This Privacy Notice outlines COMPANION INDIA approach to Data Protection to fulfil its obligations under the EU General Data Protection Regulation 2016/679 (‘GDPR’). This Privacy Notice applies to your Personal Data which is processed by us, whether in physical or electronic mode. This notice shall apply to you ONLY if GDPR applies to the processing of your Personal Data by us.
In this Privacy Notice, the expressions ‘Personal Data’, ‘Data Subject’, ‘Controller’, ‘Processor’ and ‘Processing’ shall have the meanings given to them in the GDPR.
We are committed to treating data privacy seriously. It is important that you know exactly what we do with your Personal Data.
Throughout this document, “we”, “us”, “our”, “ours” refer to COMPANION INDIA Wherever we have said ‘you’ or ‘your’, this means YOU (as a Data Subject).
Who We Are
COMPANION INDIA is a company incorporated and registered under the provisions of the Companies Act, 2013 and having its registered office at 104, Vasan Udyog Bhavan, Sun Mill Compound, Lower Parel, Mumbai 400 013. COMPANION INDIA is engaged in the business of facilitating selling, marketing and retailing clothes / garments (“Business”) through the e-commerce websites and mobile applications (“App”) both developed and owned by COMPANION INDIA and its affiliates (Website and App collectively referred to as “Platform”) or offline stores / events to conduct its Business.
Roles We Play
We play the role of a Data Controller when we collect and process Personal Data about you.
We play the role of a Data Processor when we collect and process Personal Data on behalf of another Data Controller
Our Commitment
We commit to protecting your privacy and hence our Personal Data handling practices are continually reviewed to ensure compliance with the European Union General Data Protection Regulation (GDPR), 2018.
Your rights as a data subject
We understand that when you interact with Nykaa, you have rights over your Personal Data. These rights involve providing reasonable steps to allow you to access your personal data, correct any errors among others. This is your right and you can exercise any of these rights whenever you want. In the event that you are not satisfied with our response or have unresolved concerns, you can get in touch with us to resolve the issue by means of privacy@nykaa.com.
To access your rights as a data subject for accessing or rectifying your personal data. click here.
Categories of Personal Data
Categories of Personal Data collected and processed by us are as follows;
Demographic & Identity data
- Contact details such as Name, email address, contact number, shipping address, country,date of birth
- Open data and public records such as information about YOU that is openly available on the internet
Contact details such as Name, email address, contact number, shipping address, country,date of birth
- Details such as Transaction amount, Bank Name, Card Type, Card number.
Online Identifiers and other Technical Data
- Location details such as data we get about your location, IP address, logs, or from where you connect a computer to the internet
- Technical details such as device ID when you use our mobile applications
- Communications details such as the Metadata and other Personal Data we get from communications done through e-mails, SMS, instant messages and calls
- Usage data details such as data about how you use our website or web-based properties, pages viewed, etc.
Lawful bases of Processing your Personal Data
We are permitted to process your Personal Data in compliance with GDPR by relying on one or more of the following lawful bases:
- You have explicitly agreed to us processing your Personal Data for a specific reason
- The processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you
- The processing is necessary to be in compliance with our Legal Obligations
- The processing is necessary for the purposes of a legitimate interest (“Legitimate Interest”) pursued by us, such as
- to provide services to you,
- to evaluate, develop or improve our products and services
Where the processing is based on your consent, you have a right to withdraw your consent at any time. You may withdraw consent by contacting us. Upon receipt of your written request to withdraw your consent, consequences of withdrawal will be communicated to you and, upon your agreement, your request for withdrawal will be processed.
Cookies Other Trackers
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website.
We use cookies, permissions and other trackers in our website, web-based properties and mobile applications that are used to collect data about you.
Below are the categories of cookies used on our website along with a description of what they are used for
Strictly Necessary
These cookies are needed to run our website, to keep it secure if you are logged on and to obey regulations that apply to us.
If you are a customer, they help us know who you are so that you can log on and manage your accounts. They also help us keep your details safe and private.
Functional
These cookies are used for remembering things like:
- Your user ID on the log on page
- Your region or country
- Your preferred language
- Accessibility options like large font or high contrast pages
Performance
These cookies tell us how you and our other customers use our website. We combine all this data together and study it. This helps us to:
- Improve the performance of our services
- Improve the products we provide
Most web browsers allow some control of most cookies through the browser settings. Please note disabling the ‘Strictly Necessary’ cookies may cause certain parts of our website to remain inaccessible to you.
We use other tracking mechanisms in addition to the above.
- Pixel Tags
- Log Files
- Clickstream analytics
In addition to cookies and tracking mechanisms on our website and web-based properties, we also take permissions which help us to serve you.
Personal Data Disclosure
We use third parties who provide elements of our products & services on behalf of us. We have appropriate contracts in place with our third-party partners. This means that they cannot do anything with your Personal Data which is outside of the scope permitted by us. They hold it securely and retain it only for the period specified in our contracts with them.
We might also disclose your Personal Data to appropriate authorities if we believe that it is reasonably necessary to comply with a law, regulation, legal process, to protect the safety of any person, to address fraud, security, or technical issues, or to protect our rights or the rights of those who use our products & services.
Reasons for disclosing your Personal Data to other parties:
We may disclose your Personal Data to others where it is lawful to do so including where we or they:
- need to provide you with products or services
- where you have initiated a payment
- have a legal obligation to do so, e.g. to assist with detecting and preventing fraud,
- have requirement in connection with regulatory reporting, litigation or asserting or defending legal rights and interests
- have a legitimate business reason for doing so
- want to send you information and promotional material regarding our products and services,
- have asked you for your consent to share it, and you’ve agreed
To whom your Personal Data may be disclosed:
We may disclose your Personal Data for the above purposes to other parties including:
- Other group companies and any sub-contractors, agents or service providers who work for us or provide services to us or group companies (including their employees, sub-contractors, service providers, directors and officers)
- Law Enforcement Authorities, Government Authorities, courts, dispute resolution bodies, our regulators, auditors and any party appointed or requested by our regulators to carry out investigations or audits of our activities
- Statutory and regulatory bodies and authorities (including the government) investigating agencies and entities or persons, to whom or before whom it is mandatory to disclose the Personal Data as per the applicable law, courts, judicial and quasi-judicial authorities and tribunals, arbitrators and arbitration tribunals
- Overseas regulators
- Anybody else that we’ve been instructed to share your Personal Data with by you.
Cross-border Data Transfer
Personal Data we hold about you may be transferred to other countries outside your residential country for any of the purposes described in this Privacy Notice.
You understand and accept that these countries may have differing (and potentially less stringent) laws relating to the degree of confidentiality afforded to the information it holds and that such information can become subject to the laws and disclosure requirements of such countries, including disclosure to governmental bodies, regulatory agencies and private persons, as a result of applicable governmental or regulatory inquiry, court order or other similar process. In addition, a number of countries have agreements with other countries providing for exchange of information for law enforcement, tax and other purposes.
If we transfer your Personal Data to third parties for purposes stated in this Privacy Notice, we will use best endeavors to put in place appropriate controls and safeguards to ensure that your Personal Data is kept accurate, adequately protected, and processed only for specified and reasonable purposes in a manner that is fair, transparent and has a lawful basis, and is stored for no longer than is absolutely necessary.
Data Security
We are committed to protecting your Personal Data in our custody. We take reasonable steps to ensure appropriate physical, technical and managerial safeguards are in place to protect your Personal Data from unauthorized access, alteration, transmission and deletion. We ensure that the third parties who provide services to us under appropriate contracts, take appropriate security measures to protect your Personal Data in line with our policies.
Retention and Disposal of Data
We keep the Personal Data we collect about you on our systems or with third parties for as long as it is required for the purposes set out in this Privacy Notice and for legal or regulatory reasons. We will only use your Personal Data for those purposes and will make sure that your Privacy is protected. We shall take reasonable steps to delete or permanently de-identify Personal Data that is no longer needed.
Links to Other Websites
Our website may contain links to websites of other organisations. This privacy notice does not cover how that organisation processes Personal Data. We encourage you to read the privacy notices on the other websites you visit.
Children’s Privacy
Our website is directed to be used by adults only. If you are not an adult, while you may look at our site, but you should not make a purchase, register, or submit Personal Data to us. We or our associates /affiliates do not knowingly collect information from minors.
Your Data Protection Rights
If you are an EU resident, under the GDPR, you have the following rights and we commit to provide you with the same:
- Right of Access:You have the right to get access to your Personal Data that is with us along with other supporting information
- Right to Rectification: You have the right to ask us to rectify your Personal Data that is with us that you think is inaccurate. You also have the right to ask us to complete your Personal Data that you think is incomplete
- Right to Erasure:You have the right to ask us to erase your Personal Data that is with us under certain circumstances
- Right to Restriction of Processing:You have the right to ask us to restrict the processing of your Personal Data under certain circumstances
- Right to Data Portability:You have the right to ask that we transfer the Personal Data you gave us to another organization, or to you, under certain circumstances
- Right to Object: You have the right to object to the processing of your Personal Data under certain circumstances
- Right to lodge a complaint with the Supervisory Authority:You have the right to lodge a complaint with a supervisory authority
- Right to not be subjected to Automated individual decision-making, including profiling
If you wish to make a request to exercise any of your rights, you can only send your request using the details mentioned in the ‘Contact us’ section of this notice.
Contact Us
For any further queries and complaints related to privacy, or exercising your rights under GDPR, you could reach us at: Contact Email Address: info@companionindia.com
Notification of Changes
We keep our Privacy Notice under regular review to make sure it is up to date and accurate. Any changes we may make to this Privacy Notice in the future will be posted on this page. We recommend that you re-visit this page regularly to check for any updates.