PRIVACY POLICY FOR ONLINE AND OFFLINE STORES

WROGN ("WROGN" or "we" or "us" or "our") is committed to protecting your personal identifiable Information (the "Personal Information"). This privacy policy (“Policy”) details how WROGN gathers and handles the personal information obtained through:

• websites owned, operated or controlled by us from which you are accessing this Privacy Policy (individually, a "Website", and collectively, the "Websites");
• the software applications made available by us for use on or through computers and mobile devices (collectively, the "Software");
• our social media pages that we control from which you are accessing this Privacy Policy (collectively, our "Social Media Pages")
• your communications with us or through other offline activities and interactions (e.g., customer visit to physical stores for shopping, service inquiries and engagements, user conferences, etc.)

(Collectively, we refer to the Websites, Social Media Page and Software as the ‘Online Services’ and together with offline channels the "Services").

By visiting our physical store and using usplworld.com, you are accepting and consenting to the practices described in this Policy, so please read this Policy carefully before using our Services.

We understand that you care about how your personal information is obtained and used, and we appreciate your faith in our ability to uphold the highest standards of care and sensibility in handling your data. WROGN is committed to respecting and upholding your privacy, and if you have any further questions in this regard please feel free to contact us at the coordinates listed below.

1. Personal Information

Personal information, for the purposes of this Policy, refers to information that can be used to specifically identify any individual customer of ours, such as the customer’s name, address, email address, payment data, telephone number etc. This would also include information about a customer’s activities with regard to the usage of our Services, and demographic information such as nationality, date of birth, gender, geographic area, and preferences, whenever any such information is linked to the personal information that identifies an individual. Accordingly, we collect personal information from customers to help us personalise and continually improve their shopping experience at usplworld.com. We use the information we gather from you to assist us in:

• Handling orders.
• Delivering products and services.
• Processing payments.
• Communicating with you about orders, products, services and promotional offers.
• Updating our records and generally maintaining your account with us.
• Displaying content such as wishlists and customer reviews.
• Recommending merchandise and services relevant to your interests.

We also use this information to improve our platform, prevent or detect fraud or abuses of our Services and enable third parties to carry out technical, logistical or other such functions on our behalf.

1. Types of information gathered:

Information You Provide at Online Services: We receive and store any information submitted by the customer on our website, mobile applications, or through any other platform or medium of communication. Customers retain the right not to provide certain information, however, this may interfere with their ability to avail full advantage of several of our features.

We use the information that you provide for the purpose of:

• Responding to your requests.
• Customising your future shopping experience.
• Improving our platform.
• Personalising communications with you.

Information You Provide at Offline Physical Stores: We receive and store any information submitted by the customer at our offline physical stores, i.e, name, contact number, date of birth, age. Customers retain the right not to provide certain information, however, this may interfere with their ability to avail full advantage of several of our features.

We use the information that you provide for the purpose of:

• Communicating with you about
• any type of sales/ offers/promotions/discounts,
• new product range,
• coupons,
• loyalty points,
• personalised promotions or
• any other type of sales and marketing purposes.

Automatic Information: We receive and store certain types of information at each instance of your interaction with us. For example, like many websites, we use cookies to obtain certain types of information when you access usplworld.com, or advertisements and other content served on other websites by or on behalf of usplworld.com, through your web-browser.

Shopping Behaviour: In order to personalise your product feed on WROGN, we collect information based on your shopping behaviour. Aside from the products that you purchase, this includes but is not limited to the products that you view, add to your wishlist, and add to your shopping cart while browsing usplworld.com. Additionally, we collect the information that you submit in the course of taking our Style Quiz which includes questions regarding style preference, colour preference, your aesthetic sensibilities, and your body shape. This information is only collected when you willingly provide it to us by answering the quiz questions and is used only to customize your product feed.

Third Parties: We may receive Personal information about you from third parties, such as social media services, commercially available sources, and business partners. If you access our Services through a social media service or connect a service on our website or mobile applications to a social media service, the information we collect may include your user name associated with that social media service; as well as any information or content the social media service has the right to share with us - such as your profile picture, email address or friends list, and any information you have made public in connection with that social media service. When you access the Website or mobile applications or otherwise engage any WROGN entity through social media services, or when you connect any Website or mobile application to social media services, you are authorizing WROGN to collect, store, and use and retain such information and content in accordance with this Policy.

E-mail Communications: In order to understand and improve the relevance of our email communications with you, we often receive a confirmation when you open an email from usplworld.com. The customer is free to unsubscribe from further email communications, if they wish to do so, by clicking the Unsubscribe link in the emails.

Information from Other Sources: We might receive information about you from other sources and add it to our account information. By using or continuing to use the site, you agree to our use of your information (including sensitive personal information) in accordance with this Policy, as may be amended from time to time by usplworld.com in its discretion. You also agree and consent to us collecting, storing, processing, transferring and sharing information (including sensitive personal information) related to you with third parties or service providers for the purposes as set out in this Privacy Notice.

1. Sharing Information with Third Parties

Information about our customers is an important part of our business and we are not in the business of selling it to others. usplworld.com shares customer information only as described below with usplworld.com and the subsidiaries which usplworld.com controls and that are either subject to this Privacy Notice or follow practices at least as protective as those described in this Privacy Notice.

Affiliated Businesses We Do Not Control:

• We work closely with affiliated businesses. In some cases, such as Marketplace sellers, these businesses operate stores at usplworld.com or sell offerings to you at usplworld.com.
• In other cases, we provide services jointly with or on behalf of these businesses.

Third Party Service Providers:

• We employ other companies and individuals to perform functions on our behalf. Examples include fulfilling orders, delivering packages, sending postal mail and e-mail, analysing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments and providing customer service.
• They have access to personal information needed to perform their functions but may not use it for other purposes. Further, they must process the personal information in accordance with this Privacy Notice and as permitted by the applicable law.
1. Compliance with the Law
• We may be required to share the personal information with government authorities and agencies for, inter alia, the purposes of verification of identity or for prevention, detection, investigation including cyber incidents, prosecution and punishment of offences.
• Further, we may release account and other personal information when we believe release is appropriate to enforce or apply our Conditions of Use and other agreements; or protect the rights, property or safety of usplworld.com, our users or others.
• This includes exchanging information with other companies, organisations, government or regulatory authorities for fraud protection and credit risk reduction.

You agree and consent for WROGN stores or usplworld.com to disclose your information, if so required under the applicable law. Obviously, however, this does not include selling, renting, sharing or otherwise disclosing personally identifiable information from customers for commercial purposes in a way that is contrary to the commitments made in this Privacy Notice.

When you use the WROGN Software, you may also be using the services of one or more third parties, such as Google, Facebook, MSD, Vizury, AppsFlyer, Acra, WizRocket, CleverTap, YouTube Android Player, Konotor, juspay, newrelic, squareup, packetzoom, mixpanel, proguard. Your use of these third party services may be subject to the separate policies, terms of use, and fees of these third parties.

1. Examples of Information Collected

Information You Give Us:

You provide most such information when you search, buy by availing online services or by visiting at offline physical stores, participate in a contest or questionnaire, or communicate with customer service. For example, you provide information when you:

• Visit offline/physical stores to buy accessories, apparels, shoes.
• Search for a product.
• Place an order through usplworld.com or one of our third-party sellers.
• Provide information in Your Account (and you might have more than one if you have used more than one e-mail address when shopping with us) or your "Your Profile" communicate with us by phone, e-mail or otherwise.
• Complete a questionnaire or a contest entry form.
• Compile Wish Lists, provide and rate Reviews.
• Employ other personal notification services and Order Notifications.

As a result of those actions, you might supply us with such information as: your name; address and phone number; credit card information; people to whom purchases have been dispatched (including addresses and phone numbers); content of reviews and e-mails to us; the personal description in your "Your Profile" and financial information.

Automatic Information:

Examples of the information we collect and analyses include -

• The Internet protocol (IP) address used to connect your computer to the Internet.
• Login, e-mail address, password, computer and connection information such as browser type and version, and operating system and platform
• Purchase history, which we sometimes aggregate with similar information from other customers to create features such as Best Sellers.
• The full Uniform Resource Locators (URL) clickstream to, through and from our website or mobile applications (including date and time).
• Cookie number.
• Products you viewed or searched for.
• Phone numbers used to call our customer service number.

We may also use browser data such as cookies, Flash cookies (also known as Flash Local Shared Objects), or similar data on certain parts of our website or mobile applications for fraud prevention and other purposes.

During some visits we may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Information from Other Sources:

Examples of information we receive from other sources include: updated delivery and address information from our carriers or other third parties, which we use to correct our records and deliver your next purchase or communication more easily; account information, purchase information and page-view information from some merchants.

1. Information You Can Access

Examples of information you can access easily through your WROGN account include -

• Up-to-date information regarding recent orders.
• Personal information (including name, e-mail, password, communications and personalization information).
• Payment details (including credit-card information).
• E-mail notification settings (including Alerts, Available to Order notifications, Delivers, Recommended for You and newsletters).
• Recommendations (including prior-order history).
• Wish Lists and products added to cart (only if the products are not sold out.)
1. Use of cookies

Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your Web browser. This enables our systems to recognize your browser and to provide features such as personalized recommendations, personalized advertisements on other Websites and storage of items in your Shopping Cart between visits. You can read more about how the cookies are used by referring to our cookie policy here: https://www.wrogn.com/cookie-policy/.

1. App & Device Information

We collect information about your device to make your experience on our app better and to help us analyze app crashes, debugging device specific issues and for marketing analytics.

The device information we collect includes:

• App Name, App Identifier (package name in case of the Android), App Version, App Locale, App Installed Time, App Updated Time, Mobihelp SDK Version, OS, OS Version, OS Locale.
• Device Brand, Release Keys, Device Fingerprint, Device ID, Device Manufacturer, Device Version, Referrer, Device OS, Device Info Dump, Device Make, Installer, Device Model, Device SW Build (like the carrier/custom branding of the Android OS where applicable).
• Current Active Network (as WiFi vs Mobile Network), Mobile Network Type (as GPRS/EDGE/HSPA etc), Mobile Network Operator Name, Mobile Network Country Code.
• Battery Level, Battery Status (Charging/Discharging), Screen Orientation, Device Storage Space Free/Total in MB (Internal Storage), Device Storage Space Free/Total in MB (SD Card).

We also collect referrer information which tells us the third party that referred you to us and can include utm parameters (UTM parameters are simply tags you add to a when your link is clicked, the tags are sent back to Google Analytics and tracked). We also collect information about the channel through which you installed our app, which provides us insights about our marketing advertisements and partners working with us. For example, if you install our app by clicking on an advertisement on a platform, we will get information regarding the partner (being Google in this example) and the advertisement you clicked on which is identified by an alphanumeric.

1. Securing Information & Retention

We guarantee to protect the security of your information during the purchase of any product on WROGN. For all our online payments we use a Secure Sockets Layer (SSL) software, which encrypts information you input in addition to maintaining the security of your information.

We reveal only the last four digits of your credit card numbers when confirming an order. Of course, we transmit the entire credit card number to the appropriate credit card company during order processing.

We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal information (including sensitive personal information).

Our security procedures dictate that we may occasionally request proof of identity before we disclose personal information to you.

If you choose a payment gateway to complete any transaction on Website or mobile applications then your credit card data may be stored in compliance with industry standards/recommended data security standard for security of financial information such as the Payment Card Industry Data Security Standard (PCI-DSS).

It is important for you to protect yourself against unauthorized access to your password and to your computer. Be sure to sign out when you finish using a shared computer or if you are working over an unsecure or public network.

1. Use of Information and Duration

WROGN will strive to protect the privacy and legal rights of all its users. Any and all Personal and Sensitive Information you provide to us such as usernames, emails, phone number, passwords or any other login information or personal information will be available to us and we have the right to use this information until you communicate with us and direct us not to use it further. By making use of the Service, you agree for all Personal Information to be retained up until the time it is required for the Purpose or required under applicable law, whichever is later.

1. All Non-Personal Information will be retained indefinitely:

If you delete the WROGN application from your mobile device or delete your account on the WROGN website, we will retain your Personal Information for analytical purposes and recordkeeping integrity, as well as to prevent fraud, enforce our Terms of Use, take actions we deem necessary to protect the integrity of our Service or our users, or take other actions otherwise permitted by law.

In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third party policies.

If you do not want us to use personal information that we gather to personalize advertisements we display to you or for other purposes, please write to us at support@wrogn.com.

(If you do not want to receive Conditions of Use and other legal notices from us, such as this Privacy Notice, those notices will still govern your use of usplworld.com and orders placed with usplworld.com. It is your responsibility to review them for changes.)

1. Associated Third Parties

The Services may contain links to other websites, products or services that we do not own or operate, irrespective of whether they are posted by us or third party users of WROGN.

If you choose to visit or use any third-party sites or products or services made available through a link on WROGN, please be aware that this Policy will not apply to your activities or any information you disclose while visiting or using those services.

WROGN is not responsible for the privacy practices of any such third-party sites or any products or services on or through them.

1. Security Precautions

We maintain reasonable physical, electronic and procedural safeguards to protect your information. Whenever you access your account information, we offer the use of a secure server. Once your information is in our possession, we adhere to our security guidelines to protect it against unauthorized access. However, by using the Platform, the users accept the inherent security implications of data transmission over the internet and the World Wide Web which cannot always be guaranteed as completely secure, and therefore, there would always remain certain inherent risks regarding use of the Platform. Users are responsible for ensuring the protection of login and password records for their account.

1. Choice/Opt-Out

In order to understand and improve the relevance of our communications with you, we may send promotional communications through channels such as WhatsApp, SMS, Push Notifications, email etc. In case users do not wish to receive promotional communications, you have an option to opt-out manually at any point in time.

1. Children Information

We do not knowingly solicit or collect personal information from children under the age of 18 and use of our Platform is available only to persons who can form a legally binding contract under the Indian Contract Act, 1872. If you are under the age of 18 years then you must use the Platform, application or services under the supervision of your parent, legal guardian, or any responsible adult.

1. International Visitors:

If you are using our services from outside India, please be aware that your Personal Information may be sent to, stored and processed at our servers and data centers which are located in India.

By providing your personal information to us through your use of our Service, you agree to the transfer, storage, and processing of this information in India. We may also transfer your data from India to other countries in connection with the operation of the Services.

Note that each country has its own privacy and data security laws, which differ significantly from region to region, and hence those applicable to s area of operation may not be as stringent as those in your home country.

1. Changes to this Privacy Policy

Please check our Privacy Policy periodically for changes. We may update this Privacy Policy to reflect changes to our information practices. We will alert you to significant changes by posting the date our policy got last updated, placing a notice on our Platform, or by sending you an email when we are required to do so by applicable law.

1. Grievance Officer

In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below:
Narayanaswami Appadurai
Head of Compliance
Email id: compliance1@usplworld.com | narayan@usplworld.com

1. Queries

If you have a query, issue, concern, or complaint in relation to collection or usage of your personal information under this Privacy Policy, please contact us at the contact information provided above.

By accessing the Website (www.wrogn.com) and WROGN Apps (Android & iOS), You have agreed to the terms set out in this Policy. This Policy should be read at all times along with the Terms of Use of the Website.