PRIVACY AND COOKIES POLICY

1. WHAT PERSONAL DATA WE COLLECT AND WHY

We collect your personal data, with your consent, for a variety of purposes. When you subscribe to our email newsletter, complete a registration form and/or create a customer account on our website, we collect your first and last name, email address, postal address, phone number, and similar contact information. In creating your credentials used for authentication and customer account access, we collect a password and other security information that you provide. We also collect your image when you provide one for your user profile or customer account, or if you enter a Transformation/Any other Challenge. When you order products and complete a checkout form on our website, we collect data needed to process your order, including your billing and shipping information, phone number, business name if applicable, and your credit card number with associated security code. Without this data, we cannot enter into a contractual relationship with you and fulfil your order – see our Terms and Conditions for more information

When you email us via a contact form on our website or send us something via postal service, we collect your personal data so we can respond to you and keep a record of our correspondence.  We also collect your data when you opt-in to receive our email newsletter, when you submit comments, feedback, questions or product reviews, enter a contest or Transformation/Any other Challenge, and when you complete a survey or quiz on our website.

If we ever intend to change the purpose for which we use your personal data, we will obtain your consent for that new purpose prior to using your data.

We do not intentionally or knowingly collect sensitive personal information about you, meaning, any information that reveals your race or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information used to identify you, and any information concerning your health, sex life or sexual orientation.  If you share sensitive personal information with us, we may delete it with the understanding that you explicitly consented to its deletion.

Our website uses cookies to collect data about you and your web-enabled device (for example, your computer, smartphone or other device) – see the “How we use cookies and similar technologies” section, below, for more information.  We also collect your IP address and geographical location from which you accessed our website, your internet connection and browser type, and information about how you use our website (for example, which pages you view, when you view them, and what you click on).  We use this data to understand more about how you and other users interact with our website.

2. HOW WE USE PERSONAL DATA

We use your personal data to provide you with a rich and interactive experience on our website.  Your data is used to market and sell our products, to provide customer support, to fulfill your order requests and provide invoices, confirmations and updates, to improve and develop our products and website, to make product recommendations, and to send you promotional communications, targeted advertising and relevant offers.  We use your data to respond to your comments, feedback and questions, to notify you about changes to our website, to carry out our obligations from any contracts entered into between you and us (see our Terms and Conditions for more information), and to provide you with emails, if you have consented to receiving these from us.

The personal data we collect can tell us a lot about how you and other users interact with our website and other marketing communications.  We perform various data analytics to deepen our understanding of our website users.  We can improve our websites and marketing activities when we better understand usage behaviour.

Whenever required to do so, we will use personal data to comply with our legal obligations and any applicable laws and regulations.

3. WHERE WE STORE AND PROCESS PERSONAL DATA

We are based in India with only a local reach.  To market and sell our products online, we use various third party service providers that collect and process certain personal data on our behalf.  These third parties have servers located in India and other countries – see section “Who we share personal data with and why”, below, for more information.

4. WHO WE SHARE PERSONAL DATA WITH AND WHY

We do not sell or give away your personal data.  We may share aggregated statistics about our customers – this would involve aggregating or reasonably de-identifying personal data so that any information could not reasonably be used to identify you.

We will disclose your personal data in response to a court order or other governmental request, and in compliance with any legal obligation we must uphold.  We will also share your personal data in connection with a merger, sale of company assets, or acquisition of all or a portion of our business by another company.  In the unlikely event that we go out of business or enter bankruptcy, your personal data would likely be one of the assets that is transferred to or acquired by a third party.  If any of these business transfers happens, this policy would continue to apply to your personal data and the party receiving your data would continue to follow this policy.

5. HOW LONG WE RETAIN PERSONAL DATA

We store your personal data until it is no longer necessary for us to provide our products and services or until your customer account, or other data is deleted.  See section “How to access and control your personal data”, below, for information on how to delete your personal data.  When you make a purchase on our website, we retain your billing information and order details for at least the minimum number of years required for accounting and tax purposes.

We retain your personal data to comply with legal and regulatory requirements or for our legitimate purposes, such as responding to enquiries, and may sometimes need to keep it for a longer period.  If we do not need to retain it for as long, we may delete, destroy or anonymise it sooner.

6. HOW WE KEEP YOUR PERSONAL DATA SECURE

We use a range of measures to keep your personal data safe and secure.  We and our third party service providers use secure servers to store your personal data.  Secure Sockets Layer (“SSL”) technology is used to encrypt transfers of data to and from our servers and to encrypt payments you make on or via our website.  We require our staff and any third parties who carry out any work on our behalf to comply with appropriate compliance standards including obligations to protect personal data when using and transferring such data.  We use Shopify to store data on secure servers and create server logs used to ensure network security by detecting unusual or suspicious activity, preventing unauthorized access, and blocking distribution of malicious code.  Server logs collect your IP address, the webpages you access on our site, information you request and the date/time of your request, the source of your access to our website (for example, the website or link which referred you to our website), your browser version and your operating system.

If a data breach occurs and jeopardizes the security of your personal data, we will work with our third party service providers to address the breach.  We will notify users of our website of a data breach within whatever time frame is required by law.

7. HOW TO ACCESS AND CONTROL YOUR PERSONAL DATA

You can contact us at any time to request access to, deletion of and/or updates to your personal data.  Please contact our Privacy Officer through a registered post sent through India Post, outlining your request, at the address provided in the “How to contact us” section, below.  You can withdraw your consent at any time for anything you gave consent to.  You can also object to or restrict our use of your personal data.  If you have a customer account on our website, or you have posted any comments on our website, you can request to receive an exported file of your personal data.  You can also request that we delete any personal data we hold about you, excluding any data we are obligated to keep for administrative, legal or security purposes.  When you request access to your personal data, we are required to use all reasonable measures to verify your identity before granting access.  We do this to protect your data and limit the risk of potential identity fraud/theft or unauthorized access.  Finally, you have the right to contact the privacy or data protection regulator in India to make a complaint.

8. HOW WE USE COOKIES AND SIMILAR TECHNOLOGIES

9. COLLECTION OF PERSONAL DATA FROM CHILDREN

Our websites and marketing activities are not aimed at children, defined as individuals under the age of 13. We comply with the Indian Personal Data Protection Bill, 2019 (PDP Bill) and we do not knowingly collect personal data from children. If we become aware that we have personal data of children, whether through error, deception or fraud, we will delete the data unless there is a justifiable reason to retain such data in compliance with the PDP Bill.

10. CHANGES TO THIS PRIVACY AND COOKIES POLICY

We may modify this policy from time to time. When we do, we will provide notice to you by publishing the most current version and revising the date at the top of this page. If we make a material change to the policy, we will provide additional notice by sending you an email and/or displaying a prominent notice on our websites. By continuing to use our websites after changes to this policy come into effect, you agree to the revised policy.

10. HOW TO CONTACT US

If you have questions about this Privacy and Cookies Policy, please contact us at: