Privacy Policy

FOREWORD

At IFSS Group, we prioritize the protection and privacy of your personal data. This privacy notice is designed to inform you about how we handle your personal data when you visit our website, regardless of your location. It also outlines your privacy rights. Our policy complies with the requirements of the Digital Protection Bill 2022, Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules 2011, the General Data Protection Regulation (GDPR), and other applicable legislation.

1.1 Purpose of this Privacy Notice

This privacy notice aims to provide you with information regarding how IFSS Group collects and processes your personal data when you use our website. This includes any data you provide when you sign up for our newsletter or make a purchase.

1.2 Website Not Intended for Children

Our website is not intended for children, and we do not knowingly collect data related to children.

1.3 Complementary Notices

Please read this privacy notice alongside any other specific privacy notices or fair processing notices we provide on particular occasions when collecting or processing your personal data. It is important to fully understand how and why we use your data. This privacy notice supplements other notices and does not override them.

1.4 Controller

IFSS Group consists of various legal entities. Specific details can be provided upon request. This privacy notice represents the entire IFSS Group. When we refer to “IFSS Group,” “we,” “us,” or “our” in this notice, we are referring to the relevant company within IFSS Group responsible for processing your data. IFSS Group acts as the controller and is responsible for this website.

1.5 Data Privacy Manager

We have appointed a data privacy manager (DPM) who oversees questions related to this privacy notice. For any inquiries or to exercise your legal rights, please contact the DPM at privacy@ifssgroup.in. Other individuals within IFSS Group may be authorized to act on behalf of the DPM or handle the daily collection and processing of personal data.

1.6 Right to Complain

You have the right to lodge a complaint with the relevant data protection authority at any time. However, we would appreciate the opportunity to address your concerns before you approach any authority. Please contact us initially.

1.7 Your Duty to Inform Us of Changes

To ensure the accuracy and currency of the personal data we hold about you, please inform us of any changes during your relationship with us.

1.8 Third-Party Links

Our website may contain links to third-party websites, plug-ins, and applications. Clicking on these links or enabling such connections may allow third parties to collect or share data about you. We do not have control over these third-party websites and are not responsible for their privacy statements. When you leave our website, we recommend reading the privacy notice of each website you visit.

2.1 Personal Data Collection

Personal data refers to any information that can identify an individual. It does not include data where the identity has been removed (anonymous data). We may collect, use, store, and transfer various types of personal data about you, which we have categorized as follows:

– Identity Data: Includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender.

– Contact Data: Includes billing address, delivery address, email address, and telephone numbers.

– Financial Data: Includes bank account and payment card details.

– Transaction Data: Includes details about payments to and from you, as well as other information related to products and services you have purchased from us.

– Technical Data: Includes internet protocol (IP) address, login data, browser type and version, time zone setting, location, browser plug-in types and versions, operating system, platform, and other technology used on the devices you use to access our website.

– Profile Data: Includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.

– Usage Data: Includes information about how you use our website, products, and services.

– Marketing and Communications Data: Includes your preferences for receiving marketing materials from us and our third parties, as well as your communication preferences.

We also collect, use, and share Aggregated Data, which is anonymized or statistical data that does not directly or indirectly identify you. However, if Aggregated Data is combined or connected with your personal data in a way that it can identify you, we treat it as personal data in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data (sensitive data) about you, such as information related to race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, or genetic and biometric data. We also do not collect information about criminal convictions and offenses.

3.1 Data Collection Methods

We employ various methods to collect data from and about you, including:

– Direct Interactions: You may provide us with your Identity, Contact, and Financial Data by filling in forms or corresponding with us through post, phone, email, or other means. This includes personal data you provide when applying for our products or services, creating an account, subscribing to our services or publications, requesting marketing materials, or providing feedback.

– Automated Technologies or Interactions: When you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. This is done using cookies, server logs, and similar technologies. We may also receive Technical Data about you from other websites that use our cookies. For more details, please refer to our cookie policy.

– Third Parties or Publicly Available Sources: We may receive personal data about you from various third parties and publicly available sources, including analytics providers like Google, advertising networks, social media platforms, similar online platforms, and search information providers.

We will only use your personal data when permitted by law. The following circumstances outline the most common purposes for which we use personal data:

– Performance of Contract: We use your personal data when it is necessary to fulfil a contract we have with you or are about to enter into with you.

– Legitimate Interests: We may use your personal data when it is necessary for our legitimate interests or the legitimate interests of a third party, provided that your interests and fundamental rights do not override those interests.

– Legal Obligations: We use your personal data to comply with a legal or regulatory obligation.

In general, we do not rely on your consent as a legal basis for processing your personal data, except in relation to sending third-party direct marketing communications via email or text message. You have the right to withdraw your consent for marketing at any time by contacting us at privacy@ifssgroup.in.

4.1 Purposes for which we will use your personal data:

We have outlined in the data below the specific ways we plan to use your personal data:

Purpose/Activity:

– To register you as a new customer.

– To process and deliver your order, including managing payments, fees, and charges, as well as collecting and recovering owed money.

– To manage our relationship with you, including notifying you about changes to our terms of use  or privacy policy and requesting your feedback through reviews or surveys.

– To enable you to participate in surveys.

– To administer and protect our business and website, troubleshoot issues, perform data analysis, conduct testing, maintain systems, provide support, generate reports, and host data.

– To deliver relevant website content and advertisements, measure the effectiveness of advertising, and personalize your experience.

– To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences.

– To make suggestions and recommendations about goods or services that may be of interest to you.

Types of data involved:

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Technical

(f) Usage

(g) Profile

(h) Marketing and Communications

4.2 Marketing:

We respect your choices regarding personal data use for marketing and advertising purposes. We offer the following control mechanisms:

Promotional Offers from Us:

We may use your Identity, Contact, Technical, Usage, and Profile Data to determine products, services, and offers that may be of interest to you. You will receive marketing communications from us if you have requested information, purchased goods or services, or registered for promotions and services, unless you have opted out of receiving such marketing.

Third-Party Marketing:

Before sharing your personal data with companies outside the IFSS Group group of companies for marketing purposes, we will obtain your express opt-in consent.

Opting Out:

You can opt out of receiving marketing messages from us or third parties at any time. You can adjust your marketing preferences by logging into the website and updating your settings or by following the opt-out links in marketing messages. Alternatively, you can contact us directly.

Cookies:

You have the option to configure your browser to refuse or alert you about cookies being set or accessed by websites. However, please note that disabling or refusing cookies may result in certain parts of our website becoming inaccessible or not functioning properly. For more information about the cookies we use, please refer to our Cookie Policy.

Change of Purpose:

We will only use your personal data for the purposes for which we collected it, unless we reasonably determine that we need to use it for another purpose that is compatible with the original purpose. If we need to process your personal data for an unrelated purpose, we will notify you and explain the legal basis for doing so. Please note that we may process your personal data without your knowledge or consent as required or permitted by applicable law.

We may share your personal data with the following parties for the purposes outlined in the Paragraph-(Purpose/ Activity) in section 4.

– Internal Third Parties as defined in the Glossary.

– External Third Parties as defined in the Glossary.

– Third parties to whom we may choose to sell, transfer, or merge parts of our business or assets. In the event of such a change, the new owners may use your personal data in accordance with this privacy notice.

We ensure that all third parties respect the security of your personal data and handle it in accordance with applicable laws. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may transfer your personal data within the IFSS Group, which may involve transferring your data inside and outside the Republic of India. We ensure that your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. When we transfer your personal data outside the Republic of India, we will make efforts to ensure that a similar level of protection is provided to the extent reasonably possible.

We have implemented appropriate security measures to prevent the accidental loss, unauthorized access, use, alteration, or disclosure of your personal data. Additionally, we limit access to your personal data to employees, agents, contractors, and other third parties who have a legitimate business need to access this information. They will only process your personal data on our instructions, and they are bound by confidentiality obligations. We have procedures in place to handle any suspected personal data breach and will notify you and the relevant regulatory authorities when legally required to do so.

How long we retain your personal data depends on the purposes for which we collected it, including any legal, accounting, or reporting requirements. We consider factors such as the amount, nature, and sensitivity of the personal data, the potential risk of unauthorized use or disclosure, the purposes of processing, and whether we can achieve those purposes through alternative means. In certain circumstances, you can request the deletion of your data (please see below for further information). In some cases, we may anonymize your personal data for research or statistical purposes, in which case we may use the information indefinitely without providing notice to you.

Under data protection laws, you have certain rights regarding your personal data, including the right to:

– Request access to your personal data.

– Request correction of your personal data.

– Request erasure of your personal data.

– Object to the processing of your personal data.

– Request restriction of the processing of your personal data.

– Request the transfer of your personal data.

– Withdraw consent.

If you wish to exercise any of these rights, please contact our designated Data Protection Manager (DPM) for further information. We do not usually charge a fee to fulfill these rights unless the requests are unfounded, repetitive, or excessive. In such cases, we may charge a reasonable fee or refuse to comply with the request. We may need to verify your identity and request further information to ensure the security of your personal data and to process your request promptly. We aim to respond to legitimate requests within one month, but if the request is complex or numerous, it may take longer. In such cases, we will keep you informed.

Lawful Basis:

– Legitimate Interest: Our business’s interest in conducting and managing our operations to provide you with the best service, product, and secure experience. We assess the potential impact on your rights and interests before processing your personal data for our legitimate interests.

– Performance of Contract: Processing your data when necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

– Comply with a Legal or Regulatory Obligation: Processing your personal data when necessary to comply with a legal or regulatory obligation to which we are subject.

Third Parties:

– Internal Third Parties: Other companies within the IFSS Group that act as joint controllers or processors, located in various international locations.

– External Third Parties: Service providers acting as processors, professional advisers (e.g., lawyers, bankers, auditors, insurers) providing consultancy services, and regulators or other authorities requiring reporting of processing activities in certain circumstances, acting as processors or joint controllers.

Your Legal Rights:

You have the following rights regarding your personal data:

1. Request access to your personal data: You can request a copy of the personal data we hold about you and verify the lawfulness of its processing.

2. Request correction of your personal data: If you believe that the personal data we hold about you is incomplete or inaccurate, you can request us to correct it. We may need to verify the accuracy of any new data you provide.

3. Request erasure of your personal data: You can ask us to delete or remove your personal data when there is no legitimate reason for us to continue processing it. You also have the right to request erasure if you have successfully exercised your right to object to processing, if we have processed your data unlawfully, or if erasure is required by local law. However, please note that there may be legal reasons that prevent us from fulfilling your request, and we will inform you of these, if applicable.

4. Object to processing of your personal data: If we are processing your personal data based on legitimate interests (or those of a third party) and there is something about your particular situation that leads you to object to such processing, you have the right to do so. You also have the right to object to the processing of your personal data for direct marketing purposes. In some cases, we may demonstrate compelling legitimate grounds that override your rights and freedoms.

5. Request restriction of processing of your personal data: You can ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to verify the accuracy of the data; (b) where the processing is unlawful, but you do not want us to erase the data; (c) where you need us to retain the data even if we no longer require it, as you need it to establish, exercise, or defend legal claims; or (d) if you have objected to the processing, and we need to verify whether our legitimate grounds override your rights.

6. Request the transfer of your personal data: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to have it transferred to another controller of your choice. This right applies only to automated information that you initially provided consent for or that we used to perform a contract with you.

7. Withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. However, withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal. If the withdrawal of consent impacts our ability to provide certain products or services, we will inform you at the time of withdrawal.

Please note that we reserve the right to modify this Privacy Notice at any time without prior notice. Any amendments will be posted on our website, so we recommend reviewing it regularly.