Pamphlet Box is currently in the process of company registration. Until incorporation is complete,
this Platform is operated on an unregistered / proprietary basis. References to "Pamphlet Box" in
this policy refer to the business as currently operated, and will be updated to reflect the
registered entity name, address, and CIN once incorporation is complete.
1. Introduction
This Privacy Policy explains how Pamphlet Box ("we", "us", "our") collects, uses, shares, and
protects personal data when you use our website (pamphletbox.com) and mobile application (together,
the "Platform"). This Policy is intended to align with the Digital Personal Data Protection Act,
2023 and the Digital Personal Data Protection Rules, 2025, and other applicable Indian law.
By creating an account or otherwise using the Platform, you consent to the practices described in
this Policy.
2. Who This Policy Applies To
- Businesses that create advertising campaigns on the Platform ("Advertisers")
- Individuals who subscribe to campaigns and post content to their WhatsApp Status ("Promoters")
- Visitors to our website
3. Information We Collect
3.1 Information you provide directly
- Name, phone number, email address
- Business details (Advertisers): business name, address, GST registration number
- Government ID and KYC information (Promoters, required before first payout): PAN,
Aadhaar where applicable, and bank account or UPI details
- Payment details, processed directly by our licensed Payment Aggregator partners — we do not
store full card numbers
- Campaign content, creatives, and budget information (Advertisers)
- Screenshots submitted as proof of Status posting and views (Promoters)
3.2 Information collected automatically
- Device information (device identifier, operating system, app version)
- Approximate or precise location — used only to match Promoters with campaigns available
in their area, and to let Advertisers define a campaign radius
- Usage data (features used, campaign interactions, app performance)
3.3 A note on screenshots and third-party data
Screenshots submitted for view verification may incidentally contain information about third
parties — for example, names or numbers visible in a "viewed by" list. We ask Promoters to
avoid submitting screenshots that expose more information than necessary for verification.
Screenshots are used solely for verification purposes and are not shared outside that process.
4. How We Use Your Information
- Create and manage your account
- Match Advertiser campaigns with eligible Promoters based on declared or device location
- Verify campaign views and process payouts
- Deduct and remit applicable taxes (GST, TDS) as required by law
- Communicate with you about your account, campaigns, or payouts
- Detect and prevent fraud, including coordinated activity between linked accounts
- Comply with legal and regulatory obligations
- Improve and maintain the Platform
5. Legal Basis and Consent
We collect and process personal data on the basis of your explicit, informed, and specific
consent for each stated purpose, as required under the DPDP Act, 2023. Consent is collected
separately for distinct purposes. You may withdraw consent at any time, subject to Section 9;
withdrawal does not affect the lawfulness of processing carried out before withdrawal.
6. How We Share Your Information
- Licensed Payment Aggregators (for example, Razorpay or Cashfree) to process payments and
payouts
- Licensed BBPS and voucher redemption partners, only if and when a Promoters chooses a
non-bank payout option
- Government and tax authorities, as required for GST and TDS compliance
- Service providers supporting our operations (hosting, analytics, customer support), bound by
contractual data protection obligations
- Law enforcement or regulators, where required by law
We do not sell personal data to third parties.
7. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes described in this
Policy, or as required by applicable law (for example, financial records required under tax law).
8. Data Security
We implement reasonable security safeguards, including encryption in transit, access controls,
and security requirements for vendors, to protect personal data against unauthorized access, loss,
or misuse.
9. Your Rights
- Access the personal data we hold about you
- Correct or update inaccurate or incomplete data
- Request erasure of your data, subject to our legal retention obligations
- Withdraw consent
- Nominate another individual to exercise your rights in the event of death or incapacity
- Register a grievance with our Grievance Officer, and if unresolved, escalate to the Data
Protection Board of India
To exercise these rights, contact us at
thepamphletbox@gmail.com.
10. Age Requirement
The Platform is intended for users who are 18 years of age or older. We do not knowingly collect
personal data from anyone under 18. If we learn that we have collected data from a minor, we will
delete it promptly.
11. Cookies
Our website may use cookies for basic functionality and analytics.
12. Grievance Officer
Name: [to be appointed]
Address: Greater Noida, India
Email: thepamphletbox@gmail.com
We will acknowledge grievances within 48 hours and aim to resolve them within one month of
receipt.
13. Changes to This Policy
We may update this Policy from time to time. Material changes will be notified to you through
the Platform or via email before they take effect.
14. Contact Us
Pamphlet Box
Greater Noida, India
Email: thepamphletbox@gmail.com