21 Media LLP(“Tully Gully”, “we” or “us”) recognises the importance of protecting personal details and information. This privacy policy (“Privacy Policy”) describes and will help You understand how TullyGully collects, uses and discloses Your information in connection with providing You with access to and use of our website www.tullugully.in, and any subdomains of our website or other selected domains (“Website”) and our mobile application (“App”). Our Website and the App enable You to select for alcoholic beverages (Products) F licensed retailers/outlets and get it delivered at your given address. We understand that You care how information about You is used and shared, and we appreciate Your trust that we will do so carefully and sensibly. This Privacy Policy describes our practices in connection with privacy and the Personally Identifiable Information (as defined below) that we collect through the Website and/ or App. Except as indicated below, this Privacy Policy does not extend to the collection, use or disclosure of information by any of our affiliates or by other third parties on any websites other than the Website and/ or App.
By accessing and/or using the Website and/ or App, You agree to all the terms and conditions of
this Privacy Policy. We may change this Privacy Policy from time to time and without prior
notice. If we make a change to this Privacy Policy, it will be effective as soon as we post it,
and the most current version of this Privacy Policy will always be posted under the Privacy
Policy tab of the Website and/ or App. If we make a material change to this Privacy Policy, we
may notify You of the same. You agree that You will check this Privacy Policy periodically. By
continuing to access and/or use the Website and/ or App, including after we make changes to this
Privacy Policy, You agree to be bound by the revised Privacy Policy. If You do not agree to the
revised terms of the Privacy Policy, You agree to discontinue using the Website and/ or
App.
Information We Collect Through Website and/ or
App
Personally Identifiable Information (or
“PII”)
Personally Identifiable Information (or “PII”) means and includes information that
identifies You as an individual. In order for You to take advantage of benefits provided through
the Website and/ or App (for example, to use the Services offered on the Website and/ or App),
we may require that You furnish certain PII. For example, we may ask You to complete a
registration form that asks for contact information such as Your name, date of birth, telephone
/ mobile number, Driving License copy and email address or an order form that may asks for
financial information like Your credit/debit card number, expiration date, security code / CVV
number and billing address. Your PII may also be obtained by us during the KYC process, in order
to verify Your identity and age.
For enabling You to make
payments using our Services, we may, upon Your consent, store Your financial information such as
details of Your bank account (including but not limited to, the account holder’s name,
account name, account number, sort code, online banking PIN, transaction authentication number)
or details mentioned on Your credit or debit cards or other payment instruments, that are
required for a successful transaction. Note that at no point in time will Your security code /
CVV number of Your credit card be stored by TullyGully or its payment gateway (If Any). We will
ensure that Your PII which You have shared with us, including Your bank details, are kept safe
and not shared with any third parties (except as required for the purpose of completing a
transaction initiated by You on our Website and/ or App),without Your
consent.
Additionally, when You transact on the Website and/ or
App, we may collect certain consumer information (such as products ordered and relevant
promotion codes) If You communicate with us by email, or otherwise complete online forms,
surveys, or contest entries, any information provided in such communication may be collected as
PII. You may choose not to provide us with certain personal information. In such an event, You
can still access and view much of the Website and/ or App; however, You may not be able to
reserve any products. In addition, You can choose not to provide certain optional information,
but then You might not be able to take full advantage of many of the features on the Website
and/ or App.
Non-Personally Identifiable Information (or
“Non-PII”)
Non-Personally Identifiable Information (or “Non-PII”) is aggregated information, demographic information and any other information that does not reveal Your specific identity. Through Analytics, this could include Advertising Features including Demographics & Interest reporting, Remarketing, GDN Impression Reporting and Campaign Manager Integration. We and our third-party service providers may collect Your Non-PII, including information about the device You are using in accessing and/or using the Website and/ or App, information from referring websites, and Your interaction with the Website and/ or App. We and our third-party service providers also may aggregate PII in a manner such that the end-product does not personally identify You or any other user of the Website and/ or App, for example, by using PII to calculate the percentage of our users who have a common telephone area code.
A cookie is a small piece of data that is sent to Your internet browser and stored
on Your computer’s hard drive, and that delivers information about You and Your activity
on a web browser so it can be later read back from that browser. Pixel tags and web beacons are
small graphic files that can function in various ways (such as allowing us to track how You view
an email that we send You and track Your activity on the web browser) and are commonly used in
conjunction with cookies. We, our third-party service providers and the third parties listed
under the section “How We Use The Information We Collect”, may use cookies, pixel
tags, web beacons, and other similar technologies to better serve You with more tailored
information and facilitate Your ongoing use of the Website and/ or App. If You do not want
information collected through the use of cookies, there is a simple procedure in most browsers
that allows You to decline the use of cookies. Cookies take up minimal room on Your device and
cannot damage Your device’s files. Cookies work by assigning a number to the user that has
no meaning outside of the assigning website.
Tracking
information is automatically collected and stored as You navigate through the Website and/ or
App, including but not limited to, browser type, pageviews, Internet Protocol address (“IP
Address”), referring/exit pages, information about how You interact with the
Website’s pages, third party links, and traffic and usage trends on the
Website.
IP Addresses are the Internet Protocol addresses of the
computer and/or mobile that You are using. Your IP Address is automatically assigned to the
computer that You are using by Your internet service provider (“ISP”). Your IP
Address is identified and logged automatically in our server log files whenever You visit the
Website and/ or App, along with the time(s) of Your visit(s) and the page(s) of the Website and/
or App that You visited. Collecting IP Addresses is standard practice on the Internet and is
done automatically by many websites.
When You use the App
through Your smartphone or other mobile device(s), we automatically collect the device type and
advertising identifier, a unique identifier generated within the device, and we may store this
information.
In the case of telephonic conversations between the customer and the retail store, conversations may be recorded for feedback & quality improvement purposes.
If you wish to stop third party tracking of your information, you can choose to do so by changing it accordingly in your ads settings. Alternatively, please visit https://tools.google.com/dlpage/gaoptout/ for the list of currently available opt outs for the web.
Applicable Laws
In this Privacy Policy, the term
“Applicable Laws” shall mean all treaties, statutes, enactments, acts of legislature
or parliament, laws (including rules of equity), codes, ordinances, rules, bye-laws,
regulations, notifications, guidelines, policies, directions, directives and orders, decisions,
decrees, permits, licenses, consents, approvals or other authorizations of any governmental
authority, statutory authority, regulatory authority, tribunal, board or court in India, as
amended or implemented from time to time.
Notwithstanding anything provided in this Privacy Policy, we shall, at all times, comply with the
provisions contained in the Information Technology Act, 2000 and the statutory rules framed
thereunder, from time to time, and also with all other laws, rules and regulations, whether
already in force or which may be enacted anytime in future, pertaining to data security and
management, data storage, sharing and data protection, in addition to the Aadhaar (Targeted
Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016,including all rules,
regulations, policies, manuals, procedures, guidelines, specifications, standards and directions
issued by Unique Identification Authority of India
(“UIDAI”).
How We Use The Information We
Collect
Personally Identifiable
Information
We and our third party service providers may use
Your PII and any third party PII that You may provide, as applicable:
Further, any PII collected and maintained by us in our logs shall be shared with any individual
or entity only on a need basis, and such disclosure and / or storage of the logs maintained
shall comply with Applicable Law.
Other Important Notices
Regarding Our Privacy Practices
Third Party
Websites
Except as expressly set forth herein, this Privacy
Policy does not address, and neither we nor our third party service providers are responsible
for the privacy, information or other practices of other websites and/or any third parties,
including without limitation any of our affiliates and/or any third party operating any website
to which the Website and/ or App contains a link. The inclusion of a link to a third-party
website on the Website and/ or App does not imply endorsement of the linked website by us or by
our affiliates. Please note that Your access and/or use of any third-party websites, including
by providing any information, materials and/or other content to such websites, is entirely at
Your own risk.
Security
We and
our third-party service providers use reasonable organisational, technical and administrative
measures to protect PII collected, stored and/or maintained by us and/or under our control.
Whenever You change or access Your account information, we offer the use of a secure server.
Once Your information is in our possession we adhere to strict security guidelines, protecting
it against unauthorised access. Unfortunately, no data transmission over the Internet or data
storage system can be guaranteed to be 100% secure. Please do not send us sensitive information
through email. If You have reason to believe that Your interaction with us is not secure (for
example, if You feel that the security of any account You might have with us has been
compromised), You must immediately notify us of the problem by contacting us in accordance with
the “Contacting Us” section below. (Note that if You choose to notify us via
physical mail, this will delay the time it takes for us to respond to the
problem.)
Unsubscribe
If You do
not wish to receive marketing-related emails from us, You may unsubscribe from receiving them by
clicking on the “unsubscribe” link at the bottom of any of those
emails.
Changing PII
You may
review, correct and/or update certain elements of Your PII by adjusting Your preferences in the
“My Account” section of our Website and/or App. We and our third-party service
providers are not responsible for altering PII from the databases and/or other records of third
parties with whom we and our third-party service providers have shared Your PII (as permitted by
Applicable Law).
Retention
Period
We and our third party service providers will retain PII
for the period reasonably necessary to fulfil the purposes outlined in this Privacy Policy,
unless a longer retention period is required or permitted by
law.
Note Regarding the Use of the Website and/ or App by
Minors
The Website and App are not directed to and/or intended
for use by individuals under the age as mentioned under Applicable Laws, and we request that
such individuals not use the Website and App and/ or not provide PII through the Website and/ or
App.
Disclaimer
If You choose to
access the Website and/ or App, You do so at Your own risk, and are responsible for complying
with Applicable Laws. We may limit the availability of the Website and/ or App, in whole or in
part, to any person, geographic area and/or jurisdiction we choose, at any time and at our sole
discretion.
Consent
By using the
Website and/ or App and/or by providing Your information, You consent to the collection and use
of the information You disclose on the Website and/ or App in accordance with this Privacy
Policy, including but not limited to Your consent for sharing Your information as per this
Privacy Policy.
Contacting Us
If
You have any questions regarding this Privacy Policy, please contact us by
Email Support : Open TullyGully’s mobile application -> Post a query to support@tullygully.in