PRIVACY POLICY

Last updated: 25/03/2025

We, Studds Accessories Limited (“the Company or the Studds or Data Controller or Data Processor”), respect the privacy of individuals and have implemented reasonable security practices and procedures that are commensurate with the information assets being protected and with the nature of our business.

The purpose of this privacy policy (“Policy”) is to set out the process and the framework within which the Company collects, receives, stores, deals or handles Personal Information including Sensitive Personal Data or Information and to comply with Information Technology Act, 2000, Digital Personal Data Protection Act, 2023, as amended from time to time.

This privacy policy describes the information about you that Studds collects through this website, how that information is used, maintained, shared, protected and how you can update it. It also applies to all personal data received by Studds from the Europe or European Economic Area (“EEA”) or in any format, including electronic or paper.

The Policy shall become effective from March 25, 2025

In this Policy, unless the context otherwise requires:

1. 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 the Company, is capable of identifying such person such as Name, qualifications, contact details (email address, phone numbers, physical address), spoken language(s), gender, date of birth, Voter ID, passport number, PAN Card, marital status, dependents, emergency contact details, photograph etc.
2. ‘Sensitive Personal Data or Information’ of a person means such Personal Information which consists of information relating to:
   
   1. 1. password;
      2. financial information such as bank account or credit card or debit card or other payment instrument details;
      3. physical, physiological and mental health condition;
      4. sexual orientation;
      5. medical records and history;
      6. biometric information;
      7. any detail relating to above clauses as provided to the Company for providing service; and
      8. any of the information received under any of the above Clauses by the Company for processing, stored or processed under lawful contract or otherwise:

   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 Sensitive Personal Data or Information.

3. The words and expressions used in this Policy but not defined herein but defined in the Information Technology Act 2000 (“IT Act”) or the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011 (“IT Rules”) shall have the meanings assigned to them thereunder.

DEFINITIONS

For the purposes of this Privacy Policy:

1. Account: means a unique account created for you to access our website.
2. Cookies:are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses. Cookies help inform websites about the user, enabling the websites to personalize the user experience.
3. Device:means any device that can access the website such as a computer, a mobile device or a digital tablet.
4. Personal Data:means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available is capable of identifying such person.
5. Service Provider: means any person or legal entity who processes the personal information on behalf of the Studds as may be shared by Studds.
6. Usage Data: refers to data collected automatically, either generated by the use of the website or from the website infrastructure itself (for example, the duration of a page visit).

INFORMATION ABOUT US

We process personal information as a controller and processor.>/p>

If you have any questions or complaints regarding our processing of your personal information as a controller, please contact us using the contact information provided below underGRIEVANCE REDRESSAL.

Our business in foreign countries is developed through our affiliates, consultants, distributors and subsidiary. Personal information collected in connection with products, goods, and services provided by, and other business activities conducted by our affiliates, distributors and subsidiary is processed in accordance with their privacy policies/notices. Therefore, if you have any questions regarding their processing of your personal information, please contact them using the contact information provided in their privacy policies.

INFORMATION WE COLLECT

Mode of information collection

1. 1. We collect your information either directly from you through online documentation and/ or the Website. We may also collect information when you visit any of our offices to enquire about or avail our Services or attend conferences, seminars, webinars, or other events organised by us. You agree and acknowledge that such information is collected and processed for fulfilling purposes mentioned below and Consent to Our collection thereof.
2. 2. We may collect information about you from third parties such as service providers to provide relevant services, offers and marketing services and the same would be used & processed with your Consent only. We, including our service providers may monitor, record and retain your conversation and/or electronic communication between you and us or otherwise as deemed approved.
3. 3. We may also collect Personal Information (which may include Sensitive Personal Data or Information) that is voluntarily provided to us for our business and through responses to job postings, queries, complaints, feedback, etc.

Information we process about You includes

1. 1. Personal data comprises all the details that we collect and process directly or indirectly about you as an individual, for instance personal information including but not limited to Your name, email address, mobile number.
2. 2. We may also automatically collect information about the devices you use to interact with our website. The information we automatically collect may include IP address, device identifier, web browser, and browsing information collected through cookies, web beacons, and other similar technologies (collectively “Cookies and Other Tracking Technologies”) on our Sites.

USE OF INFORMATION

We may process your personal data where such relevant personal information is required to be processed for legitimate purposes as follows, but not limited to:

1. Providing products and services,
2. Monitoring and improving our website and its content,
3. Conducting market research and surveys with the aim of improving our products and services,
4. Sending you information about our products and services for marketing purposes and promotions, for which appropriate Consent is taken,
5. Complying with applicable local or foreign law, regulation, policy, voluntary codes, directive, judgement, or court order, as well as any contractual obligation pursuant to agreements between Us and any authority, regulator or enforcement agency or body or any request coming from said entities,
6. Establishing, exercising, or defending legal rights in connection with legal proceedings (including any prospective legal proceedings) and seeking professional or legal advice in relation to such legal proceedings,
7. Surveillance of premises. (Video Recording),
8. To process your requests (such as replying to your queries)

We will only use your personal data for the purposes for which we collected it. We will keep and use it to enable us to run the business and manage our relationship with you effectively, lawfully and appropriately, whilst you are associated with us and after our association ends. If you fail to provide this data, we may not be able to fulfil our contractual obligation, or we may be prevented from complying with our legal obligations. It is important that the personal data we hold about you is accurate and current.

We may share your personal data with third parties and/or other internal group companies. We require third parties and other entities to respect the security of your data and to treat it in accordance with our instructions, and in a way that is consistent with and which respects the regional laws on data protection.

LAWFUL BASIS OF PROCESSING

Consent: In some cases, we ask you for your Consent to process your personal data, you can withdraw your Consent at any time, which will not affect the lawfulness of the processing before your Consent is withdrawn. If you would like to withdraw your Consent, you can do so by contacting us, however, your withdrawal of Consent will not impact Processing of your personal information by us for legitimate purpose such as Processing in compliance with applicable laws or under instruction of government authorities.

Legitimate Interest: We process certain data for the legitimate interests of the Company, its affiliates, partners, customers, or in compliance with applicable laws including notice from government authorities. These legitimate interests include, for example, contacting you to provide support or sending you marketing information (subject to applicable law); detecting, preventing, and investigating illegal activities and potential security issues; and maintaining and improving the Website and applications. The company will take all reasonable efforts while relying on its legitimate interests for Processing personal data only after balancing our interests and rights against the impact of the Processing on individuals.

Performance of a Contract: We also process personal data on the basis of contractual necessity, where it is necessary for the performance of a contract or pre-contractual steps at your request.

Other Legal Basis: In some cases, we may have a legal obligation to process your personal data, such as in response to a court or regulator order. We also may need to process your personal data to protect vital interests, or to exercise, establish, or defend legal claims.

OUR POLICY CONCERNING CHILDREN AND THEIR DATA

1. We are committed to protecting the privacy and safety of children. In certain circumstances, we may process personal data of children for associated services and social service initiatives. However, we take utmost care to comply with applicable laws and regulations regarding the Processing of children’s personal data.
2. When processing such data, we take reasonable efforts to obtain appropriate Consent from parents or legal guardians, in accordance with the relevant legal requirements. We ensure that the collection, use, and disclosure of children’s personal data is limited to what is necessary for the intended purposes and is done in a secure manner.
3. If you believe that we may have inadvertently collected personal data from a child without proper Consent or have any concerns regarding the Processing of children’s data, please contact us through email at customercare@studds.com or after filling the Contact Us page of our website (https://smkhelmets.com/contact-us/) and we will take reasonable endeavors to promptly address the issue. We encourage parents and guardians to actively participate in and supervise their children’s online activities to ensure their privacy and safety.

RECIPIENTS OF DATA

Your personal data processed by the company will only be accessible by a limited list of recipients on a need-to-know basis or where required by law.

Within our organization:

Within our organization, access to your data is limited to those persons who as per company’s internal policies and procedures are authorized and require access in order to provide you with the Products and Services, and to respond to your inquiries.

1. Third party(ies):

   We may use service providers & Third parties for operating and improving the function of website and services being offered. We endeavour to ensure that these service providers access, process, and store information about you only for the purposes we authorize, through the execution of relevant instrument in this regard.

   Further our service may contain links to other websites that are not operated by us. if you click on a third-party link, you will be directed to that third party’s website. We strongly advise you to review the privacy policy of every website you visit.

   We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party websites or services.

2. Authorities:

   We may access, preserve, and disclose information about you to government authorities, if we believe Disclosure is in accordance with or required by, applicable law, regulation, legal process, or audits. We may also disclose information about you if we believe that your actions are grossly inconsistent with our policies, and/or it affects the rights, property and reputation of the Company or others.

3. Transfer of business:

   If we (or our assets) are merged, amalgamated, acquired, transferred or if we go out of business, enter bankruptcy, or go through some other change of control, personal information could be one of the assets transferred to or acquired by a Third party.

SECURITY PRACTICES & RETENTION OF PERSONAL INFORMATION

The Company has implemented reasonable security practices and procedures (including appropriate managerial, technical, operational and physical security control measures) to ensure that the Personal Information and Sensitive Personal Data or Information is collected and preserved in a secure manner. The database is stored on servers secured behind a firewall and the access to servers is limited and password protected.

Your personal data is processed and retained securely for no longer than is necessary for the purposes for which the personal data was collected or unless required as per the applicable laws. At the expiry of such periods, your personal data will be deleted or archived to comply with legal retention obligations or in accordance with applicable statutory limitation periods.

INFORMATION PROVIDER’S RIGHTS IN RELATION TO THEIR SENSITIVE PERSONAL DATA OR INFORMATION COLLECTED BY THE COMPANY

1. All Sensitive Personal Data or Information provided to the Company by an information provider is voluntarily provided by such information provider.
2. The information provider may write to the Grievance Officer (Or any other designated officer), whose details are provided in Clause below, to access, review, modify or correct his/her Sensitive Personal Data or Information. However, the Company is not responsible for the authenticity of the Sensitive Personal Data or Information provided by the information provider.
3. The information provider shall, at any time while availing the services or otherwise; also have an option to withdraw his/ her consent given in relation to his/ her Sensitive Personal Data or Information. However, please note that withdrawal of consent will not be retrospective in nature and shall be applicable prospectively. Such withdrawal of the consent shall be sent in writing to the Company at customercare@studds.com . In case the information provider does not provide his/ her information or consent for usage of Sensitive Personal Data or Information or subsequently withdraws his/ her consent for usage of the Sensitive Personal Data or Information so collected, the Company reserves the right to discontinue the services for which the said information was sought.

GRIEVANCE REDRESSAL

Any discrepancies and grievances with respect to processing of Personal Information and Sensitive Personal Data or Information shall be immediately informed to the designated Grievance Officers or Data Protection Officer ) as mentioned below:

Name: Mr. Varun Chopra
Designation: Vice President – IT
Email ID: privacy@studds.com

Mr. Varun Chopra is also designated as Data Protection Officer under Digital Personal Data Protection Act, 2023 and General Data Protection Regulation (Regulation (EU) 2016/679) as amended from time to time.

Name: Ms. Jyoti Puri
Designation: Senior Manager – HR
Email ID: privacy@studds.com

CONDITIONS OF USE, NOTICES, AND REVISIONS

If you choose to use our services, your use and any dispute over privacy is subject to this notice and Studds Accessories Ltd or its directors, officers, employees, agents or representatives (collectively “representatives”), including limitations on damages, resolution of disputes, and application of the prevailing law in India. If you have any concerns about privacy on our website, please contact us with a thorough description, and we will try to resolve it.

RESTRICTION OF LIABILITY

We make no claims, promises or guarantees about the accuracy, completeness, or adequacy of the contents available through the Services and expressly disclaim liability for errors and omissions in the contents available through the Services.

No warranty of any kind, implied, expressed or statutory, including but not limited to the warranties of non-infringement of third-party rights, title, merchantability, fitness for a particular purpose and freedom from computer virus, is given with respect to the contents available through the Services or its links to other internet resources as may be available to you through the Services.

Reference in the Services to any specific commercial products, processes, or services, or the use of any trade, firm or corporation name is for the information and convenience of the public, and does not constitute endorsement, recommendation, or favouring by STUDDS.

CHANGES TO THIS POLICY

The Company reserves the right to revise and update this Policy at its sole discretion. Any such revisions will be effective on and from the date of posting the same on the website of the Company and will apply to all information collected both prior to and following the effective date.

By entering this website, the visitor consents to the terms of this Policy. By submitting his/her Personal Information and Sensitive Personal Data or Information to the Company, the visitor will be treated as having given his/her permission for processing the same in a manner provided in this Policy.