1. Introduction to Privacy Policy

This privacy policy (" PRIVACY POLICY") applies to your use of the SUTVACHA website located at www.SUTVACHA.com  ("SUTVACHA" or " WEBSITE"), and SUTVACHA applications on mobile platforms (Android, IOS etc.) (collectively, the " PLATFORM"), but does not apply to any third party websites that may be linked to them, or any relationships you may have with the businesses listed on SUTVACHA.

The terms " WE", " OUR" and " US" refer to SUTVACHA and the terms " YOU", " YOUR" and " USER" refer to you, as a user of SUTVACHA. The term " PERSONAL INFORMATION" means information that you provide to us which personally identifies you to be contacted or identified, such as your name, phone number, email address, and any other data that is tied to such information including the heads outlined below. Our practices and procedures in relation to the collection and use of Personal Information have been setout below in order to ensure safe usage of the Website for you. An indicative list of the Personal Information being collected from you is set out below. Please note that the list above is only indicative, and as such, we may collect more information and data points from you, including as detailed in this Privacy Policy:

• Your full name;
• Contact details including phone numbers, physical address (along with the postal code) and email addresses;
• Government documents and identification numbers including your Permanent Account Number;
• Information from your email accounts (as permitted);
• Information from your device (as permitted);

The Personal Information enlisted above is not a mandatory requirement to register and use our Platform. You always have the option to not provide your Personal Information by choosing not to use a particular service or feature on the Platform. In general, you can browse the Platform without revealing any Personal Information about yourself. However, to create an account on the Platform, you must provide us with certain basic Personal Information required to provide customized services.

The Platform shall clearly display the Personal Information it is collecting from you, and you have the option to not provide such Personal Information. However, this may limit the services provided to you on the Platform. As such, the specifics of certain Information collected from you is detailed in this Privacy Policy.

1. Protection of your information

We have implemented reasonable security practices and procedures that are commensurate with the information assets being protected and with the nature of our business. While we try our best to provide security that is better than the industry standards, because of the inherent vulnerabilities of the internet, we cannot ensure or warrant complete security of all information that is being transmitted to us by you. By visiting this Website, you agree and acknowledge to be bound by this Privacy Policy and you hereby consent that we will collect, use, process and share your Personal Information in the manner set out herein below. If you do not agree with these terms, you may choose to not use SUTVACHA.

It is clarified that the terms nd conditions that are provided separately, form an integral part of your use of this Website and should be read in conjunction with this Privacy Policy.

While we are committed to maintaining confidentiality of all Personal Information, we shall not be responsible for any breach of security or for any action of any third parties that receive users' personal data or events that are beyond our reasonable control including, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, etc. All Personal Information collected from the users by us is maintained in electronic form on servers and/or cloud systems located in India. The Personal Information may also be converted to physical form from time to time. Regardless of the manner of storage, we will make commercially reasonable endeavors to ensure that the Personal Information is rendered confidential and will disclose Personal Information only in accordance with the terms of this Privacy Policy.

2. Information we collect and how we use it

We access, collect, receive and store your Personal Information. If you provide your third-party account credentials (" THIRD PARTY ACCOUNT INFORMATION") to us, you understand that some content and information in those accounts may be transmitted to your account with us if you authorise such transmissions and that Third Party Account Information transmitted to us shall be covered by this Privacy Policy. You may opt to not provide us with certain information, however that will restrict you from registering with us or availing some of our features.

We use commercially reasonable efforts to ensure that the collection of Personal Information is limited to that which is necessary to fulfill the purposes identified below. If we use your information in a manner different than the purpose for which it is collected, then we will ask you for your consent prior to such use. The Information collected by us is used for, amongst others, the following purposes:

• To identify and verify you;
• To identify and understand your needs and requirements;
• To set up, manage, facilitate, offer, enhance and improve the products and services to meet your requirements including those offered by third party service providers on our Platform;
• To monitor, administer and improve the Platform;
• To provide ongoing services and products;
• To meet legal and regulatory requirements;
• To resolve disputes, technical issues and troubleshoot problems;
• To enforce terms and conditions as agreed with you;
• To detect and protect you and ourselves from any error, fraud or other suspicious / illegal activities;
• To send communications notifications, Information regarding the products or services requested by you or process queries and applications that you have made on the Platform;
• To conduct 'know your customer' verification for our third-party lending partners based on the Information shared by you;
• For any analysis and information;
• To manage our relationship with you;
• To understand and analyze consumer interest and satisfaction in our products and services;
• To provide Information to you in relation to services and products being offered to you and other potential online and offline offers, products, services, and updates;
• To use the information as permitted under applicable laws in order to enable you to receive financial services from our lending partners and third party service providers; and
• Other reasons which, prior to being put into effect, shall be communicated to you through an update carried out to this Privacy Policy.

All Personal Information collected may be retained with us for such periods as may be necessary and to comply with our legal obligations, to resolve disputes, and enforce our agreements.

In respect of the proposed rules and regulations under the Personal Data Protection Bill, 2018 (" PROPOSED LAW"), we are cognizant of the requirements under the Proposed Law and as such we have revised our internal policies, procedures, working practices in order to meet the requirements of the Proposed Law. SUTVACHA is committed to be in compliance with the Proposed Law as both a processor and controller of personal data as and when the same is enacted and notified by the concerned governmental authority.

We regularly review this Privacy Policy and make sure that we process your Information in ways that comply with applicable laws and regulations.

3. Account information

If you create an account to take advantage of the full range of services offered on SUTVACHA, we ask for and record Personal Information such as your name, email address and mobile number. We may collect and store your Sensitive Personal Data or Information (such as any financial information including inter alia credit card, debit card details, bank account and know your customer (" KYC") documents as per RBI regulations and any other information as may be applicable) that the User may opt to save in the User account created with SUTVACHA. We use your email address to send you updates, news, and newsletters (if you willingly subscribe to the newsletter during signup, or anytime after signup) and contact you on behalf of other Users (such other Users who send you friend requests, personal messages, or other social collaboration based events). If you do not want to receive communications from us that are not relevant to you or your use of our services, please click on the unsubscribe link provided at the bottom of such e-mails sent to you by us. We use your mobile numbers to send you transaction alerts and SMS alerts based on your preferences. If you do not wish to receive such SMSes from us, please notify us at store@sutvacha.com to stop receiving SMSs from us. SUTVACHAassures that your Personal Information will not be made public or sold to any third party.

The User shall have an option of erasure of any information provided by the User including Personal Information. If a User opts for the said option of erasure, SUTVACHA shall delete all stored information of the User from its servers.

We also store customer information of customers making payments through SUTVACHA. However, only when customer chooses to share the information on the businesses powered with SUTVACHA applications we share the information to respective businesses. However, SUTVACHA is not liable in any way for any misuse of this information by the business or people related to the businesses to whom the information is shared by the customer.

4. Feedback

If you contact us to provide feedback, register a complaint, or ask a question, we will record any Personal Information and other content that you provide in your communication so that we can effectively respond to your communication.

5. Activity

We record information relating to your use of SUTVACHA, such as the searches you undertake, the pages you view, your browser type, IP address, location, requested URL, referring URL, and timestamp information. We use this type of information to administer SUTVACHA and provide the highest possible level of security and service to you. We also use this information in the aggregate to perform statistical analyses of User behavior and characteristics in order to measure interest in and use of the various areas of SUTVACHA. However, you cannot be identified from this aggregate information.

We own all the intellectual property rights associated with the Website and its contents. No right, title or interest in any downloaded material is transferred to you as a result of any such downloading or copying. The Website is protected by copyright as a collective work and/ or compilation (meaning the collection, arrangement, and assembly) of all the content on this Website, pursuant to applicable law.

Our logos, product and service marks and/ or names, trademarks, copyrights and other intellectual property, whether registered or not (" OUR IP") are exclusively owned by us. Without our prior written permission, you agree to not display and/ or use Our IP in any manner. Nothing contained in this Website or the content, should be construed as granting, in any way to the User, any license or right or interest whatsoever, in and/ or to Our IP, without our express written permission.

6. Cookies

We send cookies to your computer in order to uniquely identify your browser and improve the quality of our service. The term "cookies" refers to small pieces of information that a website sends to your computer's hard drive while you are viewing the site. We may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them). Persistent cookies can be removed by following your browser help file directions. If you choose to disable cookies, some areas of SUTVACHA may not work properly or at all. SUTVACHA uses third party tools, who may collect anonymous information about your visits to SUTVACHA using cookies, and interaction with SUTVACHA products and services. Such third parties may also use information about your visits to SUTVACHA products and services and other web sites to target advertisements for SUTVACHA products and services. No Personal Information is collected or used in this process. These third parties do not know or have access to the name, phone number, address, email address, or any Personal Information about SUTVACHA Users. SUTVACHA Users can opt-out of sharing this information with third parties by deactivating cookies, the process of which varies from browser to browser. Please refer to the help file of your browser to understand the process of deactivating cookies on your browser.

7. Camera Permissions

We require access to your camera and permissions thereof to ensure that the process of uploading pictures and graphics from your camera on your devices through which you access the Platform is a smooth process. For instance, you may need to click pictures of your government identity cards for the purposes of KYC obligations.

8. Enforcement

We may use the information we collect in connection with your use of SUTVACHA (including your Personal Information) in order to investigate, enforce, and apply our terms and conditions and Privacy Policy.

9. Transfer of information

We do not share your Personal Information with any third party apart from financial institutions such as banks, RBI or other regulatory agencies (as may be required) and to provide you with services that we offer through SUTVACHA, conduct quality assurance testing, facilitate creation of accounts, provide technical and customer support, or provide specific services, such as synchronization of your contacts with other software applications, in accordance with your instructions. These third parties are required not to use your Personal Information other than to provide the services requested by you.

We may share your Personal Information with our parent company, subsidiaries, joint ventures, or other companies under a common control (collectively, " AFFILIATES") that we may have now or in the future, in which case we will require them to honor this Privacy Policy. If another company acquires our company or our assets, that company will possess your Personal Information, and will assume the rights and obligations with respect to that information as described in this Privacy Policy. We may disclose your Personal Information to third parties in a good faith belief that such disclosure is reasonably necessary to (a) take action regarding suspected illegal activities; (b) enforce or apply our terms and conditions and Privacy Policy; (c) comply with legal process, such as a search warrant, subpoena, statute, or court order; or (d) protect our rights, reputation, and property, or that of our Users, affiliates, or the public. Please note that we are not required to question or contest the validity of any search warrant, subpoena or other similar governmental request that we receive.

We may disclose information in the aggregate to third parties relating to User behavior in connection with actual or prospective business relationship with those third parties, such as advertisers and content distributors. For example, we may disclose the number of Users that have been exposed to, or clicked on, advertising banners.

We will disclose the data / Personal Information provided by a user with other technology partners to track how the user interacts with the Platform. Personal Information will also be disclosed to our credit partners to perform credit checks and credit analysis.

We may also disclose Personal Information in our sole discretion, if we 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, without any notice to you. We shall not be responsible for the manner or method in which such institutions and authorities (to whom the disclosure is made) use or disclose such Personal Information.

10. Links

References on this Website to any names, marks, products or services of third parties or hyperlinks to third party websites or information are provided solely for your convenience and do not in any way constitute or imply our endorsement, sponsorship or recommendation of the third party, information, product or service. Except as set forth herein, we do not share your Personal Information with those third parties, and are not responsible for their privacy practices. We suggest you read the privacy policies on all such third party websites.

11. User access of Personal Information

At any point of time users can choose to edit/modify or delete/withdraw any Personal Information shared for use of the Platform. This can be done by accessing the "Account" section of this Website.

Please note that deleting or withdrawing Information may affect the services we provide to you. In case of modification of Personal Information, Users will be required to furnish supporting documents relating to change in Personal Information for the purpose of verification by the Platform. As such, Users have the option of restricting our access to their Information by means of implementing suitable device settings and/or deletion of their account. In order to remove any Personal Information from our servers, you may contact us, and seek deletion of such data. Notwithstanding the same, we are not under an obligation to delete this data if we are required to retain it under applicable law or require such Personal Information for the purposes of operating and/or improving the Platform.

12. Security

Your account is password protected. We use industry standard measures to protect the Personal Information that is stored in our database. We will occasionally reset or ask users to change account passwords as a precautionary measure.

We limit the access to your Personal Information to those employees and contractors who need access to perform their job function, such as our customer service personnel. All employees and data processors, who have access to and are associated with the processing of Personal Information provided by users are obliged to respect the confidentiality of every user's Personal Information. If you have any questions about the security on SUTVACHA, please contact us at store@sutvacha.com 

You hereby acknowledge that SUTVACHA is not responsible for any intercepted information sent via the internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner.

13. Terms and modifications to this Privacy Policy

Our Privacy Policy is subject to change at any time without notice. To make sure you are aware of any changes, please review this policy periodically. These changes will be effective immediately on the Users of SUTVACHA. Please note that at all times you are responsible for updating your Personal Information, including providing us with your most current e-mail address.

If you do not wish to permit changes in our use of your Personal Information, you must notify us promptly that you wish to deactivate your account with us. Continued use of SUTVACHA after any change/ amendment to this Privacy Policy shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

14. Applicable law

Your use of this Website will be governed by and construed in accordance with the laws of India. The Users agree that any legal action or proceedings arising out of your use may be brought exclusively in the competent courts/ tribunals having jurisdiction in KOLKATA in India and irrevocably submit themselves to the jurisdiction of such courts/ tribunals.

15. Consent and Binding Agreement

By using the Platform and by providing your Information, you:

• Consent to the collection, use, sharing and disclosure of your Personal Information on the terms and conditions, and in the manner contained in this Privacy Policy; and
• Agree that this Privacy Policy will form a binding legal agreement of between you and us.

We will publish any changes to this Privacy Policy on the Platform.

16. Complaints and Grievance Contact

Any complaints or concerns in relation to your Personal Information or content of this Website or comment or breach of use of the Website or any intellectual property of any User shall be immediately informed to the designated Grievance Officer as mentioned below in writing or through email signed with the electronic signature.

Grievance Officer: Iqbal Faiz

Website: www.SUTVACHA.com 

Address: Sutvacha Skincare Private Limited, 46A, Ballygunge Place, Nr South Point High School, Kolkata 700019

Email: store@sutvacha.com 

Phone: 91 9071 97 2222