SAMMMM HBW PRIVATE LIMITED through the brand “Sammmm” (“Sammmm”, “Company” “we”, “our”, “us” and its respective connotations) respects an individual’s privacy and is committed to protecting the same. Please read the following to learn more about our privacy policy (“Policy”).  The Platform gathers certain information with prior consent from the users utilising the Platform as described in the Terms and any visitors of the Platform (hereinafter referred to as “users”, “you” and its respective connotations).This policy applies to the Personal Information (defined below) that we collect with respect to your interactions, use, and experience with our website at https://sammmm.com/en (our “Website”), our app on iOS or Android (our “App”) (hereinafter collectively referred to as “Platform(s)”). We will not disclose the Personal Information (defined in clause 1 below) shared by the user other than in compliance with this Policy. If you do not consent to any of the terms enumerated in this Policy, do not proceed to use the Platform. 

This Platform is directed to be used by adults only who are above the age of 18 years. If you are not an adult, you may look at our Platform, but you should not make a purchase, register, or submit personal information to us. If you are not an adult kindly register yourself through your parent/guardian and such a parent/guardian hereby agrees to accordingly register and supervise usage by and be responsible for the action of any such minor. We or our associates/affiliates do not knowingly collect information from minors. 

Further, you agree and consent that you will not violate or attempt to violate the security of the Platforms, including, without limitation (a) accessing any data or logging onto a server in an unauthorised manner; (b) attempting to or committing a breach of a secured system or network, including interfering with any other user’s account, system, by “flooding”, “spamming” etc. (c) sending unsolicited email, including promotions and/or advertising of products or services; (d) forging any header or any part of the header information in any email or newsgroup posting; or e) threatening the unity, integrity, defence, security or sovereignty of India, public order or causes incitement to the commission of any cognizable offence or prevents investigation of any offence.

Our Company is licensed to use and operate the Platform and supply products directly to customers who transact using the Platform and provides the users access to one or more of our services and offerings (collectively, “Services”): 

· Face Scanning;
· Generation of Skin Analysis and Progress Reports;
· Product Suggestions; and
· Product Purchase;  

1. What is Personal Information?
The term “Personal Information” shall mean any information that relates to you, which, either directly or indirectly, in combination with other information available or likely to be available with Sammmm, is capable of identifying you, which is submitted to and/or collected over the Platform and maintained by Sammmm in an accessible form. We may collect personal information from a variety of sources including (a) personal data provided by you directly including name, address, email id, contact details, date of birth, location, etc. or (b) personal data we collect automatically including data collected using cookies and tracking technologies, IP address, etc. or (c) personal data collected from other sources including data collected from trusted partnerships with third-parties, (d) financial information such as bank account or credit card or debit card or other payment instrument details, password for availing the Products at our Platform, etc. which are more specifically detailed in the section titled ‘What Personal Information do we collect?’  . We may also maintain a record of your product interests and acquire information about you from our present and/or future affiliates. Additionally, we may collect and use technical data and related information, including but not limited to, technical information about your device, system and application software, and peripherals, that is gathered periodically to facilitate the provision of software updates, product support and other services to you (if any) related to the Platform.

2. What Personal Information do we collect?
All information collected by the Company is with the users’ consent. The Company is however free to use, collect, and disclose information of the users which is in the public domain. 

When users use or sign-up to the Platform, the users may provide the Company with certain information including Personal Information voluntarily, specific to the nature of the service being availed on the Platform, and/or certain information may be collected by the Company depending solely on the usage of the Platform. 

The users hereby consent to the collection of such information by the Company. 

Personal Information collected by the Company shall include but not be limited to the following:
· Name (e.g., your name), pronouns 
· Email ID
· Phone number
· Nationality, geolocation and time zone 
· Age, gender and other demographics 
· Sexual Orientation
· Details about your menstrual cycle
· Food habits
· Information on the type of subscription you choose
· Referral source
· Notification preferences 
· Financial Information (including billing address and limited information regarding the payment mode).
· Metrics on system or App feature use, including but not limited to the date of sign-up to the Platform, number of logins, and last login to the Platform

We also collect certain information either when the users provide it while using the Platform or Services and / or automatically as the users navigate through the Platform (which may include usage details, location, IP address, device ID and type, browser type and language, the operating system used by device, access times, and information collected through web beacons and other tracking technologies and which is covered by this Privacy Policy). We DO NOT sell this data to any third parties. 

Third parties may collect certain information by way of cookies, through our Platform. Such information may be collected, inter alia, for the following purposes: 
(a) advertising;
(b) marketing; and
(c) data analytics.

You also provide information to us through our Services, including your reviews, photographs, videos, comments, lists, followers, the users you follow and other information in your account profile.

If the Company has reasons to suspect that the information provided by any user is misleading, inaccurate, obsolete or incomplete, the Company reserves the right to refuse provision of the Services to the user, at its sole discretion without incurring any liability to the user or any third-party. We will not be liable for reliance on or consequences of any misleading, inaccurate, obsolete or incomplete information. 

We may collect, process, and retain your personal information through Orbo.ai and/or other third-party service providers offering similar or related services in connection with your facial scan and skin analysis. We may also collect, process and store your Personal Information through Message Bird, Meta Sky and other third-party communications platforms associated with your communications in the community on the Platform. When you sign in to your account on the Platform, you consent to our collection, storage, and use, in accordance with this Privacy Policy.

We may also obtain information about you from third parties such as partners, marketers, third-party websites, and researchers, and combine that information with information which we collect from or about you.

3. What purpose do we use the Personal Information?
We collect, process and disclose your personal data only for specific and limited purposes. For example, to verify your identity, fulfil transactions, process your payments, to assess and handle any complaints, to develop and improve our products, services, communication methods and the functionality of our websites, to provide personalised products and offers at the Platform, communications, and targeted advertising as well as product recommendations to you. Further at your option, your personal information can be used to keep you up to date on the latest product announcements and special promotions, web exclusives, exclusive notice of Sammmm sales and other offers, through the Sammmm newsletter.

The users will be deemed to have read, understood and agreed to the terms as provided in this Policy once they provide their consent or continue using the Platform. By granting their assent to this Policy, users provide consent to such use, collection and disclosure of Personal Information as prescribed in this Policy.

4. With whom do we share the Personal Information?
Only the persons authorized by us shall have access to your Personal Information. We may share your Personal Information with our affiliates (present and/or future), service providers who perform services on our behalf based on our instructions including delivery partners responsible for delivering products (only to the extent necessary to perform services on our behalf or comply with legal requirements, or other third parties with your consent (e.g. Facebook application may share information collected through the application with your Facebook friends or other Facebook users. Additionally, we may share Personal Information with our other corporate entities, to help detect and prevent identity theft, fraud, and other potentially illegal acts; correlate related or multiple accounts to prevent abuse of our Platform. If you have any objection to such sharing, then we request not provide us with any information. There may be instances where we may seek your consent prior to sharing your Personal Information with a third party such as an event or promotion co-sponsor. If you consent, we will share your information with such third party and the information you provide may be used by such third party for their own purposes and in accordance with their own policies. In case of any major business transactions like merger, acquisition, financing due diligence, reorganization, bankruptcy, sale or purchase of assets, or transition of Service to another provider, your information may be transferred as a part of such a transaction, as per applicable law and/or contract.

Notwithstanding anything contained in this Policy, we reserve the right to disclose any Personal Information that may be required to be disclosed mandatorily under applicable law or where the disclosure is necessary to comply with any legal obligation or to law enforcement authorities or other government officials, without prior notice or consent of the site/app user. We will retain your Personal Information only if it is reasonably required or otherwise permitted or required by applicable law or regulatory requirements. We may also retain your Personal Information so long as it is necessary to fulfil the purposes for which it was collected (including for purposes of meeting any legal, administrative, accounting, or other reporting requirements). 

5. Do we use cookies?
Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser, only if you allow, that enables the sites or service providers’ systems to recognize your browser and capture and remember certain information.

We use cookies to understand and save your preferences for future visits, to advertise to you on other sites, and to compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you delete or decline cookies, some features of the Platform may not work or may not work as designed. For more information on cookies and how to disable them, you can consult the information provided by the Interactive Advertising Bureau at www.allaboutcookies.org.

However, if you choose to disable cookies, you may be unable to access certain parts of our Platform. A banner asking you to accept our cookies policy will be displayed upon the first visit to our Platform (or the first visit after you delete your cookies). Unless you have adjusted your browser setting so that it will refuse cookies and/or you have not accepted our cookies policy, our system will issue cookies when you log on to our Platform.

6. Do we transfer your Personal Information internationally?
All or any information processed by the Company shall be processed, and stored in India. We undertake to safeguard your information in accordance with the applicable laws.

7. How long do we retain your Personal Information?
Our Platform helps individuals with skin health and wellness concerns by analyzing their face, preparing wellness reports, and recommending and accessing suitable treatments and products. To monitor the progress and effectiveness of these treatments, it's necessary for us to retain face images.  

We retain the Personal Information described under this Privacy Policy that users provide us for the tenure that a particular user maintains an account on the Platform, until the user requests deletion of Personal Information through the option of deleting profile on the Platform, or till the period such retention is required for compliance under applicable laws. 

If your account has been inactive for 12 months, we provide two options for you to, (1) deactivate or (2) delete, both of which will be processed following authentication. If the account is deactivated by you, it may be reactivated by you within six months by logging in. If the account is deleted, it will be permanently removed from the system, and all personal data eligible for deletion will be erased, unless retention is required by applicable law for a specific period as mandated by legal requirements. You will receive a notice prior to us deleting your content to allow you retrieve any data that you would like to retrieve.   

Please note that we may hold anonymized data, that at one point originated from you, but as the data is truly anonymized it no longer constitutes personal data and we can keep it for as long as it is relevant to our business purposes.  

8. How do we protect the Personal Information?
Sammmm safeguards the security of your Private Information through systematic paper and electronic procedures. We also utilize the “golden standard” (SSL) encryption on all web pages where personal information is required. To purchase from www.sammmm.com , you must use an SSL enabled browser. This protects the confidentiality of your personal and credit card information while it is transmitted over the Internet. We use industry-standard SSL encryption when transferring and receiving customer data exchanged through our site server. Sammmm does not sell or distribute any Personal Information unless otherwise required as a matter of law.

However, we shall not be liable to any user for any loss, damage (whether direct, indirect, consequential, or incidental), or harm caused to the user due to the unauthorized access or misuse of the Personal Information by any third party.

We may display links to web sites that are owned or operated by third parties on our Platform. Please understand that these websites are independent from Sammmm, and Sammmm has no control over the content on that website, even if Sammmm provides information or Products to the owner of that website. Sammmm is not making any representations about, endorsing, or accepting any responsibility for the content or the use of such website. Further, we are not responsible or liable for any damage or loss related to the use of any third-party website. You should always read the terms and conditions and the privacy policy of a third-party website before accessing or using it.

9. Disclaimers
We may display links to websites that are owned or operated by third parties on our Platform and also collaborate with any third-party brands for events and campaigns. Please understand that these websites and products that are sold, owned, distributed, controlled utilised during such collaborations are independent from Sammmm, and Sammmm has no control over the content on that website or these third-party products, even if Sammmm provides information or Products to the owner of that website. Sammmm is not making any representations about, endorsing, or accepting any responsibility for the content or the use of such website or the third-party products utilised as a part of any collaboration. Further, we are not responsible or liable for any damage or loss related to the use of any third-party website or third-party products. You should always read the terms and conditions and the privacy policy of a third-party website before accessing or using it.

You also may provide information (such as ratings, reviews, tips, photos, comments, likes, bookmarks, friends, lists, etc.) to be published or displayed on publicly accessible areas of our Services, or transmitted to other users of our Services or third-parties (collectively, "Contributions"). Your Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, you may set certain privacy settings for such information by logging into your account profile. Additionally, we cannot control the actions of other users of our Services with whom you may choose to share your Contributions. Therefore, we cannot and do not guarantee that your Contributions will not be viewed by unauthorized persons. We may display this information on the Services, share it with businesses, and further distribute it to a wider audience through third party sites and services. You should be careful about revealing any sensitive details about yourself in such postings.

10. Opt-Out
You have an option to opt-out of receiving any promotional or marketing communications from us. If you do not wish to receive any promotional or marketing communications from us, you can contact us at the below given contact information.

You can update or correct your name, e-mail address, security questions, and other preferences by [logging into your account and clicking on the "My Account" page, contacting customer service desk.

Receiving newsletters and promotional e-mails: You can click on the “unsubscribe” link at the bottom of any promotional e-mail that you receive. Alternatively, you may edit your e-mail preferences on your “My Account” page or call customer care executive to discontinue receiving any promotional materials by mail/ e-mail.

Remove content from Customer review: You can remove content that you posted on a public space, such as part of a ratings and review, by e-mailing details to customercare@sammmm.com Please note that we will endeavour and try to ensure to honour your request to remove information, however, our removal of your information does not completely erase that information from the internet viz. historical copies, or "caches," may remain. Any email request shall be considered final and irrevocable, and cannot be withdrawn, rescinded, or retracted once submitted.

11. Withdrawal of Consent
If you have consented to the collection, use, and/or disclosure of your Personal Information as identified in this Policy, you may withdraw the same at any time by communicating to us at the below given contact information.

12. Updates to Policy
We may modify this Policy from time to time by posting updates on this page. Please check back periodically to view any updates.

13. If you are concerned about the handling of your Personal Information, or if you have any complaints or queries related to your Personal Information or our Policy, please contact:
Grievance Officer: Mantosh Roy
Email id:  sukruti@sammmm.com
Phone: +919004089566

14. Contact Information of Customer Service Desk
Customer Service Desk
Email id: care@sammmm.com
Phone: 9892140901
Contact Days: Monday – Friday (working hours to be included)