Effective date: 2024-09-22

## 1. Introduction

Welcome to The Softy Co.

The Softy Co. (“us”, “we”, or “our”) operates at https://thesoftyco.in (hereinafter referred to as “Service”).

Our Privacy Policy governs your visit to https://thesoftyco.in and explains how we collect, safeguard, and disclose information that results from your use of our Service.

We use your data to provide and improve Service. By using the Service, you agree to the collection and use of information by this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Our Terms and Conditions (“Terms”) govern all use of our Service and together with the Privacy Policy constitute your agreement with us (“Agreement”).

## 2. Definitions

SERVICE means the https://thesoftyco.in website operated by The Softy Co.

PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

USAGE DATA is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and how any personal data are, or are to be, processed. For this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data.

THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

## 3. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

## 4. Types of Data Collected

### Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

0.1. Email address
0.2. First name and last name
0.3. Phone number
0.4. Address, Country, State, Province, ZIP/Postal code, City
0.5. Cookies and Usage Data

We may use your Data to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link.

### Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through any device (“Usage Data”).

This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access Service with a device, this Usage Data may include information such as the type of device you use, your device unique ID, the IP address of your device, your device operating system, the type of Internet browser you use, unique device identifiers and other diagnostic data.

### Location Data

We may use and store information about your location if you permit us to do so (“Location Data”). We use this data to provide features of our Service and to improve and customize our Service.

You can enable or disable location services when you use our Service at any time by way of your device settings.

### Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

0.1. Session Cookies: We use Session Cookies to operate our Service.
0.2. Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
0.3. Security Cookies: We use Security Cookies for security purposes.
0.4. Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

### Other Data

While using our Service, we may also collect the following information: sex, age, date of birth, place of birth, passport details, citizenship, registration at the place of residence and actual address, telephone number (work, mobile), details of documents on education, qualification, professional training, employment agreements, NDA agreements, information on bonuses and compensation, information on marital status, family members, social security (or other taxpayer identification) number, office location, and other data.

### Aggregate Information

We collect Aggregate Information about you and your use of our Web site whenever you visit us online. Aggregate Information includes various forms of “click stream” information, such as entry and exit points for our Web site (i.e., referring URLs or domains), site traffic statistics, page views, impressions, operating system, and browser type. In addition, when you request pages on our Web site, our servers automatically log your IP addresses. An IP address is a number that is automatically assigned to your computer by your web service whenever you are surfing the Web.

Traffic directed to TheSoftyCo.com from affiliate Websites and the purchases that result from this traffic are also tracked by third-party software. This information is aggregated and is not tied to an individual purchase.

This Aggregate Information generally will not personally identify you or be correlated to you individually for external purposes. We may collect, compile, store, publish, promote, report, sell, or otherwise disclose or use any Aggregate Information, provided that such information does not personally identify you. When we share such information with other companies, it is not traceable to any particular user and will not be used to contact you. If we do correlate any Aggregate Information to you, such information will be treated like any other Personal Information under this Policy.

## 5. Use of Data

The Softy Co. uses the collected data for various purposes:

0.1. to provide and maintain our Service;
0.2. to notify you about changes to our Service;
0.3. to allow you to participate in interactive features of our Service when you choose to do so;
0.4. to provide customer support;
0.5. to gather analysis or valuable information so that we can improve our Service;
0.6. to monitor the usage of our Service;
0.7. to detect, prevent, and address technical issues;
0.8. to fulfill any other purpose for which you provide it;
0.9. to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
0.10. to provide you with notices about your account and/or subscription, including expiration and renewal notices, email instructions, etc.;
0.11. to provide you with news, special offers, and general information about other goods, services, and events that we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
0.12. in any other way we may describe when you provide the information;
0.13. for any other purpose with your consent.

## 6. Retention of Data

We will retain your Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

## 7. Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside India and choose to provide information to us, please note that we transfer the data, including Personal Data, to India and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

The Softy Co. will take all the steps reasonably necessary to ensure that your data is treated securely and by this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

## 8. Disclosure of Data

We may disclose personal information that we collect, or you provide:

0.1. Disclosure for Law Enforcement.
Under certain circumstances, we may be required to disclose your Data if required to do so by law or in response to valid requests by public authorities.

0.2. Business Transaction.
If we or our subsidiaries are involved in a merger, acquisition, or asset sale, your Data may be transferred.

0.3. Other cases. We may disclose your information also:
0.3.1. to our subsidiaries and affiliates;
0.3.2. to contractors, service providers, and other third parties we use to support our business;
0.3.3. to fulfill the purpose for which you provide it;
0.3.4. for including your company’s logo on our website;
0.3.5. for any other purpose disclosed by us when you provide the information;
0.3.6. with your consent in any other cases;
0.3.7. if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

### Company Sale

Information collected through our Web site is considered a trade secret of The Softy Co. As the owner of such information, we may disclose or sell such information as an asset of the company in conjunction with the sale to a third party of our company or a portion of our assets.

## 9. Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

## 10. Your Data Protection Rights Under the Information Technology Act, 2000 (IT Act) and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (SPDI Rules)

If you are a resident of India, you have certain data protection rights covered by the IT Act and SPDI Rules.

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at contact@thesoftyco.in.

Under the IT Act and SPDI Rules, you have the following data protection rights:

0.1. The right to access your personal information;
0.2. The right to correct any inaccurate or incomplete personal information;
0.3. The right to withdraw consent for the collection and use of your personal information;
0.4. The right to request deletion of your personal information;
0.5. The right to object to the processing of your personal information;
0.6. The right to seek compensation for damages caused due to unauthorized disclosure of your personal information.

Please note that we may ask you to verify your identity before responding to such requests. We may not be able to provide Service without some necessary data..

## 11. Data Localization and Cross-Border Transfer

As per the requirements of Indian data protection laws, we store your data on servers located within India. However, in some cases, your data may be transferred to other countries for processing. In such cases, we ensure that the transfer complies with applicable Indian laws and regulations, including obtaining your consent where required.

## 12. Sensitive Personal Data or Information (SPDI)

Under the SPDI Rules, the following categories of personal information are considered sensitive:

0.1. Passwords
0.2. Financial information (such as bank account details, credit card information, or other payment instrument details)
0.3. Physical, physiological, and mental health conditions
0.4. Sexual orientation
0.5. Medical records and history
0.6. Biometric information

We collect, use, and process SPDI only with your explicit consent and for the purpose for which it was collected. We implement stringent security measures to protect your SPDI as required by Indian law.

## 13. Service Providers

We may employ third-party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services, or assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

## 14. Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

## 15. CI/CD tools

We may use third-party Service Providers to automate the development process of our Service.

## 16. Behavioral Remarketing

We may use remarketing services to advertise on third-party websites to you after you visit our Service. We and our third-party vendors use cookies to inform, optimize, and serve ads based on your past visits to our Service.

## 17. Payments

We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

## 18. Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third-party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

## 19. Children’s Privacy

Our Services are not intended for use by children under the age of 18 (“Child” or “Children”).

We do not knowingly collect personally identifiable information from children under 18. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

The Softy Co. recognizes the need to provide additional privacy protection to children. Children 12 years old and younger may visit TheSoftyCo.com without disclosing any personally identifiable information. However, it is sometimes necessary to collect some personally identifiable information about children to allow them to use a feature of our site (like taking part in a contest).

Only a parent or guardian may register such information. When a parent registers a child, we request the child’s name, date of birth, and parent’s e-mail address. We collect this information to verify the details.

We will not disclose any children’s information to anyone outside of The Softy Co., our affiliates, and our agents and franchisees. Our agents may need children’s personal information to fill an order, respond to a request, support, prevent fraud, or assist us in the management and improvement of our Web site. Our franchisees may need children’s personal information to help us provide correct information and prevent fraud. We require our agents and franchisees to respect our privacy practices concerning children’s information and not use children’s information for purposes other than to carry out our instructions.

Parents may request at any time that we delete information about their children from our databases.

## 20. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service before the change becomes effective, and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

## 21. Contact Us

If you have any questions about this Privacy Policy, please contact us by email: contact@thesoftyco.in.

## 22. Franchising Information

For franchise information on The Softy Co., please visit our Franchise Opportunities section on TheSoftyCo.com.

If you choose, you may submit an electronic application seeking consideration as a prospective franchisee via the Softy Co. Franchise Opportunity website. If you submit an electronic application, we will collect your name, date of birth, address, email address, other contact information, and certain financial and employment information that you must enter on the form. By submitting this information, you agree that The Softy Co. may retain, use, and disclose the information to respond to your inquiry and to help us conduct our franchise marketing efforts. Information on your online form will become part of any application for a The Softy Co. franchise that you might later submit. We may disclose your personal information to our business units, agents, parent company, other affiliates, and other third parties as part of our consideration of your inquiry or any subsequent franchise application. We do not authorize unaffiliated third parties to use your personal information for any purpose other than consideration of your inquiry or application.

## 23. International Users

The Softy Co. controls and operates this Web site from within India. Our online privacy practices are governed by Indian laws, which may differ from privacy laws in your state or home country. By submitting your personal information to this site, you consent to the transfer of your personal information to any country and its use and disclosure by Indian law and with this privacy policy.

This English-language privacy policy is The Softy Co.’s official statement of its online privacy practices. In case of any inconsistency between this English-language privacy policy and its translation into another language, this English-language document shall control.

## 24. Inquiries

To best respond to your comments when you request information from The Softy Co. or share an experience you had at one of our stores, we’ll ask for personal information. This includes your name, address, and email address, as well as your local store address and any other information you may wish to share.

## 25. Promotional Events

When you choose to take part in a promotional event we’ll ask for information necessary for the event, such as your name, email address, and shipping address. On occasion, we may co-sponsor promotions with third parties. Before entering your data you will be notified if third parties will obtain your personal information.

## 26. Surveys

From time to time, we may post surveys that request demographic information such as age range, gender, areas of interest, and familiarity with The Softy Co. products and services, as well as customer feedback. Participation in these requests is completely voluntary. With each request, you will have the choice of whether or not to disclose information. This information will be used to create new products and services, plus improve the overall experience on TheSoftyCo.com.

## 27. Email Updates

If you decide to take part in any of The Softy Co. contests, you’ll have the choice to receive occasional updates about our site, as well as special offers for savings at your local The Softy Co. If at any time you decide you’d rather not receive emails from The Softy Co., you can unsubscribe by clicking the unsubscribe link at the bottom of any The Softy Co. email.

## 28. Cookies

Like many other Web sites, we use “cookie” technology to improve your experience at our site. Cookies are small pieces of data that we place in your computer’s browser to store your preferences. Cookies are not themselves personally identifiable but may be linked to personal information that you provide to us through your interaction at our site.

## 29. Links

You may find that it is possible to link from other Websites to this, the official The Softy Co. Website, or from this Website to other Websites. Those other Web sites are not under our control. The Softy Co. is not responsible for the privacy practices or the content of other Web sites. You should consult the privacy policy of the Web site to or from which you link to determine the information practices of that Website.

This Privacy Policy covers all aspects of our data collection, use, and disclosure practices for The Softy Co. If you have any questions or concerns about our privacy practices, please don’t hesitate to contact us using the information provided in the “Contact Us” section.