We, Senco Gold Limited (“Company”), are committed to protecting the personal information provided by the user (“You”, “Your”, or “User”) that may directly or indirectly identify You. This Privacy Policy (“Policy”) applies to Your use of the application called ‘Senco’ or related brands (“Application” or “App”) and the e-commerce website mysenco.in (“Website”), and outlines:

• The types of personal and non-personal information We may collect when You access or use our websites, applications, and other online services (collectively referred to as the “Services”); and
  
• Our policies and practices regarding the collection, use, maintenance, protection, and disclosure of such information.

ANY CAPITALIZED TERMS USED HENCEFORTH SHALL HAVE THE MEANING ACCORDED TO THEM UNDER THIS POLICY. ALL HEADINGS USED HEREIN ARE SOLELY FOR THE PURPOSE OF ORGANIZING THE VARIOUS PROVISIONS OF THIS POLICY AND SHALL NOT BE USED TO LIMIT OR INTERPRET THE SCOPE OF ANY SECTION.

Terms of our Privacy Policy:

Definitions

"Affiliate" means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for election of directors or other managing authority.

"Data" means a representation of information, facts, concepts, opinions, or instructions in a manner suitable for communication, interpretation, or processing by human beings or by automated means.

"Digital Personal Data" includes Your Personal Data, which is collected either in digital form or any non-digital form which is digitised subsequently.

"Personal Data" means any data about an individual who is identifiable by or in relation to such data.

"Service Provider" includes any natural or legal person who processes the Digital Personal Data on behalf of the Company.

"We", "Our", and "Us" shall mean and refer to the Company.

"You", "Your", "Yourself" and "User" shall mean and refer to natural persons who use the App/Website.

Types of Data Collected

During registration on our App/ Website or usage of our App/ Website or both, We will collect Your following data/information, as and when necessary, including, but not limited to:

1. User information
   • name
   • gender
   • occupation
   • education
   • address
   • consumer durables owned
2. Communication details
   • email address
   • phone number
   • postal address
   • any other contact information
3. Device information
   • operating system providing advertising ID
   • IP address
   • date and time of every user request
   • standard server log information
   • your internet protocol address
4. Behavioural patterns
   • 'liking' or 'disliking' of a product
   • 'adding' or 'removing' a product from wishlist
   • sharing a product or inspiration to social media sites such as Facebook, Instagram, Twitter etc.
   • other interactions and dialogues during interactive search
   • active seconds or minutes on Our Website/Application
5. Non-personal user information (THIS TYPE OF INFORMATION DOES NOT IDENTIFY YOU PERSONALLY)
   • the pages you visit
   • links you click
   • advertisements you view
   • number of times you access Our page
   • Your opinion on services, products, and features on Our Websites/Application
   • information regarding Your preferred books, music, movies etc.
   • operating system
   • browser type
   • internet service provider
   • aggregate user data
   • software and hardware attributes
   • number of clicks

We may also collect anonymous traffic information from You when You visit Our Website/Application. If You communicate with Us, by, for example, email or letter, any information provided in such communication may be collected and stored by Us.

Purpose of Processing of Digital Personal Data

• 1. The Digital Personal Data collected from You is used to ensure services with respect to the Website/App are presented to You in the most effective manner, to carry out Our obligations to You, and to communicate with You.
• 2. Specifically, you understand that Your Digital Personal Data may be processed for any or all of the following purposes:
  
  1. Fulfilling customer orders placed, including but not limited to, managing payment transactions, coordinating shipping logistics, and facilitating the delivery of goods;
  2. Facilitating communication regarding order confirmations, invoices, and receipts for purchases made both online and offline;
  3. Communicating updates pertaining to the status of orders or delivery schedules;
  4. Managing inquiries, complaints, or requests for assistance;
  5. Disseminating newsletters and promotional communications regarding upcoming events, sales, and the introduction of new products;
  6. Soliciting customer feedback through surveys and rating mechanisms;
  7. Enrolling in loyalty or rewards programs and thereby tracking points or rewards accumulated through purchases made both online and offline;
  8. Complying with applicable legal obligations, including but not limited to tax reporting, audit requirements, or responses to requests from law enforcement authorities;
  9. Analysing market trends, conducting market research, and improving overall business strategies, utilizing information gathered from both online and offline sales;
  10. Detecting and preventing fraudulent transactions or unauthorized access to customer accounts, thereby safeguarding both the customer and the brand across all sales channels;
  11. Sharing information with third-party service providers for limited purposes of operational and logistical functions to complete the order;
  12. Facilitating linking of customer accounts with social media platforms for the purpose of sharing purchases or promotional materials, whether derived from online or offline transactions;
  13. Employing Cookies and similar tracking technologies on the Website and/or App to analyse traffic and enhance user experience through the collection of data related to user interactions;
  14. Facilitating effective communication, assessing service quality, and managing supply chain operations for purposes related to the business relationship, including but not limited to entering into and managing agreements, evaluating supplier qualifications, processing payments, and ensuring compliance with contractual obligations;
  15. To build up marketing profiles;
  16. Aiding strategic development, data collection and business analytics;
  17. Auditing usage of the App and/or the Website;
  18. Enhancing user experience in relation to the App and/or the Website;
  19. Managing our relationship with advertisers and other partners;
  20. Any other grounds as per applicable law.

We Share Your Digital Personal Data in the Following Circumstances:

• Advertising
  The Company uses some third parties to administer a limited set of advertisements on Our App and Website. During this process, your aggregate profile information may be used in the selection of advertising to make sure that it has relevance to You. On some banner ads, an embedded pixel may be present, and while it does not associate with a cookie or other personal profile information, it may return session connection information that allows advertisers to better determine how many individual users have clicked on the advertisement banner.
• Affiliates
  We share much of Our data, including Your Digital Personal Data, with Affiliates that are committed to serving Your needs through use of Our App/Website and related services. Such data shall be shared for the sole purpose of enhancing Your experience of using the Website/Application.
• Law and Order
  We regularly cooperate with law enforcement authorities and sectoral regulators in case of any investigation, inquiries or proceedings. We shall, and You so authorise Us, to disclose Your Digital Personal Data to law enforcement and other regulatory authority as per applicable laws in connection with any investigation inquiries or proceedings.
• External Links on the Application/Website
  Our platforms may contain links to third party websites or applications. The inclusion or exclusion of the link does not imply any endorsement by the Company of the website, the website's provider, or the information on the website. You agree and understand that privacy policies of these websites are not under Our control. The Company does not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor does the Company guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, messages or other materials available on such websites. You understand that once You leave Our servers, use of any information You provide shall be governed by the privacy policy of the operator of the site used by you. Hence, the Company encourages You to read the privacy policies of each such website and You understand that it is solely such third party who is responsible to You in this regard. THIS POLICY DOES NOT APPLY TO THE DIGITAL PERSONAL DATA THAT YOU PROVIDE TO, OR THAT IS COLLECTED BY (i) ANY THIRD PARTY THROUGH OUR WEBSITE/APPLICATION AND (ii) ANY THIRD-PARTY WEBSITE(S)/APPLICATION(S) THAT YOU ACCESS OR USE IN CONNECTION WITH THE SERVICES OFFERED THROUGH OUR WEBSITE/APPLICATION. THE COMPANY SHALL NOT BE LIABLE FOR AND HAS NO CONTROL OVER THE PRACTICES AND CONTENT OF ANY SUCH THIRD PARTIES.
• Business Transfers
  In case We are acquired by or merged with another company, We shall transfer Your Digital Personal Data to the entity We are acquired by or merged with. In the event of a merger or acquisition, We shall notify You by email and put a prominent notice on the Website/App before Your Digital Personal Data is transferred and becomes subject to a different privacy policy. You will have the right to opt out of such transfer of your Digital Personal Data to the third party entity in a manner prescribed herein.
• You understand that any Digital Personal Data that You make publicly available on the Website/Application may be potentially viewed by any party, and by posting such material it is deemed that You consent to share such information with such parties. Further, 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 DIGITAL PERSONAL DATA FOR THE PURPOSE OF THIS POLICY.

YOUR RIGHTS AND CHOICES

• 1. Right to Consent:
  Collection and Processing of Your Digital Personal Data is subject to your free, specific, informed, unconditional and unambiguous consent. We agree that the Company will not collect or process your Digital Personal Data unless you specifically consent to this Policy. If You do not agree with Our practices regarding Your Digital Personal Data, please do not use Our Platforms. By accessing or using Our Platforms, You acknowledge that You have read, understood, and agree to the terms outlined in this Policy.
• 2. Right to Access Digital Personal Data:
  You have the right to request for a summary of the Digital Personal Data which We are processing along with the processing activities undertaken by Us with respect to such Digital Personal Data.
• 3. Right to Rectification and Erasure of Digital Personal Data:
  You have the right to have any inaccurate Digital Personal Data about You rectified and, taking into account the purposes of the processing, to have any incomplete Digital Personal Data about You completed. Further, You also have the right to the erasure of Your Digital Personal Data. Those circumstances include:
  • (a) the Digital Personal Data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • (b) You withdraw consent to consent-based processing;
  • (c) You object to the processing under certain rules of applicable data protection law;
  • (d) the processing is for direct marketing purposes; and
  • (e) the Digital Personal Data has been unlawfully processed.
  However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary, for exercising the right of freedom of expression and information, for compliance with a legal obligation, or for the establishment, exercise, or defence of legal claims.
• 4. Right to Restrict Processing of Digital Personal Data:
  In the following circumstances You have the right to restrict the processing of Your Digital Personal Data:
  • (a) You contest the accuracy of Your Digital Personal Data;
  • (b) processing is unlawful but You oppose erasure;
  • (c) We no longer need Your Digital Personal Data for the purposes of Our processing, but You require Your Digital Personal Data for the establishment, exercise or defence of legal claims;
  • (d) You have objected to processing, pending the verification of that objection.
  In the event the processing has been restricted on the above circumstances, We may continue to store Your Digital Personal Data. However, We will only otherwise process it, with Your consent,
  • (i) for the establishment, exercise or defence of legal claims;
  • (ii) for the protection of the rights of another natural or legal person; and
  • (iii) for reasons of public interest.
• 5. Right to Object to Processing:
  i. You have the right to object to Our processing of Your Digital Personal Data on grounds relating to Your particular situation, provided such objection is not to the extent, as far as practicable, of processing where the legal basis of such processing is necessary for:
  • (a) undertaking a transaction carried out in public interest or in the exercise of any official authority vested in Us; or
  • (b) the purposes of legitimate interests pursued by Us in a bonafide manner.
  ii. If You make such an objection as mentioned above, We will cease to process the Digital Personal Data, provided that We shall not cease such processing if We can demonstrate compelling and legitimate grounds for the processing which override Your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims. iii. You further have the right to object to Our processing of Your Digital Personal Data for direct marketing purposes, including profiling for direct marketing purposes. If You make such an objection, We will cease to process Your Digital Personal Data for this purpose. iv. Where processing is for scientific or historical research purposes or statistical purposes, You have the right to object to Our processing of Your Digital Personal Data on grounds relating to Your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest, to the extent that the legal basis for our processing of Your Digital Personal Data is:
  • (a) consented;
  • (b) that the processing is necessary for the performance of a contract to which You are party; or
  • (c) in order to take steps at Your request prior to entering into a contract, and such processing is carried out by automated means.
  Note: we may use ‘aggregate’ level user information to build marketing profiles, develop technology that can improve user experience, analyse usage of Our App/Website.
• 6. Right to Withdraw Consent:
  To the extent that the legal basis for Our processing of Your Digital Personal Data is consented, You have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. You further understand that withdrawal of consent for processing of Digital Personal Data will be implemented as soon as practicable. You also confirm that We, while accepting Your request for withdrawal of consent, will be allowed to keep such Digital Personal Data as required by the applicable laws and regulations for history and record keeping purposes for a specified period of time.
  If You need to withdraw Your consent with respect to usage of Your Digital Personal Data under Our purview, excluding the Digital Personal Data which has already been shared with the authorities, regulators or business associates and was outside Our control at that time, You will inform Us by Click Here.
• 7. Right of Grievance Redressal:
  The Company shall address any discrepancies and grievances of provider of the information with respect to collecting and processing of Digital Personal Data in a time bound manner. If You have any queries, comments or grievances relating to the processing or usage of Digital Personal Data provided by You, send us a written communication at the email ID given below.
  
  Grievance Officer: Mukund Chandak
  Email id: dataprivacy@sencogold.co.in
  Contact no: + 91-033 4021 5000 / 5004
  Important Note: Contact the grievance desk if You didn't receive a desired resolution through compliance@sencogold.co.in
  Your grievances shall be addressed by the Grievance Officer within 15 days from the date of receipt of grievance.
• 8. Right to Complain to Regulatory Authority:
  If You consider that Our processing of Your Digital Personal Data infringes applicable laws and the Company has not addressed your grievances as per this Policy, You have the right to approach the Data Protection Board of India.
• 9. Right to Nominate:
  You have the right to nominate a representative to act on Your behalf regarding the processing of Your Digital Personal Data. This representative may exercise Your data rights and make decisions concerning Your Digital Personal Data in accordance with applicable laws and regulations. To nominate a representative, You must provide written authorization to customerfeedback@sencogold.co.in specifying the individual or entity You wish to appoint as Your representative. This authorization should include the representative’s contact details and any specific instructions regarding the handling of Your Digital Personal Data. Your nomination of a representative will be considered valid and effective upon Our receipt of the written authorization. We reserve the right to verify the authenticity of the authorization and may request additional information or documentation as necessary.
• 10. Right to Data Portability:
  You have the right to request that we transfer Your Digital Personal Data to another third party. This right of data portability only applies to certain types of Digital Personal Data.

Retention of Digital Personal Data

We adhere to the principles of purpose limitation and data minimization. Therefore, we only store Your Digital Personal Data for as long as it is necessary to achieve the purposes mentioned here or as long as the many storage period required under the applicable laws. After discontinuation of the respective purpose or expiry of these deadlines, the corresponding Digital Personal Data will be deleted in accordance with the statutory provisions. However, even if we delete Your Digital Personal Data, it may persist on backup or archival media for audit, legal, tax or regulatory purposes or any other purpose specifically permitted under the applicable laws.

Transfer of Your Digital Personal Data

Your Digital Personal Data is processed at the Company’s operating offices and in any other places where the Service Providers appointed by the Company and involved in the processing are located. It means that this information may be transferred to — and maintained on — servers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Your consent to this Policy followed by Your submission of such information represents Your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that Your Digital Personal Data is treated securely and in accordance with this Policy and no transfer of Your Digital Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your Digital Personal Data.

Children under the age of 18

Our Site is not intended for children under 18 years of age, and We do not knowingly collect or use any Digital Personal Data from children under the age of 18 years. No one under 18 years of age may provide any Digital Personal Data to Us or on the Site. If We learn that We have collected or received any Digital Personal Data from a child under 18 years of age, We shall delete the information. If You believe We might have any information from or about a child under the age of 18, please contact us at customerfeedback@sencogold.co.in.

Data Security

We treat data as an asset that must be protected against loss and unauthorised access. We employ many different security techniques to protect Your Digital Personal Data from unauthorised access by members inside and outside the Company. We follow ISO 27001:2022 and PCI DSS SAQ A 4.0 industry standards to protect the Digital Personal Data submitted to Us and information that we have accessed. However, “perfect security” does not exist on the Internet. You therefore agree that any security breaches beyond the control of Our standard security procedures are at Your sole risk and discretion. We have put in place procedures and Privacy Incident and Personal information Breach Management Policy, to deal with any suspected data security breach and will notify You and any applicable regulator of a suspected breach where we are legally required to do so. Further, we work hard to protect Our users from unauthorized access or unauthorized alteration, disclosure, or destruction of information we hold. In particular:

• We encrypt Our services using Secure Sockets Layer (SSL).
• We review Our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
• We restrict access to personal information to employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

Severability

Each paragraph of this Policy shall be and remain separate from and independent of and severable from all and any other paragraphs herein except where otherwise expressly indicated or indicated by the context of the Policy. The decision or declaration that one or more of the paragraphs are null and void shall have no effect on the remaining paragraphs of this Policy.

Policy Changes

We reserve the unconditional right to change, modify, add, alter or remove portions of this Policy at any time, without specifically notifying You of such changes. Any changes or updates will be effective immediately. You should review the Policy regularly for changes. If We make any significant changes, We will endeavour to provide You with reasonable notice of such changes, such as via a prominent notice to Your email address on record with Us and where it is required as applicable by the Indian laws, We will obtain Your consent. Your acceptance of the amended Policy and/or Your continued use of Our services after We publish or send a notice about Our changes to this Policy shall signify Your consent to such changes and be legally bound by the same.

Security of Digital Personal Data

Your security is important to Us. We adopt reasonable security practices and procedures to include technical, operational, managerial and physical security control measures in order to protect Your Digital Personal Data in Our possession from loss, misuse and unauthorised access, disclosure, alteration and destruction. We maintain physical, electronic and procedural safeguards in connection with the collection, storage, processing and disclosure of Digital Personal Data.

Disclaimer of Warranties

The Company provides the Website and Application and the services “as is”. The Company makes no express or implied warranties or guarantees about the services. To the maximum extent permitted by law, the Company disclaims all such warranties, including all statutory warranties, with respect to the services and the Website, including without limitation any warranties that the services are merchantable, of satisfactory quality, accurate, fit for a particular purpose or need, or non-infringing. The Company does not guarantee that the results that may be obtained from the use of the services will be effective, reliable, or accurate or will meet Your requirements. We incorporate commercially reasonable safeguards to help protect and secure Your Digital Personal Data, however, no data transmission over the internet, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information You transmit to us, You provide us with Your information at Your own risk.

Indemnity

You agree and undertake to indemnify us in any dispute by any third party arising out of disclosure of Digital Personal Data by You to third parties either through Our App, Website or otherwise and Your use and access of apps, websites or resources of third parties. We assume no liability for any actions of third parties with regard to Your Digital Personal Data, which You may have disclosed to such third parties.

Representation and Warranties

You represent and warrant that the Digital Personal Data provided by You and regulated by this Policy is true, correct, consistent and accurate and that you agree and shall indemnify and complete save harmless the company, promptly upon demand from time to time against any and all losses, claims or actions relating to or arising out of any inaccuracy in the Digital Personal Data provided by you. You agree to periodically update the Digital Personal Data provided by you by sending an email at customerfeedback@sencogold.co.in as and when there is any change in the Digital Personal Data so provided.

Data Breach

In case of breach of Your Digital Personal Data, We will notify You via email on record with Us, and intimate the Board in the manner prescribed in the laws, when We are aware of such breach at the earliest as practicable.