1. Introduction

Spencer's Retail Limited and/or Omnipresent Retail India Private Limited (Spencer's/we/us/our) acknowledge your faith in us and we endeavor to maintain and secure your privacy at highest standards. Spencer's recognizes that your privacy is important to you and that you have certain rights in relation to your personal information ("information"). Spencer's appreciates your trust and uses your information carefully and sensibly. The aim of this privacy policy is to ensure that you understand what information we collect about you, the reasons for collection and use, and entities we share it with. By providing your consent to this privacy policy, you agree to the collection, use and transfer of your information as set out in this privacy policy. Spencer's may change its privacy policy from time to time and may display the same on its website/mobile application and hence you are requested to visit the site at regular intervals. In case you disapprove any of the terms and conditions of this privacy policy, then you should immediately cease to use the website/mobile application. Our objective is to provide a better shopping experience and services to the customers, visitors, etc. This policy also outlines how we collect, use, store and protect your personal data as per the Digital Personal Data Protection Act, 2023.

This privacy policy read along with Terms and Conditions of Use outlines Spencer's policy on the collection, use and disclosure of information shared by the visitors on its website/mobile application. We will use the information only as set out in the privacy policy. This privacy policy is published as per the Information Technology Act 2000 and DPDP Act 2023.

2. What information we collect and how we use it

Spencer's receives and stores the information you enter on its website/mobile application. Your personal details like email address, name, phone number, are generally collected. You will have the sole right to provide the information and you are not under an obligation to provide any other information, except the details required for delivery of services to you.

Information we collect:

• Personal information like name, age, gender, contact details, email address, home address, postal code;
• Preference information like search queries, clicks, browsing history, preferences;
• Technical Data such as IP address, device information, operating system, location;
• Information you provide as your content in your social media handle which is prepared/tagged through our services, including your ratings, reviews, comments, videos, etc.

We may use the information for the following purposes:

1. To personalize and improve our goods and services, to use your account;
2. To display tailored ads, promotional offers, and discounts based on your usage of our platform;
3. communicating with you through phone, mobile application or email;
4. communicate with you about promotions, upcoming events and news about the systems and services;
5. to maintain the good order and management of delivery, refund & return;
6. protecting against and preventing, fraud, illegal activity, harm, financial loss and other legal or security risks
7. dealing with enquiries and complaints, services and related activities and fixing errors and providing recommendations based on your past events;
8. responding to your queries and fulfilling your requests for information regarding our services;
9. to notify you and send offers about products and services of the holding company, its subsidiaries and all other entities over which the holding company and/or its subsidiaries exercise majority control under the RP-Sanjiv Goenka Group ("Group");
10. for marketing and for market research/industry/sector analytics purposes, including internal demographic studies, by third parties, to provide, optimize and personalize their products and services to you and to send you newsletters and information about their products and services; and
11. responding to judicial process and provide information to law enforcement agencies or as permitted by law.

Please note that you can choose not to divulge any information. However, in such case, you will not be able to use the features or services of our website/mobile application. If you post any message, complaint, feedback then we retain the information to redress the disputes and to provide a resolution.

Cross Border Transfer and Sharing of Personal Information

By voluntarily providing your personal information to us, you expressly permit us to transmit, share or transfer your personal information outside the country/ies (as permitted under applicable Laws) to our authorised cloud storage service partners, healthcare associates or other Parties. Such transfer will be carried out solely for the purposes stated in this privacy policy and in accordance with applicable regulations. We ensure to safeguard and protect your information during the transfer.

3. Your Consent

By accessing, browsing, or using our website/mobile application, and by voluntarily submitting your personal information, you expressly consent to the collection, processing, storage, transfer, sharing, disclosure, and usage of your personal data as outlined in this Privacy Policy.

You have the right to withdraw your consent, or request correction or erase of your personal information at any time by contacting our Grievance Officer. Upon withdrawal of consent, we may be unable to continue providing you with certain services, and such withdrawal shall not affect the processing of your personal data that was carried out before the withdrawal. Your continued use of the website/mobile application after any modification to the Privacy Policy shall be deemed as your acceptance of those modifications.

4. Sharing of information

We collect your information relating to your profile in order to improve our content and navigation. During this process, we identify your IP address to collect information. We use this information to customize our services and offerings to your specific needs. We may disclose/transfer your information:

1. to any law enforcement authority during course of their requirement or as it may require under any law in force;
2. to our Group for business purposes including for providing an enhanced and delightful experience;
3. to our affiliate companies for better customer satisfaction;
4. to our advisors such as lawyers, chartered accountants and financial advisors in connection with business transactions; and
5. to third parties that provide services to us or act on our behalf in connection with the operation of our business.

We may also disclose or transfer your information to another third party as a part of corporate reorganization such as merger, acquisition, or transfer.

5. Security practices and procedures

We use reasonable security measures, particularly those mandated under applicable law, to safeguard and protect your information.

15. Grievance Officer

In case of any complaints as a result of access or usage of the website/mobile application, you can reach out to the above person. We endeavor to respond to any grievances or requests within seven (7) working days from the date of receipt of your complaint, in compliance with the Digital Personal Data Protection Act, 2023.