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ELEMAGE WELLNESS LLP – PRIVACY POLICY

OBJECTIVE, SCOPE AND APPLICABILITY

Elemage Wellness LLP (“Company”, “we”, “our”, “us”) respects an individual’s privacy and is committed to protecting the individual’s privacy. This privacy policy (“Policy”) describes how we collect, disclose, use, and transfer Personal Information (as defined below) and Sensitive Personal Data (as defined below), through a platform controlled by the Company namely futuremeworld.com (the “Platform”) of the individuals who access or browse the Platform or provide information on or through the Platform, or whose information the Company otherwise collects, processes or receives in connection with the offer and sale of its products (“Products”) (hereinafter, collectively referred to as “Customers”, “you”, “your”) and ensure its compliance with applicable laws. This Policy does not apply to Personal Information collected from you offline (unless otherwise specified), to Company’s websites that do not link to this Policy, to Customers of countries other than India or to third-party websites to which Platform may link.

This Policy shall be construed to be provided in compliance with the provisions of the Information Technology Act, 2000, as amended from time to time (“IT Act”), and shall be read along with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”).

We encourage you to read this Policy regarding the collection, disclosure and use, of your information. If you are not comfortable with any of the terms or policies described in this Policy, you may choose to discontinue the usage of the Platform.

Definitions:

For the purposes of this Policy, unless the context otherwise requires:
1. the term “Personal Information” shall mean any information that relates to you, which, either directly or indirectly, in combination with other information available or likely to be available with the Company, is capable of identifying you, which is submitted to and/or collected over the Platform and maintained by the Company in an accessible form, provided that, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as Personal Information for the purposes of this Policy.
2. the term “Sensitive Personal Data” of a person means such Personal Information which consists of information relating to:
  – password;
  – financial information such as bank account or credit card or debit card or other payment instrument details;
  – physical, physiological and mental health condition;
  – sexual orientation;
  – medical records and history;
  – biometric information;
  – any detail relating to the above Clauses as provided to the Company for providing any service; and
  – any of the information received under any of the above Clauses by the Company for processing, or stored or processed under any lawful contract or otherwise.
  
  Provided that any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force will not be regarded as Sensitive Personal Data.
3. The words and expressions used in this Policy but not defined herein but defined in the IT Act or SPDI Rules will have the meanings assigned to them thereunder.

HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We communicate with you through various means and channels, including our Platform, email, phone or text messaging on your mobile phone. Such communications may involve giving to you, as well as receiving information from you.

We collect and receive the Personal Information in the following ways:
1. Automatic collection: We automatically collect and store certain types of information whenever you interact with us. Such information includes certain information about your use of the Platform, along with your interaction with content and services available through the Platform. Like many websites, unidentifiable information may be collected using various technologies, such as cookies, Internet tags, and web beacons. Your Internet browser automatically transmits to the Platform some of this unidentifiable information, such as the URL of the Website you just visited and the browser version your computer is operating. Passive information collection technologies can make your use of the Platform easier by allowing the Company to provide better service, customize sites based on consumer preferences, compile statistics, analyze trends, and otherwise administer and improve the Platform. Certain features of the Platform may not work without use of passive information collection technologies. Information collected by these technologies cannot be used to identify you without additional identifiable information. We may also receive/store information about your location and your mobile device, including a unique identifier for your device.
2. When you submit your Personal Information and Sensitive Personal Data on our Platform: The Company collects and stores the Personal Information and Sensitive Personal Data that you provide while using our Platform including when you enter your Personal Information and Sensitive Personal Data into data fields on the Platform as part of a voluntary registration process. We also collect and store your Personal Information through sponsored social media platforms, and/or events, etc. For example, you may submit your name, or postal address, or e-mail address, and/or other information in order to register, place orders for the Products, receive information about various Products, register for newsletters, receive offers, contact Company’s customer care service, or respond to the Company’s surveys. To protect your privacy, you should not provide the Company with any information that is not requested specifically or any other information that you do not intend to share. You can choose not to provide certain information, but then you might not be able to use our Platform or certain features of our Platform.
3. Other sources: We might receive information about you from other sources, such as updated delivery and address information from third parties, which we use to correct our records and deliver your next purchase more easily. Further, we may receive information about you from third parties that feature our Products or promotional offers if you opt-in to receive information from us. You may also choose to participate in a third-party application or social media sites through which you allow us to collect (or the third party to share) Personal Information about you, including usage information. We may also receive information such as marketing related or demographic information about you from third parties to enhance our ability to tailor our content and offer you the Products that we believe may be of interest to you. The Company is not responsible for the privacy practices of such third-party websites which it does not own, manage or control.

WHAT PERSONAL INFORMATION DO WE COLLECT?

The Company limits itself to collect Personal Information and Sensitive Personal Data which is necessary to ensure accurate services and is required to process your order of the Product or provide a refund and continually improve our Products and services.

WHAT IS THE PURPOSE FOR WHICH THE PERSONAL INFORMATION IS COLLECTED?

The Company may use your Personal Information to:
1. verify your identity;
2. fulfill the Product purchases and transactions;
3. communicate with you about your account and activities on the Platform;
4. sign up for our newsletter, respond to a survey or marketing communication;
5. allow us to better serve you in responding to your requests;
6. to respond to reviews, comments, or other feedback provided to us;
7. administer a contest, promotion, survey or other site feature;
8. ask for ratings and reviews of the Products;
9. follow up with you after correspondence (live chat, email or phone inquiries);
10. allow you to log in with a social media account and share activities on your social media pages;
11. comply with our legal obligations, policies and procedures, including compliance with relevant industry standards and the enforcement of our terms and conditions;
12. help us learn more about your shopping preferences;
13. conduct marketing and performance research to assist us in measuring our customer services, benchmarking our performance and to help us improve your shopping experiences and Product offerings;
14. send communication related to order updates and offers through e-mail, SMS and social media channels;
15. do internal research on our Customer’s demographics, interests, and behaviour to better understand and serve you;
16. provide you with exclusive offers at the Platform, tailor content, advertisements, and we provide you, and improve the Platform and/or for internal business purposes;
17. analyze trends, track Customer’s web page movements, help identify you and your shopping cart for aggregate use;
18. determine which of the store locations containing our Products may be closest to you, provide promotional offers, and to offer Products to you;
19. prevent, detect, investigate and take action against crimes (including but not limited to fraud and other financial crimes), any other illegal activities, suspected fraud, or violations of Company’s terms and conditions in any jurisdiction;
20. establish, exercise or defend legal rights in connection with legal proceedings (including any prospective legal proceedings) and seek professional or legal advice in relation to such legal proceedings; and
21. comply with any applicable law, regulation, legal process or enforceable governmental request.

The legal basis on which we collect your Personal Information (other than Sensitive Personal Data):
1. Performance of a Contract: Some of the Personal Information processed is performed on the basis that it is necessary for the performance of our agreement with you. An example of this would be where we process your Personal Information for delivering the Products ordered by you on our Platform.
2. Compliance with a Legal Obligation: For certain types of processing it is necessary in order to allow us to comply with a legal obligation. An example of this would be where we are required to retain business records for fixed periods of time in order to comply with local legal requirements.
3. Legitimate Interest: Legitimate interests will include where we send you marketing information about our Products, communicate with you in order to serve you better.
4. We may also collect and/or generate anonymized and aggregated information from your use of the Platform. The anonymized or aggregated information is not Personal Information since we are not able to re-identify you using any means available to us from that anonymized or aggregated information. The anonymized and aggregated information is used for a variety of functions, including to help us identify and remediate any bugs, and to improve the performance of our Platform. The Company may use such information in a number of ways, including internal analysis, analytics and research. We may share this information with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
5. We maintain a social media presence, such as a Facebook, Instagram, LinkedIn and a Twitter feed. You can interact with us through social media, such as by entering our contests, posting content, sharing material from our Platform, and using our social media plug-ins. When you interact with us using social media, we may receive information such as your user ID, your profile picture, photos you post, and similar information, which is often determined by your privacy settings at the relevant social media sites. We may use the information for the purposes we have described throughout this Policy. Your use of social media sites is primarily governed by the site operators’ privacy policies and terms of service, and the information you share with us and with others is largely controlled by the privacy settings you have established at those sites.
6. Payment Information: You may provide payment information when you use the Platform to buy our Products, including credit cards numbers, billing information using third-party intermediary PCI-DSS compliant service providers. The payment information is provided directly by you, via the Platform, into the PCI/DSS-compliant payment processing service to which the Company subscribes, and the Company does not, itself, process or store the payment information, except as stated herein. Further, these intermediaries are not permitted to store, retain, or use your billing information for any purpose except for payment processing on our behalf.
7. In case of our customer care support, we may record calls for quality and training purposes.
8. If you use the Platform, you are responsible for maintaining the confidentiality of your access information and password. You are responsible for restricting access to your computer, mobile device, etc., and you agree to accept responsibility for all activities that occur under your password. We cannot secure any information that you release on your own, that you request us to release or that is released through another third party to whom you have given access.

HOW DO WE SHARE THE PERSONAL INFORMATION?

Only the persons authorized by us shall have access to your Personal Information. We may share your Personal Information only to those mentioned below and they are either subject to this Policy or follow practices at least as protective as those described in this Policy:
1. Our affiliates and third parties; and
2. Service providers who perform services on our behalf based on our instructions which inter alia include beauty partners providing beauty services to the Customers. However, these service providers will not be authorized to use or disclose such information except as necessary to perform services on our behalf or comply with legal requirements.

We do not rent or sell your Personal Information to any third party.

We may share Personal Information with our other corporate entities who may use the said information in accordance with this Policy to help detect and prevent identity theft, fraud, and other potentially illegal acts; correlate related or multiple accounts to prevent abuse of our Platform. If you have any objection to such sharing, then we request not provide us with any information.

Should we plan to merge/sell all or substantially all of our business to another business entity or similar other transaction or be required by that business entity, we may transfer or disclose your Personal Information and/or Sensitive Personal Data to that business entity who may collect, use or disclose such information for the purpose of evaluating a proposed transaction or for operating and managing the affairs of the acquired business or for such other purposes identified in this Policy.

We may retain other companies and individuals to perform functions on our behalf consistent with this Policy. Examples include order processing companies, courier companies, data analysis firms, customer support specialists, email vendors, web-hosting companies and fulfillment companies (e.g., companies that coordinate mailings). Such third parties may be provided with access to Personal Information needed to perform their functions but may not use such information other than on our behalf and in accordance with this Policy.

In addition, in some instances, you may be offered the opportunity to consent to the sharing of your Personal Information with a third party such as an event or promotion co-sponsor. If you consent, we will share your Personal Information with such third party and the Personal Information you provide may be used by such third party for their own purposes and in accordance with their own policies.

Notwithstanding anything contained in this Policy, we may disclose Personal Information and/or Sensitive Personal Data if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to respond to any court orders or other legal processes. We may disclose Personal Information and/or Sensitive Personal Data to any law enforcement agencies, or third party rights owners, or others in the good faith belief that such disclosure is reasonably necessary to enforce our Terms and Conditions or Policy; respond to claims that an advertisement, posting or other content violates the rights of a third party; or protect the rights, property or personal safety of our Customers or the general public.

INFORMATION PROVIDER’S RIGHTS IN RELATION TO THEIR SENSITIVE PERSONAL DATA COLLECTED BY THE COMPANY

You acknowledge that all Sensitive Personal Data provided to the Company by you has been voluntarily provided to us. However, please note that withdrawal of consent will not be retrospective in nature and shall only be applicable prospectively. In case you do not provide your information or consent for usage of Sensitive Personal Data and subsequently withdraw your consent for usage of the Sensitive Personal Data so collected, the Company reserves the right to discontinue the services for which the said information was sought and you shall consent to the withdrawal of your consent in relation to the Sensitive Personal Data.

You agree and acknowledge that certain data or information may not be corrected or is prohibited to be modified as required under any applicable law, law enforcement requests or under any judicial proceedings. In respect to such data or information, the aforementioned rights will not be available.

You may write to us at dreams@futuremeworld.com to access, review, modify or correct your Sensitive Personal Data or withdraw your consent to provide Sensitive Personal Data. However, we are not responsible for the authenticity of the Sensitive Personal Data provided by you.

RETENTION OF PERSONAL INFORMATION AND SENSITIVE PERSONAL DATA

We will retain your Personal Information and/or Sensitive Personal Data only as long as it is reasonably required or otherwise permitted or required by applicable law or regulatory requirements. We may also retain your Personal Information and/or Sensitive Personal Data so long as it is necessary to fulfil the purposes for which it was collected (including for purposes of meeting any legal, administrative, accounting, or other reporting requirements). Your Personal Information and Sensitive Personal Data is safeguarded against inappropriate access and disclosure, as per this Policy.

We also maintain appropriate and adequate administrative, technical and physical safeguards designed to protect your Personal Information and Sensitive Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

OPTING OUT:

The Platform provides an option to all the Customers to opt-out of receiving any promotional or marketing communications from us. If you do not wish to receive any promotional or marketing communications from us, you can contact us at the email address provided below.

Your Choices to opt-out:
1. You have the following choices with how your Personal Information is used:
  - Opt-out options
  - What you need to do
  - Updating your Personal Information in relation to your account
  - You can update or correct your name, e-mail address, security questions, and other preferences by logging into your account and clicking on the “My Account” page, calling customer care executive.

Receiving newsletters and promotional e-mails

You can click on the “unsubscribe” link at the bottom of any promotional e-mail that you receive. Alternatively, you may edit your e-mail preferences on your “My Account” page or call customer care executive to discontinue receiving any promotional materials by mail/ e-mail.

Remove content from Customer review

You can remove content that you posted on a public space, such as part of a ratings and review, by e-mailing details to care@futuremeworld.com. Please note that we will endeavour and try to ensure to honour your request to remove information, however, our removal of your information does not completely erase that information from the internet historical copies, or “caches,” may remain.

WITHDRAWAL OF CONSENT

If you have consented to the collection, use and/or disclosure of your Personal Information and/or your Sensitive Personal Data as identified in this Policy, you have the right to withdraw this consent at any time by writing to us at care@futuremeworld.com. Please note that any processing that we have carried out before the withdrawal of your consent remains lawful. Provided that, notwithstanding such request, this information may be retained to comply with our legal obligations, resolve disputes and enforce our agreements.

HOW WE STORE YOUR PERSONAL INFORMATION AND SENSITIVE PERSONAL DATA

We may store Personal Information and Sensitive Personal Data using our own secure on-site servers or other internally hosted technology. Your Personal Information and Sensitive Personal Data may also be stored by third parties, via cloud services or other technology, with whom the Company has contracted, to support the Company’s business operations.

These third parties do not use or have access to your Personal Information and Sensitive Personal Data other than for cloud storage and retrieval, and the Company requires such parties to employ at least the same level of security that we use to protect your Personal Information.

DISPOSAL OF PERSONAL INFORMATION

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.

DO WE USE “COOKIES”?

We may track your preferences and activities on the Platform. “Cookies” are small data files transferred to your computer’s hard-drive by a website, while using a web browser (if you allow) after obtaining a written consent. They keep a record of your activities on the Platform making your subsequent visits to the site more efficient. The Cookies may store a variety of information, including, the number of times that you access the Platform, registration information and the number of times that you view a particular page or other item on the Platform. The use of cookies is a common practice adopted by most major sites to better serve their clients. Most browsers are designed to accept cookies, but they can be easily modified to block cookies.

By continuing the use of the Platform, you are agreeing to our use of cookies. If you do not agree to our use of cookie, you can block them in your browser setting, but you may lose some functionality on the Platform.

We use cookies to:
1. understand and save Customer’s preferences for future visits.
2. keep track of advertisements.
3. compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
4. you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. You may look at your browser’s help menu to learn the correct way to modify your cookies.
5. if you turn cookies off, some features will be disabled. It won’t affect the Customer’s experience that makes your site experience more efficient and may not function properly.
6. However, you will still be able to place orders.

CUSTOMER COMMENTS AND CONTENT

If you post any comments or content on our Platform, you should be aware that any information you choose to provide there may be read, collected, or used by the third parties. We are not responsible for the information you choose to submit, and we cannot guarantee that third parties have not made copies of or will not use such information in any way.

LINKS TO THIRD PARTY ADVERTISEMENTS OR SITES

We may display links to web sites that are owned or operated by third parties on our Platform. Please understand that such websites are independent of and from the Company, and the Company has no control over the contents on such websites, even if the Company provides information or Products to the owner of that website. The Company is not making any representations about, or endorsing, or accepting any responsibility for the contents or the use of such websites. Further, we are not responsible or shall be liable for any damage or loss related to the use of any third-party website. You should always read the terms and conditions and the privacy policy of any such third-party website before accessing or using it.

ANALYTICS BY THIRD PARTIES

We use analytics services provided by third parties to evaluate your use of the Platform, and compile reports on activity, collecting demographic data, analyzing performance metrics, and collect and evaluate other information relating to the Platform and mobile and internet usage. Such third parties use cookies and technologies to help us analyze and provide the information and, in a few cases, connect such information with other data held by our, or third party, environments. You consent to the processing of the information about you by these third party analytics providers in the manner and for the purposes set out in this Policy.

EMPLOYMENT OPPORTUNITIES

We provide you with a means for submitting your resume or other information through our Platform for consideration for employment opportunities at the Company. Information received through resume submissions will be kept confidential. We may contact you for additional information to supplement your resume, and we may use your information within the Company, or keep it on file for future use, as we make our hiring decisions.

CHILDREN

Our Platform is not designed for individuals under the age of eighteen (18) and we do not knowingly collect Personal Information from anyone under the age of eighteen (18). If you are under eighteen (18) years of age, you may browse our Platform, but please do not provide your Personal Information to us. For example, you cannot register. If we become aware that we have inadvertently received Personal Information from a visitor under the age of eighteen (18) on the Platform, we will delete the information from our records.

SECURITY

We endeavour to protect the Personal Information and Sensitive Personal Data against loss or theft, as well as unauthorized access, disclosure, copying, use or modification with security safeguards appropriate to the sensitivity of the Personal Information and Sensitive Personal Data, regardless of the format in which it is held. We use various methods to safeguard Personal Information and Sensitive Personal Data. They include:

Physical measures: locked filing cabinets, restriction of access to offices, and alarm systems.
Technical tools: passwords and encryption, using generally industry best practices.
Organizational controls: confidentiality agreements, limiting access on a need-to-know basis, staff training and security clearances.
Online security is also a priority. We incorporate security measures such as encryption and authentication tools to protect your Personal Information from unauthorized use. Firewalls are utilized to protect our servers and network from unauthorized users accessing and tampering with files and other information that we store.
Further, we attempt to keep your Personal Information up-to-date, accurate in the best possible manner as it may be necessary for the purpose for which it was collected. We value the importance you attach to your Personal Information given to us and therefore we have (i) taken all reasonable measures and precautions to keep such information safe and secure and to prevent any unauthorized access to or misuse of the same; and (ii) enable you to review and edit the same.
We use regular Malware Scanning.
Your Personal Information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a Customer enters, submits, or accesses their information to maintain the safety of your Personal Information.
However, we shall not be liable to any Customers for any loss, damage (whether direct, indirect, consequential or incidental) or harm caused to the Customers due to the unauthorized access or misuse of the Personal Information by any third party.
We use reasonable security measures at the minimum those mandated under the IT Act and the SPDI Rules, to safeguard and protect your Sensitive Personal Data or Personal Information.

POLICY REVIEW

The Company reserves the right, at its discretion, to change, modify, amend, add or remove portions of this Policy at any time without notice. We recommend that you review this Policy periodically to ensure that you are aware of the current privacy practices of the Company. When changes are made, the Policy link will include a notation “Revised (date).” indicating that you should review the new terms, which will be effective immediately upon posting on this page, with an updated effective date. By accessing the Platform after any changes have been made, you signify your agreement on a prospective basis to the modified Policy and any changes contained therein.

FORCE MAJEURE

The Company shall not be held responsible for any loss, damage or misuse of the Personal Information, if such loss, damage or misuse is attributable to a Force Majeure Event. A “Force Majeure Event” means any event that is beyond the reasonable control of the Company and includes, without limitation, fire, flood, explosion, acts of God, civil commotion, strikes, lock outs or industrial action of any kind, riots, insurrection, war, acts of government, power failure, sabotage, computer hacking, unauthorized access to computer data and storage device, system failure, virus, attacks, bugs, computer crashes, breach of security and encryption.

PRIVACY CONCERNS AND GRIEVANCE REDRESSAL

If you are concerned about the handling of your Personal Information and/or Sensitive Personal Data, or if you have any complaints or queries related to your Personal Information or Sensitive Personal Data or our Policy, please contact:

Name: FutureMe Consumer Care Cell (Grievance Officer)

Contact Number: +91-9819001711

Email ID – care@futuremeworld.com

The Grievance Officer is identified above pursuant to the provisions of applicable laws including but not limited to the Information Technology Act, 2000 and the Consumer Protection Act, 2019, and the rules enacted under those laws.

CONSENT BANNER

By checking this box, you consent to the collection and processing of the personal data you disclose on the Platform (including your Sensitive Personal Data or Information) in accordance with this Policy.

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