Best Practices for Employee Welcome Gifts

Introduction

At Prestige Gifting Delights, we value your trust when sharing your personal data with us and recognize that you may be concerned about the information provided to us and about how we handle that information.

If you are reading this Privacy Notice ("Privacy Notice") it may be because you may have visited a Website, Mobile App, Social Media profile, any online service, or interacted with us in venues or through activities (all of them referred to hereinafter as “Sites”) operated by Prestige Pursuits Private Limited or its affiliates ("PPPL" or "us" or "we") or, because you may have contacted us directly by phone or in writing.

This Privacy Notice sets out the basis on which we use, store and process your Personal Data ("Personal Data") when you access our Sites or contact us.

Prestige Data Processing

PPPL collects and uses Personal Data which you provide or which we collect about you when you navigate through our Sites for the purposes of advertising, supplying you with our products and services, making contact with you for marketing or other commercial purposes, answering your inquiries regarding our products, facilitating your participation in our offers and promotions, handling any product complaints, and analysing and improving the quality of our products or services.

Your access to and use of our Sites is subject to the terms and conditions of our Privacy Notice and all applicable laws. Your Personal Data processing will be limited to what it is necessary in relation to the purposes described in this Privacy Notice. We will seek your consent for some processing so that you have control of the information we process and hold about you. Otherwise, we will only process your Personal Data if necessary for the performance of a contract with you, for compliance with a legal obligation of PPPL, for the purposes of legitimate interests of PPPL, or other purposes where permitted by law.

We usually process your Personal Data in your location but, it may also be stored in systems based around the country, and may be processed by third party service providers acting on our behalf. These systems and providers may be based in territories that do not provide an equivalent level of protection over privacy as that enjoyed in your location. In that case PPPL will use reasonable endeavours to provide for adequate protections for your Personal Data that are reasonably equivalent to the one of the countries of origin. You can seek for further information and exercise your rights of access, rectification, cancellation, objection, and data portability in respect of your Personal Data, by clicking in our Contact Us feature.

We may change this Privacy Notice from time to time by posting the updated version of the Privacy Notice on our Sites. Please visit this Privacy Notice to stay informed about how we use your personal data.

This Privacy Notice is dated September 2020.

What Personal Data Do We Collect From You?

The type of information and Personal Data that we collect about you when you visit our Sites or interact with us may include the following:

• Personal details about you or provided by you - such as but not limited to your name, age, gender, postal address and other contact details, such as your telephone number and email address, your requests, any complaints you may have and any other data we receive if we communicate with you (including via telephone, email, online or via social media), and any other information you provide - for example, when you register with our Sites, sign up for our newsletters, participate in our offers and promotions, provide customer feedback, reply to surveys or purchase our products or services;
• Payment and purchase information - including data to make purchases, such as your payment account details, credit card and debit card numbers, expiration date, shipping and billing address, and details of products purchased;
• Preference information – information about your preferences, needs, interests, opinions and behaviour (e.g. in relation to our Sites, products and services);
• Account login information - including any information that is required for you to establish a user account, such as user name, password and security question and answer;
• Information collected automatically – including information about your device, IP address, and browser, that we may collect, for example, when we use in our Sites our own cookies or cookies owned by 3rd parties, web beacons and similar technologies that collect information about your use of our Sites or about your interaction with us by emails. See our Cookies Policy for further information. Cookies, including those used on our Sites, can be disabled through the settings in your browser but if you disable all cookies, you may not be able to access or have full functionality of our Sites. Disabling cookies does not delete existing cookies from your device; cookie deletion needs to be manually completed through the appropriate menu options in your browser.

Why Do We Collect Your Personal Data?

We collect and use your Personal Data for the purposes below and on any other lawful basis. Please know that if we already hold information about you, we may use that information for the same purposes.

For legitimate commercial interests: we may use your Personal Data (both on an aggregated and on an individual basis), such as your contact details, your account and electronic identification data, information regarding your purchases in our stores and online, for the purpose of providing our products and services, maintaining and updating our records, administration, information verification, advertising, marketing and for analysing and improving the quality of our products or services, as well as, to understand you as a customer.

This also means that we analyse the information that you provide to us together with your use of our Sites or of our products and services and we use all this information to improve the same and to give you a better user experience (for example, we analyse what web pages you visit, which products and services you use and like, how you use these products and services).

We may also use your Personal Data, for legitimate commercial interests such as, to generate aggregated statistics about the users of our products and services; to assist in security and fraud prevention; for system integrity purposes; to remind you of your abandoned cart or send you an order confirmation; to facilitate our business operations, to operate company policies and procedures; to enable us to make corporate transactions, such as any merger, sale, reorganization, transfer of PPPL assets or businesses, acquisition, bankruptcy, or similar event, to comply with our legal obligations; and for other legitimate business purposes permitted by applicable law, on which we would provide the relevant information at the time.

For the performance of the terms and conditions of a contract: to purchase our products or services or to develop a contest, competition or promotion in which you may have entered, to conduct the promotion and contact to you if you became a winner, to be able to answer to any information request performed using our Contact Us features.

We may also use your information, where granted, for instance for marketing purposes and for tailoring our communications with you based on your profiles via email, SMS, other electronic means or otherwise, and/or to track and analyse your preferences for purposes of consumer insights and personalised marketing. You can withdraw your consent any time; see What rights do you have regarding the Personal Data we hold about you?

To comply with our legal obligations, such as maintaining appropriate business records, handling complaints made to our customer service, managing product health, safety or quality complaints, complying with lawful requests by public authorities and with applicable laws and regulations or as otherwise required by law.

How Long Do We Retain Your Personal Data?

We will only retain your Personal Data for as long as it is necessary to satisfy the purpose for which it was provided by you or collected by us (for example, for the time necessary for us to answer queries or resolve problems).

We may therefore retain your Personal Data for a reasonable period after your last interaction with us. When the Personal Data that we collect is no longer required in this way, we destroy or delete it in a secure manner. We may, instead of destroying or erasing your Personal Data, make it anonymous so that it cannot be associated with or tracked back to you. In certain cases, we may have legal or regulatory obligations that require us to retain specific records for a set period of time.

Who Might We Share Your Personal Data With?

We may share your Personal Data with:

• PPPL entities. Your Personal Data could be shared between PPPL companies that may use your Personal Data as described in this Privacy Notice.
• Service Providers and Processors. We may engage third party vendors, agents, service providers, and affiliated entities to provide services to us on our behalf, such as support for the internal operations of our websites, Mobile Apps or online stores (including social media services providers, payment processors, brand activation agencies, advertising, marketing and promotional agencies, data analytics providers, professional advisors (e.g. accountants, bankers, business advisors, debt collectors, lawyers) and third parties we use for sending your orders to your address, such as postal courier vendors) or for the technical processing (for example, hosting services or data storage) or for customer relationship management services, as well as related offline product or promotional support services, (for example, competitions, sweepstakes and contests organizers, winner draws providers, events management agencies, prize or compensation packages vendors) and, other related services.
• In providing their services, they may access, receive, maintain or otherwise process Personal Data on our behalf. Our contracts with these service providers do not permit use of your information for their own purposes, including their marketing purposes. Consistent with applicable legal requirements, we take commercially reasonable steps to require third parties to adequately safeguard your Personal Data and only process it in accordance with our instructions.
• Partners. We may sometimes offer you a service or application in co-operation with partners (for example, co-sponsors or licensors, licensees or distributors of our branded products). We may therefore need to disclose your Personal Data to those partners. Consistent with applicable legal requirements, we take commercially reasonable steps to require third parties to adequately safeguard your Personal Data and only process it in accordance with our instructions or as co-controllers. In those cases in which the disclosure of your Personal Data with third partners takes place based on your consent or your request to do so, where relevant, we will clearly notify you of the sharing, and you will have the choice not to participate or to otherwise object to such sharing.
• Third parties in case of legal requirement. We may also disclose your Personal Data if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes; when we believe necessary or appropriate to disclose Personal Data to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law, breaches of security, or breaches of this Privacy Notice; to respond to any claims against us or our personnel; and, to protect the rights, property, or personal safety of MDLZ, our customers, employees, contractors or the public.
• Third Parties in case of a corporate transaction. In addition, information about our customers and consumers, including Personal Data, may be disclosed as part of any merger, sale, reorganization, transfer of PPPL’s assets or businesses, acquisition, bankruptcy, or similar event.
• We also use Google Analytics to help us understand how our customers use the Site--you can read more about how Google uses your Personal Information here:
  https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google
  Analytics here: https://tools.google.com/dlpage/gaoptout .

International Transfers Of Your Personal Data

The global nature of our business means that your Personal Data may be disclosed within the Prestige Group of Companies.

We also use some third party suppliers to help us provide business services. These third parties may have access to or host your Personal Data, but will always do so under our instructions and subject to a contractual relationship. When these third parties are located in territories which may not offer an equivalent level of protection to privacy as that applicable within your country, we will take reasonable steps to verify that your Personal Data receives a reasonable level of protection.

We Collect Device Information Using The Following Technologies

- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

- “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information, email address, and phone number. We refer to this information as “Order Information.”

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

How Do We Ensure The Security Of Your Personal Data?

We use a variety of physical, technical and administrative security standards, technologies and procedures to help protect your Personal Data from loss, misuse, alteration, destruction or damage to an appropriate level depending on the sensitivity of the information.

We take steps to limit access to your Personal Data to those persons who need to have access to it for one of the purposes listed in this Privacy Notice. Furthermore, we use reasonable efforts to ensure that any third party processing your Personal Data equally provide for confidentiality and integrity of your data in a secure way.

What Rights Do You Have Regarding The Personal Data We Hold About You?

You have the following rights:

• to obtain a copy of your Personal Data together with information about how and on what basis that Personal Data is processed;
• to rectify inaccurate Personal Data (including the right to have incomplete Personal Data completed);
• to request that we erase your Personal Data as may be allowed under applicable laws;
• to request that we restrict processing of your Personal Data where you advise us to do so or:
  • the accuracy of the Personal Data is contested;
  • the processing is unlawful, but you object to the erasure of the Personal Data;
  • we no longer require the Personal Data for the purposes for which it was collected, but it is required for the establishment, exercise or defense of a legal claim; or
  • you challenge the processing which is justified on the basis of a legitimate interest.

In case you may have a complaint about how we process your Personal Data, you can send it by reaching out to us through the details found at the Contact Us section. If you have any question regarding the processing of your Personal Data or this Privacy Notice or if you wish to exercise any of the above mentioned rights, please contact us through the details found at the Contact Us section. You may revoke your consent for receiving newsletter or marketing communications at any time, free of charge by following the instructions in any marketing communication. You can also control these preferences in your profile settings, where applicable.

Social Media, Other Websites, Or Online Services

When you participate in any of our PPPL profiles or wherever PPPL is present in any of the various social media forums like Facebook, Twitter, Yammer, Pinterest, Instagram, LinkedIn, Youtube, etc., you should be familiar with and understand the tools provided by those sites that allow you to make choices about how you share the Personal Data in your social media profile(s).

For these forums the privacy practices or policies of these third parties apply, so we encourage you to read the applicable privacy notices, terms of use and related information about how your Personal Data is used in these social media environments.

Subsequently our Sites may contain links to third-party websites; if you follow these links, you will exit our websites and mobile applications. While these third-party websites are selected with care, PPPL cannot accept liability for the use of your Personal Data by these organisations. For more information and details, please consult the section on Data Privacy Notices of third parties and the privacy statement of the website you are visiting (if such a statement is provided).

Except where provided otherwise, this Privacy Notice shall not apply to these social media forums and third-party websites/applications not owned by PPPL since they control and process your Personal Data.

Some of our online service providers assist us with online analytics, targeted advertising, embedded videos and other content, social media interactivity and surveys, and these providers may use cookies, web beacons, and other storage technologies to collect or receive information from our Sites and elsewhere on the internet. For example, with targeted advertising, we can tailor the delivery and content of our ads and other material on our Sites or third-party sites and online services, based on previous visits to our Sites.

The tracking described above may allow online service providers to collect information about your interaction with our Sites (including IP address) and which they may combine with information they have collected at other times and through other sources (e.g. Google may link your activity on multiple devices if you have a Google account), or with information we provide them such as email addresses. The use of these technologies allows them to help us define target customer groups based on Site usage and demographic characteristics (e.g. age, gender) deliver customised advertising content, measure the effectiveness of their advertising (e.g. by reporting on the actions people take after viewing particular ads), evaluate use of our Sites and other sites and provide other services relating to website activity and internet usage.

Those third parties may also transfer the information they collect to others where required to do so by law, or where those others process the information on their behalf.

Behavioural advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

How Do We Process Children’s Personal Data?

At PPPL, we do not believe in marketing directly to children under 12 years of age. Therefore our Sites are not intended for children under 12 years old.

We also take the protection of children’s privacy seriously. Individuals who are under 18 years old and therefore unable to provide consent should have a parent/guardian’s consent before providing any Personal Data to us via the website. If we determine upon collection that a user is under age and has not provided a parent/guardian’s consent before providing any Personal Data, we will not use or maintain his/her Personal Data without the parent/guardian’s consent. Without such consent, though, the child/individual may not be able to participate in certain activities. However, in certain circumstances, we may maintain and use such information (in accordance with the rest of this Privacy Notice and applicable law) in order to notify and obtain consent from the parent/guardian and for certain safety, security, liability, record keeping and other purposes permitted under applicable law. A parent/guardian can review, remove, change or refuse further collection or use of their child’s Personal Data by contacting us as set out in our Contact Us section, including child’s name, address and e-mail address.

Contact Us

If you have questions or requests regarding this Privacy Notice, or if you would like to exercise your rights vis-à-vis your Personal Data, you may write to contactus@prestigegiftingdelights.com or call us at 1800 or write to us at our address: Prestige Pursuits Private Limited (28^th Basant Lok Market, 2^nd& 3^rd Floor, Vasant Vihar, New Delhi, Pincode – 110057, India).