D2C brands live on first-party data built through ads and CRM: emails, phone numbers and purchase history.
In short
D2C brands run on first-party data. The Act governs how you collect it, market with it, and let customers take it back. Penalties reach ₹250 crore.
What changes for this sub-sector.
Building a first-party list is fine; using it for marketing needs clear consent and an easy opt-out.
Meta and Google pixels and conversion APIs send personal data to ad platforms; consent and disclosure apply.
Profiling for segments and lookalikes is processing; be transparent and honour objections.
Handle access, correction and deletion, including from your email tool and CRM, on request.
Your email platform, CDP, reviews and support tools are processors under contract.
Keep customer data only while it serves a stated purpose.
Fix marketing consent and pixel disclosure first.
The readiness check flags consent, pixel and vendor gaps.
Take the readiness check →