Privacy Policy

Asolear Pharma Private Limited ("Asolear Group", "we", "our", or "us") is committed to protecting and respecting your privacy. We take the security and confidentiality of your personal information seriously.

This Privacy Notice explains the types of personal information we collect through our website (including its sub-domains and microsites), mobile applications, and other digital platforms. It also outlines:

• The information we collect from you;
• The purposes for which we collect and process your information;
• How and with whom we may share your information;
• The measures we take to safeguard your personal data;
• Your rights and choices regarding your personal information; and
• How you can contact us regarding our privacy practices.

We are committed to processing your personal information in a lawful, fair, and transparent manner and in compliance with applicable data protection laws.

Please read this Privacy Notice carefully before accessing, using, or availing yourself of any products, services, websites, or applications offered by Asolear Group. By using our services, you acknowledge that you have read and understood the terms of this Privacy Notice.

1. DEFINITIONS

For the purposes of this Privacy Notice, the following terms shall have the meanings assigned to them below:

Cookies
A small text file placed on your device by our website or mobile application when you visit or use certain features of our website or mobile application. Cookies help websites remember your actions and preferences over a period of time, enhancing your browsing experience.

Data
Any information relating to an identified or identifiable individual, including non-personal information, personal information, and sensitive personal information that, either alone or in combination with other information, may be used to identify you when you visit our stores, website, or mobile application.

Data Protection Laws
Any applicable laws, regulations, rules, or guidelines in force from time to time relating to the collection, use, processing, storage, disclosure, or protection of Data.

Partners
Selected third parties, including Asolear Group Entities, with whom we maintain contractual relationships in connection with the businesses and services described in this Privacy Notice.

Service Providers
Third-party entities engaged by us or other Asolear Group Entities to process Data on our behalf for specific purposes under written agreements and subject to appropriate confidentiality and security obligations.

Asolear Pharma
Asolear Pharma Private Limited, a company incorporated under the laws of India, having its registered office at B-133, DDA Sheds Okhla Industrial Area, Phase-I, South Delhi, New Delhi – 110020, India.

Asolear Group Entity
Includes Asolear® Pharma Private Limited, Asolear® Aesthetics Private Limited, Asolear® Education – QC MAS® – Abacus Classes, and their respective subsidiaries, affiliates, associate companies, and joint venture entities with whom we may share Data pursuant to contractual arrangements for the purposes described in this Privacy Notice.

User, You, or Your
Any natural person who accesses, browses, interacts with, or uses our stores, website, mobile application, products, or services.

2. WHAT DATA DO WE COLLECT ABOUT YOU?

Asolear Group collects and processes Data for various purposes as described in this Privacy Notice. Depending on the products, services, websites, mobile applications, or programs you use, we may collect the following categories of Data:

A. Contact Information
First name, last name, email address, postal address, country, employer details, telephone number, and other similar contact information.

B. Financial Information
Payment instrument details, transaction information, transaction history, payment preferences, payment methods, spending patterns, billing details, and other related financial information.

C. Technical Information
Information relating to your use of our website, mobile applications, and services, including Internet Protocol (IP) address, browser type, device identifiers, operating system details, location information, and data collected through cookies, pixels, and similar technologies.

D. Transaction Information
Details relating to transactions conducted with us, including transaction dates, amounts, purchase history, product preferences, order details, and related information.

E. Health-Related Information
Where applicable and permitted by law, information relating to your medical or health history, health status, treatment plans, medications prescribed by healthcare professionals, dosage instructions, laboratory test results, medicines ordered through our platforms, and other related healthcare information.

F. Product and Service Information
Account registration details, membership numbers, subscription information, payment records, service preferences, and program-specific information collected when you purchase products, request services, or participate in promotional programs.

G. Personal Information
Information such as age, gender, date of birth, marital status, nationality, occupation, details of government-issued identification documents, travel history, and any other personal information voluntarily provided through forms, surveys, questionnaires, or communications with us.

H. Reviews, Feedback, and Opinions
Information contained in reviews, ratings, comments, feedback, testimonials, suggestions, and opinions you provide regarding our products, services, programs, or customer experience.

I. Loyalty Program Information
Details relating to loyalty, rewards, membership, referral, or promotional programs, including membership identifiers, account credentials, profile information, passwords, and affiliations with travel, reward, or partner programs.

Asolear Group collects only such Data as is necessary for legitimate business purposes, to provide and improve our products and services, comply with legal obligations, and enhance the overall user experience.

3. HOW WE COLLECT DATA

We collect Data through various channels to provide, improve, and personalize our products and services. The methods by which we collect Data include the following:

A. Information You Provide to Us

We receive and store any information that you voluntarily provide when you use our website, mobile application, products, services, stores, outlets, events, kiosks, customer support channels, or any other interaction with us. For additional details, please refer to the section titled "Data Shared by You."

B. Information Collected Automatically

We automatically collect certain information when you interact with our website, mobile application, or digital services through cookies, pixels, web beacons, and similar technologies. Such information may include device details, browsing activity, IP address, and usage data. For more information, please refer to the section titled "Data Collected Automatically."

C. E-mail Communications

To improve the relevance and effectiveness of our communications, we may collect information regarding your interactions with emails sent by us, including whether an email has been opened, viewed, or whether links within the email have been clicked, where supported by your device and email settings.

You may opt out of receiving promotional or marketing communications at any time by clicking the "Unsubscribe" link included in such communications or by contacting us directly.

D. Information Collected Through Third-Party Websites

We may receive and process certain information when you interact with third-party websites, applications, or platforms that utilize our technologies or with whom we have contractual relationships. In such cases, the collection, processing, and use of your information by those third parties will be governed by their respective privacy policies and practices, and not by this Privacy Notice.

E. Information from Other Sources

We may obtain information about you from publicly available sources, business partners, service providers, social media platforms, or other third parties where permitted by law. For example, if you authorize a third-party website, application, or service to interact with our platforms, we may receive information necessary to identify your account and facilitate the requested services.

F. Information Shared by Asolear Group Entities

Where you have previously provided information to any Asolear Group Entity and have consented to the sharing of such information, we may receive and use that information for the purposes outlined in this Privacy Notice.

Your Choices

You have control over the information you provide to us. Where applicable, you may access, update, correct, or request deletion of your Data through our website, mobile application, or by contacting us directly. While you may choose not to provide certain Data, doing so may limit your ability to access specific products, services, features, or functionalities.

4. DATA SHARED BY YOU

Asolear Group may collect Data that you voluntarily provide to us through your interactions with our stores, website, mobile applications, products, services, and other communication channels.

Such Data may be collected in the following circumstances, including but not limited to:

A. Account Registration

When you register, create an account, subscribe, enroll, or otherwise sign up to receive our products, services, programs, newsletters, or other offerings.

B. Transactions and Purchases

When you make, attempt to make, or facilitate a purchase, payment, booking, order, inquiry, or any other transaction through our stores, website, mobile application, or other platforms.

C. Surveys, Questionnaires, and Research

When you participate in surveys, questionnaires, feedback programs, market research activities, contests, promotional campaigns, or other initiatives conducted by or on behalf of Asolear Group.

D. Marketing and Communications

When you choose to receive newsletters, updates, promotional offers, product information, event invitations, alerts, or other communications from us through email, SMS, telephone, mobile applications, social media platforms, or other communication channels.

E. Website and Mobile Application Interactions

When you visit, browse, interact with, or use our website, mobile applications, digital platforms, online services, or customer support channels, and voluntarily provide information through forms, chat features, inquiries, reviews, comments, or other user-generated content.

F. Customer Support and Enquiries

When you contact us for assistance, submit inquiries, lodge complaints, request information, provide feedback, or otherwise communicate with our customer service teams or representatives.

G. Events, Programs, and Promotions

When you participate in events, webinars, training programs, loyalty programs, educational initiatives, promotional activities, or any other programs organized or sponsored by Asolear Group.

By providing your Data, you represent that the information supplied is accurate, complete, and up to date, and you consent to its collection, use, storage, and processing in accordance with this Privacy Notice and applicable laws.

5. DATA THAT IS COLLECTED AUTOMATICALLY

When you access or use our website, mobile application, or other digital platforms, certain information may be collected automatically through technological means to help us improve our services, enhance user experience, and maintain the security of our systems.

A. Automatically Collected Information

We automatically collect certain information when you visit our website, use our mobile application, or interact with our digital services. Such information may include your Internet Protocol (IP) address, browser type, device identifiers, operating system, access times, referring website addresses, and other technical information relating to your interaction with our platforms.

This information assists us in improving the functionality, content, navigation, and overall user experience of our website and mobile applications.

B. Analytics and Performance Information

Our web servers, technology partners, and authorized service providers that offer analytics, performance monitoring, and security services may collect information including:

• IP address;
• Device and hardware information;
• Operating system details;
• Browser type and version;
• Language preferences;
• Geographic location data (where permitted);
• Usage patterns and browsing behavior;
• Pages visited, links clicked, and session duration; and
• Other diagnostic and performance-related information.

Such information is generally aggregated and analyzed to understand website and application usage, monitor performance, improve content and services, enhance user experience, detect technical issues, and maintain the safety and security of our platforms.

C. Cookies and Similar Technologies

We may automatically collect certain Data through the use of cookies, pixels, web beacons, local storage technologies, and other similar tracking technologies, subject to your browser settings and applicable legal requirements.

These technologies help us:

• Recognize and remember your preferences;
• Personalize your experience;
• Improve website and application functionality;
• Measure the effectiveness of marketing campaigns;
• Analyze traffic and user behavior; and
• Protect against fraud, unauthorized access, and security threats.

For additional information regarding our use of cookies and similar technologies, please refer to the section titled "Cookies" in this Privacy Notice.

By continuing to use our website, mobile application, or digital services, you acknowledge and agree to the collection and processing of such automatically collected information in accordance with this Privacy Notice and applicable laws.

6. OUR USE OF DATA

We may use the Data collected from you for various business, operational, legal, and service-related purposes. Such Data helps us provide, improve, personalize, and secure our products, services, websites, mobile applications, and customer experiences.

Specifically, we may use your Data for the following purposes:

A. Contractual Obligations

To perform, administer, and fulfill obligations arising from any contract, transaction, or arrangement entered into between you and Asolear Group.

B. Provision of Products and Services

To provide products, services, customer support, and related communications, including order confirmations, account management, service updates, and operational notifications.

C. Offers from Asolear Group Entities and Partners

To enable Asolear Group Entities and authorized Partners to offer products, services, programs, promotions, and related communications that may be relevant to you.

D. Business Operations and Data Sharing

To process, store, analyze, disclose, transmit, and share Data with Asolear Group Entities, service providers, business partners, and other third parties with whom we maintain lawful business or contractual relationships.

E. Personalization and Recommendations

To provide personalized content, recommendations, offers, advertisements, and services based on your preferences, interests, transactions, and interactions with our platforms.

F. Business Improvement and Development

To operate, evaluate, maintain, improve, and develop our business operations, products, services, websites, mobile applications, and customer engagement initiatives.

G. Analytics and Customer Insights

To generate aggregated, anonymized, or statistical information that helps us understand customer behavior, preferences, purchasing patterns, trends, and other insights for business improvement and decision-making.

H. Marketing and Promotional Activities

To provide rewards, benefits, promotional campaigns, loyalty incentives, discounts, invitations, and marketing communications tailored to your profile and preferences, where permitted by applicable law.

I. Loyalty and Membership Programs

To administer and manage loyalty, rewards, membership, referral, and related programs operated by Asolear Group or its affiliated entities.

J. Customer Communications

To communicate with you regarding your account, transactions, inquiries, requests, feedback, complaints, claims, disputes, surveys, service updates, and other customer service matters.

K. Enhanced Customer Experience

To improve your shopping and service experience and provide access to membership benefits, rewards, offers, educational programs, healthcare services, and other initiatives offered by Asolear Group.

L. Compliance with Terms and Policies

To enforce our Terms of Use, contractual rights, internal policies, and other agreements governing the use of our products, services, websites, and mobile applications.

M. Security, Fraud Prevention, and Risk Management

To detect, investigate, prevent, and respond to fraud, unauthorized access, illegal activities, cybersecurity incidents, financial loss, security threats, and other risks affecting our users, business, or systems.

N. Legal and Regulatory Compliance

To comply with applicable laws, regulations, legal processes, governmental requests, court orders, regulatory requirements, and industry standards.

O. Other Legitimate Purposes

To serve any other purpose for which we provide specific notice at the time of collection or where otherwise authorized, required, or permitted under applicable law.

Legal Basis for Processing

Where required under applicable laws, including data protection and privacy laws, we will process your personal information (including sensitive personal information, where applicable) only:

• With your consent;
• Where necessary to provide products or services requested by you;
• To fulfill contractual obligations;
• To comply with legal or regulatory obligations;
• To protect vital interests;
• For the establishment, exercise, or defense of legal claims; or
• Where we have a legitimate business interest that is not overridden by your rights and freedoms.

Where we derive insights, profiles, preferences, or other inferences from your Data, such information will be treated as personal information (or sensitive personal information, where applicable) and protected in accordance with this Privacy Notice and applicable laws.

Some of the purposes listed above may overlap, and more than one legal basis may apply to the processing of your Data.

7. MINORS

Our website, mobile applications, products, and services are not directed toward individuals under the age of 18 years ("Minors").

If you are under 18 years of age, you may use our website or mobile application only under the supervision and with the consent of a parent or legal guardian. We do not knowingly collect personal information from Minors without appropriate parental or guardian consent where required by applicable law.

If we become aware that we have inadvertently collected personal information from a Minor without the necessary consent, we will take reasonable steps to delete such information promptly.

8. SHARING OF DATA

We may share your Data with the following categories of recipients for the purposes described in this Privacy Notice:

A. Partners

We may make available products, services, applications, promotions, and programs offered by our authorized Partners through our website, mobile application, or other platforms. Where you choose to engage with such offerings, relevant Data may be shared with the applicable Partner to facilitate the provision of those products or services.

All Partners are required to process your Data in accordance with applicable laws and appropriate confidentiality and security obligations.

B. Asolear Group Entities

We may share your Data with Asolear Group Entities to:

• Provide products and services;
• Manage customer relationships;
• Process your requests and inquiries;
• Conduct marketing and promotional activities;
• Administer loyalty and rewards programs; and
• Support business operations and service delivery.

C. Unified Customer Platforms

Where Asolear Group operates integrated customer platforms, loyalty programs, or unified account systems, your Data may be shared among participating Asolear Group Entities and authorized service providers to facilitate enrollment, account management, customer support, rewards, benefits, and a seamless user experience across multiple Asolear services.

D. Service Providers

We may engage third-party Service Providers to perform functions on our behalf, including:

• Data storage and hosting;
• Payment processing;
• Customer support;
• Analytics and reporting;
• Fraud prevention and security monitoring;
• Technology support and maintenance;
• Marketing and communication services; and
• Other business operations.

Such Service Providers are contractually obligated to process Data only in accordance with our instructions and applicable laws and to implement appropriate technical, organizational, and security measures.

E. Information Received from Other Sources

Where you authorize third parties to share information with us, we may receive and process such Data in accordance with this Privacy Notice and applicable laws.

F. Protection of Asolear Group and Others

We may disclose Data where necessary to:

• Comply with applicable laws, regulations, court orders, or governmental requests;
• Enforce our Terms of Use and contractual rights;
• Protect the rights, property, safety, and security of Asolear Group, our users, employees, or third parties;
• Investigate, prevent, or address suspected fraud, illegal activity, cybersecurity incidents, or other misconduct; and
• Establish, exercise, or defend legal claims.

G. Business Transfers

In connection with a merger, acquisition, restructuring, reorganization, financing transaction, sale of assets, or other corporate transaction, your Data may be transferred to the relevant successor entity or transaction participant, subject to appropriate confidentiality and legal safeguards.

H. Other Third Parties

We may share your Data with other third parties where:

• You have expressly consented to such disclosure;
• You request or authorize us to do so;
• Disclosure is required by law or legal process; or
• Disclosure is necessary to maintain the security and integrity of our systems and services.

Please note that the privacy practices of Asolear Group Entities, Partners, and third-party websites may differ from those described in this Privacy Notice. When you interact directly with such entities, their respective privacy policies will govern the collection and use of your information.

9. KEEPING DATA SECURE

We maintain appropriate technical, administrative, and organizational safeguards designed to protect your Data against unauthorized access, disclosure, alteration, loss, misuse, or destruction.

These measures may include:

• Secure server infrastructure;
• Access controls and authentication procedures;
• Encryption and data protection technologies;
• Network and application security monitoring;
• Employee confidentiality obligations; and
• Incident response and breach management procedures.

If you become aware of any unauthorized use of your Data or suspect a security incident, please contact us immediately using the details provided in the "How to Contact Us" section.

10. RETENTION OF DATA

We retain your Data only for as long as necessary to:

• Provide products and services;
• Maintain your account and customer relationship;
• Comply with legal, regulatory, tax, accounting, and reporting obligations;
• Resolve disputes;
• Enforce agreements; and
• Protect our legitimate business interests.

Retention periods vary depending on the nature of the Data and the purpose for which it is processed.

Even after deletion, certain Data may remain in backup systems, archives, audit logs, or records where retention is required by law or necessary for legal, regulatory, tax, security, or compliance purposes.

11. YOUR RIGHTS AND CHOICES

Subject to applicable law, you may have the following rights regarding your personal information:

A. Right of Access

To request access to the personal information we hold about you.

B. Right to Correction

To request correction or updating of inaccurate, incomplete, or outdated information.

C. Right to Withdraw Consent

To withdraw any consent previously provided for the processing of your personal information, subject to legal or contractual restrictions.

D. Right to Erasure

Where permitted by law, to request deletion of your personal information.

E. Right to Grievance Redressal

To raise concerns or complaints regarding the processing of your personal information.

To exercise any of these rights, please contact us using the details provided in the "How to Contact Us" section.

You are responsible for ensuring that the information you provide to us remains accurate and up to date.

12. WHERE WE STORE DATA

Data collected under this Privacy Notice is primarily stored and processed on secure servers located within India.

Where permitted by applicable law, Data may also be processed by authorized service providers or affiliates in other jurisdictions, subject to appropriate contractual, legal, and security safeguards.

13. PROCESSING OF DATA

We process Data in accordance with this Privacy Notice and applicable laws.

To ensure adequate protection of your Data, we maintain appropriate contractual arrangements with Asolear Group Entities, Partners, and Service Providers who process Data on our behalf. These arrangements require such parties to implement appropriate privacy, confidentiality, and security measures consistent with applicable legal requirements.

14. APP PERMISSIONS WE MAY REQUEST

Depending on the features you use, our mobile application may request access to certain device permissions, including:

Location

To provide location-based services, product availability information, and personalized experiences.

Camera

To enable image capture, document uploads, prescription uploads, profile photos, and related features.

Photos, Media, and Files

To allow uploading, storing, and accessing files, documents, and images selected by you.

SMS and OTP Verification

To facilitate secure account verification and automatic OTP detection where supported.

Wi-Fi and Network Information

To optimize application performance, connectivity, and service delivery.

Microphone

To support voice calls, video consultations, audio recording features, and customer support interactions.

Bluetooth

To enable connectivity with compatible Bluetooth-enabled devices and accessories.

You may manage or revoke these permissions at any time through your device settings, although doing so may affect the functionality of certain features.

15. SEVERABILITY

If any provision of this Privacy Notice is determined by a court or competent authority to be invalid, illegal, or unenforceable, such provision shall be deemed modified or removed to the minimum extent necessary, and the remaining provisions shall remain valid, enforceable, and in full force and effect.

16. CHANGES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time to reflect changes in our business practices, technologies, legal requirements, or services.

Any updated version of this Privacy Notice will be published on our website and mobile applications and will become effective upon publication unless otherwise stated.

Where required by applicable law, we will notify you of material changes through appropriate communication channels.

We encourage you to periodically review this Privacy Notice to stay informed about how we collect, use, share, and protect your information.

17. HOW TO CONTACT US

If you have any questions, concerns, requests, or complaints regarding this Privacy Notice or the manner in which your personal information is collected, used, stored, disclosed, or processed by Asolear Group, you may contact us using the details below:

Asolear Pharma Private Limited
1st Floor, DDA Sheds B-133, Okhla Industrial Area, Phase-I, South Delhi, New Delhi – 110020, India

Website:https://asoleargroup.com
Email:asoleargroup@gmail.com(or your designated privacy/contact email address)

You may contact us to:

• Access, review, update, or correct your personal information;
• Withdraw consent previously provided for the processing of your personal information, where applicable;
• Request deletion of your personal information, subject to applicable law;
• Exercise any rights available to you under applicable data protection laws;
• Obtain information regarding the categories of Service Providers, Partners, and Asolear Group Entities with whom your Data may be shared; or
• Submit any privacy-related query, concern, complaint, or grievance.

We will acknowledge and respond to your request within a reasonable period and, where required by applicable law, within thirty (30) days from the date of receipt of your request.

Where required under applicable law, privacy complaints and grievances will be handled in accordance with our grievance redressal procedures and applicable regulatory requirements.

18. GRIEVANCE OFFICER

In accordance with applicable laws and regulations, including data protection and privacy requirements, Asolear Pharma Private Limited has appointed a Grievance Officer to address any concerns, complaints, or requests relating to the collection, processing, storage, use, disclosure, or protection of personal information.

The contact details of the Grievance Officer are as follows:

Name: Mr. S.K. Kushwaha
Designation: Grievance Officer
Email:asoleargroup@gmail.com

Postal Address:
Grievance Officer
Asolear Pharma Private Limited
B-133, DDA Sheds, Okhla Industrial Area, Phase-I,
South Delhi, New Delhi – 110020, India

You may contact the Grievance Officer regarding:

• Privacy-related complaints or concerns;
• Requests to access, update, correct, or delete personal information;
• Withdrawal of consent;
• Questions regarding the processing of personal information;
• Data protection and privacy rights; or
• Any other matter relating to this Privacy Notice.

The Grievance Officer will acknowledge and address your concerns within the timelines prescribed under applicable law.