OBJECTIVE, SCOPE AND APPLICABILITY

Honasa Consumer Limited Ltd. ("Company", "we", "our", "us") respects an individual's privacy and is committed to protecting the same. This Privacy Policy ("Policy") describes how we collect, use, disclose and transfer Personal Information (as defined below), through platforms controlled by the Company viz www.bblunt.com and mobile sites/application (the "Platforms") of the individuals who browse, or access the Platform or provide information on or through the Platform, or whose information the Company otherwise collects, receives or processes 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 and regulations. 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.

By accessing and/or using our Platform and providing the information as explained in this Policy, you consent to the collection and use of the information you disclose on the Platform in accordance with this Policy, including but not limited to your consent for sharing your information as per this Policy. We encourage you to read this Policy regarding the collection, use, and disclosure of your information. If you are not comfortable with any of the terms or policies described in this Policy, you may choose to discontinue usage of the Platform.

Further, you agree and consent to receive all communications related to our services on the mobile number provided by you to the Company, even if such mobile number is registered under DND/NCPR list under the Telecom Commercial Communications Customer Preference Regulations, 2018 ("TRAI Regulations,"). Notwithstanding your registration with the National Do Not Call Registry (In Fully or Partly blocked category under National Customer Preference Register set up under the Telecom Regulatory Authority of India), you hereby express your interest and accord informed consent to receive communications (including commercial communications) in relation to the Company’s services. You further confirm that no communication to you from the Company or on behalf of the Company shall be construed as Unsolicited Commercial Communication under Regulation 2(bw) of the TRAI Regulations and you have specifically opted to receive communications in this regard on the mobile number provided by you.

For the purpose of this Policy, 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.

HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We communicate with you through a variety of means and channels, including our Platform, email, phone or text messaging on your mobile phone, although we do generally note that our preferred means of communication is email which has the least impact on the environment. 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:

When you submit your Personal Information on our Platform: The Company collects and stores the Personal Information that you provide while using our Platform including when you enter your Personal Information 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, events, etc. For example, you may submit your name, postal address, 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 specifically requested or that you do not wish 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.
Automatic collection: We automatically collect and store certain types of information whenever you interact with us. Such information includes information about your use of the Platform, 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 identity 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.
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 information 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.

Following are the categories of Personal Information that is collected and processed by us:

your name, e-mail and postal addresses, phone number(s), country;
date of birth, language preference, location;
any open data and public records such as information about you that is openly available on the Internet;
names of people to whom purchases have been shipped including address and telephone numbers, IP addresses;
Product interest information and in certain circumstances, your opinions and individual preferences, etc.;
You may also provide us with information like financial information such as bank account or credit card or debit card or other payment instrument details, password for availing the Products at our Platform;
We may also maintain a record of your Product interests and acquire information about you from our future affiliates;
phone numbers used to call our customer service number.

We may collect and use technical data and related information, including but not limited to, technical information about your device, system and application software, and peripherals, that is gathered periodically to facilitate the provision of software updates, product support and other services to you (if any) related to the Platform.

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

The Company may use your Personal Information to:

verify your identity;
fulfill the Product purchases and transactions;
communicate with you about your account and activities on the Platform;
sign up for our newsletter, respond to a survey or marketing communication;
allow us to better serve you in responding to your requests;
to respond to reviews, comments, or other feedback provided to us;
administer a contest, promotion, survey or other site feature;
ask for ratings and reviews of the Products;
follow up with you after correspondence (live chat, email or phone inquiries);
allow you to log in with a social media account and share activities on your social media pages;
comply with our legal obligations, policies and procedures, including compliance with relevant industry standards and the enforcement of our terms and conditions;
help us learn more about your shopping preferences;
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;
send communication related to order updates and offers through e-mail, SMS and social media channels;
do internal research on our Customer's demographics, interests, and behaviour to better understand and serve you;
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;
analyze trends, track Customer's web page movements, help identify you and your shopping cart for aggregate use;
determine which of the store locations containing our Products may be closest to you, provide promotional offers, and to offer Products to you;
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;
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
comply with any applicable law, regulation, legal process or enforceable governmental request.

The legal basis on which we collect your Personal Information:

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.
Legitimate Interest: legitimate interests will include where we send you marketing information about our Products, communicate with you in order to serve you better.
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.
Consent: Finally, in certain limited situations, we rely on your consent in order to process your Personal Information. Where we require your consent in order to collect and process certain Personal Information, we seek your consent at the time of provision, and such processing will only be performed where consent is secured. You can withdraw your consent, as per this Policy where applicable, by sending an email to care@bblunt.com.

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.

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.

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.

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 you own, that you request us to release or that is released through another third party to whim you have given access.

In case of our customer care support, we may record calls for quality and training purposes.

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:

Our affiliates and third parties;
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.

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 to that business entity who may collect, use or disclose such information for the purposes of evaluating the proposed transaction or for operating and managing the affairs of the acquired business or for other purposes identified in this Policy.

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.

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 information with a third party such as an event or promotion co-sponsor. If you consent, we will share your information with such third party and the 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 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 to law enforcement offices, 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.

RETENTION OF PERSONAL INFORMATION

We will retain your Personal Information 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 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 is safeguarded against inappropriate access and disclosure, as per this Policy.

Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We also maintain appropriate and adequate administrative, technical and physical safeguards designed to protect your Personal Information 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 address provided below.

Your Choices to opt-out:

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@bblunt.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 viz. historical copies, or "caches," may remain.

WITHDRAWAL OF CONSENT

If you have consented to the collection, use and/or disclosure of your Personal Information as identified in this Policy, you have the right to withdraw this consent at any time by writing to us at care@bblunt.com. Where you are providing location information via a mobile app, you may turn off your location services on your device at any time. 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

We may store Personal Information using our own secure on-site servers or other internally hosted technology. Your Personal Information 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 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). 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:

understand and save Customer's preferences for future visits.
keep track of advertisements.
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.
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.
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. 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 ADVERTISEMNTS OR SITES

We may display links to web sites that are owned or operated by third parties on our Platform. Please understand that these websites are independent from the Company, and the Company has no control over the content on that website, even if the Company provides information or Products to the owner of that website. The Company is not making any representations about, endorsing, or accepting any responsibility for the content or the use of such website. Further, we are not responsible or 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 a third-party website before accessing or using it.

THIRD PARTY ANALYTICS:

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

At present, we work with the following analytic partners:

Google
- Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for Customers. We use Google AdSense Advertising on our Platform. Google, as a third-party vendor, uses cookies to serve ads on our Platform. Google's use of the DART cookie enables it to serve ads to our Customers based on previous visits to our Platform and other sites on the Internet. The Customers may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.
- We have implemented the following:
  1. Remarketing with Google AdSense
  2. Google Display Network Impression Reporting
  3. Demographics and Interests Reporting
  4. Double Click Platform Integration
- We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding the Customer interactions with ad impressions and other ad service functions as they relate to our Platform.
- The Customers can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt-Out page or by using the Google Analytics Opt-Out Browser Add-on.

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 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, regardless of the format in which it is held. We use various methods to safeguard Personal Information. 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.

POLICY REVIEW

Please note that we review and may make changes to this Policy from time to time. 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.

PRIVACY CONCERNS

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

Supratim Sarkar

(Grievance Officer)

Honasa Consumer Limited

11th Floor, Capital Cyberscape,

Sector-59, Gurugram, Haryana, 122102

India

Email id - care@bblunt.com and marketing@bblunt.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.

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