Privacy Policy

Privacy Policy

 

Setmore Exim Pvt Ltd. (“SEPL” or “we”) takes the privacy of your information seriously. This Privacy Notice describes the types of personal information we collect from you through our stores, website (including sub-domains and microsites). It also describes the purposes for which we collect that personal information, the other parties with whom we may share it and the measures we take to protect the security of your data. It also tells you about your rights and choices with respect to your personal information, and how you can contact us about our privacy practices.

 

You are advised to carefully read this Privacy Notice before using or availing any of our products and/or services.

 

  1. DEFINITIONS

In this Privacy Notice, the following definitions are used:

 

 Cookies
A small file placed on your device by our website when you either visit or use certain features of our website. A cookie generally allows a website to remember your actions or preference for a certain period of time.

 

Data

includes non-personal information, personal information and sensitive personal information about you, which either directly or indirectly in combination with other information, could allow you to be identified when you visit our stores and/or website.

 

Data Protection Laws

Applicable law for the time being in force relating to the processing of Data is presently governed by Digital Personal Data Protection Act, 2023 and further as may be amended from time to time.

 

Partners & Associates

select third parties (including Group Entities) with whom we have contracts for the businesses described in this Privacy Notice.

 

Service Providers

includes entities to whom we or other Group Entities will disclose your Data in order to process information for a specific purpose. 

 

SEPL

is a company incorporated in India whose registered office is at Setmore Exim Pvt Ltd, 8 No. Ho Chi Min Sarani, Room Number-12E, Ground Floor, Kolkata- 700071. 

Group Entity

Shall mean and include its subsidiaries, affiliates, associate companies and joint venture companies with whom we have a contractual arrangement to, inter alia, share data for the purposes described in this Privacy Notice.

 

User or you

the natural person who accesses our stores, website or mobile application.

 

WHAT DATA DO WE COLLECT ABOUT YOU

SEPL collects Data for various purposes set out in this Privacy Notice.

This Data includes, without limitation, the following categories:

  1. Contact information: first and last name, email address, postal address, country, employer, phone number and other similar contact data.
  2. Financial information: payment instrument information, transactions, transaction history, preferences, method, mode and manner of payment, spending pattern or trends, and other similar data.
  3. Technical information: website, device and mobile app usage, Internet Protocol (IP) address and similar information collected via automated means, such as cookies, pixels and similar technologies.
  4. Transaction information: the date of the transaction, total amount, transaction history and preferences and related details.
  5. Product and service information: Your account membership number, registration and payment information, and program-specific information, when you request products and/or services directly from us, or participate in marketing programs.
  6. Personal information: Age, sex, date of birth, marital status, nationality, details of government identification documents provided, occupation, ethnicity, religion, or any other personal information provided in responses to surveys or questionnaires.
  7. Your reviews, feedback and opinions about our products, programmes and services.

 

HOW WE COLLECT DATA

We collect Data in the following ways:

 

Information You Give Us:

We receive and store any information you enter on our website or give us in any other way (e.g., at outlets, stores, kiosks). Please see the section titled “Data Shared by You” for more information.

Automatic Information We Collect:

We use “cookies”, pixels and similar technologies to receive and store certain types of information whenever you interact with us. Please see the section below, titled “Data that is Collected Automatically” for more information.

E-mail Communications:

To help us make e-mails more relevant and interesting, we often receive a confirmation (if your device supports such capabilities) when you open e-mail from us or click on a link in the e-mail. You can choose not to receive marketing emails from us by clicking on the unsubscribe link in any marketing email.

Automatic Information We Collect from Other Websites: 

We may receive and store certain types of information when you interact with third-party websites that use our technology or with whom we have a specific agreement.  Because we process this information on behalf of the applicable website operators, collection, processing, and use of such information is subject to the applicable website operators’ privacy policies and is not covered by our Privacy Notice.

Information from Other Sources: 

We may obtain information from other sources. An example of this is when you authorize a third-party website to interact directly with our website to provide or receive Data about you. In that case, we might receive such Data used by that third-party website to identify your account with that website.

 

DATA SHARED BY YOU

SEPL may collect your Data in several ways from your use of our stores, website.

For instance:

when you register with us to receive our products and/or services;

when you conduct a transaction with us or attempt a transaction at our stores or on our website;

when you complete surveys conducted by or for us;

when you elect to receive any communications (including promotional offers) from us;

from the information gathered by your visit to our stores or website;

 

DATA THAT IS COLLECTED AUTOMATICALLY

  • . We automatically collect some information when you visit our website. This information helps us to make improvements to our content and navigation. The information collected automatically includes your IP address.

We may collect your Data automatically via Cookies, pixels and similar technologies in line with settings on your browser.

 

OUR USE OF DATA

Any or all the above Data may be required by us from time to time to provide information relating to SEPL and to work on the experience when using our website. Specifically, Data may be used by us for the following reasons:

carry out our obligations arising from any contract entered into between you and us;

provide products and/or services and communicate with you about products and/or services offered by us;

provide you with offers (including for financial products and/or services), personalized services and recommendations and improve your experience on our website;

operate, evaluate and improve our business, website and mobile application;

generate aggregated data to prepare insights to enable us to understand customer behaviour, patterns and trends with a view to learning more about your preferences or other characteristics;

enforce the terms of use of our website;

protect against and prevent fraud, illegal activity, harm, financial loss and other legal or information security risks; and

serve other purposes for which we provide specific notice at the time of collection, and as otherwise authorized or required by applicable law.

 

We treat these inferences as personal information (or sensitive personal information, as the case may be), where required under applicable law. Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

Where required under applicable law, we will only use your personal information with your consent; as necessary to provide you with products and/or services; to comply with a legal obligation; or when there is a legitimate interest that necessitates the use.

 

MINORS

Our website and mobile application do not offer products or services for use by minors. If you are under 18, you may use our website only with the involvement of a parent or guardian.

 

SHARING OF DATA

We may share your Data with/ for:

 

  • . Partners:
  1. We may make available to you services, products, or applications provided by Partners for use on or through our website. If you choose to use such service, customer information related to those transactions may be shared with such Partner. Such Partners will be required to respect the security of your Data and to treat it in accordance with this privacy policy and applicable law.
  2. Group Entities:

We may make available to you products, services and /or applications to assist them to reach out to you in relation to their programs or campaigns and to process your queries and requests. Accordingly, we may share your Data with our Group Entities. We may also share your Data with our entities as is relevant for the purposes set out in Clause 7 above, and to facilitate the operation of our business.

  1. Service Providers:

We or other Group Entities may share your Data with Service Providers. Examples include storing and analyzing Data, protecting and securing our systems, providing search results and links, providing customer service, credit analysis, processing your information for profiling, user analysis and payment processing.

These Service Providers will be required to only process Data in accordance with express instructions and as necessary to perform services for purposes set forth in this Privacy Notice. The Service Providers will also be required to safeguard the security and confidentiality of the Data they process by implementing appropriate technical and organizational security measures and confidentiality obligations binding employees accessing Data.

  1. Protecting SEPL:

We may release Data when we believe release is appropriate to comply with applicable law or legal process, [enforce or apply the Terms of Use of our website and other agreements,] protect SEPL against harm or financial loss, when we believe disclosure is necessary to protect individuals’ vital interests, or in connection with an investigation of suspected or actual fraudulent or illegal activity. This may include exchanging information with other companies and organizations for fraud protection, risk management and dispute resolution.  This does not include selling or otherwise disclosing personally identifiable information from users for commercial purposes in violation of this Privacy Notice.

  1. Business Transfers:

As we continue to develop our business, we might sell or buy subsidiaries or business units. Your Data may be transferred as part of such transaction.

 

  1. Third Parties:

We may also share your Data with other third parties where: 

You request or authorize us to do so;

We need to comply with applicable law or respond to valid legal process; or

We need to operate and maintain the security of our website including but not limited to prevent or stop an attack on our computer systems or networks.

We require these third parties by contract to only process sensitive personal data in accordance with our instructions and as necessary to perform services on our behalf or in compliance with applicable law. We also require them to safeguard the security and confidentiality of the sensitive personal data they process on our behalf by implementing appropriate confidentiality, technical and organizational security measures.

 

KEEPING DATA SECURE

We will use technical and organisational measures to safeguard your Data and we store your Data on secure servers.  Technical and organisational measures include measures to deal with any suspected data breach.  If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us by e-mail.

 

RETENTION OF DATA

SEPL retains Data for as long as necessary for the use of our products and/or services or to provide access to and use of our website or for other essential purposes such as complying with our legal obligations, resolving disputes, enforcing our agreements and as long as processing and retaining your Data is necessary for our legitimate interests. Because these needs can vary for different data types and purposes, actual retention periods can vary significantly.

Even if we delete your Data, including on account of exercise of your right under Clause below, it may persist on backup or archival media for audit, legal, tax or regulatory purposes.

 

YOUR RIGHTS AND CHOICES

When we process Data about you, we do so with your consent and/or as necessary to operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests of SEPL as described in this Privacy Notice.

Depending on which Data Protection Laws are applicable to you, you may have the right or choice to:

  • opt out of some collection or uses of your Data, including the use of cookies, pixels and similar technologies and the use of your Data for marketing purposes.
  • access your Data, rectify it, restrict or object to its processing, or request its deletion or anonymization.
  • change or edit information submitted to us.
  • receive the Data you provided to us to transmit it to another company.
  • withdraw any consent provided or alter your preferences.
  • where applicable, lodge a complaint with your supervisory authority.

You may submit a request as described in the “How to Contact Us” section below. We will not charge you for any request. Where we are legally permitted to do so, we may refuse your request.  If we refuse your request, we will tell you the reasons why.

It is important that the Data we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold it.

 

WHERE WE STORE DATA

Data collected under this Privacy Notice is hosted on servers located in India or places where SEPL decides from time to time and/or as may be required for safety of the data.

 

PROCESSING YOUR DATA

We take steps to ensure that the Data we collect under this Privacy Notice is processed according to the provisions of this Privacy Notice and the requirements of applicable law.

 

SEVERABILITY

If any court or competent authority finds that any provision of this Privacy Notice (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Notice will not be affected.

 

CHANGES TO THIS PRIVACY NOTICE

Our business changes constantly and our Privacy Notice will change also. We may e-mail periodic reminders of our notices and conditions, unless you have instructed us not to, but you should check our website frequently to see recent changes.  The updated version will be effective as soon as it is accessible. Any changes will be immediately posted on our website and you are deemed to have accepted the terms of the updated Privacy Notice on your first use of our website or first purchase of the products and/or services following the alterations. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

 

Disclaimers

1. Users of the Deeper Connect device bear full responsibility for ensuring that their use of the device is in strict compliance with all applicable local, national, and international laws. It is the sole obligation of the user to be informed of, and to adhere to, any and all relevant legal requirements.

2. The Deeper Connect device is strictly prohibited from being used for any unlawful purposes. Any individual found to be engaging in illegal activity through the use of the device may be subject to legal action, including but not limited to prosecution to the fullest extent permissible under local, national, or international law.

* Mining with Deeper Connect devices for DPR is not available for Indian IP addresses.

HOW TO CONTACT US

You may contact us on setmoreexim@gmail.com for information on Service Providers, Partners and Group Entities with whom we may share your Data in compliance with this Privacy Notice and applicable law. We will respond to your request within 15 days.