PRIVACY POLICY  

This privacy policy (“Privacy Policy”) along with the Terms of use (hyperlink) (“Indulge Global Policies”), are legally binding electronic records as prescribed under the Information Technology Act, 2000 (as may be amended, modified, re-enacted, consolidated or replaced from time to time) and any/all rules made thereunder, including but not limited to those prescribed under different statutes pertaining to electronic records as applicable and amended from time to time.

The Indulge Global Policies together apply to the Services (defined below) available on the Platform (defined below)  which is owner, hosted and maintained by Pricetime Technologies Private Limited (hereinafter referred to as  “Indulge Global”, “Our”, “We”, or “Us”, which expression shall, unless repugnant to the context or meaning  thereof, be deemed to include its successors, legal representatives and permitted assigns) having its registered office  at 1-65/123, Amar Co-op. Society Near Durgam Cheruvu, Madhapur, Hyderabad, Rangareddi, Telangana – 500081,  India.

This Privacy Policy is intended to provide users who access or browse and/or signup/register themselves on the  Platform (“User” or “Users” or “You(r)” or “Your”) with complete information about the data and the Information  that Indulge Global collects, receives and collates in connection with the Services (defined below) and the way that  such information is stored and used. Hence, this Privacy Policy constitutes a legally binding Agreement between  You and Indulge Global, and governs the usage practices that apply to the Platform including the information and/or  database that the Platform gathers (categorized as mandatory or optional) and how the same is received, collected,  used, held, shared and protected.

Indulge Global, recommends that You review this Privacy Policy carefully to understand the privacy practices We  follow. You may approach Karan, our Grievance Officer, at Karan@indulge.global and info@indulge.global to  address any queries, concerns, discrepancies or grievances with respect to this Privacy Policy. 

Any terms used herein which begin with a capitalized letter shall have such meaning as assigned to it under  the Terms of use or under the respective clauses of this Privacy Policy.

BY USING OUR SERVICES OR BY OTHERWISE GIVING US YOUR PERSONAL  INFORMATION, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY AND CONSENT TO  COLLECTION, RETENTION AND USE OF YOUR INFORMATION AS PER THE APPLICABLE LAW.

1. BACKGROUND

1.1. Indulge Global, inter alia, offers a members-only online platform to the Users for accessing concierge and  luxury lifestyle management products and services, including arranging travel and restaurant bookings,  flowers, gifts, hotel accommodations, luxury goods, tickets for premium events, auctions and e-commerce in  India (“Services”). The Services are offered through the online/digital website and mobile application  (whether android or IOS) owned, operated and hosted by Indulge Global, and downloadable from third party  service providers, including any updates thereof, through which Users, can access premium concierge and  lifestyle management products/services (“Platform”).

1.2. We at Indulge Global value the trust that Users place in Us and take there privacy very seriously. We are  committed to safeguarding Your privacy while providing a personalized and valuable access to Our Platform.

2. ACCEPTANCE OF THE PRIVACY POLICY

2.1. You accept this Privacy Policy by accessing the Services and expressly consent to Our collection, use,  disclosure, and retention of Your Information as described in this Privacy Policy. If You do not agree to  this Privacy Policy and/or to Our processing of Your data/information in the manner outlined herein,  please do not use this Platform or submit any Information to Us. 

2.2. No Information collected through the Platform is rented or sold to any third party by Us, unless expressly consented to by You. When Your use Our Services, a high standard of security is maintained by Us in respect  of Information collected from You, however, You agree and understand that transmission of information via internet or telephone networks is not completely secure. While Indulge Global does its best to protect the  Information, particularly Your Personal Information, We cannot ensure the security of Your data transmitted  via the internet, telephone or any other networks which are not in Our control. 

2.3. Indulge Global has the right to amend the Privacy Policy without any prior notice to You. To make sure  You are aware of changes, please read this Privacy Policy periodically. Your continued use of the  Platform following the posting of changes to this Privacy Policy will be deemed Your acceptance of  those changes.

2.4. You have a legal right to a copy of Your Personal Information held by Us and to correct any errors in  such Personal Information. You also have a right to request that Indulge Global cease to use Your  Personal Information for direct marketing purposes, unless agreed to the contrary under the Terms, by  emailing us in the manner as prescribed above.

3. INFORMATION COLLECTED 

3.1. You, by way of this Privacy Policy understand and accept that Indulge Global through the Platform and its  Services collects, stores and uses certain “Personal Information” in order to provide the Services to You.  For the sake of clarity this Personal Information means any information that may be used to uniquely identify  an individual, including but not limited to the following: 

(a) Information about Your personal identity inter alia, as name, date of birth, age and sex.

(b) Your contact details such as Your address, postal code, telephone or mobile number and facsimile.

(c) User ID information such as Your username, email address and other security-related information used  by You in relation to access and use of Our Platform/Services and/or Content. However, the password and username of Your Registered Account with the Platform automatically gets saved in Indulge Global’s server when You create a Registered Account which shall not be accessed by Indulge Global unless desired under any legal obligation

(d) In order to provide Services, Indulge Global automatically track and collect the following categories of  information when You access and/ or use the Platform/Services (“Traffic Data”): 

• IP addresses;
• Domain server details; and
• Other information with respect to Your device, interaction of Your device with the Platform,  other Services and application.

(e) Information relating to payment instruments, including credit card, debit card and any other payment  instrument used to pay on the Platform.

(f) Your use of the Platform such as the date and time You visit, the sections or pages You visit, the amount  of time You spend viewing the Platform, visits to website outside Our network, and other click-stream data.

(g) any other personally identifiable information provided by You in any form during any interaction or  communication with Indulge Global, its Vendors or any other users of Our Platform.

3.2. When You use the Platform, Indulge Global receives, collects and stores Your Personal Information in order  to record, support and facilitate Your participation in the Services You select and transactions You undertake  (including to facilitate and process payments), track Your preferences, to provide You with a customized  browsing experience, to notify You of any updated information and new activities, services, and other related  functions offered by the Platform/Services, keep You informed about latest content available on the Platform,  special/promotional offers, and other facilities, services of the Platform, to assist You with customer service  or technical support issues, to follow up with You after Your usage and, for research and development  purposes. For the aforesaid purpose, Indulge Global only collects such Personal Information that We consider  relevant to understand You or Your interests.

3.3. We may transfer alphanumeric identifiers to Your device through Your browser to enable Our systems to  recognize You, remember information specific to You and/ or provide certain features to You (“Cookies”).  We may place both permanent as well as temporary Cookies in Your device, however, such Cookies shall not  contain any of Your Personal Information. We do not control and are not liable for any Cookies placed by  third parties on Your device.

3.4. You acknowledge and accept that acknowledges and accepts that the Services offered by Indulge Global on  the Platform are provided through third party service providers, including but not limited concierge or brand  managers or their employees, agents and/or service providers, who possess the necessary expertise, skill and  resources to provide the Services to You (“Vendors”). Hence, certain Personal Information may also get  collected and shared with such Vendors for

(i) logistics and delivery of the Services ordered through the  Platform;

(ii) rendering of the Services on behalf of Indulge Global;

(iii) assuring Platform’s security,  maintenance, repair or other technical reasons. If there is Content from the Platform that You specifically and  knowingly upload, share or transmit to an email recipient, online community, website, platform or to the  public, for instance in the form of uploaded photos, posted reviews or comments, or information about You  or anything posted by You that You choose to share with others through features which may be provided on  Our Platform. Such uploaded, shared or transmitted Content will also be subject to the privacy policy of the  email, online community, website, platform, social media or other similar medium to which You upload, share  or transmit the Content. 

3.5. Indulge Global may access information about You from third-party sources and  platforms/website/applications (such as social networking applications, platforms, databases, online marketing  firms, and ad targeting firms), including when You access third-party social networking services (such as  WhatsApp or Twitter etc.) through the Platform/for the Services. Indulge Global may collect certain  information and/or any personal data that is part of Your profile on such third party social network service and  that You allow that third party social network services to share with Us (e.g. name, email address, gender,  birthday, city, profile picture, user ID, friend list). Further, We may gather Your demographic data (such as  age range, gender, buying behavior, preferences and interests), advertisement interaction and viewing data,  (such as ad click-through rates and information about how many times You viewed a particular ad).

3.6. Please note that the Platform may combine the information that Indulge Global collects with information  gathered from third-party sources for the purpose of facilitating Your experience and/or for rendering the  Services. Some of this information may be shared with partners who referred You to the Platform and who  will use the data to optimize who else they may refer to the Platform. Sometimes this information can be  shared with partners who help Indulge Global deliver ads to You on the Platform not controlled by Us.

3.7. In addition to the above, We may collect information about how You use Our Website such as the date and  time You visit the Website, the sections or pages of the Website that You visit, the amount of time You spend  viewing the Website, the number of times You return to the Website, visits to Website outside Our network,  and other click-stream data. Some of this information may be shared with partners who referred You to Our  Website and who will use the data to optimize who else they may refer to Our Website. Sometimes this  information can be shared with partners who help Us deliver ads to You on Websites not controlled by Us 

3.8. Traffic Data, Personal Information and such other information as may be collected pursuant to this Privacy  Policy, together constitute the information collected by Indulge Global pursuant to Your use of Our Platform  and/ or Services (“Information”).

4. USE OF INFORMATION COLLECTED 

4.1. Indulge Global uses the Information collected in such manner that enables Us to provide the Platform, Services  and/ or any parts thereof to You in an effective way and route You through the relevant information that meets  Your need. This includes using Information collected to:

(a) assist You in accessing the Services and/ or any part(s) thereof, and processing Your login for the  Platform and/or identifying You as a User.

(b) build Your Registered Account and render the Services availed by You including completing and  fulfilling Your purchase, process payments and send notifications in this regard.

(c) prevent any potentially illegal activity and to screen and prevent undesirable or abusive activity during  provision of Services and/ or any part thereof.

d) monitor, maintain, troubleshoot and/ or improve the Services and/ or any associated features, including  evaluation of or devising new features for the Platform.

(e) perform statistical and/ or other analysis of the Information collected.

(f) analyze and measure Your behavior and trends, to increase Our Platform’s functionality, update new  features, detect, prevent and address security & technical issues, and to better tailor Our content, services and design to suit Your needs so as to provide a smooth, efficient, safe and customized  experience while using the Platform.

(g) use read_phone_state permission to check if Your device is connected to the internet or not; and/ or 

(h) audit Your usage of the Platform or Services.

(i) help Us respond to Your customer service requests and support needs, more efficiently. 

4.2. Indulge Global does not sell, rent, trade or exchange any Information of Users, except as specified in this  Privacy Policy or without obtaining prior written consent from the User. In addition to Clause 4.1 above, We  may use the Information Collected (including Personal Information in aggregated form) to aid strategic  development, data collection and analytics with respect to the Platform and/ or Services provided by Us and  to manage Our relationships with Our advertisers, partners or any Vendor. To the extent Indulge Global use  Your Information to market to You, We will provide You the ability to opt-out of such uses. 

4.3. The Information Collected shall not be used in any form or manner other than as is described in this Privacy  Policy, specifically Clause 4 of this Privacy Policy, and, while We use Our best efforts to protect all  Information collected, this Privacy Policy is not intended to restrict Our use of Information collected  (“Permitted Use”).

4.4. Indulge Global may also use the Information to provide contents and Services that are targeted to Your  interests. By accepting the Privacy Policy, You expressly agree to receive these communications/information.  If You do not wish to receive these communications, We encourage You to opt out of the receipt of certain  communications in Your profile under Your Registered Account or by clicking unsubscribe any email  communication.

4.5. Indulge Global may use the Information to send You e-mail communications, such as updates, information  about Your account or changes to the Platform, Indulge Global Policies, newsletters, marketing and  promotional messages about Our own or Our marketing partners’ products and services that may be of interest  to You. It may also be used to respond to Your inquiries, questions, and/or other requests. If You signed up  for one of Our email newsletters, We will also send You the newsletters that You requested. If You decide to  opt-in to Our mailing list, You will receive emails that may include Indulge Global news, updates, related  product or service information, etc. If at any time the User would like to unsubscribe from receiving future  emails, We include the unsubscribe tab/provision at the bottom of each email.

IN ADDITION TO THE USES IDENTIFED ABOVE, INDULGE GLOBAL MAY USE THE  INFORMATION THAT WE COLLECT FOR ANY OTHER PURPOSES DISCLOSED TO YOU AT THE  TIME WE COLLECT YOUR INFORMATION.

5. DISCLOSURE OF INFORMATION COLLECTED

5.1. Legal Requests and/or Compliance with Applicable Laws: Indulge Global is invested in always cooperating  with law enforcement and regulatory inquiries, as well as other third parties to enforce laws, such as  intellectual property rights, fraud and other rights, to help protect You and the community. Therefore, in  response to a verified request by any statutory authority including but not limited to law enforcement  authorities or other government officials relating to a criminal investigation or alleged illegal activity, We  may (and You authorize Us to) disclose, as per the applicable laws, any/all of Your Information as is  reasonably necessary to respond /comply with the statutory mandate including but not limited to court  orders, or other legal process. We may access, use, transfer or disclose Your Personal Information to  government or law enforcement authorities or private parties, if it is legally and statutorily required to do so  under any of the following conditions: 

(a) To satisfy any applicable law, rule, regulation, governmental requests or legal process. 

(b) To protect and/or defend and/or enforce Our Privacy Policy for online services or other policies  applicable to any online services in case of potential violations.

(c) To secure Our systems. 

(d) To respond to claims that an advertisement, posting or other Content violates the rights of a third  party. 

(e) To protect the rights, property or personal safety of the Users and the public in general for any reason.

 (f) To detect, prevent or otherwise address fraud, security or technical issues.

(g) To prevent or stop activity We may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity.

5.2. In case of any illegal, unethical or legally actionable activity, Indulge Global may use IP address or other  device identifiers, to identify Users, and may do so in cooperation with third parties such as internet service  providers, wireless service providers and/or law enforcement authorities, including disclosing such  Information to third parties, all in Our discretion. Such disclosures may be carried out without notice to You.  However, Indulge Global shall not sell, share or rent the Users Information to any third party or use any  Users’ e-mail id for sending any unsolicited mails. 

5.3. Other Corporate Entities: Indulge Global may share data, including Information about You, with Our  affiliates, subsidiaries, and joint ventures that are committed to serving Your online requests and related  Services, throughout the world. To the extent that these entities have access to Your Information, they  remain bound by the existing Privacy Policy. As Indulge Global continues to develop this business, We  might sell or buy stores, subsidiaries or business units. In such transactions, Users’ Information generally is  one of the transferred business assets but shall remain subject to the terms and conditions contained in this  Privacy Policy. 

5.4. If You are located outside India and choose to provide Information to Us, please note that Your Information,  including Personal Information, may be transferred to India and/or anywhere around the globe for the  purposes as described and detailed under the Privacy Policy and You hereby unconditionally consent to this  Privacy Policy by Your continued use of the Platform and Your submission of such Information represents  Your agreement to that transfer. 

5.5. Vendors and Third Party Service Providers: Besides the Vendors that provide Services through the Platform,  Indulge Global may employ third party services to facilitate or outsource one or more aspects of the Platform  operations (e.g., search technology, discussion boards, bill collection, affiliate and rewards programs, co branded credit cards) and therefore We may provide some of Your Personal Information to these third-party  service providers. Such third party service providers may analyze the Information, measure actions of Users,  and collate the payments and revenue through google analytics or other tools. These third party service  providers, also, analyze information in statistical form in order to visualize User navigation paths,  understand User groups and use the Information in other related services. However, they are subject to  confidentiality agreements with Us and other legal restrictions that prohibit their use of Your Personal  Information for any other purpose except to facilitate the specific outsourced service. In the event of Your  direct involvement with the third-party service provider, any additional information disclosed by You to  them shall be subject to third party service provider’s own applicable privacy policy and the  Platform/Indulge Global shall not be responsible for the same.

5.6. With Users’ explicit consent: Indulge Global does not sell or rent Users’ Personal Information to third parties  for their marketing purposes, but with Your explicit consent, We may disclose Your Personal Information 

(i) to third parties for their marketing and advertising purposes;

(ii) to send You promotions, notifications,  or other services. However, the Users have the right to opt-out of receiving such marketing communications. 

INDULGE GLOBAL RESERVES THE RIGHT TO DISCLOSE ANY INFORMATION COLLECTED  IF, IN OUR REASONABLE OPINION, SUCH DISCLOSURE IS NECESSARY TO PROTECT AND  DEFEND OUR OR OUR USERS’ RIGHTS, PROPERTY AND/ OR PERSONAL SAFETY; OR A  PERMITTED USE.

6. CONFIDENTIALITY

6.1. Indulge Global uses best efforts to keep confidential any Information collected which is marked  confidential or may be of confidential nature in Our opinion, with the exception of such information  which

(a) was already known to Us prior to collecting such information from You,

(b) was received from  a third party which is not subject to similar confidentiality restrictions,

(c) is independently developed  by Us and/or

(d) is permitted to be disclosed by applicable law.

6.2. Except as otherwise provided in this Privacy Policy, Indulge Global will keep all the Personal Information  private and will not share it with third parties, unless We have a bona fide belief that such disclosure is  necessary for Permitted Use or to comply with a court order or any other legal process, protect Our, Our employees’, Users’ or third parties’ rights, property and/ or safety, enforce the Agreement; and/ or respond to  any claims.

7. SECURITY

7.1. The security of any Personal Information is important to Indulge Global. To protect Personal Information  during transmission and upon receipt, We follow generally accepted industry standards, including the  International Standard IS/ISO/IEC 27001 on “Information Technology – Security Techniques – Information  Security Management System – Requirements”, and the provisions of the Information Technology Act, 2000  and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or  Information) Rules. 

7.2. Although Indulge Global makes best possible efforts to transmit and store all the Information in a secure  operating environment that is not open to public, You understand and acknowledge that there is no such thing  as complete security and We do not guarantee that there will be no unintended disclosures of any Information.  Consequently, Indulge Global cannot ensure or warrant the security of any Information You transmit to Us  and You understand that any Information that You share is done at Your own risk.

7.3. If Indulge Global becomes aware that any of Your Information being disclosed in a manner that is not in  accordance with this Privacy Policy, We will use the best efforts to notify You of the nature and extent of such  disclosure (to the extent We know that information) as soon as reasonably possible and as permitted by law. 

7.4. Pursuant to Your use of the Services, You may access links to third party websites or applications, including  advertisements and/ or promotions. The privacy policies of such third party links are not under Indulge  Global’s control, hence once You leave Our servers, use of any Information provided by You will not be  governed by this Privacy Policy.

8. RETAINING PERSONAL INFORMATION

Unless specified otherwise in this Privacy Policy, Indulge Global reserves the right to retain Your Information  as permitted or required under applicable law. In some cases, even after cancellation of the Registered  Account, Your Information may be retained for the purpose of legal and regulatory compliances, resolving  disputes, archival purposes, concluding activities related to account cancellation, enforcing Our agreements  and Privacy Policy or for any other reason which may be deemed necessary. However, the Information of a  User will get anonymized upon cancellation of a Registered Account except for the abovementioned purposes.

9. CHANGE IN PERSONAL INFORMATION 

You are responsible for maintaining the accuracy of the Personal Information submitted at the time of login.  If there are any changes in Your Personal Information details, You may correct or update such Information.  To do so, please log into Your Registered Account, and You will find an option for editing the Information  You have submitted.

10. DISCLAIMER 

THIS PRIVACY POLICY IS TO BE READ WITH OTHER INDULGE GLOBAL POLICIES WHICH  TOGETHER ESTABLISH THE USE AND LIMITATIONS OF LIABILITY GOVERNING THE USE  OF THE PLATFORM AND OUR SERVICES.

11. INDEMNIFICATION 

11.1. You agree and undertake to indemnify and hold harmless Indulge Global, to the fullest extent permitted by  law, from and against any and all suit, dispute, actions, damages, costs and expenses, if any of whatsoever nature, arising out of or in any way connected with this Privacy Policy, Information and/or Your use or access  of Platform and/or Services. 

11.2. You expressly understand that under no circumstances, including, but not limited to, negligence, shall Indulge  Global be liable to You or any other person or entity for any direct, indirect, incidental, special, or  consequential damages, including, but not limited to damages for loss of profits, goodwill, use, data or other  intangible losses, resulting from circumstances, including but not limited to:

(i) unauthorized access to or  alteration of Information;

(ii) any unauthorized access to or use of Our secure servers and/or any and all  Information stored therein. 

11.3. You represent that You have accessed the Platform/Services and have provided Information on Your own  initiative and are responsible for compliance with all applicable laws including, but not limited to, any  applicable laws. This Privacy Policy is governed by the laws of India and the courts at Hyderabad shall have  exclusive jurisdiction.

12. UPDATES AND CHANGES TO PRIVACY POLICY

12.1. Indulge Global reserves the right, at any time, to add to, change, update, or modify this Privacy Policy so You  must review it frequently. Although, We will endeavor to inform You of any changes incorporated in this  Privacy Policy that are significant (in Our opinion), however, the same can be changed with or without prior  notice to You, and hence, You are requested to regularly visit this page.

12.2. You signify that You have carefully read, understood and agree to be bound by the Privacy Policy (as may be  amended from time to time) and You expressly and voluntarily accept this Privacy Policy including any  change, alteration or modification made to the Privacy Policy. Indulge Global shall not be liable for any  damages You or third-party may suffer as a result of failure to provide You or third-party notice of any changes  to this Privacy Policy as set forth herein.