This document/page (“Privacy Policy” or “Policy”) is an electronic record in terms of the Information Technology Act, 2000, and rules thereunder as applicable and the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. A computer system generates this electronic record, which does not require any physical or digital signatures.

1. ABOUT THIS POLICY

This Policy outlines ASSIDUUS DISTRIBUTION PRIVATE LIMITED’s (“Assiduus”) Data Protection and Privacy policy and applies to your Personal Data which is processed by us, whether physically or electronically.

Assiduus is a company incorporated and registered under the provisions of the Companies Act, 2013, having its registered office at #11-13, 60 Feet Road, 5^th Block Koramangala, Bengaluru 340056, India. Assiduus is engaged in the business of facilitating selling, marketing, and retailing direct-to-consumer products (“Business”) through the e-commerce Platform developed and owned by Assiduus and/or its parent company, and/or their affiliates or offline stores/events to conduct its Business.

Please note that while you browse the platform (Website and App collectively referred to as “Platform”) from countries outside of India, we do not offer any product/service under this Platform outside India. By visiting the platform or providing your information, you expressly agree to be bound by this Privacy Policy and to be governed by the laws of India, including but not limited to the laws applicable to data protection and privacy. If you do not agree, please do not access or use our Platform.

2. DEFINITIONS

In this Policy, the expressions ‘Personal Information’, ‘Data Subject’, ‘Controller’, ‘Processor’, and ‘Processing’ shall have the meanings given to them in the applicable privacy laws. Throughout this document, “we”, “us”, “our”, and “ours” refer to Assiduus, and ‘you’, ‘your’, and ‘Customer’, this means YOU.

3. DATA CONTROLLER & DATA PROCESSOR

Under applicable law, we conduct our role and responsibilities as a Data Controller when collecting and processing Personal Information about you, and as a Data Processor when we collect and process Personal Information on behalf of another Data Controller

4. PURPOSE OF USE OF DATA

We use your personal information for the purpose of operating, providing, developing, and improving our products and services, including but not necessarily limited to:

• PURCHASE AND DELIVERY OF PRODUCTS AND SERVICES: to take and handle orders, deliver products and services, process payments, and communicate with you about orders, products and services, and promotional offers.
• PROVIDE, TROUBLESHOOT, & IMPROVE: to provide functionality, analyze performance, fix errors, and improve the usability and effectiveness of the Platform.
• Recommendations and Personalization: to recommend features, products, and services that might interest you, identify your preferences, and personalize your experience with the Platform.
• Communicate With You: to communicate with you about the Platform, including but not limited to its services and offerings, via different channels (e.g. SMS, WhatsApp, by phone, e-mail, chat).
• Advertising: to display interest-based ads for features, products, and services that might interest you.

5. DATA COLLECTION

We receive, collect, and store any information you provide while using the Platform, via information you have either provided directly on the Platform or have allowed us access to collect otherwise and in any other way.  If you are an international user accessing our Platform, we only collect strictly necessary data for the functioning of the Platform. If you choose not to provide certain information or decline to allow, you may be unable to use the Platform.

6. DATA TYPES

Categories of Personal Information collected and processed by us are a) demographic & Identity data such as contact details such as name, email address, contact number, shipping address, country, date of birth, and profile picture, b) open data and public records such as information about YOU that is openly available on the internet, c) details such as Transaction amount, bank name, card type, card number, d) online Identifiers and other technical data, e) location details such as data we get about your location, IP address, logs, or from where you connect a computer to the internet, f) technical details such as device information, location, and network carrier when you use our mobile applications, g) communications details such as the metadata and other Personal Information we get from communications done through e-mails, SMS, instant messages and calls, h) usage data details such as data about how you use our Platform or web-based properties, pages viewed, etc.

7. USE OF DATA

The information we receive or gather from you, personal or otherwise, may be used to register you, verify your identity to permit you to use the app, undertake transactions (including facilitating and processing payments), communicate with you (including responding to your requests), convey any promotional offers (including services or updates associated with Assiduus), customize and improve your experience on the platform, and generally maintain your accounts with us. Moreover, we use "cookies," and we obtain certain types of information when your web browser accesses our Services. We may also receive, collect, and store information about your location and your mobile device, including a unique identifier for your device. We may use this information for internal analysis and to provide you with location-based services, such as advertising, search results, and other personalized content.

8. INFORMATION CORRECTION

We might receive information about you from other sources, such as updated delivery and address information from our carriers, which we use to correct our records and deliver your next purchase more easily.

9. CONSENT

By using the Platform and/or by providing your information, you agree and consent to us collecting, storing, processing, transferring, using, and sharing your personal information (including sensitive personal information as per applicable law) that you disclose on the Platform with third parties or service providers for the purposes set out and following this Privacy Policy.

10. COOKIES AND OTHER TRACKERS USED BY OUR DIGITAL PROPERTIES

Cookies are small text files placed on your computer by websites that you visit. Similarly, there are other types of trackers used. Likewise, Mobile Apps use requisite permissions and SDKs. These are used to make websites & apps work or work more efficiently, as well as to provide information to the owners of the website/app.

We use cookies, permissions, and other trackers on our Platform to collect and process data to provide you with a better online experience as well as improve our services.

Depending upon the jurisdiction from where you might be accessing our Platform and as per applicable laws you may be served different types of cookies such as strictly necessary cookies, performance cookies, etc. 

For more information about cookies, and how to disable them, visit https://www.allaboutcookies.org. Below are the categories of cookies used on our website along with a description of what they are used for: 

• STRICTLY NECESSARY: These cookies are needed to run our website, to keep it secure if you are logged on, and to obey regulations that apply to us. If you are a customer, they help us know who you are so that you can log on and manage your accounts. They also help us keep your details safe and private.
• FUNCTIONAL: These cookies are used for remembering things like: a) your user ID on the log-on page, b) your region or country, c) your preferred language, and d) accessibility options like large font or high contrast pages.
• PERFORMANCE: These cookies tell us how you and our other customers use our website. We combine all this data together and study it. This helps us to: a) improve the performance of our services, and b) improve the products we provide. Most web browsers allow some control of most cookies through the browser settings. Please note disabling the ‘Strictly Necessary’ cookies may cause certain parts of our website to remain inaccessible to you. We use other tracking mechanisms in addition to the above such as: a) Pixel Tags, b) Log Files, c) Clickstream analytics.
• ‘DO NOT TRACK’: Some web browsers have a “Do Not Track” feature. This feature lets you tell websites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers. Our sites are not currently set up to respond to those signals.

11. DATA SHARING

11.1 PURPOSE OF DATA SHARING: We may share your Data with select third parties or group companies for the below purposes including but not limited to: a) order processing (for instance using a third-party order management system to track and document the orders you place with us), b) delivering packages (for instance using third party delivery service providers to ensure delivery of orders placed by You), c) sending emails communication and marketing assistance to optimize our methods and channels of communication with You, d) processing payments to enable secure and convenient modes of payment processing, e) providing customer support to collate Your queries received via different modes and ensure timely resolution, f) analyzing data to continuously better our services and for prevention, detection, mitigation, and investigation of fraudulent or illegal activities related to our products and services. We have put in place appropriate contracts and personal data protection obligations on the third parties engaged by us, and they are subject to strict contractual obligations when processing your personal data.

11.2 OTHERS WE MAY SHARE WITH: We may disclose your Personal Information for the above purposes to other parties including: a) other group companies and any subcontractors, agents or service providers who work for us or provide services to us or group companies (including their employees, sub-contractors, service providers, directors and officers), b) law enforcement authorities, government authorities, courts, dispute resolution bodies, our regulators, auditors and any party appointed or requested by our regulators to carry out investigations or audits of our activities, c) statutory and regulatory bodies and authorities (including the government) investigating agencies and entities or persons, to whom or before whom it is mandatory to disclose the Personal Information as per the applicable law, courts, judicial and quasi-judicial authorities and tribunals, arbitrators and arbitration tribunals, d) overseas regulators, and e) anybody else that we’ve been instructed to share your Personal Information with by you.

11.3 REASONS FOR SHARING: We may disclose your Personal Information to others where it is lawful to do so including where we or they: a) have a legal obligation to do so, e.g. to assist with detecting and preventing fraud, b) have requirement in connection with regulatory reporting, litigation or asserting or defending legal rights and interests, c) have a legitimate business reason for doing so, d) want to send you information and promotional material regarding our products and services, e) have asked you for your consent to share it, and you’ve agreed, f) improve your online experience for using our product, and g) to protect the safety of any person, or to protect our rights or the rights of those who use our products & services.

11.4 THIRD-PARTY SDKs: The Platform may contain third-party SDKs that collect personally identifiable information (PII). They use this information to better target users or provide elements of our products & services on behalf of us. These third-party sites have separate and independent privacy policies. We use the following SDKs:

SDKs	Purpose
Analytics	Analyze in-depth detail about the visitors on our app, settle errors, improve/better target users, and provide push notifications and digital ads to the users (for example, Clevertap, Appsflyer, Crashlytics, and Gamooga)
Payment	Complete customers’ payment transaction (for example, PayU, Razorpay, and Cashfree)
Login	Help users login on the Platform (for example, Google, and Facebook)

12. Cross-Border Data Transfer

Personal Information we hold about you may be transferred to other countries outside your residential country for any of the purposes described in this Privacy Policy.

You understand and accept that these countries may have differing (and potentially less stringent) laws relating to the degree of confidentiality afforded to the information it holds and that such information can become subject to the laws and disclosure requirements of such countries, including disclosure to governmental bodies, regulatory agencies and private persons, as a result of applicable governmental or regulatory inquiry, court order or other similar process. In addition, a number of countries have agreements with other countries providing for exchange of information for law enforcement, tax and other purposes.

If we transfer your Personal Information to third parties for purposes stated in this Privacy Policy, we will use best endeavors to put in place appropriate controls and safeguards to ensure that your Personal Information is kept accurate, adequately protected, and processed only for specified and reasonable purposes in a manner that is fair, transparent and has a lawful basis, and is stored for no longer than is absolutely necessary.

13. DATA SECURITY

We are committed to protecting your Personal Information in our custody. We take reasonable steps to ensure appropriate physical, technical and managerial safeguards are in place to protect your Personal Information from unauthorized access, alteration, transmission and deletion. We work to protect the security of your personal information during transmission by using encryption protocols. We use multi-layered controls to help protect our infrastructure, constantly monitoring and improving our applications, systems, and processes to meet the growing demands and challenges of security. We ensure that the third parties who provide services to us under appropriate contracts, take appropriate security measures to protect your Personal Information in line with our policies.

14. RETENTION AND DISPOSAL OF DATA

We keep the Personal Information we collect about you on our systems or with third parties for as long as it is required for the purposes set out in this Privacy Policy and for legal or regulatory reasons. We will only use your Personal Information for those purposes 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.

15. LINKS TO OTHER WEBSITES

Our Platform may contain links to the websites of other organizations. This privacy policy does not cover how that organization processes Personal Information. We encourage you to read the privacy policies on the other websites you visit.

16. CHILDREN’S PRIVACY

Our platform is directed to be used by adults only. If you are not an adult, while you may look at our site, you should not make a purchase, register, or submit Personal Information to us. We or our associates /affiliates do not knowingly collect information from minors.

17. CONSUMER/USER RIGHTS

We understand that when you interact with Assiduus, you have rights over your Personal Information. These rights involve providing reasonable steps to allow you to access your Personal Information, and correct any errors among others. If you are not satisfied with our response or have unresolved concerns, you can get in touch with us to resolve the issue using privacy@aacarto.com

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