Privacy Policy

1. Introduction

Daley Global Pvt Ltd ("we", "our", "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose and safeguard personal information when you visit daleyglobalex.com or contact us for business enquiries.

This policy applies to all personal data submitted through our contact forms, sample request forms, or by direct email and WhatsApp communication. Browsing our website without submitting a form does not in itself constitute consent to data processing beyond the technical data described in Section 2.

2. Information We Collect

We collect the following categories of personal data:

• Contact and business information — your name, email address, phone or WhatsApp number, company name, and country, when you submit an enquiry or sample request form.
• Enquiry details — product interests, quantity requirements, destination country, Incoterms preference, and any message or specification you provide.
• Technical data — IP address, browser type, and pages visited, recorded in web server logs by our hosting provider (Hostinger). We do not currently use a separate web analytics platform.
• Language preference — if you use the language selector on our site (powered by Google Translate), Google may set a cookie to remember your selected language. See Section 7 for details.

We do not collect payment card details, national identity numbers, biometric data, or any other special category of personal data.

3. How We Use Your Information

We use the personal data we collect for the following purposes:

• To respond to your product enquiry, send pricing, specifications, and technical data sheets.
• To process and dispatch free product samples via DHL or FedEx.
• To send follow-up communications directly related to your enquiry (we do not send unsolicited marketing emails).
• To prepare and issue Proforma Invoices, Commercial Invoices, and export documentation for confirmed orders.
• To comply with Indian export regulations, including record-keeping obligations under APEDA, IEC, and FSSAI requirements.
• To improve website content and correct errors in product information.
• To detect and prevent fraud or misuse of our enquiry forms.

4. Legal Basis for Processing

Under the EU/UK General Data Protection Regulation (GDPR):

• Legitimate interests (Article 6(1)(f)) — responding to B2B enquiries from businesses is a legitimate interest. We rely on this basis when a business representative contacts us with a genuine trade enquiry.
• Contract performance (Article 6(1)(b)) — where a sample has been requested or an order confirmed, processing is necessary to perform that engagement.
• Consent (Article 6(1)(a)) — where you actively submit your details through a contact or sample request form, this constitutes active consent for us to respond. You may withdraw consent at any time by emailing info@daleyglobalex.com.
• Legal obligation (Article 6(1)(c)) — where Indian export law requires us to retain records (e.g. for Customs, APEDA, or FSSAI compliance).

Under India's Digital Personal Data Protection Act 2023 (DPDP Act): see Section 13 below.

5. Sharing Your Information

We do not sell, rent or trade your personal data to any third party. We may share data in the following limited circumstances:

• Web hosting provider — Hostinger International Ltd, which hosts daleyglobalex.com and retains server access logs. Hostinger's servers may be located in the EU or USA.
• Google LLC — if you use the Google Translate widget on our website, your page content and browser data are transmitted to Google. Google's privacy policy applies to that processing: policies.google.com/privacy.
• Logistics partners — DHL or FedEx, for sample dispatch. Only your name, company address and phone number are shared with the courier for shipment purposes.
• Legal authorities — Indian Customs, APEDA, DGFT, FSSAI, or other regulatory bodies, where required by law or export compliance obligations.

6. International Data Transfers

Daley Global Pvt Ltd is based in India. If you are located in the European Union, United Kingdom, or another country with data protection laws, please note that your personal data is processed and stored in India, which may not be recognised by the EU or UK as providing an equivalent level of data protection to GDPR.

By submitting a business enquiry to us, you acknowledge this transfer. We take reasonable steps to protect your data in accordance with this policy.

Additionally, use of Google Translate on our site may result in data being processed by Google on servers in the United States or other countries. Google has implemented EU Standard Contractual Clauses for these transfers.

7. Cookies

Our website uses the following categories of cookies:

• Strictly necessary cookies — store your cookie consent preference (accepted or declined). These cannot be disabled without breaking the consent mechanism itself. No personal data is sent to third parties via these cookies.
• Translation cookies (optional) — Google Translate sets a googtrans cookie to remember your selected language. If you decline our cookie banner, this cookie will still be set by Google Translate when you interact with the language selector; we recommend avoiding the language selector if you have declined cookies. These cookies are controlled by Google LLC.

We do not currently use advertising cookies, tracking pixels, or web analytics cookies (such as Google Analytics). If we add analytics in the future, this policy will be updated before any such tool is activated.

You can manage or delete cookies through your browser settings at any time. Note that disabling essential cookies may affect your ability to use the consent mechanism on our site.

8. Data Retention

We retain personal data only for as long as necessary for the purpose for which it was collected:

• Enquiry and contact data — up to 3 years from the date of last contact, unless an order follows.
• Order and export records — 7 years from the date of shipment, as required under Indian tax and export regulations (Companies Act 2013, GST Act, FEMA, Customs Act).
• Web server logs — retained by Hostinger as per their standard retention period (typically 30–90 days).

9. Your Rights

Depending on your jurisdiction, you may have the following rights:

• Right of access — request a copy of the personal data we hold about you.
• Right to rectification — ask us to correct inaccurate data.
• Right to erasure — ask us to delete your data where no legal obligation requires us to retain it.
• Right to restriction — ask us to limit how we use your data.
• Right to object — object to processing based on legitimate interests.
• Right to data portability — request your data in a portable format (EU/UK GDPR only).
• Right to withdraw consent — at any time, without affecting the lawfulness of prior processing.

To exercise any of these rights, email info@daleyglobalex.com with "Data Request" in the subject line. We will respond within 30 days. We may need to verify your identity before processing your request.

If you are in the EU or UK and are unsatisfied with our response, you have the right to lodge a complaint with your national data protection authority (e.g. the ICO in the UK, or your country's supervisory authority in the EU).

10. Data Security

We implement reasonable technical and organisational measures to protect your personal data, including:

• HTTPS encryption on all pages of daleyglobalex.com.
• Access to enquiry data limited to authorised personnel only.
• Email communications with buyers conducted over standard SMTP with TLS where supported.

No method of internet transmission is 100% secure. We cannot guarantee absolute security but will notify affected individuals promptly if a data breach occurs that is likely to result in a high risk to their rights and freedoms.

11. Third-Party Links

Our website may contain links to third-party platforms including WhatsApp, LinkedIn, Google Maps, and B2B trade directories. We are not responsible for the privacy practices of those platforms. We recommend reviewing their privacy policies before submitting any personal data to them.

12. Children's Privacy

This website is a B2B platform intended for business professionals. We do not knowingly collect personal data from individuals under the age of 18. If you believe we have inadvertently collected such data, please contact us and we will delete it promptly.

13. India – Digital Personal Data Protection Act 2023 (DPDP Act)

Daley Global Pvt Ltd, as an Indian registered company, is subject to the Digital Personal Data Protection Act, 2023 (DPDP Act). Under the DPDP Act:

• We act as a Data Fiduciary in respect of personal data collected from users who interact with our website.
• We collect and process personal data only for lawful purposes as described in this policy.
• You, as the Data Principal, have the right to obtain information about your data, correct inaccurate data, erase data (subject to retention obligations), and raise grievances.
• To raise a grievance under the DPDP Act, contact us at info@daleyglobalex.com. We will acknowledge within 48 hours and respond within 30 days.
• We do not transfer personal data to countries notified as restricted by the Indian Government under Section 16 of the DPDP Act.

Note: The DPDP Act's implementing rules are expected to be notified by the Government of India. Once the rules are in force, this section will be updated to reflect any additional requirements.

14. Changes to This Policy

We may update this Privacy Policy from time to time. The most recent version will always be available at daleyglobalex.com/privacy-policy.html with the "Last updated" date revised accordingly. For material changes, we will make reasonable efforts to notify active enquiry contacts by email.

15. Contact Us

For questions about this Privacy Policy, to exercise your data rights, or to raise a grievance: