PRIVACY POLICY

Renovatio Soulworks Private Limited (“Renovatio”) is the owner and the service provider of an internet based website and mobile application, which endeavors to provide the world with an exclusive range inspired beauty products under the brand name called MITTEE.

Our privacy policy is designed to provide greater transparency into our privacy practices and principles while processing your personal information.

Effective Date: 22 August 2018

This privacy policy describes the treatment of certain Personal Information provided by you or collected by us on products and services (collectively “Services”) where this privacy policy is posted.

By using our Services, you are hereby consenting to collection of your information by us. The information in some cases may include Personal Information and Sensitive Personal Information. The requirement to click on the box confirms your acceptance of this Privacy Policy. By accepting this Privacy Policy you are representing that you are eighteen (18) years of age or above.

  1. Legal Basis for collecting information

We process certain Information because it is necessary for us to be able to provide and administer the Services and its features. We also process certain Information to comply with certain statutory requirements.

Such data is processed based on your consent. To the extent that processing is carried out on the basis of consent, it is for you to give such a consent and you may at any time, wholly or partly, withdraw your consent. If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place.

Please note that certain Services require us to access certain Information and if you refuse to provide us the consent, it may result in a suspension of your account.

  1. Types of Information We Collect

We collect the following information as and when you access and use the Services as set out below:

  • Information you provide when you sign up for our Services: Registration information you provide when you create an account, including your first name and surname, country of residence, gender, age, email address, username and password;
  • Information you provide when you purchase products from our Services: Transaction information you provide when you request information or purchase products from our Services, including your postal address, telephone number and payment information;
  • Information you provide when you use our Services: Location information (either provided by a mobile device through which you utilize our Services or associated with your IP address) when you use our Services, usage, viewing and technical data, including your device identifier or IP address, when you use our Services on third-party sites or platforms or open emails we send;
  • Information you provide when you contact us for support: Information sent either one-to-one or within a limited group using our message, chat, post or similar functionality, where we are permitted by law to collect this information.
  1. How and Why We Collect Your Information 
  • We collect information through technology, such as cookies and web beacons when you use our Services. This enables us to identify the products and services that will work best for you. The information we learn from customers helps us personalize and continually improve your experience of the Services as set out below:
    • Provide the services you have requested;
    • Respond to your request for information and provide you with more effective and efficient customer service;
    • Provide you with product updates and information about the products you have purchased from us;
    • Provide you with service notifications via email and within the Services based on your notification selections;
    • Contact you by email, postal mail, or phone regarding services, surveys, research studies, promotions, special events and other subjects that we think may be of interest to you;
    • Provide a customized experience by providing targeted marketing and advertisements;
    • Help us better understand your interests and needs and improve the Services;
    • Synthesize and derive insights from your use of different products and services provided by us;
    • Engage in analysis, research, and reports regarding use of our Services;
    • Provide, manage, and improve the Services;
    • Protect our Services and our users;
    • Understand and resolve app crashes and other issues being reported.
  • We acquire information from other trusted sources to update or supplement the information you have provided to us or which are collected automatically.
  • We also use this information to improve our platform, prevent or detect fraud or abuses of our Services, for market research purposes and enable third parties to carry out technical, logistical or other functions on our behalf.
  • In addition to the above, we process your Personal Information to prevent, detect and investigate potential prohibited or illegal activities, including fraud, and to enforce our terms of use or for any other offer or marketing campaign as the case may be.
  1. Sharing with Third-Party
  • We share non-personally identifiable information with Google Analytics to improve our website’s load time, conversion rate and to check browser type, language preference, referring site and time of visit.
  • Payment – Within India we use CCAvenue as our payment gateway and internationally we use PayPal. We use VISA, MasterCard and American Express as our payment processors and pass on your Personal Information to them when you decide to upgrade your Services account so that this information can be used to prepare invoices. Your credit card information is securely stored with them at the time of purchase and is used for recurring billing.
  1. Information that cannot be uploaded

While using the Services, you shall not host, display, upload, modify, publish, transmit, update or share any information on to the Services that:

  • belongs to another person and to which you do not have any right to;
  • is grossly harmful, harassing, blasphemous, defamatory, obscene, pornographic, pedophilic, libelous, invasive of another's privacy, hateful, or racially/ethnically objectionable, disparaging, relating to or encouraging money laundering or gambling, or otherwise unlawful in any manner whatever;
  • harms minors in any way;
  • infringes any patent, trademark, copyright or other proprietary rights;
  • violates any law for the time being in force;
  • deceives or misleads the addressee about the origin of such messages or communicates any information which is grossly offensive or menacing in nature;
  • impersonates another person;
  • contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer resource;
  • threatens the unity, integrity, defense, security or sovereignty of India, friendly relations with foreign states, or public order or causes incitement to the commission of any cognizable offence or prevents investigation of any offence or is insulting any other nation.
  1. Your Controls and Choices

You can control your choices regarding our collection, use and sharing of your information. In accordance with local law, your controls and choices may include:           

  • You may correct, update and delete your account;
  • You may change your choices for subscriptions, newsletters, product emails and alerts;
  • You may request access to the personal information we hold about you and that we shall amend or delete it and we shall request third parties with whom we have shared the information do the same. Once you place a request to delete the personal information, we shall take all reasonable steps taking into account available technology and the means available to us, including technical measures to erase the personal information.

Further, you may exercise your right to data portability, which means that you have the right to receive the Personal Information processed about you in a structured, commonly used and machine-readable i.e. HTML format. Please note that some of the rights above only may be exercised in certain situations, e.g. the right to data portability, which only applies when the processing is carried out on the basis of an agreement or a consent and if the processing is carried out by automated means. In case you have any questions regarding how we process your Personal Information, would like to exercise any of your rights or want to know more about the rights, you may contact us as indicated below.

E-mail address: customercare@mittee.com 

If you do not want us to process your Personal Information for direct marketing, you can give written notice thereof to us. In each newsletter, you will also be informed that you can opt out of receiving further newsletters.

You are also entitled to lodging a complaint with a supervisory authority if you consider that your Personal Information has been processed in contradiction with applicable data protection legislation.

You may exercise your controls and choices, or request access to your personal information, by contacting us at customercare@mittee.com, or can follow instructions provided in communications sent to you. Please be aware that, if you do not allow us to collect personal information from you, we may not be able to deliver certain products and services to you, and some of our services may not be able to take account of your interests and preferences. If you have questions regarding the specific personal information about you that we process or retain, please contact our grievance office mentioned in clause 12

  1. Children’s Privacy

Use of the Services is available only to persons who can form a legally binding contract under the Indian Contract Act, 1872. Our Services are not meant for minors and users below 18 (eighteen) years of age. We do not intentionally collect data from users who are below 18 (years) of age.

  1. How long is the data kept?

We will keep Personal Information regarding you only as long as it is necessary, having regard to the purpose of the processing. This means that Personal Information collected and processed will be stored for as long as you have an account and deleted within 6 months after your subscription has ended unless you have given us your voluntary consent to continue to process such data.

We will also, during the same period, keep your account information, to facilitate your easy return. We may store data for longer if required by law or if required in our legal interests, for example if there are ongoing legal proceedings.

  1. Data security and integrity

The security, integrity and confidentiality of your Personal Information are extremely important to us. We have implemented technical, administrative and physical security measures that are designed to protect guest information from unauthorized access, disclosure, use and modification. From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable. We limit access to personal information about you to employees who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs.

However, we may be required to share the aforesaid Personal Information with government authorities and agencies for the purposes of verification of identity or for prevention, detection, investigation including cyber incidents, prosecution and punishment of offences. You agree and consent for us to disclose your information, if so required under the applicable law.     

All interactions with our Services use the Transport Layer Security/Secure Sockets Layer (TLS/SSL) protocol. We use a third-party Payment Gateway to securely process credit card transactions.

All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted. Except for your password, data isn’t encrypted while it’s live in our database (since it needs to be ready to send to you when you need it).

All data that we store in our log files or send to third party software that we use to analyze errors with the software is anonymized and no personal identifiable information is sent to them.

  1. Data Transfers, Storage and Processing Globally

We operate globally and may transfer your Personal Information and Sensitive Personal Information to third parties in locations around the world for the purposes described in this privacy policy. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. By accepting this Privacy Policy, you hereby explicitly provide your consent and grant us the right to transfer your Personal Information and Sensitive Personal Information to third parties.

  1. Changes to this Privacy Policy

From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We shall provide notice to you through the contact details provided to us by you. Please note that in the event you fail to accept our revised Privacy Policy within 30 days of us intimating the revisions to the privacy policy, your access to the Services shall be suspended till such time you accept the revisions of the privacy policy.

  1. Contact in case of grievances

If you have any concerns about privacy or grievances regarding the Services, please contact us at customercare@mittee.com along with a thorough description of the issue and we shall try and resolve the matter at the earliest and to the best of our ability.

  1. Comments and Questions 

If you have a comment or question about this privacy policy, please contact us at customercare@mittee.com . Our Services may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our Services and to read the privacy policies of other sites that may collect your personal information.     

  1. Cookies

What are cookies?

Cookies are pieces of information that a website places on the hard drive of your computer when you visit the website. Cookies may involve the transmission of information from us to you and from you directly to us, to another party on our behalf, or to another party in accordance with its privacy policy. 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. If you turn cookies off, you won’t have access to many features that make your guest experience more efficient and some of our services will not function properly.

How do we use cookies?

We and certain service providers operating on our behalf collect information about your activity on our Services using tracking technologies such as cookies, flash cookies and web beacons. We use two types: persistent cookies and session cookies. A persistent cookie helps us recognize you as an existing user, so it’s easier to return to the Services or interact with our Services without signing in again. After you sign in, a persistent cookie stays in your browser and will be read by us when you return to one of our products. Session cookies only last for as long as the session (usually the current visit to a website or a browser session). This tracking data is used for many purposes including, for example, to: 

  • Authentication: If you’re signed in to the Services, cookies help us show you the right information and personalize your experience.
  • Security: We use cookies to enable and support our security features, and to help us detect malicious activity and violations of our Terms & Conditions.
  • Preferences, features and services: Cookies can tell us what your communications and product preferences are.
  • Performance, Analytics and Research: Cookies help us learn how well our site and plugins perform in different locations. We also use cookies to understand, improve, and research products, features, and services, including when you access our Services from other websites, applications, or devices such as your work computer or your mobile device.

Controlling cookies

While you may block and/or limit our access to cookies, if you limit the ability of websites to set cookies, if may affect your overall user experience, since it will no longer be personalized to you. It may also stop you from saving customized settings like login information.

Definitions

Anonymous Information. Anonymous information means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual guest. 

IP address. An IP address is associated with the access point through which you enter the Internet, and is typically controlled by your Internet Service Provider (ISP), your company, or your university. We may use IP addresses to collect information regarding the frequency with which our guests visit various parts of our products hosting our Services, and we may combine IP addresses with personal information. 

Notice. Notice may be by email to you at the last email address you provided us, by posting notice of such changes in our Services, or by other means, consistent with applicable law.

Personal information. Personal information means and includes information that identifies (whether directly or indirectly) and Sensitive Personal Information of a person by reference to an identifier such as a name, an identification number, location data or an online identifier to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of such person. When anonymous information is directly or indirectly associated with personal information, this anonymous information also is treated as personal information.

Public Forums. Our Services may offer message boards, conversation pages, blogs, chat rooms, social community environments, profile pages, and other forums that do not have a restricted audience. If you provide personal information when you use any of these features, that personal information may be publicly posted and otherwise disclosed without limitation as to its use by us or by a third party.

Sensitive Personal Information. Sensitive Personal Information shall have the meaning ascribed to it under the applicable law and is presently defined to mean such personal information which consists of information relating to (i) passwords; (ii) financial information such as bank accounts or credit card or debit card or other payment instrument details; (iii) physical, physiological and mental health conditions; (iv) sexual orientation; (v) medical records and history; (vi) Biometric information; (vii) any detail relating to the above clauses as provided to body corporate for providing service; and (viii) any of the information received under above clauses by body corporate for processing, stored or processed under 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, 2000 or any other law for the time being in force shall not be regarded as sensitive personal information.