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Privacy Policy

Effective Date:
XYZ beverages (“Company”, “we”, “our”, “us”) respects an individual’s privacy and is committed to protecting the same. This Privacy Policy (“Policy”) describes how we collect, use, disclose and transfer Personal Information (as defined below), through platforms of the individuals who browse, or access the Platform or provide information on or through the Platform, or whose information the Company otherwise collects, receives or processes in connection with the offer and sale of its products (“Products”) (hereinafter, collectively referred to as “Customers”, “you”, “your”) and ensure its compliance with applicable laws and regulations.
1. By accessing and/or using our Platform and providing the information as explained in this Policy, you consent to the collection and use of the information you disclose on the Platform in accordance with this Policy, including but not limited to your consent for sharing your information as per this Policy. We encourage you to read this Policy regarding the collection, use, and disclosure of your information. If you are not comfortable with any of the terms or policies described in this Policy, you may choose to discontinue usage of the Platform.
2. Further, you agree and consent to receive all communications related to our services on the mobile number provided by you to the Company, even if such mobile number is registered under DND/NCPR list under the Telecom Commercial Communications Customer Preference Regulations, 2018 (“TRAI Regulations”). Notwithstanding your registration with the National Do Not Call Registry (In Fully or Partly blocked category under National Customer Preference Register set up under the Telecom Regulatory Authority of India), you hereby express your interest and accord informed consent to receive communications (including commercial communications) in relation to the Company’s services. You further confirm that no communication to you from the Company or on behalf of the Company shall be construed as Unsolicited Commercial Communication under Regulation 2(bw) of the TRAI Regulations and you have specifically opted to receive communications in this regard on the mobile number provided by you.
3. For the purpose of this Policy, the term “Personal Information” shall mean any information that relates to you, which, either directly or indirectly, in combination with other information available or likely to be available with the Company, which is submitted to and/or collected over the Platform and maintained by the Company in an accessible form. However, any information available in public domain shall not be regarded as Personal Information for the purpose of this Policy.

COLLECTION OF YOUR PERSONAL INFORMATION

1. We communicate with you through a variety of means and channels, including our Platform, email, phone or text messaging on your mobile phone, although we do generally note that our preferred means of communication is email which has the least impact on the environment. Such communications may involve giving to you, as well as receiving information from you. We collect and receive the Personal Information in the following ways:
2. When you submit your Personal Information on our Platform: When you engage in certain activities on the Website, such as creating an account, ordering a product or service from us, submitting content and/or posting content in discussion forums, filling out a survey, posting a review, requesting information about our services, applying for a job (collectively, "Identification Activities"), we may ask you to provide certain information about yourself. It is optional for you to engage in an Identification Activity. If you elect to engage in an Identification Activity, however, we may ask you to provide us with certain Personal Information about you, such as
  • your first and last name
  • mailing address (including PIN code)
  • email address, telephone number
  • and date of birth, age and other details.
    • When you order products, we may also ask you to provide us with your credit card number, expiration date and authentication codes or related information. Depending on the activity, some of the information we ask you to provide is identified as mandatory and some is identified as voluntary. If you do not provide the mandatory information for a particular activity that requires it, you will not be permitted to engage in that activity. Further, we also collect and store your Personal Information through sponsored social media platforms, events, etc. To protect your privacy, you should not provide the Company with any information that is not specifically requested or that you do not wish to share. You can choose not to provide certain information, but then you might not be able to use our Platform or certain features of our Platform.
    3. Other sources: We might receive information about you from other sources, such as delivery and address information from third parties, which we use to correct our records and deliver your next purchase more easily. Further, we may receive information about you from third parties that feature our Products or promotional offers if you opt-in to receive information from us. You may also choose to participate in a third party application or social media sites through which you allow us to collect (or the third party to share) Personal Information about you, including usage information. We may also receive information, such as marketing related or demographic information about you from third parties to enhance our ability to tailor our content and offer you the Products that we believe may be of interest to you. The Company is not responsible for the privacy practices of such third-party websites which it does not own, manage or control.

    WHAT PERSONAL INFORMATION DO WE COLLECT?

    1. The Company limits itself to collect information which is necessary to ensure accurate services and is required to process your order of the Product or provide a refund and continually improve our Products and services.
    2. Following are the categories of Personal Information that is/ maybe collected and processed by us:
  • your name, e-mail and postal addresses, phone number(s), country;
  • date of birth, language preference, location;
  • any open data and public records such as information about you that is openly available on the internet;
  • names of people to whom purchases have been shipped including address, telephone numbers and IP addresses;
  • Product interest information and in certain circumstances, your opinions and individual preferences, etc.;
  • You may also provide us with information like financial information such as bank account or credit card or debit card or other payment instrument details, password for availing the Products at our Platform;
  • We may also maintain a record of your Product interests and acquire information about you from our future affiliates;
  • phone numbers used to call our customer service number.
  • We may collect and use technical data and related information, including but not limited to, technical information about your device, system and application software, and peripherals, that is gathered periodically to facilitate the provision of software updates, product support and other services to you (if any) related to the Platform.

    • WHAT IS THE PURPOSE FOR WHICH THE PERSONAL INFORMATION IS COLLECTED?

    The Company may use your Personal Information to:
    • 1. verify your identity;
    • 2. fulfill the Product purchases and transactions;
    • 3. communicate with you about your account and activities on the Platform;
    • 4. sign up for our newsletter, respond to a survey or marketing communication;
    • 5. allow us to serve you better in responding to your requests;
    • 6. to respond to reviews, comments, or other feedback provided to us;
    • 7. administer a contest, promotion, survey or other site feature;
    • 8. ask for ratings and reviews of the Products;
    • 9. follow up with you after correspondence (live chat, email or phone inquiries);
    • 10. allow you to log in with a social media account and share activities on your social media pages;
    • 11. comply with our legal obligations, policies and procedures, including compliance with relevant industry standards and the enforcement of our terms and conditions;
    • 12. help us learn more about your shopping preferences;
    • 13. conduct marketing and performance research to assist us in measuring our customer services, benchmarking our performance and to help us improve your shopping experiences and Product offerings;
    • 14. send communication related to order updates and offers through e-mail, SMS and social media channels;
    • 15. do internal research on our Customer’s demographics, interests, and behaviour to better understand and serve you;
    • 16. provide you with exclusive offers at the Platform, tailor content, advertisements, and improve the Platform and/or for internal business purposes;
    • 17. analyze trends, track Customer’s web page movements, help identify you and your shopping cart for aggregate use;
    • 18. establish, exercise or defend legal rights in connection with legal proceedings (including any prospective legal proceedings) and seek professional or legal advice in relation to such legal proceedings; and
    • 19. comply with any applicable law, regulation, legal process or enforceable governmental request.

    GROUNDS FOR YOUR PERSONAL INFORMATION:

    1. Performance of a Contract: some of the Personal Information processed is performed on the basis that it is necessary for the performance of our agreement with you. An example of this would be where we process your Personal Information for delivering the Products ordered by you on our Platform.
    2. Legitimate Interest: legitimate interests will include where we send you marketing information about our Products, communicate with you in order to serve you better.
    3. Compliance with a Legal Obligation: for certain types of processing it is necessary in order to allow us to comply with a legal obligation. An example of this would be where we are required to retain business records for fixed periods of time in order to comply with local legal requirements.

    CONSENT:

    1. By providing your consent/ information, you agree to the collection, use, storage, disclosure and otherwise processing of your information (including sensitive personal information) on the Platform in accordance with this Privacy Policy. If you disclose to us any personal information relating to other people, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
    2. You, while providing your personal information over the Platform, consent to us (including our other corporate entities, affiliates, lending partners, technology partners, marketing channels, business partners and other third parties) to contact you through SMS, instant messaging apps, call and/or e-mail for the purposes specified in this Privacy Policy.
    3. We may also collect and/or generate anonymized and aggregated information from your use of the Platform. The anonymized or aggregated information is not Personal Information since we are not able to re-identify you using any means available to us from that anonymized or aggregated information. The anonymized and aggregated information is used for a variety of functions, including to help us identify and remediate any bugs, and to improve the performance of our Platform. The Company may use such information in a number of ways, including internal analysis, analytics and research. We may share this information with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
    4. We maintain a social media presence, such as a facebook, instagram, youtube and a twitter feed. You can interact with us through social media, such as by entering our contests, posting content, sharing material from our Platform, and using our social media plug-ins. We may use the Personal Information during such interaction for the purposes described throughout this Policy.
    5. Payment Information: We collect card/debit card and other payment instrument (“Payment Information”) details from you when you set up an account or transact with us. The Payment Information is provided directly by you, via the Platform, into the PCI/DSS-compliant payment processing service to which the Company subscribes, and the Company does not, itself, process or store the Payment Information, except as stated herein.
    6. We maintain reasonable physical, electronic and procedural safeguards to protect your information. Whenever you access your account information, we offer the use of a secure server. Once your information is in our possession we adhere to our security guidelines to protect it against unauthorized access. However, by using the Platform, the users accept the inherent security implications of data transmission over the internet and the world wide web which cannot always be guaranteed as completely secure, and therefore, there would always remain certain inherent risks regarding use of the Platform. Users are responsible for ensuring the protection of login and password records for their account.
    7. We use third-party services to evaluate your use of the Platform, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Platform. You consent to the processing of information about you by these third parties in the manner and for the purposes set out in this Policy.
    8. At present we work with multiple third parties for data analytics and ensure data security/privacy through valid contracts.

    WHOM DO WE SHARE THE PERSONAL INFORMATION?

    1. Only the persons authorized by us shall have access to your Personal Information. We may share your Personal Information only to those mentioned below and they are either subject to this Policy or follow practices at least as protective as those described in this Policy:
    2. Our affiliates and third parties;
    3. Service providers who perform services on our behalf based on our instructions are not authorized to use or disclose such information except as necessary to perform services on our behalf or comply with legal requirements;
    4. We do not rent or sell your Personal Information to any third party.
    5. Should we plan to merge/sell all or substantially all of our business to another business entity or similar other transaction or be required by that business entity, we may transfer or disclose your Personal Information to that business entity who may collect, use or disclose such information for the purposes of evaluating the proposed transaction or for operating and managing the affairs of the acquired business or for other purposes identified in this Policy.
    6. We may share Personal Information with our other corporate entities who may use the said information in accordance with this Policy to help detect and prevent identity theft, fraud, and other potentially illegal acts; correlate related or multiple accounts to prevent abuse of our Platform. If you have any objection to such sharing, then we request not provide us with any information.
    7. We may retain other companies and individuals to perform functions on our behalf consistent with this Policy. Examples include order processing companies, courier companies, data analysis firms, customer support specialists, email vendors, web-hosting companies and fulfillment companies (e.g., companies that coordinate mailings). Such third parties may be provided with access to Personal Information needed to perform their functions but may not use such information other than on our behalf and in accordance with this Policy.
    8. In addition, in some instances, you may be offered the opportunity to consent to the sharing of your information with a third party such as an event or promotion co-sponsor. If you consent, we will share your information with such third party and the information you provide may be used by such third party for their own purposes and in accordance with their own policies.
    9. Notwithstanding anything contained in this Policy, we may disclose Personal Information if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to respond to any court orders or other legal processes. We may disclose Personal Information to law enforcement offices, third party rights owners, or others in the good faith belief that such disclosure is reasonably necessary to: enforce our Terms and Conditions or Policy; respond to claims that an advertisement, posting or other content violates the rights of a third party; or protect the rights, property or personal safety of our Customers or the general public.

    RETENTION OF PERSONAL INFORMATION

    1. We will retain your Personal Information only as long as it is reasonably required or otherwise permitted or required by applicable law or regulatory requirements. We may also retain your Personal Information so long as it is necessary to fulfil the purposes for which it was collected (including for purposes of meeting any legal, administrative, accounting, or other reporting requirements). Your Personal Information is safeguarded against inappropriate access and disclosure, as per this Policy. We may delete or anonymize Personal Information upon completion of its purpose.
    2. We also maintain appropriate and adequate administrative, technical and physical safeguards designed to protect your Personal Information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

    HOW WE STORE YOUR PERSONAL INFORMATION

    1. We may store Personal Information using our own secure on-site servers or other internally hosted technology. Your Personal Information may also be stored by third parties, via cloud services or other technology, with whom the Company has contracted, to support the Company's business operations.
    2. These third parties do not use or have access to your Personal Information other than for cloud storage and retrieval, and the Company requires such parties to employ at least the same level of security that we use to protect your Personal Information.

    DISPOSAL OF PERSONAL INFORMATION

    We will only use your Personal Information for purposes outlined under point 6 and will make sure that your privacy is protected. We shall take reasonable steps to delete or permanently de-identify Personal Information that is no longer needed.

    CUSTOMER COMMENTS AND CONTENT

    If you post any comments or content on our Platform, you should be aware that any information you choose to provide that may be read, collected, or used by the third parties. We are not responsible for the information you choose to submit, and we cannot guarantee that third parties have not made copies of or will not use such information in any way.

    LINKS TO THIRD PARTY ADVERTISEMENTS OR SITES

    We may display links to web sites that are owned or operated by third parties on our Platform. Please understand that these websites are independent from the Company, and the Company has no control over the content on that website, even if the Company provides information or Products to the owner of that website. The Company is not making any representations about, endorsing, or accepting any responsibility for the content or the use of such website. Further, we are not responsible or liable for any damage or loss related to the use of any third-party website. You should always read the terms and conditions and the privacy policy of a third-party website before accessing or using it.

    THIRD PARTY ANALYTICS:

    We use third-party analytics services to evaluate your use of the Platform, compile reports on activity, collect demographic data, analyze performance metrics, and evaluate other information relating to the Platform and mobile and internet usage. These third parties use cookies and other technologies to help analyze and provide us the information and, in some cases, connect such information with other data held by our, or third party, environments. You consent to the processing of information about you by these analytics providers in the manner and for the purposes set out in this Policy.

    SECURITY

    If you believe that you have found security vulnerability or Bug on any of XYZ beverages owned Website or Application, we encourage you to let us know straight away on xyz@abc Our Team will investigate all legitimate reports and do our best to quickly fix the problem. We endeavour to protect the Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification with security safeguards appropriate to the sensitivity of the Personal Information, regardless of the format in which it is held. We incorporate security measures such as encryption and authentication tools to protect your Personal Information from unauthorized use. Firewalls are utilized to protect our servers and network from unauthorized users accessing and tampering with files and other information that we store. However, we shall not be liable to you for any loss, damage (whether direct, indirect, consequential or incidental) or harm caused due to the unauthorized access or misuse of the Personal Information by any third party.

    WITHDRAWAL OR AMENDMENT OF PERSONAL INFORMATION

    In case you wish to amend/withdraw/erase your personal information stored by us, please raise a request for the same with our support team on community@xyz

    OPTING OUT FROM COMMUNICATION

    In case you wish to opt out from receiving promotional content and messages, please raise a request with our support team on - community@xyz

    THE DATA PRINCIPAL RIGHTS AS PER THE ACT ARE:

    1. The right to access information about personal data processed 2. The right to correction and erasure of data 3. The right to grievance redressal 4. The right to nominate a person to exercise rights in case of death or incapacity

    POLICY REVIEW

    We may update this Policy to reflect changes to our information practices.

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