QJ Club — Privacy Policy
Draft v0.11 · 29 October 2026 · for review, not yet in force
Written for the Digital Personal Data Protection Act, 2023 (DPDP Act). All decisions taken by Queens Jewels (Sunny Singhal, 13 September 2026); for legal review.
1. Who is responsible for your data
Fabyouare Private Limited (trading as Queens Jewels), LG54, Mega Mall, DLF Phase 1, Gurugram 122002, Haryana, GSTIN 06AADCF0880F1ZW ("Queens Jewels", "we") is the data fiduciary for the QJ Club membership programme — we decide why and how your personal data is used.
The programme runs on a membership platform provided by our technology partner, which processes your data only on our instructions as our data processor.
2. What we collect
| Data | Where it comes from |
|---|---|
| Mobile number | You, when you join |
| Name | You (optional; the counter may add it) |
| Email address | You (optional): in the app, or at the counter — proved either way by a code we send to it. If you have no WhatsApp, the store can send your bills, points, vouchers and sign-in codes there instead |
| A second WhatsApp number | You, at the counter, when your mobile has no WhatsApp. Used — for the messages and sign-in codes below — only after you read back a code we send to it, we call your mobile, and the store's admin approves it; you are still found by your mobile, and your card shows both numbers |
| Purchases: bill number, date, amount, items where recorded | Our billing, linked to your membership at the counter |
| GST number and the name it is registered in (GSTIN, GST billing name) | You, only when you ask for a GST bill; kept so your next GST bill offers them back |
| Points earned and redeemed, tier | Generated by the programme from your purchases |
| Visits and enquiries recorded by staff at the counter | Our staff |
| Consent choices and when you made them | You |
| Sign-in and device information (session, browser type) needed to keep you signed in | Your device |
We do not collect payment card details, and we do not use any camera-based or biometric recognition. Birthday, anniversary and address are not asked for; if you have given them to the store earlier they are kept only for the purposes below.
3. Why we use it
| Purpose | Basis |
|---|---|
| Running your membership: identifying you at the counter, crediting and redeeming points, tier status, showing your card and passbook | Your consent when you join, and performance of the programme you asked for |
| Sending one-time codes and transactional messages (points earned, redeemed or reversed, welcome and store-issued vouchers, tier, expiry) on WhatsApp or email | Necessary to provide the membership |
| Telling you on WhatsApp about a piece you have left with us: that we have taken it in, with its reference, and that it is ready to collect | Necessary to provide the repair or order you asked for |
| Sending offers and updates on WhatsApp | Your separate consent, which you can withdraw in Profile at any time |
| Sending offers by email | Your separate yes, given at the counter or in the app when your email is proved — optional, and not a condition of the points for adding an email; every offer email has a one-click unsubscribe |
| Showing you our ads on advertising platforms, and finding people with similar interests: we share your mobile number, email and name in hashed (scrambled) form so the platform can match them to an account you already hold there | Your consent, which you can withdraw at any time by writing to us; you are then left out of every later list we share |
| Store operations: counts of walk-ins, sales and conversion, and internal notifications to store staff | Legitimate running of the store; reports use counts, not your identity |
| Putting your GST number and registered name on a GST invoice you asked for, and the tax that applies (CGST + SGST, or IGST for a GST number from another state) | Necessary for the bill you asked for, and legal obligation |
| Keeping records required by tax and other law | Legal obligation |
We do not sell your data, and we do not allow any platform to use it for its own advertising or anyone else's — only to show you ours.
4. Who we share it with
- Our technology partner, which operates the membership platform for us.
- Cloud hosting providers, with the platform and its database hosted in India.
- A WhatsApp Business messaging provider, to deliver our WhatsApp messages to you.
- Google (Google Workspace), whose mail service sends our emails to you from the store's own mailbox.
- Advertising platforms — Meta (Facebook, Instagram) and Google (Search, YouTube and its partner sites) — your mobile number, email and name, hashed before they leave us, to match you to your account there and show you our ads. Each uses it under its terms for advertisers. If we add another platform, we will name it here before we share anything with it.
- An internal team-messaging tool used to notify store staff about walk-ins and sales (your name, member number and bill or order reference; never your phone number or email).
- Government authorities where the law requires.
Each processor is bound to use your data only for the service it provides to us.
5. How long we keep it
- Membership data: while you are a member, and for 90 days after you close it, so points and disputes can be settled.
- Purchase and billing records: 8 years, as required by tax law, even after you leave the Club.
- Advertising lists: rebuilt from our records each time we share one; a person who withdraws is left out of the next list, and we remove lists we no longer use from the platform.
- Consent records: every choice you make and when you made it, kept for as long as the consent is relevant and 1 year after withdrawal, as proof. These records do not name you once your data is erased.
- After these periods data is deleted or anonymised.
6. Your rights
Under the DPDP Act you may:
- See the personal data we hold about you and how it has been used.
- Correct or update it — name and email can be changed in Profile; anything else, ask us.
- Erase it — ask us to close your membership and delete your data, except records we must keep by law. Erasure removes your name, number, email, profile details, card and sign-in; your past purchases stay in the store's accounts without your name on them, and GST bills keep the buyer details tax law requires. We also delete your contact with our WhatsApp provider.
- Withdraw consent — offers on WhatsApp can be switched off in Profile; ad matching on Meta, Google and any other platform named in section 4 by writing to us; membership consent by closing your membership.
- Nominate someone to exercise these rights for you if you are unable to.
- Complain — first to our Grievance Officer below; if unresolved, to the Data Protection Board of India.
To exercise a right, write to the Grievance Officer. We will verify it is you (usually with a code to your registered mobile) and respond within 30 days.
7. Security
Your data is stored in India, encrypted in transit, and protected by row-level access controls so that you can see only your own records and staff can see only this store's. Sign-in uses one-time codes; there are no passwords to steal. Staff access is by named login and role, and is logged.
8. Children
The Club is for adults. We do not knowingly enrol anyone under 18; if we learn we have, we will delete the membership.
9. Cookies and the app
The app sets only the cookies needed to keep you signed in and to remember which store's card to show. No advertising or third-party analytics cookies are used.
10. Changes
We will publish any change to this policy in the app and, for material changes, tell you on WhatsApp or email before it takes effect.
11. Grievance Officer and contact
Anshika Talwar, Grievance Officer, Fabyouare Private Limited anshikatalwar@fabyouare.com · info@queensjewels.in · LG54, Mega Mall, DLF Phase 1, Gurugram 122002, Haryana
See also the Terms & Conditions.
