Privacy Policy

INTRODUCTION

  1. This document is published in accordance with the provisions of Information Technology Act, 2000 and Rule 4(1) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 which requires the publishing of a privacy policy for handling of or dealing in personal information including sensitive personal data or information. Below described privacy policy (“Privacy Policy”) is applicable when services of Anaar are availed either directly or through merchant partners for any [payment] transaction with Anaar.

  2. The words “Anaar”, “we”, “our” and “us” refers to Kleo Consumer Brands Private Limited, hereinafter referred to as “Kleo”, a company incorporated under the laws of India and having its registered office at 903, Floor-9, Plot- 211, B wing, Dalamal Towers, Free Press Journal Marg, Nariman Point, Mumbai, Maharashtra - 400021.

  3. The words "you", "your" or "yours" refer to any person who is using, accessing or browsing or has used, accessed or browsed the Site (as defined below) and/or is using or accessing or has used or accessed any version of the Anaar mobile application (“App”) and/or has availed the services offered by us. The terms / words not defined herein shall have the same meanings as defined in the Terms and Conditions (as defined below) applicable to the use or user of Anaar website or any other website created by Anaar, as may be modified by Anaar from time to time (“Site”) and the use or user of the App.
  4. We are engaged in the business of sale & marketing of luxury wedding footwear. Like our service, we keep things simple and easy. We value your privacy and security and follow the highest industry standards and practices to ensure the information you provide to us is secure.

INFORMATION COLLECTION, USE, HANDLING AND SHARING 

Use of information for access to Site and/or the App and/or services of Anaar:
  1. This Privacy Policy contains provisions regarding collection, usage, storage, handling and sharing of information that you share on the Site and/or the App. For the purpose of this Privacy Policy, the type of information collected and handled by us includes:

    (a) “Personal Information” means the data or information relating to a natural person which, either directly or indirectly, in combination other available or likely to be available information, can be used to identify such person and includes mandatory or voluntary disclosures that you make while and for using the Site and/or the App and/or the services offered by us, including but not limited to your name, address, telephone number, email address, images, etc. as may be provided by you while using the Site and/or the App and/or the services offered by us.

    (b) “Sensitive Personal Data or Information” or “SPDI” shall have the meaning given to the term under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. Provided that any personal and sensitive information provided by you will not be considered as SPDI if it is freely available and/or accessible in the public domain. Further, any reviews, comments, messages, blogs posted/uploaded/conveyed/communicated by users on the public sections of the Site, or an Application Store (like the App Store or Play Store) becomes published content and is not considered personal and/or sensitive information subject to this Privacy Policy.

  2. To avail certain services on the Site and/or the App, users are required to provide some personal and sensitive information for the registration process including without limitation (a) your name, (b) email address, (c) phone number, (d) access to your phone’s text messages (SMS) inbox records/ logs, (e) phone contacts, (f) location information (GPS, IP address and cell tower location), (g) information pertaining to your mobile device and your usage thereof (including the names of other applications installed on your mobile device and how you use them, information about your use of features or functions on your device), and any other such information as required. We collect the aforementioned information when you download and install the App and give the permission to read information from your device. The information as supplied by the users enables us to improve the Site and/or the App and provide you the most user-friendly experience. Further, we collect information about your SMSs to help us to keep track of multiple bank accounts of our users in one platform and also to establish their financial status and credit history. All required information is service dependent, and we may use the above said user information to maintain, protect, and improve the Site and/or the App and for developing new services. 

  3. Kindly note that we may also require credit card or debit card details for facilitating payments, however, such details shall not be stored or used by us in any manner other than in accordance with the Terms and Conditions.

  4. The information collected is relevant and necessary to understand you or your online browsing search pattern. The information is collected with an intention to provide you with updated information, help regarding usage of the Site, the App or new services, offers, if any, that we think you might be interested in, to carry out follow ups, to assist with customer service or technical support issues, to enforce the Terms and Conditions or to prevent fraud and unlawful use. We will use the information provided by you only for the purposes for which it is consensually collected, as more particularly described hereunder and/or indicated to you while using/ accessing the Site and/or the App.

  5. We may also use your phone number, email address or other personal and sensitive information to send commercial or marketing messages without your consent. We may, however, use your email address and phone number without further consent for non-marketing or administrative purposes (such as notifying you of major changes, for customer service purposes, providing information about updates to the Site and/or the App, etc.). 

  6. In case you choose to decline to submit your Personal Information and/or SPDI on the Site/App, we may not be able to provide certain services on the Site/App to you. We will make reasonable efforts to notify you of the same at the appropriate time. In any case, we will not be liable and or responsible for the denial of certain services to you for lack of you providing the necessary information. 

  7. When you register with the Site and/or the App, we may contact you from time to time about updation of your personal information to provide such features that we believe may benefit/interest you. 

  8. It may be noted that we have strict guidelines with respect to unauthorized access to information provided by you. However, we may pass or disclose your Personal Information to other third parties in certain scenarios including the following:
    • to procure credit reports from credit bureaus and identity verification services (such as those provided by UIDAI);
    • to help us process questions you may have about the Site and/or the App and/or the services offered by Anaar;
    • To confirm or correct what we know about you; 
    • We may pass your Personal Information to our employees, contractors, suppliers and/or agents to administer the services provided to you by us now or in the future; 
    • To help us or law enforcement agencies prevent fraud, money laundering, terrorism and other crimes. Also, we may disclose your Personal Information to the police, regulatory bodies or legal advisers in connection with any alleged criminal offence or suspected breach of this Privacy Policy and/or the Terms and Conditions or otherwise where required by law and we will co-operate with any law enforcement authorities or court order requesting or directing us to disclose the identity of or locate anyone breaching this Privacy Policy or otherwise for the prevention or detection of crime or the apprehension or prosecution of offenders; 
    • Assisting an agency in undertaking information for us; 
    • If another organization is engaged by us to perform tasks on our behalf; 
    • To enable other organisations, business partners or associates in administering services (including improved services) to you by us or them now or in the future. 
    • Compliance with an audit on our business; 
    • If we sell all or any part of our business or merge with another company; 
    • If it is necessary for legal proceedings and when we believe in good faith that any applicable law, regulation, government, regulatory or other authority, agency or officer requires it or to protect the safety or security of users of the Site and/or the App; 
    • If we use third party processors to administer and process your Personal Information for the purposes notified in this Privacy Policy, e.g. for hosting activities related to the use of the Site, the App or the services offered by Anaar; 
    • To obtain advice from third parties such as auditors or legal advisors. 
    • With our group or affiliates companies to further enhance our products and services for you.

  9. In addition to the above, disclosures may also be made if it was clearly stated at the time of registration and, where required, if you have given permission for this. Generally, we will disclose only the information we consider reasonably necessary to disclose. Also, some general statistical information about the Site/App user base, traffic volumes and related matters may be passed on to reputable third parties, but these details will not include information personally identifying you.

  10. In the event you submit any comment or feedback on the Site and/or the App, we may (but not obliged to) publish your comments or feedback (including images) online or offline to promote our business and services. We will collect your name which will be displayed next to your comment, and e-mail address, which will not be published, but which we may use to contact you in relation to your comment. From time to time, we may ask you for your opinion on our services. When we do surveys wherein we may use Cookies (as defined below) or other on-device storage and may combine the information collected by those Cookies or other on-device storage with your answers. We will make sure that the survey results do not identify you, or anyone else who fills in our surveys.

  11. What we know about you we get mostly from you. But we may also have to find out more about you from other sources in order to verify the information submitted by you, and to make sure that what we know about you is correct and complete satisfaction of Kleo. This kind of verification is primarily done in order to address various security concerns, and to ensure that you comply with the provisions of applicable laws, and the terms and conditions available on the Site and the App (“Terms and Conditions”) and other terms and conditions as may be prescribed by us from time to time.

  12. Your Personal Information may also be used by us to: (i) Monitor, develop and improve the Site, the App and services offered by Anaar and your experience; (ii) Assist in and administer the provision of services offered by Anaar to you; (iii) Process and deal with any complaints or enquiries made by or about you, and (iv) Investigate any suspected breach of the Terms and Conditions or the breach of other terms and conditions otherwise relating to you and to monitor compliance including by way of checking postings or submissions to the Site and/or the App.

  13. You hereby agree and acknowledge that by accessing and browsing the Site and/or accessing and using the App, you consent to us undertaking the following: (i) Send you and keep you updated with information by email, telephone (including SMS) or mail about existing and new services and benefits from us; (ii) Use the information for marketing and for market research/industry/sector analytics purposes, including internal demographic studies, to provide, optimize and personalize our services and to further enhance our products and services for you and to send you newsletters and information about our services. 

  14. The information is readily available on the Site and/or the App and only viewable by you after logging on to the Site and/or the App. You, at all times, have the option not to provide any Personal Information or other information about you without agreeing to register on the Site and/or the App and otherwise withdraw your consent or request to remove/ delete your information by communicating the same to us in the manner stipulated in the Terms and Conditions and the policies of Anaar. Upon withdrawal, Anaar will have no obligations towards you nor will it be liable in relation to any services offered by us during the time you had consented to retain the information with us. Alternatively, you can uninstall the App in its entirety, in which event, your consent would be deemed to be withdrawn.

  15. Please note that if you opt out from providing personal or other information requested by us, you may not be able to access certain areas of the Site and/or the App and/or avail certain services offered by Anaar. However, it may be noted that Anaar reserves the right to send service related and your specific and preferred transaction related communication without offering you the facility to opt-out. You can update your Account Information (defined below), Personal Information and other information at any time. At your request, Anaar can also cancel your registration and remove/block your Personal Information from its database/ Site and/or the App. However, this information may remain in our archive even after deletion or termination of your account as required by law and the handling of the same is in accordance with the provisions of the applicable law and as intimated by the government agency from time to time.

  16. In relation to any payment made through the Site and/or the App and/or the services offered by Anaar, the online payment gateway operated by third party is being used by Anaar. It may be noted that the information that you provide at the time of making any payment through the Site and/or the App and/or services offered by Anaar is held and stored with third party payment gateway operator authorized at multiple points. The payment gateway operator may also have access to your online payment history/details in relation to the payment made through the Site and/or the App and/or the services offered by Anaar. These payment gateways are digitally encrypted, thereby providing the highest possible degree of privacy and care available, currently. Whilst we are unable to guarantee 100% (One Hundred percent) security, this makes it hard for a hacker to decrypt your details. You are strongly recommended not to send full credit or debit card details in unencrypted electronic communications with us. Also, you are responsible for protecting against unauthorized access to your password and to your computer or mobile. We will not be liable for the disclosure and dissemination of Personal Information to third parties which you as prudent user put up on the Site and/or the App, and available to the other users of the Site and/or the App.

  17. It may be noted that Anaar handles all such information in accordance with the provisions of the applicable law as may be applicable from time to time and only for the duration lawfully required, there under. We may disclose aggregated information, including to aggregators, about the use of the Site and/or the App without Personal Information. Anaar implements standard measures to protect against unauthorized access to and unlawful interception of Personal Information. However, we feel prudent to inform you that no internet site can fully eliminate security risks and enforcement of privacy laws are at a developing stage in some parts of the world.

  18. We take reasonable steps to ensure that your SPDI is handled securely and is retained only for so long as is necessary for the purpose for which it was collected, unless a longer period of retention is required under lawful contract or by applicable law.

USE OF COOKIES

  1. By using or accessing the Site, our servers (hosted by a third party service provider) may collect information indirectly and automatically about your activities on the Site by way of cookies. For the purpose of this Privacy Policy, “Cookies” are pieces of information that a site sends to your computer or other media device while you are viewing or interacting with the site. We use Cookies and other such devices to compile anonymous, aggregated statistics that allow us to understand how users use our Site and to help us improve the structure of our Site (we cannot identify you personally in this way). Further it allows us to understand who has seen which pages and advertisements on the Site, to determine how frequently such particular pages and advertisements are visited, to determine the most popular areas of the Site and generally in order to monitor usage of the Site. We may combine your visitor session information or other information collected through Cookies and other technical methods with personally identifiable information in order to understand and improve your online experiences and to determine what category/nature of businesses and locations you prefer or are likely to be of interest to you. This information is not linked to your Personal Information and is maintained distinctly.

  2. You may also get Cookies from our advertisers. We do not control these Cookies, and once you have clicked on the advertisement and left the Site, our Privacy Policy no longer applies. We are not responsible for collecting Cookies through Linked Sites (defined below), neither is it liable for misuse of the information you provide to Linked Sites.

  3. It is clarified that we store information including Personal Information only in the manner contained herein and in accordance with the provisions of applicable law.

  4. You can change your web browsers settings to accept or not to accept Cookies. We may use third-party service providers to serve ads on its behalf across the internet and sometimes on the Site. Such third party service providers may collect anonymous information about your visits to the Site and use of the services offered by us. Personally identifiable information is not linked to data collected from this source.

  5. The Site could use log file including internet protocol addresses, browser type, internet service provider, referring/exit pages, platform type, date/time stamp, and number of clicks to analyse trends, administer the Site, track user movement and gather broad demographic information for aggregate use. These are not linked to information identifiable personally.

THIRD PARTY WEBSITES

  1. The Site may link you to other websites or platforms (“Linked Sites”, “Third Party Links” or “Third Party” or “third parties”) which may require you to disclose their information. You acknowledge and agree that we are not responsible for the way in which third party websites operate or the way in which they may process any information including Personal Information, which you provide to them. It is important that you understand this and check their respective privacy policies and terms of use. We will only collect, process and use other personal data from websites operated by third parties in accordance with applicable laws. You acknowledge and agree that, to the fullest extent possible under applicable law, we are not liable for any loss or damage which may be incurred by you or any member as a result of the collection and/or disclosure of information via Third Party Links, as a result of any reliance placed by them on the completeness, accuracy or existence of any advertising, products services, or other materials on, or available via such Third Party Links. This will include all transactions, and information transmitted therein, between you or any member and any such Third Party Links or applications or resources, such transactions are strictly bi-partite. We shall not be liable for any disputes arising from or in connection with such transactions between the members and the aforementioned third parties.

  2. Such Third Party Links, and external applications or resources, accessible via the Third Party Links may have their own privacy policies governing the collection, storage, retention and disclosure of information that the members may be subject to. We recommend that you familiarise yourself with such policies and exercise reasonable diligence, as you would in traditional offline channels and practice judgment and common sense before committing to any transaction or exchange of information, including but not limited to reviewing the third party website or application’s privacy policy.

SECURITY

  1. We take precautions to protect your information including your SPDI. When you submit sensitive information via the Site and/or the App, your information is protected both online and offline. Wherever we collect sensitive information (such as credit card data or other payment preferences), that information is encrypted and transmitted to us in a secure way by using secured sockets layer (SSL) encryption.

  2. While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service or responding to legal requests) are granted access to Personal Information. The servers in which we store Personal Information, SDPI and payment information are kept in a secure environment with required isolation.

  3. We strive to ensure the security, integrity protection and privacy of your Personal Information against unauthorized access or unauthorized alteration, disclosure or destruction. We follow stringent security techniques and requirements for handling sensitive and Personal Information. These techniques and requirements are fully compliant with the guidelines set forth under the applicable laws. Our servers are accessible only to authorized personnel. Your information covered under this Privacy Policy is shared with respective personnel only on need to know basis and/ or to provide the services you have requested. All representatives handling information under these provisions are under contractual confidentiality obligation with Anaar. While we take every step to safeguard the confidentiality of your Personal Information, by using the Site and/or the App, you agree and confirm that we are not liable for any negligence, disclosure due to errors in transmission or unauthorized acts of third parties or Linked Sites.

  4. Notwithstanding the foregoing, you must keep account details, including your username and password (“Account Information”) confidential at all times, and should not reveal the same to any third parties. You must take appropriate security measures to prevent unauthorized disclosure of your Account Information (including logging out from your account at the end of each session), and you must notify us immediately if your Account Information becomes known to any unauthorized user. You are solely responsible for maintaining the confidentiality of your Account Information, and all activities that occur under your account(s). Any breach of this Privacy Policy by anyone to whom you disclose your account details, including your username and password will be treated as if the breach had been committed by you, and will not relieve you of your obligations under this Privacy Policy and the Terms and Conditions.

  5. Notwithstanding anything contained herein, we shall not be liable for any loss, damage or misuse of your Personal Information including SPDI due to a Force Majeure Event. A “Force Majeure Event” for the purposes of this Privacy Policy shall mean any event that is beyond our reasonable control and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, unauthorized access to computer data and storage device, computer viruses breach of security and encryption or any other cause beyond our control.
REGISTRATION

To avail any of the services offered by us, you are required to register and open an account with us by using the Account Information. You agree to provide correct information towards your continued usage of our service. We will save your Account Information, including identification (as profile), payment (as saved accounts) and transaction (as transaction history) related information to process your requests faster and securely for your convenience.

ACCEPTANCE TO TERMS
  1. By using, accessing, clicking any relevant icon or button on the Site and/or the App and/or registering on the Site and/or the App or using the services offered by us, you are agreeing to this Privacy Policy and the Terms and Conditions and are providing us your affirmative consent that we can collect, store, handle, process and transfer your information including Personal Information and Account Information. You also confirm that you understand that such collection, storage, handling, processing and transferring is lawful, necessary and permissible under the applicable laws. 

  2. By using the Site and/or the App and/or the services offered by us or by otherwise giving us your information, you will be deemed to have the capacity to enter into a legally binding contract the Indian Contract Act, 1872, and consequently, you will be deemed to have read, understood and agreed to the practices and policies outlined in this Privacy Policy and agree to be bound by the same.

  3. By using the Services, you agree and acknowledge that your Personal Information may be transferred within national boundaries. You acknowledge that in the process of providing the services through the Site and/or the App, some activities relating to handling of information collected under the Privacy Policy may be done by our trusted third-party vendors or agents, web hosting providers, communication services, and web analytic providers who are bound by our Privacy Policy.

  4. By availing services offered by us [or by using the Site and/or the App], you accept that we may communicate with you about our products, services, offers, events and promotions, and offer you products and services we believe may be of interest to you. This includes offers, discounts and general information.
AMENDMENTS TO PRIVACY POLICY
  1. We reserve the right, in our sole discretion, to change, modify, add or delete portions of this Privacy Policy at any time without notice, and it is your responsibility to review this Privacy Policy from time to time on the Site and/or the App, in order to keep track and take note of the changes. Your use of the Site and/or the App following any amendment of this Privacy Policy will signify and constitute your consent to and acceptance of such revised this Privacy Policy. We will not file or store a copy of these terms for each interaction on transaction by you through the Site and/or the App. We therefore recommend that you save a copy of this Privacy Policy for future reference, and ensure that such copies can be reliably verified as being effective (i.e. published on the Site and/or the App) on a particular date. 
YOUR ACCESS TO AND CONTROL OVER INFORMATION

  1. In case you do not want to give us access to any of your information, including any Personal Information or Account Information, you may choose to opt-out of all promotional/non-promotional communications or if you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you or your preferences or you have notice any discrepancies in the information provided to us or have any grievance against us, you may mail us at customercare@anaar.in or you may call us on +91 8655978333 from [9 AM to 10 PM], Monday to Friday.

  2. At any time, you can do the following by contacting us via the email address or phone number provided as above to:  
    • Check and edit your profile information, including [Personal Information] and/or Account Information; 
    • Check what data we have about you, if any; 
    • Change and/or correct any data we have about you; 
    • Delete any data we have about you. 
    • Express any concern you have about our use of your data. 

  3. We will collect and retain information about your transactions and service requests based on Cookies, network information and device information to provide adequate security, prevent fraudulent transactions and for audit and legal purposes which will not be revealed in public.

DISPUTES

Any disputes over inter alia collection, storage and handling of Personal Information will be governed by this Privacy Policy, Terms and Conditions and by the laws of India and courts of Mumbai shall have exclusive jurisdiction. 

 GRIEVANCE OFFICER

In accordance with the Information Technology Act, 2000 and rules made thereunder, the name and contact details of the Grievance Officer are provided below: 

Name: Ms. Jasmin Virani

Address: 903, Floor-9, Plot- 211, B wing, Dalamal Towers, Free Press Journal Marg, Nariman Point, Mumbai, Maharashtra - 400021.