Privacy Policy

This Privacy Policy explains what information we collect, how we use it, how we protect it, and your rights in relation to your personal data.

1. Introduction

1.1 Divine Benidictions Private Limited, a company incorporated under the Companies Act, 2013, having CIN: U46596PB2023PTC059636 and its registered office at 4 R.B, Duni Chand road, Lawrence road extension, Amritsar 143001 Punjab, India ("Company"), operates the website taxpearl.com ("Website") under the brand name "Tax Pearls Consultancy." All references to "Tax Pearls Consultancy," "we," "us," or "our" in this Policy refer to Divine Benidictions Private Limited.

1.2 This Privacy Policy explains what information we collect, how we use it, how we protect it, and your rights in relation to your personal data. This Policy applies to all information collected through the Website and through direct interactions with the Company (including email, phone, and in-person communications).

1.3 By using this Website or providing your personal data to us, you consent to the collection, use, storage, and disclosure of your information as described in this Privacy Policy. If you do not agree with this Policy, you should not use this Website or provide personal data to us.

2. Information We Collect

2.1 Personal Information

We may collect the following personal information when you interact with our Website or engage our services:

• Full name
• Email address
• Phone number and mobile number
• Postal address
• Organisation name and designation
• PAN, GSTIN, or other tax identification numbers (when provided for engagement purposes)
• Any other information you voluntarily provide through enquiry forms, emails, or during the course of an engagement

2.2 Sensitive Personal Data or Information (SPDI)

Under Rule 3 of the SPDI Rules, sensitive personal data or information includes information relating to passwords, financial information (such as bank account or credit/debit card details), physical, physiological, and mental health conditions, sexual orientation, medical records, and biometric information.

We do not ordinarily collect sensitive personal data through this Website. In the event that sensitive personal data is required for the provision of our Professional Services (for example, financial information for tax return preparation or audit), such data will be collected only with your explicit consent, will be used solely for the purpose for which it was collected, and will be protected in accordance with the reasonable security practices described in this Policy.

2.3 Automatically Collected Information

When you visit our Website, certain information may be automatically collected through cookies and similar technologies, including:

• IP address
• Browser type and version
• Operating system
• Pages visited, time spent on pages, and navigation patterns
• Referring website or source
• Device type (desktop, mobile, tablet)

This information is collected for the purpose of improving the Website's functionality, analysing usage patterns, and enhancing your browsing experience. This information is not linked to your personal identity unless you have separately provided personal information to us.

3. Purpose of Collection and Use

We collect and use your personal information for the following purposes:

• Responding to Enquiries: To respond to queries submitted through the contact form, email, or phone.
• Providing Professional Services: To deliver the tax advisory, audit, GST, and other professional services for which you have formally engaged us.
• Sending Communications: To send you tax alerts, regulatory updates, newsletters, event invitations, and other communications that you have opted to receive.
• Website Improvement: To analyse usage patterns, improve Website functionality, and enhance user experience.
• Legal and Regulatory Compliance: To comply with applicable laws, regulations, professional standards, and regulatory requirements, including the Companies Act, 2013, anti-money laundering obligations, and professional ethics requirements prescribed by the Institute of Chartered Accountants of India (ICAI) and the Bar Council of India, as applicable.
• Legitimate Business Purposes: To maintain internal records, manage the Company's operations, and protect the Company's legal interests.

4. Consent

4.1 By providing your personal information to us through the Website (including by submitting the contact form, subscribing to the newsletter, or sending an email), you consent to the collection, use, storage, and processing of your personal information in accordance with this Privacy Policy.

4.2 Where sensitive personal data is required, we will obtain your explicit consent before collection, as required under Rule 5(1) of the SPDI Rules.

4.3 You have the right to withdraw your consent at any time by writing to our Grievance Officer at the contact details provided in Section 12 below. Please note that withdrawal of consent may affect our ability to provide certain services to you.

5. Disclosure of Information

5.1 We do not sell, trade, rent, or otherwise disclose your personal information to third parties for their marketing or commercial purposes.

5.2 We may disclose your personal information in the following circumstances:

• With Your Consent: Where you have expressly authorised the disclosure.
• Service Providers: To third-party service providers who assist us in operating the Website (such as hosting providers, email service providers, and analytics providers), subject to confidentiality obligations and, where applicable, data processing agreements.
• Professional Obligations: To the extent necessary for the provision of Professional Services (for example, filing returns with tax authorities on your behalf, where you have engaged us to do so).
• Group Entities: To any subsidiary, holding company, or fellow subsidiary of Divine Benidictions Private Limited, subject to confidentiality obligations equivalent to those in this Policy.
• Legal Requirements: Where disclosure is required by law, regulation, court order, or governmental authority. As required under Rule 6 of the SPDI Rules, we may disclose information to government agencies mandated under law, provided such agency furnishes a written request stating the purpose of seeking the information.
• Protection of Rights: Where disclosure is necessary to protect the rights, property, or safety of the Company, its clients, or the public.
• Corporate Transactions: In the event of a merger, acquisition, reorganisation, or sale of assets of the Company, your personal information may be transferred to the successor entity, subject to this Privacy Policy.

6. Data Retention

6.1 We retain your personal information only for as long as is necessary for the purposes for which it was collected, or as required by applicable law (including the Companies Act, 2013, which prescribes certain record-retention obligations for companies).

6.2 For clients with whom we have a formal engagement, we retain engagement-related records for a minimum of eight years from the completion of the engagement, in accordance with professional standards and regulatory requirements applicable to Chartered Accountants and tax practitioners. You should verify the exact retention period applicable under the current ICAI guidance and any DPDP Act requirements that may become operative.

6.3 For newsletter subscribers, we retain your email address until you unsubscribe. For contact form enquiries that do not result in a formal engagement, we retain the information for a period of twelve months from the date of submission, after which it is securely deleted.

7. Security Practices and Procedures

7.1 As a body corporate within the meaning of Section 43A of the IT Act, the Company implements reasonable security practices and procedures to protect your personal information from unauthorised access, alteration, disclosure, or destruction.

7.2 Our security measures include:

• Encryption of data in transit using SSL/TLS protocols.
• Access controls limiting access to personal information to authorised personnel only.
• Regular review of information collection, storage, and processing practices.
• Physical and logical security measures for systems storing personal data.
• Periodic security audits as required under Rule 8 of the SPDI Rules.

7.4 While we take all reasonable steps to protect your personal information, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee the absolute security of your information.

8. Cookies

8.1 This Website uses cookies — small text files placed on your device — to enhance your browsing experience. Cookies help us understand how you interact with the Website, remember your preferences, and improve site performance.

8.2 We use the following types of cookies:

• Essential Cookies: Required for the basic functioning of the Website (session management, security).
• Analytics Cookies: Used to collect anonymous usage data (such as pages visited and time spent) to help us improve the Website. We use Google Analytics for this purpose.

8.3 You can manage cookie preferences through your browser settings. Disabling cookies may affect the functionality of certain parts of the Website.

9. Your Rights

Under the SPDI Rules and, upon full enforcement, the DPDP Act, you have the following rights in relation to your personal information:

• Right to Access: You may request access to the personal information we hold about you.
• Right to Correction: You may request correction or amendment of any personal information that is inaccurate or deficient (Rule 5(6) of the SPDI Rules).
• Right to Withdraw Consent: You may withdraw your consent to the processing of your personal information at any time (Rule 5(7) of the SPDI Rules).
• Right to Erasure: Upon full enforcement of the DPDP Act (expected by May 2027), you will have the right to request erasure of your personal data, subject to applicable retention requirements under law.
• Right to Nomination: Upon full enforcement of the DPDP Act, you will have the right to nominate an individual to exercise your data rights in the event of your death or incapacity.
• Right to Grievance Redressal: You have the right to file a complaint with our Grievance Officer. If your complaint is not resolved to your satisfaction, you will, upon the operationalisation of the Data Protection Board of India, have the right to file a complaint with the Board.

To exercise any of these rights, please contact our Grievance Officer at the details provided in Section 12 below.

10. Cross-Border Data Transfer

We do not ordinarily transfer your personal information outside India. In the event that such transfer becomes necessary (for example, where a service provider's servers are located outside India), we will ensure that the receiving entity maintains the same level of data protection as required under the SPDI Rules and, upon enforcement, the DPDP Act. We will not transfer your personal information to any country that the Central Government may restrict or prohibit under the DPDP Act.

11. Third-Party Websites and Services

This Website may contain links to third-party websites. This Privacy Policy does not apply to third-party websites. We encourage you to review the privacy policies of any third-party websites you visit.

12. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. Any changes will be posted on this page with a revised "Effective Date." We will update this Policy to reflect the full requirements of the DPDP Act and DPDP Rules before the Phase 3 enforcement date (expected May 2027). We encourage you to review this page periodically.

13. Grievance Officer

In accordance with Rule 5(9) of the SPDI Rules, the Company has designated the following Grievance Officer to address any complaints or concerns regarding the processing of personal information: