions while transmitting data over the Internet or when it is stored in our systems. Additionally, when you click on a link leading to a third-party website, please be aware that you will be leaving our site, and we do not have control over or endorse the content found on such third-party sites.
Customer personal data is completely secure with the data security provisions.
DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES:
We may show Personal Data to:
- Our parent and subsidiary company(ies), affiliate(s), or collaborated institutions.
- Third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and service providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers, professional advisors, payment systems operators, and financial institutions.
- Our employees and senior management of our Company.
- Our existing or potential agents or business partners.
- Regulatory authorities in the event you do not pay for goods or services we have provided to you.
- Courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or to establish, exercise, or defend our legal rights.
- Third parties, including agents or sub-contractors, who help us in providing information, products, services, or direct marketing to you.
- Third parties to collect and process data for converting your photo to caricature.
- An entity that buys, or to which we transfer all or substantially all our assets and business.
PRIVACY GRIEVANCES:
If you have any questions about this Notice, wish to exercise your rights, have concerns about privacy of your data or any privacy related grievances in respect of the Website. In case you have any discrepancy or grievances with regard to our processing of information provided by, or any questions regarding this Policy, you may contact the Data Protection Officer (DPO) as identified below:
(Mr. Balwant Singh),
Call: 0120-4043200 (Monday – Friday 10 AM -5 PM on working days)
E-mail: privacy@dsgroup.com
If you are an Indian resident and you have a complaint, you may refer it to the Data Protection Board (DPB) of India under the relevant provisions of Digital Personal Data Protection Act, 2023. The DPB serves as India’s primary authority in matters relating to personal data protection.
UPDATES TO PRIVACY NOTICE:
At our discretion, we may update our privacy notice from time to time to reflect updates in our business processes, current acceptable practices, or legislative or regulatory changes, and inclusion/ exclusion of target audience and stakeholders. All updates will be posted at the same link.
If the changes are significant, or if required by applicable law, we will notify you through email, website alerts or your chosen communication preferences.
Last updated on : 4 September 2025