Privacy Policy

This Privacy Policy explains how GSP Horizon, operating under the trade name Positive Charge, collects, uses, shares, and protects personal data through positivecharge.in and any related digital properties. This policy is issued in accordance with the Digital Personal Data Protection Act, 2023 (India), the Information Technology Act, 2000, and the Consumer Protection Act, 2019.

Last updated: 18 July 2026

1. Who we are

Data Fiduciary: GSP Horizon (Partnership) Trade name: Positive Charge Registered address: Plot 231, Kakinada Industrial Area, Ramanayyapeta, Kakinada, Andhra Pradesh 533005, India GSTIN: 37ABEFG5094K1ZY Email: contact@gsphorizon.com Phone: +91 79957 72226

In this policy, "we", "us" and "our" refer to GSP Horizon. "You" and "your" refer to any individual whose personal data we collect through positivecharge.in.

2. Current status of the site

Positive Charge is in a pre-launch phase. At the time this policy is published, we are not selling or dispatching any product. The only personal data we actively collect is a name, email address and, optionally, a phone number when a visitor voluntarily joins our launch waitlist. Once we begin selling products, the additional processing described in Sections 3, 5 and 7 will begin.

3. What personal data we collect

We collect only the data we need to run our business and deliver what you request. Depending on how you use the site, this may include:

Waitlist data (collected now):

• Full name (optional)
• Email address
• Phone number (optional)
• Marketing consent status and timestamp
• The IP address and browser from which the form was submitted (for fraud and audit purposes)

Transactional data (collected only once we begin selling):

• Billing name and address
• Shipping name and address
• Email address and phone number for order notifications
• Order contents, quantity and value
• Payment method reference (we do not store your card number or UPI credentials — see Section 6)
• Order and delivery status

Account data (only if you create an account with us):

• Login credentials, hashed
• Order history
• Saved addresses

Communications data:

• The content of any email, phone, or contact-form message you send us
• Attachments and photographs you send us with a complaint or return request

Technical and analytics data:

• IP address, device type, browser type, operating system
• Pages visited, actions taken and referring URL
• Cookies and similar tracking technologies (see Section 8)

We do not knowingly collect sensitive personal data as defined under the DPDP Act, 2023 (for example, biometric, health, genetic or financial data beyond what is required to complete a transaction). If you voluntarily share sensitive information in a complaint, we will use it only to resolve the complaint and will not retain it beyond that purpose.

4. Why we collect it

We collect and use your personal data only for the following defined purposes:

1. To operate the positivecharge.in website and improve its performance.
2. To send you a single notification when Element 1 becomes available for purchase, if you joined the waitlist.
3. To process and dispatch your order and to communicate with you about it (once we begin selling).
4. To respond to your questions, complaints, and return requests.
5. To send you marketing communications, only if you have separately opted in.
6. To meet our legal, tax, regulatory and accounting obligations under Indian law (including FSSAI, GST and Consumer Protection).
7. To detect, prevent and address fraud, security or technical issues.

We will not use your personal data for any purpose other than those listed above without seeking your fresh consent.

5. Legal basis for processing

Under the DPDP Act, 2023, we rely on the following bases to process your personal data:

• Consent — for the waitlist signup, marketing communications, and any optional data.
• Contract — to fulfil an order you have placed.
• Legal obligation — to comply with tax, FSSAI, and consumer protection requirements.
• Legitimate use — to prevent fraud, secure the site, and enforce this policy.

You may withdraw your consent at any time by writing to contact@gsphorizon.com. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

6. Who we share your data with

We do not sell your personal data. We do not rent it. We do not share it with any third party for their independent marketing purposes.

We share personal data only with the following categories of recipients, and only to the extent strictly necessary:

• Shopify Inc. — our e-commerce platform provider. Shopify processes waitlist signups, customer accounts, and order data on our behalf. Shopify's own privacy practices are available at shopify.com/legal/privacy.
• Payment gateways (once we begin selling) — for example Razorpay, Stripe, or similar. These providers process your payment credentials directly. We do not store your card, UPI, or bank account details on our servers.
• Logistics and courier partners (once we begin selling) — to deliver your order, we share your name, address, phone number and order reference with the courier we select.
• Manufacturing partner — for order fulfilment we share the minimum information necessary with our contract manufacturer, 3S Fitness Technologies Private Limited, and only the information required to prepare and dispatch your order.
• Professional advisors — auditors, lawyers, and accountants under duty of confidentiality.
• Government authorities — where required by valid Indian law, court order, or regulatory demand.
• Acquirer or successor — in the event of a business sale, merger or reorganisation, subject to the acquirer accepting obligations no less protective than this policy.

Every third party listed above is required to process your data only for the specified purpose and to maintain appropriate safeguards.

7. How long we keep your data

• Waitlist data — until Element 1 launches, plus twelve (12) months to complete the launch communications cycle. You may ask us to delete your waitlist entry earlier by writing to contact@gsphorizon.com.
• Transactional data — for the duration required by Indian tax and accounting law (currently eight financial years from the end of the relevant year), and then securely deleted or anonymised.
• Account data — for as long as your account is active. If your account is inactive for 24 consecutive months, we may deactivate and delete it after written notice.
• Communications data — for up to three (3) years from the date of the last communication, unless required longer to resolve a legal matter.
• Marketing consent records — for as long as we hold your data, to prove lawful basis.

8. Cookies and similar technologies

positivecharge.in uses cookies and similar technologies to keep you logged in, remember your cart, understand which pages perform well, and detect fraud. These include:

• Strictly necessary cookies — required for the site to function (login, cart, checkout, security).
• Analytics cookies — help us understand how visitors use the site, on an aggregated basis.
• Preferences cookies — remember your language, currency or display preferences.

You may configure your browser to refuse cookies. If you do, some parts of the site may not function. We do not currently run behavioural advertising cookies.

9. Third-party services embedded on our site

The site loads the following third-party resources, whose privacy practices apply when those resources load:

• Google Fonts — for the Manrope and Inter fonts used across the site. Google receives your IP address as part of the font request.
• Shopify — for the e-commerce infrastructure of the site.

We do not run third-party advertising, retargeting pixels, or session recording on the site at the time this policy is published. If we add such tools later, we will update this policy and, where required, request fresh consent.

10. International data transfers

Some of the third parties listed in Section 6 may store or process personal data on servers located outside India. Where this occurs, we require the recipient to protect your data at a standard equivalent to Indian law and to permit onward transfer only in accordance with the DPDP Act, 2023 and any rules issued under it.

11. Your rights

Under the DPDP Act, 2023 you have the following rights in respect of your personal data:

• Access — the right to receive a summary of the personal data we hold about you and how we process it.
• Correction — the right to have inaccurate or misleading data corrected, and incomplete data completed.
• Erasure — the right to have your personal data deleted where it is no longer necessary for the purpose it was collected for, or where you withdraw consent and no other lawful basis applies.
• Withdrawal of consent — the right to withdraw consent for any consent-based processing, at any time.
• Grievance redressal — the right to raise a grievance about our processing of your personal data.
• Nomination — the right to nominate another individual to exercise your rights in the event of your death or incapacity.

To exercise any of these rights, email contact@gsphorizon.com with your name, the email address associated with your data, and a description of your request. We will respond within thirty (30) days. We may ask for reasonable proof of identity before actioning a request, to protect your data from an impostor.

12. Grievance Officer

In accordance with Section 8(9) of the DPDP Act, 2023 and Rule 5(9) of the Information Technology (Reasonable Security Practices) Rules, 2011, our designated Grievance Officer is:

Sri Ganesh Datta Chaitanya Goli (on behalf of GSP Horizon) Email: contact@gsphorizon.com Phone: +91 79957 72226 Address: Plot 231, Kakinada Industrial Area, Ramanayyapeta, Kakinada, Andhra Pradesh 533005, India

The Grievance Officer will acknowledge your grievance within seven (7) working days and will substantively respond within thirty (30) days of receipt. If you are not satisfied with our response, you may approach the Data Protection Board of India constituted under the DPDP Act, 2023.

13. Children under 18

positivecharge.in is intended only for individuals aged eighteen (18) years or older. Our product is a nutraceutical for adults. We do not knowingly collect personal data from anyone under 18. If we discover that we have collected personal data from a minor, we will delete it promptly. A parent or guardian who believes their child has provided us data may contact us at contact@gsphorizon.com to request deletion.

14. Security

We use reasonable and appropriate technical and organisational security measures to protect your personal data, consistent with Rule 8 of the Information Technology (Reasonable Security Practices) Rules, 2011. These include encrypted transmission (HTTPS), access controls, and the delegation of payment processing to PCI-DSS-compliant gateways. Despite these measures, no system connected to the internet can be guaranteed to be perfectly secure. You share personal data with us at your own risk to the extent permitted by law.

If we become aware of a personal data breach affecting your data, we will notify the Data Protection Board of India and, where required, notify you, in accordance with the DPDP Act, 2023.

15. No sale of personal data

We do not sell, rent, or trade your personal data to any third party under any circumstances. We do not permit any third party listed in Section 6 to use your personal data for their independent marketing purposes.

16. Changes to this policy

We may amend this policy from time to time. When we make a material change, we will publish the updated version on this page and, where required by law, contact you directly. The version in effect at the date of your interaction with the site is the version that governs that interaction. It is your responsibility to review this policy periodically.

17. Governing law and jurisdiction

This policy is governed by the laws of the Republic of India. Any dispute arising out of, or in connection with, this policy shall be subject to the exclusive jurisdiction of the competent courts in Kakinada, Andhra Pradesh, without prejudice to any competing jurisdiction available to a Data Principal under the Digital Personal Data Protection Act, 2023.

18. Contact

For any question relating to this Privacy Policy, or to exercise any of your rights under Section 11, contact:

GSP Horizon (Partnership) Plot 231, Kakinada Industrial Area, Ramanayyapeta, Kakinada, Andhra Pradesh 533005, India.

Email: contact@gsphorizon.com Phone: +91 79957 72226