PRIVACY POLICY

This Privacy Policy Statement (“Policy”) outlines Zyra Beauty (“We” or “Us” or “Our”) practices in relation to the storage, use, processing, and disclosure of personal data that you have chosen to share with Us when you access our website www.zyrabeauty.in and mobile application Zyra Beauty (collectively, the “Platform”).

This document is an electronic record in terms of Information Technology Act, 2000 and rules there under as applicable and the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000.

This electronic record is generated by a computer system and does not require any physical or digital signatures.

This Policy sets out the following:

(a) The type of information We collect;

(b) Purpose for collection of such information;

(c) Usage of the information;

(d) Intended recipients of the information;

(e) Third Parties which collect and retain the information;

(f) Security measures;

(g) Transfer of data;

(h) Authentication of information you choose to provide; and

(i) Disclosure of information to third parties.

Capitalised words in the Policy shall have the same meaning ascribed to them in the Terms and Conditions (“Terms”), available at www.zyrabeauty.in/terms. Please read this Policy in consonance with the Terms.

By using the Platform, you consent to the collection, use, and disclosure of in accordance with, and are agreeing to be bound by, this Policy.

1. COLLECTION OF PERSONAL AND OTHER INFORMATION

(a) By using the Platform, you allow Us to collect information about your activity and trends on the Platform. We will not collect any information from you, except where it is knowingly and explicitly provided by you.

(b) You expressly agree and acknowledge that We may collect and store your personal

information including, but not limited to, your user name, passwords, email address(es), name, address, age, date of birth, sex, map location information you choose to share with Us, nationality, usage history, etc., as well as any content or other information you upload, share, and/or update on the Platform. You acknowledge that this information may be used by Us to provide the Platform, pricing and its features to you.

(c) To use some features of the Platform, you may be requested to register your phone number, email address, and/or any other device to receive text messages, notifications, and other services. You authorise Us to send you electronic alerts for details pertaining to registration, other service requirements, and advertising.

(d) You are aware that by using and/or creating an account with the Platform, you authorise Us and Our associate partners to contact you via email, phone, or otherwise. This is to ensure that you are aware of all the features of the Platform. Further, you agree to receive promotional and other emails from Us. Through Our email services you will receive information about the latest developments on the Platform. You may unsubscribe from Our mailing list at any time, via the unsubscribe/opt out option We offer.

(e) You are aware that any and all information pertaining to you, whether or not you directly provide it to Us (via the Platform or otherwise), including, but not limited to, personal correspondence such as emails or letters, instructions from you etc., may be collected and compiled by Us and you expressly consent to the same.

(f) If any intended use of personal data goes beyond the purposes envisioned during collection, We will notify you of the new purpose(s) and seek consent to use your personal data for such additional purpose(s).

(g) You are aware that this Policy covers Our treatment of any personally identifiable information that you share with Us.

(h) You are aware that your personal data will continue to be stored and retained by Us for a reasonable period after termination of your account on the Platform, and that any and all content or information uploaded by you may be retained and/or displayed on the Platform indefinitely.

(i) You do not have to supply any personal data or information to Us but in doing so, you may not be able to take advantage of all the features of the Platform.

(j) We will comply with the requirements under the Information Technology Act, 2000 and the rules made thereunder in the event of a data or security risk.

2. DISCLOSURE OF PERSONAL INFORMATION

In general, We will not disclose personal data except in accordance with the following: (a) In order to carry out the purpose for which the personal data was collected; (b) Where you have consented to the disclosure;

(c) To enforce Our Terms;

(d) By law; or

(e) Where ordered to do so by a court of competent jurisdiction or by any governmental agency.

3. AUTHENTICITY OF INFORMATION

(a) We have taken all reasonable steps to ensure that the information on the Platform is authentic.

(b) You agree that the information and personal data you provide Us with are true, correct, and accurate. We shall not be liable for any incorrect or false information or personal data that you provide.

(c) You may review the information and personal data that you have provided during your use of the Platform and choose to correct or modify the same. You may do so by writing to Us or Our Grievance Officer at the address provided in Section 11 of this Policy.

4. THIRD PARTY USER EXPERIENCE IMPROVEMENT SERVICES

(a) We use third-party user experience improvement services (including, but not limited to, those provided by Razorpay, Google, Inc. and/or its affiliates) and other applications to better understand your behavior on the Platform.

(b) The information collected includes (but is not limited to):

(i) Age;

(ii) Gender;

(iii) Preferences; and

(iv) Interests.

(c) Your relationship with these third parties and their services and tools is independent of

your relationship with Us. These third parties may allow you to permit/restrict the information that is collected. It may be in your interest to individually restrict or enable such data collections.

(d) The place of processing information depends on each third-party service provider and you may wish to check the privacy policy of each of the service provider to identify the data shared and the purpose for sharing such data.

5. THIRD PARTY AUTHENTICATION SERVICES

(a) We use third party authentication services (including but not limited to those provided by Google Inc. and/or its affiliates and Facebook Inc. and/or its affiliates). In such cases, We may be privy to, granted access to, and/or store certain data available with these third parties for registration and identification purposes.

(b) The place of processing information depends on each third-party service provider and you may wish to check the privacy policy of each of the service providers to identify the data shared and its purpose. You will be subject to a third party’s privacy policy if you opt in to receive communications from third parties. We will not be responsible for the privacy standards and practices of third parties.

6. SECURITY MEASURES

We implement certain security measures including encryption, firewalls, and socket layer technology to protect your personal information from unauthorised access and such security measures are in compliance with the security practices and procedures as prescribed under the Information Technology Act, 2000 and the applicable rules (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information Rules, 2011). However, you agree and acknowledge that the above-mentioned measures do not guarantee absolute protection to the personal information and by accessing the Platform, you agree to assume all risks associated with disclosure of personal information arising due to breach of firewalls and secure server software.

7. BUSINESS TRANSITIONS

You are aware that in the event We go through a business transition, such as a merger, acquisition by another organisation, or sale of all or a portion of Our assets, your personal data might be among the assets transferred.

8. TRANSFER OF DATA

(a) As a part of your use of the Platform, the information and personal data you provide to

Us may be transferred to and stored in countries other than India. This may happen if any of Our servers are from time to time located in a country other than India, or one of Our service providers is located in a country other than India. We may also share information with entities of countries other than India. These countries shall be subject to data laws of their respective countries.

(b) If you use the Platform while you are outside India, your information may be transferred to a country other than India in order to provide you with the Platform.

(c) By submitting your information and personal data to Us, you agree to the transfer, storage, and/or processing of such information and personal data outside India in the manner described above.

9. COOKIES

(a) We collect data by way of ‘cookies’. Cookies are small data files which are sent to your browser from the Platform and are stored on your computer or device (hard drive). The cookies shall not provide access to data in your computer or device such as email addresses or any other data that can be traced to you personally. The data collected by way of cookies will allow Us to administer the Platform and provide you with a tailored and user-friendly service. The cookies shall enable you to access certain features or services of the Platform. Most web browsers and devices can be set to notify when you receive a cookie or prevent cookies from being sent. If you do prevent cookies from being sent, it may limit the functionality that We can provide when you visit the Platform.

(b) Additionally, you may encounter cookies or other similar devices on certain pages of the Platform that are placed by third parties. We do not control the use of cookies by third parties. If you send Us personal correspondence, such as emails or letters, or if other users or third parties send Us correspondence about your activities or postings on the Platform, We may collect such information into a file specific to you.

10. CHANGE IN PRIVACY POLICY

We may amend this policy from time to time, at Our sole discretion. If there are substantial changes in the way your personal information is being used, We will notify you by posting the changes on the Policy page.

11. GRIEVANCE OFFICER

You may contact Us at www.zyrabeauty.in/contact-us with any enquiry relating to this Policy or an enquiry relating to your personal information (review, update, deletion).