Privacy Policy

OBJECTIVE, SCOPE AND APPLICABILITY

Hlreem Consumer Limited. (“Company”, “we”, “our”, “us”) respects an individual’s
privacy and is committed to protecting the same. This Privacy Policy (“Policy”)
describes how we collect, use, disclose and transfer Personal Information (as defined
below), through platforms controlled by the Company viz. www.hlreem.com and
mobile sites/application (the “Platforms”) of the individuals who browse, or access
the Platform or provide information on or through the Platform, or whose
information the Company otherwise collects, receives or processes in connection
with the offer and sale of its products (“Products”) (hereinafter, collectively referred
to as “Customers”, “you”, “your”) and ensure its compliance with applicable laws
and regulations. This Policy does not apply to Personal Information collected from
you offline (unless otherwise specified), to Company’s websites that do not link to
this Policy, to Customers of countries other than India or to third-party websites to
which Platform may link.

By accessing and/or using our Platform and providing the information as explained
in this Policy, you consent to the collection and use of the information you disclose
on the Platform in accordance with this Policy, including but not limited to your
consent for sharing your information as per this Policy. We encourage you to read
this Policy regarding the collection, use, and disclosure of your information. If you
are not comfortable with any of the terms or policies described in this Policy, you
may choose to discontinue usage of the Platform.

Further, you agree and consent to receive all communications related to our
services on the mobile number provided by you to the Company, even if such mobile
number is registered under DND/NCPR list under the Telecom Commercial
Communications Customer Preference Regulations, 2018 (“TRAI Regulations”).
Notwithstanding your registration with the National Do Not Call Registry (In Fully or
Partly blocked category under National Customer Preference Register set up under
the Telecom Regulatory Authority of India), you hereby express your interest and
accord informed consent to receive communications (including commercial
communications) in relation to the Company’s services. You further confirm that no
communication to you from the Company or on behalf of the Company shall be
construed as Unsolicited Commercial Communication under Regulation 2(bw) of the
TRAI Regulations and you have specifically opted to receive communications in this
regard on the mobile number provided by you.

For the purpose of this Policy, the term “Personal Information” shall mean any
information that relates to you, which, either directly or indirectly, in combination
with other information available or likely to be available with the Company, is
capable of identifying you, which is submitted to and/or collected over the Platform
and maintained by the Company in an accessible form, provided that, any
information that is freely available or accessible in public domain or furnished under
the Right to Information Act, 2005 or any other law for the time being in force shall
not be regarded as Personal Information for the purposes of this Policy.

HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We communicate with you through a variety of means and channels, including our
Platform, email, phone or text messaging on your mobile phone, although we do
generally note that our preferred means of communication is email which has the
least impact on the environment. Such communications may involve giving to you, as
well as receiving information from you. We collect and receive the Personal
Information in the following ways:

When you submit your Personal Information on our Platform: The Company
collects and stores the Personal Information that you provide while using our
Platform including when you enter your Personal Information into data fields on the
Platform as part of a voluntary registration process. We also collect and store your
Personal Information through sponsored social media platforms, events, etc. For
example, you may submit your name, postal address, e-mail address, and/or other
information in order to register, place orders for the Products, receive information
about various Products, register for newsletters, receive offers, contact Company’s
customer care service, or respond to the Company’s surveys. To protect your
privacy, you should not provide the Company with any information that is not
specifically requested or that you do not wish to share. You can choose not to
provide certain information, but then you might not be able to use our Platform or
certain features of our Platform.

Automatic collection: We automatically collect and store certain types of
information whenever you interact with us. Such information includes information
about your use of the Platform, your interaction with content and services available
through the Platform. Like many websites, unidentifiable information may be

collected using various technologies, such as cookies, Internet tags, and web
beacons. Your Internet browser automatically transmits to the Platform some of this
unidentifiable information, such as the URL of the Website you just visited and the
browser version your computer is operating. Passive information collection
technologies can make your use of the Platform easier by allowing the Company to
provide better service, customize sites based on consumer preferences, compile
statistics, analyze trends, and otherwise administer and improve the Platform.
Certain features of the Platform may not work without use of passive information
collection technologies. Information collected by these technologies cannot be used
to identity you without additional identifiable information. We may also
receive/store information about your location and your mobile device, including a
unique identifier for your device.

Other sources: We might receive information about you from other sources, such
as updated delivery and address information from third parties, which we use to
correct our records and deliver your next purchase more easily. Further, we may
receive information about you from third parties that feature our Products or
promotional offers if you opt-in to receive information from us. You may also choose
to participate in a third party application or social media sites through which you
allow us to collect (or the third party to share) Personal Information about you,
including usage information. We may also receive information, such as marketing
related or demographic information about you from third parties to enhance our
ability to tailor our content and offer you the Products that we believe may be of
interest to you. The Company is not responsible for the privacy practices of such
third-party websites which it does not own, manage or control.

WHAT PERSONAL INFORMATION DO WE COLLECT?

The Company limits itself to collect information which is necessary to ensure
accurate services and is required to process your order of the Product or provide a
refund and continually improve our Products and services.

Following are the categories of Personal Information that is collected and
processed by us:

your name, e-mail and postal addresses, phone number(s), country;

date of birth, language preference, location;

any open data and public records such as information about you that is openly
available on the Internet;

names of people to whom purchases have been shipped including address and
telephone numbers, IP addresses;

Product interest information and in certain circumstances, your opinions and
individual preferences, etc.;

You may also provide us with information like financial information such as bank
account or credit card or debit card or other payment instrument details, password
for availing the Products at our Platform;

We may also maintain a record of your Product interests and acquire information
about you from our future affiliates;

phone numbers used to call our customer service number.

We may collect and use technical data and related information, including but not
limited to, technical information about your device, system and application software,
and peripherals, that is gathered periodically to facilitate the provision of software
updates, product support and other services to you (if any) related to the Platform.

WHAT IS THE PURPOSE FOR WHICH THE PERSONAL INFORMATION IS COLLECTED?

The Company may use your Personal Information to:

verify your identity;

fulfill the Product purchases and transactions;

communicate with you about your account and activities on the Platform;

allow us to better serve you in responding to your requests;

to respond to reviews, comments, or other feedback provided to us;

administer a contest, promotion, survey or other site feature;

ask for ratings and reviews of the Products;

follow up with you after correspondence (live chat, email or phone inquiries);

allow you to log in with a social media account and share activities on your social
media pages;

comply with our legal obligations, policies and procedures, including compliance
with relevant industry standards and the enforcement of our terms and conditions;

help us learn more about your shopping preferences;

conduct marketing and performance research to assist us in measuring our
customer services, benchmarking our performance and to help us improve your
shopping experiences and Product offerings;

send communication related to order updates and offers through e-mail, SMS and
social media channels;

do internal research on our Customer’s demographics, interests, and behaviour to
better understand and serve you;

provide you with exclusive offers at the Platform, tailor content, advertisements,
and we provide you, and improve the Platform and/or for internal business
purposes;

analyze trends, track Customer’s web page movements, help identify you and your
shopping cart for aggregate use;

determine which of the store locations containing our Products may be closest to
you, provide promotional offers, and to offer Products to you;

prevent, detect, investigate and take action against crimes (including but not
limited to fraud and other financial crimes), any other illegal activities, suspected
fraud, or violations of Company’s terms and conditions in any jurisdiction;

establish, exercise or defend legal rights in connection with legal proceedings
(including any prospective legal proceedings) and seek professional or legal advice in
relation to such legal proceedings; and

comply with any applicable law, regulation, legal process or enforceable
governmental request.

The legal basis on which we collect your Personal Information:

Performance of a Contract: some of the Personal Information processed is
performed on the basis that it is necessary for the performance of our agreement
with you. An example of this would be where we process your Personal Information
for delivering the Products ordered by you on our Platform.

Legitimate Interest: legitimate interests will include where we send you marketing
information about our Products, communicate with you in order to serve you better.

Compliance with a Legal Obligation: for certain types of processing it is necessary
in order to allow us to comply with a legal obligation. An example of this would be
where we are required to retain business records for fixed periods of time in order to
comply with local legal requirements.

Consent: Finally, in certain limited situations, we rely on your consent in order to
process your Personal Information. Where we require your consent in order to
collect and process certain Personal Information, we seek your consent at the time
of provision, and such processing will only be performed where consent is secured.
You can withdraw your consent, as per this Policy where applicable, by sending an
email to Care@hlreem.com.

We may also collect and/or generate anonymized and aggregated information
from your use of the Platform. The anonymized or aggregated information is not
Personal Information since we are not able to re-identify you using any means
available to us from that anonymized or aggregated information. The anonymized
and aggregated information is used for a variety of functions, including to help us
identify and remediate any bugs, and to improve the performance of our Platform.
The Company may use such information in a number of ways, including internal
analysis, analytics and research. We may share this information with third parties for
our or their purposes in an anonymized or aggregated form that is designed to
prevent anyone from identifying you.

We maintain a social media presence, such as a Facebook, Instagram, LinkedIn and
a Twitter feed. You can interact with us through social media, such as by entering
our contests, posting content, sharing material from our Platform, and using our
social media plug-ins. When you interact with us using social media, we may receive
information such as your user ID, your profile picture, photos you post, and similar
information, which is often determined by your privacy settings at the relevant social
media sites. We may use the information for the purposes we have described
throughout this Policy. Your use of social media sites is primarily governed by the site
operators’ privacy policies and terms of service, and the information you share with
us and with others is largely controlled by the privacy settings you have established
at those sites.

Payment Information: You may provide payment information when you use the
Platform to buy our Products, including credit cards numbers, billing information
using third-party intermediary PCI-DSS compliant service providers. The payment
information is provided directly by you, via the Platform, into the PCI/DSS-compliant
payment processing service to which the Company subscribes, and the Company
does not, itself, process or store the payment information, except as stated herein.
Further, these intermediaries are not permitted to store, retain, or use your billing
information for any purpose except for payment processing on our behalf.

If you use the Platform, you are responsible for maintaining the confidentiality of
your access information and password. You are responsible for restricting access to
your computer, mobile device, etc., and you agree to accept responsibility for all
activities that occur under your password. We cannot secure any information that
you release on you own, that you request us to release or that is released through
another third party to whim you have given access.

HOW DO WE SHARE THE PERSONAL INFORMATION?

Only the persons authorized by us shall have access to your Personal Information.
We may share your Personal Information only to those mentioned below and they
are either subject to this Policy or follow practices at least as protective as those
described in this Policy:

Our affiliates and third parties;

Service providers who perform services on our behalf based on our instructions
which inter alia include beauty partners providing beauty services to the Customers.
However, these service providers will not be authorized to use or disclose such
information except as necessary to perform services on our behalf or comply with
legal requirements;

We do not rent or sell your Personal Information to any third party.

Should we plan to merge/sell all or substantially all of our business to another
business entity or similar other transaction or be required by that business entity, we
may transfer or disclose your Personal Information to that business entity who may
collect, use or disclose such information for the purposes of evaluating the proposed
transaction or for operating and managing the affairs of the acquired business or for
other purposes identified in this Policy.

We may share Personal Information with our other corporate entities who may use
the said information in accordance with this Policy to help detect and prevent
identity theft, fraud, and other potentially illegal acts; correlate related or multiple
accounts to prevent abuse of our Platform. If you have any objection to such sharing,
then we request not provide us with any information.

We may retain other companies and individuals to perform functions on our behalf
consistent with this Policy. Examples include order processing companies, courier
companies, data analysis firms, customer support specialists, email vendors, web-
hosting companies and fulfillment companies (e.g., companies that coordinate
mailings). Such third parties may be provided with access to Personal Information
needed to perform their functions but may not use such information other than on
our behalf and in accordance with this Policy.

In addition, in some instances, you may be offered the opportunity to consent to
the sharing of your information with a third party such as an event or promotion co-
sponsor. If you consent, we will share your information with such third party and the
information you provide may be used by such third party for their own purposes and
in accordance with their own policies.

Notwithstanding anything contained in this Policy, we may disclose Personal
Information if required to do so by law or in the good faith belief that such disclosure
is reasonably necessary to respond to any court orders or other legal processes. We
may disclose Personal Information to law enforcement offices, third party rights
owners, or others in the good faith belief that such disclosure is reasonably
necessary to: enforce our Terms and Conditions or Policy; respond to claims that an
advertisement, posting or other content violates the rights of a third party; or
protect the rights, property or personal safety of our Customers or the general
public.

RETENTION OF PERSONAL INFORMATION

We will retain your Personal Information only as long as it is reasonably required or
otherwise permitted or required by applicable law or regulatory requirements. We

may also retain your Personal Information so long as it is necessary to fulfil the
purposes for which it was collected (including for purposes of meeting any legal,
administrative, accounting, or other reporting requirements). Your Personal
Information is safeguarded against inappropriate access and disclosure, as per this
Policy.

We also maintain appropriate and adequate administrative, technical and physical
safeguards designed to protect your Personal Information against accidental,
unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

OPTING OUT:

The Platform provides an option to all the Customers to opt-out of receiving any
promotional or marketing communications from us. If you do not wish to receive any
promotional or marketing communications from us, you can contact us at the
address provided below.

Your Choices to opt-out:

You have the following choices with how your Personal Information is used:

Opt-out options

What you need to do

Updating your Personal Information in relation to your account

You can update or correct your name, e-mail address, security questions, and other
preferences by [logging into your account and clicking on the "My Account" page,
calling/writing customer care executive.

Receiving newsletters and promotional e-mails

You can click on the “unsubscribe” link at the bottom of any promotional e-mail that
you receive. Alternatively, you may edit your e-mail preferences on your “My
Account” page or call customer care executive to discontinue receiving any
promotional materials by mail/ e-mail.

Remove content from Customer review

You can remove content that you posted on a public space, such as part of a ratings
and review, by e-mailing details to care@hlreem.com. Please note that we will
endeavour and try to ensure to honour your request to remove information,
however, our removal of your information does not completely erase that
information from the internet viz. historical copies, or "caches," may remain.

WITHDRAWAL OF CONSENT

If you have consented to the collection, use and/or disclosure of your Personal
Information as identified in this Policy, you have the right to withdraw this consent
at any time by writing to us at care@hlreem.com. Where you are providing location
information via a mobile app, you may turn off your location services on your device
at any time. Please note that any processing that we have carried out before the
withdrawal of your consent remains lawful. Provided that, notwithstanding such
request, this information may be retained to comply with our legal obligations,
resolve disputes and enforce our agreements.

HOW WE STORE YOUR PERSONAL INFORMATION

We may store Personal Information using our own secure on-site servers or other
internally hosted technology. Your Personal Information may also be stored by third
parties, via cloud services or other technology, with whom the Company has
contracted, to support the Company's business operations.

These third parties do not use or have access to your Personal Information other
than for cloud storage and retrieval, and the Company requires such parties to
employ at least the same level of security that we use to protect your Personal
Information.

DISPOSAL OF PERSONAL INFORMATION

We will only use your Personal Information for those purposes and will make sure
that your privacy is protected. We shall take reasonable steps to delete or
permanently de-identify Personal Information that is no longer needed.

DO WE USE “COOKIES”?

We may track your preferences and activities on the Platform. “Cookies” are small
data files transferred to your computer's hard-drive by a website, while using a web
browser (if you allow). They keep a record of your activities on the Platform making
your subsequent visits to the site more efficient. The Cookies may store a variety of

information, including, the number of times that you access the Platform,
registration information and the number of times that you view a particular page or
other item on the Platform. The use of cookies is a common practice adopted by
most major sites to better serve their clients. Most browsers are designed to accept
cookies, but they can be easily modified to block cookies.

By continuing the use of the Platform, you are agreeing to our use of cookies. If
you do not agree to our use of cookie, you can block them in your browser setting,
but you may lose some functionality on the Platform.

We use cookies to:

understand and save Customer’s preferences for future visits.

keep track of advertisements.

compile aggregate data about site traffic and site interactions in order to offer
better site experiences and tools in the future. We may also use trusted third-party
services that track this information on our behalf.

you can choose to have your computer warn you each time a cookie is being sent,
or you can choose to turn off all cookies. You do this through your browser settings.
You may look at your browser’s help menu to learn the correct way to modify your
cookies.

if you turn cookies off, some features will be disabled. It won’t affect the
Customer’s experience that makes your site experience more efficient and may not
function properly.

However, you will still be able to place orders.

CUSTOMER COMMENTS AND CONTENT

If you post any comments or content on our Platform, you should be aware that any
information you choose to provide there may be read, collected, or used by the third
parties. We are not responsible for the information you choose to submit, and we
cannot guarantee that third parties have not made copies of or will not use such
information in any way.

LINKS TO THIRD PARTY ADVERTISEMNTS OR SITES

We may display links to web sites that are owned or operated by third parties on our
Platform. Please understand that these websites are independent from the
Company, and the Company has no control over the content on that website, even if
the Company provides information or Products to the owner of that website. The
Company is not making any representations about, endorsing, or accepting any
responsibility for the content or the use of such website. Further, we are not
responsible or liable for any damage or loss related to the use of any third-party
website. You should always read the terms and conditions and the privacy policy of a
third-party website before accessing or using it.

THIRD PARTY ANALYTICS:

We use third-party analytics services to evaluate your use of the Platform, compile
reports on activity, collect demographic data, analyze performance metrics, and
collect and evaluate other information relating to the Platform and mobile and
internet usage. These third parties use cookies and other technologies to help

analyze and provide us the information and, in some cases, connect such
information with other data held by our, or third party, environments. You consent
to the processing of information about you by these analytics providers in the
manner and for the purposes set out in this Policy.

At present, we work with the following analytic partners:

Google

Google’s advertising requirements can be summed up by Google’s Advertising
Principles. They are put in place to provide a positive experience for Customers. We
use Google AdSense Advertising on our Platform. Google, as a third-party vendor,
uses cookies to serve ads on our Platform. Google’s use of the DART cookie enables
it to serve ads to our Customers based on previous visits to our Platform and other
sites on the Internet. The Customers may opt-out of the use of the DART cookie by
visiting the Google Ad and Content Network privacy policy.

We have implemented the following:

Remarketing with Google AdSense

Google Display Network Impression Reporting

Demographics and Interests Reporting

DoubleClick Platform Integration

We, along with third-party vendors such as Google use first-party cookies (such as
the Google Analytics cookies) and third-party cookies (such as the DoubleClick
cookie) or other third-party identifiers together to compile data regarding the
Customer interactions with ad impressions and other ad service functions as they
relate to our Platform.

The Customers can set preferences for how Google advertises to you using the
Google Ad Settings page. Alternatively, you can opt out by visiting the Network
Advertising Initiative Opt-Out page or by using the Google Analytics Opt-Out Browser
Add-on.

SECURITY MEASURES**

We employ industry-standard security measures to safeguard your personal
information. However, no method of transmission over the internet or electronic
storage is 100% secure. While we strive to protect your information, we cannot
guarantee its absolute security.

EMPLOYMENT OPPORTUNITIES:

We provide you with a means for submitting your resume or other information
through our Platform for consideration for employment opportunities at the
Company. Information received through resume submissions will be kept
confidential. We may contact you for additional information to supplement your
resume, and we may use your information within the Company, or keep it on file for
future use, as we make our hiring decisions.

CHILDREN

Out Platform is not designed for individuals under the age of eighteen (18) and we
do not knowingly collect Personal Information from anyone under the age of
eighteen (18). If you are under eighteen (18) years of age, you may browse our
Platform, but please do not provide your Personal Information to us. For example,
you cannot register. If we become aware that we have inadvertently received
Personal Information from a visitor under the age of eighteen (18) on the Platform,
we will delete the information from our records.

SECURITY

We endeavour to protect the Personal Information against loss or theft, as well as
unauthorized access, disclosure, copying, use or modification with security
safeguards appropriate to the sensitivity of the Personal Information, regardless of
the format in which it is held. We use various methods to safeguard Personal
Information. They include:

Physical measures: locked filing cabinets, restriction of access to offices, and alarm
systems.

Technical tools: passwords and encryption, using generally industry best practices.

Organizational controls: confidentiality agreements, limiting access on a need-to-
know basis, staff training and security clearances.

Online security is also a priority. We incorporate security measures such as
encryption and authentication tools to protect your Personal Information from
unauthorized use. Firewalls are utilized to protect our servers and network from
unauthorized users accessing and tampering with files and other information that we
store.

We use regular Malware Scanning.

Your Personal Information is contained behind secured networks and is only
accessible by a limited number of persons who have special access rights to such
systems and are required to keep the information confidential. In addition, all
sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL)
technology.

We implement a variety of security measures when a Customer enters, submits, or
accesses their information to maintain the safety of your Personal Information.

However, we shall not be liable to any Customers for any loss, damage (whether
direct, indirect, consequential or incidental) or harm caused to the Customers due to
the unauthorized access or misuse of the Personal Information by any third party.

POLICY REVIEW

Please note that we review and may make changes to this Policy from time to time.
When changes are made, the Policy link will include a notation “Revised (date).”
indicating that you should review the new terms, which will be effective immediately
upon posting on this page, with an updated effective date. By accessing the Platform
after any changes have been made, you signify your agreement on a prospective
basis to the modified Policy and any changes contained therein.

PRIVACY CONCERNS

If you are concerned about the handling of your Personal Information, or if you have
any complaints or queries related to your Personal Information or our Policy, please
contact:

Grievance Officer

Hlreem Consumer Limited

Khasra – 463, Delhi road , Arjun nagar

Krishna market , Hapur, Uttar Pradesh, 245101

India

Email id – care@hlreem.com

The Grievance Officer is identified above pursuant to the provisions of applicable
laws including but not limited to the Information Technology Act, 2000 and the
Consumer Protection Act, 2019, and the rules enacted under those laws.

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