Privacy Policy                        

Last Major Update : 01-Jun-2025
Effective Date : 01-Jun-2025



Mitsu Inc., (“Company”) a Proprietary concern, An Intermediary as defined in Section 2(1)(w) of the IT Act 2000, MSME registered entity, engaged as service provider for IT and IT enabled services (ITeS), IT consultancy and also an Accredited Domain Name Registrar (“Services”), having its registered office at 65, 3rd Floor, Diamond Mansion, 366/368, Dr.Veigas Street, Kalbadevi, Mumbai - 400 002, Maharashtra, India, where such expression shall, unless repugnant to the context thereof, be deemed to include its respective representatives, administrators, employees, owners, officers, agents and their successors and assigns, owns and manages the website https://www.mitsu.in (#1 Indian Domains) and its other digital platforms and website(s) running under the Company mainly Bharat Domains dba Bharat.in, Business Solutions - Businessx.in, Inregistrar DBA InRegistrar.com and their other branding GTLD/CCTLD domain names running under the name and style of Mitsu*.* including https://www.mitsu.com (collectively called as “Platform”). We value your privacy and take highest level of care/security in relation to your data.

The term ‘You’, “Your” & ‘User(s)’ shall mean any legal person or entity accessing or using the services provided on this Platform, who is competent to enter into binding contracts, as per the provisions of the Indian Contract Act, 1872;

The terms “Platform”, ‘We’, ‘Us’ & ‘Our’ shall mean the Website (s) and/or the Company, as the context so requires.

The terms ‘Party’ & ‘Parties’ shall respectively be used to refer to the User and the Company individually and collectively, as the context so requires.

The headings of each section in this Policy are only for the purpose of organizing the various provisions under this Policy in an orderly manner, and shall not be used by either Party to interpret the provisions contained herein in any manner. Further, it is specifically agreed to by the Parties that the headings shall have no legal or contractual value.

This Privacy Policy (“Privacy Policy”) as well as other policies mainly the Terms & Conditions (https://www.mitsu.in/legal), Cookies Policy (https://www.mitsu.in/legal), Disclaimer (https://www.mitsu.in/legal) and Refund and Return Policy (https://www.mitsu.in/refund) are published in compliance with inter alia:

Section 43A of the Information Technology Act, 2000 and the rules framed thereunder (as amended from time to time) ("IT Act");
Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”);
Rule 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2021;
Getting ready for The DPDP Act (Digital Personal Data Protection Act, 2023) -Subject to Government Notification;
Indian Contract Act, 1872; and
Article 21 of the Constitution of India

Why We collect Information?
We required to collect Information of the User to provide Services under Our contractual obligation with respective Domain Name Registries through Registrar Accreditation Agreement (RAA) or with Hosting Service providers or with any other IT or IT enabled services providers, We as an Intermediaries collecting and processing Your data as Data processor.

Intermediary as defined below under Rule 2 (g) of the SPDI Rules along with section 2(1)(w) of The IT Act :

"with respect to any particular electronic records, means any person who on behalf of another person receives, stores or transmits that record or provides any service with respect to that record and includes telecom service providers, network service providers, internet service providers, web-hosting service providers, search engines, online payment sites, online-auction sites, online-market places, and cyber cafes."

This Privacy Policy deals with information we may collect and process information in relation to our Platform.
Whose data does the 'Platform' collect:
People who use our services (Customers and Resellers)
Visitors to our website
Job applicants
Interns
"Third Party" (Third Party Company/ websites/ referrer connected with Platform)
Current employees
Information Collections:
How We collect and use that information including Personal Information ?;
How You can provide information selectively, and how You can access and update this information ?; and
How We process, share and protect Your information ?.
Define in details below :
General:
1.1. The Platform are owned and managed by Mitsu Inc. , This Privacy Policy applies to all current and former users accessing or using Our Platform, or otherwise engaging with us through email or other means.

1.2. The collection and processing of information in the course of our delivery of Services, or other contractual or commercial engagements that we may enter into, will be done in accordance with the specific terms applicable thereto i.e. " https://www.mitsu.in/legal ", and not by this Privacy Policy.

1.3. By accessing or using Our Platform or by otherwise giving Us Your information, You confirm that You are above 18 years of age and have the capacity to enter into a legally binding contract and have read, understood and agreed to the practices and policies outlined in this Privacy Policy.

The User unequivocally agrees that this Policy and the aforementioned Terms constitute a legally binding agreement between the User and the Company, and that the User shall be subject to the rules, guidelines, policies, terms, and conditions applicable to any service that is provided by the Platform, and that the same shall be deemed to be incorporated into the Terms, and shall be treated as part and parcel of the same.

The User acknowledges and agrees that no signature or express act is required to make these Terms and the Policy binding on the User, and that the User’s act of visiting any part of the Platform constitutes the User’s full and final acceptance of the Policy and the aforementioned Terms.

1.4. You hereby consent to Our collection, use, sharing, and disclosure of Your information as described in this Privacy Policy. By visiting the home page of the Platform and/or using any of the services provided on the Platform shall be deemed to signify the User’s unequivocal acceptance of this Policy and the aforementioned Terms, and the User expressly agrees to be bound by the same. The User expressly agrees and acknowledges that the Terms and Policy are co-terminus, and that expiry / termination of either one will lead to the termination of the other.

1.5. The Parties expressly agree that the Company retains the sole and exclusive right to amend, add, delete or modify the Privacy Policy from time to time in part or as a whole, and the aforementioned Terms without any prior permission or intimation to the User, and the User expressly agrees that any such amendments or modifications shall come into effect immediately. The User has a duty to periodically check the Policy and Terms, and stay updated on their provisions and requirements.

If the User continues to use the Platform following such a change, the User will be deemed to have consented to any and all amendments / modifications made to the Policy and Terms. In so far as the User complies with the Policy and Terms, he/she is granted a personal, non-exclusive, non-transferable, revocable, limited privilege to enter, access and use the Platform.

1.6. If You are accessing or using the Platform from any location outside India, You do so at Your own risk, You explicitly consent Us for Your Information under this Privacy Policy and also You will be solely liable for Your Information provided on this Platform. We are govern by applicable Indian Law ONLY with Jurisdiction at Mumbai-India.

1.7. We do not allow or encourage any person below the age of 18 years to use our website and Services, thus The DPDP Act requires verifiable parental consent before processing the data of children under 18, does not applicable to us.
Information Collection and Method of Collection
2.1. We collect the following types of personal information about You, both through offline documentation that You may provide for compliance or KYC, as well as when You use Our Platform : User Information, Demographic Information, Behavioural Information, and Indirect Information, (each of which have been defined below, and collectively, “Information”):
User Information
In order to access Our Platform to avail Services, You required to provide Us with information in the nature of:
Full Name / Company Name
Email
Mobile / Phone No.
Full Address / Work Address
GST / Tax Info
IP address / Mac Address
Payment Info for Payment Processing by Payment Gateways.
Any other info which may require for compliances and KYC,
(collectively, “User Information”).

2.2. We collect Your Information either directly from You through offline documentation provided by You for compliance or to verify or to submit the KYC as required by Domain Name Registry or any other Law Enforcement Agencies (LEA) and/or through our Platform or third party service provider. We collect/receive information about you in the following manner:

When You fills up the registration form to create customer or reseller account or otherwise submits personal information for any interactions or reporting on Platform;
Or Information given to appointed Third party website for KYC compliance/ verifications;
Or Interacts with the Platform;
Or Indirectly by using different technologies;
Or From public sources.

2.3. We may also collect User Information when You visit any of Our office(s) to enquire about, or avail Our Services or attend any seminars, webinars, conferences or events organised by Us or where We participated. Further, We may collect User Information that You provide Us with for attending meetings or online sessions or interactions. You agree and acknowledge that such information is only collected temporarily for the aforesaid limited purposes and consent to Our collection thereof.
Demographic Information
2.4. We may collect from You, information which is not unique to You and refers to selected population characteristics (“Demographic Information”) including age, gender and current location details etc..
Behavioural Information
2.5. We may and our analytical service provider like Google Analytics, Cloudflare or any other service provider also collect information about User behaviour to generate analytics reports for the Platform and which may include information about Your device(s) and software including usage statistics, traffic data, Your IP address/ISP details, Mac address, data related to payment risk mitigation, browser and operating system type, domain names, access times, approximate geolocation, referrer sites, Keywords You use to reach our Platform, purchasing behaviour, advertisement conversion, First-party cookies and Your interactions with the site or app, such as page-views, bounce rates, and average session duration and details regarding the parts of the Platform that You access (“Behavioural Information”).

Mainly this Behavioural Information are not typically personally identifiable:
Cookies:
When You use Our services, We send one or more cookies - a small file containing a string of characters - to Your device that uniquely identifies Your browser. We use cookies to improve the quality of our service, including for storing user preferences, tracking user trends, and providing you with a better experience. We may set one or more cookies in your browser when You use Our services or one of our partner's services. When You send messages, publish content, post material, transmit information or email through Our services, We may retain the same in order to process Your inquiries, respond to Your requests and improve Our services. Further details are explained in Cookies Policies.

Our infrastructure consists of servers deployed at multiple data centres that are owned and operated by Us or Our partners. All information collected within Our services resides on this network of servers.

While Google Analytics uses cookies to track users, the data collected is not typically personally identifiable. To learn more about how We use cookies and Your choices in relation to these tracking technologies, please refer to Our Cookie Policy.

Google Analytics does not collect or store personally identifiable information (PII) by default. Customers can configure cookies and data collection settings to further protect User privacy.

Users can opt out of Google Analytics data collection by disabling cookies or using other browser extensions.
Indirect Information
2.6. Your use of certain third party services on the Platform also requires Us to collect such information as is considered necessary for that purpose (“Indirect Information”).

2.7. While We may collect Demographic Information, Behavioural Information and Indirect Information when You access or use Our Platform, We collect User Information only from You or sources mentioned above with Your prior consent unless there are other legal grounds for doing so, as further specified in this Privacy Policy. Where You provide Us with User Information of third parties, We understand that You have obtained consent of such third parties, and have sufficient rights, approvals and licenses to provide such information to Us.
No-Spam Policy
We have a strict No-Spam Policy prohibiting the use of any data collected to send spam. We will not sell any contact information to third parties.
Sensitive Personal Data or Information” (“SPDI”)
2.8. The IT Act and the SPDI Rules regulate the collection, usage, retention and disclosure of personal information, which is defined under the SPDI Rules 2(i) as any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying such person (“Personal Information”).

For this Privacy Policy we rely on following important definitions of SPDI Rules:
Rule 2 (e) of the SPDI Rules define data as defined in clause (o) of sub-section (1) of section 2 of the Act.
Rule 2 (d) of the SPDI Rules defines "cyber incidents"
Rule 2 (g) of the SPDI Rules define “intermediary” as defined in clause (w) of sub-section (1) of section 2 of the IT Act.

2.9. The SPDI Rule 3 further define “Sensitive Personal Data or Information” (“SPDI”) of a person as Personal Information about that person relating to:

Passwords;
Financial information such as details of bank accounts, credit cards, debit cards or other payment instruments;
Identity Documents;
any detail relating to the above categories (mentioned only the portions of the said Rule 2(i) which is applicable in our case), as specified in this paragraph, as provided to the body corporate for providing services; and
Any of the information received under the above categories, as specified in this paragraph, by a body corporate for processing, stored or processed under lawful contract or otherwise.
Further, such SPDI can be disclosed to Government agencies for investigation, prevention, verification of identities, etc., and can be disclosed under an order of law for the time being in force (Rule 6 of SPDI).

2.10. Some of the Information collected by Us may qualify as Personal Information.

2.11. We understand that all Personal Information provided by You to Us in any form is voluntarily to use our Services. Collection, use and disclosure of Personal Information requires Your express consent, unless there are other legal grounds available to us to collect such information as further specified in this Privacy Policy. By using or accessing the Platform or otherwise providing Us with Your Personal Information, where applicable, You are providing Us with Your consent to Our use, collection, retention, transfer and disclosure of the Personal Information in accordance with the terms of this Privacy Policy.

2.12. In the event of a change in the law applicable to data protection in India, You hereby expressly consent to Our continued use, storage, collection and disclosure of Your Information including Personal Information to the fullest extent permitted under such applicable law. We may reach out to You for obtaining KYC, additional consents and approvals as required under the amended law and You will be required to comply with such requests. Should You choose to not provide Us with such additional consents and approvals, We may have to discontinue your access to the Platform.

2.13. You may choose to not provide Us with or withdraw any or all information included under Personal Information, but in the event that You do so, We may be unable to allow you to access the Platform or otherwise avail services for the provision of which your information is being collected or processed.
Use of Information
3.1. We use or share Your Information for the following purposes:

We will use the information that we collect about You for the following purposes:

Creating user account
Transmitting and sharing with respective Domain Name Registries and their TSP
Transmitting and sharing with Hosting / other Technical Service Providers
Transmitting and sharing with other Domain Registrars (Transfer of domain name(s))
Transmitting and sharing with third party for Compliance and KYC
Enforce T&C
Processing payment and determining the Taxations
Transmitting and sharing with Payment Gateway for Financial Transactions
Support or Support services provider
Manage customer order(s)
Transmitting and sharing with Law Enforcement Agencies (LEA) as and when required
Transmitting and sharing with Taxation authorities
Manage user account
Dispute resolution

We require such third party’s to use the personal information we transfer to them only for the purpose for which it was transferred and not to retain it for longer than is required for fulfilling the said purpose.

We may also disclose your personal information for the following:
(1) to comply with applicable law, regulation, court order or other legal process;
(2) to enforce your agreements with us, including this Privacy Policy; or
(3) to respond to claims that your use of the Service violates any third-party rights. If the Service or Company is merged or acquired by another company, your information will be one of the assets that is transferred to the new owner.

If we want to use your information for any other purpose, we will ask you for consent and will use your information only on receiving your consent and then, only for the purpose(s) for which grant consent unless we are required to do otherwise by law.

Also to operate and improve the Platform in order to foster a positive user experience and to improve Our business as a whole; Analysing data, tracking trends, building algorithms, creating databases for rating systems, recommendations engines, Research etc..

For non-targeting reasons such as frequency capping, compliance, information reporting or delivery, market research or product development purposes;

To conduct audits and quality assessment procedures; and

To analyse the use of Our resources and troubleshooting problems in relation to Our Platform.

3.2. In addition to the above, We also use Your Information, including Personal Information, for the following purposes:

For Our internal operational purpose such as record keeping, accounting and compliance with applicable taxation laws or data retention as per law;

For the purposes of recording information including dates, times and locations at which Our Platform have been accessed by using various tracking technologies and thereby improve Our Platform and Your experience by providing You with relevant information based on the above. Your disabling of tracking technologies on the Platform by changing settings on Your smartphone and/or web browser may result in Your inability to use the Platform fully or at all;

For providing, You with regulatory updates which We believe are relevant for You;

To invite You for seminars, webinars and workshops conducted by Us or Respective Registries which We believe may be of interest to You;

To comply with applicable law and Law Enforcement Agencies (LEA) or Govt and Respective Domain Name Registries Advisories;

To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or entity, or as otherwise required by law;

To respond to any queries that You may have, and to communicate information to You, including notifications of any alerts, any updates to the Platform; and To contact You from time to time to record Your valuable feedback on Our Platform, as they currently stand, and/or any potential services that may be offered in the future;

(Collectively, the above constitute “the Purposes”).

3.3. If You wish to opt out of receiving communications such as information regarding the Platform and/or any regulatory updates provided by Us, You may do so by login into your customer account.

3.4. Further, We may use social media platform such as LinkedIn, Twitter, Youtube , Facebook or any other platform or websites.. If You connect with Us through any of these services, then such engagement will be subject to the terms of service and privacy policy of the relevant social media platform and You should review the same before connecting with Us on such social media platform.

3.5. Our processing of Your Personal Information in the context of Your customer account creation, and use of Our Platform are based on your legitimate interests to avail the Services on our website , to optimize Our website(s), and to protect it from attacks. Furthermore, Our processing of Your Personal Information for providing regulatory updates or conducting other business development activities serves the legitimate interests of the users to receive periodically update by respective registries and know-how and serves Our legitimate interests to develop Our business and promote client relationships.
Disclosure of the Information
4.1. We disclose Your Information including Personal Information, as the case may be to third parties in the manner specified below:

Disclosing Your Information including Personal Information to respective domain name registries, hosting providers, payment gateways and companies and individuals who are acting as our Technical Service Providers (TSP), counterparties, consultants and advisors in relation to the Platform;

Disclosing Your Information including Personal Information to companies and individuals who are authorised by Us to perform certain functions in relation to the Platform and/or Our business, including Our third party service providers, consultants and professional advisors and insurers;

We also share aggregated information about You with partners, other Platform users, and other third parties for the purpose of improving Our Platform;

We may transfer Information including Personal Information to third parties, including persons outside India, in furtherance of the above; and Such third parties may include:

Any of Our agents, contractors or third party service providers that process or will be processing Your Information, on Our behalf, including but not limited to those which provide administrative or other services to Us such as mailing houses, telecommunication companies, information technology companies and data centres; and

Third parties, such as service providers, to whom disclosure by Us is for one or more of the Purposes and such third parties would in turn be collecting and processing Your Information including Personal Information for one or more of the Purposes.

4.2. We may disclose Your Information, including Personal Information, if legally required to do so, pursuant to an order from a governmental entity or in good faith. We will disclose the Information to:

Conform to legal requirements or comply with legal process;
Protect Our rights or property;
Prevent a crime or protect national security; or
Protect the personal safety of users or the public.
Third Party Links
5.1. The Platform may contain links to third party websites and services (“Third Party Services”). We have no control over such Third Party Services, which are provided by persons or companies other than Us. We are not responsible for any collection or disclosure of Your information by such companies or persons thereof.

5.2. Further, We are not liable for any loss or damage which may be incurred by You as a result of the collection and/or disclosure of Your information via Third Party Services. We shall not be liable for any disputes arising from or in connection with such transactions between You and the aforementioned third parties.

5.3. Such third party websites, and external applications or resources, accessible via the Platform may have their own privacy policies governing the collection, storage, transfer, retention and/or disclosure of Your information that You may be subject to. We recommend that You exercise reasonable diligence, as You would in traditional offline channels and practice judgment and common sense before committing to any transaction or exchange of information, including but not limited to reviewing the third party website or application’s privacy policy.
Changes to Your Information & Your Rights & Obligations
6.1. You may review, correct, update, or change Your Personal Information on the Platform by login into your account with us.

6.2. You may also request Us to delete Your Personal Information, and We will comply with such requests within a reasonable time, unless We are required to keep certain information for legal and tax compliance purposes as required by law.

6.3. Should You choose to delete Your Personal Information, or modify it in a way that is not verifiable by Us, or leads to such Personal Information being incorrect, We will be unable to provide You with access to Our Platform, and such a deletion or modification may be regarded as the user seeking to discontinue access to Our Platform.

6.4. We reserve the right to verify and authenticate Your identity and Your Personal Information in order to ensure accurate delivery of services through the Platform. You give explicit confirmation for the same and abide to provide any such documentation on demand for verifications.

6.5. Access to, or correction, updating or deletion of Your Personal Information may be denied or limited by Us if it would violate another person’s rights and/or is not otherwise permitted by applicable law.

6.6. Depending on the law that applies, you may have a right to access and rectify or erase your personal data or view your personal data, restrict or object to the active processing of Your data, You may ask us to share (port) Your personal information to another entity, withdraw any consent you provided to us to process your data, in that case We will be unable to provide You with access to Our Platform, and such a deletion or modification may be regarded as the user seeking to discontinue access to Our Platform.

You also has right to lodge a complaint with a statutory authority and such other rights as may be relevant under applicable laws. To exercise these rights, you can write to us at [email protected] . We will respond to your request in accordance with applicable law.

Your Obligations For Privacy

6.7. You acknowledges that You are agree/acknowledge and abide by the Company's websites policies, You also undertakes that You will also respect the privacy of the Company / Platform or its owner and employees, in any condition You will not use any part of the internal communications or email (as whole or in part) or any details of ongoing complaint escalation process or any information of personal nature or identity info of any of Company's employee or any confidential data or Company's intellectual property or Trade Mark etc. to publish or share on any public forum or platform or on any website or on social media without Company's consent and/or if You violates any of the given instructions and warnings, Your account(s)/service(s) are liable for suspension and any legal process initiated against You in this regard will be at Your cost.
Security of Your Information
7.1. We endeavour to maintain highest and best industry practice for physical, technical and procedural safeguards that are appropriate to protect Your Information against loss, misuse, copying, damage, hacking or modification and unauthorized access or disclosure. Some of the security measures adopted by Us are:

We periodically review Our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems, also periodically do the security audit of website, emails and servers where data is stored and also we adopt the best security practice and available latest technology, currently we are rated at A+ security rating; and

We restrict access to Personal Information, to Our employees, agents and service providers who need to know that information in order to process it for Us, and who are subject to strict contractual confidentiality obligations, and who may be disciplined or whose relationship with Us may terminate, if they fail to meet these obligations.

7.2. Further, We shall not be responsible for any breach of security or for any actions of respective domain name registries or any third parties or events that are beyond Our reasonable control including but not limited to acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, etc.
Retention of Information
8.1. We will put in place measures such that Your Personal Information, which is in Our possession or under Our control, is destroyed and/or anonymized as soon as and in any case, within 5 (five) years of it being reasonable to assume that (i) the Purpose for which that Personal Information was collected is no longer being served by the retention of such Personal Information or 2 years after Your user accounts remain idle or does not hold any active order(s); and (ii) retention is no longer necessary for any other reason including applicable law.

We may need to retain certain information for longer periods such as record-keeping / reporting in accordance with applicable law or for other legitimate reasons like enforcement of legal rights, fraud prevention, etc. Residual anonymous information and aggregate information, neither of which identifies you (directly or indirectly), may be stored indefinitely.

8.2. If You wish that We no longer use Your Personal Information in accordance with the terms of this Privacy Policy, contact Us at [email protected].

8.3. We, however, reserve the right to retain, store and use Your Information including Personal Information for Our business purposes, whether such Information has been deleted or not. After a period of time, Your data may be anonymized and aggregated, and then may be held by Us as long as necessary for Us to provide Our Services effectively.

8.4. Your withdrawal of consent to use Your Personal Information may result in Us not being able to provide You with access to the Platform, or terminate any existing relationship that We may have with You.
Disclaimer
We cannot ensure that all of Your Information including Personal Information will never be disclosed in ways not otherwise described in this Privacy Policy. Therefore, although We are committed to protecting Your privacy, We do not promise, and You should not expect, that Your Information or private communications will always remain private. As a user of the Platform, You assume all responsibility and risk for Your use of the Platform, the internet generally and the information You post or access and for Your conduct on and off the Platform. Some of the domain name registries like .com registry disclose registrant information’s publically.
Indemnity
You agree and undertake to indemnify Us in any suit or dispute by any third party arising out of disclosure of information by You to third parties either through Our Platform or otherwise, and Your use and access of websites, applications and resources of third parties. We assume no liability for any actions of third parties with regard to Your Information or Personal Information which You may have disclosed to such third parties.

In case If You are accessing or using the Platform from any location outside India or created Your user account and/or to avail Our Services using any location outside India, You do so at Your own risk, and You agree and undertake to indemnify Us in any case of data breach or any other issues related to this policy. You also abide by this Privacy Policy.
Juridiction
Company causes the control and maintenance of this Platform from India. Company makes no representations that the information and material contained in this Platform are appropriate or permitted for use in jurisdictions outside India.

The Privacy Policy are governed by the laws of India without giving effect to any principles of conflicts of laws.

The usage of the Platform by the User is subject to the exclusive jurisdiction of the courts located in Mumbai, Maharashtra, India without prejudice to the right of Company to take action in any jurisdiction whatsoever.
Grievance Officer / Data Protection Officer and Contact information
If you have any queries or concerns about the processing of your information that is available with us, you may contact our Grievance Officer/ Data Protection Officer. We will address your concerns in accordance with applicable law.

In accordance with the IT Act and rules made there under, the name and contact details of the Grievance Officer/ Data Protection Officer are provided below:

Mr. R.S.Agarwal
Email at [email protected]

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