New Shakti Enterprise is the licensed owner of the brand NOVA and the website novaproducts.in ("the Site"), and/or any sub-domains and/or the mobile application (collectively the "Platform"). New Shakti Enterprise is the controller responsible for the processing of your data; exceptions are outlined in this Privacy Policy. This Privacy Policy provides the kind of information that New Shakti Enterprise may collect from you when you access or use the Platform and avail the Services or purchase the Products, and the manner in which your data is collected and used by New Shakti Enterprise on the Platform.

As a visitor to the Platform, you are advised to read this Privacy Policy carefully. By accessing the Platform and the Products and Services provided on the Platform you agree to the collection and use of your data by New Shakti Enterprise in the manner provided in this Privacy Policy. You acknowledge that you are providing your data out of your free will and that the personal data provided by you is accurate and authentic. New Shakti Enterprise shall not be liable for any dispute or claim arising out of the accuracy or authenticity of the data provided by you. In the event you do not provide your data as may be required for registration or thereafter, or you fail to provide permissions or withdraw your consent for processing the data, New Shakti Enterprise shall not have any obligation to provide the Services or sell the Products, and we may restrict or prohibit your use of our Platform, Services and Products.

In the event you grant access to any third party to our Services or Products under your account, then the terms "user", "you" and "your" shall by inference include such third party, and this Privacy Policy shall, to the extent permitted under law, apply mutatis mutandis to such third party. It shall be your sole responsibility to make such third-party users aware of the terms of this Privacy Policy. You shall be liable to indemnify New Shakti Enterprise against any claims or breach of this Privacy Policy by such third-party users.

When and what information we collect

As part of the registration process on the Platform, and for the purpose of providing Services and Products to you, New Shakti Enterprise may collect the following personally identifiable information and sensitive personal data about you: name including first and last name, alternate email address, mobile phone number and contact details, postal code, demographic profile (such as your age, gender, occupation, education and address), other information capable of identifying you, and financial information (payment instrument information, transactions, transaction history, preferred mode and manner of payment, spending patterns or trends and other similar data), as well as information about the pages you visit, the links you click and the number of times you access a page. We collect this information:

• Directly from you when you provide it to us; and/or
• Automatically as you navigate through the Platform or our Services and Products (information collected automatically may include usage details, IP addresses and information collected through cookies and other tracking technologies).

New Shakti Enterprise will collect personally identifiable information about you only as part of a voluntary registration process, an online survey or any combination thereof. The Platform may contain links to other websites. New Shakti Enterprise is not responsible for the privacy practices of websites it does not own, manage or control. The Platform and third-party vendors, including Google, use first-party cookies (such as Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to inform, optimise and serve ads based on past visits to the Platform.

How we use the information we collect

New Shakti Enterprise will use your personal information for the following lawful purposes:

• to provide personalised features to you on the Platform.
• to provide promotional offers to you through the Platform and other channels.
• to provide this information to its business associates and partners so they can get in touch with you when necessary to provide the Services or Products requested by you.
• to preserve transaction history as governed by existing law or policy.
• to use the contact information internally to direct its efforts for product improvement, to contact you as a survey respondent, to notify you if you win a contest, and to send you promotional materials from its contest sponsors or advertisers.
• to serve promotional and advertising materials to you via display advertisements through the Google Ad network on third-party websites. You can opt out of Google Analytics for Display Advertising and customise Google Display network ads using Ads Preferences Manager.
• to share aggregate customer transaction, demographic and location data (excluding information that identifies you specifically) with partners for creating additional features, appropriate merchandising, new products and Services, and for marketing research and statistical analysis of customer behaviour and transactions.
• processing, disclosing, transmitting and/or sharing the data with New Shakti Enterprise entities and other third parties which have business or contractual dealings with us.
• to carry out New Shakti Enterprise's obligations arising from any contract entered into between you and New Shakti Enterprise.
• to understand our users — what they do on the Platform, what features they like and how they use them.
• to process and respond to your queries.
• to generate and review reports and data about, and to conduct research on, our user base and Service usage patterns.
• to allow you to participate in interactive features of our Services, if any.

With whom your information will be shared

New Shakti Enterprise will not use your financial information for any purpose other than to complete a transaction with you. New Shakti Enterprise does not rent, sell or share your personal information and will not disclose any of your personally identifiable information to third parties. In cases where it has your permission to provide Products or Services you have requested, and such information is necessary to provide them, the information may be shared with New Shakti Enterprise business associates and partners. New Shakti Enterprise may share consumer information on an aggregate basis with its partners or third parties where it deems necessary. In addition, New Shakti Enterprise may use this information for promotional offers, to help investigate, prevent or take action regarding unlawful and illegal activities, suspected fraud, potential threats to the safety or security of any person, violations of the Platform's terms of use, or to defend against legal claims; and in special circumstances such as compliance with subpoenas, court orders or requests from legal authorities or law enforcement agencies requiring such disclosure.

How we protect your information

To protect against the loss, misuse and alteration of the information under its control, New Shakti Enterprise has in place appropriate physical, electronic and managerial procedures. For example, New Shakti Enterprise servers are accessible only to authorised personnel, and your information is shared with employees and authorised personnel on a need-to-know basis to complete the transaction and provide the Services or Products requested by you. Although New Shakti Enterprise will endeavour to safeguard the confidentiality of your personally identifiable information, transmissions made by means of the Internet cannot be made absolutely secure. By using this Platform, you agree that New Shakti Enterprise will have no liability for disclosure of your information due to errors in transmission or unauthorised acts of third parties. If you suspect any data breach, including misuse, loss or unauthorised access to your data, please let New Shakti Enterprise know immediately by contacting the email address provided in this Privacy Policy.

Retention of your information

New Shakti Enterprise retains your personal information as long as necessary for the use of our Products and Services or to provide access to and use of the Platform, or for other essential purposes such as complying with our legal obligations, resolving disputes, enforcing our agreements, and as long as processing and retaining your information is necessary for our legitimate interest. Because these needs vary for different data types and purposes, actual retention periods can vary significantly. Even if we delete your information, it may persist on backup or archival media for audit, legal, tax or regulatory purposes.

Children and persons with disability

New Shakti Enterprise does not provide Services or Products directly to children under the age of 18 years or proactively collect their personal data. However, New Shakti Enterprise may allow children to use its Services or Products provided that their parents or legal guardians give verifiable consent. The parent or legal guardian shall assume all responsibility and legal liability for the conduct of such child, including monitoring the child's access and use of the Services and Products.

If New Shakti Enterprise learns that the personal data of a child has been collected without verifiable parental consent, it may take appropriate steps to delete such information. If you discover your child has submitted their data to us, you may request to have such data deleted from our database by sending an email request to the address given under 'Contact us'. Upon receiving the request, New Shakti Enterprise shall delete such information from its database within a reasonable time.

A person with disability who has a lawful guardian may use New Shakti Enterprise Services and Products, provided that the legal guardian consents to such use. The legal guardian shall assume all responsibility and legal liability for the conduct of such person, including monitoring their access and use. If we learn that the Services are being used by a person with disability without verifiable consent of their legal guardian, New Shakti Enterprise may take appropriate steps to delete such information.

Your rights and choices

When New Shakti Enterprise processes information about you, it does so with your consent and/or as necessary to operate its business, meet its contractual and legal obligations, protect the security of its systems and customers, or fulfil other legitimate interests described in this Privacy Policy. You may however request the following:

• opt out of some collection or uses of your information, including the use of cookies and similar technologies and the use of your information for marketing purposes.
• access your information or request its deletion or anonymisation.
• change or edit information submitted to us.
• withdraw any consent provided or alter your preferences.
• Right to nominate — you have the right to nominate a person who shall, in case of your death or inability to exercise your rights as a user, take appropriate action on your behalf.
• Right to grievance redressal, as provided under 'Contact us' below.

To correct or update any information you have provided, the Platform allows you to do so online. You may also submit a request for deletion of your personal information, withdrawal of consent, or, in the event of loss of access details, send an email to info@novaproducts.in. New Shakti Enterprise does not charge you for any such request. Where legally permitted to do so, New Shakti Enterprise may refuse your request, and will tell you the reason why.

Changes to this Privacy Policy

New Shakti Enterprise reserves the right to change or update this policy at any time. Such changes shall be effective immediately upon posting to the Platform. You can access the latest version of this Privacy Policy at any given time on the Platform, and it shall be your responsibility to stay updated on any changes. In case you disapprove of the Privacy Policy or withdraw your consent, you should immediately cease to use the Platform. The terms of this Privacy Policy shall be read with, and as an integral part of, the terms and conditions.

Selling your data is strictly against our policy. We track your events and share them with our third-party analytics partners to provide you with better Services and Products.

Contact us

New Shakti Enterprise takes your privacy very seriously and tries to adhere to the highest standards when collecting and processing your data. If you think there is a problem with the way New Shakti Enterprise is processing your personal data, we encourage you to contact our Grievance Officer directly to see if your concerns can be addressed.

If you are not satisfied with the outcome of the grievance redressal mechanism, or if you consider that your complaint has not been handled correctly, you may lodge a complaint with the Data Protection Board of India or the Information Commissioner's Office, as may be applicable.

Grievance officer

In accordance with the Information Technology Act, 2000, the Digital Personal Data Protection Act, 2023 and the Rules made thereunder, the name and contact details of the Grievance Officer are provided below.

• First escalation — IT Grievance Officer: techsupport@novaproducts.in. Turnaround time: within 3 days.
• Returns and refunds, first escalation — Grievance Officer: feedback@newshaktient.com, mobile 9819719930. Turnaround time: within 3 days.
• Second escalation — Nodal Officer: nodal@novaproducts.in. Turnaround time: within 7 days from escalation.

If you wish to make a complaint regarding any violation of the provisions of this Privacy Policy, you may send a written complaint to the Grievance Officer, who shall redress the complaint in accordance with the provisions of the Information Technology Act, 2000, the Digital Personal Data Protection Act, 2023 and the Rules made thereunder.