PRIVACY POLICY

INTRODUCTION

11 BAZAARGATE LLP is a Limited Liability Partnership (referred to herein as Bazaargate, “We”, “Our” or “Us”) and is engaged in the business of [retailing] various categories of goods across India through various modes of distribution channel (“Products”) through of www.11bazaargate.com   (“Website”) which is maintained and operated by Bazaargate.

This privacy policy (“Privacy Policy”) is applicable to the Website and outlines the principles adopted by Bazaargate to protect the Personal Information (defined below) and/or Sensitive Personal Data (defined below) or Information of individuals and employees that we collect, use or disclose in the conduct of our activities, governance, internal administration and interaction with the public.

This Privacy Policy incorporates the requirements under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

This Privacy Policy covers the information Bazaargate collects from the user(s) and/or participants in our program (“User(s)” and/or “You”) accessing the Website and/or the services on the Website.

 

Information Collection and Use
  • The Personal Information and Sensitive Personal Data or Information which You may provide to us and/or which Bazaargate may collect, includes the following:
  • Your contact information and Personal Information including name, age, gender, address and telephone number, login credentials such as password and/or email address.
  • Your contact details, billing, and other information pertaining to Your transactions on the Website or related to the Services.
  • IP address, operating system, browser type, browser version, browser configuration, name of internet service provider, and other types of computer and connection related information relevant to identifying your type of device, connecting to the Website, enabling data exchange with You and your device, and ensuring a convenient use of the Website.
  • The full uniform resource locator (URL) click stream to, through and from the Website, including date and time, details of the computer system or computer network which You use to visit the Website and undertake any activity on the Website and similar details which you agree to disclose by accepting cookies from our Website.
  • User preferences (e.g., preferred language settings) and customer feedback or service requests
  • Transaction history, including open and completed transactions on the Webiste;
  • Search terms entered and services viewed or searched for on the Website;
  • Information collected by cookies or similar technologies;
  • Enrolment for promotions, use of discount codes or special offers, etc.
  • Consents, authorizations, etc. granted;
  • Survey answers, reviews, ratings and other types of feedback provided; and
  • Any other information that you enter on, or upload to, the Website (e.g., content that you fill into an online form, a photo that you upload).
  • By using our Website, You hereby expressly agree and grant consent to the collection, use, processing and storage of this Personal Information and/or Sensitive Personal Data or Information by Bazaargate. Bazaargate reserves the right to share, disclose and transfer the aforesaid information collected hereunder with its affiliates or any other third parties. Where the Personal Information and/or Sensitive Personal Data or Information, pertains to participants who are minors, You, the guardians and/or parent of the concerned minor expressly agree and grant consent to the collection, use, processing and storage of this Personal Information and/or Sensitive Personal Data or Information relating to the minor by Bazaargate.  You (including guardians / parents in case of a minor) hereby expressly grant consent and permission to Bazaargate for disclosure and transfer of such information to such third parties. Further, Bazaargate reserves the right to disclose Personal Information and/or Sensitive Personal Data or Information as obligated by law, in response to duly authorized legal process, governmental requests and as necessary to protect the rights and interests of Bazaargate.
  • While You have the option not to provide us with certain information or withdraw consent to collect, retain, store and/or handle certain Personal Information and/or Sensitive Personal Data or Information, kindly note that in such an event You may not be able to take full advantage of the entire scope of features and services offered to You and we reserve the right not to provide You with our services.
  • In addition, Bazaargate participates in cooperative database services. These services help us to direct catalogues, mailings and other marketing initiatives to appropriate Website visitors. Names and mailing addresses may be shared between participating parties in the cooperative database services.
  • Our primary purpose in collecting information from You is to allow You to use the Website and various features and Services on or in relation to the Website; contact You for any services provided by Bazaargate or its affiliates or its various service providers or business partners and advertisers; to record your information for registration details as permitted and required under applicable laws, statutory direction or judicial orders; to serve various promotion materials and advertising materials to You; and such other uses as provided in this Privacy Policy.
  • Bazaargate may also use the information for transactional emails or to provide You with information, direct marketing, online and offline advertising and other materials regarding products, services and other offers from time to time in connection with the Website or Bazaargate.
  • We also use the information we collect about You to improve the content of our Website, to respond to Your inquiries and feedback, and to provide You with a personalized experience. We may also use the information to notify You about important functionality changes to the Website, new Bazaargate programmes and updates which You may find relevant.
  • Bazaargate may also collect information to track User behaviour and preferences for internal analytics from all Users of the Website. This information is collected through the use of server log files and tracking technologies to collect and analyse certain types of technical information and may include cookies and web beacons.
  • Bazaargate may combine your Personal Information and/or Sensitive Personal Data or Information, other information and information collected from tracking technologies and aggregate it with information collected from other Users using our Website to attempt to provide You with better services on our Website.
  • The Users hereby agree to handling the Personal Information and/or Sensitive Personal Data or Information. Where the Users or the participants in the Bazaargate program are minors, You (the parents and/or guardians) will have provided their acceptance of this Privacy Policy in writing. The Users (or their guardian/ parents in case of minor participants) understand and acknowledge that our collection, storage and processing of Personal Information and/or Sensitive Personal Data or Information is for a lawful purpose and is considered necessary for Bazaargate to provide various services provided by Bazaargate in relation to the Website.
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    Limiting use, disclosure and retention of Personal Information:
  • Bazaargate is the recipient of all the Personal Information and/or Sensitive Personal Data or Information and shall exercise reasonable commercial endeavors for ensure that the Personal Information and/or Sensitive Personal Data or Information provided by the Users is only used for the purposes for which it is collected. Bazaargate may enable access of the Users’ information to affiliates or third parties for the purposes of the services provided by them.
  • Bazaargate will ensure that it will not retain Personal Information and/or Sensitive Personal Data or Information for longer than is reasonably required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force. On a good faith basis, Bazaargate shall ensure that the third parties and agents employed by us for the purposes of the Website are under an obligation to maintain confidentiality with respect to the Personal Information and/or Sensitive Information Data or Information provided by the Users and to use it strictly for the purposes of the Website only.
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      Compliance with Laws and Law Enforcement

    Bazaargate cooperates with mandated government and law enforcement agencies or to any third parties by an order under law for the time being in force to enforce and comply with the law. Bazaargate will disclose any information about You to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process, to protect the property and rights of Bazaargate or a third party, to protect the safety of the public or any person, or to prevent or stop any illegal, unethical or legally actionable activity. Bazaargate may also provide your Personal Information to various tax authorities upon any demand or request from them.

     

    Email Policies

    You have full control regarding which emails You want to receive from us. If You decide at any time that You no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications. Please note that once Bazaargate receives your request, it may take an additional period of time for your opt-out to become effective.

  • Deleting Your Information
  • If You wish to have the Personal Information and/or Sensitive Personal Data or Information that You have provided to us deleted, You can always do so by sending a request to us on the e-mail address of our [grievance officer] provided at the bottom of this page. You may note that deletion of certain Personal Information may lead to cancellation of your registration with the Website and your access to certain features of the Website.

     

    Security
  • Bazaargate will protect Sensitive Personal Data or Information with security safeguards commensurate to the sensitivity of the Sensitive Personal Data or Information. Furthermore, all of the customer data Bazaargate collects is protected against unauthorized access implement security practices and implement an information security policy containing managerial, technical, operational and physical security control measures that are commensurate with the information assets being protected with the nature of business.
  • You will not be able to inadvertently place an order through an unsecured connection. It is important for You to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a shared computer. While we implement the above security measures on this site, You should be aware that 100 % security is not always possible.
  • All information provided by You is stored and retained on the secure servers and systems of Bazaargate. Bazaargate maintains secure and reasonable security practices and procedures such as encryption and firewalls to protect data from misuse and unauthorized access. (“Security Practice”). Such Security Practice involves measures including, but not limited to password protection, limitation of access to specified personnel on a need to know basis, security measures including encryption if required and other physical security measures to guard against unauthorized access to the server and systems and information residing on such server and systems. Bazaargate’s Security Practice protects against unauthorized access to, or unauthorized alteration, disclosure or destruction of the information. Bazaargate’s Security Practice contains managerial, technical, operational and physical security control measures which are commensurate with the information assets being protected and with the nature of business. You acknowledge and agree that the Security Practice and procedures as mentioned above are reasonable and are designed to protect the information provided by You.
  • In respect of Sensitive Personal Data or Information collected in or transferred to India, Bazaargate, its agent and affiliates will not transfer or disclose any information to any other organisation or to a person that does not maintain the same level of data protection that is adhered to by Bazaargate as provided for under this Policy.
  • To prevent unauthorized access, maintain data accuracy, and ensure correct use of information, Bazaargate will employ commercially reasonable and practicable security practices and procedures and security methods and technologies. Bazaargate will also ensure on reasonable commercial efforts basis that any agent or third party that Bazaargate employ comply with the same security standards as us for the protection of your Personal Information.
  • Your information may be transferred to or be maintained on computers, computer systems and computer resources located outside of your state or country where the privacy laws may not be as protective as those where You live. If You are located outside India and choose to provide information to us, please be aware that Bazaargate keeps or transfers information to India and processes it there. Your submission of such information represents your agreement to that transfer.
  • Unfortunately, the transmission of information over the internet is not completely secure. Although Bazaargate shall strive to protect your personal data, however Bazaargate cannot guarantee the security of your data while it is being transmitted to our site; any transmission is at your own risk. Once Bazaargate have received your information, Bazaargate have commercially reasonable procedures and security features in place to reasonably endeavour to prevent unauthorized access.
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      Links to Other Sites

    Bazaargate may provide links to other websites for your convenience and information. These sites may have their own privacy policies in place, which Bazaargate recommends You review if You visit any linked websites. Bazaargate is not responsible for the content of linked sites or any use of the sites.

       

      Changes in Privacy Policy

    This privacy statement is effective as of [•], 2020. From time to time Bazaargate may update this Privacy Policy. Your continued subscription to our Services constitutes an acceptance of the then-current Privacy Policy so We encourage You to visit this page periodically to review any changes.

     

    Phishing

    Identity theft and the practice currently known as "phishing" are of great concern to Bazaargate. Safeguarding information to help protect You from identity theft is a top priority. Bazaargate does not and will not, at any time, request your credit card information or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.

     

    Cookies

    We use cookies placed on your computer's hard drive through your web browser to enable our systems to recognize your browser during your visit to our website and when You return to our Website.

     

    Contact Us

    If You have any questions about this Privacy Policy, the practices of Bazaargate or your dealings with the Website, You can contact us via the links and email addresses below:

    [info@11bazaargate.com]

     

      Grievances

    If You have any questions or grievance or want to delete or modify your Personal Information, You shall mark your correspondence as “Grievance/Complaint” (given under the heading “Contact Us”) to our grievance officer at [info@11bazaargate.com]. Any communication which is not marked as such shall not be treated as a valid and binding communication for the purpose of this Privacy Policy and applicable laws with respect to this Privacy Policy.

     

      Definitions

    The relevant definitions as used in this Privacy Policy are as follows:

     

    • The term ‘Sensitive Personal Data or Information’ means and includes: (i) passwords, (ii) financial information such as Bank account, debit or credit card details, (iii) physical, psychological and mental health condition, (iv) sexual orientation, (v) medical records and history, (vi) biometric information, (vii) any detail relating to the above as provided to the body corporate for providing a service, and (viii) any of the information received under each of the heads by the body corporate for processing, or to be stored or processed under a lawful contract. Based on the definition of the sensitive personal data or information, financial information belonging to individual clients of Barclays India such as bank account details, debit or credit card information would be regarded as sensitive personal data.

     

    • The term ‘Personal Information’ means any information relating to a natural person, which either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.

     

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