@sternetIndustries

2021 January 30

Privacy Policy

Sternet Industries India, Pvt. Ltd. dba HUELITE and its affiliates and subsidiaries (" HUELITE", " we", " us", or " our") are committed to protecting your privacy. Please read this Privacy Policy (the " Privacy Policy") carefully to understand our policies and practices regarding your information and how we will treat it. This Privacy Policy is intended to inform you about the kind of information, including personally identifiable information, that we may collect from you in connection with your use of the Services and how, and for what purpose, we use that information.

This Privacy Policy is a part of and incorporated into the HUELITE Terms of Service (the " Terms"). If any provision of this Privacy Policy is inconsistent or conflicts with any provision in the Terms, this Privacy Policy will control with respect to the subject matter hereof. Capitalized terms used in this Privacy Policy but not defined in this Privacy Policy have the meanings given to them in the Terms.

WHO WE (HUELITE) ARE

When we refer to or use " HUELITE", " we", " us", or " our" throughout this Privacy Policy it means the HUELITE entity who is the controller of your data under this Privacy Policy, namely the HUELITE entity with which you had, have, or will have a business relationship or that otherwise decides what data of yours is collected and how it is used.

Please note that the HUELITE subsidiaries and affiliates include companies in which Sternet Industries India, Pvt. Ltd. dba HUELITE has control, either through direct or indirect ownership.

WHEN THIS PRIVACY POLICY APPLIES (AND WHEN IT DOESN'T)

This Privacy Policy applies when you :

• Visit or use the HUELITE Website, HUELITE App or our social media channels;
• Purchase and use the HUELITE Products;
• Subscribe to our newsletters, marketing campaigns or participate in our surveys or giveaways;
• Contact our customer support
• Collaborate with us in a paid or unpaid partnership; or
• Otherwise interact with us in your capacity as a customer.

Unless otherwise stated in this Privacy Policy, this Privacy Policy does ** not ** apply :

• When you visit or use third party links and websites.
• To information you share when you connect, integrate or use the HUELITE Products with third party applications, integrations, or services.

YOU GIVE US CONSENT

By accessing or using the Services, or submitting information through the Services, you acknowledge and agree that by providing us Personal Information you (1) understand that you allow us to identify you; and (2) have read, understand, and agree to the terms of this Privacy Policy and you expressly consent to the collection, use, and disclosure of your Personal Information and Anonymous Information (as each term is defined below) in accordance with this Privacy Policy.

Some of the services we provide may be obstructed if you do not provide us the necessary Personal Information. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, UNLESS OTHERWISE STATED, YOUR CHOICE IS NOT TO USE OR ACCESS THE SERVICES.

DEFINING "PERSONAL INFORMATION"

We collect data and information from you in connection with your use of the Services, which includes both Personal Information and Anonymous Information.

" Personal Information" is information that allows someone to identify or contact you, as well as any other non-public information about you that is associated with or linked to any of the foregoing, and can include, for example, an individual's first and last name, address, phone number, e-mail address, IP address, location or other personally identifiable details. Personal Information does not include Anonymous Data.

" Anonymous Information" means aggregated and/or anonymized data that is not associated with or linked to your Personal Information. Anonymous Information does not, by itself, permit the identification of individual persons.

PROTECTING YOUR PRIVACY

We do not share, rent or sell your account information to any third party, except as expressly set forth in this Privacy Policy. Please help us protect your privacy by keeping your account information safe. Do not disclose your account password or login information to anyone and keep changing it periodically.

INFORMATION WE COLLECT AND HOW WE USE IT

Depending on your interactions with us (for example, online, offline, over the phone, etc.) we may process different data about you. We may collect your data, for example, when you visit or use the HUELITE Website, HUELITE App or our social media channels, purchase and use the HUELITE Products, subscribe to our newsletters, download a software update to the HUELITE App or HUELITE Products, contact our customer support, participate to our giveaways, promotions, surveys, and marketing campaigns or otherwise interact with us.

INFORMATION YOU PROVIDE US

Account & Log in Information

When you register an account for the HUELITE App you are required to provide us your email address. In addition, when you access your account you provide us your log in ID, password or other security codes.

We may use the Personal Information you submit during the registration process to send you services-related communications. In addition, to the extent permitted by applicable law, we may also use such Personal Information to send you electronic newsletters or promotional e-mails, unless you have requested not to receive such promotional communications from us as described below.

Purchase and Billing Information

When you purchase HUELITE Products our third party store providers (Amazon, Flipkart) and payment processor will collect, on our behalf, your first and last name, email address, shipping and billing address, and complete credit card information or bank account information, that enables us to receive your payment and provide you with the HUELITE Products.

We may use such Personal Information to provide in order to ship you the HUELITE Products and fulfill your order. In addition, to the extent permitted by applicable law, we may also use the email address provided to send you electronic newsletters or promotional e-mails, unless you have requested not to receive such promotional communications from us as described below.

Direct Communications with us, Feedback and Support

If you provide us Feedback or contact us via e-mail or through our forms, or contact us for support related inquiries, we will collect your first and last name, e-mail address and any information requested in our forms, as well as any other content included in the Feedback or your e-mail or in the contact-us" support inquiries you send to us.

We may use Personal Information submitted in these communications to contact and respond to you and send you related services communications. Any Feedback you provide will be governed by the Terms.

Surveys, Giveaways and Marketing Campaigns

If you participate in our surveys, giveaways, or marketing campaigns, we may collect your name, mailing address, email, images and/or videos from which you may be identified, pictures and any other information requested and/or required with respect to your participation in the surveys, giveaways, and marketing campaigns.

We may use Personal Information submitted in connection with our surveys, giveaways and marketing campaigns to carry out the surveys, giveaways, and marketing campaigns and provide related marketing communications that we may think are of interest to you.

Additional Services and Communications

We may provide certain additional services and/or communications if you select such additional services and/or communications by opting-in to such additional services and/or communications using certain buttons provided in the user interface of our services. We will collect the information specified for such additional services and/or communications in the user interface of our services where you opt-in by clicking on such buttons. We may use such Personal Information to send you the corresponding additional services and/or communications.

INFORMATION COLLECTED AUTOMATICALLY

When you visit or use the HUELITE Website, HUELITE App or HUELITE Products, or subscribe to our newsletters, participate in our surveys, giveaways or marketing campaigns, or otherwise interact with us through our social media channels, in addition to the information you provide to us directly, we may collect information sent to us by your computer, mobile phone or other access device.

This information is used to (i) provide you the HUELITE Website, HUELITE App and other services requested by you, (ii) improve the HUELITE Website, HUELITE App and other services provided to you by us, (iii) notify user about updates to the Services, and (iv) contact you for our own internal marketing purposes.

For example, we may collect:

Device Information

Hardware model, IMEI number and other unique device identifiers, MAC address, IP address, operating system version, and settings of the device you use to access the Services.

Location Information

Your actual location (derived from your IP address or other location-based technologies), that may be collected when you enable location-based products or features through the HUELITE Website, HUELITE Apps or HUELITE Products.

Log File Information

Log file information, which may include your internet protocol (IP) address, URLs of referring/exit pages, information you search for, click stream data, which pages areas of the Services you visit or use, access times, time and duration of your use of the Services.

INFORMATION COLLECTED FROM OTHER SOURCES

To the extent permitted by applicable law, in addition to the HUELITE Website and HUELITE App, we may also obtain information about you from other sources, such as joint marketing partners, social media platforms and other third parties. For example, depending on your social media settings, if you choose to connect your social media account to your HUELITE App account, certain data from your social media account will be shared with us, which may include data that is part of your profile.

Anonymous Information

We may create Anonymous Information records from Personal Information by excluding information (such as your name) that would otherwise make such data personally identifiable to you. We may use Anonymous Information at our discretion and for any purpose. When we provide or use this information, we employ procedures so that the data does not identify you and we contractually prohibit recipients of the data from manipulating the data in a way that would re-identify it back to you.

HOW YOUR INFORMATION IS SHARED

We will share your Personal Information with third parties only in the ways that are described in this Privacy Policy. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Information with certain third parties without further notice to you, as set forth below.

Service Providers

We may provide your information to third party service providers (such as, but not limited to, our cloud service, data storage, e-commerce, payment processors and shipping and distribution providers) who require the information to perform services for us in order to provide you the Services. These third party service providers are required not to use your Personal Information other than to provide the services requested by us.

Affiliates

To provide the Services and other various services to you, we may use the efforts of our parent company, and any subsidiaries, joint ventures, or other companies, existing or formed in the future, under a common control (collectively, " Affiliates"). We may share some or all of your Personal Information with our Affiliates in which case we will require our Affiliates to comply with this Privacy Policy.

Business Transfers

As we develop our business, we might sell or buy businesses or assets. In the event we are acquired by or merged with a third party, we reserve the right to transfer or assign the information we have collected from our users as a part of such merger, acquisition, sale, or other change of control. In an event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors' rights generally, your Personal Information may be transferred by the trustee. If HUELITE or any of its Affiliates is acquired by or merged with a third party, that third party will possess the Personal Information in HUELITE's or its Affiliate's possession and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.

Other Third Parties

We may share Personal Information with our headquarters and affiliates, business partners and professional advisors such as banks, insurance companies, auditors, lawyers, accountants, other professional advisors, to whom it is reasonably necessary or desirable for us to disclose your data for the purposes described in this Privacy Policy. We may also make certain Anonymous Data available to third parties for various purposes, including for business or marketing purposes or to assist third parties in understanding our users' interest, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and functionality available through the Services.

Other Disclosures

Regardless of any choices you make regarding your Personal Information (as set forth below), we may disclose your Personal Information (i) to respond to subpoenas, warrants, court orders, lawful requests or legal process, (ii) to establish or exercise our legal rights or defend against legal claims or protect other users, (iii) in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, or as otherwise required by law, or (iv) to investigate, prevent, or take action regarding any violation of this Privacy Policy or the Terms.

THIRD PARTY BUTTONS

We may display third-party content on or through the Services, including third-party advertising. Third-party content may use other mechanisms for obtaining data in connection with your viewing of the third party content on the Service. Additionally, we may implement third party buttons, such as Facebook, Instagram, Twitter or other social media "share" buttons, that may function as tracking mechanism even when you do not interact with the button. Information collected through third-party buttons is collected directly by these third parties, not by HUELITE. Please consult such third party's data collection, use, and disclosure policies for more information.

Third Party Links to Websites

The HUELITE Website contains links to other third party websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. Other sites follow different rules regarding the use or disclosure of the Personal Information you submit to them. We are not responsible for the content, privacy and security practices, and policies of third-party sites or services to which links or access are provided through the Services. We encourage you to read the privacy policies or statements of the other websites you visit.

YOUR RESPONSIBILITIES, PRIVACY RIGHTS AND CHOICES

Your Responsibilities

While HUELITE is committed to protecting your privacy, it is your responsibility to ensure that to the best of your knowledge the information and data you provide us is accurate, complete and up-to-date. It is also your responsibility that in the event you share Personal Information of other people with us, you collect such Personal Information in compliance with local legal requirements and that you have the appropriate consent to share such Personal Information. At a minimum, you should inform any such people about this Privacy Policy and obtain their consent prior to sharing their Personal Information with HUELITE.

Changes and Deletion of your Data

To the extent we provide you with access to and control of your information (for example, to update modify or, to the extent legally permissible, delete it), we strongly encourage you to take control of your information.

Please note that we may still use Anonymous Information that does not identify any individual and that even if you have requested deletion of your information, we may retain such information to the extent permitted by applicable law as further described in the section title "Data Deletion and Retention" below.

Marketing Communications

If you decide at any time that you no longer wish to receive such marketing communications from us, please follow the unsubscribe instructions provided in any of the communications. You may also opt out from receiving commercial email from us by sending your request to us by email at privacy@huelite.in. Please be aware that, even after you opt out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Services.

Where required by law, we obtain your consent for the processing of certain Personal Information collected by technologies, or used to send you direct marketing communications, or when we carry out other processing activities for which consent may be required. If we rely on consent for the processing of your Personal Information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.

Services-Related Communications

If you have registered an account for the HUELITE App or if you have contacted us for support or for other reasons, you may not, despite your indicated e-mail preferences, "opt-out" of other services-related communications regarding your account, support requests, or any payments made, or to be collected, by you, including receiving notices of any updates to our Terms or this Privacy Policy, except by terminating your account.

DATA DELETION AND RETENTION

We keep your data for the period necessary to fulfill the purposes for which it has been collected (for details on these purposes, see section titled "Information We Collect and How We Use It" above). We also take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period.

When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations. In any event, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

SECURITY

HUELITE takes appropriate measures that are consistent with applicable data protection and data security laws and regulations to protect your information, including requiring our service providers to use appropriate measures to protect the confidentiality and security of your information and data. Depending on the state of the art, the costs of the implementation and the nature of the data to be protected, we employ technical and organization measures designed to prevent against risks such as accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession.

Please be aware that no security measures are perfect or impenetrable. We cannot guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our administrative, physical, and electronic safeguards, subject to requirements under applicable law to ensure or warrant information security. You acknowledge and agree that you provide your Personal Information at your own risk.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be amended by us from time to time. If we make material changes to this Privacy Policy, we will use all reasonable efforts to notify you of such changes by posting the revised Privacy Policy on the HUELITE Website or through the user interface of the HUELITE App or by notifying you by email if you have provided it to us. Your continued use of the Services after such notification of changes as described above will constitute your agreement to such changes. If you object to any change, your sole recourse shall be to immediately terminate your account and/or cease all access and use of the Services.

QUESTIONS AND ADDITIONAL INFORMATION

Please feel free to contact us at support@huelite.in if you have any questions about this Privacy Policy or HUELITE's information collection and security practices.

If you come across any abuse or violation of these Terms, please report to support@huelite.in

© 2020 Sternet Industries India Pvt. Ltd. All rights reserved.