MAKELY
The Garment Manufacturing Aggregator

Privacy Policy

Effective Date: 10 October 2025  |  Last Updated: 21 February 2026

Terms & Conditions Privacy Policy

Table of Contents

  1. Introduction
  2. Information We Collect
  3. How We Use Your Information
  4. Legal Basis for Processing
  5. Data Sharing & Disclosure
  6. Data Retention
  7. Data Security
  8. Your Rights
  9. Cookies & Tracking Technologies
  10. Third-Party Services
  11. Children’s Privacy
  12. Changes to This Policy
  13. Grievance Officer
  14. Contact Information
  15. Governing Law & Jurisdiction

1. Introduction

This Privacy Policy (“Policy”) describes how Makely (“we”, “us”, “our”), the garment manufacturing aggregator platform with its registered office at FE-369, Sector-3, Salt Lake, Kolkata-700106, West Bengal, India, collects, uses, stores, shares, and protects the personal and business information of Users (“You”, “Your”) who access or use the Makely mobile application, website, and associated services (collectively, the “Platform”).

This Policy applies to all Users of the Platform, including Makers (Job Workers) and Production Houses (Brand Owners). By accessing or using the Platform, You consent to the collection, use, and processing of Your information as described in this Policy.

This Policy is published in compliance with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the Digital Personal Data Protection Act, 2023, as applicable.

2. Information We Collect

We collect the following categories of information from Users:

2.1 Personal Information

Full name, phone number, email address, date of birth, gender, photograph, identity documents (PAN, Aadhaar where permitted by law), residential and business addresses.

2.2 Business Information

Business name, type of entity, Goods and Services Tax Identification Number (GSTIN), business registration details, workshop or factory address, production capacity, equipment details, previous work experience, and portfolio information.

2.3 Financial Information

Bank account details (account number, IFSC code, account holder name), UPI identifiers, payment history, transaction records, invoices, service fee records, and tax-related information (TDS, GST filings).

2.4 Device and Technical Information

Device model, manufacturer, operating system and version, unique device identifiers (IMEI, Android ID, Advertising ID), screen resolution, Internet Protocol (IP) address, browser type and version, mobile network information, application version, and language preferences.

2.5 Location Data

Precise and approximate geolocation data derived from GPS, Wi-Fi, cellular network triangulation, and IP address geolocation. Location data may be collected when the application is in active use.

2.6 Usage Data

Application usage patterns, pages and screens viewed, features used, time spent on the Platform, clickstream data, search queries, navigation paths, interaction with notifications, session duration and frequency, referral sources, and crash logs.

2.7 Transaction Data

Bid submissions, order details, production requirements, sample submissions and approvals, material dispatch records, delivery records, payment transactions, escrow records, alteration requests, quality assessments, and dispute records.

2.8 Communication Data

Messages exchanged between Users through the Platform, customer support interactions, feedback and reviews, complaint records, and any other communications conducted through or in connection with the Platform.

2.9 Documents and Media

Photographs of products, samples, materials, counting challans, delivery receipts, quality inspection images, profile photographs, business documents, and any other files or media uploaded to the Platform.

3. How We Use Your Information

We use the information collected for the following purposes:

3.1 Platform Operations & Service Delivery

To provide, operate, and maintain the Platform and its features; to process registrations and verify User identity; to facilitate bidding, order matching, communication, logistics, and payment settlement between Makers and Production Houses; to operate the escrow payment system; and to provide customer support.

3.2 Business Development

To conduct market analysis and identify business opportunities; to expand Platform services and geographic reach; to develop new features, products, and service offerings; to create aggregated industry reports, insights, and benchmarks; to improve matching and recommendation algorithms; to perform competitive analysis; and to inform strategic business planning and decision-making.

3.3 Product Improvement

To analyse usage patterns and User behaviour; to identify, diagnose, and resolve software bugs and technical issues; to optimise Platform performance, speed, and reliability; to conduct A/B testing and user research studies; to prioritise feature development based on usage data; to improve user interface and user experience design; and to enhance algorithmic accuracy and efficiency.

3.4 User Experience Improvement

To personalise the User experience through customised recommendations, suggestions, and content; to deliver targeted and contextually relevant notifications; to optimise communication preferences and timing; to tailor the Platform interface to individual User patterns; and to enhance overall service quality and User satisfaction.

3.5 Analytics & Profiling

To create User profiles based on collected data; to generate behavioural analytics and usage statistics; to produce aggregated and de-identified data sets for research and reporting; to build predictive models for service optimisation; and to measure the effectiveness of Platform features and services.

3.6 Fraud Prevention & Security

To detect, prevent, and investigate fraudulent, unauthorised, or illegal activities; to monitor for Terms of Service violations; to verify User identity and prevent impersonation; to protect the security and integrity of the Platform; and to enforce our Terms & Conditions.

3.7 Legal & Regulatory Compliance

To comply with applicable laws, regulations, legal processes, and government requests; to respond to subpoenas, court orders, or legal proceedings; to enforce our agreements, policies, and Terms & Conditions; to protect Makely’s rights, property, and safety; and to maintain records as required by Indian law.

3.8 Communications

To send transactional messages (order confirmations, payment receipts, delivery updates); to deliver service announcements and Platform updates; to send promotional offers, marketing communications, and surveys; to provide customer support responses; and to facilitate inter-User communications through the Platform.

3.9 Dispute Resolution

To investigate and resolve disputes between Users; to provide evidence and records for mediation and arbitration proceedings; and to support legal proceedings where necessary.

4. Legal Basis for Processing

We process Your information on the following legal bases:

  • Consent: By using the Platform and accepting our Terms & Conditions, You provide explicit consent for the collection and use of Your data as described in this Policy, in accordance with the Information Technology Act, 2000, and the Digital Personal Data Protection Act, 2023.
  • Contractual Necessity: Processing is necessary to perform our contractual obligations to You, including providing Platform services, processing payments, and facilitating transactions.
  • Legitimate Interests: Processing is necessary for our legitimate business interests, including business development, product improvement, fraud prevention, platform security, and analytics, provided that such interests are not overridden by Your fundamental rights.
  • Legal Obligation: Processing is necessary to comply with applicable laws, regulations, and legal processes under Indian law.

5. Data Sharing & Disclosure

We may share Your information in the following circumstances:

5.1 Between Platform Users

Relevant business information (business name, location, production capacity, ratings) is shared between Makers and Production Houses as necessary to facilitate transactions, bidding, communication, and order fulfilment through the Platform.

5.2 Service Providers

We share data with trusted third-party service providers who assist us in operating the Platform, including:

  • Payment processors and escrow service providers;
  • Logistics and courier partners;
  • SMS gateway providers and communication services;
  • Cloud hosting and infrastructure providers;
  • Analytics and data processing providers;
  • Customer support tools and services.

These service providers are contractually obligated to use Your data only for the purposes specified by Makely and to maintain appropriate security measures.

5.3 Legal & Regulatory Authorities

We may disclose Your information to law enforcement agencies, government authorities, regulatory bodies, or courts as required by law, legal process, or government request, or where we believe disclosure is necessary to protect Makely’s rights, safety, or property, or the rights, safety, or property of other Users or the public.

5.4 Aggregated & Anonymised Data

We may share aggregated, de-identified, or anonymised data with business partners, investors, industry bodies, research institutions, and the public. Such data cannot be used to identify individual Users.

5.5 Business Transfers

In the event of a merger, acquisition, reorganisation, sale of assets, or bankruptcy, Your information may be transferred to the acquiring entity as part of the transaction, subject to applicable data protection laws.

6. Data Retention

We retain Your personal and business data in accordance with the following retention schedule:

  • Active Account Data: Retained for the duration of Your account activity plus eight (8) years from the date of last activity.
  • Transaction Records: Retained for a minimum of eight (8) years from the date of the transaction, as required for tax, audit, and legal compliance purposes.
  • Communication Logs: Retained for a minimum of five (5) years from the date of communication.
  • Post-Termination Data: Upon account termination or deletion, we shall retain all data for a minimum of eight (8) years for legal compliance, audit, dispute resolution, and regulatory purposes.
  • Aggregated & Anonymised Data: Retained indefinitely, as it cannot be used to identify individual Users.

The retention periods specified above represent minimum retention periods. Makely may retain data for longer periods where required by applicable law, ongoing legal proceedings, or legitimate business purposes.

7. Data Security

We implement industry-standard technical and organisational security measures to protect Your information against unauthorised access, alteration, disclosure, or destruction, including:

  • Encryption of data in transit (TLS/SSL) and at rest;
  • Secure server infrastructure with access controls and firewalls;
  • Role-based access controls limiting data access to authorised personnel only;
  • Regular security audits and vulnerability assessments;
  • Secure authentication mechanisms including multi-factor authentication;
  • Incident response procedures for data breach detection and notification.

However, no method of electronic transmission or storage is completely secure. While we strive to use commercially acceptable means to protect Your information, we cannot guarantee its absolute security. You acknowledge and accept this inherent risk when using the Platform.

8. Your Rights

Subject to applicable law and the data retention requirements described in Section 6, You may have the following rights regarding Your personal data:

  • Right to Access: You may request access to the personal data we hold about You.
  • Right to Correction: You may request correction of inaccurate or incomplete personal data.
  • Right to Data Portability: You may request a copy of Your data in a structured, commonly used, machine-readable format, subject to technical feasibility.
  • Right to Withdraw Consent: You may withdraw Your consent at any time by requesting account deletion. However, withdrawal of consent shall result in immediate termination of Your account and access to the Platform, and shall not affect the lawfulness of processing conducted prior to withdrawal or Makely’s right to retain data under applicable law.

Please note: The right to erasure or deletion is subject to Makely’s data retention obligations under applicable Indian law, ongoing legal proceedings, dispute resolution requirements, and legitimate business purposes. Makely shall retain data in accordance with Section 6 even upon receipt of a deletion request.

To exercise any of these rights, please contact our Grievance Officer as detailed in Section 13 below.

9. Cookies & Tracking Technologies

The Makely Platform may use the following tracking technologies:

  • Device Identifiers: Unique device identifiers (Android ID, Advertising ID, IMEI) for analytics, fraud prevention, and User identification.
  • Analytics SDKs: Third-party analytics tools to measure Platform usage, performance, and User behaviour.
  • Push Notification Tokens: Device tokens for delivering push notifications.
  • Session Data: Session identifiers and authentication tokens for maintaining secure login sessions.
  • Crash Reporting: Automated crash and error reporting tools for diagnosing and resolving technical issues.

By using the Platform, You consent to the use of these tracking technologies as described herein.

10. Third-Party Services

The Platform integrates with and relies upon third-party services, including but not limited to payment gateways, SMS and communication providers, cloud hosting services, analytics providers, and logistics partners. These third-party services have their own privacy policies and terms of service.

Makely is not responsible for the privacy practices, security measures, or data handling of any third-party service provider. We encourage You to review the privacy policies of any third-party services You interact with through the Platform.

11. Children’s Privacy

The Makely Platform is intended for use by individuals who are at least eighteen (18) years of age. We do not knowingly collect, solicit, or process personal data from individuals under the age of eighteen (18). If we become aware that we have collected personal data from a child under 18, we will take steps to delete such data promptly.

If You are a parent or guardian and believe that Your child has provided personal data to Makely, please contact our Grievance Officer immediately.

12. Changes to This Policy

Makely reserves the right to update, amend, or modify this Privacy Policy at any time, at its sole discretion, without prior individual notice. The updated Policy shall be effective immediately upon posting on the Platform. The “Last Updated” date at the top of this Policy indicates when it was most recently revised.

Your continued use of the Platform after any changes to this Policy shall constitute Your acceptance of such changes. We encourage You to review this Policy periodically to stay informed about how we collect, use, and protect Your information.

13. Grievance Officer

In accordance with the Information Technology Act, 2000, and the rules framed thereunder, the details of the Grievance Officer are as follows:

  • Name: Brijesh Mundhra
  • Designation: Co-Founder & Grievance Officer
  • Email: grievance@makely.in
  • Address: FE-369, Sector-3, Salt Lake, Kolkata-700106, West Bengal, India

The Grievance Officer shall acknowledge receipt of any complaint within forty-eight (48) hours and shall endeavour to resolve the complaint within thirty (30) days of receipt, in accordance with applicable law.

14. Contact Information

For any questions, concerns, or requests regarding this Privacy Policy or the handling of Your data, please contact us at:

  • Entity: Makely
  • Registered Office: FE-369, Sector-3, Salt Lake, Kolkata-700106, West Bengal, India
  • Email: legal@makely.in

15. Governing Law & Jurisdiction

This Privacy Policy shall be governed by and construed in accordance with the laws of India, including the Information Technology Act, 2000, the Digital Personal Data Protection Act, 2023, and all applicable Indian data protection and privacy laws.

Any disputes arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Kolkata, West Bengal, India.

Makely — The Garment Manufacturing Aggregator

Registered Office: FE-369, Sector-3, Salt Lake, Kolkata-700106, West Bengal, India

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