Data Retention & Record Policy

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1. Purpose of This Policy

This Data Retention & Record Policy explains how 4CERA GLOBAL PRIVATE LIMITED, operating under the brand name Kiaara Diamonds (“Company”), collects, stores, retains, and manages records of Customers and Direct Sellers.

The objectives of this Policy are to:

  • Ensure transparency and accountability
  • Support audits and regulatory inquiries
  • Comply with applicable Indian laws
  • Protect the rights and data of users

2. Scope of Records Covered

This Policy applies to all records generated through the use of the Kiaara Diamonds platform, including but not limited to:

  • Customer and Direct Seller registration records
  • KYC and identity verification documents
  • Purchase, repurchase, and order invoices
  • Incentive, commission, and payout records
  • Cashback Wallet transactions
  • Grievances, complaints, and resolutions
  • Communication records related to compliance

3. Data Retention Period

Kiaara Diamonds retains records for the following minimum periods, unless a longer period is required by law:

3.1 KYC & Identity Records

PAN, Aadhaar (where applicable), bank details, and other KYC documents.

  • Retention Period: Minimum 2 (Two) years from the date of last transaction or account closure
3.2 Transaction & Financial Records
  • Product purchase invoices
  • Incentive and commission payouts
  • Cashback Wallet credits and utilization
  • Tax deduction (TDS) and statutory records

Retention Period:

  • Minimum 3 (Three) years, or
  • As required under the Income Tax Act, GST laws, or audit regulations
3.3 Direct Seller Agreement & Policy Acceptance
  • Registration forms
  • Acceptance of Terms & Conditions, Compensation Plan, and Company Policies

Retention Period:

  • Minimum 2 (Two) years from termination or resignation
3.4 Grievance & Dispute Records
  • Complaints raised by Customers or Direct Sellers
  • Investigation notes and resolution outcomes

Retention Period:

  • Minimum 2 (Two) years from final resolution, or
  • Till closure of any legal or regulatory proceedings

4. Audit & Regulatory Inquiry Support

Kiaara Diamonds maintains records in a manner that enables:

  • Internal audits
  • Statutory audits
  • Government or regulatory inspections
  • Consumer authority inquiries
  • Law enforcement requests, where legally required

Records shall be provided only to authorized authorities and strictly in accordance with applicable laws.

5. Data Storage & Security Measures

  • All records are stored in secure electronic systems with controlled access
  • Reasonable security practices are followed to prevent unauthorized access, alteration, or loss
  • Access to sensitive records is restricted to authorized personnel only

6. Data Confidentiality & Use Limitation

  • Personal and financial data is used only for lawful business, compliance, and regulatory purposes
  • Records are not sold, shared, or disclosed to third parties except with:
    • Banks and payment gateways
    • Statutory auditors
    • Government or regulatory authorities (as required by law)

7. Record Deletion & Anonymization

After completion of the applicable retention period:

  • Records may be securely deleted, archived, or anonymized
  • Deletion is carried out in a manner that prevents unauthorized recovery

This does not apply where data must be retained due to:

  • Ongoing disputes
  • Legal proceedings
  • Regulatory directions

8. User Rights

Customers and Direct Sellers may:

  • Request confirmation of data held by the Company
  • Seek correction of inaccurate records
  • Request deletion, subject to legal and regulatory retention requirements

Requests may be submitted through the Company’s official support channels.

9. Policy Review & Amendments

This Policy may be updated from time to time to reflect:

  • Changes in law or regulations
  • Updates in compliance requirements
  • Improvements in data security practices

Revised versions shall be published on the official website.

10. Governing Law & Jurisdiction

This Data Retention & Record Policy shall be governed by the laws of India, and courts at Delhi (India) shall have exclusive jurisdiction.

Kiaara Diamonds
Secure Records.
Transparent Operations.
Compliance Without Compromise.