This version is drafted to align with the Digital Personal Data Protection Act, 2023, the IT (Reasonable Security Practices and Sensitive Personal Data or Information) Rules, 2011, and the IT Rules, 2021.

1. Introduction

This Cookie Policy explains how Panjabipassions (“Panjabipassions”, “we”, “our”, “us”, or the “Platform”) uses cookies and similar tracking technologies (including web beacons, pixels, local storage, and SDKs) when you visit or use our website and related services (the “Platform”). We process personal data in accordance with the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and applicable rules made thereunder, and, to the extent still applicable, the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”).

Except for cookies that are strictly necessary for the Platform to function, we will only set cookies on your device after you have given clear, specific, and affirmative consent through our cookie preference banner/tool. You may withdraw this consent at any time, as easily as you gave it, through the “Cookie Preferences” link in our website footer.

2. What Are Cookies?

Cookies are small text files placed on your computer, smartphone, tablet, or other device when you visit a website. They help websites function, remember your preferences, improve your browsing experience, and provide usage analytics.

Some cookies collect information that, on its own or combined with other information, can identify you (for example, an account or device identifier) and therefore qualify as “personal data” under the DPDP Act. Where this is the case, this Policy and our Privacy Policy both apply.

3. Categories of Cookies We Use

A. Strictly Necessary / Essential Cookies

These enable core functions and cannot be switched off, as they do not require consent under applicable law:

  • Secure login and session authentication
  • Shopping cart and checkout functionality (where applicable)
  • Fraud prevention and platform security
  • Load balancing and session management

You can block these through your browser, but doing so is likely to break core parts of the Platform.

B. Performance & Analytics Cookies (consent required)

These help us understand aggregate visitor behaviour: visit counts, pages viewed, time on page, navigation paths, and error reports. We use this to improve the Platform. These are only set after you accept them in our cookie tool.

C. Functional Cookies (consent required)

These remember your preferences and settings, such as language, region, recently viewed profiles or products, and saved/wishlist items. They enhance your experience but are not essential to core operation.

D. Marketing & Advertising Cookies (explicit opt-in consent required)

Where you give explicit, opt-in consent, these cookies may be used to show relevant advertisements, measure campaign effectiveness, build behavioural/interest profiles, and limit repeat ad views. These are set by Panjabipassions or by advertising partners acting as data processors/fiduciaries under written agreements with us. This category is switched off by default and will remain off unless you affirmatively opt in.

4. Cookie Inventory

The table below is illustrative; the live, authoritative list is maintained in our cookie consent tool and updates automatically as vendors change.

Cookie Name Category Purpose Set By Duration session_id Essential Maintains your logged-in session and cart/checkout state (1st party) Session csrf_token Essential Prevents cross-site request forgery / fraud (1st party) Session _ga / _gid Analytics Distinguishes users and sessions for site- usage statistics Google Analytics (3rd party) Up to 24 months lang_pref Functional Remembers your chosen language/region Panjabipassions (1st party) 12 months Cookie Name Category Purpose Set By Duration recent_views Functional Remembers recently viewed profiles/products (1st party) 3 months ad_id / fbp Marketing Builds an advertising profile and measures campaign performance Ad partner (3rd party) Up to 12 months

5. Consent, and How to Withdraw It

  • On your first visit, a cookie banner will ask you to accept, reject, or customise non-essential

cookies by category.

  • Marketing/advertising cookies are opt-in only and are never pre-ticked.
  • You can change or withdraw your preferences at any time via “Cookie Preferences” in the

footer, or through your browser settings.

  • Withdrawing consent does not affect the lawfulness of processing carried out before

withdrawal, and will not affect your ability to use the essential features of the Platform.

  • If you are under 18, the DPDP Act requires verifiable consent from a parent or lawful guardian

before we process your personal data, including through non-essential cookies. The Platform is not intended for use by individuals under 18 in any event.

6. Third-Party Cookies and Data Sharing

Certain trusted third parties may place cookies on your device through our Platform, including:

  • Analytics providers (e.g., web analytics services)
  • Payment gateway providers, for processing transactions
  • Social media platforms, where you interact with embedded content
  • Advertising and ad-measurement partners
  • Customer support and chat tools

These third parties act as our data processors under written contracts requiring them to process personal data only on our instructions and to apply appropriate security safeguards, or, where they act independently, are subject to their own privacy and cookie policies, which we encourage you to review. Panjabipassions does not control cookies set independently by third parties.

7. Cross-Border Transfer of Information

Some of our third-party service providers may process cookie-derived data outside India. Consistent with Section 16 of the DPDP Act, we do not transfer personal data to any country or territory that the Central Government has restricted by notification. Where data is transferred internationally, we require contractual safeguards from our processors to protect it to a standard consistent with Indian law.

8. Data Retention

We retain cookie-derived personal data only for as long as necessary for the purpose for which it was collected, or as required by law, after which it is deleted or anonymised. Indicative retention periods are set out in the cookie table in Section 4; category-level defaults are: session cookies (until browser close), analytics (up to 24 months), functional (up to 12 months), and marketing (up to 12 months, or until you withdraw consent, whichever is earlier).

9. Your Rights as a Data Principal

Under the DPDP Act, you have the right to:

  • Obtain a summary of the personal data we hold about you and the processing activities carried

out on it (right to access).

  • Request correction, completion, or updating of your personal data (right to correction).
  • Request erasure of your personal data where it is no longer necessary for the purpose collected,

subject to any legal retention requirements (right to erasure).

  • Withdraw consent at any time, as easily as you gave it.
  • Nominate another individual to exercise these rights on your behalf in the event of death or

incapacity.

  • Register a grievance with us, and, if unresolved, approach the Data Protection Board of India.

To exercise any of these rights, contact our Grievance Officer using the details in Section 11.

10. Managing Cookies Through Your Browser

Independently of our cookie tool, most browsers let you view, delete, block all cookies, block specific cookies, or receive alerts before cookies are stored. Disabling certain cookies may affect functionality, including login, checkout, and personalisation. We do not currently respond to “Do Not Track” browser signals, as no common industry standard exists for interpreting them; your choices in our cookie preference tool remain authoritative.

11. Grievance Officer / Contact Us

In accordance with the DPDP Act and the Information Technology Rules, 2021, we have appointed a Grievance Officer to address your queries, complaints, or requests concerning this Policy or your personal data:

Grievance Officer: Mr. Sandip Malakar Email: support@panjabipassions.com Postal Address: 150, Haltu School Lane, Kolkata – 700078 Response Timeline: Acknowledgement within 24 hours; resolution ordinarily within 15 days.

If you are not satisfied with our response, you may file a complaint with the Data Protection Board of India through the mechanism it prescribes.

12. Updates to This Cookie Policy

We may revise this Cookie Policy periodically to reflect changes in our practices, technology, vendors, or legal requirements. The updated version will be published on the Platform with a revised “Last Updated” date. Where changes are material — for example, introducing a new category of non-essential cookie — we will seek your fresh consent before applying them. Continued use of the Platform after non-material changes constitutes acknowledgement of the revised Policy.