Privacy Policy

Who are we?

We are VISAGE LINES PERSONAL CARE ECOMMERCE PVT. LTD. 5th Floor, Gulf Adiba, Plot Number 272, Udyog Vihar, Phase – II, Gurugram, Haryana – 122008

How do we collect information about you?

We may collect information about you in various ways.

You may provide us with information directly (e.g. filling in a form, or making a call to us).
We may collect information automatically (e.g. when you use our website).
We may acquire information from third parties (e.g. publicly-available information on social media platforms such as Facebook and Twitter).

In this notice, we refer to all the methods by which you are in contact with us as

“Touchpoints”. Touchpoints include digital (for example, our website) and when available physical touchpoints such as retail outlets and events. We may collect or process information that you provide directly. Typically, this will happen when you:

sign up to be a member of our databases (this could be, for example, online via our website);
purchase our products or services through a Touchpoint;
download, or use, a Touchpoint (e.g. a website);
contact us through a Touchpoint, or by e-mail, social media or telephone;
subscribe to our portal;
register to receive our press releases, e-mail alerts, or marketing communications;
participate in surveys or (where permitted by law) competitions or promotions; or
attend an event that we have organized.

We may collect or process information about you automatically. Typically this will happen when you:

attend an event that we have organized (for example, through purchases at the event or through sensors at the event that connect with mobile technology);
communicate with us (for example, through a Touchpoint; or social media platforms);
use the Touchpoints (for example, through tracking mechanisms (such as cookies and web beacons/pixels) that you receive when you use the Touchpoint or get an e-mail from us);
use third party websites (for example, using technology similar to that described in the bullet above, that you receive when you visit our Touchpoint or get an e-mail from us); or
make public posts on social media platforms that we follow (for example, so that we can understand public opinion, or respond to requests concerning our products).

As mentioned above, we may collect or process information about you automatically through the use of cookies and similar tracking technologies (such as web beacons/pixels) that you receive when you visit our digital Touchpoints or get an e-mail from us. The specific cookies and other mechanisms used will depend on the Touchpoint in question. To learn about these mechanisms used on a Touchpoint, including how you can accept or refuse cookies, please see the information made available on or through that Touchpoint. These mechanisms may include Google analytics cookies.

Where permitted by law, we may acquire information about you from third parties. This may include information shared between our affiliates, publicly-available profile information (such as your preferences and interests) on third party social media sites (such as Facebook and Twitter), and marketing lists acquired from third party marketing agencies.

We may also collect or process information in other contexts made apparent to you at the time.

What information about you do we collect?

We may collect various types of information about you:

information necessary to fulfil your orders
information you give us in forms, surveys or at Touchpoints (which includes information which may be automatically collected)
information about your location
information about your visits to our events
information about your preferences and interests
information necessary to verify your age
information we received about you from third parties

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Information that we collect from you directly will be apparent from the context in which you provide it. For example:

if you order a product from us through a Touchpoint, you provide your name, contact, billing details, and the products you have chosen so that we can fulfil your order;
you may provide information on your product preferences and interests so that we can offer you products and services that will interest you;

Information that we collect automatically will generally concern:

details of your visit or call (such as time, date, and duration);
recordings (where permitted) of your calls or visits to Touchpoints, which we may transcribe to text format;
your use of Touchpoints (such as the pages you visit, the page from which you came, and the page to which you went when you left, search terms entered, or links clicked within the Touchpoint, when you first open the Touchpoint, for how long you use it, and how you interact with messages or advertisements we send you); we may use cookies and similar tracking technologies (such as pixels/web beacons) to do this;
your use of third-party websites, where the information collected will be similar to that described in the bullet above (we may use cookies and similar tracking technologies (such as pixels/web beacons) to do this);
your mobile or desktop device and software (such as your IP address or unique device identifier (for example, mobile advertising identifier (MAID) or Android ID (SSAID)), location data (either derived from your IP address or if you choose to share your precise location with us for specified purposes, device brand and model, the display settings of your monitor, web browser type, operating system, (some of which may be used in “digital fingerprinting” (see for what purposes we use information about you, below)) and details of any cookies that we may have stored on your device);

Information that we collect from third parties will generally consist of publicly available profile information (such as your preferences and interests), for example from public social media posts.

For what purposes do we use information about you, and on what legal basis?

In this section, we describe the purposes for which we use personal information.

Subject to the above, we use information about you for the following purposes:

To comply with regulatory obligations, verifying your age and status as a user of our products
To sell our products to you, including fulfilling your orders, processing your payments
To provide sales-related services to you, including dealing with your inquiries and requests and support services
To market our products (where permitted by law), including administering any loyalty programs, product improvement, market research, developing marketing strategies, administering marketing campaigns, and (where available) customizing your experiences at outlets that sell our products and at events
To understand whether you are still engaged with our marketing and whether you wish to continue to receive it
For us or our business partners to inform you of potential opportunities to get involved in marketing or promoting our products
To support all the above, including administering your accounts, enabling you to use Touchpoints, corresponding with you, customizing your experiences of Touchpoints, fraud prevention (for example in the context of our promotions, competitions and surveys, to ensure that they are not taken more than once by the same person), and administration and troubleshooting
For business analytics, statistical or scientific purposes, including improving our products, outlets and events, and the information that we (or our affiliates) provide to our customers
For other purposes that we notify you of, or will be clear from the context, at the point information about you is first collected

The legal basis for our collection, processing or use of information about you is your explicit consent taken during your onboarding i.e., account creation, during your purchase of our products or when you post user generated content. .

The purposes for which we use information about you, with corresponding methods of collection and legal basis for use, are:

Purpose

Method of collection and legal basis for processing

Comply with regulatory obligations

● verify or collect data regarding your age and status as a user of our products

This information is generally provided to us by you directly.

We use it on the grounds that we have your consent to do this.

Sell our products

● fulfil your orders (including sending receipts)

● provide support services

This information is generally provided to us by you directly (typically, name, address, e-mail address.

We use it on the grounds that we have your consent to do this.

Provide sales-related services

● deal with your inquiries and requests

● correspond with you

● general administration and troubleshooting

● administer any loyalty programs

This information is generally provided to us by you directly.

We use it on the grounds that we have your consent to do this.

Market our products (where permitted by law)

● understand your preferences (such as what products or events may interest you or may be better tailored to your needs) and, where permitted by law, market to you personally

● understand whether you are still engaged with our marketing and whether you wish to continue to receive it

● administer any loyalty programs

● invite you to participate in, and administer, surveys or market research campaigns

● for market research

● develop marketing strategies

● administer marketing campaigns

● customize your experience of Touchpoints (for example, to personalize your visit, such as with greetings or suggestions that might interest you)

This will typically be a combination of information that you provide to us (for example, your name and contact and social media details); information that we collect automatically (for example, using technology (such as cookies and web beacons/pixels) to monitor your use of Touchpoints and e-mails from us), and using similar technology to monitor your use of third party touchpoints; and (where permitted by law) information that we acquire from third parties (such as public social media posts).

We use it on the grounds that we have your consent to do this.

Market our products (where permitted by law)

● provide you with information about, and to manage our promotions, products and services, events and the regulation of our products; and to develop and improve tools to pursue these purposes

This will typically be a combination of information that you provide to us (for example, your name and contact details, your social media handles); information that we collect automatically (for example, using cookies and similar technologies) and (where permitted by law) information that we acquire from third parties (such as public social media posts).

We use it on the grounds that we have your consent to do this.

Support for all the above purposes

● administering your accounts

● enabling you to use Touchpoints (for example, allowing you to remain logged in to sections of a Touchpoint that are reserved for authorized users only, administering your language preference, associating your shopping cart with you,

● corresponding with you

● supporting our products or services (for example, regarding a new product, or after-sales service)

● enhancing your experiences

● fraud prevention (for example in the context of any promotions, competitions and surveys, to ensure that they are not taken more than once by the same person)

● personnel training and quality control and administration and troubleshooting

This will typically be a combination of information that you provide to us (typically, name, password (or equivalent)) and information that we collect automatically (for example, information about your device, and cookies and similar tracking technologies, “digital fingerprinting” as described above, and (where permitted) recordings of your calls (and transcriptions of those recordings) or visits to Touchpoints).

We use it on the grounds that we have your consent to do this.

Business analytics and improvements

● allowing us or our business partners to inform you of potential opportunities to get involved in promoting our products

● for business analytics, statistical or scientific purposes (including for improving our products, services, events, Touchpoints and the information that we provide to our customers)

This will typically be a combination of information that you provide to us (such as demographic information, e.g. your age, gender and the city where you live); information that we collect automatically but where we seek your consent to use certain data, we won’t use that data for these purposes unless you have given your consent to it; and (where permitted by law) information that we acquire from third parties. Where we have more than one type of information from these categories, we will combine them to improve our analysis.

We use it on the grounds that

We have your consent to do this.

In some instances, we may use information about you in ways that are not described above. Where this is the case, we will provide a supplemental privacy notice that explains such use. You should read any supplemental notice in conjunction with this notice.

Who do we share your information with, and for what purposes?

We may share information about you with:

Our affiliates;
third parties who provide us or our affiliates or you with products or services;
carefully selected business partners and advertisers (in areas connected with our products, or consistent with their style and image) so that they can contact you with offers that they think may interest you, in accordance with your preferences; and
other third parties, where required or permitted by law.

We share information about you with others only in accordance with applicable laws. Thus, where law requires your consent, we will first ask for it.

We will fully comply with all applicable laws, including the Information Technology Act, 2000 and the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011.

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Sharing data with our affiliates

Information about you may be shared with our manufacturing partner Fertin India Pvt. Ltd and our parent company Fertin Pharma A/S, Denmark for the purposes and in accordance with this notice who are both our affiliates.

For clarity, you consent to the disclosure and/or transfer of your information to our

Sharing data with Third Parties

To the extent permitted by applicable law, we may share information about you with third parties who provide our affiliates or you with products or services (such as advisers, payment service providers, delivery providers, information services providers and age verification providers i.e., logistics service providers).
Your personal information is stored on servers managed by our third-party service providers such as Shopify Commerce Singapore Pte. Ltd.
To the extent permitted by applicable law, we may share information about you with our affiliates’ carefully-selected third party business partners and advertisers (in line with the kind of thing you might associate with our products, for example because they have similar or complementary image, style, or functionality) so that they can contact you with products, services and promotions that they think may interest you, in accordance with your preferences.
We may share information about you with other third parties, where required or permitted by law, for example: regulatory bodies or authorities; government departments; in response to a request from law enforcement authorities or other government officials; when we consider disclosure to be necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity; and in the context of organizational restructuring.

Where might information about you be sent?

Information about you may be disclosed or transferred globally (for example, if you are in India, your information may be transferred outside India).

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When using information as described in this notice, information about you may be disclosed and transferred either within or outside the country or territory where it was collected, including to a country or territory that may not have equivalent data protection standards.

In all such cases, the transfer will be:

subject to appropriate safeguards i.e., the disclosure or transfer will only be made to entities which at minimum ensure the same level of protection to your data as prescribed under applicable Indian laws;
necessary to discharge obligations under a contract between you and us (or the implementation of pre-contractual measures taken at your request); and
subject to your consent to such disclosure or transfer.

In all cases, appropriate security measures for the protection of personal information will be applied in those countries or territories, in accordance with applicable data protection laws.

Our service providers are located in many countries throughout the world, including in particular the EEA, Switzerland, Canada, India, and Singapore who may assist us with the collection or processing of your personal information or data.

How do we protect information about you?

We implement appropriate technical and organisational measures to protect personal information that we hold from unauthorised disclosure, use, alteration or destruction. Where appropriate, we use encryption and other technologies that can assist in securing the information you provide. We also require our service providers to comply with strict data privacy and security requirements.

How long will information about you be kept?

We will retain information about you for the period necessary to fulfil the purposes for which the information was collected. After that, we will delete it. The period will vary depending on the purposes for which the information was collected. Note that in some circumstances, you have the right to request us to delete the information. Also, we are sometimes legally obliged to retain the information, for example, for tax and accounting purposes.

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Typically, we retain data based on the criteria described in the table below:

Type	Explanation/typical retention criteria
● marketing to you (including marketing communications) (if you use digital Touchpoints and are contactable)	Most of the information in your marketing profile is kept for the duration of our marketing relationship with you or until we fulfil our contractual or legal obligations that may arise in relation to your access or use of the Website; for example, while you continue to use Touchpoints, or respond to our communications. However, some elements of your marketing profile, such as records of how we interact with you, naturally go out of date after a period of time, so we delete them automatically after defined periods (typically 3 years) as appropriate for the purpose for which we collected them even though your marketing relationship with us may be subsisting.
● marketing to you (including marketing communications) (if you are no longer in contact with us)	This scenario is the same as the above, but if we don’t have any contact with you for a long period (typically 2 years), we will stop sending you marketing communications and delete your history of responses to them. This will happen, for example, if you never click through to an invitation to an event, log on to a Touchpoint, or contact customer care, during that time. The reason is that in these circumstances, we assume you would prefer not to receive the communications.
● marketing to you (including marketing communications) (if you are not contactable)	If you have registered to receive marketing communications, but the information you give us to contact you doesn’t work, we will retain your details for a period of typically only 6 months to allow you to return and correct it.
● marketing to you (including marketing communications) (incomplete registrations)	If you commence registering yourself in a database, but do not complete the process (for example, if you don’t complete the age verification process, or you don’t accept the Touchpoint’s terms of use), we will retain your details for only 6 months to allow you to return and complete the process.
● market research	If you are not registered with us for other purposes (e.g. marketing communications, customer care), and we use publicly available information about you (which does not amount to sensitive personal data or information as prescribed under applicable Indian laws) in order to understand the market or your preferences, we will retain the information about you for a short period in order to perform the particular item of market research.
● purchases	If you purchase goods, we will retain details of this for so long as required to complete the sale, and to comply with any legal obligations (for example, for tax and accounting record-keeping purposes).
● customer care	If you contact customer care, we will make a record of the matter (including details of your enquiry and our response) and retain it while it remains relevant to our relationship, for example, if your recent enquiries are relevant. Temporary records (for example, an automated recording of a telephone call in which you ask us to direct you to a retail outlet) may be relevant only until more permanent records are made and will be retained only temporarily.
● system audit logs	System audit logs are retained typically for a period of only a few months or as may be required under applicable laws.
● business analytics	Business analytics data is typically collected automatically when you use Touchpoints and anonymised/aggregated shortly afterwards.

What rights and options do you have?

You may have some or all of the following rights in respect of information about you that we hold:

request us to give you access to it;
request us to rectify it, update it, or erase it;
request us to restrict our using it, in certain circumstances;
object to our using it, in certain circumstances;
not provide the personal information, which may detrimentally affect our ability to provide our services;
withdraw your consent to our using it or sharing it, except where required under applicable laws;
data portability, in certain circumstances;
unsubscribe or opt out from our using it for direct marketing; and
lodge a complaint with the supervisory authority in your country (if there is one).

We offer you easy ways to exercise these rights, such as “unsubscribe” links, or giving you a contact address, in messages you receive.

Who should you contact with questions?

If you have any questions, wish to exercise any of your rights, or wish to report any grievances you can contact Mr. Prashant Sadanand

Contact: info.vfppl@vecturafertin.com

Contact details will also be given in any communications that we send you.

If your country has a data protection authority, you have a right to contact it with any questions or concerns. If the relevant PMI affiliate cannot resolve your questions or concerns, you also have the right to seek judicial remedy before a national court.

Changes to this notice

We may update this notice (and any supplemental privacy notice), from time to time. Where the law requires it, we will notify you of the changes; further, where the law requires it, we will also obtain your consent to the changes.

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