PRIVACY POLICY
This privacy policy (“Policy”) was last changed on January 05, 2019. We may
occasionally make changes to the Policy. If we do, we shall notify either by sending
you an e-mail or sending you a notification through our mobile application (“App”).
Please make sure to read such notices carefully.
We hold the sincere belief that you should always know what data we collect from you,
the purposes for which such data is used, and that you should have the ability to make
informed decisions about what data you want to share with us.
This is why we want to be fully transparent about: (i) how and why we collect, store,
share and use your personal data through the various capacities in which you interact
with us; and (ii) the rights that you have to determine the parameters of this interaction.
While we would strongly advise you to read the Policy in full, the following summary
will give you a snapshot of the salient points covered herein:
This Policy details the critical aspects governing your personal data relationship
with ‘VLCC’ which is owned and operated by VLCC Wellness Private Limited,
a company incorporated under the laws of India, and having its registered
office at No. 30, 80 Feet Road, HAL 3rd Stage, Indiranagar, Bangalore- 560
075, Karnataka, India;
Your personal data relationship with VLCC varies based on the capacity in
which you interact with us/avail of our products and services (“Services”).
You could be: (i) a visitor to https://www.VLCC.com (“Website”) or any pages
thereof (“Visitor”); or (ii) a person who has an account with VLCC to avail our
Services (“Registered User”);
Based on whether you are a Visitor or Registered User, the type of data we
collect and the purpose for which we use it will differ and this Policy details
such variations;
This Policy applies to all the Services provided by VLCC through the Website,
App or any other associated website of VLCC;
This Policy is a part of and should be read in conjunction with our Terms of
Service; and
This Policy will clarify the rights available to you vis-à-vis the personal data you
share with us.
If you have any queries or concerns with this Policy, please contact our Grievance
Officer. If you do not agree with the Policy, we would advise you to not visit/use the
Website or the App.
1. INFORMATION WE COLLECT AND HOW WE USE IT
TYPE OF
USER
VISITOR
REGISTERED USER
WHAT
DATA WE
MAY
COLLECT
1. Your IP Address;
2. Your location;
3. How you behave on the
Website, (what pages
you land on, how much
time you spend, etc.);
4. What device you use to
access the Website and
its details (model,
operating system, etc.);
and
5. Cookies and web
beacon data.
1. Your name, age, gender, phone
number, e-mail address, mailing
address;
2. Your height, weight;
3. Your lifestyle, food
preferences, medical conditions
(if any), health goals or other
fitness regimes;
4. Your ethnicity, genetics, health
or sexual orientation;
5. Username or other relevant
unique identifier;
6. How you behave on the
Website, (what pages you land
on, how much time you spend,
etc.);
7. Credit card/debit card/other
payment mode information to
facilitate payments for our
Services;
8. Your IP Address;
9. Your location unless you
deactivate location services in
the relevant section of the
Website/App;
10. How you behave in the relevant
product environment and use
the features;
11. What device you use to access
the Website/App and its details
(model, operating system, etc.);
and
12. Cookies and web beacon data.
13. Steps data for calculation of
your calorie burn.
TYPE OF
USER
VISITOR
REGISTERED USER
HOW AND
WHY WE
USE IT
We use this information to
analyse and identify your
behaviour and enhance the
interactions you have with the
Website.
If you submit your details and
give us your consent, we may use
your data to send you e-
mails/newsletters, re-target
VLCC advertisements or re-
market our Services using
services from third-parties like
Facebook and Google.
We collect this data in order to help you
register for and facilitate provision of our
Services.
We use this data to show age appropriate
content and advertisements.
We use this data to track your nutrition,
weight and fitness regimes.
We use the data from the device you
access our Website/App to identify the
login information of multiple users from
the same device.
We use this data to prepare a specific diet
plan and training regime for you.
We use this data to enable you to make
payments for our Services. We use a third-
party service provider to manage payment
processing. This service provider is not
permitted to store, retain, or use
information you provide except for the
sole purpose of payment processing on
our behalf
We use this data for processing your
requests, enquiries and complaints,
customer services and related activities.
We use this data to communicate about
existing or new offers, content,
advertisements, surveys, key policies or
other administrative information.
We also use this data to provide you with
informative features and services that are
developed by us from time to time.
We also use this data for providing,
testing, improving, or recommending the
Services.
We also use this data for analytics and
reviews to improve the Services.
TYPE OF
USER
VISITOR
REGISTERED USER
We also use this data to provide support
to law enforcement agencies or in
connection with an investigation on
matters related to public safety, as
permitted by law or anti-fraud
activities/systems.
If you give us your consent, we may send
you newsletters and emails to market
other products and services we may
provide.
SPECIAL CATEGORIES OF PERSONAL DATA
We may collect and process ‘special categories of personal data’ such as ethnic origin,
genetics, health or sexual orientation, which are considered sensitive. We use this
special category of personal data, for example to provide specialized diet plan and
exercise routines. We require your explicit consent to collect and process special
categories of personal data. You may refuse or revoke your consent at any time,
please see the section about 'Your Rights & Preferences As A Data Subject In The
EU' below. A limited number of our personnel will have access to special categories
of personal data provided by you.
WHAT ARE THE COOKIES AND WEB BEACONS REFERRED TO ABOVE?
TYPE
OF
FILE
COOKIES
WEB BEACON
WHAT
THEY
DO
Cookies are text files which
are sent from our server and
downloaded to your device
when you visit our Website.
They are useful because
they allow us to recognize
your device when you
return. You can disable
them through your browser
should you so wish.
We use cookies to see
which parts of our Website
are used by Registered
Users/Visitors and to record
Web beacon (also known as Clear GIF, Web Bugs or
Pixel Tag) is a tiny picture file embedded on the
Website/App that tracks your behaviour and
navigation. It is similar to a cookie in what it does,
but it does not get downloaded on to your device.
We use web beacons to manage cookies, record
visits, and to learn marketing metrics. We also use
web beacons to track and monitor email opening
rates as well as link clicks.
You can find more information about web beacons
at:http://www.allaboutcookies.org/faqs/beacons.htm
l
TYPE
OF
FILE
COOKIES
WEB BEACON
the number of visits to our
Website.
You can find more
information about cookies
at:www.allaboutcookies.or
g
WHAT
THEY
WON’
T DO
Contain any executable software, malicious code or virus.
Usually, browsers have default setting to accept cookies until you change your
browser settings. You can choose to reject and remove cookies from our Website by
changing your browser settings. If you reject or remove our cookies, it could affect how
our Website works.
FOR THE AVOIDANCE OF ANY DOUBT, WE SHOULD CLARIFY THAT IN THE
EVENT WE ANONYMIZE AND AGGREGATE INFORMATION COLLECTED FROM
YOU, WE WILL BE ENTITLED TO USE SUCH ANONYMIZED DATA FREELY,
WITHOUT ANY RESTRICTIONS OTHER THAN THOSE SET OUT UNDER
APPLICABLE LAW.
2. YOUR RIGHTS & PREFERENCES AS A DATA SUBJECT IN
THE EU
It might have come to your attention that a new law was passed in the European Union
(EU) called the General Data Protection Regulation (GDPR). The GDPR gives certain
rights to individuals who are EU data subjects, in relation to their personal data.
Subject to the GDPR and applicable law’s limitations, the rights afforded to you if you
are an EU data subject are:
RIGHT OF ACCESS
You have a right to access the personal data
you have provided by requesting us to provide
you with the same.
RIGHT TO ERASURE
You have a right to request us to delete your
personal data.
RIGHT TO OBJECT
You have a right, at any time, to object to our
processing of your personal data under certain
circumstances. You have an absolute right to
object to us processing your personal data for
the purposes of direct marketing.
RIGHT NOT TO BE SUBJECT TO
AUTOMATED DECISION-MAKING
You have a right to not be subject to a decision
based solely on automated decision making,
including profiling.
In case you want to exercise the rights set out above you can contact our Grievance
Officer whose details are set out in Section 13 below.
The data provided by you as a Visitor, or when you sign up as a Registered User for
our Services will be processed by us for the purpose of rendering Services to you or
in order to take steps prior to rendering such Services, at your request. Where such
data is not being used by us to render Services to you, we shall explicitly seek your
consent for using the same.