PROVALO (Aayanik Global Private Limited)      Date :- 19 April 2022

# Your data is yours! We shall make every endeavour to protect and respect your Privacy! 

This Privacy Policy outlines Provalo’s approach to Data Protection and Privacy to fulfil its obligations under the applicable laws and regulations and applies to your Personal Data processed by us in physical or electronic mode. 

In reference to this Policy, “we”, “us”, “our”, “ours” refers to “Provalo” (Aayanik Global Pvt. Ltd). Wherever, we have said ‘you’ or ‘your’, this means ‘YOU’ or any company and/or organization and/or any other entity.

Who are we?

Aayanik Global Private Limited., is a company incorporated and registered under the provisions of the Companies Act, 2013. We have our registered office address at B-201/202, Sai Anand, Opp. Bank of Baroda, Anand Nagar, Dahisar (East), Mumbai – 400 068. We are engaged in the business of beauty and personal care products. 

Our commitment

We stand committed to protecting your privacy and personal information. Our personal information handling practices shall be continuously reviewed to ensure compliance with the applicable Privacy Laws and Regulations. 

This Privacy Policy (“Policy”) describes how we collect, use, disclose and transfer Personal Information through platforms controlled by us viz. https://www.provalocosmetics.com/ (“Platform”) of the individuals who browse, or access the Platform or provide information on or through the Platform, or whose information we otherwise collect, receive or process in connection with the offer and sale of our products (“Products”) and ensure compliance with applicable laws and regulations. This Policy does not apply to Personal Information collected from you offline (unless otherwise specified), to websites that do not link to this Policy, to Consumers of countries other than India or to third-party websites to which the Platform may link.

By accessing and/or using our Platform and providing information as explained in this Policy, you hereby consent to the collection and use of the information and disclosure on the Platform in accordance with this Policy, including but not limited to your consent for sharing your information in accordance with this Policy. We encourage you to read this Policy regarding the collection, use, and disclosure of your information. If you do not agree with any of the terms or policies described in this Policy, you can contact us at grievance@provalocosmetics.com.

You hereby agree and consent to receive all communications related to our services on the mobile number provided by you to us, even if such mobile number is registered under DND/NCPR list under the Telecom Commercial Communications Customer Preference Regulations, 2018 (“TRAI Regulations”). Notwithstanding the same, 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 our services. You hereby also agree and confirm that no communication to you from us or on our behalf 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 mobile number provided by you. 

For the purpose of this Policy, the term “Personal Information” shall mean any information that relates to you, either directly or indirectly, in combination with other information available or probably available with us and/or is capable of identifying you, which is submitted to and/or collected over the Platform and maintained by us 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 is personal information gathered by Provalo? 

We communicate with you through a variety of means and channels, including our Platform, email, phone or sms on your mobile phone, although we emphasize that our preferred means of communication is email which has 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: 

We restrict ourselves to collect information which is necessary to ensure accurate services and are required to process your order of the Product or provide a refund and continuously improve our Products and services.

The categories of Personal Information collected and processed by us is as follows:

We may maintain a record of your Product interests and acquire information about you from our future affiliates and 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.

Why is your personal information collected? 

We collect and use your Personal Information for verifying your identity, fulfill product purchases and transactions, communicate with you about your account and activities on the Platform, to sign up for our newsletter, respond to a survey or marketing communication, for  providing better services and responding to your requests, to respond to reviews, comments, or other feedback provided to us, to  administer a contest, promotion, survey or other site feature, to ask for ratings and reviews of the Products, to follow up with you after correspondence (live chat, email or phone inquiries), to allow you to log in with a social media account and share activities on your social media pages, to comply with our legal obligations, policies and procedures, including compliance with relevant industry standards and the enforcement of our terms and conditions, to help us learn more about your shopping preferences, for marketing and performance research and to assist us in measuring our customer services, benchmarking our performance and to help us improve your shopping experiences and product offerings, to send communication related to order updates and offers through e-mail, SMS and social media channels and do internal research on our Consumer’s demographics, interests, and behaviour to better understand and serve you, to provide you with exclusive offers at the Platform, alter content, advertisements, and improve the Platform and/or for internal business purposes, analyse trends, track Consumer’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 our terms and conditions in any jurisdiction and to establish, exercise or defend our 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. 

• Performance of a Contract: By purchasing our products and paying consideration to us, you entered into contract with us and accordingly we perform our contract of delivering the products required by you after you facilitate us with your personal information. An example of this would be where we would process your Personal Information for delivering the Products ordered by you on our Platform.

• Legitimate Interest: We have legitimate interest in obtaining your personal information, whereby we will be able to send you marketing information about our Products, communicate with you for serving you better.

• Compliance with a Legal Obligation: In order to comply with certain obligation we would be required to process your Personal Information. An example of this would be where we are required to retain business records for fixed periods of time for compliance of certain legal requirements.

• Consent: Your consent matters to us. We rely on your consent in order to process your Personal Information. Your consent is important to us to collect and process certain Personal Information and the same can only be done after securing your consent. You can withdraw your consent, in accordance to this Policy where applicable, by sending an email to grievance@provalocosmetics.com.

• Sharing of your information: 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. We 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. 

• Interactive Information: We maintain a social media presence, such as a Facebook, Instagram and LinkedIn Account. 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, your photos and similar information, which is often determined by your privacy settings at the relevant social media sites. We shall 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: We care about your Financial 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 we subscribe, and we do not, ourselves 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. 

• Personal Information: If use of your personal information through our Platform concerns you, you are requested to safeguard your Personal Information and maintain the confidentiality of your access information and password. You are also advised for restricting access to your computer, mobile device, etc., and as such it is your responsibility to secure your Password and guard yourself from all activities that are conducted under your password. We cannot secure any information that you release on you own or you request us to release or that is released through another third party who you may have given access to such information.

• Customer Support: We may record your calls for quality and training purposes.

 How we share your personal information? 

Your Personal Information can be accessed by those persons who are authorised by us. We may share your Personal Information only with persons who are subjected 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 Consumers. 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 obligations;

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

• In case, we plan to merge and/or sell all or substantially all of our business to another business entity or enter into such similar transactions or are required by such 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 or co-related acts or multiple accounts to prevent abuse of our Platform. If you have any objection to such sharing, you may contact us at grievance@provalocosmetics.com. 

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

Additionally, in some instances, in accordance with the policy of any third party, you may be offered the opportunity to consent for 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 by doing so, such information provided by you 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 for enforcement of our terms and conditions or Policy and respond to claims that an advertisement, posting or content right violation of a third party or protect the rights, property or personal safety of our products Consumers or the public. 

Third party interface 

Whenever you post any comments or content on our Platform, it may be read, collected, or used by the third parties. We advised you to submit your information carefully. We shall be not responsible for information you may choose to submit and cannot guarantee the manner in which the third parties will or may use your information. 

We may display links to websites that are owned or operated by third parties on our Platform. Please understand that these websites are independent from us and we do not have any control over their website and/or activities even if we provide information about their products on our website and/or information about our products to such Third Party Websites. We do not endorse and/or make any representations about accepting any responsibility for the content or practice or use of such third-party website. We also state that we shall not be responsible or liable in any manner for any damage or loss related to use of any third-party website. You are requested to read the terms and conditions and the privacy policy of a third-party website before allowing access or using it.

Why we use third party analytics? 

We use third-party analytics services to evaluate your use of the Platform, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to the Platform 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 may consent to processing of your information by these analytics providers in the manner and for the purposes set out in this Policy. 

We work with the following analytic partners:

We have implemented the use of remarketing with Google AdSense, Google Display Network Impression Reporting, Demographics and Interests Reporting, DoubleClick 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 may compile data regarding the Consumer interactions with ad impressions and other ad service functions as they relate to our Platform. You 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.

Retention of personal information 

We shall retain your Personal Information till the time it is reasonably required and/or otherwise permitted or required by law in force. We may also retain your Personal Information till the time it is necessary to fulfil the purposes for which it was collected (including for purposes of any legal, administrative, accounting, or other reporting requirements). Your Personal Information is safeguarded against inappropriate use, access and disclosure, in accordance with this Policy. 

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

Storing of 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 we have contracted, to support our business operations. 

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

Disposal of personal information

We shall endeavour to delete your Personal Information except for aforesaid reasons at your behest. 

• Do we use “COOKIES”? 

“Cookies” are small data files transferred to your computer's hard-drive by a website, while using a web browser after your consent is obtained. They keep a record of your activities on the Platform making your subsequent visits to the site more efficient. Cookies may store a variety of information, including, the number of times that you access the Platform, registration information and the number of times you viewed a particular page or other item on the Platform. Use of cookies is a common practice adopted by most major sites to better serve their clients. Various browsers are designed to accept cookies, however, they can be easily modified to block cookies. By continuing the use of our 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 our Platform.  

• Why we use cookies?

We use cookies to understand and save Consumer’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 allow notification to warn you each time a cookie is being sent, or you can choose to turn off all cookies through your browser settings and take help of your browser’s menu to learn the correct way to modify your cookies. 

Please take note that, if you turn cookies off, some features will be disabled which may affect your experience of qualitative e-services provided by us and may affect the efficient and smooth functioning of our website for you. However, it will not affect placing of orders for our products. 

Security 

We shall endeavour to protect your 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, which, interalia, include, physical measures such as locked filing cabinets, restriction of access to offices, and alarm systems and technical tools such as passwords and encryption, using generally industry best practices, organizational controls such as confidentiality agreements, limiting access on a need-to-know basis, staff training and security clearances.

Online security shall be our priority. We shall 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. We shall also attempt to keep your Personal Information updated, 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 taken all reasonable measures and precautions to keep such information safe and secure and to prevent any unauthorized access and/or or misuse of 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 Consumer enters, submits, or accesses their information to maintain the safety of your Personal Information.

However, we shall not be liable to any Consumers for any loss, damage (whether direct, indirect, consequential or incidental) or harm caused to Consumers due to the unauthorized access or misuse of the Personal Information by any third party.

Opting out: 

Provalo provides an option to all Consumers to opt-out of receiving any promotional or marketing communications from us. In case, you do not wish to receive any promotional or marketing communications from us, you can contact us at grievance@provalocosmetics.com or follow the steps as mentioned hereinbelow:

1. 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; 
2. You can remove content from Customer review; 
3. You can remove content that you posted on a public space, such as part of a ratings and review, by e-mailing details to grievance@provalocosmetics.com. 

Please note that we will endeavour to honour your request for removing your information, however, our removal of your information does not completely erase that information from the internet viz. historical copies, or “caches,” may remain. 

Consent is Consent. If you have accorded your consent to the collection, use and/or disclosure of your Personal Information in accordance with this Policy, you have the right to withdraw this consent at any time by writing to us at grievance@provalocosmetics.com.

You are requested to turn off location services on your device and/or handphone to avoid sharing any information through such device and/or handphone at anytime as you desire. 

Please note that, processing of any information carried out by us before the withdrawal of your consent shall remain lawful. 

Notwithstanding any withdrawal of your consent or request thereof, this information may be retained by us to comply with certain legal obligations, resolve disputes and enforce our agreements.

Children’s privacy 

Our website is designed to be used by adults only. We shall not knowingly collect any Personal Information from anyone below the age of eighteen (18). If you are below eighteen (18) years of age, you may browse our Website, however, you are requested to not provide your Personal Information to us. You are requested to not make any purchase and/or register and/or submit your information to our Website.

In case, we become aware that we have inadvertently received Personal Information from a visitor under the age of eighteen (18) on our Website, we shall delete the information from our records.

Policy review 

We may make amendments and/or alterations to this Policy from time to time in accordance with the law in force and/or whenever there are any requirements and/or any suggestions from you regarding this Policy. When such amendments and/or alterations are carried out with the Policy, the Policy link shall include the updated and/or revised date and you will receive such notification indicating that you should review the new terms, which will be effective immediately upon uploading on this website. 

By accessing the Platform after any such amendments and/or alterations have been made, you would signify your agreement on a prospective basis to the modified Policy and any amendments and/or alterations contained therein. 

Your rights as a consumer 

We believe that ‘Consumer is King’. We respect your ‘Right to Privacy’ and understand that you may interact with Provalo when you have privacy concerns. We understand that you have rights over your personal information and data. These rights involve providing reasonable steps to allow access to your personal information and/or to correct any errors and/or withdraw your consent and/or opt-out of marketing and/or ad-services. If you are concerned and/or unsatisfied about the handling of your Personal Information and/or with our response or have any unresolved concerns or if you have any complaints or queries related to your Personal Information or our Policy, you can get in touch with: 

Mr. Ramesh Kamble  (Grievance Officer)

Mob. No. +91 91117 96668

Email id – grievance@provalocosmetics.com 

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