Privacy Policy

1. OBJECTIVE

This Privacy Policy (hereinafter referred to as the “Policy”) describes the Company policies and procedures on the collection, use, processing and disclosure of your information when you use the Services we provide at the Website and tells you about your privacy rights and how the law protects you.

This Privacy Policy is an electronic record under the Information Technology Act, 2000 and the rules made there under and the provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000, from time to time. This electronic record is generated by a computer system and does not require any physical or digital signatures to make the terms of this Privacy Policy binding.

This Privacy Policy is published under the requirements specified by the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) rules, 2011, made under the Information Technology Act, 2000 and other applicable laws.

The Privacy Policy and your privacy is vital to us and hence it is important for You to know what Personal Data we collect, how we collect it, where all do we use it and also some of the rights that You are entitled to as a Data Subject.

2. DEFINITIONS

For the purposes of this Privacy Policy:

• Account: means a unique account created by You to access our Service or parts of our Service at the Website.
• Company: (For the purpose of this Policy, the terms Company and inter alia the terms "our", "ourselves", "we" and "us" refer to Dharampal Satyapal Foods Limited (formerly known as DS Confectionery Products Limited) which include its associates, affiliates, group companies, and subsidiary (ies), unless the context clearly provides otherwise.)
• Data Controller: means the entity which provides services to its end customers (individuals – ‘providers of information’ under the ITAA 2008) under a direct relationship and determines the means and purpose of data collection and processing.
• Data Processor: means the entity which provides services to its clients (organizations) under a lawful contract having indirect relationship with the end customers (providers of information) as per the instructions from Data Controller; e.g. business process outsourcing service providers and also includes any entity processing Personal Data on behalf of and as per instructions of the Data Controller.
• Data Subjects: Any natural or legal person / individual who provides its personal information/ Personal Data to Data Controller, which for the purpose of this Policy is you.
• you/your/yourself: As used in this policy, member (whether registered or not) shall be referred to as "you", "your" and "yourself" which shall mean any natural or legal person / individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable at the Website.
• Service: refers to the services offered at the Website.
• Cookies: are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.
• Country: refers to: India or any country where we provide our Services
• Device: means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Information: shall mean any information provided by you on the Website including but not limited to the Personal Data/Information as defined below.
• Personal Data/ Information : is any information that relates to an identified or identifiable individual.
• Service Provider: means any natural or legal person who processes the Information on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• Third-party Social Media Service: refers to any websites or any social network websites through which a user can log in or create an account to use the Service.
• Usage Data: refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website: refers to the below mentioned e-commerce website www.laderach.in

The Policy hereby governs the collecting and /or processing of your Personal Data by us and is hereby notified to you in accordance with the required legal provisions.

3. SCOPE

The Website is operated and managed by the Company (Laderach Brand -Business partner in India).

This Privacy Policy ("Policy") applies to “Data Subjects” information collected and used by Company (which for the purpose of this Policy is the “Data Controller” and / or “Data Processor” as applicable unless otherwise specified herein) on its Website as a result of your use of Website or sharing of such information with us by any other means in connection with the activities undertaken on the Website.

The Website recognizes the importance of maintaining your privacy. We value your privacy and appreciate your trust in us. This policy describes how we treat information we collect from you, the types of information that we collect and matters related thereto. By visiting and/or using our Website, and or by signing up on the Website, you agree to the terms of this Privacy Policy and provide us with your consent to collect, store, handle and process such information. If you do not agree, please do not use or access our Website.

4. COLLECTING AND USING YOUR DATA/INFORMATION

4.1 TYPES OF DATA COLLECTED

Personal Data

While visiting the Website, ordering the products offered therein, there will be a number of instances where we may be collecting and you will be providing us with your personal information as the same is required to serve you better and for fulfilling the objectives of our Service and Website related activities provided to you. The below are certain types of information that we may collect from you.

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Usage Data

There are a number of situations in which your personal information may be collected by us in order to serve you better. At various touch points, we may collect the following personal information including but not limited to your name, address and contact information, date year of birth, anniversary date, gender, and consumption pattern/details of the Services availed by you on the Website. Besides the aforesaid personal information, we may also collect:

• User name, and membership number and password made by you when you register at our Website or become a member of our loyalty program.
• Your transaction history.
• Your queries, comments and complaints.

Usage Data

Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit the Website or access the Websites by or through any medium.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse Our Service. The technologies we use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. For example, when someone visits a page within the Sites, a cookie is placed on the user's machine (if the user accepts cookies) or is read if the user has visited the Sites previously. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, You may not be able to use some parts of our Services. Unless you have adjusted your browser setting so that it will refuse Cookies, our Service may use Cookies. Some example of Cookies we use are:
• Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies.
• Security Cookies.  We use Security Cookies for security purposes.
• Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

• Web Beacons

  Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related Website statistics (for example, recording the popularity of a certain section and verifying system and server integrity). We may include Web beacons in promotional e-mail messages or R Club Newsletters in order to determine whether messages have been opened and acted upon. We may also place Web beacons from third parties on our site in order to compile aggregated statistics and to help determine the effectiveness of our joint promotional or advertising campaigns. We prohibit Web beacons on our Website from being used by third parties to access your personal information.

• Use of Logs Files

  Log file information is automatically reported by your browser each time you access a web page. When you use the Services, our servers automatically record certain information your web browser sends whenever you visit any websites. These server logs may include information such as your web request, Internet Protocol address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information. You may, however, visit our Website anonymously. We will collect personally identifiable information from you only if you voluntarily submit such information to us. You can always refuse to provide personally identifiable information, but by doing so, you may be prevented from engaging in Website related activities. In the event that you opt to withdraw your consent for processing any personal information in the manner as prescribed herein, we will be in a rightful position to delete your access to the account or the loyalty program or to restrict any other activity on the Website, which in the absence of personal information cannot be undertaken. You can always refuse to provide personally identifiable information, but by doing so, you may be prevented from engaging in our Website related activities.

Non- Personally Identifiable Information:

Shopify

Our Website is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you. Your data is stored through Shopify’s data storage, databases and the general Shopify application. They store your data on a secure server behind a firewall. For further details on how Shopify, stores and processes your information, please visit the Shopify privacy policy.

5. USE OF DATA/INFORMATION

5.1 PERSONAL INFORMATION

We may use or share the information collected from you at the time of your visit on our Website and register for our loyalty program, sign up for our promotions, respond to a survey or marketing communication or use certain other site features in for the following purposes:

• To personalize user's experience.
• Provide service to you and preparing monthly statements for your account maintenance.
• Keeping track of loyalty point transactions, for solving any issue related to transactions on the Website, dealing with your requests, enquiries or complaints and related activities, and all other general administrative and business activities, marketing our products and services.
• To allow us to serve you better in responding to your customer service requests.
• To seek your feedback/opinion or to contact you in relation to the services offered on our Website, allocating or offering rewards, discounts or other benefits as part of the loyalty program.
• While registering on the Website, you are also entering the Loyalty program offered by us at the Website, you have given your consent to contact you via landline/mobile or postal mail to receive loyalty program offers. We may also contact you via email or courier for administrative purposes, such as program change notifications. Our customer care department may contact you in response to an enquiry that you submit, relating your loyalty program or with an offer in which you might have participated.
• To administer a contest, promotion, survey or other Website feature.
• To quickly process your transactions.
• To send regular emails regarding your order or other products and services.
• To trace computer resources or any person who may have contravened, or is suspected of having or being likely to contravene, any provision of law including the Information Technology Act, 2000 or any amendment thereof, that is likely to have an adverse impact on the services provided on the Website or otherwise by us;
• To ensure compliance with law.
• To alert you to special offers, updated information and other new products from our Website, outlets or to forward promotional materials to you;
• To ensure the Websites are relevant to your needs;
• To help us create and publish content most relevant to you;
• To notify you about a material change to this privacy policy or the Terms of Use Agreement, if necessary;
• To allow you access to limited-entry areas of the Website; and
• To contact you in response to sign up forms such as Contact us or other inquiry.

5.2 NON-PERSONALLY IDENTIFIABLE INFORMATION

Non-personally identifiable information is used as described above and in other ways as permitted by applicable laws, including combining non-personally identifiable information with personally identifiable information.

5.3 TRANSFER OR SHARE OF PERSONAL DATA/INFORMATION

We do not sell, rent, trade or publish your personal data/information. However, we may share your personal data/information only with:

• With Service Providers / Third Parties.

  We may share your personal information with Service Providers / Third parties such as websites hosting partners, online payment gateways and other parties who assist us in operating our Website, conducting our business, or serving you, so long as those parties agree to keep personal data/information confidential to monitor and analyze the use of our Service, to contact you. In such cases, service providers and /or third parties with whom we have shared your personal data to be referred here as Data Processor.

• For business transfers.

  We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.

• With Affiliates.

  We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our company, group companies, subsidiaries, associates, entities and any other subsidiaries, joint venture partners or other companies that we are associated with.

• With business partners.

  We may share your information with our business partners to offer you certain products, services or promotions.

• With Government Statutory bodies.

  Government or statutory authorities, if required by law, conditions of use of Website or sale, or as may be reasonably necessary to protect the rights, property and safety of others or ourselves.

• Please note that when you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see your name, profile, pictures and description of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you and view your profile.
• Except as stated herein above, you shall be given a notice about sharing of your personal data/information and an option shall be provided to you to decide whether we can share the same. In the event you decide not to allow us sharing your personal data/information pursuant to the notice herein, the Services connected with that particular notice may be affected and you may not be able to use the same. You shall not seek any compensation or bring an action, suit or claim against us where your information is disclosed in the aforesaid manner or in accordance with this Policy.

The Company allows you to create an account and log in to use the Service through the following Third-party social media services but not limited to:

• Google
• Facebook
• Twitter

If you decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal Data and information that is already associated with Your Third-Party Social Media Service's account, such as your name, your email address, your activities or your contact list associated with that account.

You may also have the option of sharing additional information with the Company through your Third-Party Social Media Service's account. If you choose to provide such information and Personal Data, during registration or otherwise, you are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

We may use third-party Service Providers to monitor and analyze the use of our Service. For example: Google Analytics is a web analytics service offered by Google that tracks and reports Website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

5.4. DISCLOSURE OF PERSONAL DATA

Your Personal Data or information may be disclosed for the purposes including but not limited to the following:

• Business Transactions. To

  Corporates, businesses or third parties as part of any corporate reorganization process including, but not limited to,mergers, acquisitions, and sales of all or substantially all of our assets. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

• Law enforcement

  Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency), to comply with the law or in the good faith belief that such action is necessary in order to conform to the requirements of law or comply with legal process served on us, protect and defend our rights or property, including the rights and property of our Website or act in urgent circumstances to protect the personal safety of our end users.

• Other legal requirements.

  The Company may disclose your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability
• Unaffiliated third-party service providers, agents or independent contractors,

  who help us maintain our Website and provide other administrative services to us (including, but not limited to, order processing and fulfillment, providing customer service, maintaining and analyzing data, sending customer communications on our behalf). We seek to ensure that these unaffiliated third parties will not use the personally identifiable information for any other purpose than to provide the administrative services for which they are responsible. Because such unaffiliated third-party service providers that help us administer our Website will have access to users' personally identifiable information, if you do not wish for our unaffiliated third-party service providers to have access to your information, please do not register or submit any personally identifiable information to us. Our Website is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you. Your data is stored through Shopify’s data storage, databases and the general Shopify application. They store your data on a secure server behind a firewall. For further details on how Shopify, stores, protects and processes your information, please visit the Shopify privacy policy Except as described in this Privacy Policy or at the time we request the information, we do not otherwise use, share or otherwise disclose your personally identifiable information to any third parties.

6. SECURITY OF PERSONAL DATA

Shopify work tirelessly to protect your information, and to ensure the security and integrity of the Shopify platform. Shopify platform also have independent auditors who assess the security of your data storage. However, we all know that no method of transmission over the Internet and method of electronic storage, can be 100% secure. This means we cannot guarantee the absolute security of your information, while we strive to use commercially acceptable means to protect your personal data. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk.

Once we receive your transmission, we make reasonable efforts to ensure security on our systems. We use firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.

If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using these Sites or providing personally identifiable information to us you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Website. We may post a notice on our Website if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances

We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) protocol for establishing secure links between networked computers. Secure Sockets Layer (SSL) authenticates a website's identity and enables an encrypted connection and encrypts all your personally identifiable information. The encryption process takes the characters you enter and converts them into bits of code (unreadable format) that are then securely transmitted over the internet.

Shopify is certified according to the Level 1 PCI DSS standard. It means that our Website is equipped with data encryption tools, protection of Shopify payment transfers, prevention of viruses at the servers, risk analysis tools as well as constant security monitoring.

We adopt appropriate data storage and security measures to protect against unauthorized access, alteration, disclosure of your personally identifiable information stored on our Website. For the measures that Shopify has in place for the protection of your personally identifiable information stored on our Website, you may visit https://www.shopify.com/security.

Although we will endeavor to safeguard the confidentiality of your personally identifiable information however, transmissions made by means of the internet cannot be made absolutely secure. By using this Website, you agree that we will have no liability (whether direct, indirect, consequential or incidental) for disclosure of your information due to errors in transmission or unauthorized acts of third parties. You also undertake not to bring any suit, action or claim against us on grounds of such disclosure.

7. RETENTION OF PERSONAL DATA

The Company will retain Your Personal Data and information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data and information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or we are legally obligated to retain this data for longer time periods.

8. ACCESS AND CORRECTION OF PERSONAL DATA

In the event you wish to know what all personal information we have collected from you from the Website, you can apply to us in writing at dsfldpo@dsgroup.com. We will provide you with all the details that you have requested for, except for the information which we cannot inform you about due to any legal obligation/restriction.

If in the event, there is a change/correction needed in any of the information that you have provided to us, which may or may not affect the provision of our services on this Website, you can apply to us in writing for making the correction in that information. Please note that we rely on you with regard to the accuracy of the information shared on the Website and hence any correction required shall be applied for in a timely manner.

On receipt of such correction application, we will conduct an assessment to the extent required. If any additional information/evidence is required, you shall provide the same to us for further assessing your application. On completing the assessment, we will correct the information as applied for and notify you or in case we are of the opinion that such correction is not required, we will notify you of the same along with the reasons.

9. ACCURACY

Please note that we rely on you with regard to the accuracy of the information shared on the Website. You hereby represent to us that:

• The information you provide to us from time to time is and shall be authentic, correct, current and updated and you have all the rights, permissions and consents, as may be required, to provide such information to us.
• You are providing the information to us and our consequent storage, collection, usage, transfer, access or processing of the same shall not be in violation of any applicable laws, third party agreement, judgments, orders and court decrees.

We and each of our representatives, officers, directors, contractors and agents shall not be responsible for the authenticity of the information that you provide to us. You shall indemnify and hold us harmless and each of our officers, directors, contractors, agents or any third party relying on the information provided by you in the event:-(i) you are in breach of this policy including this provision and the immediately preceding provision; and (ii) any suit, action or claim is brought against us by any third party with respect to the information provided by you to us.

10. CONSENT AND WITHDRAWAL

By using the Website and/or by providing us your information, you give the consent to collect, handle, process and use of the information you disclose on the Website in accordance with this Policy, including but not limited to your consent for sharing your information as per this Policy.

If any stage, you wish to withdraw your consent, you need to send a written request regarding the same to the Data Protection Officer and to the extent applicable, state the reasons behind such withdrawal. On receipt of your application, we will provide you with the response on the same at the earliest after conducting an assessment if required. Please note that from the date your withdrawal application is accepted by us and notified to you, you will no longer be able to access the Services provided via the Website. Post the same, we will not be processing your information, unless we have any other legal basis to do so.

11. EMAIL / SMS OPT-OUT

You can opt out of receiving our marketing/promotional emails. To stop receiving our promotional emails, please send us an e-mail with subject STOP to: laderach.care@dsgroup.com. To opt in, you will need to e-mail with subject: START to: laderach.care@dsgroup.com. It may take up to 7 working days to process your request. Even if you opt out of getting marketing messages, you will receive your transactional messages through email and SMS about your transactions.

12. LINKS TO OTHER WEBSITES

Our Service may facilitate you to link to other websites, for your convenience, transactions and/or other services, which are not within our control. When we do this, we will try and make it as clear as possible that you are leaving our Website. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility and liability for the content, privacy policies or practices of any third party sites or services. Once you have left our Website or is again redirected by third party on this Website, we shall not be responsible for the protection and privacy of any information for the period of absence from our Website and for the information which you provide to any third party websites. You should exercise caution and look at the privacy statement applicable to the website in question.

13. CHANGES AND UPDATES TO PRIVACY POLICY

We may update our Privacy Policy from time to time at our sole discretion. We will notify you of any changes by posting the new Privacy Policy on our Website. We will let you know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the bottom of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on the Website.

14. JURISDICTION

If you choose to visit the Website, your visit and any dispute over privacy arising from your visit to our Website, is subject to this Policy and the Website's terms of use. In addition to the foregoing, any disputes arising under this Policy shall be governed by the Laws of India and shall be under exclusive jurisdiction of the Courts located at New Delhi.

15. GRIEVANCE OR DATA PROTECTION OFFICER

If you choose to visit the Website, your visit and any dispute over privacy arising from your visit to our Website, is subject to this Policy and the Website's terms of use. In case you have any discrepancy or grievances with regard to our processing of information provided by, or any questions regarding this Policy, you may contact the Grievance or Data Protection Officer as identified below:

Mr. Balwant Singh
Deputy General Manager
Address: C-6-10, D.S. Road,
Sector-67, Noida-201309 (U.P)
e-mail : dsfldpo@dsgroup.com

**THIS POLICY WAS LAST UPDATED ON 9.1.2023**