This Privacy Policy (“Privacy Policy”) is an electronic record in terms of Information Technology Act, 2000 and rules there under as applicable and the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.

This Privacy Policy is published in compliance with, interalia, (i) Section 43A of the Information Technology Act, 2000; (ii) Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”); and (iii) Rule 3 (1) of the Information Technology (Intermediaries guidelines) Rules, 2011 :

M/s Magic Media Solutions (B) Sdn Bhd is a company registered office at No.2 Simpang 995, Jalan Tutong, Kg. Kilanas, BF2520 , Brunei Darussalam (the “Company”, (which also includes its subsidiaries and affiliates) is the author and publisher of the internet resource (“Website”) on the World Wide Web as well as the software and applications (including mobile application) under the brand name 'BittyBru' (Website, software and mobile application are hereinafter collectively referred to as the “Platform”, “Application” or the “BittyBru Application”).

This Privacy Policy forms a part of the User Terms and Conditions of the Platform (“Terms of Use”). Capitalised terms used herein but not defined shall have the meaning assigned to such term in the Terms of Use.

We are committed to Your privacy. This Privacy Policy applies to the collection, use, storage, processing, disclosure and transfer of Your Information (defined below) when You use the Platform.

The terms 'You' or 'Your' or ‘User’ refer to You as the Users (irrespective of whether You are a Registered Users or Non-registered user and the terms ‘BittyBru' or 'We' or 'Us' or 'Company', and 'Our' refer to M/s No.2 Simpang 995, Jalan Tutong, Kg. Kilanas, BF2520 , Brunei Darussalam .



This Privacy Policy should be at all times read along with the Terms of Use / Terms of the Platform as maybe applicable. Unless stated otherwise, the Policy applies to all information that We have about You and Your account.

We reserve the right, in its sole discretion, to change, modify, add or delete portions of the terms of this Privacy Policy at any time. We may e-mail periodic reminders of the notices and conditions, unless You have instructed Us not to, but You should check the Platform frequently to see recent changes. Notwithstanding the above, We shall not be required to notify You of any changes made to this Privacy Policy. The revised Privacy Policy shall be made available on the Platform. Your continued use of the Platform, following changes to this Privacy Policy, will constitute Your acceptance of those changes.

If You choose to visit the Platform, Your visit and any dispute over privacy is subject to this Privacy Policy and the Terms of Use. In addition to the foregoing, any disputes arising under this Privacy Policy shall be governed by the laws of India and courts in Mumbai alone have jurisdiction in respect of the matter arising out the of this Privacy Policy.


Generally, some of the Services require Us to know who you are so that We can best meet your needs. When you access the Services, or through any interaction with Us via emails, telephone calls or other correspondence, We may ask you to voluntarily provide Us with certain information that personally identifies you or could be used to personally identify you. We also collect anonymous data from every visitor of the Platform to monitor traffic and fix bugs. For example, We collect information like web requests, the data sent in response to such requests, the Internet Protocol address, the browser type, the browser language, and a timestamp for the request. To access certain section to the Platform, We may ask You to register and provide certain personal information in order to be able to save Your profile and the documents and comments associated with it. You hereby consent to the collection of such information. Without prejudice to the generality of the above, information collected by Us from You may include (but is not limited to) the following:

  • contact data (such as Your name, email address, residential address, office address phone number and emergency contact information);

  • demographic data (such as Your gender, Your date of birth and Your pin code);

  • data regarding Your usage of the Services and history of the appointments made by or with You through the use of Services;

  • Address and GPS location of the User

  • name, qualification, experience, specialization, personal statement, education, professional memberships, GST and other statutory details , Drug license under the Drug and Cosmetics Act, 1940, registration certificate of the pharmacist along with membership number, website address (if any), working days and hours, contact data, demographic data, address, GPS Location, etc (for Pharmacies and Distributors)

  • information relating to the electronic device including but not limited to the type of electronic device You use, its unique device ID, its IP address and/or the device’s operating system etc.

  • other information that You voluntarily choose to provide to Us (such as information shared by You with Us through emails or letters).

  • The information collected from You by Us may constitute ‘personal information’ or ‘sensitive personal data or information’.

Personal Information” is defined under the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 (“SPI Rules”), to mean 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.

The SPI Rules further define “Sensitive Personal Data or Information” of a person to mean personal information about that person relating to:

  • passwords;

  • financial information such as bank accounts, credit and debit card details or other payment instrument details;

  • any detail relating to the above clauses as provided to body corporate for providing service;

In general, You can browse the Platform without telling Us who You are or revealing any Personal Information about Yourself. While You can browse some sections of Our Platform without being a Registered User, certain activities (such as placing an order, or providing a requisition) do require registration. Once You give Us Your Personal Information, You are not anonymous to Us. Where possible, We will indicate which fields are required and which fields are optional. You always have the option to not provide information by choosing not to use a particular service or feature on the Platform. In an effort to make Our Platform effective, certain information may be collected each time you visit the Platform. Such information may be stored in Our server logs. These encrypted statistics do not identify You personally, but provide Us the information regarding Your visit to the Platform and the type of user who is accessing Our Platform and certain browsing activities by You. This data may include: IP address of Your server from where the Platform is being accessed, the type of browser (Internet Explorer, Firefox, Opera, Google Chrome etc.), the operating system of Your system and the websites You last visited before visiting to Our Platform. The duration of Your stay on Our Platform is also stored in the session along with the date and time of Your access. These data are used by Us to understand the use and number of Users visiting the Platform. We will allow the updation of the Personal Information (including sensitive personal data or information) at any point of time to ensure that only the most updated, accurate and relevant information/documents are stored with Us.


We collect only such Personal Information that We believe to be relevant and is required to understand Your interests. The methods by which We collect Your Information include but are not limited to the following:

(i) When You register on Our Platform,

(ii) When You create a profile on Our Platform or as part of Services

(iii) When You provide Your Information to us,

(iv) When You use the features on Our Platform and/or when You use Services,

(v) When You access Platform or Services,

(vi) By use of cookies (discussed below).

When You use the Platform, Our servers (which may be hosted by a third party service provider) may collect information indirectly and automatically about Your activities on the Platform; for instance, by way of cookies. A cookie is a small amount of data that is sent to a User’s browser from a web server and is eventually stored on a User’s computer hard drive. This anonymous information is maintained distinctly and is not linked to the Personal Information You submit to Us.

Whether You want Your web browser to accept cookies or not is up to You. If You haven’t changed Your computer’s settings, most likely Your browser already accepts cookies. If You choose to decline cookies, You may not be able to fully experience all features of the Platform. You can also delete Your browser cookies or disable them entirely, but this may significantly impact Your experience with the Platform and may make parts of the Platform non-functional or inaccessible.

We may use third-party service providers to serve ads on Our behalf across the internet and sometimes on this Platform. They may collect anonymous information about Your visits to Our Platform and Your interaction with Our Services. No personally identifiable information is collected or used in this process. They do not know the name, phone number, address, email address, or any personally identifying information about the User.

We also use the log file like other servers which is the standard measures. They include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring / exit pages, platform type, date / time stamp, and number of clicks. We use them to analyse trends, administer the site, track a User’s movement and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to personally identifiable information. Some of the Services of Our Platform may also track the GPS location of the User in order to provide the Services.

We do not trade or sell Your Personal Information in any manner, except as specified herein, or if express consent is sought from You.

Some third parties provide Us with Personal Information about You, such as the following:

  1. information from third party sources: We may obtain information about You from other sources, including through third party services and organizations to supplement information provided by You. For example, if You access through Platform through a third-party application, such as an app store, a third-party login service, or a social networking site, We may collect information about You from that third-party application that You have made public via Your privacy settings. Information We collect through these services may include Your name, Your user identification number, Your user name, location, gender, birth date, email, profile picture, and Your contacts stored in that service.

  2. Information from Our advertising partners: We receive information about You from some of Our service providers, who assist Us with marketing or promotional services related to how You interact with Platforms, applications, products, services, advertisements or communications.


We collect Your Information for various purposes, including the following:

  1. to record, support and facilitate Your participation on the Platform.

  2. to respond to Your inquiries;

  3. to provide You with information about products and services available on the Platform;

  4. to personalize Your experience on the Platform;

  5. to help You address Your problems incurred on the Platform including addressing any technical problems;

  6. for proper administering of the Platform;

  7. to conduct internal reviews and data analysis for the Platform (e.g., to determine the number of visitors to specific pages within the Platform);

  8. to improve the services, content and advertising on the Platform;

  9. to protect the integrity of the Platform; and

  10. to respond to judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law.

  11. to conduct analytical studies on various aspects including user behaviour, user preferences etc

  12. to make disclosures as may be required under applicable law.

You acknowledge that apart from Your Personal Information, if You upload any content on the Platform, such content may contain information including Personal Information and the same may be available to the other users of the Platform. We will not be liable for the disclosure and dissemination of such Personal Information to third parties.

We may disclose aggregated information about the use of the Platform, but it will never contain Personal Information. We do not disclose Personal Information to third parties in the normal course of operations. However, in situations when We are legally obligated to disclose information to the government or other third parties, We will do so.

We implement standard measures to protect against unauthorized access to and unlawful interception of Personal Information. However, no internet site can fully eliminate security risks.

We may keep records of electronic communications and telephone calls received and made for placing orders for the purpose of administration of Services, customer support, research and development and for better listing of the Pharmacies and Distributors.


You are required to submit Your information at the time of using the Services. The information You share with Us is transferred and shared with Pharmacies and Distributors, as may be applicable, registered with the Platform. The said Pharmacies/Distributors may also have access to Your purchase history / details that You make from the Platform.

We may share Personal Information with Our other corporate entities and affiliates to help detect and prevent identity theft, fraud and other potentially illegal acts; correlate related or multiple accounts to prevent abuse of Our Services; and to facilitate joint or co-branded services that You may request where such services are provided by more than one corporate entity. Those entities and affiliates may not market to You as a result of such sharing unless You explicitly opt-in.

We also share Your Information when necessary to complete a transaction initiated or authorized by You or to provide You with a product or service You have requested. In addition to those set forth above, these parties also include: (i) other users (where You post information publicly or as otherwise necessary to effect a transaction initiated or authorized by You); (ii) social media services (if You interact with them through Your use of the Platform); (iii) third party business partners who You access through the Platform; (iv) third party payment providers (v) other parties authorized by You.

We also share Your Information when We believe it is necessary to:

  1. Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies

  2. Protect Us, Our business or Our users, for example to enforce Terms of Use, prevent spam or other unwanted communications and investigate or protect against fraud; and

  3. Maintain the security of Our products and services.

We also share Your Information with third parties when You give Us consent to do so.

Moreover, if We sell all or part of Our assets, or if Corporate Insolvency Resolution Process under the Insolvency and Bankruptcy Code, 2016 is initiated against Us, user information would be one of the assets that is transferred or acquired by a third party, and We would share Your Information with the party that is acquiring Our assets. You acknowledge that such transfers may occur, and that any acquirer of Us or Our assets may continue to use Your information as set forth in this Privacy Policy.

We may exchange, transfer, share, part with all or any of Your Information, across borders and from Your country to any other countries across the world with Our affiliates / agents / third party service providers / partners / banks and financial institutions for the purposes specified under this Privacy Policy or as may be required by applicable law or in case of sale, acquisition, merger or bankruptcy involving Us.

You acknowledge that some countries where We may transfer Your Information may not have data protection laws which are as stringent as the laws of Your own country.

You acknowledge that it is adequate that when We transfer Your Information to any other entity within or outside Your country of residence, We will place contractual obligations on the transferee which will oblige the transferee to adhere to the provisions of this Privacy Policy.


The Platform provides third-party advertisements and links to other websites. We do not provide any Personal Information to these third-party websites or advertisers.

The Platform will contain links to other websites (“Linked Site”), which are operated by third parties and are not controlled by, or affiliated to, or associated with, us unless expressly specified on the Platform. We are not responsible for any form of transmission, whatsoever, received by You from any Linked Site. Accordingly, we do not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor do We control or guarantee the accuracy, integrity, or quality of the information, data, text, software, music, sound, photographs, graphics, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any endorsement by Us of such website, the website’s provider, or the information on the website. The information provided by You to such third party websites shall be governed in accordance with the privacy policies of such websites and it is recommended that You review the privacy policy on any such websites prior to using such websites.

These third-party websites and advertisers may use technology to send the advertisements that appear on the Platform directly to Your browser. In such cases, the third party websites or advertisers automatically receive Your IP address. They may also use cookies, JavaScript, web beacons and other technologies to measure the effectiveness of their advertisements and to personalize advertising content. We do not have access to or control over cookies or other features that such third party websites and advertisers may use, and the information practices of these third-party websites and advertisers are not covered by this Privacy Policy. Please contact them directly for more information about their privacy practices.

We may also provide for third party payment provider’s links to provide for payment of Services availed by You on the Platform. They may collect details of Your Personal Information and/or financial information including credit/debit card details, net-banking or UPI details for facilitating the payment. This Privacy Policy does not apply to such third party payment providers. They are governed by their own terms and conditions and privacy policy. Please contact them directly for more information about their privacy practices.


A. For all Users:

This section applies to all users.

  1. Accordingly, a condition of each User’s use of and access to the Services is their acceptance of the Terms of Use, which also involves acceptance of the terms of this Privacy Policy. Any User that does not agree with any provisions of the same has the option to discontinue the use of the Platform.

  2. All the information provided to Us by a User, including Personal Information or any Sensitive Personal Data or Information, is voluntary. You understand that We may use certain information of yours, which has been designated as Personal Information or ‘Sensitive Personal Data or Information’ under the SPI Rules, (a) for the purpose of providing you the Services, (b) for commercial purposes and in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, (c) for sale or transfer of such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates (d) for communication purpose so as to provide You a better way of placing orders and for obtaining feedback in relation to the Pharmacies and/or Distributors, as maybe applicable and their practice, (e) debugging customer support related issues. We also reserve the right to use information provided by or about the User for the following purposes:

    • Publishing such information on the Platform.

    • Contacting Users for offering new products or services.

    • Contacting Users for taking products and Service feedback.

    • Analysing software usage patterns for improving product design and utility.

    • Analysing anonymized practice information for commercial use.

    If you have voluntarily provided Your Personal Information to Us for any of the purposes stated above, You hereby consent to such collection and use of such information by Us.

  3. Collection, use and disclosure of information which has been designated as Personal Information or ‘Sensitive Personal Data or Information’ under the SPI Rules requires Your express consent. By affirming Your assent to this Privacy Policy, You provide Your consent to such use, collection and disclosure as required under applicable law.

  4. We do not control or endorse the content, messages or information found in any Services and, therefore, we specifically disclaim any liability with regard to the Services and any actions resulting from Your participation in any Services, and You agree that You waive any claims against Us relating to same, and to the extent such waiver may be ineffective, you agree to release any claims against Us relating to the same.

  5. You are responsible for maintaining the accuracy of the information You submit to Us, such as Your contact information provided as part of account registration. If Your personal information changes, You may correct, delete inaccuracies, or amend information by making the change on Our Platform or You may send updates and corrections to Us at and We will take all reasonable efforts to incorporate the changes within a reasonable period of time. If You provide any information that is untrue, inaccurate, out of date or incomplete (or becomes untrue, inaccurate, out of date or incomplete), or We have reasonable grounds to suspect that the information provided by You is untrue, inaccurate, out of date or incomplete, We may, at its sole discretion, discontinue the provision of the Services to You. There may be circumstances where We will not correct, delete or update Your Personal Data, including (a) where the Personal Data is opinion data that is kept solely for evaluative purpose; and (b) the Personal Data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed.

  6. If You wish to cancel Your account or request that We no longer use Your information to provide you Services, contact Us through . We will retain your information for as long as Your account with the Services is active and as needed to provide You the Services. We shall not retain such information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force. 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, but Our use of the anonymized data will be solely for analytic purposes. Please note that Your withdrawal of consent, or cancellation of account may result in Us being unable to provide You with its Services, , or to terminate any existing relationship Us may have with you.

  7. If you wish to opt-out of receiving non-essential communications such as promotional and marketing-related information regarding the Services, please send Us an email at .

  8. A User may have limited access to the Platform without creating an account on the Platform. In order to have access to all the features and benefits on Our Platform, a User must first create an account on Our Platform. To create an account, a User is required to provide the following information, which such User recognizes and expressly acknowledges is Personal Information allowing others, including Us, to identify the User: name, User ID, email address, country, postal code, age, phone number, password chosen by the User, address and GPS Location. We may, in future, include other optional requests for information from the User to help Us to customize the Platform to deliver personalized information to the User.

  9. The Platform may enable User to communicate with other Users or to post information to be accessed by others, whereupon other Users may collect such data. Such Users, including any moderators or administrators, are not authorized Us representatives or agents, and their opinions or statements do not necessarily reflect Ours, and they are not authorized to bind Us to any contract. We hereby expressly disclaim any liability for any reliance or misuse of such information that is made available by Users or visitors in such a manner.

  10. We do not collect information about the visitors of the Platform from other sources, such as public records or bodies, or private organisations, save and except for the purposes of registration of the Users (the collection, use, storage and disclosure of which each User must agree to under the Terms of Use in order for Us to effectively render the Services).

  11. We maintain a strict "No-Spam" policy, which means that We do not intend to sell, rent or otherwise give Your e-mail address to a third party without your consent.

  12. We have implemented best international market practices and security policies, rules and technical measures to protect the personal data that it has under its control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. However, for any data loss or theft due to unauthorized access to the User’s electronic devices through which the User avails the Services, We shall not be held liable for any loss whatsoever incurred by the User.

  13. We implement reasonable security practices and procedures and have a comprehensive documented information security programme and information security policies that contain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of Our business.

  14. We take Your right to privacy very seriously and other than as specifically stated in this Privacy Policy, will only disclose your Personal Information in the event it is required to do so by law, rule, regulation, law enforcement agency, governmental official, legal authority or similar requirements or when We, in Our sole discretion, deem it necessary in order to protect Our rights or the rights of others, to prevent harm to persons or property, to fight fraud and credit risk, or to enforce or apply the Terms of Use.

B. For Registered Users:

This section applies to all users.

  1. As part of the registration as well as the application creation and submission process that is available to Registered Users on the Platform, certain information, including Personal Information or Sensitive Personal Data or Information is collected from the Registered Users.

  2. All the statements in this Privacy Policy apply to all Registered Users, and all Registered Users are therefore required to read and understand the privacy statements set out herein prior to submitting any Personal Information or Sensitive Personal Data or Information to Us, failing which they are required to leave the Services, including the Platform immediately.

  3. Registered Users’ personally identifiable information, which they choose to provide to Us, is used to help them describe and identify themselves. You will be the owner of Your information and You consent to Us for collecting, using, processing and/or disclosing this information for the purposes hereinafter stated. We may use such information for commercial purposes and in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, and may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates. We also reserve the right to use information provided by or about the Registered Users for the following purposes:

    • Publishing such information on the Platform (Pharmacies and Distributors only).

    • Contacting Registered Users for taking feedback.

    • Analysing software usage patterns for improving product design and utility.

    • Analysing anonymized practice information including financial, and inventory information for commercial use.

  4. We allow the listing of Registered Users’ information on the Platform. The information listed on Platform is displayed on Platform, and the information listed on Platform is used by the Users to avail Services. We display such information on Our Platform on an as-is basis making no representation or warranty on the accuracy or completeness of the information. As such, We strongly encourage the Users to check the accuracy and completeness of their information from time to time, and inform Us immediately of any discrepancies, changes or updates to such information.

C. For Casual Visitors:

  1. No sensitive personal data or information is automatically collected by Us from any casual visitors of this Platform, who are merely perusing the Platform.

  2. Nevertheless, certain provisions of this Privacy Policy are applicable to even such casual visitors, and such casual visitors are also required to read and understand the privacy statements set out herein, failing which they are required to leave this Platform immediately.

  3. If you, as a casual visitor, have inadvertently browsed any other page of this Platform prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is obtained, collected, processed, stored, used, disclosed or retained, merely quitting this browser application should ordinarily clear all temporary cookies installed by Us. All visitors, however, are encouraged to use the “clear cookies” functionality of their browsers to ensure such clearing / deletion, as We cannot guarantee, predict or provide for the behaviour of the equipment of all the visitors of the Platform.

  4. You are not a casual visitor if you have willingly submitted any personal data or information to Us through any means, including email, post or through the registration process on the Platform. All such visitors will be deemed to be, and will be treated as, Users for the purposes of this Privacy Policy, and in which case, all the statements in this Privacy Policy apply to such persons.


BittyBru strives to ensure the security, integrity and privacy of Your Personal Information and to protect Your Personal Information against unauthorized access or unauthorized alteration, disclosure or destruction. Your Personal Information is maintained by Us in electronic form on its equipment, and on the equipment of its employees. Such information may also be converted to physical form from time to time. We take all necessary precautions to protect your personal information both online and off-line, and implements reasonable security practices and measures including certain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of Our business.

No administrator at BittyBru will have knowledge of Your password. It is important for You to protect against unauthorized access to Your password, Your computer and Your mobile phone. Be sure to log off from the Platform when finished. We do not undertake any liability for any unauthorised use of Your account and password. If You suspect any unauthorized use of Your account, You must immediately notify Us by sending an email to So that such unauthorised access account shall be blocked by Us and data shall be be restored securely on further request.

We make all User information accessible to its employees, agents or partners and third parties only on a need-to-know basis, and binds only its employees to strict confidentiality obligations.

Notwithstanding the above, we are not responsible for the confidentiality, security or distribution of your Personal Information by Our partners and third parties outside the scope of Our agreement with such partners and third parties. Further, we shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of Ours including but not limited to, acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the User etc.


We have appointed a Grievance Officer to address any concerns or grievances that You may have regarding the processing of Your Personal Information. If You have any such grievances, please write to Our Grievance Officer at and Our officer will attempt to resolve Your issues in a timely manner.