DRAFT — OWNER REVIEW REQUIRED

Commercial Privacy & Data Protection Policy

Last Updated: October 2026 | Governing Entity: SPARPULSE LLP (Pune, Maharashtra, India)

1. Introduction & Data Controller

SPARPULSE LLP (“we”, “our”, or “us”), a limited liability partnership registered under the laws of India with LLPIN: ACO-3390, having its registered office at 41 Evoke, C-301, Adarsh Nagar, Ravet, Pune 412101, Maharashtra, India, acts as the Data Fiduciary/Controller for personal and commercial information submitted via this website (https://sparllp.com/).

2. Information We Collect

Because our website operates strictly as a Business-to-Business (B2B) trade platform, we collect information submitted voluntarily by corporate representatives, importers, wholesalers, and procurement agents:

  • Commercial Identity Data: Full name, corporate title, company/brand name, business address, and registered country of incorporation.
  • Contact Information: Corporate email address, telephone/WhatsApp contact numbers.
  • Procurement Requirements: Target product categories, volume estimates, desired Incoterms, destination seaports, and technical product specifications.
  • Technical Audit Data: IP address, browser type, referral URLs, and standard server logs necessary for spam detection and website security.

3. Purpose & Legal Basis of Processing

We process your data strictly for legitimate commercial interests and pre-contractual steps:

  • Assessing commercial feasibility and issuing formal Requests for Quotation (RFQs).
  • Coordinating physical pre-production samples and counter-sample courier dispatches.
  • Communicating trade milestones, production status, and pre-shipment inspection schedules.
  • Fulfilling statutory export reporting, customs documentation, and indirect tax records under Indian foreign trade regulations.

4. Information Sharing & Third Parties

SPARPULSE LLP does not sell, rent, or trade buyer contact lists to marketing brokers. Information is shared strictly on a need-to-know basis with:

  • Manufacturing Partners: Technical parameters and packaging specs (excluding confidential financial terms) required to produce samples or fulfill orders.
  • Inspection Agencies: Technical criteria provided to independent testing labs (e.g., SGS, Intertek) for quality audit verification.
  • Logistics & Customs Providers: Commercial invoices and packing manifests supplied to customs brokers and maritime shipping carriers.
  • Statutory Authorities: Indian customs (DGFT, ICEGATE), tax authorities (GST), or judicial bodies when legally mandated.

5. Data Retention & Security

Commercial enquiry details are retained as long as required to service trade relationships and comply with Indian statutory accounting and foreign trade recordkeeping mandates (typically 7 years). We employ TLS encryption for data in transit, strict access control, and anti-spam safeguards.

6. Your Rights & Sourcing Desk Contact

You may request access to, correction of, or deletion of your commercial contact details by writing to our compliance officer at:

Data Privacy Officer / Management Desk:
SPARPULSE LLP
Email: rohit@sparllp.com
Corporate Office: 41 Evoke, C-301, Adarsh Nagar, Ravet, Pune 412101, Maharashtra, India.