Privacy Policy – Wenger

Snaphire IT Services (“We” or “Us” or “Our”) operates www.wenger.co.in and respects the privacy concerns of our website users and customers and has established this Privacy Policy to explain how we collect, use, and protect your information. This Privacy Policy applies only to communications in India for the website located at www.wenger.co.in (the “Website“ or “site“).

 

Our Commitment to Privacy& Personally Identifiable Information

We collect personally identifiable information only when voluntarily provided by you, such as through account registration, product purchases, or social media integration. This information may include your name, email, address, phone number, date of birth, payment details, and other contact information. Content shared publicly may be visible to others and is beyond the scope of our privacy safeguards.

 

Non-Personally Identifiable Information

We may automatically collect non-personally identifiable information such as browser type, usage patterns, and other analytics. These are used to optimize website performance and user experience.

 

Cookies

We use cookies and similar technologies to collect session data, customize content, and track website usage. You may manage cookies through your browser settings, though disabling them might limit certain functionalities.

 

Tracking Links and Clickstream Data

We monitor link activity and clickstream patterns to understand user behavior and personalize our offerings. This data is collected anonymously unless otherwise stated.

 

Interest-Based Advertising

We or our partners may use non-personally identifiable data for tailored advertising on this or other websites. This includes behavioral advertising using anonymous data.

Governing Law and Jurisdiction

We follow industry-standard encryption practices to safeguard your data. Despite our best efforts, no online transmission is 100% secure. Use of the Website is governed by the laws of India and subject to the jurisdiction of the courts in Mumbai.

 

Protection for Children

We do not knowingly collect data from individuals under 18. If such data is inadvertently collected, we will delete it promptly.

 

Changes to this Privacy Policy

We reserve the right to amend this policy at any time. Material changes will be posted, and where required, your consent will be sought.

 

Data Retention

We retain information as long as necessary for business or legal reasons, and continue to use anonymized data for analytical purposes.

 

Opt-Out Process

You may manage your cookie preferences via your browser. Email communication preferences can be changed via unsubscribe links provided.

 

Links to Third-Party Sites andSocial Media Platforms

We are not responsible for the privacy practices of third-party sites linked through our Website. Interactions on social media platforms are governed by those platforms’ respective policies.

 

Information Storage

Our servers are located in India. We will ensure compliance with the data protection laws in force at the time in the event we undertake any cross border transfer of personal data in our possession.

 

Addressing Questions, Concerns and Complaints

For any questions or requests regarding your personal information, you may contact:

Name:  Mr. Sanjeev Kumar
Email: orders@cloud9retail.com
Address:  Snaphire IT Services,
A-54 Scheme No. 78,
New Loha Mandi,Indore,
Madhya Pradesh – 452014

 

Your Rights

You may instruct us to provide you with any personal data we hold about you. Please note that provision of such information will be subject to the supply of appropriate evidence (as deemed by us) of your identity. Additionally, you have the right to:

• a grievance redressal mechanism and access to a data protection officer for complaints against our treatment of your personal data for the exercise of your rights;
• to nominate any other individual who, in case of your death or incapacity, can exercise your rights when dealing with us;
• provide, review, withdraw, or manage consent that is given to the individual through a consent manager;
• withdraw consent with ease comparable to the ease with which the consent to process the personal data was given to us;
• make a request to us for the completion of any incomplete personal data in addition to the right to update, correct, and erase your personal data as provided under this privacy policy; and

have every request for consent made to you by us accompanied by a notice informing you that you have a right to withdraw consent, and such notice shall also provide for the manner in which you may make a complaint to the data protection board.

 

Personal Data Breach

In the event of a personal data breach that is likely to cause harm to you, we committed to complying with all the applicable laws. As soon as we gain knowledge of a personal data breach, we will undertake the following steps:

• without delay, notify the affected users of the personal data breach of the following information through their registered communication channels about the nature of the breach, the type of data involved, potential consequences, and measures being taken by us to address the breach and mitigate potential harm.
• notify the data protection board about a description of the personal data breach, which will include its nature, extent, timing and location of occurrence alongside the impact it will likely have.
• within 72 (seventy-two) hours of the personal data breach, we will provide the data protection board a report with the following information:
  • (a) updates details and information about the personal data breach;
  • (b) the broad facts, reasons and circumstances about the personal data breach;
  • (c) risk mitigation measure undertaken to contain the personal data breach;
  • (d) findings about the person who may have caused the personal data breach;
  • (e) measures undertaken to avoid such a situation in the future; and
  • (f) a report regarding the updates and information provided to the users of www.wenger.co.in

 

Disclosure of Personal Data

We may disclose your personal data to any person, insofar as reasonably necessary for the purposes set out in this Privacy Policy.

 

In addition, we may disclose your personal information:

In the course of day-to-day business operations, we may, from time to time, utilize and/or transfer personal data for various purposes. These transfers of personal data are necessary in order to carry out our internal management purposes as mentioned hereinabove of this Privacy Policy or for the purposes mentioned hereinbelow:

• For the performance by the government or any of its instrumentalities of any function under any law for the time being in force in India or in the interest of sovereignty, security, or integrity of India.
• Fulfilling any obligation under any law for the time being in force in India on any person to disclose any information to the government or any of its instrumentalities, subject to such processing, is in accordance with the provisions regarding disclosure of such information in any other law for the time being in force.
• For compliance with any judgment, decree, or order issued under any law for the time being in force in India or any judgment or order relating to claims of a contractual or civil nature under any law for the time being in force outside India.
• For responding to a medical emergency involving a threat to the life or immediate threat to the individual providing the personal data or any other individual’s health.
• For taking measures to provide medical treatment or health services to the individual providing the personal data or any other person during an epidemic, outbreak of disease, or any other threat to public health.
• For taking measures to ensure the safety of or to provide assistance or services to the individual providing the personal data or any other person during any disaster, or any breakdown of public order.

To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal data where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal data.

 

Post-account closure/termination:

• Upon closure or termination of your account, or upon your valid request for erasure, we will securely delete or effectively anonymise your personal data in accordance with our retention schedules and applicable law. The process for deletion will involve secure removal from relevant database tables.
• Some data may be retained in an aggregated and anonymised form for research, analytics, and service improvement purposes, where it can no longer be used to identify you.
• We may also retain certain information if necessary to comply with our legal obligations, resolve disputes, prevent fraud, or enforce our agreements.

When personal data is no longer needed, it will be securely disposed of using methods that prevent its recovery or misuse.

 

Consent and Withdrawal of Consent:

• You may choose not to have your personal data transferred. You must communicate your desire to withdraw your consent as outlined below. If you exercise your right to withdraw your consent, you will be informed of the impact such withdrawal may have on your rights and interests.
• Your consent shall be free, specific, informed, unconditional, and unambiguous, with clear affirmative action, and shall signify an agreement to the processing of your personal data for the purpose mentioned in this Privacy Policy and the processing will be limited to such personal data as is necessary for such purpose.
• Any part of consent that constitutes an infringement of the provisions of any law for the time being in force shall be invalid to the extent of such infringement.
• Every request for consent shall be presented to you in clear and plain language, giving you the option to access such request in English or any of the 22 languages listed in the Eighth Schedule to the Constitution of India and providing the contact details of a data protection officer, where applicable, or of any other person authorized by us to respond to any communication from you for the purpose of exercising your rights.
• Where your consent is the basis of the processing of personal data, you shall have the right to withdraw your consent at any time, with the ease of doing so being comparable to the ease with which such consent was given.
• The consequences of the withdrawal shall be your liability, and your withdrawal of consent shall not affect the legality of the processing of the personal data based on consent before its withdrawal.

 

Use of Personal Data:

We may use your personal data to perform the following functions and obligations with your explicit consent, where applicable:

• for user registration, account creation, identity verification, and ongoing account management, we process your identity and contact and account data;
• to process your subscription payments, manage renewals, manage cancellations, process eligible refunds, address billing inquiries, and handle other financial transactions related to the services;
• to conduct internal research and statistical analysis to evaluate and enhance program effectiveness, develop new services, or contribute to general wellness knowledge;
• to comply with applicable Indian laws, regulations, court orders, summons, or other legal processes and government requests;
• to protect our and our licensors and supplier’s rights, property, or safety of or the public, as required or permitted by law;
• to detect, prevent, investigate and address fraud, security breaches, unauthorised access, or misuse of the services; and
• to enforce our Terms and Conditions and other policies.