Privacy Policy

1. Information We Collect

We may collect the following categories of personal information:

• Contact Information: Name, email address, postal address, phone number, and similar identifiers.
• Account Information: Username, password, and account preferences when you register.
• Payment Information: Credit/debit card details, billing address, transaction history (processed securely via PCI‑compliant partners).
• Demographic Information: Age, gender, location, language, and interests.
• Technical Information: IP address, browser type, device identifiers, operating system, and browsing activity (including pages visited and time spent).
• Communication Data: Records of your correspondence with us, including emails, chat messages, and call recordings (where permitted by law).
• Usage Data: How you interact with our websites and services, including search queries, clicks, and feature usage.
• Marketing Preferences: Your choices regarding receiving promotional communications.

2. How We Collect Information

We collect information through:

• Direct interactions: When you fill out forms, create an account, make a purchase, subscribe to newsletters, participate in surveys, or contact customer support.
• Automated technologies: Cookies, web beacons, and similar tracking tools (see our Cookie Notice).
• Third‑party sources: Business partners, data brokers, social media platforms (with your consent), and publicly available information.

3. How We Use Your Information

We use your personal information for the following purposes:

• To provide, operate, and improve our products and services.
• To process transactions and manage your account.
• To communicate with you, including responding to inquiries and sending service‑related notices.
• To personalize your experience and deliver relevant content, recommendations, and advertisements.
• To conduct research, analytics, and market analysis.
• To prevent fraud, protect security, and comply with legal obligations.
• To send marketing communications (with your consent or as permitted by law).
• To administer contests, promotions, or surveys.
• To create aggregated, anonymized data for business insights.

4. Legal Basis for Processing

We process your personal data based on one or more of the following legal grounds:

• Consent: Where you have given explicit consent (e.g., marketing emails, cookies).
• Contractual necessity: To perform a contract with you (e.g., delivering purchased products).
• Legal obligation: To comply with applicable laws, regulations, or court orders.
• Legitimate interests: For our legitimate business interests (e.g., fraud prevention, analytics, direct marketing) that do not override your rights.

Legal Framework in Pakistan: Pakistan has not yet enacted a comprehensive data protection law, but the Personal Data Protection Bill 2023 (PDPB) is under consideration. Once enacted, it will establish the National Commission for Personal Data Protection (NCPDP) and impose obligations on data controllers. We are committed to complying with the PDPB when it becomes effective. Currently, we adhere to internationally recognized principles and respect your right to privacy under Article 14 of the Constitution of Pakistan.

5. Sharing Your Personal Data

We may share your personal data with:

• Within Brackly Group: Subsidiaries and affiliates for internal business purposes.
• Service providers: Third‑party vendors who perform services on our behalf (e.g., payment processing, hosting, analytics, customer support). They are contractually bound to protect your data.
• Business partners: Trusted partners for co‑branded products or promotions.
• Advertising and analytics partners: To deliver relevant ads and measure campaign effectiveness.
• Legal and regulatory authorities: When required by law or to protect our rights, property, or safety.
• Business transfers: In connection with a merger, acquisition, or sale of assets, your data may be transferred.

6. International Data Transfers

We operate globally and may transfer your personal data to countries other than your own. These countries may have different data protection laws. When we transfer data internationally, we implement appropriate safeguards, such as standard contractual clauses, to ensure your data is protected. If the PDPB is enacted, we will comply with its cross‑border data transfer requirements, including any data localization mandates.

7. Data Security

We implement technical and organizational measures to protect your personal data against accidental loss, unauthorized access, alteration, or disclosure. These include encryption, access controls, regular security assessments, and employee training. However, no method of transmission over the internet is 100% secure. You are responsible for safeguarding your account credentials.

8. Data Retention

We retain your personal data only as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required by law. The retention period depends on the nature of the data, the purposes of processing, and legal obligations. After retention, we securely delete or anonymize your data.

9. Your Rights

Depending on your jurisdiction, you may have the following rights:

• Right to Access: Request a copy of your personal data.
• Right to Rectification: Correct inaccurate or incomplete data.
• Right to Erasure: Request deletion of your data (subject to legal exceptions).
• Right to Restrict Processing: Limit how we use your data.
• Right to Data Portability: Receive your data in a structured, machine‑readable format.
• Right to Object: Object to processing based on legitimate interests or direct marketing.
• Right to Withdraw Consent: Withdraw consent at any time without affecting the lawfulness of prior processing.
• Right to Lodge a Complaint: File a complaint with a supervisory authority (once established under the PDPB).

To exercise any of these rights, contact us at [email protected]. We will respond within a reasonable timeframe (usually 30 days).

10. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience, analyze traffic, and personalize content. You can control cookies through your browser settings or our cookie management tool. For detailed information, see our Cookie Notice.

11. Children's Privacy

Our services are not directed to children under the age of 13 (or the applicable age of consent in your jurisdiction). We do not knowingly collect personal data from children without parental consent. If you believe we have inadvertently collected such data, please contact us to delete it.

12. Third-Party Links

Our websites may contain links to third‑party websites. We are not responsible for the privacy practices of those sites. We encourage you to read their privacy policies before providing any personal information.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The “Effective Date” at the top indicates the latest revision. We will notify you of material changes by posting the updated policy on our website or through other appropriate channels. Your continued use of our services after the changes become effective constitutes acceptance of the revised policy.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

For general inquiries: [email protected]

We aim to respond to all legitimate requests within 30 days. If your request is complex, we may take longer and will notify you of the delay.