PRIVACY POLICY
This privacy policy outlines how We make use of the information or your Personal Data that You submit to us during surfing, registration, or availing any of the services offered to You on the website – www.theEnthuCutlets.com. Please note that We reserve the right to modify and update this Privacy Policy at any time. To protect your interests, We encourage you to visit this page periodically to review the current terms of our Privacy Policy. Further, we will notify you through a separate intimation whenever we make any material changes in this privacy policy prior to giving effect to such changes.
By visiting this Website and/or Mobile Application, You agree to be bound by the terms of this Privacy Policy. If You do not agree, please do not use or access our Website. By continuing to use the Website, You expressly consent to the changes made in our Privacy Policy.
Please note that we are compliant with the (EU) 2016/679 (General Data Protection Regulation).
Henceforth, the Website shall be referred to as “Portal”.
Collecting Data
When You use our Portal, We collect and store information that you provide us in the course of your access to our Portal including your personal information (referred to as “Personal Data”) for the purposes of this Privacy Policy.
We collect, store and process your Personal Data through our Portal which we have listed below in detail:
Contact and Identity Related Data: full name, date of birth, age, gender, username, password, other registration information, personal description and/or photograph, billing address, email address, and telephone numbers including numbers used to call our customer care, your preferred mode of communication.
Technical Data: your Device, OS platform, version of OS, your UDID (Unique Device Identifiers, your IP address, your internet browser, data about how you use our Portal, information about your visit(s), your URL, date and time of visit, your searches and services availed, length of page visit, scrolling pattern, page response time, errors, your interaction within the portal, any unique internal identification number given to us by the Portal, installing add-ons or software for availing Services, information that is stored on your Device (mobile or tablet or computer) such as contact, login, audio-visual, images or written content.
General Data: Your submissions to us whether through emails or directly through the Portal, your comments on the Portal, purchases made or cancelled, interests, feedback, queries and survey results, your usage of the Portal, whether you like to receive marketing offers from us or our marketing partners.
We use different methods to collect data about you, and we have listed these below for your reference:
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When you access the Portal and browse through it;
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When you fill out the registration form and enter our Portal, making purchases on the Portal and/or avail Services, create an account on the Portal, log in, request for communication, make comments, upload images, write on the portal, make written submission in any form, answer a survey, provide feedback, interact within the Portal, request marketing options to be sent to you, respond to marketing sent, enter competitions or quiz, answer queries;
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When you generally browse through or use the Portal, we collect data about your activities on the Portal, we have in place technology that collects Technical Data (described above) about you.
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We also employ cookie technology to allow you to move more quickly through the Portal and to enhance user experience. Cookies are small text files a Website can use to recognize repeat users and facilitate the user's ongoing access to and use of the site. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use the Portal, but your ability to use some features or areas of our site may be limited. Additionally, the Portal also collects and uses your information through Google Adsense and Google Analytics. Should you choose to opt out of the Google Analytics Data Collection, you may do so on Google's website at https://tools.google.com/dlpage/gaoptout/. You can also opt out of Cookies by denying permission when asked through a pop-up.
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We also receive information about you from our marketing partners, server hosts, and other relevant third parties such as payment gateways, travel partners, quiz partners, competition holders, gift and giveaway partners, portals promoted through the Portal and vice-versa, third party advertising portals, third party analytics providers such as Google Analytics, or through publicly available information.
Processing Data
It is important for us to inform you that we process your personal data. As per the EU data protection laws, ‘processing’ means any action done in relation to the data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Such an action could be manual or automated.
Purpose and Use of Processing Your Data
We respect your privacy and treat it with utmost regard. We store and use your personal data including sensitive personal data for lawful purpose and in a lawful manner within bounds as prescribed by the applicable laws and EU data protection laws. We process your personal data for various technical and commercial purposes, most of which are done in order to provide you our Services, or to enhance your user experience, or to improve our Services, or to store your data in protected environment for which we need to bring on board necessary third parties.
Don’t worry, we only collect and/or use your personal data strictly in accordance with the lawful manner under the EU data protection laws.
To give you a better idea, we may process your personal data including sensitive personal data (health data) for the following purpose(s):
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It is necessary for the performance of the contract so as to make our Service available to you,
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To review your data to provide you with customized Services as the core purpose of Portal is to provide personalised Services that are unique to each of you.
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As part of legal compliance, or to provide it before a court of law or adjudicatory authority, if asked.
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We need to process your personal data to protect your vital interest or the vital interest of another person who is physically or legally incapable of giving consent, while providing you the Services so that you receive accurate and beneficial fitness and nutrition plans.
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For the purpose of our legitimate interest, which we shall update you about in case we process your personal data for this purpose.
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To undertake general website technical upgrade and better navigation.
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Processing and responding to queries and complaints received from you.
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Inform you of necessary changes and updates to Services and the Portal.
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Communicating with you on important health and nutrition issues, if you agree to receive communication from us in this regard.
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To carry out internal administration, running competitions, testing and research. To provide you with necessary information and marketing offers, in case you consent on receiving marketing offers from us.
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To resolve disputes; troubleshoot problems, help promote a safe service, collect fees owed, measure consumer interest in our products and services, customize your experience, detect and protect us against error, fraud and other criminal activity, enforce our terms and conditions.
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To advertise our Services and those of the Portal, in terms of testimonials, success stories etc. However, we will expressly seek your consent before we use your photograph publicly for this purpose if you have made it available to us voluntarily.
We may use your personal data to collect and analyze demographic and statistical data to compile and report statistics and health demographics to various interested third parties, with all the relevant personal and/or proprietary information which can be done for any purpose including research, statistical evaluation, and macro level health analysis. However, this shall be done only on a statistical or demographic level as a mass of data which is specifically de-identified prior to completion of such statistics where your personal data shall be used in a manner so that it does not directly link to you or reveal your identity as an individual, so as to remove it from under the purview of Protected Health Information. This may be done for our internal purpose such as customer experience enhancement or for sharing with health agencies or organizations which ultilize such data for research and development.
Disclosing Your Data
To provide you our Services and for the purposes set out in this Privacy Policy, we need to disclose your personal data including sensitive personal data in the following manner:
Within our internal team who use such data to provide you the best possible Service.
To various experts and consultants who work with us as consultants and are under similar confidentiality obligations as in this Privacy Policy to keep your data safeguarded.
To third parties whose services we avail for the purpose of technical aid such as processing data, such as data storage facilities, hosting servers, analytics firms, IT. Please note that all of these third parties work under similar data privacy obligations as us and we ensure that the same set of obligations flow in our contracts with them.
To third parties whose services we avail for the purpose of accounting and billing, shipping and fulfillment, internal administration, developing, delivering, and enhancing the Services we provide you through our Portal.
To our communication, outreach, networking, and advertising partners in case you allow us to do so as per this Privacy Policy.
To any third parties who we plan to buy, hold, merge with or acquire, or become a subsidiary of, whether in whole or part. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Policy.
To legal agencies or supervisory authority of the EU or other authority of applicable jurisdiction as per legal compliance.
To necessary agencies who help us in securing all the data processed by us such as for fraud detection or credit risk reduction.
To third parties such as research firms and think tanks for the purpose of research and analysis. Any data disclosed or transferred to such firms is always in the form of aggregated and pseudonymised information in the context of providing public information and conducting academic research without disclosing your individual identity.
Storage and Security of Personal Data
Your personal data including sensitive personal data is stored with industry recognized third party servers that are internally compliant with the data privacy regulations of EU. Consequently, they apply the best technological and operational safeguards to host your data in the safest and most secure environment possible. All passwords are saved in encrypted form.
However, please do understand no data stored or transmitted on the internet is completely safe. Therefore, it is not viable for us to provide you a hundred per cent guarantee that your data will be completely safe with our third party hosts, but rest assured that the safety measures we employ are in line with the standards imposed by the international data privacy laws.
Transfer
Your personal data including your sensitive personal data shall be transferred to our hosting servers that are based out of India. Our hosting servers employ an advanced form of data security measures while storing and transmission of your personal data.
Our legal basis for transferring your personal data to our hosting servers in India is based on your explicit consent. We shall expressly seek your consent at the time when you avail our Services or when you provide us any of your data for the first time.
Please note that if you do not allow the above, then we will be unable to provide you our Services through the Portal and therefore, we request you to please note use our Portal in case you do not wish your data to be transferred to our hosting servers.
Timing for Data Retention
We store and retain your personal data for as long as is necessary for the purpose we obtained it for. With the context that your personal data may be used for research purposes (as described above), we will retain any information held on an individual for up to 5 years after that you have ceased to use our Services. After this time, we shall delete your data held by us.
Your Data Related Rights
If you are based out of the European Union, then you are protected under the European Union’s data privacy laws (General Data Protection Regulation). Therefore, you have the following rights as a Data Subject:
i. PROCESSING YOUR DATA:
You have the right to restrict us from collecting or processing your personal data. However, please understand that we need your personal data to be able to provide you with our Services and in case, you do not wish to provide us with your necessary personal data, we shall not be able to provide you with the Services. In such a scenario, we strongly request you to please not visit or purchase products / services from our website.
ii. DISCLOSING YOUR DATA:
As described above, we disclose your personal data to concerned third parties in line with this Privacy Policy. You have the right to opt-out of this so we do not disclose your information. To request a restriction, please contact the Privacy and Security Officer whose contact information is below. When you visit or make a purchase on the Website, you may need to fill out certain personal information about You, such as your full name, physical and email address, information that allows us to process your payment to us etc. If you do not provide us with the necessary information, you may not be able to complete the registration process and thus, avail any of the services being offered by us.
Privacy and Data Protection Officer:
Shlagha Jindal
B-1005, Navnirman Apartments, Sector 2, Dwarka, New Delhi - 110075
+91 96437 25105
iii. ACCESS AND COPY OF DATA:
You have the right to access and copy your personal data stored or processed by us. Please write to our Privacy and Security Officer if you wish to access your information and we shall be happy to accommodate you within one month of your request. We may charge a fees or refuse to comply if we receive repetitive, exorbitant or numerous requests from you. Further, we may also take security measures to confirm your identity before we provide you access to your personal data. Further, we may also refuse to provide access to the data if we are not completely satisfied about your identity.
iv. DELETING YOUR DATA:
You have the right to request that all of your personal data processed by us be deleted. If you wish to do so, please contact your Privacy and Security Officer and we shall delete all of your personal data.
v. AMENDING OR UPDATING YOUR DATA:
You have the right to seek update or amendment of your personal data processed by us. If you wish to do so, please contact your Privacy and Security Officer and we shall amend your data within one month of your request. If however, we feel that your personal data is already updated or does not need amendment, we may deny such a request.
vi. AUTOMATED DECISION MAKING:
You have the right to object out of automated decision making and profiling or processing data for the purpose of automated decision making or profiling. If you choose to object, please contact our Privacy and Security Officer.
vii. DIRECT MARKETING:
You have the right to restrict us from using your personal data for the purpose of direct marketing or communication. Please contact our Privacy and Security Officer and we shall comply.
Limitation of Liability
The Company is not liable for any losses You incur as a result of someone else's use/knowledge of your account or password, either with or without your knowledge and approval. You may be held liable for any losses incurred by the Company, our affiliates, officers, directors, employees, consultants, agents and representatives due to someone else's use of your account or password.
Links to Third Parties
Our Site may provide links to other websites that may collect personally identifiable information about you. The Company is not responsible for the privacy practices or the content of those linked websites. You may be able to see various advertisements or solicitations on the Website. Should you choose to click on them, you will be bound by their Terms of Use and there is no link between such advertisement-destination websites and the Company. As such, no claims or complaints will accrue to the Company upon your use of advertisements and solicitations appearing on the Website.
Trademarks / Copyright Complaint
The Company respects the intellectual property of others. In case You feel that Your Trademark or Copyright or other intellectual property has been infringed, You can write to our customer service at hellocutlets@gmail.com.
Support
If you have any concerns or queries regarding our Privacy Policy, please write to us at hellocutlets@gmail.com.