Suffle Online

Operated by Naucera Travel Private Limited

1. Purpose and Scope

This Policy explains how users may request deletion of their Suffle Online account and how Suffle handles deletion, de-identification, retention, archival and lawful preservation of data after an account-deletion request.

It applies to customer and seller accounts and to information associated with those accounts, including marketplace orders, payments, documents, connected services, email-related records, AI/tracking records, reminders, subscriptions, referrals and support records.

This Policy should be read with the Privacy Policy, Data Security & Protection Policy, Document Policy, Connected Apps & Accounts Policy, Gmail / Email Data Policy and Grievance Redressal Policy.

2. Company and Contact

Suffle Online is operated by Naucera Travel Private Limited.

Website: www.suffleonline.com

General Support / Grievance Email: info@flyshoppy.com

Grievance Officer: Mr. Roopal Jain, Managing Director

Grievance Officer Mobile: 9707669981

Grievance Officer Email: info@flyshoppy.com

Address: 707, N. T. Road, Nalbari-781435 (Assam), India.

3. Account Deletion Principle

Suffle intends to provide an appropriate mechanism for an authenticated user to request deletion of their account and eligible personal data, subject to applicable law, technical limitations and lawful retention requirements.

Deletion is different from simply logging out, uninstalling an application, disconnecting a service or deleting a local browser record.

4. Who May Request Deletion

An authenticated account holder may request deletion of their own Suffle account.

An authorised representative may submit a request where appropriate, subject to reasonable verification of authority.

Suffle may require identity or account verification before executing a deletion request in order to prevent unauthorised account deletion.

5. How to Request Account Deletion

Where an in-account deletion control is provided, the user may initiate deletion through the account settings or designated account-management area.

Users may also contact Suffle support or the grievance channel to request deletion where an in-account mechanism is unavailable.

Requests should identify the relevant account without including passwords, OTPs, UPI PINs, CVV, ATM PINs or banking passwords.

6. Authentication and Verification

Suffle may require reasonable authentication or verification before processing a deletion request.

Verification should be proportionate to the risk and should not require disclosure of unnecessary sensitive information.

A deletion request made by an unauthorised person may be rejected or paused.

7. Deletion Request Status

The central account system may use statuses such as Requested, Verification Required, Under Review, Scheduled, Processing, Completed, Partially Completed, Rejected or Cancelled.

Status information should reflect actual backend processing and must not be marked Completed merely because a request was submitted.

8. Central Account Deletion System

Suffle should use one central Account Deletion and Data Retention system rather than separate deletion workflows for marketplace, seller, travel, documents, subscriptions or other modules.

The central system should coordinate eligible deletion, retention exceptions, connected-service disconnection, access revocation and audit records.

9. What May Be Deleted

Subject to applicable law and retention requirements, Suffle may delete or de-identify eligible account profile information, preferences, saved content, eligible documents, reminders, non-required tracking records and other personal data that no longer needs to be retained.

The exact data eligible for deletion depends on the purpose, system architecture, legal requirements and whether the data is necessary for a transaction, dispute, security or other lawful purpose.

10. What May Need to Be Retained

Suffle may retain information where necessary to comply with legal obligations, maintain financial/accounting records, complete or document transactions, resolve disputes, prevent fraud and abuse, protect security, enforce agreements or establish/exercise/defend legal claims.

Retention does not mean that Suffle may use retained information for unrelated purposes without an applicable lawful basis.

11. Completed Marketplace Orders

Deleting an account does not necessarily erase records of completed marketplace orders that Suffle is required or reasonably permitted to retain for financial, tax, accounting, dispute, fraud-prevention, seller-settlement or legal purposes.

Where a record must be retained, Suffle should restrict its use to the applicable lawful purpose and retain it only for the necessary period.

12. Pending Orders

If an account has pending orders, returns, refunds, disputes or other active transactions, Suffle may need to retain relevant information until the transaction or dispute is completed and applicable retention requirements are satisfied.

Account deletion should not be represented as cancelling a transaction unless the applicable cancellation process has actually been completed.

13. Payments and Financial Records

Payment transaction records may need to be retained for reconciliation, accounting, refunds, disputes, chargebacks, fraud prevention and legal obligations.

Marketplace payment records and WhatsApp software subscription payment records are separate ledgers and may have separate retention requirements.

Suffle must not retain prohibited payment credentials such as UPI PINs, CVV, ATM PINs or banking passwords merely because an account is deleted.

14. Refunds, Returns and Disputes

Where a refund, return, replacement, chargeback, grievance or dispute is open, relevant records may need to be retained until the matter is resolved and the applicable retention period has passed.

Deleting the account does not automatically eliminate a lawful claim or obligation.

15. Seller Records

Seller accounts may have additional records relating to verification, GST/PAN or other compliance documents, products, orders, settlements, commissions, returns, customer disputes and legal obligations.

Some seller records may need to be retained after account closure for compliance, financial, dispute, fraud-prevention or legal purposes.

16. Seller Compliance Documents

Private seller compliance documents should remain access-controlled after account closure if they must be retained.

Where the retention purpose expires, eligible documents should be deleted or securely disposed of according to the applicable retention schedule.

17. Customer Documents

Customer-uploaded documents may be deleted where eligible after account deletion.

Documents necessary for an ongoing transaction, dispute, legal obligation, security investigation or other lawful purpose may be retained for the applicable period.

Customer customization files should not be retained indefinitely merely because they were once uploaded.

18. Connected Apps and Accounts

Account deletion should revoke or disable Suffle's access to connected services according to the applicable connection architecture.

Where the user separately disconnects a service, future access should stop according to the Connected Apps & Accounts Policy.

Previously imported records may remain subject to the applicable retention rules.

19. Gmail and Email Data

Deletion of a Suffle account should stop Suffle's ongoing account-based access to connected email services according to the authorised connection state.

Eligible imported email data and attachments should be deleted or de-identified where applicable, subject to lawful retention requirements.

Email processing and retention are additionally governed by the Gmail / Email Data Policy.

20. AI and Automated Processing Records

AI prompts, outputs, tracking records, automated-processing metadata or related records may be deleted or de-identified where eligible.

Records required for security, fraud prevention, dispute resolution, legal compliance or audit may be retained for the applicable purpose.

AI systems must not continue accessing a deleted user's private data merely because an old model/session retains technical context.

21. Tracking and Reminder Records

Eligible tracking records, reminders and associated personal data may be deleted or de-identified after account deletion.

Records required to document transactions, disputes, security events or legal obligations may be retained as permitted by applicable law.

22. Referral and Rewards Records

Referral and rewards records may be retained where necessary to prevent fraud, reconcile benefits, resolve disputes or meet legal/accounting requirements.

Unused promotional benefits may be cancelled when an account is deleted unless applicable programme rules or law provide otherwise.

23. Subscription Records

WhatsApp software subscription status and payment records may be retained for financial, contractual, dispute and compliance purposes.

Account deletion does not necessarily erase historical subscription transactions that Suffle is required to retain.

24. Email Communication Records

Suffle may retain essential communication records, support messages, delivery logs and legal notices for service, security, dispute and compliance purposes.

Promotional suppression records may also need to be retained so that a valid opt-out continues to be respected.

25. Grievance and Support Records

Support tickets, grievance records, complaints, investigation evidence and resolution history may be retained for support, accountability, dispute resolution, security and legal purposes.

Access to retained grievance information should remain restricted.

26. Security and Fraud Records

Suffle may retain security logs, fraud indicators, abuse records and related evidence where necessary to protect users, investigate incidents, prevent repeated abuse or comply with law.

Such retention should be limited to the legitimate security or legal purpose.

27. Backups and Disaster Recovery

Deleted data may persist temporarily in encrypted backups or disaster-recovery systems until the relevant backup cycle expires or the data is securely overwritten according to Suffle's retention architecture.

Backup copies should not be used to restore intentionally deleted personal data except where required for disaster recovery, legal preservation or another legitimate system purpose.

Production deletion and backup expiry should be managed through documented retention controls.

28. Search Indexes, Caches and Derived Data

Deletion workflows should address eligible search indexes, caches, derived records and other copies of personal data under Suffle's control where technically applicable.

Temporary technical copies may persist for a limited period where necessary to complete secure deletion and system operations.

29. De-identification and Aggregation

Where deletion of a record is not required or practical because information has been lawfully transformed into genuinely non-personal aggregated information, Suffle may retain such information for legitimate analytics, reporting, security or service-improvement purposes.

De-identification should be implemented so that the information is not reasonably used to identify the individual in the context for which it is retained.

30. Legal Holds and Preservation

Where Suffle reasonably needs to preserve information for a legal claim, dispute, regulatory request, investigation, fraud inquiry or other lawful preservation requirement, deletion of the affected information may be paused.

Access to preserved information should be restricted and the preservation should end when the lawful need expires.

31. Account Closure vs Data Deletion

Closing, suspending or deactivating an account is not necessarily the same as deleting all associated data.

Suffle may first disable access and then process eligible deletion and retention exceptions according to this Policy.

32. Consequences of Account Deletion

After deletion, the user may lose access to account history, saved preferences, documents, wishlist, reminders, tracking records, seller tools, subscription features and other account-linked functionality.

Data that is lawfully retained may no longer be accessible through the deleted account even though it remains retained in restricted systems.

33. Re-Registration After Deletion

A person may create a new Suffle account if permitted by the then-current registration rules.

A new account does not automatically restore information from a deleted account.

Fraud, legal restrictions or other valid reasons may prevent or limit re-registration.

34. Third-Party Data

Account deletion from Suffle does not automatically delete information held independently by payment providers, sellers, couriers, connected service providers, email providers or other third parties.

Where appropriate, Suffle may provide information or instructions concerning a third party's own deletion process, but cannot guarantee deletion from systems it does not control.

35. Seller and Customer Access After Deletion

Once an account is deleted, access credentials and ordinary account access should be revoked.

Historical transaction records may continue to show limited information required for seller/customer transaction records, accounting, disputes or legal purposes, with appropriate access restrictions.

36. Data Security During Deletion

Deletion operations should use appropriate authentication, authorisation, logging and secure-processing controls.

Deletion requests should be protected against unauthorised initiation or manipulation.

Sensitive data awaiting deletion should remain protected under the Data Security & Protection Policy.

37. Failed or Partial Deletion

If a deletion operation cannot be fully completed because of a technical failure, legal hold, third-party dependency or other valid reason, Suffle should record the exception and complete eligible deletion when reasonably possible.

Users should not be told that all data has been permanently deleted when the system retains lawful exceptions.

38. Verification of Completion

Where Suffle provides a deletion confirmation, it should reflect the actual completion status of the eligible deletion workflow.

A confirmation should not imply deletion from independent third-party systems unless Suffle has actually verified such deletion.

39. Data Retention Schedule

Suffle should maintain a central retention schedule identifying relevant data categories, purposes, retention periods or criteria, deletion/de-identification method, legal basis where applicable and responsible system.

Retention periods should be based on actual legal, contractual, operational, security and business requirements rather than indefinite default retention.

40. Privacy Rights and Requests

Users may have rights relating to their personal data under applicable law, including rights and mechanisms described in the Privacy Policy.

Deletion requests should be assessed against the applicable legal framework, the user's identity/authority and relevant retention exceptions.

41. Grievance and Escalation

If a user believes a deletion request was improperly rejected, delayed or incompletely handled, the user may raise a grievance through Suffle's Grievance Redressal Policy.

The grievance should reference the deletion request where possible so that Suffle can review the actual processing history.

42. No Unauthorised Recovery

Users must not attempt to recover, access or reconstruct deleted or restricted account data through technical means, scraping, security bypasses or unauthorised access.

Any recovery feature offered by Suffle will be governed by the actual account workflow and applicable retention state.

43. Relationship with Other Policies

This Policy should be read with the Terms & Conditions, Privacy Policy, Data Security & Protection Policy, Document Policy, Connected Apps & Accounts Policy, Gmail / Email Data Policy, AI Tracking / Automated Processing Notice, Suffle AI Terms, Payment Information Policy, Subscription Policy and Grievance Redressal Policy.

44. Policy Updates

Suffle may update this Policy as its data architecture, deletion mechanisms, retention requirements, legal obligations or platform features change.

The current effective version should be maintained through Suffle's central legal/policy management system.

45. Legal and Implementation Note

This Policy describes Suffle's intended account-deletion and data-retention framework. Actual deletion and retention periods must be configured according to the data category, applicable Indian law, contractual obligations, accounting requirements, security needs and the live technical architecture.

Applicable data-protection rights and obligations should be implemented consistently with the Digital Personal Data Protection Act, 2023, applicable rules and other laws in force at the relevant time.

This Policy should be reviewed by qualified Indian privacy, e-commerce and technology counsel before publication and periodically thereafter.

Critical Account Deletion & Retention Rules

·       Use one central Account Deletion and Data Retention system; do not create separate deletion databases or workflows for individual Suffle modules.

·       Account deletion must be authenticated and traceable to prevent unauthorised deletion.

·       Deleting an account does not necessarily delete transaction, payment, tax, accounting, dispute, security, fraud-prevention or legally required records.

·       Customer customization files and eligible personal documents should be deleted when no longer required, subject to lawful retention exceptions.

·       Connected-service access should be revoked/disabled when the account is deleted; third-party systems are not automatically deleted.

·       Backups, caches and technical copies may persist temporarily according to documented deletion cycles.

·       Suffle must not claim that all data has been deleted when lawful or technical retention exceptions remain.

·       Retention should be purpose-based and time-limited, with a central retention schedule and auditable deletion/de-identification controls.

Account Deletion Contact

Support / Grievance Email: info@flyshoppy.com

Grievance Officer: Mr. Roopal Jain, Managing Director

Mobile: 9707669981

Address: 707, N. T. Road, Nalbari-781435 (Assam), India.

Related Suffle Policies

·       Terms & Conditions

·       Privacy Policy

·       Data Security & Protection Policy

·       Document Policy

·       Connected Apps & Accounts Policy

·       Gmail / Email Data Policy

·       AI Tracking / Automated Processing Notice

·       Suffle AI Terms

·       Payment Information Policy

·       Subscription Policy

·       Grievance Redressal Policy

Retention Governance Requirement

The production system should maintain a central data-retention schedule and deletion orchestration layer covering account data, documents, orders, payments, communications, connected-service data, AI/tracking records, seller records, support/grievance records, backups and derived data. Each retained category should have a documented purpose, retention criterion, access control and deletion/de-identification action.