We process your data on the basis of the following:
• Your explicit consent for processing your data (as mentioned in Section 2 below), and for the purposes mentioned in Section 4 below;
• For the performance of contracts entered into by you for providing any of the Services; and
• Our legitimate interests, i.e. registering and administering accounts on our Services to provide you access to all content, updates and services you have purchased, and to facilitate the efficient running and operation of our business.

We collect certain data from you directly, like the information you enter yourself, your shipping details for online purchases, contact details for offline purchases. We also collect some data automatically, like information about your device and what parts of our Services you interact with or spend time using.

We use tools like cookies, web beacons, analytics services, and advertising providers to gather the data listed above. Some of these tools offer you the ability to opt out of data collection.

• 4.1 How we use your data:

• We use your data to do things like provide our Services, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our Services, analyse how people use our Services, serve personalised advertising, and as required by law or necessary for safety and integrity.
• We use the data we collect through your use of the Services to:
  - Provide and administer the Services, including to display customised content and facilitate communication with other users;
  - Process your requests for programs, plans, specific services, information, or features;
  - Communicate with you about your account by:
      Responding to your questions and concerns;
      Sending you administrative messages and information, including messages from health coaches, yoga instructors or ayurvedic        consultants, notifications about changes to our Service, and updates to our agreements;
      Sending you information and in-app messages about our services;
      Sending push notifications to your wireless device to provide updates and other relevant messages (which you can manage from        the “options” or “settings” page of the mobile app).
  - Manage your account preferences;
  - Facilitate the Services’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse;
  - Solicit feedback from users;
  - Market and administer surveys and promotions administered or sponsored by us;
  - Learn more about you by linking your data with additional data through third-party data providers or analysing the data with the help of analytics service providers;
  - Identify unique users across devices;
  - Tailor advertisements across devices;
  - Improve our Services and develop new products, services, and features;
  - Analyse trends and traffic, track purchases, and track usage data;
  - Advertise the Services on third-party websites and applications;
  - As required or permitted by law; or
  - As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Services.

• 4.2 Criterion For Determining Data Retention Period:
• It is not possible for us to determine a specific period for which we may retain your data. However, we will retain your data for longer than necessary, taking into account the following:

• The purpose(s) and use of your data, both now and in the future (such as whether it is necessary to continue to store that information in furtherance of our obligations under a contract with you, or to contact you in the future);
• Whether we have any legal obligation to continue processing your data (such as any record-keeping obligations imposed by any applicable law);
• Whether we have any further legal basis to continue processing your information (including your consent);
• Whether there is any relevant agreed industry practice on how long such data should be retained;
• The levels of risk and liability involved for us to continue holding the data;
• The amount of difficulty we may face to ensure the data can be kept updated and accurate; and
• Any other circumstances (such as the nature and status of our relationship with you).

• 5.1 We share certain data about you with our business partners, analytics and data enrichment providers, your social media providers, companies helping us run promotions and surveys, and advertising companies who help us promote our Services.  We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get your consent.

• 5.2 We may share your data with third parties under the following circumstances or as otherwise described in this Privacy Policy:

• With service providers, contractors, and agents: We share your data with third-party companies who perform services on our behalf, like payment processing, data analysis, marketing, and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.
• With business partners: We have agreements with other websites and platforms to distribute our Services and drive traffic to us.
• With analytics and data enrichment services: As part of our use of third-party analytics tools like Google Analytics and data enrichment services like Clearbit or Pipl, we share certain contact information, Account Data, System Data, Usage Data (as detailed in Section 2), or de-identified data as needed. De-identified data means data where we’ve removed things like your name and email address and replaced it with a token ID. This allows these providers to provide analytics services or match your data with publicly-available database information (including contact and social information from other sources). We do this to communicate with you in a more effective and customised manner.
• To power social media features: The social media features in the Services (like the Facebook/Instagram Share) may allow the third-party social media provider to collect things like your IP address and which page of the Services you’re visiting, and to set a cookie to enable the feature. Your interactions with these features are governed by the third-party company’s privacy policy.
• To administer promotions and surveys: We may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by applicable law (like to provide a winners list or make required filings), or in accordance with the rules of the promotion or survey.
• For advertising: If we decide to offer advertising in the future, we may use and share certain System Data and Usage Data with third-party advertisers and networks to show general demographic and preference information among our users. We may also allow advertisers to collect System Data through Data Collection Tools (as detailed in Section 3.1), and to use this data to offer you targeted ad delivery to personalise your user experience (through behavioural advertising) and undertake web analytics. Advertisers may also share with us the data they collect about you. To learn more or opt out from participating ad networks’ behavioural advertising, see Section 7.1 (Your Choices About the Use of Your Data) below. Note that if you opt out, you’ll continue to be served generic ads.
• For security and legal compliance: We may disclose your data to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
   Permitted or required by law;
   Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
   Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
   Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;
   Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues; or
   Reasonably necessary in our discretion to protect against imminent harm to our rights, property, or safety, or that of our users, employees, members of the public, or our Services.
   We may also disclose data about you to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Policy.
• During a Change in Control: If we undergo a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organisation during such transition or in contemplation of a transition (including during due diligence).
• After Aggregation/De-identification: We can disclose or use aggregate or de-identified data for any purpose.
• With Your Permission: With your consent, we may share data to third parties outside the scope of this Privacy Policy.

• 6.1 We use appropriate security based on the type and sensitivity of data being stored. As with any internet-enabled system, there is always a risk of unauthorised access, so it’s important to protect your password and to contact us if you suspect any unauthorised access to your account.

• 6.2 We take appropriate security measures such as using HTTPS to transfer your data to protect against unauthorised access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and us, the Services, or any information provided to us in connection with the data we collect through the Services will be free from unauthorised access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately.

You have certain rights around the use of your data, including the ability to opt out of promotional emails, cookies, and collection of your data by certain analytics providers. You can update or terminate your account from within our Services, and can also contact us for individual rights requests about your personal data such as to restrict our processing of your data, to erase all data we have stored about you, and the right to ask for the data to be provided to you/ported to any other service in a commonly used machine readable format.

• 7.1 Your Choices About the Use of Your Data:
• You can choose not to provide certain data to us, but you may not be able to use certain features of the Services

• To stop receiving promotional communications from us, you can opt out by using the unsubscribe mechanism in the promotional communication you receive or by changing the email preferences in your account. Note that regardless of your email preference settings, we will send you transactional and relationship messages regarding the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about our policies.
• The browser or device you use may allow you to control cookies and other types of local data storage. Your wireless device may also allow you to control whether location or other data is collected and shared.

• If you have any questions about your data, our use of it, or your rights, contact us at support@abcoffee.in.

• 7.2 Accessing, Updating and Correcting, Porting and Deleting Your Personal Data:
• You can access and update your personal data that we collect and maintain as follows:

• To update data you provide directly, log into your account and update your account at any time.
• To terminate your account:
  - Write to support@abcoffee.in to delete your account permanently.
  - Please note: even after your account is terminated, some or all of your data may still be visible to others, including without limitation any data that has been (a) copied, stored, or disseminated by other users; (b) shared or disseminated by you or others (including in your shared content); or (c) posted to a third-party platform. Even after your account is terminated, we retain your data for as long as we have a legitimate purpose to do so (and in accordance with applicable law), including to assist with legal obligations, resolve disputes, and enforce our agreements. We may retain and disclose such data pursuant to this Privacy Policy after your account has been terminated.
• To request to access, correct, port, or delete your personal data, or to restrict processing of your personal data, please email support@abcoffee.in. Please allow up to 30 days for a response. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify your identity before implementing your request. Please note that we post deletion, we may retain certain data where we have a lawful basis to do so, including for mandatory record-keeping and to complete transactions.

• 7.3 Revocation of Consent:
• We recognise that the processing of your data may be based on your consent. In case you wish to withdraw such consent given to us for the processing of your data, please e-mail us at support@abcoffee.in. Please allow up to 30 days for a response. For your protection, we may require that the request be sent through the email address associated with your account, and may need to verify your identity before implementing your request. Further, please note that such revocation of consent shall be prospective in nature, and shall not affect the lawfulness of any data processed based on your consent given prior to revocation.

• 7.4 Complaints about our privacy policy or use of your data:
• While we take all measures to protect and secure your data, we understand that you may have grievances about our use of your data, or of our data protection measures. Please feel free to reach out to us at support@abcoffee.in with any such complaints.
• In case you are not satisfied with our response, you can also reach out to the national data protection authorities in your region (provided you are in the EU).
• Please note that while we urge you to write to us for any grievances or with any complaints you may have, this does not preclude you from directly approaching the national data protection authorities mentioned above.

When we make a material change to this Privacy Policy, we will notify you via email, in-product notice, or another mechanism required by law. Changes become effective the day they are posted. Please contact us via email with any questions, concerns, or disputes.

• 8.1 Modifications to This Privacy Policy:
• From time to time, we may update this Privacy Policy. If we make any material change to it, we will notify you via email, through a notification posted on the Services, or as required by applicable law. We will also include a summary of the key changes. Unless stated otherwise, modifications will become effective on the day they are posted.
• As permitted by applicable law, if you continue to use the Services after the effective date of any change, then your access and/or use will be deemed an acceptance of (and agreement to follow and be bound by) the revised Privacy Policy. The revised Privacy Policy supersedes all previous privacy policies.

• 8.2 Interpretation:
• Any capitalised terms not defined in this policy are defined as specified in our Terms of Use.

• 8.3 Questions:
• If you have any questions, concerns, or disputes regarding our Privacy Policy, please feel free to contact our privacy team (including our designated Data Protection Officer) at support@abcoffee.in.
• The name and contact details of our data protection officer is as provided below:
• Name: Shivam
  Designation: Data Protection Officer
  Email: shivam@abcoffee.in
  Phone Number: 7400167381
• Our Data Protection Officer may be contacted with respect to any complaints or concerns including those pertaining to breach of our Terms of Use and/or Privacy Policy.

• 9.1 What are cookies?
• Cookies are small text files stored by your browser as you browse the internet. They can be used to collect, store, and share data about your activities across websites, including on abCoffee. Cookies also allow us to remember things about your visits to abCoffee, like your account ID, and to make the site easier to use.
• We use both session cookies, which expire after a short time or when you close your browser, and persistent cookies, which remain stored in your browser for a set period of time. We use session cookies to identify you during a single browsing session, like when you log into abCoffee. We use persistent cookies where we need to identify you over a longer period, like when you request that we keep you signed in.

• 9.2 Why do we use cookies and similar technologies?
• We use cookies and similar technologies like web beacons, pixel tags, or local shared objects (“Flash Cookies”), to deliver, measure, and improve our services in various ways. We use these cookies both when you visit our site and services through a browser and through our mobile app. As we adopt additional technologies, we may also gather additional data through other methods.
• We use cookies for the following purposes:
• To identify a user's device upon visiting the website, monitor a user's activity throughout the site, and facilitate any e-commerce features. Additionally, to enhance the website's user experience and analyze its usage patterns.

• 9.3 What are my privacy options?
• You have a number of options to control or limit how we and our partners use cookies:
  - Most browsers automatically accept cookies, but you can change your browser settings to decline cookies by consulting your browser’s support articles. If you decide to decline cookies, please note that you may not be able to sign in, customise, or use some interactive features in the Services.
  -Flash Cookies operate differently than browser cookies, so your browser’s cookie-management tools may not remove them.