Privacy Policy
How DownTown collects, uses and protects your data.
This Privacy Policy explains how EMERGENT, having its registered office at EMERGENT Building, Sirsi, Uttara Kannada, Karnataka ("DownTown", "we", "us", "our"), collects, uses, shares and protects personal data when you use the DownTown mobile application, the website mydowntown.in and any related services (together, the "Platform"). By creating an account, placing an order, submitting an enquiry or otherwise using the Platform, you give your consent to the processing described here. If you do not agree, do not use the Platform.
This policy is published under the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, the Consumer Protection (E-Commerce) Rules, 2020, and the Digital Personal Data Protection Act, 2023 and rules made under it, as applicable.
1. Our role
1.1 DownTown is a technology platform and intermediary. It connects users with independent third parties: restaurants and food outlets, grocery and retail stores, service providers, property owners, builders and agents, and delivery personnel (together, "Partners").
1.2 Partners are independent businesses. When you place an order or enquiry, the Partner receives the personal data needed to fulfil it and processes that data under its own responsibility. DownTown is not responsible for how a Partner handles your data once shared for fulfilment, subject to applicable law.
1.3 DownTown operates in certain towns through franchisees. Franchisees may access user data for their operating area to run local operations, under confidentiality obligations to DownTown.
2. Data we collect
Data you give us
- Identity and contact: name, mobile number, email address, date of birth (if provided), profile photo.
- Addresses: delivery addresses, landmarks, saved locations.
- Order and enquiry details: items ordered, special instructions, dietary preferences you state, service requests, property enquiries, site-visit requests.
- Listings you submit (for Partners and property owners): business details, property details, photographs, pricing, identity and ownership documents, GST, FSSAI and RERA numbers, bank details for settlement.
- Communications: chats, calls, emails, reviews, ratings, complaints, photographs and videos you upload as evidence.
Data we collect automatically
- Location: precise location (GPS) when the app is in use, to show nearby Partners, calculate delivery charges and track delivery. You may turn this off in your device settings; some features will then not work.
- Device and usage: device model, operating system, app version, IP address, device identifiers, crash logs, pages and screens viewed, search terms, time spent, clicks.
- Transaction records: order value, payment method type, payment status, refunds, coupons used.
Data from others
- Payment gateways send us payment status and limited payment identifiers. We do not collect or store your full card number, CVV, UPI PIN or net-banking password.
- Partners and delivery personnel may report order issues, delivery attempts and incidents involving you.
- Referrals: a friend who refers you may share your mobile number with us.
3. How we use data
We use personal data to:
- Create and manage your account and verify your mobile number.
- Process orders, enquiries and bookings, and pass them to the relevant Partner.
- Arrange delivery and share live order status.
- Process payments, refunds, wallet credits and settlements to Partners.
- Handle complaints, investigate refund claims and recover amounts from Partners at fault.
- Detect, prevent and investigate fraud, abuse, fake orders, coupon misuse and fraudulent refund claims.
- Send transactional messages by SMS, WhatsApp, push notification, email or call.
- Send offers and promotions, where you have not opted out.
- Personalise the Platform, including recommendations and search results.
- Analyse usage and improve the Platform, including aggregated and anonymised analytics.
- Comply with law, court orders, tax and accounting duties, and requests from government authorities.
- Enforce our Terms and Conditions and protect the rights, property and safety of DownTown, users, Partners and the public.
4. Who we share data with
We do not sell your personal data. We share it only as follows:
- Restaurants and stores: your name, order details, instructions and, where needed, contact number and address.
- Delivery personnel: your name, delivery address, location pin and a contact number (masked where our system supports masking).
- Service providers and property owners/agents: your name, contact number and enquiry details when you submit an enquiry, request a callback or book a visit. After this, they may contact you directly. DownTown does not control that contact.
- Franchisees: data for orders and users in their territory.
- Vendors who help us run the Platform: cloud hosting, database, SMS, WhatsApp, maps, analytics, payment gateways and customer support tools. They process data on our instructions.
- Authorities: government, law enforcement, courts and regulators where required by law or to protect rights and safety.
- Business transfers: a buyer, investor or successor entity in a merger, acquisition, restructuring or sale of assets, bound by this policy.
5. Reviews, ratings and public content
Reviews, ratings, photos and listing content you post are public. Your first name or display name may appear with them. We may keep, display, edit for length, or remove such content at our discretion.
6. Calls and chats
Calls and chats between you, DownTown support, Partners and delivery personnel may be recorded or logged for quality, training, dispute resolution and fraud prevention. By using these channels you consent to such recording.
7. Cookies and tracking
The website and app use cookies, SDKs and similar technologies for login, preferences, analytics and advertising measurement (for example, Google and Meta tools). You can control cookies through your browser. Blocking them may affect how the Platform works.
8. Retention
We keep personal data only as long as needed for the purposes above or as required by law. Order, payment and tax records are kept for at least 8 years to meet tax and accounting laws. Data needed to defend legal claims or investigate fraud is kept until the matter is closed. After this, data is deleted or anonymised.
9. Security
We use reasonable security practices, including encrypted connections (HTTPS/TLS), access controls and restricted staff access. No internet transmission or storage is fully secure. To the extent permitted by law, DownTown is not liable for unauthorised access caused by events beyond its reasonable control, or by your failure to protect your device, OTP or account credentials. Never share your OTP with anyone, including people claiming to be DownTown staff.
10. Your rights
Subject to applicable law, you may:
- Access a summary of the personal data we hold about you.
- Correct or update inaccurate data (most fields can be edited in the app).
- Request erasure of your data and deletion of your account, except data we must keep by law or for pending orders, refunds or disputes.
- Withdraw consent at any time. Withdrawal does not affect processing already done, and some services may stop working.
- Opt out of promotional messages through app settings or by replying STOP where supported. Transactional messages will continue.
- Nominate another person to exercise your rights in case of death or incapacity.
- Raise a grievance with our Grievance Officer (Section 13) and, if unresolved, with the Data Protection Board of India.
We may verify your identity before acting on a request.
11. Children
The Platform is meant for persons aged 18 and above. We do not knowingly collect data of children without verifiable consent of a parent or lawful guardian. If you are a parent and believe your child has used the Platform, contact us and we will delete the data.
12. Third-party links and services
The Platform may link to third-party websites, apps, payment pages or Partner pages. Their privacy practices are governed by their own policies. DownTown is not responsible for them.
13. Grievance Officer
In accordance with the Information Technology Act, 2000, the rules made under it and the Consumer Protection (E-Commerce) Rules, 2020:
- Name: Raghavendra Naik
- Designation: Grievance Officer, EMERGENT
- Address: EMERGENT Building, Sirsi, Uttara Kannada, Karnataka
- Email: support@mydowntown.in
- Phone / WhatsApp: +91 73490 59409
We acknowledge complaints within 48 hours and aim to resolve them within one month from receipt.
14. Changes to this policy
We may update this policy from time to time. The updated version will be posted on the Platform with a new "Last updated" date. Material changes will be notified in the app. Continued use after the update means you accept the revised policy.