Account Closure & Data Deletion Policy
This Account Closure & Data Deletion Policy (“Policy”) sets out the process by which an Account Holder being a person or entity that has registered and maintains an account on the SutraFin Platform (hereinafter referred to as the “Platform”), operated by SutraOS Technologies Private Limited (hereinafter referred to as “Company”), may request closure of the account and deletion of personal data, subject to applicable law, contractual obligations and legitimate requirements for retaining certain information.
1. Request for Account Closure or Data Deletion
a.An Account Holder may request closure of the account and, where applicable, deletion of personal data by submitting a request through the following channel:
Email: support@sutrafin.com
b.The request should contain sufficient information to identify the relevant account and enable the Company to verify and process the request. The Company may require reasonable verification or additional information where necessary to authenticate the requester and prevent unauthorised requests.
2. Verification of Request
The Company may take reasonable steps to verify the identity and, where applicable, the authority of the person making an account closure or data deletion request before processing such request. Such verification may include OTP verification through the registered mobile number or email address, verification of an authorised representative, or such other reasonable authentication measures as the Company may consider appropriate.
3. Pending Orders and Obligations
a.Account closure may be deferred where the Account Holder has pending orders, returns, refunds, payments, Platform charges, disputes, investigations, regulatory requirements or other outstanding obligations requiring resolution.
b.Account closure shall not affect any rights, obligations or liabilities accrued by the Account Holder prior to such closure.
4. Effect of Account Closure
Upon closure of an account, the Account Holder’s ability to log in, place new orders or access Platform services associated with the account may be disabled. Account closure shall not, by itself, result in the deletion of all information relating to the Account Holder. Certain information may continue to be retained where required or permitted under applicable law or for the purposes set out in this Policy and the Privacy Policy.
5. Deletion of Personal Data
a.Upon receipt and verification of a valid data deletion request, the Company shall assess the personal data associated with the relevant account and delete, anonymise or securely dispose of such data where such data is no longer required for a lawful purpose.
b.Deletion of personal data shall remain subject to applicable legal, regulatory, contractual, accounting, tax, dispute resolution, security, fraud prevention and other applicable retention requirements.
6. Data and Records Retained
a.Notwithstanding account closure or a data deletion request, the Company may retain information and records where required or permitted under applicable law or regulatory requirements, including:
- invoices, GST and other tax records;
- accounting and financial records;
- completed transaction and order records;
- contractual records;
- records relating to fraud prevention, security and misuse of the Platform;
- complaints, disputes and investigation records;
- records required for litigation, legal proceedings or enforcement of rights;
- audit and compliance records; and
- other records that the Company is required or permitted to retain under applicable law or regulatory requirements.
7. Use of Retained Information
Information retained by the Company after account closure shall be protected in accordance with applicable security and data protection requirements. Such information shall be used only where necessary for the purpose for which it has been retained, including to comply with applicable law, meet tax, accounting or regulatory requirements, prevent fraud or misuse of the Platform, maintain security, conduct audits, resolve disputes, or establish, exercise or defend legal claims.
8. Backups and Archived Data
a.Where personal data has been deleted from the Company’s active systems, copies of such data may continue to exist in secure backups or archival systems for a limited period. Such copies may be retained for purposes such as business continuity, disaster recovery, security or compliance with applicable requirements.
b.The Company shall delete, overwrite or otherwise securely dispose of such data in accordance with its applicable backup and data retention procedures.
9. Distributor Accounts
a.Closure of a Distributor Account shall not affect any obligations or liabilities arising from transactions or activities undertaken through the Platform before such closure, including obligations relating to fulfilment, payments, taxes, returns, recalls, warranties, confidentiality, disputes, indemnities or any other contractual or legal obligations.
10. Processing of Requests
a.The Company shall process account closure and data deletion requests within a reasonable period, having regard to the nature of the request, applicable legal and regulatory requirements, verification requirements and any pending obligations or applicable retention requirements.
b.Where appropriate, the Company may communicate the status or outcome of a request through the registered mobile number, email address or such other authorised communication channel.
11. Contact
a.For any request relating to account closure or deletion of personal data, the Account Holder may contact the Company at:
Account Closure and Data Deletion Requests: support@sutrafin.com
Privacy-related Queries: support@sutrafin.com
Grievance Officer: support@sutrafin.com
12. Amendment
The Company may amend or modify this Policy from time to time to reflect changes in the Platform, applicable law, regulatory requirements or the Company’s data processing and retention practices. Any amendment or modification to this Policy shall be made available through the Platform or the Company’s website, as applicable.