PRIVACY POLICY
At The Luxe Wardrobe ("we," "us," or "our"), we are committed to protecting the privacy and security of our discerning clientele. We understand that our services—ranging from wardrobe management and personal styling to exclusive membership privileges—require a high degree of trust and confidentiality. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal data when you interact with our website, utilize our bespoke services, or join our exclusive membership tier, The Front Row.
Note: This Privacy Policy should be read in conjunction with our Terms & Conditions available at www.theluxewardrobe.com/terms-conditions.
Applicability: This policy is crafted to ensure compliance with applicable Indian data protection laws, including the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules"), and the Digital Personal Data Protection Act, 2023 ("DPDP Act"). By using our services, you explicitly agree to the terms of this Privacy Policy.
1. WHO WE ARE
The Luxe Wardrobe is a premier luxury lifestyle management consultancy specializing in personal styling, wardrobe curation, and corporate grooming.
Registered Office:
The Luxe Wardrobe Pvt. Ltd. [Insert Full Indian Address] [City], India
Email: info@theluxewardrobe.com
Website: www.theluxewardrobe.com
2. APPLICABILITY & JURISDICTION
This Privacy Policy applies to all clients, members of The Front Row, website visitors, and participants in our workshops who are located in India or avail our services offered pan-India.
3. INFORMATION WE COLLECT
We collect various types of personal data to provide our bespoke services. By engaging with us, you consent to the collection of the following categories of data, which we deem necessary for optimal service delivery:
| Category | Description of Data Collected |
|---|---|
| Identity & Contact Data | Name, username, marital status, title, date of birth, gender, billing address, delivery address, email address, telephone numbers, business associates and their contact information (where relevant for gifting/corporate services), and social media profile data obtained through public sources or provided by you. |
| Styling & Physical Data | Body measurements, height, weight, skin tone, hair color, eye color, clothing sizes (across brands), shoe size, fit preferences, personal style preferences, lifestyle details, and photographs of your person and wardrobe. |
| Financial Data | Bank account details, payment card details (processed securely via third-party gateways), spending history, luxury purchase preferences, and creditworthiness assessment data. |
| Technical & Usage Data | Internet Protocol (IP) address, login data, browser type and version, time zone setting, location data, device identifiers, mobile advertising IDs, operating system, and information about how you use our website and services. |
| Profile Data | Membership ID, purchases/orders made by you, interests, preferences, feedback, survey responses, and behavioral inferences drawn from your interactions with our services. |
| Other Data | Any other data necessary for optimal service delivery as determined by the specific requirements of your bespoke request. |
4. HOW WE USE YOUR INFORMATION
We use your personal data for legitimate business purposes permitted under Indian law, including but not limited to:
- Service Delivery: To provide wardrobe management, personal styling, shopping services, and membership benefits.
- Business Operations: To manage our relationship with you, process payments, and ensure business continuity.
- Analytics & Improvement: For business analytics, trend analysis, service improvement, and to create anonymized datasets for research and commercial purposes.
- Marketing & Promotion: To provide you with information about services we feel may interest you, including targeted advertising and promotional campaigns (unless you have opted out).
- Risk Management: To assess creditworthiness, payment capacity, and for security, fraud prevention, and risk assessment purposes.
- Legal Compliance: To comply with legal obligations, including tax laws and regulatory requirements.
5. LEGAL BASIS FOR PROCESSING
Under Indian data protection laws, we process your personal data based on the following lawful grounds:
| Lawful Basis | Context |
|---|---|
| Consent | We obtain your explicit consent before collecting and processing sensitive personal data or information (SPDI). By using our services, you grant broad consent for data processing necessary for our business operations. |
| Performance of Contract | To fulfill our contractual obligations to you regarding styling services, membership benefits, and product delivery. |
| Legitimate Interests | To improve our services, manage our relationship with you, prevent fraud, ensure business continuity, and maintain the security of our operations. |
| Legal Obligation | To comply with applicable Indian laws, including tax regulations and financial reporting requirements. |
6. SHARING OF INFORMATION
We may share your personal data with third parties to facilitate our services and business operations. By using our services, you explicitly consent to such sharing with:
- Service Partners: Personal shoppers, stylists, photographers, tailors, and luxury brands/retailers involved in fulfilling your requests.
- Business Associates: Business partners, affiliates, and group companies for joint marketing efforts and cross-promotions.
- Service Providers: IT and system administration providers, data analytics providers, marketing platforms, and professional advisers (lawyers, auditors, insurers).
- Financial Institutions: Credit agencies, banks, and payment processors for payment verification and credit risk assessment.
- Legal Authorities: Regulators, law enforcement agencies, and other authorities where required by law.
- Business Successors: Any successor entity or third party in the event of a merger, acquisition, restructuring, or sale of assets/business.
Note: You acknowledge that certain data sharing is essential for our business operations and cannot be restricted without impacting service delivery.
7. DATA SECURITY & LIABILITY
We have implemented reasonable security practices and procedures commensurate with the information assets being protected and the nature of our business.
Limitation of Liability: While we strive to use commercially acceptable means to protect your personal data, you acknowledge that no method of transmission over the Internet or method of electronic storage is 100% secure. To the fullest extent permitted by law:
- We shall not be liable except as expressly provided herein for unauthorized access, hacking, data loss, or data breaches caused by circumstances beyond our reasonable control or due to third-party actions.
- Our total liability for any data breach or privacy violation shall be strictly limited to INR 50,000 (Fifty Thousand Rupees) OR the total fees paid by you for Services in the preceding six (6) months, whichever is LOWER.
- You are solely responsible for maintaining the confidentiality of your account login credentials and for any activity that occurs under your account.
8. INTERNATIONAL DATA TRANSFERS
As a luxury service provider with international operations and partners, we may transfer, store, and process your data outside India.
- Consent to Transfer: By using our services, you explicitly consent to the transfer of your personal data to countries outside India, including to cloud servers and service providers located in jurisdictions that may have different data protection laws.
- Safeguards: While we endeavor to ensure appropriate safeguards (such as contractual protections), you acknowledge that overseas data transfers carry inherent risks and may be subject to foreign laws and access by foreign authorities.
9. DATA RETENTION
We retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, and for legitimate business interests.
| Data Category | Retention Period |
|---|---|
| Client Profiles & Styling Data | Retained for a minimum of 7 years after the end of the client relationship to facilitate re-engagement, trend analysis, and service continuity. |
| Financial & Transaction Data | Retained for a minimum of 7 years as mandated by the Income Tax Act, 1961 and other financial regulations. |
| Marketing Data | Retained indefinitely unless we receive a valid, verified request for deletion from you. |
| Visual Assets | Photography, wardrobe images, and styling portfolios may be retained permanently for quality assurance, portfolio records, and historical trend analysis. |
We reserve the right to retain anonymized data indefinitely for research and statistical purposes without further notice to you.
10. MARKETING COMMUNICATIONS
We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.
- Opt-Out Mechanism: You will receive marketing communications from us unless you have explicitly opted out. You may ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us.
- Processing Time: Please allow 30-45 business days for your opt-out request to be processed and reflected in our systems.
- Service Messages: Even if you opt out of marketing messages, we may still send you transactional and service-related communications (e.g., order updates, appointment confirmations, membership notices) which are necessary for the performance of our contract.
- Legitimate Interest: We may process your data for direct marketing purposes based on our legitimate business interests where permitted by law, even without explicit consent, provided it does not override your fundamental rights.
11. YOUR RIGHTS UNDER INDIAN LAW
Under the Digital Personal Data Protection Act, 2023 and SPDI Rules, you have certain rights. However, these rights are subject to limitations necessary for our business operations and legal compliance.
11.1 RIGHT TO ACCESS & CORRECTION
You may request access to or correction of your personal data. We reserve the right to verify your identity through government-issued photo ID and address proof before processing any such request.
11.2 RIGHT TO ERASURE
You may request the deletion of your personal data, subject to the following exceptions where we may be required or permitted to retain data:
- For compliance with legal obligations (e.g., tax, audit).
- For the establishment, exercise, or defense of legal claims.
- For legitimate business interests, including fraud prevention and security.
11.3 RIGHT TO WITHDRAW CONSENT
You may withdraw consent for data processing at any time by contacting us. However:
- Withdrawal is prospective only and does not affect the lawfulness of processing carried out prior to withdrawal.
- We may continue to retain and process your data where required for legal compliance or legitimate business purposes.
- Withdrawal of consent may result in our inability to provide certain services to you.
- Processing time for withdrawal of consent is 30-45 days.
11.4 PROCESSING FEES & LIMITATIONS
We aim to respond to all legitimate requests within 30-45 days. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Fees: We reserve the right to charge a reasonable fee (minimum INR 500) for excessive, repetitive, or manifestly unfounded requests, or for requests requiring significant administrative effort. We may also refuse to comply with such requests.
12. AUTOMATED DECISION MAKING & PROFILING
We may use automated decision-making and profiling technologies to:
- Analyze your preferences and tailor our services.
- Determine pricing tiers and membership eligibility.
- Assess credit risk and fraud probability.
You may request a human review of significant automated decisions, but you acknowledge that the final decision remains at our discretion based on our business criteria.
13. YOUR RIGHTS UNDER INDIAN LAW
Under the Digital Personal Data Protection Act, 2023 and SPDI Rules, you have certain rights. However, these rights are subject to limitations necessary for our business operations and legal compliance.
13.1 RIGHT TO ACCESS & CORRECTION
You may request access to or correction of your personal data. We reserve the right to verify your identity through government-issued photo ID and address proof before processing any such request.
13.2 RIGHT TO ERASURE
You may request the deletion of your personal data, subject to the following exceptions where we may be required or permitted to retain data:
- For compliance with legal obligations (e.g., tax, audit).
- For the establishment, exercise, or defense of legal claims.
- For legitimate business interests, including fraud prevention and security.
13.3 RIGHT TO WITHDRAW CONSENT
You may withdraw consent for data processing at any time by contacting us. However:
- Withdrawal is prospective only and does not affect the lawfulness of processing carried out prior to withdrawal.
- We may continue to retain and process your data where required for legal compliance or legitimate business purposes.
- Withdrawal of consent may result in our inability to provide certain services to you.
- Processing time for withdrawal of consent is 30-45 days.
13.4 PROCESSING FEES & LIMITATIONS
We aim to respond to all legitimate requests within 30-45 days. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Fees: We reserve the right to charge a reasonable fee (minimum INR 500) for excessive, repetitive, or manifestly unfounded requests, or for requests requiring significant administrative effort. We may also refuse to comply with such requests.
14. AUTOMATED DECISION MAKING & PROFILING
We may use automated decision-making and profiling technologies to:
- Analyze your preferences and tailor our services.
- Determine pricing tiers and membership eligibility.
- Assess credit risk and fraud probability.
You may request a human review of significant automated decisions, but you acknowledge that the final decision remains at our discretion based on our business criteria.
15. CHANGES TO THIS PRIVACY POLICY
We reserve the right to update or modify this Privacy Policy at any time without prior individual notice. Any changes will be effective immediately upon posting the revised policy on our website.
Acceptance of Changes: Your continued use of our services after any changes to this Privacy Policy constitutes your acceptance of such changes. It is your responsibility to review this Privacy Policy periodically for updates. Material changes may be notified via email, but failure to receive such email does not invalidate the changes.
16. CONTACT US & GRIEVANCE REDRESSAL
If you have any questions, concerns, or complaints about this Privacy Policy or our data processing practices, please contact our Grievance Officer as required under the SPDI Rules:
Grievance Officer Name: [Insert Name]
Designation: Chief Privacy Officer / Grievance Officer
Company: The Luxe Wardrobe Pvt. Ltd.
Email: privacy@theluxewardrobe.com
Phone: +91 [Insert Number]
Postal Address: [Insert Full Business Address], India
Response Time: We aim to resolve all complaints within 30-45 days of receipt.
If your grievance is not resolved to your satisfaction, you have the right to lodge a complaint with the Data Protection Board of India established under the Digital Personal Data Protection Act, 2023.
17. GOVERNING LAW
This Privacy Policy is governed by the laws of India. Any disputes arising out of or in connection with this policy shall be subject to the exclusive jurisdiction of the courts in New Delhi, India.
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