This Privacy Policy describes how www.curryfreezy.com (the “Site” or “we”) collects, uses, and discloses your Personal Information when you visit or make a purchase from the Site.

HOW WE USE YOUR INFORMATION

The sections below outline what we use your information for, why we do it and what allows us to do so legally:

WHEN YOU VISIT OUR WEBSITE OR CONTACT US DIRECTLY, WE COLLECT THE FOLLOWING INFORMATION:

• Contact information and personal identifiers, such as your name, address, email address, telephone number, and username or social media handle.
• We’ll also record your IP address if you contact us by Website chat and your social media account information when you contact us through our social media channels.
• Device identifiers, such as information about your device like your MAC address, IP address, or other online identifiers.
• Demographic information, such as your age, sex, and gender (some of which may be protected by applicable law).
• Physical characteristics, such as your hair type and colour, skin type, and eye colour.
• Commercial information, such as the products or services you have purchased, returned or considered, and your product preferences.
• Payment information, such as your method of payment and payment card information (including payment card number, expiration date, delivery address and billing address).
• Identity verification information, such as account and other authentication information (like passwords).
• Online or network activity information, such as information regarding your interaction with our Website, digital properties, and advertisements, information about your browsing and search history on our Website and log file information which includes, but may not be limited to, your browser type, webpages you visit, and other electronic network activity.
• Audio and visual information, such as recordings of your voice when you call our customer service and when using our Virtual Consultation.
• Health and medical information, such as skincare concerns, diagnoses, and history, (if you choose to volunteer this information during our Virtual Consultation process), however we do not keep a record of this information. We only retain your contact details and consultation topic.
• Professional or employment-related information, such as information from your resume, employment history, education information, and professional licenses or certifications.
• User Content, such as your communications with us and any other content you provide (including photographs and images, videos, reviews, articles, survey responses and comments).
• Inferences drawn from or created based on any of the information identified above.

What we do	What we do it	Why we can do it (legally)
Deliver items to your address	Ensure that you receive the items you have paid for.	When you buy something from us you enter into a contract of sale. We need your personal details to fulfil this contract.
Process your payment information	To ensure we get paid for the items you buy; to be able to give you a refund when you return something.	We need this information to fulfill our sales contract with you.
Allow you to register an account with us	To save your preferences and make it easier for you to shop with us.	It’s important for us as a business to make your shopping experience as easy as possible.
Manage cookies on our Website	We use cookies to improve the experience of visitors to our Website, analyse site usage, and assist in our marketing efforts.	We ask for your consent to use cookies.
Respond to queries and complaints	We want to ensure that we give you the best possible service.	It is important to us as a business that you get the best experience.
Review your previous orders	To help us respond to queries and complaints.	It is important to us as a business that you get the best experience.
Receive accident and incident reports	To investigate accidents and incidents and keep a record of them.	It is important to us as a business that we do this.
Respond to Data Subject Rights Requests	Your data protection rights are important to us and we want to help you execute them.	We have a legal obligation to do this.
Record your details when you contact us on social media	To help provide assistance in securing an item or service or when you are unhappy with our products/services	It is important for us as a business to do this.
Customer address mapping and location analysis (using data from 3rd Party)	So that we can see which stores are located closest to our customers and to understand shopping patterns.	It is important for us as a business to do this.
Customer Analysis	To reward customer loyalty, to analyse the business performance and to improve customer satisfaction.	It is important for us as a business to do this.
Customer Consent Management	To ensure our records are up to date with your consent preferences	It is important for us as a business to do this.
Email, Direct Mail and SMS Marketing	To inform our subscribers about CURRYFREEZY, our promotions and new services.;	We get your consent to send you marketing information.
Analyse Website browsing behaviour and ad effectiveness, including on 3rd Party websites.	To show you more relevant ads and to measure how well our advertising campaigns are working.	It is important for us as a business to do this.
Run social media competitions	To raise brand awareness.	It is important to us as a business to raise our brand awareness.
Social media analysis	To improve the product recommendations we give you and to help when you are unhappy with our products / services.	We ask for your consent to use your information for marketing and/or sentiment analysis.
Investigate complaints and handle legal and insurance claims	To resolve your complaint, ensure the same complaint doesn’t arise again, to provide legal advice and to protect ourselves against fraudulent claims.	We have a legal obligation to do this and it is important to us as a business to do it.

FOR MARKETING AND CUSTOMER INSIGHT PURPOSES

We use your information for customer insight and marketing purposes. In some cases we will purchase information from 3rd Parties, but this usually aggregated data and does not normally directly identify you. We will also keep a record of your social media account name and information you make available to us via your social media account settings when you connect your social media account to ours, by messaging us, liking or following a page, tagging us in post or commenting on our posts.

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example:

• We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

You can opt out of targeted advertising by:

[INCLUDE OPT-OUT LINKS FROM WHICHEVER SERVICES BEING USED. COMMON LINKS INCLUDE:

·  FACEBOOK – https://www.facebook.com/settings/?tab=ads

·  GOOGLE – https://www.google.com/settings/ads/anonymous

· BING – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads]

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: https://optout.aboutads.info/.

Personalising your digital experience

Sometimes, we use your personal data such as your browsing history, username and purchases to personalise our Websites, online media and communications so they’re more relevant to you, giving you a better online experience. We do this through our use of Cookies and, where appropriate, information we have gathered about you from other interactions (e.g. products you buy or browse, or links that you have clicked on) or other sources (e.g. CURRYFREEZY Membership). For example, we may greet you by name, show search results that reflect things most likely to be of interest to you and show you content that’s more relevant to you and the things you have previously shown an interest in.

Personalisation, can I opt out and how do I do it?

Yes, but we believe it’ll result in your online experience being less personal and relevant to you. The content and search results you see will be generic rather than related to your interests. Personalising your online experience doesn’t affect the marketing options you have selected, it’s to offer you a service personalised to your needs. If you have an account, you can email the contact details given below with your request. If you’re not a registered customer, information held in our Cookies may be used to select content that we feel is more relevant for you. To prevent this, you can clear your cookies.

Where we process information on the basis that it is important for us as a business to do it, we will consider your interests also. We will weigh up our business interests with your interests to ensure they are fairly balanced. You can contact us for further information on this.

HOW WE SECURE YOUR INFORMATION

We take great care to ensure the security of our Websites and your personal information. To ensure that we keep your information secure we use technical security measures such as encryption, access controls, firewalls and logging, and organisational security controls such as security policies and procedures, awareness training for employees and 3rd party vendor assessments.

To take full advantage of all security features you should use an up-to-date browser. To further ensure your personal information is safe, please note, we will never ask a customer to confirm any debit or credit card details via email.

WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

• We may share your information internally within the CIRCE CARE group, including other brands owned by CIRCE CARE, on a need to know basis when required for our business to function.
• We may share your information externally with our core service providers when required for our business to function. These include for example companies who help us provide our Websites, pick and pack orders, make deliveries, print materials or provide customer support services.
• In connection with a sale or business transaction. If we decide to sell, buy, merge or otherwise reorganise our businesses in certain countries, this may involve us disclosing personal data to prospective or actual purchasers and their advisers, or receiving personal data from sellers and their advisers.
• We may need to share personal data in order to protect ourselves against fraudulent claims and to manage insurance and legal claims.
• We may need to share personal data to support our IT system providers to keep our systems secure. Each of the external companies we work with has been selected by us for their ability to provide what we need to our required specification, including their ability to handle sensitive data (like your personal information) securely and appropriately.
• We may need to share personal data when we receive requests for information from government departments, the police and other enforcement agencies. If this happens, and there is a proper legal basis for providing your personal information, we will provide it to the organisation asking for it.
• We may share your information with other partners when we have your consent to do so.

LAWFUL BASIS

Pursuant to the General Data Protection Regulation (“GDPR”), if you are a resident of the European Economic Area (“EEA”), we process your personal information under the following lawful bases:

• Your consent;
• The performance of the contract between you and the Site;
• Compliance with our legal obligations;
• To protect your vital interests;
• To perform a task carried out in the public interest;
• For our legitimate interests, which do not override your fundamental rights and freedoms.

Retention

When you place an order through the Site, we will retain your Personal Information for our records unless and until you ask us to erase this information. For more information on your right of erasure, please see the ‘Your rights’ section below.

Automatic decision-making

If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.

We do not engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.

Services that include elements of automated decision-making include:

• Temporary blacklist of IP addresses associated with repeated failed transactions. This blacklist persists for a small number of hours.
• Temporary blacklist of credit cards associated with blacklisted IP addresses. This blacklist persists for a small number of days.

Your rights

YOUR RIGHTS

• You can ask us for a copy of the personal information we hold about you.
• You can ask us about how we collect, share and use your personal information.
• You can ask us to update and correct your personal details.
• You can request that we restrict processing of your personal data in certain circumstances.
• You can object to processing that is carried out where we have decided that it is important for us as a business (legitimate interests).
• In certain circumstances, you may ask us to delete your personal information.
• You have a right to move your information (your right to Portability). Where you have provided information in a structured, commonly used and machine readable format we can share a digital copy of your information directly with you or another organisation.
• You can object to any automated decision making, including profiling, where the decision has a legal or significant impact on you.
• You have a right to request access to your personal information.
• You can change your mind wherever you give us your consent and withdraw that consent, such as for direct marketing. You can exercise any of these rights by filling out a request in our Privacy Portal or by contacting our Privacy Manager in writing by email or post using the details outlined below. When you contact us to ask about your information, we may ask you to identify yourself. This is to help protect your information.

Our email is [email protected]

GDPR

If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information above. 

CCPA

If you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the ‘Right to Know’), to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information above. 

If you would like to designate an authorized agent to submit these requests on your behalf, please contact us at the address below.

HOW LONG DO WE KEEP YOUR INFORMATION FOR?

• We keep personal data for a variety of purposes and for a variety of time periods. The general guidelines for how long we keep personal data are based on what is necessary and proportionate in our business, taking into consideration how and why we collected it and with particular reference to legal obligations that apply to our business.
• Where there is no legally defined time period for keeping data, we will keep your information for a time period based on relevant industry standards.
• Where there is no relevant industry standard, we will use a time limit that allows us to serve you as customers but also ensures we don’t keep your personal information for longer than we need to.
• In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for regulatory or statistical purposes in which case we may use this information indefinitely without further notice to you.
• All personal data will be kept in line with our retention policy.

LINKS TO THIRD PARTY SITES

From time to time we may provide links to other sites. This privacy Notice only covers our Website and any website that we own and control. It does not cover links to other sites nor information collected by parties that own and control those sites or their use of cookies when you visit another site. This notice does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any Website or service to which our services link. The inclusion of a link on our services sites does not imply endorsement of the linked site or service by us or by our affiliates. In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organisations, such as Facebook, Apple, Google, Microsoft, RIM, or any other application developer, application provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any personal data you disclose to other organisations through or in connection with the applications or our social media pages.

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Do Not Track

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

Changes

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.

Contact

After reviewing this policy, if you have additional questions, want more information about our privacy practices, or would like to make a complaint, please contact us by e-mail at [email protected] or [email protected] or by mail using the details provided below:

CIRCE CARE, VP WARD, PO THANA, KANNUR, KERALA- 670012

CIRCE Group FZC LLC, PO BOX 222297, AlAin, AbuDhabi, UAE

Complaints

As noted above, if you would like to make a complaint, please contact us by e-mail or by mail using the details provided under “Contact” above.

If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority. You can contact your local data protection authority.