PRIVACY POLICY

Introduction

Globemark Beverages LLP ("Globemark", "Company", "we", "us", "our"), the owner and operator of the "Clean Sin" brand and the website [INSERT WEBSITE URL] and affiliated storefronts (collectively, the "Platform"), is committed to protecting the privacy of visitors, registered users, and customers ("you", "User").

This Privacy Policy explains what personal information we collect, how we use, store, share, and protect it, and the choices and rights available to you.

Information We Collect

Information You Provide Directly

• Identity and contact details: name, email address, phone number, date of birth where age verification is relevant, billing and shipping address.
• Account credentials, where you register an account on the Platform.
• Order details: products purchased, order value, order history, and preferences you share, such as flavour preference.
• Payment-related information collected at checkout. Card, UPI and net-banking credentials are processed directly by PCI-DSS compliant payment gateway partners and are not stored on Globemark's own servers.
• Communications you send us, including customer support queries, feedback, reviews, contest entries and User Content submitted via social media tags.

Information Collected Automatically

• Device and usage information such as IP address, browser type, operating system, referring URLs, pages viewed and time spent on the Platform.
• Cookies and similar tracking technologies.
• Approximate location derived from IP address or, where permitted by you, precise device location for delivery purposes.

Information from Third Parties

We may receive information about you from payment gateways, logistics/delivery partners, analytics providers, advertising platforms and Third-Party Marketplaces through which Clean Sin Products are sold, to the extent necessary to fulfil and support your Order.

How We Use Your Information

We use personal information for the following purposes, each grounded in your consent, the performance of a contract with you, or our legitimate business interests as permitted under Applicable Data Law:

• Processing, fulfilling and delivering Orders, and providing order-related communication.
• Creating and managing your account and customer support requests.
• Processing payments and preventing fraudulent transactions.
• Sending promotional communications, offers and newsletters where you have opted in.
• Personalising your experience on the Platform and improving our Products and services.
• Conducting analytics, market research and measuring marketing campaign performance.
• Complying with applicable legal, tax, FSSAI and regulatory obligations.
• Detecting, preventing and investigating fraud, abuse or security incidents.

Disclosure & Sharing

We do not sell or rent your personal information to third parties. We may share your information with:

• Logistics and delivery partners, to the extent necessary to fulfil and deliver your Order.
• Payment gateway providers, for processing transactions securely.
• Cloud hosting, IT infrastructure, analytics, email/SMS/WhatsApp communication and marketing technology vendors acting on our behalf under contractual confidentiality obligations.
• Third-Party Marketplaces, solely to the extent an Order is placed through such a marketplace.
• Professional advisors and regulatory or law enforcement authorities where required by law, court order or to protect rights, property or safety.
• A successor entity in connection with a merger, acquisition, restructuring or sale of assets, subject to that entity's agreement to honour the commitments made in this Policy.

Cookies & Tracking

The Platform uses cookies, web beacons and similar technologies to operate core functionality such as shopping cart and login sessions, remember preferences, analyse traffic and deliver targeted advertising.

You can control or disable cookies through your browser settings. Note that disabling essential cookies may affect the functionality of the Platform, including checkout.

Security & Retention

We implement reasonable security practices and procedures, including encryption in transit, access controls and restricted internal access, in line with the SPDI Rules and Applicable Data Law.

We retain personal information only for as long as necessary to fulfil the purposes described in this Policy, comply with legal, tax and regulatory retention obligations, resolve disputes and enforce our agreements, after which it is securely deleted or anonymised.

Data Hosting & Transfer

Personal information collected through the Platform may be stored or processed on servers located in India or, where our service providers are located outside India, transferred internationally, subject to appropriate contractual and technical safeguards consistent with Applicable Data Law.

Your Rights & Choices

Subject to Applicable Data Law and the phased implementation of the Digital Personal Data Protection Rules, 2025, you may exercise the following rights by contacting us using the details in Section 12:

• Right to access a summary of the personal information we hold about you and the processing activities undertaken.
• Right to correction, completion and updating of inaccurate or outdated personal information.
• Right to erasure of personal information that is no longer necessary for the purpose for which it was collected, subject to legal retention requirements.
• Right to withdraw consent for optional processing such as marketing communications at any time.
• Right to grievance redressal through our Grievance Officer and, where applicable, the right to file a complaint with the Data Protection Board of India.
• Right to nominate another individual to exercise these rights on your behalf in the event of death or incapacity, where such functionality is enabled.

We may require reasonable verification of your identity before acting on a request and may decline requests that are manifestly unfounded, excessive or where an exemption applies under Applicable Data Law.

Marketing Communications

Where you have opted in, we may send you promotional emails, SMS, WhatsApp messages or push notifications about new flavours, offers and campaigns.

You may opt out at any time using the "unsubscribe" link in our communications or by contacting our support team. Transactional communications, such as order confirmations, are not covered by such opt-out.

Children's Privacy

The Platform is not directed at, and we do not knowingly collect personal information from, individuals under the age of eighteen (18) without the consent of a parent or legal guardian, in accordance with Applicable Data Law.

If we become aware that we have inadvertently collected personal information from a child without appropriate consent, we will take reasonable steps to delete such information.

Third-Party Links

The Platform may link to, or be complemented by, Third-Party Marketplaces and social media platforms with their own privacy practices.

This Policy does not apply to information you provide directly to such third parties, and we encourage you to review their respective privacy policies.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements or other operational reasons.

The revised Policy will be posted on the Platform with an updated "Last Updated" date, and material changes will, where required, be notified to you through appropriate channels.