Cookie Policy, Marketing & Communication Consent Policy

1. PURPOSE

This Policy explains how StudioMitra, a brand operated by SAFALPAY INDIA PRIVATE LIMITED (“StudioMitra”, “Company”, “we”, “us” or “our”), uses cookies and similar technologies on www.studiomitra.in and how visitors/users may provide, manage or withdraw consent for analytics, personalization and marketing communications.

The Policy also describes the Company's approach to promotional communication through email, SMS, telephone/voice calls, WhatsApp and other lawful digital or communication channels, subject to applicable consent, preference, opt-out and telecom requirements.

2. IMPORTANT CONSENT PRINCIPLE

Acceptance of necessary cookies alone does not automatically constitute consent to receive promotional emails, marketing calls, WhatsApp marketing, SMS or other commercial communications. Where marketing consent is required, StudioMitra will use a separate or sufficiently clear consent mechanism that identifies the communication purposes and, where appropriate, the channels.

A visitor may choose to accept all cookies, reject non-essential cookies, or manage individual cookie categories where the website's consent-management mechanism provides those choices.

3. COMPANY DETAILS

4. WHAT ARE COOKIES?

Cookies are small text files or similar identifiers stored on or associated with a user's browser or device when visiting a website. They may help a website remember preferences, maintain sessions, understand website usage, improve security and, where permitted, support marketing or advertising activities.

5. TYPES OF COOKIES WE MAY USE

• Strictly Necessary / Essential Cookies: required for core website operation, security, login/session management and essential functionality.
• Functional Cookies: remember preferences and settings to improve the user experience.
• Analytics / Performance Cookies: help understand traffic, page usage, performance and technical issues.
• Preference Cookies: remember language, interface or other selected preferences.
• Marketing / Advertising Cookies: where enabled and legally permitted, help measure or support relevant advertising and marketing activities.
• Security Cookies / Identifiers: assist with fraud prevention, abuse detection and protection of accounts and services.
• Session Cookies: generally operate during a browsing session.
• Persistent Cookies: remain for a defined period or until removed/expired.

6. PURPOSES OF COOKIE USE

• Website operation and essential functionality.
• Authentication and session management.
• Security, fraud prevention and abuse detection.
• Remembering user preferences.
• Website performance and troubleshooting.
• Analytics and service improvement.
• Understanding campaign performance.
• Personalizing website content where permitted.
• Supporting marketing and advertising measurement where consent or another lawful basis permits it.
• Maintaining consent and cookie preferences.

7. ANALYTICS

StudioMitra may use analytics tools to understand website traffic, page views, browser/device characteristics, referral sources, performance and user interactions. Analytics information may be aggregated or otherwise handled according to the applicable privacy and cookie settings.

8. THIRD-PARTY COOKIES

Third-party service providers may place cookies or similar technologies when their services are integrated into the website. Examples may include analytics, security, communication, advertising, embedded content, customer-support or performance services.

Third-party providers may have their own privacy policies and cookie practices. StudioMitra will seek to configure third-party technologies consistently with applicable consent and privacy requirements.

9. COOKIE CONSENT BANNER

Where non-essential cookies are used, StudioMitra may display a cookie consent banner or consent-management interface. Depending on the implementation, the visitor may be offered options such as “Accept All”, “Reject Non-Essential”, “Manage Preferences” or equivalent controls.

The Company may record information about the consent choice, such as date/time, consent status, relevant cookie categories and technical identifiers necessary to demonstrate or administer consent, subject to applicable law.

10. MARKETING CONSENT

Where a visitor/user voluntarily provides contact information and separately opts in to promotional communications, StudioMitra may use that information for marketing purposes in accordance with the consent given and applicable law, including:

• StudioMitra product and software announcements.
• New features, plans, services and functionality.
• Promotional offers and discounts.
• Events, webinars, demonstrations and educational content.
• Business updates and relevant StudioMitra communications.
• Customer engagement and feedback campaigns.
• Marketing communications from StudioMitra or authorized marketing partners where the user has appropriately consented, where applicable.

11. EMAIL MARKETING

Where valid marketing consent has been provided, StudioMitra may send promotional emails concerning products, features, offers, events, educational material and other relevant business communications.

Marketing emails should provide a practical method to unsubscribe or withdraw promotional communication consent. A user may also contact StudioMitra to request removal from marketing communications.

12. SMS / TEXT MESSAGE MARKETING

StudioMitra may send commercial or promotional SMS/text communications only through an appropriate communication process and subject to applicable telecom rules, consent/preferences, sender/header/template requirements and opt-out mechanisms.

India's TRAI framework regulates unsolicited commercial communications and provides a framework for commercial communications based on consent and customer preferences. StudioMitra will assess and follow applicable TCCCPR requirements for communications sent through telecom resources.

13. MARKETING TELEPHONE / VOICE CALLS

Where StudioMitra conducts promotional or sales calls, it will use applicable consent, preference and telecom-compliance mechanisms. Commercial calls must not be treated as permission to ignore applicable Do-Not-Disturb, customer preference, consent or telemarketing requirements.

TRAI's UCC framework covers commercial communication through telecom resources and includes requirements and directions concerning voice calls, SMS, consent, preferences and telemarketing.

14. WHATSAPP MARKETING

Where StudioMitra uses WhatsApp or another business-messaging platform for promotional communication, it will use the applicable platform rules, consent/opt-in requirements, messaging templates or controls, and applicable Indian laws and telecom/customer-preference requirements.

Marketing WhatsApp messages should be sent only to contacts for whom StudioMitra has an appropriate basis to send the communication. Users should be provided a practical way to stop promotional WhatsApp communications where applicable.

The availability of a customer's WhatsApp number does not by itself constitute blanket consent for unlimited promotional messaging.

15. OTHER DIGITAL MARKETING CHANNELS

Subject to applicable law, consent and platform rules, StudioMitra may use other digital communication channels, including app notifications, web push notifications, in-product messages, social-media messaging, online advertising, remarketing/retargeting technologies, and other electronic communication channels.

Where a particular channel requires separate permission, preference or opt-in, StudioMitra will obtain or rely on that permission as appropriate.

16. MARKETING PARTNERS

Where StudioMitra engages marketing, communication, analytics or advertising vendors, such vendors may process limited information on StudioMitra's behalf under applicable contractual and security controls.

StudioMitra will not authorize a vendor to use personal information for unrelated purposes merely because the vendor provides a marketing service, except where permitted by law and appropriately disclosed/consented to.

17. PERSONALIZED MARKETING

Where permitted by law and the applicable consent settings, StudioMitra may use information such as website interactions, product interests, communication preferences or account/service information to make marketing more relevant.

Users may withdraw promotional consent. Withdrawal of marketing consent does not necessarily affect processing required to provide the service, maintain security, comply with law or complete transactions.

18. TRANSACTIONAL VS PROMOTIONAL COMMUNICATION

Service, transactional, security and account communications may be different from promotional communications. Examples include account verification, password reset, booking/service notifications, security alerts, invoices, payment confirmations and important service notices.

Unsubscribing from promotional communications may not stop essential transactional, security or legally required communications.

19. CONSENT RECORDS

Where consent is used for marketing, StudioMitra may maintain records sufficient to demonstrate or administer the consent, including the channel, date/time, purpose/category, source and withdrawal status, subject to applicable law and retention requirements.

For telecom commercial communication, StudioMitra will maintain or use applicable consent/preference mechanisms required by the relevant telecom framework and service providers. TRAI's framework specifically provides for digital recording and revocation of consent and customer preferences.

20. WITHDRAWAL / OPT-OUT

Users may withdraw marketing consent or opt out of promotional communications through available unsubscribe links, communication-specific opt-out instructions, account settings, cookie preference controls where applicable, or by contacting StudioMitra.

Withdrawal will be processed within a reasonable operational period. Some communications may continue briefly while suppression lists and communication systems synchronize.

21. COOKIE PREFERENCE WITHDRAWAL

Where the website provides a cookie-preference tool, visitors may change their non-essential cookie choices. Disabling certain cookies may affect website functionality, personalization, analytics or other features.

22. BROWSER CONTROLS

Most browsers allow users to block, delete or restrict cookies. Browser settings vary. Blocking essential cookies may prevent parts of the website from functioning properly.

23. MARKETING SUPPRESSION LIST

When a user unsubscribes from promotional communications, StudioMitra may retain a limited suppression record such as an email address or phone number solely to prevent future unwanted marketing communications, where legally permitted and reasonably necessary.

A suppression record does not mean the Company is continuing to use the contact for marketing.

24. DATA USED FOR MARKETING

• Name and contact information voluntarily provided by the user.
• Email address.
• Mobile/telephone number.
• Communication preferences.
• Relevant business or product interests.
• Website interaction information where permitted by cookie/analytics settings.
• Marketing consent and opt-out status.
• Campaign or communication response information.

25. SENSITIVE INFORMATION

StudioMitra should not request unnecessary sensitive personal information for ordinary marketing purposes. Users should not provide passwords, OTPs, PINs, CVV, authentication secrets or other security credentials through marketing forms or messages.

26. DATA SHARING FOR MARKETING

Where necessary to deliver a marketing communication, StudioMitra may share limited information with authorized email, SMS, telephony, WhatsApp/business-messaging, analytics, advertising or communication service providers. Such sharing will be limited to the relevant purpose and subject to applicable contractual, security and legal requirements.

27. RETENTION

Cookie information, consent records and marketing contact information may be retained for as long as reasonably necessary for the stated purposes, to demonstrate consent/withdrawal, comply with legal requirements, prevent repeated unwanted communication and maintain appropriate business records.

28. SECURITY

StudioMitra will apply reasonable technical and organizational measures to protect cookie-related information, contact data, consent records and marketing systems against unauthorized access, alteration, disclosure or misuse.

29. CHILDREN

StudioMitra's services are intended for the relevant business and adult users. Marketing communications should not knowingly be directed at children where prohibited by applicable law. Where age-related restrictions apply, appropriate controls should be implemented.

30. FRAUD / SECURITY COMMUNICATIONS

StudioMitra will not use this Policy as authorization to request passwords, OTPs, PINs, CVV or other confidential authentication information through marketing communications. Users should independently verify suspicious messages claiming to be from StudioMitra.

31. DO-NOT-DISTURB / CUSTOMER PREFERENCES

StudioMitra will respect applicable telecom customer preferences, consent records, opt-out mechanisms and communication restrictions. TRAI states that its TCCCPR framework is intended to facilitate commercial communication to recipients who have opted in or set relevant preferences, while addressing unsolicited commercial communication.

32. COMPLIANCE WITH PLATFORM RULES

Email providers, WhatsApp/business-messaging platforms, SMS providers, telephony providers, advertising platforms and other communication services may impose additional rules. StudioMitra may modify, restrict or stop a marketing channel where necessary to comply with provider policies, legal requirements or user preferences.

33. NO GUARANTEE OF DELIVERY

StudioMitra does not guarantee that every marketing communication will be delivered, opened or received. Delivery may be affected by provider filters, network conditions, user settings, blocked numbers, invalid addresses, spam filtering, platform restrictions or other factors.

34. WEBSITE TRACKING AND ADVERTISING

Where permitted and enabled by the visitor's settings, StudioMitra may use advertising or measurement technologies to understand campaign performance or display relevant StudioMitra advertising on third-party platforms.

Non-essential marketing/advertising technologies should be controlled through the website's applicable consent mechanism where required.

35. DO NOT SELL / UNRELATED MARKETING

StudioMitra will not treat ordinary cookie acceptance as permission to sell or transfer a user's contact information to unrelated third parties for their independent marketing purposes. Any independent third-party marketing arrangement should be assessed separately under applicable law and consent requirements.

36. RELATIONSHIP WITH PRIVACY POLICY

This Cookie & Marketing Policy should be read together with StudioMitra's Privacy Policy, Terms & Conditions, Information Security & Cyber Security Policy and other applicable policies. The Privacy Policy explains broader processing of personal information.

37. CONTACT AND GRIEVANCE

For privacy, cookie, consent, marketing opt-out or communication-related concerns:

38. POLICY CHANGES

StudioMitra may update this Policy from time to time to reflect changes in technology, cookies, marketing channels, business operations, legal requirements, telecom rules or service-provider requirements. The latest version will be published on the website where appropriate.

39. EFFECTIVE DATE

40. IMPORTANT IMPLEMENTATION REQUIREMENT

For practical compliance, the StudioMitra website should not rely on a single generic “Accept Cookies” button as the sole authorization for every type of marketing communication. The website should preferably provide clear choices for necessary cookies and non-essential categories, and a separate marketing-consent mechanism for promotional communications.

For SMS and promotional voice communication in India, the Company should implement the applicable TRAI/TCCCPR sender, consent, preference, DLT, template, header and telemarketing requirements relevant to its communication model. TRAI currently maintains the consolidated TCCCPR-2018 framework and related directions.

This Policy is a governance document and should be aligned with the actual cookie tools, CRM, email platform, WhatsApp/business-messaging provider, SMS/voice provider and consent-management system used by StudioMitra.