External Privacy Notice

Updated as 02nd January 2024

Tata Soulfull Website
We at Tata Consumer Soulfull Private Limited ("TCSPL" or "We") are a wholly owned subsidiary of Tata Consumer Products Limited. We respect your Privacy and are committed to protecting it through our compliance with our Privacy Policy.

This Privacy Notice governs the manner in which www.soulfull.co.in (“Tata Soulfull,” “we,” “us,” or “our”) collects, uses, shares, maintains and discloses Personal Data collected from users (each, a "User", “you”) of the Website ("www.soulfull.co.in ").

We encourage you to read our Privacy Notice on a regular basis and whenever you intend to provide Personal Data to us. We may amend this Privacy Notice from time to time to reflect changes in our data handling practices.

Website collects, processes, uses, storages, discloses, transfers, or otherwise makes available (“Processing”, “Process” or “Processed”) your Personal Data as legally permitted under Digital Personal Data Protection Act (IN), 2023 and other in-scope Data Protection Regulations.

The privacy practices set forth in this Privacy Notice are for this Website only. If you are re-directed to other Websites or provide personal data to any of those Websites, please review the privacy notices posted at those Websites.

Data We Collect About You and How We Collect It
i. Personal Data That You Give Us: We receive and store any data you provide in relation to our Services. You can choose not to provide certain data, but then you might not be able to take advantage of many of our Services. Examples of what data you give us includes your first and last name, contact details such as your email address and phone number, payment information such as but not limited to credit/ debit card number, expiration date. We may also gather information about your access to our website, order history, no. of times you have visited our website and the services/products accessed/purchased by you at our website. This information is used by us to personalize your shopping experience, to process your transactions, deliver your orders, process payment and to make communication regarding your order and/or our products and services. The name, contact number, postal and e-mail address are used by us for contacting you for the fulfilment of your order, sending you information and promotional codes and notifying you about any offer, updates, or new service. The information is also used by us staff members/fulfilment partners, who are involved in the completion of your transaction.

ii. Personal Data That Is Collected Automatically: We automatically collect and store certain types of data about your use of our Services, including data about your interaction with our Website and services availed through our Website. This data is used by us to personalize your shopping experience, to process your transactions, deliver your orders, process payment and to make communications regarding your order and /or our products, offers and services. Like many Websites, we use "cookies" and other unique identifiers, and we obtain certain types of information when your web browser or device accesses our Services and other content served by or on behalf of us on other Websites. Examples of what Personal Data we may collect includes the internet protocol (IP) address used to connect your computer to the internet, purchase and content use history, browser and device information, browsers you used to access our Site and services, webpages viewed, time spent on webpages, links clicks, transactions entered, site-navigation patterns, referring Website addresses and other diagnostic data from your use and interaction with our Site. Please refer to our Cookie Policy on details around how we collect and process your personal data.

iii. Entering a Contest or Promotions: If you participate or enrol in an active promotional campaign that may be launched on the Website, you are giving us your consent to collect name, contact information, and any other information that you choose to include on the form. If you are an account holder, we may note in your account that you participated in a promotion.

How we use your data
We may use the data that we collect or that you provide to us, including any Personal Data:
i. For processing your orders, contact you in relation to your order (for example tracking your order, an item is out of stock, payment hasn’t cleared or just to let you know that we’ve saved your basket for you etc.) and to pass your payment information onto our payments processing partners;

ii. For marketing and advertising purposes, such as to communicate with you about our products and services and those of our subsidiaries, affiliates, and parent companies that may be of interest to you;

iii. For administrative purposes, such as to register you for, or notify you that you are a winner of a contest or other promotion; to assist you with managing your account and passwords; for technical support; to maintain security and operability of our Website (including for debugging purposes); to provide reports to prospective partners, service providers, regulators, and others; to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect you and us; to enforce this privacy policy notice, our Terms of Use, and other policies;

iv. For customer service purposes, such as to respond to your queries and requests;

v. To undertake, with your consent, marketing campaigns and any other promotional activities such as providing information about special events;

vi. To build our contact database once you have made a purchase, completed a transaction and/or registered to receive more information;

vii. Upon your opt-in, for research and analytics, such as for internal market analysis, such as identification of trends and measuring the amount of traffic to our Website; to improve our Website, products, and customer experience; to understand what parts of our Website are most popular or to improve upon our Website; to understand our customer demographics; and for other research and analytical purposes.

viii. To deliver target advertising and coupons if you have signed up or registered to receive this information.

ix. To comply with applicable legal or regulatory obligations, including to respond to a subpoena or court order; to cooperate with law enforcement or other governmental investigations; and as part of legal proceedings.

x. Where we believe it is necessary to protect us and others, including, without limitation to detect, prevent, and respond to fraud, security incidents, or other issues where we believe it is appropriate to protect us and others.

Legal Basis of Processing Personal Data
With your use of this Website, we may process your Personal Data based on the following legal grounds:

i. Your Consent – When you subscribe to Tata Soulfull updates, create/register profile on the Website, manage your cookie preference or in every other case where you provide us with your clear and specific consent; or

ii. Our legitimate use

• For a specified purpose you voluntarily provide your personal data to us for which you have not indicated to us that you do not consent to the use of Personal Data;
• When we use your Personal Data to comply with laws;
• When we improve our services, when we detect and prevent fraud and abuse in order to protect the security of our customers, ourselves, or others, and when we provide you with interest-based advertising, and
• When we comply to any judgement, order or decree relating to claims of a contractual or civil nature under any law for the time being in force in India.

Disclosure of Your Data
We may disclose Personal Data that we collect or you provide to us as described in this privacy policy notice:
i. To our subsidiaries and affiliates;

ii. To contractors, service providers, and other third parties to develop or improve our products, services and Websites;

iii. To contractors, service providers, and other third parties to administer a sweepstakes, contest or other promotion.

iv. To advertisers and marketers, including ad networks for targeted advertising. We do not use tracking technologies unless you opt-in on our Website.

v. To suppliers and distributors of our products;

vi. To contractors, service providers, and other third parties for email distribution services;

vii. To contractors, service providers, and other third parties for Website management;

viii. To third party service providers as individually identified in this policy;

ix. To our e-commerce platform, “Shopify”. For more information on how they collect/use your information, please see their privacy notice https://www.shopify.com/legal/privacy

x. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, or other sale or transfer of some or all of TCSP's assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding in which personal data we hold is among the assets transferred;

xi. As necessary to fulfill the purpose for which you provide it;

xii. Otherwise with your consent or in a manner disclosed by us when you provide the information.

We may also disclose your Personal Data
i. To comply with any court order, law, legal process, or law enforcement, including to respond to any government or regulatory request;

ii. To enforce or apply our terms of use, terms of sale, and other agreements with you, including for billing or collection; and

iii. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of TCSP, our customers, or others.
TCSPL employs appropriate safeguard for cross-border transfers of Personal Data, as required by applicable local law(s).

Minors Data
The Site is not intended for individuals under the age of 18. We do not intentionally collect Personal Data of children. If you are the parent or guardian and believe your child has provided us with Personal Data, please contact us at the Email ID below to request deletion.

Data Retention
We will retain your Personal Data (collected through online and offline methods) for as long as it is necessary for the purposes described in this Notice. We will also retain and use your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
Even if we delete your Data, it may persist on backup or archival media for audit, legal, tax or regulatory purposes.

Data Principal Rights
In this Section, we have summarized the rights that you may have under the Digital Personal Data Protection Act 2023 (“the Act”). Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

i. Right to Access Information- You may ask us to provide suitable privacy notices containing relevant information about the collection and usage of your data. You may also ask us to provide you with a copy of your Personal Data held by us, free of charge, in an electronic format;

ii. Right to Correction and Erasure- You may ask us to correct, update and/or otherwise amend your inaccurate or incomplete Personal Data held by us. You may also ask us to delete all your Personal Data we hold;

iii. Right of Grievance Redressal – You may have grievances regarding the Website, the contents thereof or the Services. You may reach out to Tata Consumer Products customer support at GDPO@tataconsumer.com . Our representative shall address any complaint or grievance that is raised by you within a period of 30 days from the date of raising of such complaint or grievance.

iv. Right to Nominate – You have the right to nominate any other individual who in the event of death or incapacity can exercise the Rights on your behalf.

You may exercise any of your rights in relation to your Personal Data by raising an Email request to us at GDPO@tataconsumer.com . Please note that we may contact you and ask you to confirm your identity to ensure that we do not disclose your Personal Data to any unauthorized person, and that we may ask you to specify your request before we perform any actions. Once we have confirmed your identity and understood exactly what you would like us to do, we will handle your request in accordance with applicable law.

If at any instance, access cannot be provided within a reasonable time frame, TCSP shall provide you with a date when the information will be provided. If for some reason access is denied, shall provide an explanation as to why access has been denied.

Duties of Data Principals
In this section we have summarized the duties assigned to you under the Digital Personal Data Protection Act (IN), 2023 (“the Act”).

• To comply to the provisions of applicable laws while exercising rights under the Act;
• To not to impersonate any other person while providing his or her Personal Data;
• To ensure not to register false or frivolous grievances or complaints with the Data Protection Board of India (“the Board”).

Cross Border Data Transfer
Whenever we transfer personal data to countries outside India, we ensure that the data is transferred in accordance with this Privacy Notice and as permitted by the applicable laws on Data Protection. We adhere to Government of India’s decisions on restriction of transfer of Personal Data to blacklisted countries or use contracts with standard safeguards and similar measures under applicable Data Protection laws for such transfers as may be notified by the Central Government.

Data Security
We adopt appropriate data collection, processing and storage practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your Personal Data, username, password, transaction information and data stored on our Site.

We use commercially reasonable and industry standard security technologies and safeguards to protect the Personal Data that we collect and use. We also expect our service providers to protect such Personal Data in the same manner. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us at GDPO@tataconsumer.com

Changes to this Privacy Notice
We reserve the right to change this notice from time to time. The date the Privacy Notice was last revised is identified at the top. Any changes shall be effective immediately upon the posting of the revised Privacy Notice. We encourage you to periodically review this page for latest information on our privacy practices.

Complaints Or Inquiry
If you have any questions or complaints about this Privacy Notice, the practices of this site, or your dealings with this site, please contact us at: GDPO@tataconsumer.com

You also have the right to complain to a Data Protection Board (“The Board”) about Our collection and use of Your Personal Data.