SECRET HAIRCARE PRIVATE LIMITED (referred to as “we”, “us”, "Company") is the author and publisher of the website www.thesecrethaircare.com and its sub-domains, if any, (collectively referred to as "Website") and other applications, mobile applications (“Services”) and has provided this privacy policy ("Policy") to familiarize You with the manner in which the Company uses and discloses Your information collected through the Website or its Services.

Company created this Privacy Policy to demonstrate its commitment to the protection of Users’ privacy and Users’ personal information. Users’ use of and access to the Services is subject to this Privacy Policy and the attached Terms of Use. Any term used but not defined in this Privacy Policy shall have the same meaning as attributed to it in the Terms of Use.

BY CONFIRMING THAT YOU ARE BOUND BY THIS PRIVACY POLICY (BY THE MEANS PROVIDED ON THIS WEBSITE OR APPLICATION), BY USING THE SERVICES OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU AGREE TO THE POLICIES AND PRACTICES OUTLINED IN THIS PRIVACY POLICY AND YOU HEREBY CONSENT TO OUR COLLECTION, USE AND SHARING OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. WE RESERVE THE RIGHT TO CHANGE, MODIFY, ADD OR DELETE PORTIONS OF THE TERMS OF THIS PRIVACY POLICY, AT OUR SOLE DISCRETION, AT ANY TIME AND PUBLISH THE SAME. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AT ANY TIME, DO NOT USE ANY OF THE SERVICES OR GIVE US ANY OF YOUR INFORMATION. IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE (SUCH AS YOUR SPOUSE, CHILD OR OTHER CLOSE FAMILY MEMBER) OR AN ENTITY, YOU REPRESENT THAT YOU ARE AUTHORISED BY SUCH INDIVIDUAL OR ENTITY TO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF.

BY USING THE WEBSITE, YOU AGREE TO THE TERMS AND CONDITIONS OF THIS POLICY.

1. SCOPE OF POLICY

1.1 When You use the Website or the Services, the Company may seek and collect certain personal and non-personal information classified as mandatory or voluntary (collectively "Information"). Accordingly, whenever You use the Website or the Services, You consent to the collection, use, and disclosure of the Information in accordance with this Policy.

2. COLLECTION AND USE OF PERSONAL INFORMATION

2.1 Personal information is data that can be used to uniquely identify or contact a single person. “Personal Information” for the purposes of this Policy shall include, but not be limited to, information regarding Your name, address, telephone number, date of birth, gender, e-mail address, image and video captures, biometric information, etc.

2.2 Some of the Information that Company may ask You to provide may be identified as mandatory and some as voluntary. If You do not provide the mandatory Information, You will not be able to avail the services provided by Company.

2.3 Company collects Personal Information that Company believes to be relevant and which is required to provide the Services to the User. The Company may share your Personal Information with non-affiliated entities to continuously improve the User experience with regards to the Service, to improve security measures and/or to provide offers and promotional materials and with delivery partners to fulfill the supply of items requested by the User.

2.4 All the information provided to us by a User, including sensitive personal information, is voluntary. You understand that Company, either itself or with its Partners, may use certain information of yours, which has been designated as ‘sensitive personal data or information;

• (a) for the purpose of providing you the Services,

• (b) for commercial purposes and in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes,

• (c) for sale or transfer of such research, statistical or intelligence data in an aggregated or non-personally identifiable form,

• (d) for the purpose of marketing and promotional activities to deliver personalized content to the Users.

2.5 You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. If your personal information changes, you may correct, delete inaccuracies, or amend information by making the change on your profile information page on the Websites or Application or by contacting Company authorized email info@thesecrethaircare.com.

2.6 Company may require the User to pay with a credit card, debit card, net banking, wallets, or other online payment mechanisms for Services for which an amount(s) is/are payable. Company will collect such User’s credit card number and/or other financial institution information such as bank account numbers and will use that information for the billing and payment processes, including but not limited to the use and disclosure of such credit card number and information to third parties as necessary to complete such billing operation. Verification of credit information, however, is accomplished solely by the User through the authentication process offered by a third-party payment gateway. User’s credit card/ debit card details are transacted upon secure sites of approved payment gateways which are digitally encrypted, thereby providing the highest possible degree of care as per latest technology currently available. User is cautioned, however, that internet technology is not foolproof or safe and User should exercise discretion on using the same.

3. DISCLOSURE OF PERSONAL INFORMATION

3.1 Company will keep Your Personal Information confidential to the maximum possible extent. Company limits the disclosure of Personal Information to Company's employees, independent contractors, affiliates, consultants, business associates, service providers on a need-to-know basis, and only for the purposes stated in Clause 2 above and only for the entities described below.

3.2 In addition to the above, the Company may share Personal Information which the Company may believe to be necessary or appropriate:

• (i) under applicable law;

• (ii) to comply with any legal processes;

• (iii) to respond to requests from public and government authorities;

• (iv) to enforce the User Terms;

• (v) to protect Company's operations or those of any of Company's affiliates, consultants, business associates, service providers;

• (vi) to protect Company's rights, privacy, safety or property, and/or that of Company's affiliates, You or others; and

• (vii) to allow Company to pursue available remedies or limit the damages that Company may sustain.

4. COLLECTION AND USE OF NON-PERSONAL INFORMATION

4.1 Non-personal information is any information that does not reveal Your specific identity, such as, browser information, Internet protocol (IP) address, particulars of the accessing device, and other information collected through cookies ("Non-Personal Information"). The Website gathers some information automatically when You visit the URL of the Website and stores it in log files. Accordingly, when You use the Website, Company may collect certain information about Your computer or device to facilitate, evaluate and verify Your use of the Website. This information is generally collected in aggregate form, without identifying any user individually.

4.2 As Non-Personal Information does not personally identify You, Company may use and disclose Non-Personal Information for any purpose. In some instances, Company may combine Non-Personal Information with Personal Information (such as combining Your name with Your geographical location). If Company combines any Non-Personal Information with Personal Information, the combined information will be treated by Company as Personal Information as long as it is combined.

5. THIRD-PARTY LINKS TO OTHER WEBSITES

5.1 The Website or any other interface comprised in the Service may provide third-party advertisements and links to other websites. Company does not provide any Personal Information to these third-party websites or advertisers.

5.2 The links to other websites on the Website are operated by third parties and are not controlled by, or affiliated to, or associated with, Company. Accordingly, 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 Company control or guarantee the accuracy, integrity, or quality of the information, data, text, software, music, sound, photographs, graphics, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any endorsement by Company of such websites, such websites’ provider, or the information on such websites. The information provided by You to such third-party websites shall be governed in accordance with the privacy policies of such websites and it is recommended that You review the privacy policy on any such websites prior to using such websites.

6. USER DISCRETION

As stated earlier, You can always choose not to provide Information, even though it might be needed by the Company for its business purposes. In such cases, if the information required is classified as mandatory, You may not be able to avail the services provided by the Company.

7. GENERAL PROVISIONS

7.1 Company may make changes to this Policy, from time to time at Company's sole discretion or on account of changes in law. You are encouraged to check the Website frequently to see recent changes. Notwithstanding the above, Company shall not be required to notify You of any changes made to the Policy. The revised Policy shall be made available on the Website. Your continued use of the Website or the Services, following changes to the Policy, will constitute Your acceptance of those changes.

This Privacy Policy is published in compliance with, inter alia; Section 43A of the Information Technology Act, 2000, Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”) and Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011 and Rule 4 of Consumer Protection (E-Commerce) Rules, 2020. if you have any grievances or concerns about Company’s Privacy Policy or if you would like to make a complaint about a possible breach of privacy in, you may contact the Grievance Officer, Mr. Chethan at chethan@thesecrethaircare.com

7.3 If You choose to visit the Website or avail the Services, Your visit and any dispute over privacy is subject to this Policy and the Website and the User Terms, and the applicable law shall be the law of the Republic of India.

8. CONSENT TO THIS POLICY

8.1 You acknowledge that this Privacy Policy is a part of the Terms of Use of the Website and the other Services, and you unconditionally agree that becoming a User of the Website, the Application, and its Services signifies your assent to this Privacy Policy. Your visit to the Website, use of the App, and use of the Services is subject to this Privacy Policy and the Terms of Use. This Policy should be at all times read along with the User Terms of the Website. Unless stated otherwise, the Policy applies to all Information that Company has about You.

9. CONTACT INFORMATION

9.1 If you have questions about this Privacy Policy or use and disclosure practices, you may contact us at info@thesecrethaircare.com.

9.2 If you have any grievance with respect to our use of your information, you may communicate such grievance to:

The Chief Data Officer - PriyaDarshini J

priya@thesecrethaircare.com