Smytten Privacy Policy

This Privacy Policy outlines Surfboats Solutions Pvt. Ltd. ’s approach to Data Protection and Privacy to fulfil its obligations under the applicable laws and regulations . This Privacy Policy applies to your Personal Data which is processed by us, whether in physical or electronic mode.

In this Privacy Policy, the expressions ‘Personal Data’, ‘Data Subject’, ‘Controller’, ‘Processor’ and ‘Processing’ shall have the meanings given to them in the applicable privacy laws .

We are committed to treating data privacy seriously. It is important that you know exactly what we do with your Personal Data.

Throughout this document, “we”, “us”, “our”, “ours” refer to SURFBOATS SOLUTIONS PVT. LTD. . Wherever we have said ‘you’ or ‘your’, this means YOU

WHO WE ARE

SURFBOATS SOLUTIONS PVT. LTD. is a company incorporated and registered under the provisions of the Companies Act, 2013 and having its registered office at ANM39F, Akashneem Marg, DLF Phase 2, Gurgaon 122018. Surfboats Solutions Pvt. Ltd. is engaged in the business of facilitating selling, marketing and retailing personal care, food & beverages and health care products (“Business”) through the e-commerce websites and mobile applications (“App”) both developed and owned by Surfboats Solutions Pvt. Ltd. and/or its parent company, and/or its affiliates (Website and App collectively referred to as “Platform”) or events to conduct its Business.

ROLES WE PLAY

We play the role of a Data Controller when we collect and process Personal Data about you.

We play the role of a Data Processor when we collect and process Personal Data on behalf of another Data Controller

OUR COMMITMENT

We commit to protecting your privacy and hence our Personal Data handling practices are continually reviewed to ensure compliance with the applicable Privacy laws and regulations

PERSONAL INFORMATION GATHERED BY SMYTTEN

The information we learn and gather from you, personal or otherwise, is used to register you, verify your identity to permit you to use the app, undertake transactions (including to facilitate and process payments), communicate with you, convey any promotional offers, services or updates associated with SMYTTEN, and generally maintain your accounts with us. We also use this information to customize your experience and improve SMYTTEN.

INFORMATION YOU GIVE US:

We receive and store any information you provide while using SMYTTEN or give us in any other way. You can choose not to provide certain information, but then you might not be able to use SMYTTEN. We use the information that you provide for such purposes as opening your account, processing your transactions, responding to your requests, and communicating with you

INFORMATION WE COLLECT ABOUT YOU:

We receive and store certain types of information whenever you interact with us. For example, like many websites, we use "cookies," and we obtain certain types of information when your web browser accesses our Services. We may also receive/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.

INFORMATION FROM OTHER SOURCES:

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.

CATEGORIES OF PERSONAL DATA

Categories of Personal Data collected and processed by us are as follows;

Demographic & Identity data

Contact details such as Name, email address, contact number, shipping address, country, date of birth, profile picture
Open data and public records such as information about YOU that is openly available on the internet
Details such as Transaction amount, Bank Name, Card Type, Card number.

Online Identifiers and other Technical Data

Location details such as data we get about your location, IP address, logs, or from where you connect a computer to the internet
Technical details such as device information, location and network carrier when you use our mobile applications
Communications details such as the Metadata and other Personal Data we get from communications done through e-mails, SMS, instant messages and calls
Usage data details such as data about how you use our website or web-based properties, pages viewed, etc.

CONSENT

By using the Website and/ or by providing your information, you consent to the collection and use of the information you disclose on the Website in accordance with this Privacy Policy, including but not limited to your consent for sharing your information as per this privacy policy.

PURPOSES OF GATHERING YOUR PERSONAL DATA

We use your personal information to operate, provide, develop, and improve the products and services. These purposes include:

PURCHASE AND DELIVERY OF PRODUCTS AND SERVICES

We use your personal information 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, AND IMPROVE SMYTTEN

We use your personal information to provide functionality, analyse performance, fix errors, and improve the usability and effectiveness of the SMYTTEN.

RECOMMENDATIONS AND PERSONALIZATION

We use your personal information to recommend features, products, and services that might be of interest to you, identify your preferences, and personalize your experience with SMYTTEN.

COMMUNICATE WITH YOU

We use your personal information to communicate with you in relation to SMYTTEN via different channels (e.g., by phone, e-mail, chat).

ADVERTISING

We use your personal information to display interest-based ads for features, products, and services that might be of interest to you.

LAWFUL BASES OF PROCESSING YOUR PERSONAL DATA

We are permitted to process your Personal Data in compliance with applicable laws and regulations by relying on one or more of the following lawful bases:

You have explicitly agreed to us processing your Personal Data for a specific reason
The processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you
The processing is necessary to be in compliance with our Legal Obligations
The processing is necessary for the purposes of a legitimate interest (“Legitimate Interest”) pursued by us, such as
to provide services to you,
to evaluate, develop or improve our products and services

Where the processing is based on your consent, you have a right to withdraw your consent at any time. You may withdraw consent by contacting us. Upon receipt of your written request to withdraw your consent, consequences of withdrawal will be communicated to you and, upon your agreement, your request for withdrawal will be processed.

COOKIES AND OTHER TRACKERS USED BY OUR DIGITAL PROPERTIES

Cookies are small text files that are 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 in our website, web-based properties and mobile applications that are used to collect and process data about you so we can provide you a better online experience as well as improve our services

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:

Your user ID on the log on page
Your region or country
Your preferred language
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:

Improve the performance of our services
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

Pixel Tags
Log Files
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.

PERSONAL DATA DISCLOSURE

Smytten app contains 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.

SMYTTEN USES THREE TYPES OF SDKs:

SDKs	Purpose
Analytics	· Analyse in-depth detail about the visitors on our app · Settle errors · Better target users and · Provide push notifications and digital ads to the users · Example – Singular, Clevertap, Crashlytics, Gamooga, Formcept
Payment	· Complete customers’ payment transaction Example - Paytm, Razorpay, Paypal
Login	· Help users login to Smytten \| Example: Google, Facebook, Apple, LinkedIn

Links to the Privacy Policies of the third-party service providers used by our application are given below:

We have appropriate contracts in place with our third-party partners. This means that they cannot do anything with your Personal Data which is outside of the scope permitted by us. They hold it securely and retain it only for the period specified in our contracts with them.

We might also disclose your Personal Data to appropriate authorities if we believe that it is reasonably necessary to comply with a law, regulation, legal process, to protect the safety of any person, to address fraud, security, or technical issues, or to protect our rights or the rights of those who use our products & services.

Reasons for disclosing your Personal Data to other parties:

We may disclose your Personal Data to others where it is lawful to do so including where we or they:

need to provide you with products or services
where you have initiated a payment
have a legal obligation to do so, e.g. to assist with detecting and preventing fraud,
have requirement in connection with regulatory reporting, litigation or asserting or defending legal rights and interests
have a legitimate business reason for doing so
want to send you information and promotional material regarding our products and services,
have asked you for your consent to share it, and you’ve agreed
Improve your online experience for using our product.

To whom your Personal Data may be disclosed:

We may disclose your Personal Data for the above purposes to other parties including:

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)
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
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 Data as per the applicable law, courts, judicial and quasi-judicial authorities and tribunals, arbitrators and arbitration tribunals
Overseas regulators
Anybody else that we’ve been instructed to share your Personal Data with by you

CROSS-BORDER DATA TRANSFER

Personal Data 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 Data to third parties for purposes stated in this Privacy Policy, we will use best endeavours to put in place appropriate controls and safeguards to ensure that your Personal Data 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.

DATA SECURITY

We are committed to protecting your Personal Data in our custody. We take reasonable steps to ensure appropriate physical, technical and managerial safeguards are in place to protect your Personal Data 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 Data in line with our policies.

RETENTION AND DISPOSAL OF DATA

We keep the Personal Data 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 Data for those purposes and will make sure that your Privacy is protected. We shall take reasonable steps to delete or permanently de-identify Personal Data that is no longer needed.

If you wish to delete your User Content on our Site or in connection with our mobile applications, please contact us by email at care@smytten.com and request you to include the following personal information in your deletion request: first name, last name, user name, email address associated with our Site and/or mobile applications, your reason for deleting the posting, and date(s) of posting(s) you wish to delete (if you have it). We may not be able to process your deletion request if you are unable to provide such information to us. Please allow up to 60 business days to process your deletion request.

LINKS TO OTHER WEBSITES

Our website may contain links to websites of other organisations. This privacy policy does not cover how that organisation processes Personal Data. We encourage you to read the privacy policies on the other websites you visit.

CHILDREN’S PRIVACY

Our website 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 Data to us. We or our associates /affiliates do not knowingly collect information from minors.

YOUR RIGHTS AS A CUSTOMER

We understand that when you interact with Smytten, you have rights over your Personal Data. These rights involve providing reasonable steps to allow you to access your personal data, correct any errors among others. In the event that you are not satisfied with our response or have unresolved concerns, you can get in touch with us to resolve the issue by means of care@Smytten.com.

CONTACT US

For any further queries and complaints related to privacy under applicable laws and regulations, you could reach us at:

Contact Email Address: care@smytten.com

NOTIFICATION OF CHANGES

We keep our Privacy Policy under regular review to make sure it is up to date and accurate. Any changes we may make to this Privacy Policy in the future will be posted on this page. We recommend that you re-visit this page regularly to check for any updates.