Privacy Policy


Smollan India Private Limited (“Smollan” or “We”)

  1. Smollan believes in protecting the Sensitive Personal Information (defined hereinafter) it collects from persons that access or use (“Users” or “you”) the website situated at (“Website“).


  1. By accessing the Website, Users agree to be bound by this privacy policy (“Privacy Policy”) effective at the time of any such access. This Privacy Policy forms part of the Smollan Website standard terms and conditions (“Terms and Conditions”) available at [] and is to be read in addition to the Terms and Conditions. In the event of any inconsistency or ambiguity arising between the Terms and Conditions and the terms of this Privacy Policy, the provisions in this Privacy Policy shall prevail to the extent of such inconsistency or ambiguity.


  1. Smollan reserves the right in its sole discretion to amend this Privacy Policy from time to time. In this event, Smollan will post the revised Privacy Policy on the Website. Each time a User accesses the Website, the User agrees to be bound by the Privacy Policy posted on the Website at that time.


  1. Smollan will take all reasonable steps to use or disclose Users’ Personal Information only in the manner allowed by this Privacy Policy.


  1. The Personal Information or Sensitive Personal Data or Information collected hereto shall be collected by:

Grievance Officer

And retained by:

Smollan India Private Limited


  1. User information

Personal information (“Personal Information”) refers to information that relates to a User which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying the User and shall include all private information about an identifiable individual, including, but not limited to, a user’s name, contact details, identity number, income levels, age, personal views and preferences.

Sensitive personal data or information (“Sensitive Personal Information”) of a User refers to Personal Information regarding the User’s password, financial information such as details of bank accounts, credit/ debit cards and other payment instruments, physical, mental or physiological health, sexual orientation, medical records and history, biometric data, and any such data provided to Smollan on the Website or in relation to the Services (defined hereinafter) or for processing, stored or processed under lawful contract or otherwise, provided that any information which 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 Information


  1. Active collection of Sensitive Personal Information

The Website actively collects personal information from Users by asking Users specific questions and by permitting Users to communicate directly with Smollan or its permitted representatives, for example via e-mail and/or chat windows.

Some areas of the Website may also require the User to submit Sensitive Personal Data or Information in order for the User to register for certain services or benefit from specified features (for example newsletter subscriptions, tips/pointers, employment opportunities) or to participate in a particular activity (such as competitions or other promotions) (collectively referred to as the “Value Added Services“).

In these situations, Smollan will ask the User for particular information, and inform the User at each information point what information is required and what information is optional. Users may choose not to provide such information. However, doing so may impact the Users’ usage or ability to access the features of the Website or Services.


  1. Passive collection of Personal Information

Smollan passively collects (i.e. without the User actively providing the information) Personal Information about a User as the User accesses and navigates through the Website using various technologies and means, such as navigational data collection and cookies.

A cookie is an alphanumeric identifier which Smollan’s computer system transfers to a User’s hard drive through the User’s web browser when the User visits the Website. It enables Smollan’s system to recognise the User when the User visits the Website again and to improve the Services (defined hereinafter) made available to the User.

This enables Smollan to diagnose problems with its server, report and aggregate information, determine the fastest route for a User’s computer to use in connecting with the Website, and better administer and improve the site.

Please note that Users may disable the use of cookies by configuring the User’s browser accordingly. However, doing so may impact the Users’ usage or ability to access the features of the Website or Services. Kindly refer to Smollan’s cookie policy [insert hyperlink] for further details.

User shall request the Grievance Officer to rectify or amend any personal information or information which is found to be inaccurate or deficient. Smollan shall not be responsible for the authenticity of the personal information or sensitive personal data or information supplied by the User.


  1. Option to withdraw consent

User shall, at any time while availing the services or otherwise, also have an option to withdraw its consent given earlier to Smollan. Such withdrawal of the consent shall be sent in writing to Smollan. In case of User not providing or later on withdrawing his consent, Smollan shall have the option not to provide services for which the said information was sought.


  1. Consent to collection, use and storage of information

The User agrees that Smollan may collect, use and store the User’s Personal Information and/or Sensitive Personal Information:

  • to establish and verify a User’s identity;
  • to maintain and update Smollan’s customer, or potential customer, databases;
  • to greet the User when he/she accesses the Website;
  • to provide the User with Value Added Services;
  • to communicate with the User;
  • to customise and improve the Website to Users’ preferences;
  • to inform the User of facts relating to his/her access to and use of the Website;
  • to improve the content of the Website or any of the services provided by Smollan (“Services“);
  • to inform the User about competitions, promotions and special offers from Smollan;
  • for marketing, product research and development purposes of Smollan;
  • to provide the User with targeted advertising when the User accesses the Website or other websites of Smollan or its affiliates; and
  • to compile, use, disclose, store, transfer and trade with, non-personal statistical information about browsing habits, click-patterns, User preferences and access to the Website.


  1. Disclosure of User’s Sensitive Personal Information

Smollan will not disclose, for commercial gain or otherwise, Users’ Sensitive Personal Data or Information other than as set out in this Privacy Policy without the User’s consent.

Notwithstanding the foregoing, the User agrees and hereby consents that Smollan may disclose the User’s Sensitive Personal Information.

  • to Smollan’s affiliates;
  • to third parties contracted or employed by Smollan to provide services for or to Smollan, including for example, Website hosting and development, web analytics, technical support, financial services such as processing of credit card or other payments, delivery services, and other support services in relation to the Website and the Services. These third parties require access to Users’ Personal Information to perform their functions and not for any other purposes and Smollan will take all reasonable steps to ensure that the same level of data protection as provided by Smollan to the Users shall be provided by the relevant third parties or companies or service providers to the Users;
  • to any third party who acquires all, or substantially all, or a controlling interest in all, of the assets or shares in Smollan, any of Smollan’s affiliates, and/or the Website, whether by sale, merger, acquisition or otherwise; and
  • without consent of the User to governmental agencies, exchanges and other regulatory or self-regulatory bodies if Smollan is required to do so by law or if Smollan believes that such action is necessary to–
    • comply with the law or with any legal process or the Terms and Conditions;
    • protect and defend the rights, property or safety of Smollan, its affiliates or their customers, or visitors of the Website or Users of the Services;
    • prevent or deal with fraud or the abuse, misuse or unauthorised use of the Website; and/or
    • protect the rights, property or safety of members of the public (if a User provides false or deceptive information about him/herself or misrepresents him/herself as being someone else, Smollan will proactively disclose such information to the appropriate regulatory bodies and commercial entities).
    • with Government agencies mandated under the law to obtain information including sensitive personal information for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences.
    • shall be disclosed to any third party by an order under the law for the time being in force.

The User agrees that Smollan may use the User’s Sensitive Personal Data or Information to compile profiles for statistical purposes and may freely trade with such profiles and statistical data, provided that the profiles or statistical data cannot be linked to the User by a third party.


  1. Transfer of information

Smollan or any person on its behalf may transfer any information, including sensitive personal information, to any other body corporate or a person in India, or located in any other country, that ensures the same level of data protection that is adhered to by Smollan as provided for under these Rules. The transfer may be allowed only if it is necessary for the performance of the lawful contract between the body corporate or any person on its behalf and Smollan or where User has consented to such data transfer.


  1. Smollan undertakes that it shall not retain your Personal Information/Sensitive Personal Information or Data for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force.


  1. Smollan undertakes that your Personal Information/Sensitive Personal Information collected shall be used for the purpose for which it has been collected.


  1. Accuracy of information

In order to ensure that the User’s information is accurate, current, and complete, the User may contact Smollan at the contact details below:

Smollan will take reasonable steps to correct or update such information.
Smollan reserves the right to charge the User a fee to cover Smollan’s expenses in this regard.


  1. Unsolicited communications

Should a User not wish to receive electronic communications at any time from Smollan, the User may unsubscribe from such communications by clicking on the “unsubscribe” link in the communication section.


  1. Security

Smollan takes reasonable steps to put in place and maintain electronic procedures and systems with reference to accepted technological standards under the Information Technology Act, 2000 and the rules thereunder–

  • to ensure the accuracy of;
  • to prevent unauthorised access to or disclosure of; and
  • to protect from misuse, loss, alteration or destruction Users’ Sensitive Personal Data or Information.

Users’ Sensitive Personal Information is stored on controlled servers or duly protected Smollan/third party vendor machinery. We endeavour to maintain physical, technical and procedural safeguards that are appropriate to protect User Personal Information. Access is limited to the authorized members and personnel or consultants on a need-to-know basis.

However, the User acknowledges that internet communications and transactions are not 100% secure or error free. In particular, information may not be secure in transit from the User to the Website and Smollan takes no responsibility for the same.

Moreover, the User acknowledges that it is the User’s responsibility to safeguard its Sensitive Personal Information.


  1. Linking to third party websites

Smollan is not responsible for the privacy practices of third party websites to which there may be links on the Website or which Users may access in relation to the Services or Value Added Services or which may be provided in communications or content sent to the User by Smollan. Smollan advises Users to read the privacy policy of each Website which the Users visit.


  1. Queries and complaints

In accordance with the Information Technology Act, 2000 and the rules thereunder, if a User has any queries or complaints concerning this Privacy Policy and its application, the User may contact the Grievance Officer at . The Grievance Officer shall endeavour to redress any grievances at the earliest and no later than one month from the date of receipt of grievance


  1. Governing Law and Jurisdiction

These terms and conditions and the relationship between Users and Smollan will be governed by the laws of the Republic of India.

You consent to the jurisdiction of the courts of Mumbai in respect of any proceedings instituted by either party in terms of these terms and conditions. In the event that legal proceedings are instituted by either party against the other, the unsuccessful party will pay the costs of the successful party on an attorney and own client scale.