Privacy Policy
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At Sapy International, we are committed to protecting your privacy and handling your personal data with transparency, integrity, and care. This Privacy Policy explains how Sapy International ("Company", "we", "us", "our") collects, uses, stores, shares, and protects personal information submitted by individuals ("you", "your") through our website located at www.sapyinternational.com.
This Privacy Policy has been prepared in compliance with the Digital Personal Data Protection Act, 2023 (DPDPA) of India and other applicable data protection regulations. By accessing or using our website, submitting an enquiry, or applying to become a retail partner, you consent to the practices described in this Privacy Policy.
Please read this policy carefully. If you do not agree with its terms, please discontinue use of our website.
1. Who We Are
Sapy International is a New Delhi-based company specialising in the curation and distribution of luxury and semi-luxury international eyewear brands across India. We are the authorised distribution partner for a curated portfolio of international eyewear brands including Italia Independent, Laps, FAOS, Odette Lunettes, and COCO Leni. For all privacy-related queries and data protection matters, please contact us at:
Data Controller: Sapy International
3rd Floor, DDA Retail Business Centre, Unit No. 312, Nangal Raya Extention, Karan Market, Block A, Nangal Raya, Janakpuri, New Delhi, Delhi 110046.
Email: info@sapyinternational.com
Phone: +91 80762 24831 2. Information We Collect
We collect personal information only when it is necessary for legitimate business purposes. The types of personal information we may collect include:
2.1 Information You Provide Directly When you interact with our website — by submitting an enquiry form, completing a retail partner application, or contacting us directly — we may collect the following:
Full name
Business or store name
Email address
Phone number
Business address including city, state, and PIN code
Type of business or store
Annual eyewear turnover range (where voluntarily provided)
Brands currently stocked
Brands of interest from our portfolio
How you heard about us
Any additional information you choose to include in the message or comments field
2.2 Information Collected Automatically When you visit our website, certain technical information is collected automatically through cookies and analytics tools, including:
IP address and approximate geographic location Browser type and version Device type and operating system Pages visited and time spent on each page Referring website or source Date and time of visit Session duration and navigation path
2.3 Information from Third Parties
We may receive information about you from third parties in limited circumstances, such as when a retail partner or brand principal refers you to us or provides your contact details in connection with a business enquiry.
3. How We Use Your Information
We use the personal information we collect for the following purposes:
3.1 Responding to Enquiries To review, process, and respond to enquiries submitted through our contact or enquiry forms, including questions about our brand portfolio, distribution services, or retail partnership opportunities.
3.2 Retail Partner Applications To assess and process applications from optical retailers, boutiques, and multi-brand stores seeking to become Sapy International retail partners. This includes reviewing store details, location, and brand preferences to determine suitability.
3.3 Business Communications To send you relevant information about our brands, new collection launches, trade show participation, and other business updates — but only where you have provided your consent or where we have a legitimate business interest in doing so.
3.4 Marketing Communications With your consent, to send you marketing communications including newsletters, brand announcements, exhibition invitations, and promotional updates. You may withdraw your consent to marketing communications at any time by clicking "Unsubscribe" in any email we send or by contacting us directly.
3.5 Website Improvement To analyse website usage patterns through anonymised analytics data, allowing us to improve the structure, content, and user experience of our website.
3.6 Legal Compliance To comply with applicable laws, regulations, and legal obligations in India, including the Digital Personal Data Protection Act, 2023, and to respond to lawful requests from regulatory or government authorities.
3.7 Fraud Prevention & Security To protect the integrity of our website and business operations, detect and prevent fraudulent enquiries or applications, and maintain the security of our systems and data.
4. Legal Basis for Processing Under the Digital Personal Data Protection Act, 2023 (DPDPA), we process your personal data on the following legal bases:
Consent — where you have given us clear consent to process your data for a specific purpose, such as receiving marketing communications Contractual Necessity — where processing is necessary to fulfil a business arrangement or pre-contractual steps you have requested, such as a retail partner application Legitimate Interests — where processing is necessary for our legitimate business interests, such as responding to general enquiries, improving our website, or maintaining business records, provided those interests are not overridden by your rights Legal Obligation — where processing is required to comply with a legal or regulatory obligation applicable to Sapy International under Indian law
5. How We Share Your Information
Sapy International does not sell, rent, or trade your personal information to any third party. We may share your information in the following limited and controlled circumstances:
5.1 Brand Principals
Where you enquire about a specific brand in our portfolio, we may share relevant details of your enquiry with the brand principal or manufacturer concerned, strictly for the purpose of facilitating your request. This will only be done where it is necessary and appropriate.
5.2 Service Providers
We work with trusted third-party service providers who assist us in operating our website and running our business — including web hosting providers, email delivery platforms, CRM software providers, and analytics services. These providers are contractually bound to process your data only as instructed by us and to maintain appropriate confidentiality and security standards.
5.3 Legal & Regulatory Authorities
We may disclose your personal information to law enforcement agencies, regulatory bodies, or other government authorities where we are required to do so by law, court order, or other legal process applicable in India.
5.4 Business Transfers
In the event of a merger, acquisition, restructuring, or sale of all or part of Sapy International's business, your personal data may be transferred to the relevant successor entity, subject to the same privacy protections described in this policy. We will never share your data with third parties for their own independent marketing or commercial purposes without your explicit consent.
6. Cookies & Tracking Technologies
Our website uses cookies and similar tracking technologies to enhance your browsing experience and gather analytical insights. Please refer to our Cookie Policy for full details on the types of cookies we use, their purpose, and how you can manage your cookie preferences. In summary, we use the following types of cookies:
Strictly Necessary Cookies — essential for the website to function and cannot be disabled
Analytics Cookies — help us understand how visitors use our website (anonymised data via Google Analytics)
Functional Cookies — remember your preferences for a more personalised experience
You can manage and disable non-essential cookies through your browser settings or via the cookie consent tool on our website at any time.
7. Data Retention
We retain your personal information only for as long as is necessary to fulfil the purposes for which it was collected, unless a longer retention period is required or permitted by applicable Indian law. Our general data retention guidelines are as follows:
Enquiry and contact form submissions — retained for up to 24 months from the date of submission, or longer if an active business relationship develops Retail partner applications — retained for the duration of the partnership, and for up to 36 months following the end of the relationship Marketing communication records — retained until you withdraw consent or unsubscribe Website analytics data — retained in anonymised, aggregated form for up to 26 months (standard Google Analytics retention) Legal and compliance records — retained for the period required under applicable Indian law
When personal data is no longer required, we will securely delete or anonymise it in accordance with our internal data management procedures.
8. Data Security
Sapy International takes the security of your personal data seriously. We implement appropriate technical and organisational measures to protect your information against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:
Secure HTTPS encryption across the entire website Access controls limiting data access to authorised personnel only Secure, reputable third-party hosting infrastructure Regular review of our data handling and security practices
While we take every reasonable precaution to protect your data, please be aware that no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security of data transmitted over the internet. If you believe your data has been compromised or you become aware of any unauthorised use of your information, please contact us immediately at info@sapyinternational.com.
9. Your Rights Under the DPDPA 2023 Under the Digital Personal Data Protection Act, 2023 (DPDPA) of India, you have the following rights in relation to your personal data:
9.1 Right to Access You have the right to request confirmation of whether we hold personal data about you, and to receive a copy of that data along with information about how it is being processed.
9.2 Right to Correction You have the right to request that we correct any inaccurate, incomplete, or outdated personal data we hold about you.
9.3 Right to Erasure You have the right to request that we delete your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent on which processing was based — subject to any overriding legal obligations that require us to retain the data.
9.4 Right to Withdraw Consent Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.
9.5 Right to Grievance Redressal You have the right to have your privacy grievances addressed promptly. If you raise a concern with us, we will respond within a reasonable timeframe.
9.6 Right to Nominate Under the DPDPA 2023, you have the right to nominate another individual to exercise your data rights on your behalf in the event of your death or incapacity. To exercise any of the above rights, please contact us in writing at: Email: info@sapyinternational.com Subject Line: Data Privacy Request — [Your Name] We will respond to all valid data rights requests within 30 days of receipt. We may need to verify your identity before processing your request.
10. Children's Privacy
Our website is intended for use by business professionals, optical retailers, brand representatives, and trade buyers. It is not directed at children under the age of 18. We do not knowingly collect, process, or store personal data from individuals under the age of 18. If you believe that a minor has submitted personal data to us through this website, please contact us immediately at info@sapyinternational.com and we will take prompt steps to delete such data.
11. International Data Transfers
Sapy International is based in India and primarily processes data within India. In limited circumstances — for example, when communicating with international brand principals based outside India — personal data may be transferred to or accessed from countries outside India. Where such transfers occur, we take appropriate steps to ensure that your data receives an adequate level of protection consistent with the requirements of the DPDPA 2023 and applicable Indian data protection standards.
12. Third-Party Links
Our website may contain links to third-party websites, including the websites of our brand partners and industry publications. Sapy International is not responsible for the privacy practices, terms, or content of any third-party website. We encourage you to review the privacy policies of any external websites you visit. The presence of a link to a third-party site on our website does not constitute an endorsement of that site's privacy practices.
13. Changes to This Privacy Policy
Sapy International reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our business practices, applicable law, or data processing activities. Any material changes to this Privacy Policy will be posted on this page with a revised effective date. Where required by law or where changes are significant, we will notify you directly — for example, by email if we hold your contact details.
We encourage you to review this Privacy Policy periodically to remain informed about how we protect your personal data. Your continued use of our website following the posting of changes constitutes your acceptance of the updated Privacy Policy.
14. Grievance Officer
In accordance with the Digital Personal Data Protection Act, 2023, and other applicable Indian regulations, Sapy International has designated a point of contact for all privacy-related grievances: Grievance Contact: Sapy International
Attn: Privacy & Data Protection 3rd Floor, DDA Retail Business Centre, Unit No. 312, Nangal Raya Extention, Karan Market, Block A, Nangal Raya, Janakpuri, New Delhi, Delhi 110046. Email: info@sapyinternational.com
All privacy grievances will be acknowledged within 72 hours and resolved within 30 days of receipt, in accordance with applicable law.
15. Governing Law & Jurisdiction
This Privacy Policy is governed by and shall be construed in accordance with the laws of the Republic of India, including the Digital Personal Data Protection Act, 2023, and the Information Technology Act, 2000 and its amendments. Any disputes arising from or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the competent courts located in New Delhi, India.
1. Who We Are
Sapy International is a New Delhi-based company specialising in the curation and distribution of luxury and semi-luxury international eyewear brands across India. We are the authorised distribution partner for a curated portfolio of international eyewear brands including Italia Independent, Laps, FAOS, Odette Lunettes, and COCO Leni. For all privacy-related queries and data protection matters, please contact us at:
Data Controller: Sapy International
3rd Floor, DDA Retail Business Centre, Unit No. 312, Nangal Raya Extention, Karan Market, Block A, Nangal Raya, Janakpuri, New Delhi, Delhi 110046.
Email: info@sapyinternational.com
Phone: +91 80762 24831 2. Information We Collect
We collect personal information only when it is necessary for legitimate business purposes. The types of personal information we may collect include:
2.1 Information You Provide Directly When you interact with our website — by submitting an enquiry form, completing a retail partner application, or contacting us directly — we may collect the following:
Full name
Business or store name
Email address
Phone number
Business address including city, state, and PIN code
Type of business or store
Annual eyewear turnover range (where voluntarily provided)
Brands currently stocked
Brands of interest from our portfolio
How you heard about us
Any additional information you choose to include in the message or comments field
2.2 Information Collected Automatically When you visit our website, certain technical information is collected automatically through cookies and analytics tools, including:
IP address and approximate geographic location Browser type and version Device type and operating system Pages visited and time spent on each page Referring website or source Date and time of visit Session duration and navigation path
2.3 Information from Third Parties
We may receive information about you from third parties in limited circumstances, such as when a retail partner or brand principal refers you to us or provides your contact details in connection with a business enquiry.
3. How We Use Your Information
We use the personal information we collect for the following purposes:
3.1 Responding to Enquiries To review, process, and respond to enquiries submitted through our contact or enquiry forms, including questions about our brand portfolio, distribution services, or retail partnership opportunities.
3.2 Retail Partner Applications To assess and process applications from optical retailers, boutiques, and multi-brand stores seeking to become Sapy International retail partners. This includes reviewing store details, location, and brand preferences to determine suitability.
3.3 Business Communications To send you relevant information about our brands, new collection launches, trade show participation, and other business updates — but only where you have provided your consent or where we have a legitimate business interest in doing so.
3.4 Marketing Communications With your consent, to send you marketing communications including newsletters, brand announcements, exhibition invitations, and promotional updates. You may withdraw your consent to marketing communications at any time by clicking "Unsubscribe" in any email we send or by contacting us directly.
3.5 Website Improvement To analyse website usage patterns through anonymised analytics data, allowing us to improve the structure, content, and user experience of our website.
3.6 Legal Compliance To comply with applicable laws, regulations, and legal obligations in India, including the Digital Personal Data Protection Act, 2023, and to respond to lawful requests from regulatory or government authorities.
3.7 Fraud Prevention & Security To protect the integrity of our website and business operations, detect and prevent fraudulent enquiries or applications, and maintain the security of our systems and data.
4. Legal Basis for Processing Under the Digital Personal Data Protection Act, 2023 (DPDPA), we process your personal data on the following legal bases:
Consent — where you have given us clear consent to process your data for a specific purpose, such as receiving marketing communications Contractual Necessity — where processing is necessary to fulfil a business arrangement or pre-contractual steps you have requested, such as a retail partner application Legitimate Interests — where processing is necessary for our legitimate business interests, such as responding to general enquiries, improving our website, or maintaining business records, provided those interests are not overridden by your rights Legal Obligation — where processing is required to comply with a legal or regulatory obligation applicable to Sapy International under Indian law
5. How We Share Your Information
Sapy International does not sell, rent, or trade your personal information to any third party. We may share your information in the following limited and controlled circumstances:
5.1 Brand Principals
Where you enquire about a specific brand in our portfolio, we may share relevant details of your enquiry with the brand principal or manufacturer concerned, strictly for the purpose of facilitating your request. This will only be done where it is necessary and appropriate.
5.2 Service Providers
We work with trusted third-party service providers who assist us in operating our website and running our business — including web hosting providers, email delivery platforms, CRM software providers, and analytics services. These providers are contractually bound to process your data only as instructed by us and to maintain appropriate confidentiality and security standards.
5.3 Legal & Regulatory Authorities
We may disclose your personal information to law enforcement agencies, regulatory bodies, or other government authorities where we are required to do so by law, court order, or other legal process applicable in India.
5.4 Business Transfers
In the event of a merger, acquisition, restructuring, or sale of all or part of Sapy International's business, your personal data may be transferred to the relevant successor entity, subject to the same privacy protections described in this policy. We will never share your data with third parties for their own independent marketing or commercial purposes without your explicit consent.
6. Cookies & Tracking Technologies
Our website uses cookies and similar tracking technologies to enhance your browsing experience and gather analytical insights. Please refer to our Cookie Policy for full details on the types of cookies we use, their purpose, and how you can manage your cookie preferences. In summary, we use the following types of cookies:
Strictly Necessary Cookies — essential for the website to function and cannot be disabled
Analytics Cookies — help us understand how visitors use our website (anonymised data via Google Analytics)
Functional Cookies — remember your preferences for a more personalised experience
You can manage and disable non-essential cookies through your browser settings or via the cookie consent tool on our website at any time.
7. Data Retention
We retain your personal information only for as long as is necessary to fulfil the purposes for which it was collected, unless a longer retention period is required or permitted by applicable Indian law. Our general data retention guidelines are as follows:
Enquiry and contact form submissions — retained for up to 24 months from the date of submission, or longer if an active business relationship develops Retail partner applications — retained for the duration of the partnership, and for up to 36 months following the end of the relationship Marketing communication records — retained until you withdraw consent or unsubscribe Website analytics data — retained in anonymised, aggregated form for up to 26 months (standard Google Analytics retention) Legal and compliance records — retained for the period required under applicable Indian law
When personal data is no longer required, we will securely delete or anonymise it in accordance with our internal data management procedures.
8. Data Security
Sapy International takes the security of your personal data seriously. We implement appropriate technical and organisational measures to protect your information against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:
Secure HTTPS encryption across the entire website Access controls limiting data access to authorised personnel only Secure, reputable third-party hosting infrastructure Regular review of our data handling and security practices
While we take every reasonable precaution to protect your data, please be aware that no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security of data transmitted over the internet. If you believe your data has been compromised or you become aware of any unauthorised use of your information, please contact us immediately at info@sapyinternational.com.
9. Your Rights Under the DPDPA 2023 Under the Digital Personal Data Protection Act, 2023 (DPDPA) of India, you have the following rights in relation to your personal data:
9.1 Right to Access You have the right to request confirmation of whether we hold personal data about you, and to receive a copy of that data along with information about how it is being processed.
9.2 Right to Correction You have the right to request that we correct any inaccurate, incomplete, or outdated personal data we hold about you.
9.3 Right to Erasure You have the right to request that we delete your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent on which processing was based — subject to any overriding legal obligations that require us to retain the data.
9.4 Right to Withdraw Consent Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.
9.5 Right to Grievance Redressal You have the right to have your privacy grievances addressed promptly. If you raise a concern with us, we will respond within a reasonable timeframe.
9.6 Right to Nominate Under the DPDPA 2023, you have the right to nominate another individual to exercise your data rights on your behalf in the event of your death or incapacity. To exercise any of the above rights, please contact us in writing at: Email: info@sapyinternational.com Subject Line: Data Privacy Request — [Your Name] We will respond to all valid data rights requests within 30 days of receipt. We may need to verify your identity before processing your request.
10. Children's Privacy
Our website is intended for use by business professionals, optical retailers, brand representatives, and trade buyers. It is not directed at children under the age of 18. We do not knowingly collect, process, or store personal data from individuals under the age of 18. If you believe that a minor has submitted personal data to us through this website, please contact us immediately at info@sapyinternational.com and we will take prompt steps to delete such data.
11. International Data Transfers
Sapy International is based in India and primarily processes data within India. In limited circumstances — for example, when communicating with international brand principals based outside India — personal data may be transferred to or accessed from countries outside India. Where such transfers occur, we take appropriate steps to ensure that your data receives an adequate level of protection consistent with the requirements of the DPDPA 2023 and applicable Indian data protection standards.
12. Third-Party Links
Our website may contain links to third-party websites, including the websites of our brand partners and industry publications. Sapy International is not responsible for the privacy practices, terms, or content of any third-party website. We encourage you to review the privacy policies of any external websites you visit. The presence of a link to a third-party site on our website does not constitute an endorsement of that site's privacy practices.
13. Changes to This Privacy Policy
Sapy International reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our business practices, applicable law, or data processing activities. Any material changes to this Privacy Policy will be posted on this page with a revised effective date. Where required by law or where changes are significant, we will notify you directly — for example, by email if we hold your contact details.
We encourage you to review this Privacy Policy periodically to remain informed about how we protect your personal data. Your continued use of our website following the posting of changes constitutes your acceptance of the updated Privacy Policy.
14. Grievance Officer
In accordance with the Digital Personal Data Protection Act, 2023, and other applicable Indian regulations, Sapy International has designated a point of contact for all privacy-related grievances: Grievance Contact: Sapy International
Attn: Privacy & Data Protection 3rd Floor, DDA Retail Business Centre, Unit No. 312, Nangal Raya Extention, Karan Market, Block A, Nangal Raya, Janakpuri, New Delhi, Delhi 110046. Email: info@sapyinternational.com
All privacy grievances will be acknowledged within 72 hours and resolved within 30 days of receipt, in accordance with applicable law.
15. Governing Law & Jurisdiction
This Privacy Policy is governed by and shall be construed in accordance with the laws of the Republic of India, including the Digital Personal Data Protection Act, 2023, and the Information Technology Act, 2000 and its amendments. Any disputes arising from or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the competent courts located in New Delhi, India.