I.  INTRODUCTION

1. Qurate Space (Hereinafter “the Website””) is a website and moderated to provide users with ideas to redesign and decorate their existing spaces.
2. We value the trust you place in us and respect your privacy. We are committed to make sure that there is complete compliance from our part with the data privacy laws of India as we recognize the importance of secure transaction and information privacy.
3. This privacy policy is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000 and the rules made thereunder and the amended provisions pertaining to electronic documents / records in various statutes as amended by the Information Technology Act, 2000.This privacy policy includes how we collect, use, disclose, and safeguard the information provided by you, when you use our website. This policy provides information related to the procedure to support the products and services offered by Qurate Space.
4. We urge all Users and individuals who are to visit, use or gain access to our Services and are in correspondence with us via email, messaging service and / or any other forms of electronic communication to go through this Privacy Policy to be reasonably informed regarding policies. By visiting the website, providing your information, or availing our services, you expressly agree to be bound by the terms and conditions of this privacy policy. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, PLEASE DO NOT PROCEDE WITH THE WEBSITE. You hereby provide your unconditional consent or agreements to us as provided under section 43A and section 72A of Information Technology Act, 2000.
5. We reserve all the rights to make changes to this Privacy Policy at any time for any certain reason. The changes made by us in the Privacy Policy will be updated as ‘Last Update’. We encourage you to review the Privacy Policy and stay updated.

II.  DEFINITIONS

1. LAW– The Information Technology Act and the Information technology Amendment Act 2008 for governing the provisions related to Cyber Laws in India. The Right to Information Act, The Indian Penal Act and the laws associated with different jurisdictions.
2. USER – The expression “User” under the policy may include any person voluntarily interacting with the website, Users of the service, Users availing such trial pack or service, or any such User which has directly or indirectly involved in any transactions with the website.
3. DATA SUBJECT – The legal or natural person to whom the Personal Data refers to or is associated with.
4. DATA – The expression “Data” under the policy may include all such relevant information or data which has been collected or provided by the User.
5. SERVICES – The expression “Services” under the policy may include all the various services offered by the website.
6. PERSONAL INFORMATION – Personal Identifiable Information (PII):
   • Information by which User(s) can be recognised, contacted, and identified such as:
   • His/her name.
   • Address (Residential or otherwise).
   • Occupation/Organisation/institute.
   • Email address.
   • Telephone number.
   • Education
   • Internet Service Provider details.
7. SENSITIVE PERSONAL DATA OR INFORMATION (SPDI): Sensitive personal data or information of a person means such personal information which consists of information relating to:
   • Passwords
   • Any information so provided regarding the sexual orientation of the User(s);
   • Any information regarding financial information of the User(s)
   • Any confidential information related to the projects, competitions, questionnaires uploaded by the Users on the Website.

Provided that, any information that 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 data or information for the purposes of these rules.

III.  DATA COLLECTED AND PURPOSE:

The website is created for the purpose of providing a platform for providing consumers with reference images with creative and fresh ideas and perspective to redecorate and design a space and linking these images to sellers, businesses and local retailers selling similar aesthetic or design products as in the reference image. The links provided, any collaboration with businesses or local retailers and use of data shall only be for lawful purposes. The website shall use, collect and retain Data and Information of the User(s) and including Personal Identifiable Information and Sensitive Personal Information for the following purposes:

1. To identify the User(s) and provide the complete services of the website to its fullest potential in order to maximise the benefit of the User(s)
2. To create and manage user(s) account and enable user-to-user communication.
3. To verify the consumers, and collaborate and link consumers to verified businesses, sellers and local retailers selling similar aesthetic design products as in the reference images.
4. All the images for reference of the consumers will be purchased and uploaded on the website and all links attached to the aesthetic design products will inform the consumers of the source of the product.
5. In order to keep records, data, information and statistics to chart the User’s taste and requirements while using the website, verify their needs according to their image preference, and further modifications if any required for the purposes of betterment of User – website relations;
6. In order to keep the User(s) regularly updated on any and all notifications, new images, perspectives, improvements or addition and to update and enable business to understand the consumers taste and requirements.
7. To respond to user’s concerns, inquires, or address your requests for information about the various services we offer.
8. In order to report any and all policy changes, newsletters, promotional activities and / or service offerings that are either provided or going to be provided in the near future by the website.
9. The Data or Information provided by the Users is liable to be shared with third-party apps, websites, or other services that use, or are integrated with, our services in order to improve our quality of services.
10. In order to enhance the security and safety of services provided by the webiste to the User(s);
11. Any and all lawful purposes related to and arising from the working of the website and / or in furtherance of the same.
12. We collect your public profile data only from your consent that you grant before initiating Social Login, from the social network used to login at our website. This data includes your first name, last name, email address, link to your social media profile, unique identifier, link to social profile avatar or the social profile avatar itself in the case of Facebook and Linkedin login. This data is used to create your user profile at our website. You can revoke this consent at any time from your profile page at our website or by sending us an email.
13. We use Google Analytics to track social shares made at our website. Google automatically collect and store certain information in their server logs which includes device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL, cookies that may uniquely identify your browser or your Google Account, in accordance with their data privacy policy: https://policies.google.com/privacy

That the website shall notify the User(s) of any and all changes regarding the purpose of the collection, storage and retention of above Data and Information. The information will be kept

IV.  DISCLOSURE OF YOUR INFORMATION

The data collected and stored by us can be shared in certain situation as follows:

1. By Law or to Protect Rights

If the release of information is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.  This includes exchanging information with other entities for fraud protection and credit risk reduction.

2. Third Party Service Providers

Information can be shared with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. 

3. Marketing Communications

With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.

4. Online Postings

When you post comments, contributions or other content to the website, your posts may be viewed by all users.

5. Business Partners

We may share your information with our business partners to offer you certain products, services or promotions.

6. Other Third Parties

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience.  Specifically, we may use information collected about you via the website to:

• Administer sweepstakes, promotions, and contests.
• Compile anonymous statistical data and analysis for use internally or with third parties.
• Create and manage your account.
• Deliver targeted advertising, coupons, newsletters, and other information regarding promotions.
• Email you regarding your account or order.
• Enable user-to-user communications.
• Fulfil and manage any purchases, orders, payments, and other transactions related to the website.
• Generate a personal profile about you to make future visits to the website more personalized.
• Increase the efficiency and operation of the website.
• Monitor and analyse usage and trends to improve your experience with the website.
• Notify you of updates to the website.
• Offer new products, services, mobile applications, and/or recommendations to you.
• Perform other business activities as needed.
• Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
• Request feedback and contact you about your use of the website
• Resolve disputes and troubleshoot problems.

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations.  If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

V.  TRACKING TECHNOLOGIES

We use the following third party websites, plug-ins and general software for the purposes so specified above and enhance the working, performance and personalization of the Website:

Cookies and Web beacons

We may use cookies, web beacons, tracking pixels, and other tracking technologies on the website to help customize the website and improve your experience. When you access the website, your personal information is not collected using tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies but be aware that such action could affect the availability and functionality of the website. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your device settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.

Third Party Advertisers

We do host and partake in the process of hosting certain third-party advertisements and links. By accessing the website, you consent to the collection and use of your information by these third-party vendors. The User must note however that such third parties are in no manner associated with the Website and that the User(s) must click on such advertisements / links on their own accord, risk and/or understanding.  You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors.

VI.  RIGHTS OF USER

That under this Privacy Policy the User(s) shall have the following rights regarding their Data and information, namely:

A. Account Information

1. The User(s) shall have the right to access the Data and Information so stored by the website during the period of use of the website by the User.
2. The User(s) shall have the right to refuse non –essential cookies and web beacons on opening the website. The User(s) shall be clearly explained the exact purpose of each and every cookie / web beacon.
3. The User shall have the right to delete, erase, clear and pause all forms and methods of data and information collection, use, retention and storage by the Website.
4. The User shall send a request via mail to the Grievance Officer requesting such deletion of Data and Information;
5. The User shall have the right to raise all grievances regarding use, storage and retention of data and information by the website Such Grievances shall be raised by sending an email to the Grievance Officer so appointed by the website for the purposes of answering any and all questions, doubts, clarifications and pointers regarding the Privacy Policy of the Services.

B. Account Termination

1. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

VII. PRACTICES FOR MAINTAINING AND SECURING DATA

1. 1. QURATE SPACE promises to take and ensure all the possible checks and balance to maintain reasonable security practices and procedure to protect the personal data of any breach and unauthorised access or misappropriation.
   2. In order to ensure a well secured environment to protect our data and information, we audit and update our policy time to time in order to protect the interest of all the stakeholders.
   3. QURATE SPACE also may retain information as required or permitted by applicable laws and regulations, including to honour your choices, for our billing or records purposes and to fulfil the purposes described in this Privacy Statement. We take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required. Hence, reasonable time to be followed and provided in circumstances relating to such request regarding any changes in data or information for looking into the matter and no action or liability can be directed before such period.

VIII. FINANCIAL DATA AND INFORMATION

1. That the website shall store and retain only the transaction details of the User which are necessary for the purposes of proper functioning of the website, maintenance of records of User, correspondence and authentication of purchases so made on the Website.
2. Apart from the above specified Data and Information, all financial information is stored by our Payment Processor and you are encouraged to review their privacy policy and contact them directly for responses to your questions.

 IX.  DATA SECURITY AND GRIEVANCE OFFICER

1. We use software, hardware and technical based security measures to help protect your Data. While we have taken reasonable steps to secure the Data you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.
2. In the event there is any complaint / clarification / doubt that the User so seeks to be clarified, they must contact the Grievance Officer as stipulated under Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011. Following are the details of the Grievance Officer:

3. The Grievance Officer shall attempt to resolve any and all issues so brought before him /her in a fair and expeditious manner within 28 business days. After completion of the review the Grievance Officer shall submit a report to the User.

X.  ACCESS AND DATA OF INDIVIDUALS UNDER 16 YEARS OF AGE

We STRONGLY state that no minor below the age of 16 years may access the website without the express supervision of a guardian. If they are to accept this policy and access the Services, they shall be deemed to have done so under the supervision of a guardian. The website shall in no manner be responsible for any and all actions taken by a User(s) below the age of 16 who is not under the supervision of a guardian.

XI.  CROSS-BORDER DATA TRANSFER

The personal data held by us can be transferred to other countries outside the user’s residential country for any of the purposes described in this Privacy Policy. These countries may have differing (and potentially less stringent) laws relating to the degree of confidentiality afforded to the information it holds and that such information can become subject to the laws and disclosure requirements of such countries, including disclosure to governmental bodies, regulatory agencies and private persons, as a result of applicable law and regulation. In addition, several countries have agreements with other countries providing for exchange of information for law enforcement, tax and other purposes.

In situation where we disclose the information to a third party, we will use best endeavours to put in place appropriate controls and safeguards to ensure that your Personal Data is kept accurate, adequately protected, and processed only for specified and reasonable purposes in a manner that is fair, transparent and has a lawful basis, and is stored for no longer than is absolutely necessary.

XII. DATA SECURITY

We are committed to protecting your Personal Data in our custody. We take reasonable steps to ensure appropriate physical, technical and managerial safeguards are in place to protect your data from unauthorized access, alteration, transmission and deletion. We work to protect the security of your personal information during transmission by using encryption protocols. We use multi-layered controls to help protect our infrastructure, constantly monitoring and improving our website, systems, and processes to meet the growing demands and challenges of security. We ensure that the third parties who provide services to us under appropriate contracts, take appropriate security measures to protect your Personal Data in line with our policies.

XII. CHANGES TO THE POLICY

Qurate Space reserves the right to make changes and update the terms of the policy from time to time for the purpose of improving our Privacy and Data framework and any such changes shall be notified or reflected on the website.