PRIVACY POLICY
1. Introduction
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Thank you for choosing Pinwheels Accessories
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This document, i.e., Privacy Policy (“Policy”) contains the manner and details in which PINWHEELS ACCESSORIES, that owns and controls the brand known as ‘Pinwheels Accessories’ (“we”, “us”, “our”) collects and processes the data that you, the user (“user”, “you”, “your”) of this platform www.pinwheels.in (“Website”) provided to us. Pinwheels Accessories is having its registered address at A-1, Navroze Mansion, 1st Floor, Above Amar Restaurant, Opp Bhatia hospital, Tardeo, Mumbai 400007.
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As you may have noticed, we collect and process your data in the course of providing our Services through the Website, which among other things, allows us to offer you a seamless transaction experience with us.
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We understand that the data that we may collect in the course of providing you our Services, may contain information that is personal in nature. Since we value the privacy and security of your personal information as much as you do, we would like you to understand the exact nature of the personal data that we collect from you and how we collect it, how we store it, how we use it, and whom we share it with.
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Additionally, please also read our Terms of Use for the Website here. This Policy and the Terms of Use are to be read in consonance and form part of a single understanding. Any capitalised terms not defined herein shall be interpreted to mean as defined in the Terms of Use.
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2. What Is The Aim Of This Policy?
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Broadly, this Policy governs the manner in which we handle all personal data provided by you while using the Website.
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Specifically, this Policy aims to achieve the following:
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Help you understand the exact nature of the personal data that we collect;
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Explain why we collect and what we do with the personal data that you share with us to help us create your personal freedom journey;
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Explain to you, your rights in relation to what personal data we use and how we can use it.
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We may change the terms of this Policy from time to time. The date at the top of the Policy shall reflect the date on which the Policy was last revised. In the event that there are material changes to the Policy, we may send you additional notice by way of an e-mail or a notification on the Website.
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Should you have any questions or concerns in relation to this Policy, you are always welcome to contact us by writing to us at pinwheels001@gmail.com and we’ll endeavour to do our best to address them.
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Alternatively, while we aim to be completely transparent in the manner we choose to protect your privacy, you may not agree with the terms of this Policy. Should this be the case, please remember it is your choice whether you wish to continue using our Services and Website.
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3. Information That We Collect From You On The Website
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Type of user data
Name
Phone Number
E-mail ID
Gender
Age
Password
Location
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Legal basis for collecting and processing this data
Performance of a contract in the case of name and location, e-mail ID, and password.
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When do we collect this data?
We ask you for this information when you –1 ) register on the Website by making an account using the “Sign Up” feature; or2 ) enter these details when checking out using the “Continue as a Guest” feature.
The above list of data being collected is a non-exhaustive list and we may require you to share further information from time to time for which we will notify you.
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4. Information That Is Generated By You While Using The Website
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Type of usage data
Data and inferred data about how you interact with the Website including but not limited to the products you show interest in, your search queries, the text and content you input the Website, the location from where you access the Website.
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Legal basis for collecting and processing this data
Performance of a contract in relation to the information you choose to post since this is part of the contracted service. You can choose what you make public.
Legitimate interests in relation to inferences about your interests which we use in our business to tailor and improve the Services. Where cookies are used for such processing (as explained below), we obtain prior consent where required under applicable laws.
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When do we collect this data?
The information related to your usage of the Website is collected automatically and in a dynamic manner as and when you use the Website.
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5. Technical Information Collected By Us Through Your Use Of The Website
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Type of data
Information about the types of devices you are using such as unique device IDs, network connection type; provider, network and device performance browser type; information enabling digital rights management; operating system, and the version of the Website.
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Legal basis for collecting and processing this data
Legitimate interests in managing and improving our Services and protecting our content.
When do we collect this data?
Technical information is collected automatically and in a dynamic manner as and when you use the Website.
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6. Why We Collect and Process Personal Data and How We Use It
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To fulfil buying and selling requests on the Website.
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To conduct business planning and forecasting.
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To enable us to diagnose and identify any technical advancements or troubleshoot issues.
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For marketing, promotional, and advertising purposes.
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To answer your questions or requests for information or handle your complaints.
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To ensure that content provided regarding our Services is presented in the most effective manner for you and for your computer or other devices.
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To notify you about updates or changes to our Services or Website features and content.
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To provide you with promotional communications, to the extent that you have provided consent to receive such communications under applicable law.
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To serve our advertisements to you through third-party platforms, including Facebook, Google, and e-mail service providers.
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To comply with legal obligations and requests by law enforcement.
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To establish, exercise, or defend legal claims.
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Inferences drawn from your browsing patterns help us understand your preferences better, thereby allowing us to offer a more focused range of products and optimise our Services.
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Inferences drawn from how you interact with the Website allow us to constantly identify what we could do better to help our users.
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To detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Pinwheels Accessories.
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7. Analytics Technologies
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Tracking Technologies
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1. Pinwheels Accessories and our analytics partners use tracking technologies such as cookies, beacons, tags, and scripts.
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When you visit our Website, we may place a number of cookies in your browser. These are first-party cookies, which allow us to hold session information as you navigate within the Website. We use cookies on our Website to understand visitor and user preferences, improve their experience, and track and analyse usage, navigational, and other statistical information.
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2. Many jurisdictions require or recommend that website operators disclose the types of cookies they use and occasionally get consent from users before placing certain cookies. We may use any of the following categories of cookies on our Website as detailed below. Each cookie falls within one of these four categories:
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Type of Cookies & Description
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Essential Cookies - Essential cookies (first-party cookies) are sometimes called “strictly necessary” as without them we cannot provide many services that you need on the Website. For example, essential cookies help remember your preferences as you move around the Website.
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Analytics Cookies - These cookies track information about Website visits so we can make improvements and report our performance. For example, we analyse visitor and user behaviour to provide more relevant content or suggest certain activities. These cookies collect information about how visitors use the Website, which site the user came from, the number of each user’s visits, and how long a user stays on the Website. We might also use analytics cookies to test new ads, pages, or features to see how users react to them.
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Functionality or Preference Cookies - During your visit to the Website, these cookies are used to remember information you have entered or choices you make such as your username, language, or region. They also store your preferences when personalizing the Website to optimize your use of Freedom Guru, for example, your preferred language. These preferences are remembered through the use of the persistent cookies, and the next time you visit the Website you won’t have to set them again.
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Targeting or Advertising Cookies - These third-party cookies are placed by third-party advertising platforms or networks in order to deliver ads and track ad performance, enabling advertising networks to deliver ads that may be relevant to you based upon your activities (this is sometimes called behavioural, tracking, or targeted advertising) on the Website. They may subsequently use information about your visit to show you ads that you may be interested in our Website and other websites. For example, these cookies remember which browsers have visited the Website.
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3. You can control the use of cookies at the individual browser level. If you choose not to activate cookies or to later disable them, you can still visit our Website, but your ability to use some features may be limited.
4. Web beacons, tags, and scripts may be used on the Website or in e-mails to help us deliver cookies, count visits, understand usage and advertising campaign effectiveness, and determine whether an email has been opened and clicked on. We may receive reports based on the use of the aforesaid technologies by our service/analytics providers on an individual and aggregated basis.
5. We partner with third parties, such as Google Analytics and SendGrid, to manage the advertising of our brand on other sites or platforms as well as across other devices you use, based on your past visits to our Website. Our third-party partners may use tracking technologies to gather data about your activities on our Website to deliver such advertising to you, including retargeting ads.
6. We may use third-party trackers to let us know when users have visited the Website by “clicking-through” our sponsored advertising or content hosted on third-party platforms. The Website uses Google Analytics code to gather statistical data. Google Analytics sets cookies to help us accurately estimate the number of visitors on the Website and the volume of usage of the Website. This is done, inter alia, to ensure that the Website is available and running efficiently even with maximum traffic.
7. In the event you seek to opt-out of this tracking, please write to us at pinwheels001@gmail.com. Please note that this does not opt you out of being served advertisements. You may continue to receive generic ads on these third-party platforms. You may also opt-out of receiving advertisements across devices by adjusting your ad preference in your relevant device account, Google account, or Apple account.
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Log Files
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As is true of most websites, we gather certain data and automatically store it in log files. This data may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. These and the open statistics are used in aggregate form to give us an indication of the popularity of the content and to help us make decisions about future content and formatting.
Social Media Widgets
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Our Website includes social media features, such as the Facebook Like button, and widgets, such as the “Share This” button or interactive mini-programs. These features may collect your IP address, which page you are visiting on the Website, and may set a cookie to enable the feature to function properly. Your interactions with third-party features are governed by the privacy statement of the company providing it.
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8. Sensitive Data
As per the Information Technology (Reasonable Security Practice) Rules, 2011, a certain category of user’s data is classified as “sensitive personal data”. For the sake of clarity, we have provided a table enlisting the type of data considered to be sensitive personal data and information as to whether Pinwheels Accessories and/or its third-party associates process or collect such data on the Website.
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Password
Financial information including bank account or payment instrument details
Physical, physiological or mental health condition
Sexual orientation
Medical records and history
Biometric information
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We collect and process user’s passwords that are created by the user at the time of signing up. The passwords are stored and secured by us using high-end encryption.
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All financial information shared by the users is collected and processed by the payment aggregator associated with us, on the payments page. Pinwheels Accessories does not collect, process, or store user’s financial information on the Website.
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9. Your Rights over the Personal Data That You Share with Us
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The General Data Protection Regulation and other privacy laws across the world grant individual’s rights over their personal data. These rights allow you to control the personal data that we collect and the manner in which we use it.
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Your rights & Explanation
Right to confirmation and access - The right to be informed of, and request access to your personal data that is collected and processed by us.
Right to correction, rectification, and erasure - The right to request that any incomplete or inaccurate personal data provided be updated, corrected, or erased.
Right to restrict - The right to request that we temporarily or permanently stop processing all or some part of the personal data that you provide to us.
Right to object - The right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
The right to object to your personal data being processed for direct marketing purposes.
Right to data portability - The right to request a copy of your personal data in an electronic format and the right to have such personal data transferred or transmitted to a third-party service.
Right to not be subject to automated decision making - The right to not be subject to a decision based on automated decision-making based on the personal data that you share with us. This includes profiling, in the event that such profiling would have a legal effect on you or a similarly significant effect.
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In case of any requests or queries in relation to the above, please contact us at pinwheels001@gmail.com.
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9. Who Do We Share Your Data With?
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From time to time, we may share your personal data with third-parties such as:
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IT & Email Service Providers
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Law Enforcement Authorities
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Data Analytics Agencies
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Fraud Prevention Vendors
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Courier / Shipping Service Providers
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Social Media Partners
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Payment Processors
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Advertisers Partners
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Entities Seeking To Acquire Or Invest In Pinwheels Accessories
11. How Do We Protect Your Data?
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We implement appropriate technical and organisational measures to help protect the security of your personal data including pseudonymisation, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems. Your password protects your Account and therefore we recommend using a strong password that is unique to your Itara account.
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12. Retention and Deletion of Data
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Retention of data
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We collect and store your data for only as long as it is necessary for you to operate the Website. In addition to this, we may also retain your data for legitimate and essential business purposes, including but not limited to making data-driven business decisions, complying with legal obligations, and resolving any disputes that may arise from time to time.
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Deletion of data
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Unless legally allowed or legally mandated to store such data, upon receiving a request, we will delete all your personal data or anonymize it so that such data is no longer identifiable to you as an individual.
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13. Transfer of Data
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While Pinwheels Accessories is based in India, we may transfer your data to third-parties that are located in countries other than India or to the country you are accessing the Website from. Therefore, your personal data may be subject to privacy laws that are different from your country. For example, if you are based in the United States of America, your personal data may be processed by a third-party based outside the United States of America. In such an instance, please note that Pinwheels Accessories shall transfer your personal data in accordance with applicable privacy laws. However, please note that some of these countries may not provide equivalent levels of data protection as the country that you are accessing the Website.
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Whenever we transfer your personal data out of the United Kingdom (“UK”) or European Economic Area (“EEA”), we will ensure similar protection and, where transfers are made to countries that have not been found to provide an adequate level of protection for personal data, we will use specific approved contracts with our service providers that are based in countries outside the EEA. These contracts give your personal data the same protection it has in the EEA.
14. California Privacy Rights
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If you are a California resident, California law also provides you with specific rights regarding your personal information, including:
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The right to request to know more details about the categories and specific pieces of personal data we have collected about you; and
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The right to request deletion of your personal data; and
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The right to not be discriminated against for exercising these rights.
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Pinwheels Accessories does not “sell” the personal data we collect. In the event that we may sell the personal data that we collect in the future, we shall provide you notice and the opportunity to opt-out.
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California residents may make a rights request by emailing us at pinwheels001@gmail.com. You may designate, in writing or through a power of attorney, an authorised agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorised it to act on your behalf, and we may need you to verify your identity directly with us.
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15. Third-Party Links
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The Website may contain links to external websites owned and operated by third parties. Please note that when you use third-party services, their own terms of use and privacy policies will govern your use of those services. Pinwheels Accessories does not collect, process, or store any personal data provided by you to such third-party links, including the payment gateway, through the Website. Please check these policies before you submit any personal data to these external websites.
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16. Governing Law, Jurisdiction And Arbitration
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As provided in our Terms of Use
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17. Contact Us
If you have any questions regarding this Policy, please feel free to reach out to us by writing an email to pinwheels001@gmail.com