V1. Last Updated on: [23-08-2022]

A. OVERVIEW

Welcome to www.makeupcentral.in, website owned by USAYGLAM Services Private Limited

(“MakeupCentral”, “Makeup Central” “Us” or “We”) and mobile application represented as

“MakeupCentral app” in android and apple application store. This privacy policy (the “Privacy Policy”)

hereby states about the practices regarding collection, use, and disclosure of data or information that

you may have provided while using our services via Platforms (both website and mobile applications)

collectively referred to as the “Services”). We understand the importance of your privacy and are

committed to protect your rights to privacy pertaining to the information submitted by you as a user

or vendor, partner (collectively referred to as partners) of our company. We have made every effort

to ensure your information is secure. You have the right to know how your data is being used and for

how long with your consent.

The Services on our Platforms are governed by this Policy, Terms and conditions, and any other rules,

policies or guidelines published on the Platforms as applicable to you. Please read this Policy carefully

prior to accessing our Platforms and using the Services. By accessing and using the Platforms, providing

your Personal Information (defined below), or by otherwise signalling your agreement when the

option is presented to you, you consent to the collection, use, disclosure, sharing and storing of

information described in this Policy, Terms of Service and any other rules, policies or guidelines

published on the Platforms as applicable to you (collectively referred to as the “Platforms Terms”),

and Makeup Central disclaims all the liabilities arising therefrom. If you have inadvertently submitted

any Personal Information to Us prior to reading this Policy statements set out herein, or you do not

agree with the way your Personal Information is collected, stored, or used, then you may access,

modify and/or delete your Personal Information in accordance with this Policy (refer to the sections

about Your Choices and Your Rights).

If any information you have provided or uploaded on the Platforms violates the Platforms Terms,

Makeup Central may be required to delete such information upon informing you of the same and

revoke your access to the Platforms if required.

Capitalized terms used but not defined in this Policy can be found in our Terms and conditions.

If you have any questions about this Policy, please contact us at Support@makeupcentral.in

B. ACCESS

You may be allowed to access and view the Platforms (both or either website and mobile application)

as a guest and without creating an account on the Platforms or providing any Personal Information;

Makeup Central does not validate or takes no responsibility towards information, if any, provided by

you as a guest, except as otherwise required under any law, regulation, or an order of competent

authority. However, to have access to all the features and benefits on our Platforms, you are required

to first create an account on our Platforms. To create an account, you are required to provide certain

Personal Information as may be required during the time of registration and all other information

requested on the registration page, including the ability to receive promotional offers from Us, is

optional. Makeup Central may, in future, include other optional requests for information from you to

help Us to customize the Platforms to deliver personalized information to you. We may keep records

of telephone calls or emails received from or made by you for making enquiries, feedback, or other

purposes for the purpose of rendering Services effectively and efficiently.

C. ACCESS BY CHILDREN

To register on the Platforms you must meet the ‘Age Requirements’ (as defined in our Terms and

conditions). If you are a “Minor” or “Child” i.e., an individual who does not meet the Age

Requirements, then you may not register on the Platforms, and only your Parent (defined below) can

their guidance and supervision.

While no Services require collection of a Child’s Personal Information, If you are a guardian/parent

and you are aware that your Child has provided us with any Personal Information without your

consent, please contact us at Support@makeupcentral.in If we become aware that we have collected

Personal Information from a Child in the absence of consent of the Parent, we will take steps to

remove such information from our servers.

D. INFORMATION CONTROL

Makeup Central is the controller of Personal Information that it collects and processes in connection

with the use of the Platforms and the provision of the Services on the Platforms. The kind of Personal

Information we collect in connection with such use is detailed below.

E. PERSONAL INFORMATION

“Personal Information” shall mean the information which identifies a User i.e., first and last name,

identification number, Pan card number, email address, age, gender, location, photograph and/or

phone number provided at the time of registration or any time thereafter on the Platforms.

“Sensitive Personal Information” shall include (i) passwords and financial data (except the truncated

last four digits of credit/debit card), (ii) health data, (iii) official identifier (such as biometric data,

Aadhaar number, Pan card number, driver’s license, passport, etc.,), (iv) information about sexual life,

sexual identifier, race, ethnicity, political or religious belief or affiliation, (v) account details and

passwords, or (vi) other data/information categorized as ‘sensitive personal data’ or ‘special

categories of data’ under the Information Technology (Reasonable Security Practices and Procedures

and Sensitive Personal Data or Information) Rules, 2011, or General Data Protection Regulation

(GDPR) (“Data Protection Laws”) and in context of this Policy or other equivalent / similar legislations.

Usage of the term ‘Personal Information’ shall include ‘Sensitive Personal Information’ as may be

applicable to the context of its usage.

We request you to not provide Makeup Central with any Personal Information unless specifically

requested by us. In the event you share with Makeup Central any Personal Information without us

having specifically requested for the same, then we bear no liability in respect of such Personal

Information provided by you.

F. INFORMATION COLLECTED

We only collect information about you if we have a reason to do so — for example, to provide our

Services on the Platforms, to communicate with you, or to make our Services better.

We collect this information from the following sources:

A. Information we collect from You:

i. Basic account information: In order to access certain features of the Platforms, you will need

to create an account and register with us. We ask for basic information which may include

your name, an email address, state of residence, country and password, along with a

username and phone/mobile number.

ii. Know Your Customer ('KYC') information: If you are an instructor of any course registered with

us on Our Platforms, then, we also collect the KYC information, which may include information

pertaining to your PAN number, Aadhaar number, driver’s license, passport, your entity

details such as name, MOU/AOA, certificate of incorporation, list of directors/partners, social

security number etc., along with the relevant documents. We collect this information and

documents from you to complete our verification process including pursuant to any other

arrangement / agreement executed with you.

iii. Public profile information: If you are a Vendor/artist, we may also collect certain additional

information from you to enable creation of your public profile, if any, on the Platforms to help

users know you better.

iv. Your public profile will only contain Personal Information that are required for Users to know

you (as applicable) viz., your username, a brief description of any content you have made

available on the Platforms, your educational qualifications, your past associations, your photo,

and such similar information that may enable a User's or other User to know you better. The

information in your public profile will be based on the information you provide to us or as

updated by you on such applicable sections.

v. Information when you communicate with us: When you write to us with a question or to ask

for help, we will keep that correspondence, and the email address, for future reference; this

may also include any phone/ mobile numbers if you have provided us the same as part of your

communication either in writing (emails included), over a phone call or otherwise. When you

browse pages on our Platforms, we will track that for statistical purposes which may be to

improve the Platforms and the Services. You may also provide us your Personal Information

or other information when you respond to surveys, enter any form of contests, tests, events,

competitions, webinars, etc., hosted by Makeup Central, either on the Platforms or otherwise,

or when you otherwise communicate with us via form, e-form, email, phone, or otherwise,

we store a copy of our communications (including any call recordings or emails, if any, as

permitted by applicable law).

B. Information collected automatically:

i. Device and Log information: When you access our Platforms, we collect information that web

browsers, mobile devices, and servers typically make available, including the browser type, IP

address, unique device identifiers, language preference, referring site, the date and time of

access, operating system, and mobile network information. We collect log information when

you use our Platforms — for example, when you create or make changes to your account

information on the Platforms.

ii. Usage information: We collect information about your usage of our Platforms. We also collect

information about what happens when you use our Platforms (e.g., page views, support

document searches, features enabled for your account, interactions with other parts of our

Services) along with information about your Supported Device (e.g., screen size, name of

cellular network, and mobile device manufacturer). We use this information to provide our

Platforms to you, get insights on how people use our Platforms so that we can make our

Platforms better, and understand and make predictions about User retention.

iii. Location information: We may determine the approximate location of your Supported Device

from your Internet Protocol (IP) address. We may collect and use this information to calculate

how many people visit from certain geographic regions or to improve our Platforms Services.

iv. Information from cookies & other technologies: We may collect information about you

through the use of cookies and other similar technologies. A cookie is a string of information

that a website stores on a visitor’s computer, and that the visitor’s browser provides to the

website each time the visitor returns. For more information on our use of cookies and similar

technologies, please refer to our Cookie Policy.

C. Information collected from other sources:

We might receive and collect information about you from other sources in the course of their services

to us or from publicly available sources, as permitted by law, which we may combine with other

information we receive from or about you. For example, we may receive information about you from

a social media site or a Google service if you connect to the Services through that site or if you use the

Google sign-in.

G. BASIS OF COLLECTION, PROCESSING OF YOUR PERSONAL INFORMATION

We collect and process your Personal Information based on the following legal parameters depending

upon the nature of Personal Information and the purposes for which it is processed:

i. Consent: We rely on your consent to process your Personal Information in certain situations.

If we require your consent to collect and process certain Personal Information, as per the

requirements under the applicable Data Protection Laws, your consent is sought at the time

of collection of your Personal Information and such processing will be performed where

consent is secured.

ii. Compliance with a legal obligation: Your Personal Information may be processed by us, to the

extent that such processing is necessary to comply with a legal obligation.

We may process your Personal Information in connection with any of the purposes and uses set out

in this Policy on one or more of the following legal grounds:

i. Because it is necessary to perform the Services you have requested or to comply with your

instructions or other contractual obligations between you and us;

ii. To comply with our legal obligations as well as to keep records of our compliance processes;

iii. Because our legitimate interests, or those of a third-party recipient of your Personal

Information, make the processing necessary, provided those interests are not overridden by

your interests or fundamental rights and freedoms;

iv. Because you have chosen to publish or display your Personal Information on a public area of

the Platforms, such as a comment area;

v. Because it is necessary to protect your vital interests;

vi. Because it is necessary in the public interest; or

vii. Because you have expressly given us your consent to process your Personal Information in a

particular manner.

Where the processing of your Personal Information is based on your consent, you have the right to

withdraw your consent at any point in time in accordance with this Policy. Please note that should the

withdrawal of consent result in us not being able to continue offering our Services to you, we reserve

the right to withdraw or cease from offering our Services to you upon your consent withdrawal. You

may withdraw consent by contacting us with a written request to the contact details provided in

the ‘Grievances’ section below. Upon receipt of your request to withdraw your consent, the

consequences of withdrawal may be communicated to you. Upon your agreement to the same, your

request for withdrawal will be processed.

H. USING AND SHARE THE INFORMATION COLLECTED

We use/process your information in the following manner:

i. To provide Services on our Platforms: We use your information as collected by us to allow you

to access the Platforms and the Services offered therein, including without limitation to set-

up and maintain your account, provide customer service, fulfil purchases through the

Platforms, verify User information and to resolve any glitches with our Platforms. The legal

basis for this processing is consent or, where applicable, our legitimate interests in the proper

administration of our Platforms, and/or the performance of a contract between you and us.

ii. To improve our Platforms and maintain safety: We use your information to improve and

customize the Platforms and Services offered by us, including providing automatic updates to

newer versions of our Platforms and creating new features based on the Platforms usage

analysis. Further, we also use your information to prevent, detect, investigate, and take

measures against criminal activity, fraud, misuse of or damage to our Platforms or network,

and other threats and violations to Makeup Central’s or a third party's rights and property, or

the safety of Makeup Central, its users, or others. The legal basis for this processing is consent

or, where applicable, our legitimate interests in the proper administration of our Platforms,

and/or the performance of a contract between you and us.

iii. To market our Platforms and communicate with You: We will use your information to develop

a more targeted marketing of our Platforms, to communicate with you about our offers, new

products, services or even receive your feedback on the Platforms. The legal basis for this

processing is consent or, where applicable, our legitimate interests in the proper

administration of our Platforms, and/or the performance of a contract between you and us.

iv. To establish, exercise, or defend legal claims: We may process any Personal Information

identified in this Policy when necessary for establishing, exercising, or defending legal claims,

whether in court, administrative, or other proceedings. The legal basis for this processing is

our legitimate interest in the protection and assertion of our legal rights, your legal rights, and

the legal rights of others.

v. To manage risk and obtain professional advice: We may process any of the Personal

Information identified in this Policy to manage risk or obtain professional advice. The legal

basis for this processing is our legitimate interest in the proper protection of our business and

Platforms

vi. Consent: We may otherwise use your information with your consent or at your direction.

vii. To Better Understand Our Users: We may use information we gather to determine which

areas of the Services are most frequently visited to understand how to enhance the Services.

We share the information collected as per terms of this Policy only in the manner specified

hereinbelow. We do not sell or otherwise disclose Personal Information we collect about you for

monetary or other valuable consideration. Further, only authorized representatives of Makeup

Central and on a need-to-know basis use any information received from you and as consented by you.

In the event of any identified unauthorized use or disclosure of information or upon your complaint

as stated under the ‘Grievances’ section below, we will investigate any such complaint and take the

appropriate action as per the applicable Data Protection Laws.

i. Affiliates and Subsidiaries: We may disclose information about you to our affiliates,

subsidiaries and other businesses under the same control and ownership, and their respective

officers, directors, employees, accountants, attorneys, or agents, who need the information

to help us provide the Services or process the information on our behalf. We require our

affiliate, subsidiaries and other businesses under the same control and ownership to follow

this Privacy Policy for any Personal Information that we share with them.

ii. Third-party vendors/service providers including integrated services on the Platforms: We may

share information about you with third-party vendors or service providers (including

consultants, payment processors, and other service providers and integrated services) who

need the information to provide their support services to us or you, or to provide their services

to you on our behalf either directly or through the Platforms. These services may include

providing customer support, performing business and sales analysis, supporting our website

functionality, facilitating payment processing, and supporting contests, surveys, and other

features offered on our Platforms. Such third-party vendors are not allowed to use the

information for any purpose other than what it was provided for, and they are required to

process and use the information in accordance with this Privacy Policy.

iii. Third-party Platforms to facilitate the additional offerings: We may share information about

you with third-party Platforms that are used to create interactive forums between Content

Providers and Users to enable the Users a more conducive environment. The information

shared with these Platforms are limited to the information required to facilitate your

participation in the forums and is based on your consent. However, the privacy practices of

these Platforms are independent of this Policy, and we suggest that you read through the

privacy policies and terms and condition of the Platforms relevant to you prior to consenting

to being a part of any forums made available on these third-party Platforms.

iv. Legal Disclosures: We may disclose information about you in response to a court order, or

other governmental request. Without limitation to the foregoing, we reserve the right to

disclose such information where we believe in good faith that such disclosure is necessary to:

o comply with applicable laws, regulations, court orders, government and law

enforcement agencies’ requests;

o protect and defend Makeup Central’s or a third party's rights and property, or the

safety of Makeup Central, our users, our employees, or others; or

o prevent, detect, investigate and take measures against criminal activity, fraud and

misuse or unauthorized use of our Platforms and/or to enforce our Terms and

Conditions or other agreements or policies.

To the extent permitted by law, we will attempt to give you prior notice before disclosing your

information in response to such a request.

v. Business transfers: In the event Makeup Central undergoes any merger, acquisition, or sale of

company assets, in part or in full, with another company, or in the unlikely event that Makeup

Central goes out of business or enters bankruptcy, user information would likely be one of the

assets that is transferred or acquired by a third party. If any of these events were to happen,

this Privacy Policy would continue to apply to your information and the party receiving your

information may continue to use your information, but only consistent with this Privacy Policy.

vi. Advertising and Analytics Partners: We may share usage data with third-party advertisers,

advertisement networks, and analytics providers through cookies and other similar

technologies.

vii. With Your Consent: We may share and disclose information with your consent or at your

direction.

Your information may be shared for reasons not described in this Policy, however, we will seek your

consent before we do the same or share information upon your direction.

I. DURATION FOR WHICH YOUR INFORMATION IS STORED

Mostly, when you delete any of the information provided by you or when you delete your account, on

the Platforms, the same will be deleted from our servers too. However, in certain cases, we will retain

your information for as long as it is required for us to retain for the purposes stated hereinabove,

including for the purpose of complying with legal obligation or business compliances.

Further, please note that we may not be able to delete all communications or photos, files, or other

documents publicly made available by you on the Platforms (for example: Comments, ratings,

feedback, etc.), however, we shall anonymize your Personal Information in such a way that you can

no longer be identified as an individual in association with such information made available by you on

the Platforms. We will never disclose aggregated or de-identified information in a manner that could

identify you as an individual.

Note: If you wish to exercise any of your rights (as specified in ‘Your Rights’ section below) to access,

modify and delete any or all information stored about you, then you may do so by using the options

provided within the Platforms. You can always write to us at Support@makeupcentral.in for any

clarifications needed.

J. YOUR CHOICES

(i) Limit the information You provide: You always have an option to choose the information you

provide to us, including the option to update or delete your information. However, please note that

lack of certain information may not allow you the access to the Platforms or any of its features, in part

or in full.

(ii) Limit the communications You receive from us: Further, you will also have the option to choose

what kind of communication you would like to receive from us and whether you would like to receive

such communication at all or not. However, there may be certain communications that are required

for legal or security purposes, including changes to various legal agreements, that you may not be able

to limit.

(iii) Reject Cookies and other similar technologies: You may reject or remove cookies from your web

browser; you will always have the option to change the default settings on your web browser if the

same is set to ‘accept cookies’. However, please note that some Services offered on the Platforms may

not function or be available to you, when the cookies are rejected, removed, or disabled.

K. YOUR RIGHTS

If you are a User, you may exercise any of these rights by using the options provided to you within the

Platforms upon your login. If however, you are facing any issues or require any clarifications, you can

always write to us at the address noted in the ‘Grievances’ section below, and we will address your

concerns to the extent required by the applicable law.

a. Right to Confirmation and Access: You have the right to get confirmation and access to your

Personal Information that is with us along with other supporting information.

b. Right to Correction: You have the right to ask us to rectify your Personal Information that is

with us that you think is inaccurate. You also have the right to ask us to update your Personal

Information that you think is incomplete or out-of-date.

c. Right to be Forgotten: You have the right to restrict or prevent the continuing disclosure of

your Personal Information under certain circumstances.

d. Right to Erasure: If you wish to withdraw/remove your Personal Information from our

Platforms, you have the right to request erasure of your Personal Information from our

Platforms. However, please note that such erasure will remove all your Personal Information

from our Platforms (except as specifically stated in this Policy) and may result in deletion of

your account on the Platforms permanently, and the same will not be retrievable.

Remember, you are entitled to exercise your rights as stated above only with respect to your

information, including Personal Information, and not that of other Users. Further, when we receive

any requests or queries over email or physically to the address specified in the ‘Grievances’ section

below, then, as per the applicable Data Protection Laws, we may need to ask you a few additional

information to verify your identity in association with the Platforms and the request received.

L. PROMOTIONAL COMMUNICATIONS

You will always have the option to opt out of receiving some or all of our promotional communications

through the setting provided within the Platforms upon your login, by using the unsubscribe link in

any email communications sent to you or by emailing Support@makeupcentral.in

If you opt out of promotional communications, we may still send you transactional communications,

such as service announcements, administrative and legal notices, and information about your account,

without offering you the opportunity to opt out of these communications. If you no longer wish to use

our Platforms or receive any communications from us (except for those that are legally required), then

you may delete your account by using the option enabled within the Platforms or by writing to us

at Support@makeupcentral.in

Advertisers or ad companies working on their behalf sometimes use technology to serve the ads that

appear on our sites directly to Your browser. They automatically receive Your IP address when this

happens. They may also use cookies to measure the effectiveness of their ads and to personalize ad

content. We do not have access to or control over cookies or other features that advertisers and third-

party sites may use, and the information practices of these advertisers and third-party websites are

not covered by our Policy. Please contact them directly for more information about their privacy

practices.

Please note that opting out of promotional email communications only affects future communications

from us. If we have already provided your information to a third party (as stated in this Policy) before

you changed your preferences or updated your information, you may have to change your preferences

directly with that third party.

We do not sell your Personal Information to third parties, and we do not use your name or name of

your company in marketing statements without your consent.

However, if you have purchased any Services on our Platforms, we may ask you for testimonial and if

you authorize us, we will display your testimonial on our website, photos and videos or in our social

media channels such as Facebook, Twitter, LinkedIn, YouTube, Instagram or any live platform. You

should be aware that your publicly identifiable information could be used to send you promotional,

unsolicited messages. We are not responsible for your personal information which you have chosen

to display.

If you don't want us to feature your pictures/testimonials on our website or on our social media

channels, you can write a mail to Support@makeupcentral.in

You can contact us if you notice that the information we are holding is incorrect or incomplete. Please

write to us at support@makeupcentral.in

M. UPDATES TO OUR PRIVACY POLICY

Our business changes constantly and our Policy may change from time to time. We may, at our

discretion (unless required by applicable laws to mandatorily do so), email periodic reminders of our

notices and conditions, unless you have instructed us not to, but we encourage you to check our

Platforms frequently to see the recent changes. Unless stated otherwise, our current Policy applies to

all information that we have about you and your account. We stand behind the promises we make,

however, and will not materially change our policies and practices making them less protective of

customer information collected in the past without your consent.

Further, it is hereby clarified and declared that We are a Platforms based in India and GDPR legislation

is not applicable to Us or the Platforms.

N. GRIEVANCES

If you have any questions about this Policy, wish to exercise your rights, concerns about privacy or

grievances at Platforms, please register your complaint with a thorough description via email to

Support@makeupcentral.in addressed to our grievance officer MR. [T.R Vikram] (Designation;- COF)

or via a registered post to the below address-

USAYGLAM Services Private Limited

Unit no 203, 2nd Floor, 216,

SBR CV Towers, HUDA Techno Enclave,

Hyderabad, Telangana- 500081