This “Privacy Policy” describes how ViralCurry Private Limited (“We” or “Us”) the proprietary owner of tradename Praush and any and all digital platforms including applications, website or other digital platforms (“Site”) through which data subject/principal (“User”, “Your” or “You”) will disclose Your Personal Data for accessing Our services

Definition

• “Act” means the Digital Personal Data Protection Act, 2023
• “Board” means the Data Protection Board of India established by the Central Government under section 18 of the Act.
• “Data Fiduciary” means any person who alone or in conjunction with other persons determines the purpose and means of the processing of personal data; For the purpose of this Policy, unless required under applicable laws, We will only be considered Data Fiduciary if You have directly disclose Your information to us through Our Site.
• “Data Processor” means any person who processes personal data on behalf of a Data Fiduciary;
• “Data Protection Officer” means an individual appointed by us in our capacity as the Data Fiduciary in compliance with the applicable laws.
• “Personal Data” means any data about an individual who is identifiable by or in relation to such data;

Collecting Personal Data

When You visit the Site, We collect certain information about Your device, Your interaction with the Site, and information necessary to process Your purchases or any other information required to fulfill any Specified Purpose. We may also collect additional information if You contact us for customer support. See the “Schedule- A” below for more information about what Personal Data We collect and why.

Consent

• You hereby understand that by accessing, registering, using, downloading or making purchase through the Site, You consent to collection, storage, processing, disclosure and usage of Your Personal Data as outlined in this Policy and You confirm that such usage of Your Personal Data in accordance with the provisions of this Policy shall not cause any wrongful loss to You.
• You acknowledge that You are providing Your Personal Data out of Your free will. You hereby acknowledge and agree that the collection and receipt of Your Personal Data by Us is necessary to provide the services to You.
• You hereby agree that the Personal Data provided by You is accurate and is true to Your knowledge. We shall not be liable for any dispute or claim arising out of the accuracy of the Personal Data provided by You.
• In the event You do not Consent to provide Your Personal Data as may be required for registration or thereafter, or You fail to provide permissions or withdraw Your consent for processing the Personal Data, We shall not have any obligations to provide the services agreed to be provided under the terms and conditions and We may restrict or prohibit Your usage of the Site.
• In the event, You grant access to any third party to Our services under Your account, then the terms “user”, “you”, “your” shall by inference include such third party, and this Privacy Policy, to the extent permitted under law, shall mutatis-mutandis apply to such third party. Notwithstanding anything to the contrary, it shall be Your sole responsibility to make such third-party user(s) being granted access under Your authorization aware of the terms of this Privacy Policy and adhere to its obligation. You and such user shall be jointly and severally liable to indemnify Us against any claims or breach of this Policy by such third party user(s).

Withdrawal

• You have the right to withdraw, manage, modify or review Your Consent at any time by going to the settings page [insert link of the settings page] on our Site, or email, call, or write to Us using the contact details under ‘Contact Us’ section below
• In case of such withdrawal:

i) The consequences of such withdrawal shall be borne by You, and such withdrawal shall not affect the legality of processing the Personal Data based on consent given before its withdrawal.

ii) We shall cease, delete and cause our Data Processor to cease and delete the processing of such Personal Data.

Sharing and processing of Personal Data

• We share Your Personal Data with third party service providers, affiliates or Processors (“Data Processors”) to help Us provide our services and fulfill our contracts with You. Details of third party service providers or Data Processors is more fully described under “Schedule - B”
• Personal Data that You provide  directly through websites or emails

i) We may collect Your Personal Data, when You register, make purchase, fill forms on or raise a query through our Sites, or send emails, call Us or write to Us.

ii) Disclaimer: Our Site may contain links to other websites that may collect Personal Data about You. If You submit Your Personal Data or any other information to any of those sites, Your Personal Data is governed by their privacy policies. We encourage You to carefully read the terms and conditions and the privacy policy of any website You visit. We shall not be responsible for the privacy practices or the content of those linked websites.

• Personal Data that is collected from other controllers

i) You can engage with Us through other service providers including but not limited to Google, Microsoft or social media websites or through websites that integrate Us with social media sites (“Other Controllers”). If You access Our Site through any such Other Controller, the data We collect may including Your user name associated with that social media service, any information or content the social media service has the right to share with Us, or any information You have made public in connection with that Other Controller. When You access our Site or otherwise deal with Us through Other Controllers, You are authorizing Us to collect, store, process, use and retain such information and content in accordance with this Policy.

ii) Other Controllers hereby acknowledge that by consenting to this Privacy Policy they are consenting Us for collecting, using, retaining or processing the Personal Data provided to Us by such Other Controller. It shall be the sole responsibility of the Other Controllers to take consent of the Users to provide Us with their Personal Data. It is hereby clarified that We shall not be liable for accuracy or authenticity of Personal Data received from Other Controllers. In case Other Controllers receive requests from the users to withdraw their consent, erase or make correction to their Personal Data, the Other Controllers shall promptly notify such request to Us.

• We may share Your Personal Data to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information We receive, or to otherwise protect our rights.

Data Transfer

• Transfer to other Data Processors: Your Personal Information is forwarded to other Data Processors only if required for the fulfillment of a contractual obligation, or if we ourselves, or a third party, have a legitimate interest in the data transfer, or if you have given your consent to such transfer.
• Transfer to third party service providers: We may disclose your information to third party service providers who work on behalf of or with us to provide you with our Services, to help us communicate with you, or to maintain Services. Additionally, we may disclose your information to such other third parties on need to know basis for rendering any external service through our Website. Such third party service providers shall include but not be limited to hosting services, marketing agencies, etc.
• Transfer due to statutory obligations or administrative or judicial order: We may transfer your Personal Information if we are obliged to transfer your Personal Information to any authority or government body due to any statutory regulations or any enforceable administrative or judicial orders.

Non Personal Data

• In addition to the Personal Data, We may collect and track data, not specifically identifiable or in relation to You (“Non Personal Data”) which may include data about Your visit to the Site, domain name and the name of the webpage from which You were directed to our Site or the browser through which You use Our services, how much time You spend on each of our webpage, Internet Protocol (IP) address associated with Your computer, operating system and platform, transaction history, pages viewed, information searched, access time and other relevant information and statistics.
• You hereby consent that We may use, process, store, analyze and disclose such Non Personal Data. We may use Non Personal data to diagnose problems, improve our products or user experience, provide services and conduct marketing, research and development activities.
• You further understand and agree that such Non Personal Data or any derivativearising out of such data shall be owned by Us and We shall not be restricted to share, disclose or use such data in any way.
• Any rights and provision under the Act which apply to Personal data, does not apply to Non personal Data.

Children/Disabled Person

• The Site is not intended for individuals under the age of 18 years (“Children”) or Disabled Person who has a lawful guardian (“Disabled Person”). We do not intentionally collect Personal Data from Children or Disabled Person.
• Personal Data of the Children or Disabled Person is collected by Us, only after the due Consent of the parents or guardians, as the case may be. The parents or guardian may register their Child or Disable Person account as a sub account to their own registered account, which implies the free consent of parents or guardian to allow Us to collect and process the Personal Data of such Children or disabled person. On providing such consent, the parent or guardian shall assume full responsibility of their Child or Disabled Person’s conduct including the accessing and purchases made on the Site.
• If You are the parent or guardian and believe Your child has provided us with Personal Data without Your consent, please contact the Data Protection Officer at the address mentioned below to request deletion.

Notice

• We will provide You with the Notice through a pop up, before Collecting and processing Your Personal Data to the following effect:

i) the personal data and the purpose for which the same is proposed to be processed;

ii) the manner in which You may exercise the rights related to withdrawal of Your Consent at any time; and

iii) the manner in which You may make a complaint to the Board.

• If You reject such Notice, We will restrict Your access to the Site and will not be able to provide service to You or fulfill the obligation under the contract.

GDPR

• Pursuant to the General Data Protection Regulation (“GDPR”), if You are a resident of the European Economic Area (“EEA”), We process Your Personal Data under the following lawful bases:

i) Your consent;

ii) The performance of the contract between You and the Site;

iii) Compliance with our legal obligations;

iv) To protect Your vital interests;

v) To perform a task carried out in the public interest;

vi) For our legitimate interests, which do not override your fundamental rights and freedom.

• Our Representative in European Union As We do not have an establishment in the European Union (“EU”), we have appointed a representative based in the [insert representative’s country], who You may address if You are located in the EU to raise any issues or queries You may have relating to our processing of Your Personal data and/or this Policy. Our EU representative is [insert name of the representative] located at [insert representative’s registered address]. Our EU representative can be contacted directly by emailing them at the following address [insert representative’s email id].

Retention

• When You place an order through the Site or access the Site, We will retain your Personal Data unless You withdraw your Consent or request for deletion or for as long as We have a legitimate interest in storing the data.
• We will retain the data for a longer period as required under the applicable laws or as required to do so for the performance of a legal or contractual obligation or upon order of any authority.

Cookies

A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the Site, for instance whether it’s their first time visiting or if they are a frequent visitor.

We use the following cookies to optimize your experience on our Site and to provide our services.

Cookies Necessary for the Functioning of the Store

Name	Function
_ab	Used in connection with access to admin.
_secure_session_id	Used in connection with navigation through a storefront.
Cart	Used in connection with shopping cart
cart_sig	Used in connection with checkout
cart_ts	Used in connection with checkout
checkout_token	Used in connection with checkout
Secret	Used in connection with checkout
secure_customer_sig	Used in connection with customer login.
storefront_digest	Used in connection with customer login.
_shopify_u	Used to facilitate updating customer account information.

 

Reporting and Analytics

Name	Function
_tracking_consent	Tracking preferences.
_landing_page	Track landing pages
_orig_referrer	Track landing pages
_s	Shopify analytics.
_shopify_fs	Shopify analytics.
_shopify_s	Shopify analytics.
_shopify_sa_p	Shopify analytics relating to marketing & referrals.
_shopify_sa_t	Shopify analytics relating to marketing & referrals.
_shopify_y	Shopify analytics.
y	Shopify analytics.

 

The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies We use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.

You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact Your user experience and parts of our website may no longer be fully accessible.

Most browsers/Consent Managers automatically accept cookies, but You can choose whether or not to accept cookies through Your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in Your browser’s help file or through such sites as www.allaboutcookies.org.

Additionally, please note that blocking cookies may not completely prevent how We share information with third parties such as our advertising partners. To exercise Your rights or opt-out of certain uses of Your information by these parties, please follow the instructions in the “Behavioural Advertising” section above.

Security Measure

• We protect the Personal Data in our possession or under our control, including in respect of any processing undertaken by Us or by a Data Processor, for which reasonable security safeguards are in place to prevent personal data breach.
• You hereby accept the inherent security implications of providing privacy to Your Personal Data shared with Us and You will not hold us responsible for any breach of security or the disclosure of Personal Data unless We have been grossly and willfully negligent.
• We may enter into agreement with third parties other Controllers or data processors (in or outside of India) to store or process Your Personal Data. These third parties may have their own security standards to safeguard Your information or data and We will on a commercial reasonable basis require such third parties to adopt reasonable security standards to safeguard Your information / data.

User Rights

• The User’s shall have the right to obtain from Us:

i) a summary of Personal Data which is being processed by Us and the processing activities undertaken by Us with respect to such Personal Data;

ii) the identities of all other Data Fiduciaries and Data Processors with whom the Personal Data has been shared, along with a description of the Personal Data so shared; and

iii) any other information related to the Personal Data and its processing, as may be prescribed.

If You wish to obtain such information then, You can request a copy of such information by going to the settings page on our Site or by writing on email-id using the details provided in the “Contact Us” section.

• You shall have the right to correction, completion, updating of Personal Data for the processing.
• You have the right to erase or delete Your Personal Data, under certain conditions. You may go to the settings page [insert link of the settings page] on our Site to erase Your Personal Data in the following circumstances:

i) the Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;

ii) You withdraw consent on which the processing is based and there is no other legal ground for the processing of the data;

iii) there is no overriding legitimate interest for us to continue the processing of the data;

iv) Your Personal Data was unlawfully processed; or

v) Your Personal Data must be erased in order to comply with a legal obligation.

• You shall have the right to nominate any other individual, who shall, in the event of Your death or incapacity, exercise the rights of User in accordance with the provisions of this Policy.

• Additional Rights to Users residing in European Union

a) Right to Data Portability: In case You wish to transmit the data concerning Your Personal Data that You have received from Us in a structured, commonly used, and machine-readable format to another controller, then you can freely transmit such data to another controller without hindrance from Us.

b) Right to restrict processing of Your Personal Data: You have the right to restrict the processing of Your Personal Data in the following circumstances:

i) You contest the accuracy of the Personal data;

ii) You have objected to our processing of Your Personal Data;

iii) the processing is unlawful and You do not wish for the data to be erased but require restricted processing of the data instead; or

iv) We no longer require Your personal data but You require the data to establish, exercise or defend a legal claim.

When processing of Your Personal Data has been restricted, We will be permitted to store Your data but will not perform any other processing of it, unless You consent to further processing or processing is necessary for the establishment of a legal claim; for the protection of rights of another person; or for reasons of important public interest.

c) Right to object to processing Your Personal Data: You have the right to object to us processing Your Personal Data where our legal basis for processing the data is:

i) In case You object to our processing of Your Personal Data for direct marketing purposes (including profiling), We will stop processing Your personal data for this purpose; and

ii) for scientific or historical research purposes or statistical purposes, unless the processing is necessary for the performance of a task carried out for reasons of public interest. Should You object to our processing of Your Personal Data on this legal basis, Your objection must be based on grounds relating to Your particular situation.

d) Right to oppose Automated Decision-Making and Profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning You, or similarly significantly affects You, if such a process is:

i) not necessary for entering into, or the performance of, a contract between for providing Services

ii) is not authorized by laws to which We are a subject

iii) is not based on Your explicit consent.

Grievance Redressal Mechanism

• You have the right to access and contact our Data Protection Officer with respect to following:

i) Any act or omission in relation to the Personal Data or to exercise the rights under the provisions of the Act and this Policy.

ii) If You have any complaint related to processing Your Personal Data or any other queries or complaints

• You may make such request or submit such grievances on the coordinates provided below:

Name: (insert name)

Email: (insert mail id)

Phone No: (insert number)

Address: (insert address)

• The Data Protection Officer shall respond to any grievances referred to him within (insert number of days) from the date of its receipt.
• If You are not satisfied with the outcome of our grievance redressal mechanism, or if You consider that Your complaint has not been handled correctly, You may lodge a complaint with the Data Protection Board of India or Information Commissioner's Office, as the case may be.
• Your opportunity of redressing Your grievance under this section will be exhausted before approaching the Board.

Important Disclaimer

Although We provide full security and secrecy to Your Personal Data, We urge You to be careful with sharing of Your Personal Data with any third party claiming to be related to Us on separate emails/phone calls etc. We disclaim any and all liabilities towards any such claims that have arisen due to Your own negligence or willful misconduct and We take no responsibility for the same. Further, We are not responsible for the authenticity of the Personal Data provided by You.

Changes

• We reserve the right to update, change or remove this Privacy Policy from time to time at our sole discretion in order to reflect changes to our practices or for other operational, legal, or regulatory reasons
• You can access the latest version of this Policy at any given time on our website and it shall be Your responsibility to stay updated on any changes to this Privacy Policy. Once posted, those changes are effective immediately, unless stated otherwise.
• Your visit on the website is deemed to be your acceptance for the terms and conditions and practices described in Policy and in case you disapprove the terms and conditions then You should immediately cease to use the website. The terms of this Policy shall be read with and as an integral part of the terms and conditions.

Contact Us

For more information about our privacy practices, if You have questions, or if You would like to make a complaint, please contact us by e-mail at [email address] or by mail using the details provided below:Viralcurry Digital Media & Marketing services pvt ltd, B-1/638A, Janakpuri East, Delhi, 110058 New Delhi DL, India.