This privacy policy (“Privacy Policy”) describes how Gupta HC Overseas Private Limited and/or its group/ affiliate company, Oroh (referred to as “OROH”, “Our”, “We” or “Us” in this Policy) collects, uses, shares, and protects the user’s (“You”, “Your” or “User(s)”) Personal Information, what choices the User(s) have relating to their Personal Information (as defined herein), and how such User can contact Us.
We are committed to respecting the privacy rights of Our customers and all visitors to Our website, web pages, interactive features, blogs, social networks, and other online or wireless offerings, that post a link to this Privacy Policy. This Policy Privacy applies to the information gathered through the use of [insert website link], and any other website that We own and control and that link to this policy.
WHAT YOU WILL FIND IN THIS PRIVACY POLICY
- What information and Personal Information We might collect about You
- How We may use Your Personal Information
- How is Your information shared
- What choices can You make about Your data
- How do We protect Your data
- US State Privacy Rights
- Contact Information
1. What information and Personal Information We might collect about You
Information that you provide (“Personal Information”):
In order to handle Your purchases, provide customer service, improve Our products and services, engage with You on social media and online, and send You information about Our products, trends and promotions, We may ask You to provide Your:
- Identifiers: such as Your name, postal address, email address, social media handle, telephone number, or identification materials used to verify eligibility for discounts and other offers;
- Demographic information: such as Your age, date of birth, or gender;
- Transaction information: such as information regarding purchases, returns or exchanges; product reviews You provide; clothing size/fit information; and communications between Us;
- Payment information, including gift card information; and
- User generated content (“UGC”): such as photos, videos, blog posts, social media posts, or direct or personal messages sent to Us on social media platforms.
If You choose not to provide certain information to Us, You may not be able to complete a purchase, participate in an experience, or receive other services or information.
Information that we automatically collect from You:
When You visit Our website, We may automatically collect:
- Identifiers: such as device ID, IP address, and online identifiers, such as cookie data;
- Internet activity information: such as device type; browser types and version; browsing history; search history; interactions with Our website, communications, and advertisements; referring sites; and content and pages viewed;
- Location information: such as geo-location of Your devices;
- Audiovisual information: such as call recordings;
- Inferences: such as Your preferences and interests based on Your online activities;
- Browsing behavior on Our website: such as when and how You visit Our website, the amount of time spent viewing Our website, the buttons and links You click, the search terms that You enter on Our website, and the form submissions, purchases, and transactions you make through the website; and
- Text or other messages sent or shared through chat or chatbot services.
Other information We collect:
We may collect information about You for activities related to other businesses or third parties like web hosting providers, shipping providers, retail partners, analytics companies, social media platforms, data companies, and marketing and advertising services such as:
- Identifiers: such as updated contact information, social media handles, device identifiers, cookie data or similar online identifiers;
- Demographic information: such as Your age, date of birth, or gender;
- Internet activity information: such as content or reviews You post on social media or other third-party platforms; and
- Inferences: such as information about Your shopping preferences and interests.
The information that we obtain from social media platforms depends on Your account and privacy settings within the platforms and the platforms privacy policies.
Some of the information above is collected on Our website through web browser cookies and other technologies (web beacons/gifs, pixels, page tags, script) that receive and store certain types of information whenever You interact with Us or third parties that may direct You to Our website. We use these tools for a variety of reasons, including to analyse and improve Our website, or to remember Your preferences and provide more personalized advertising.
Third party automated information collection and Interest-Based Advertising
We use third party advertising companies to display ads tailored to You based on how You browse and shop online, a practice commonly referred to as “interest-based” or “behavioural” advertising. We allow these third parties to collect certain information when You visit Our website, including non-personally identifiable information (browser type, subject of advertisements clicked on, session IDs) and Personal Information (such as IP address).These third parties typically use cookies or tracking technologies to collect this information on website owned by Us or third parties.
2. How We may use Your Personal Information
We use the information We collect for a variety of purposes, including:
- To process Your transactions and provide You with the products and services You request;
- To provide, maintain, protect, develop, and improve Our website and services;
- To improve Your experience on Our website;
- For customer service, including to respond to Your inquiries and requests;
- To communicate with You about Our products and services, in accordance with applicable laws and with Your consent where required;
- To analyse and learn about consumer trends and interests;
- To learn about the devices You use to access Our website;
- To personalize the content You see on Our website;
- To administer contests, sweepstakes, surveys and other promotions;
- To maintain Your reward or loyalty program memberships;
- To provide You with communications, recommendations, ads, and other information of interest to You, including via text message and email and interest-based advertising based on Your online activities on Our website;
- To use Your UGC on Our website, social media account, and other marketing platforms (with Your Consent);
- To verify eligibility for discounts and other offers;
- To prevent and detect fraud, criminal activity and violations of Our terms and conditions;
- To protect Our rights, as well as Yours and others; and
- To comply with Our legal obligations.
We may also use information for purposes disclosed to You at the point of collection, as authorized by You, or as otherwise permitted or required by law.
3. How is Your information shared
We may share or transfer infomation about You:
- As and when required by law or a legal process, including investigating a potential crime;
- When We believe it is necessary to protect the rights, property, or safety of OROH or other persons.
We disclose the following categories of information (as elaborated above) to service providers and contractors, payment processors, advertising and marketing partners, affiliates and subsidiaries, law enforcement, public and government authorities, and others, advisors and consultants, retail partners and joint marketing partners, for Our business purposes:
- Identifiers
- Demographic information
- Transaction information
- Payment information
- Internet activity information
- User generated content (UGC)
- Location information
- Audiovisual information
- Inferences
At OROH, We do not share Your Personal Information with third parties in exchange for money. We do share certain information with advertising and marketing partners in exchange for insights, digital advertising, and other valuable services. Such sharing may be considered a “Sale,” “Sharing,” or “Targeted Advertising” under certain laws. We disclose the following information in such circumstances:
- Identifiers;
- Demographic information;
- Internet activity information;
- Location information;
- Inferences; and
- Transaction information.
We may also share Your information in the event of an actual or potential sale, merger, acquisition or transfer of Our business or assets.
We retain the information We collect for as long as We have a legitimate business purpose to retain the information, as long as permitted by law, or until You request We delete the information if such a right exists in Your jurisdiction.
4. What choices can You make about Your data
Accessing, Correcting or Deleting Your Data
If You would like for OROH to correct or delete Your data, you may do so by contacting Us via the contact information provided below. However, please note that We can only delete the Personal Information shared with Us by You, We may not be able to delete the existing order information. Such order information is retained for as long as necessary. Regardless, You have the option to alter Your Personal Information via Your profile section, whenever You please.
Unsubscribe/Opt-Out
If You no longer wish to receive promotional emails or direct mail from OROH, You can request to opt-out by contacting Us via the contact information provided below.
5. How do We protect Your data
We use a variety of technical, administrative, and organizational security measures, including encryption and authentication tools in certain circumstances, that are intended to protect Your Personal Information. Please be aware that despite Our efforts, no data security measures can guarantee security. You can help keep Your data safe by taking reasonable steps to protect Your Personal Information against unauthorized disclosure or misuse.
6. US State Privacy Rights
Depending on the state in which You reside, You may have the following privacy rights, subject to statutory limitations:
Right to Opt Out of Sales and Sharing or Using Personal Information for Targeted Advertising: You have the right to opt-out of Our “sales” or “sharing” or use for targeted advertising of Your Personal Information.
Right to Limit the Use of Sensitive Personal Information: You have a right to request that We use and disclose certain sensitive information only for certain purposes permitted under law.
In order to exercise such rights, You need to submit a request. If You submit a request to exercise Your rights, We may ask that You provide certain information to verify Your identity. The information that We ask You to provide to verify Your identity will depend on Your prior interactions with Us and the sensitivity of the Personal Information at issue. We will respond to Your request in accordance with Your respective state law.
7. Contact Information
If You have any questions about this Privacy Policy or OROH’s data practices, please contact info@theorohlife.com.
8. Supplemental California Privacy Policy
In this Supplemental California Privacy Policy, we, OROH, disclose information about Our data processing practices as required by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (the “CCPA”) and California law.
A. Who and what information is subject to the CCPA?
The CCPA protects Californians with respect to their personal information. As a result, the Supplemental CCPA Disclosures and relevant CCPA Rights subsections below may not apply when they restrict Our ability to comply with a court order or regulator with competent authority, federal, state or local laws, cooperation with law enforcement, exercise of Our legal claims, or collection or use of de-identified information.
B. Supplemental CCPA Disclosures
We have set out below the categories of personal information we have collected about California residents in the preceding 12 months and describe, for each category of personal information collected, the business or commercial purposes for which the information was collected. Each of the categories of personal information listed in the table are collected directly from consumers. Each of the categories of personal information in the table may also be shared with the following categories of third parties: (i) our Service providers, contractors, and business partners (ii) Government entities as required by applicable law (iii) other recipients at your discretion or with your consent (iv) Third parties in the event of a proposed or actual business transaction involving all or any portion of our business. We disclose that information for the purposes described in Section 3 of the Privacy Policy. Additional information about sales of information can be found below the table.
| Category of personal information: | We collected such personal information for the following purposes: |
| Identifiers: such as Your name, postal address, email address, social media handle, telephone number, or Identification materials. |
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| Categories of personal information described in subdivision (v) of Section 1798.140 of the California Civil Code, including name, signature, address, telephone number, passport number, and credit card number, debit card number, or any other financial information. | We use this information to process payment, fulfil Your order, or process a return. |
| Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | We use this information to fulfil your order, manage consumers’ online account with us, personalize and optimize consumers’ shopping experience with us (for example, letting you know when a favourite product is back in stock, recording certain information from past purchases which can be used in future purchases such as preferred address), provide consumers with customer care, and customize a product per a consumer’s specific request. |
| Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site or advertisement. |
We may use this information for any of the purposes described in section 2. |
| User Generated Content (UGC). |
We may use this information for any of the purposes described in section 2. |
| Audio, electronic, visual, or similar information. | We use audio, visual or similar information that You may voluntarily provide in connection with customer care inquiries or when You engage with Our social media initiatives for purposes of providing and improving customer service, training, resolving complaints or inquiries, legal compliance, and exercising or defending legal claims. |
| Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics and attitudes. | We use such information to personalize and optimize consumers’ shopping experience with Us, enable consumers to use Our “wish list” or “add to closet” features online, tailor Our marketing efforts, and develop and improve Our products and services. |
| Sensitive personal information, including account credentials and precise geolocation. | We use account credentials for the security purposes and to process your transactions and provide You with the products and services You request. |
We retain personal information for as long as We have a relationship with You. Once Our relationship with You has come to an end, We retain Your personal information for a period of time that enables Us to:
- Maintain business records for analysis and/or audit purposes.
- Comply with record retention requirements under the law or other relevant legal or regulatory requirements.
- Defend or bring any existing or potential legal claims.
- Deal with any complaints regarding the services.
- Preserve historical records of transactions.
Company to confirm if there will be any loyalty program memberships.