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DPDPA Compliance for E-Commerce Platforms

Consumer Data Protection at Scale

9 min read28 November 2024
"E-commerce platforms process millions of transactions daily. Each transaction is a consent and privacy event."

E-commerce platforms operate at massive data scale, processing personal data across the entire customer lifecycle—from browsing to post-purchase support. DPDPA compliance must be embedded in every touchpoint.

1E-Commerce Data Lifecycle

Map DPDPA requirements to each stage of the customer journey.

  • Browsing: Cookie consent, analytics disclosure
  • Account creation: Registration consent, privacy policy acceptance
  • Purchase: Payment data handling, address collection
  • Fulfillment: Third-party logistics data sharing
  • Marketing: Separate opt-in for promotional communications
  • Support: Customer service data retention

2Marketplace vs. Inventory Model

Compliance architecture differs based on business model.

  • Inventory model: Platform is sole Data Fiduciary
  • Marketplace model: Platform and sellers may both be Fiduciaries
  • Marketplace: Seller access to customer data requires disclosure
  • Marketplace: DPAs required with seller partners
  • Both: Logistics partners are Data Processors
Counsel Advisory

Marketplace Complexity: Customers may not realize their data is shared with sellers. Transparent disclosure prevents regulatory and reputational risk.

Key Takeaways

1

E-commerce consent must cover entire customer lifecycle

2

Marketplace models create complex Fiduciary relationships

3

Marketing requires separate opt-in consent

4

Logistics partners require DPA coverage

5

Payment data attracts additional PCI-DSS requirements

Statutory References

Section 5 (Notice)Section 6 (Consent)Section 8(7) (Processors)Rule 4 (Consent Withdrawal)

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