Overview
For Vstaarplus Lifestyle Private Limited (The, “Company”) focuses on protecting the
confidential data provided by the customers, employee, C&F, Direct sellers.
Therefore, company is taking every possible step to protect the interest of Consumer of the
Company and ensures to take reasonable interest for the protection of the consumer interest.
Applicability
This policy shall be called Information Technology
(Reasonable security practices which
must be followed on for protecting the sensitive personal data and information)
by the
Vstaarplus Lifestyle Private Limited (Herein after referred as “Company”) and applies on
sensitive personal data provided by the concerned person.
Objective
The main objective associated with policy is to protect the data, information and personal
information which majorly relate either directly or indirectly with the concerned person.
Applicable laws
The Consumer Protection (Direct Selling) Rules, 2021, Consumer Protection Act, 2019,
Consumer Protection (E-Commerce) Rules, 2020 and Information Technology (Reasonable
security practices and procedures and sensitive personal data or information) Rules, 2011.
Definitions:
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"Act" means the Information Technology Act, 2000 (21 of 2000);
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“Company” means Vstaarplus Lifestyle Private Limited.
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“Concerned person” means direct sellers, customers, C&F, employees of the Company.
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"Cyber incidents" means any real or suspected adverse event in relation to cyber security
that violates an explicitly or implicitly applicable security policy resulting in unauthorized
access, denial of service or disruption, unauthorized use of a computer resource for processing
or storage of information or changes to data, information without authorization;
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"Data" means representation of information, knowledge, facts, concepts or instructions
which are being prepared or have been prepared in a formalized manner, and is intended to be
processed, is being processed or has been processed in a computer system or computer network,
and may be in any form (including computer printouts magnetic or optical storage media,
punched cards, punched tapes) or stored internally in the memory of the computer
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"Information” includes [data, message, text,] images, sound, voice, codes, computer
programmes, software and data bases or micro film or computer-generated micro fiche
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"Intermediary with respect to any particular electronic records, means any person who on
behalf of another person receives, stores or transmits that record or provides any service with
respect to that record and includes telecom service providers, network service providers,
internet service providers, web-hosting service providers, search engines, online payment sites,
online-auction sites, online-market places and cyber cafes
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"Password" means a secret word or phrase or code or passphrase or secret key, or encryption
or decryption keys that one uses to gain admittance or access to information;
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"Personal information" means any information that relates to a natural person, which, either
directly or indirectly, in combination with other information available or likely to be available
with a Company, is capable of identifying such person.
Sensitive personal data and information
Sensitive personal data or information of a person means such personal information which
consists of information relating to; —
- password;
-
financial information such as Bank account or credit card or debit card or other
payment instrument details;
- physical, physiological and mental health condition;
- sexual orientation;
- medical records and history;
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any detail relating to the above clauses as provided to Company for providing service;
and
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any of the information received under above clauses by Company for processing,
stored or processed under lawful contract or otherwise
Need of your Information
As per the company policy, there is no requirement to provide above mentioned sensitive
personal data and information in our general procedures. However, in certain specific
circumstances as per law such as placing order, providing commission to direct sellers,
requiring personal information related with medical record and history while conducting any
routine health check-ups/or to buy a particular product. The company ensures that all the
information shall be collected as per the provision of the Information Technology (Reasonable
security practices and procedures and sensitive personal data or information) Rules, 2011.
Collection of Information
- Consent as per your choice
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Without your acceptance or permission, we don’t receive any personal/sensitive from
your side.
-
However, Company obtain consent in writing through letter or Mobile OTP or email
from the provider of the sensitive personal data or information regarding the use of such
information
- Collected for lawful purpose
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The Company shall not collect any sensitive personal data unless the information has
been collected for the lawful purpose, required for the functioning of the company and
has been considered necessary for that purpose.
- Your information is in your knowledge
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The company shall take reasonable steps to ensure that the concerned person, from
whom the information is collected, must have the knowledge of
- The fact that the information is being collected
- The purpose for which the information is being collected
- The intended receipts of information
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The name and address of person who will be collecting and retaining the
information.
- Not hold information for the longer period of time
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The company or any other authorized person not retains the information for longer
that it is required under any law for the time being in force.
- Information shall be used for the relevant purpose only
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The collected information shall be used for the relevant purpose for which it is collected.
- Review of information
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The company may ask for updation of your collected information or any further
information, if any required by company or applicable law.
However, the company shall not be considered responsible for the authenticity of the
personal information or sensitive personal data provided by any person.
- Withdrawal of information
The company before providing the information relate with sensitive personal data provides
an option with the provider of the information regarding not providing the information.
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The provider of information shall at any time while availing the service possess the
option to withdraw the consent.
- The withdrawal of consent shall be in writing.
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However, in the case provider of information not providing or later on withdrawing the
consent, the Company shall possess the option not to provide the goods and services
for which the information was sought.
- Address discrepancies or grievances
- The company shall address any discrepancies or grievances of information provider.
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In accordance with this provision, the company shall appoint a Grievance Officer that
shall redress the grievances within 1 month from the date of receiving.
Disclosure of Information
- Disclosure of information to Third Party
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Prior approval: Disclosure of information by Company to any third party will require
prior approval from the provider of the information.
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Sharing of information with parties: The information be shared, without obtaining
prior consent from provider of information, with Government agencies mandated under
the law to obtain information including sensitive personal data or information for the
purpose of verification of identity, or for prevention, detection, investigation including
cyber incidents, prosecution, and punishment of offences
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Not Publish sensitive personal data: The Company shall not publish the sensitive
personal data.
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Information received by third party: The third party after receiving the sensitive
personal data or information from the Company shall not disclose it further.
To whom your Personal Data may be disclosed:
We may disclose your Personal Data for the above purposes to other parties including:
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Other group companies and any subcontractors, direct seller, agents or service providers
who work for us or provide services to us or group companies (including their
employees, sub-contractors, service providers, directors and officers)
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Law Enforcement Authorities, Government Authorities, courts, dispute resolution
bodies, our regulators, auditors and any party appointed or requested by our regulators
to carry out investigations or audits of our activities
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Statutory and regulatory bodies and authorities (including the government)
investigating agencies and entities or persons, to whom or before whom it is mandatory
to disclose the Personal Data as per the applicable law, courts, judicial and quasi-
judicial authorities and tribunals, arbitrators and arbitration tribunals
- Overseas regulators
- Anybody else that we’ve been instructed to share your Personal Data with by you.
Transfer of Information
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Transfer the data: The Company or any other authorized person can possess the
authority to transfer the sensitive personal data or information including any person, to
any other person or company.
However, that said party need to ensures same level of data protection that is adhered
to by the Company.
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Allowed: The transfer of information may be allowed only if it is necessary for the
performance of the lawful contract between the Company or any person on its behalf
and provider of information or where such person has consented to data transfer.
For Reasonable Security Practices of above mentioned sensitive personal information
Complied with all aspects: We comply and follow international Standard IS/ISO/IEC 27001
on "Information Technology - Security Techniques - Information Security Management
System Requirements” for the sensitive personal data and information.
Notification of changes
We keep our sensitive personal information protection policy under regular review to make
sure it is up to date and accurate. Any changes we may make to this Policy in the future will be
posted on this page. We recommend that you re-visit this page regularly to check for any
updates.
For any additional questions or support, reach out to data@vstaarplus.in