Privacy policy

Privacy Policy

We know that you care about your Personal Data and how it is used, and we want you to trust that Fresabbit Hygiene Private Limited (“Habbits”) uses your Personal Data carefully. This Privacy Notice will help you understand what Personal Data we collect, why we collect it and what we do with it. This Notice also constitutes a privacy policy for the purposes of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

As you read this Notice, please keep in mind that it applies to all Habbits group companies (means Fresabbit Hygiene Private Limited and any company directly or indirectly owned and/or controlled by them). You will find more details in the Whom Will It Be Shared With section.

Please take a moment to familiarise yourself with our privacy practices and let us know if you have any questions by sending us an email at hello@habbits.in or submitting a request through the “Contact Us” form on our website.

We have tried to keep this Notice as simple as possible, but if you’re not familiar with terms, such as Cookies, IP Addresses, and browsers, then please go to the Key Terms section first.

You have the right to withdraw your Consent for uses of your Personal Data based on Consent provided by you. See what your rights are and how you can exercise them in the sections below.

Who Is Collecting It?
Any Personal Data provided to or collected by and controlled by Habbits, the Data Fiduciary.
This Privacy Notice applies to Personal Data collected by Habbits in connection with the services and products we offer. References to Habbits in this Notice means Fresabbit Hygiene Private Limited, or any company directly or indirectly owned and/or controlled by Fresabbit Hygiene Private Limited.

This Privacy Notice also applies to Habbits’ marketing content, including offers and advertisements for Habbits products and services, which we (or a service provider acting on our behalf) send to you on Third-Party websites, platforms and applications based on your site usage information. These Third-Party websites generally have their own Privacy Notice and Terms and Conditions. We encourage you to read them before using those websites.

Key Terms You Should Know The Meaning Of

What Personal Data Is Being Collected?

You are not required to provide Habbits the Personal Data that we request, but if you choose not to do so, we may not be able to provide you with our products or services, or with a high quality of service or respond to any queries you may have. We may collect Personal Data from a variety of sources. This includes:

1. Personal Data you give us directly,
2. Personal Data we collect automatically, and
3. Personal Data we collect from other sources.

You may be asked to provide your Personal Data when you are in contact with us. Habbits group companies may share your Personal Data with each other and use it in a manner consistent with this Privacy Notice. We may also combine it with other information to improve our products, services, content, and advertising.

Ways in which we collect your Personal Data
We may collect Personal Data from a variety of sources. This includes:

Personal Data you give us directly. We collect data about how you use our services and products, such as the types of content you view or engage with, or the frequency and duration of your activities. We also collect Personal Data you provide us when you sign up for a marketing newsletter, complete a survey, register for an account to buy our products, or otherwise interact with our services. In so doing, we may ask for Personal Data, including but not limited to your name, gender, date of birth, address, email address, and telephone number, along with transaction-related information. We may also collect information relating to your preferences (such as product suitability or allergies), strictly on a voluntary basis and, where required, based on your explicit consent.

We do not collect or process biometric data, facial recognition data, genetic data, or any information relating to religion or sexuality. For more information on how we collect and use your Personal Data, please refer to the relevant sections below.

Personal Data we collect automatically. We also receive and store certain types of Personal Data whenever you interact with us online. For example, we use Cookies and tracking technologies to obtain Personal Data when your web browser accesses our websites or advertisements and other content served by or on behalf of Habbits on other websites. You can read the “How We Use Cookies” section for greater detail.

Your Personal Data is also collected when you search, buy, post, participate in a contest or questionnaire, or communicate with our customer service teams. Examples of the types of Personal Data we collect include IP address, device ID, location data (where permitted), and technical information such as browser type and version, time zone setting, browser plug-in types and versions, operating system, and purchase history, which may be aggregated with similar information from other users.

During your interaction with our websites, we may also use software tools to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information, and navigation patterns. We may also collect technical information to help identify your device for fraud prevention and diagnostic purposes.

Personal Data we collect from other sources. We collect Personal Data from other sources including trusted third-party partners and platforms where we operate our accounts. Additionally, we receive information about your interactions with our advertising to measure its relevance and effectiveness. We may also receive information about you from third parties when we jointly offer services or products, or from analytics and data partners who provide insights to help us improve our services, subject to applicable law.

When and why we collect “special categories of personal data”
Certain categories of Personal Data, such as Health Data and limited Financial Data, may be considered sensitive in nature and require a higher standard of protection.

We limit the circumstances in which we collect and process such data and ensure that it is done only where necessary and with your explicit consent, where applicable.

Habbits may collect certain health-related information, such as allergies or product suitability preferences, in order to recommend appropriate products and provide a better user experience, including tailored recommendations and relevant promotions. Such information is collected only on a voluntary basis and is processed strictly in accordance with the consent provided by you.

In some instances, your interactions with our products or services may indirectly indicate certain preferences (such as product usage patterns). However, we do not intentionally collect or process any information relating to religion, sexuality, biometric identifiers, or genetic data.

How do we protect children’s privacy?
We understand the importance of taking extra precautions to protect the privacy and safety of children using Habbits products and services.

Habbits’s website is designed and intended for use by adults. Where one of our websites is intended for use by a younger audience, we will obtain Consent from the person with guardian responsibility before we collect Personal Data where it is required by applicable laws and regulations.

If you are a child under the age where guardian Consent is required in India, you should review the terms of this Privacy Notice with your parent or guardian to make sure you understand and accept them. If we discover that we have collected Personal Data from a child without Consent from a parent or guardian where such Consent should have been obtained, we will delete that Personal Data as soon as practical. Access to certain parts of the Habbits’s websites and/or eligibility to receive prizes, samples or other rewards are generally limited to users over a certain age.

We sometimes use your Personal Data to carry out age verification checks and enforce any such age restrictions.

What Purpose Do We Use Your Data For?

We collect, process and disclose your Personal Data only for specific and limited purposes. For example, to assess and handle any complaints, to develop and improve our products, services, communication methods and the functionality of our websites, and to provide personalised product recommendations, communications and targeted advertising.

We may analyse information about your online browsing, searching and buying behaviour, and your interactions with our communications, to understand user preferences and improve our offerings. This may involve grouping users into segments with similar characteristics for the limited purpose of enhancing user experience and relevance of content.

Additionally, Habbits may process certain Personal Data using automated means. However, such processing is limited in nature and is used only to support business operations, improve services, and enhance user experience. No automated decision-making carried out by Habbits produces legal or similarly significant effects on you.

We collect, process and disclose your Personal Data for the following purposes:

• To process and respond to your inquiries or requests;
• To develop and improve our products, services, communication methods and website functionality;
• To administer competitions, promotions, or campaigns that you participate in;
• To manage your account, including ecommerce services, loyalty or reward programs, and other platforms;
• To communicate with you, including managing your subscriptions to newsletters or other communications;
• To manage our business operations relating to your participation in promotional activities;
• To verify your identity when you contact us;
• For internal training, analytics, and quality assurance purposes;
• To understand consumer preferences and improve existing or develop new products and services; and
• To provide personalised product recommendations, communications and relevant advertising (subject to applicable consent requirements).

We do not collect, store, or process your full payment instrument details (such as card numbers, UPI IDs, or bank account information). Payments made on our platform are processed directly by third-party payment service providers in accordance with their own privacy policies and applicable law. We may receive limited transaction-related information such as payment confirmation, transaction ID, and payment status for order fulfilment, reconciliation, and compliance purposes.

Where appropriate, we will seek your consent before processing your Personal Data. Where you have provided consent, you have the right to withdraw such consent at any time.

In certain cases, we may rely on legitimate uses as permitted under applicable law for processing your Personal Data. For example, when you voluntarily sign up for our loyalty programme (such as Trust Circle), we may process your Personal Data to provide associated benefits, services, and communications.

We may also process your Personal Data where required to comply with applicable legal obligations, including but not limited to tax, regulatory, or law enforcement requirements. This may include responding to lawful requests, court orders, or complying with obligations under applicable anti-money laundering or other regulatory frameworks.

Profiling

Habbits uses your Personal Data to build limited user profiles. We create such profiles by analysing information about your online browsing, searching and buying behaviour, and your interactions with our brand communications. This may involve grouping users into segments (i.e., groups with similar characteristics) and placing your Personal Data into one or more such segments.

These segments are used by Habbits to personalise your experience, including tailoring website content, communications (such as newsletters), and displaying relevant offers and advertisements, including through Third-Party platforms. Such segmentation is carried out in a limited and proportionate manner to improve user experience and marketing relevance.

Such profiling does not result in any legal or similarly significant effects on you.

By way of example –

• Habbits may collect data from: 
• Our website regarding the content you view and how you interact with it;
• Our digital advertising displayed on social media platforms and third-party publisher websites; and
• Forms that you voluntarily complete indicating your interests or preferences.
• We may track whether you interact with our advertisements and subsequently make a purchase through our platform or authorised partners, for the limited purpose of measuring effectiveness and improving our offerings.
• If you have opted to receive email or SMS communications from us, we may track whether such communications are opened, read, or clicked, in order to improve the relevance of future communications.
• We use this information to understand general user preferences. For instance, if you frequently view a particular category of products on our website, we may highlight similar or related products that may be of interest to you.
• Based on this information, we may display advertisements that are more relevant to your interests, either on our platform or through our advertising partners. Where required under applicable law, such activities shall be carried out based on your consent.
• With your consent, we may also use limited location information to provide you with relevant promotions or updates that may be of interest in your area.
• We may also use information that you have consented to share with third parties (such as basic demographic or preference-related information) to better understand customer segments and improve the relevance of our communications and offerings.

How We Use Cookies

We use traffic log Cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We use this information for statistical analysis purposes and then data is removed from the system. Overall, Cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any other information about you, other than the data you choose to share with us.

You can choose to accept or decline Cookies. Most web browsers automatically accept Cookies, but you can usually modify your browser settings to decline Cookies if you prefer. This may prevent you from taking full advantage of the website.

Whom Will It Be Shared With?

Habbits shares your Personal Data within its corporate group and with selected third-parties in the following circumstances:

• Third-Party service providers. In order to carry out your requests, process transactions, respond to your inquiries, fulfil orders, honour promotions, provide samples, and enable various features and services on our platform, we may share your Personal Data with third-party service providers who perform functions on our behalf. These may include entities that host or operate our websites, process payments, provide analytics, customer support, logistics or delivery services, and administer promotions. Such service providers are granted access only to the Personal Data necessary for performing their functions and are contractually obligated to process such data solely for the specified purpose, maintain confidentiality, and comply with applicable data protection laws. 
• Other third-parties. We may share your Personal Data with advertising partners, social media platforms, analytics providers, and other third parties in connection with marketing, promotional activities, and improving our services. Such sharing shall be undertaken in accordance with applicable law and, where required, based on your consent. Where such third parties process your Personal Data independently for their own purposes, they shall be responsible for obtaining appropriate consent or relying on a valid legal basis for such processing.
• Business transfers. As part of our business operations, we may transfer or disclose Personal Data within the Habbits group or to third parties in connection with any merger, acquisition, restructuring, sale of assets, or similar transaction. In such cases, Personal Data shall continue to be subject to the commitments made in this Privacy Policy, unless otherwise required by law or consented to by you. During such transactions, Personal Data may also be shared as part of due diligence, subject to appropriate confidentiality and data protection safeguards.
• Legal disclosure. We may transfer and disclose your Personal Data to third-parties:
• To comply with a legal obligation;
• When we believe in good faith that an applicable law requires it;
• At the request of governmental authorities conducting an investigation;
• To verify or enforce our “Terms of Use” or other applicable policies;
• To detect and protect against fraud, or any technical or security vulnerabilities;
• To respond to an emergency; or otherwise
• To protect the rights, property, safety, or security of third-parties, visitors to Habbits’s websites, Habbits, or the public.
• International Data Transfers

Habbits may share Personal Data or processed data across international borders for purposes described in this Privacy Notice but will make sure that the Personal Data is protected in a similar manner. However, your data will only be transferred if permitted and in accordance with applicable local and international regulations.

How Do We Protect Your Personal Data?

Habbits takes the security of your Personal Data very seriously. We implement reasonable and appropriate technical and organisational measures to protect your Personal Data against misuse, loss, unauthorised access, modification, or disclosure.

Our measures include implementing access controls, maintaining secure IT infrastructure, and using safeguards such as encryption, pseudonymisation, and anonymisation, where appropriate. We also maintain internal policies and procedures to ensure the lawful processing and protection of Personal Data.

Access to your Personal Data is restricted to authorised employees, agents, and service providers on a need-to-know basis and is subject to strict confidentiality and contractual obligations.

How Long Do We Keep Your Personal Data For?

We will retain your Personal Data only for as long as necessary for the purposes for which it is processed, unless a longer retention period is required or permitted under applicable law. For example, where you make a purchase with us, we will retain data related to such transaction for the duration necessary to perform the contract and thereafter for a reasonable period to address any related complaints, queries, or concerns.

Your Personal Data may also be retained for a limited period to improve your experience with us and to ensure that you receive any applicable loyalty benefits or services.

Where Personal Data is processed for marketing or communication purposes, such data will be retained only for as long as it remains relevant for such purposes and in accordance with applicable law. We will not engage in excessive or indiscriminate marketing. If you withdraw your consent, we will take reasonable steps to delete or cease processing your Personal Data within a reasonable timeframe, unless retention is required for compliance with legal obligations or other lawful purposes.

We periodically review the Personal Data we hold and securely delete or anonymise it when it is no longer required for legal, business, or operational purposes.

What Are Your Rights?

• The right to be informed: You have the right to receive clear, transparent, and easily understandable information about how we collect, use, and process your Personal Data. This Privacy Notice is intended to provide such information.
• The right to access, update and rectification: You have the right to access and request correction or updating of your Personal Data. We will take reasonable steps to ensure that inaccurate or incomplete data is corrected.
• The right to erasure: Under certain circumstances, you may request deletion of your Personal Data. We will take reasonable steps to delete such data where it is no longer necessary for the purposes for which it was collected, unless retention is required under applicable law.
• The right to withdraw consent: Where processing is based on your consent, you have the right to withdraw such consent at any time. Withdrawal of consent shall not affect the lawfulness of processing carried out prior to such withdrawal. Please note that withdrawal of consent for essential data may impact our ability to provide services to you.
• The right to object to processing: You may object to certain types of processing, including processing for direct marketing purposes, subject to applicable law.
• Right to grievance redressal: You have the right to raise requests or grievances in relation to your Personal Data by contacting our designated grievance officer at nimisha@habbits.in. We will address such requests in accordance with applicable law.
• Right to nominate: You may nominate another individual to exercise your rights in the event of your death or incapacity, in accordance with applicable law.
• Right to lodge a complaint: You have the right to lodge a complaint with the Data Protection Board or any other competent authority under applicable law.
• Further information and advice about your rights can be obtained from the data protection Regulator in your Country.

How Do You Contact Habbits?

We are committed to protect your personal information collected and processed by us and look forward to your continued support for the same. If you have any query, grievance with respect to the processing of information by us, you can reach out to our designated contact person at +91-8767114711 or submitting a request through the “Contact Us (Privacy Request/Concern)” form available on the Habbits website.

When a privacy question or access request is received, we have a dedicated team which triages the contacts and seeks to address the specific concern or query which you are seeking to raise. Where your issue may be more substantive in nature, more information may be sought from you. If you are dissatisfied with the reply received, you may refer your complaint to the relevant Supervisory Authority. If you ask us, we will endeavour to provide you with information about relevant complaint avenues which may be applicable to your circumstances.

How Do We Keep This Notice Up To Date?

We will update this Privacy Notice when necessary to reflect customer feedback, our practices, scope of processing, and changes in our products and services. When we post changes to this statement, we will revise the “last updated” date at the bottom of this Notice. You are encouraged to periodically visit this page to review the Privacy Notice and any changes to it. Your continued use or access after any modification(s) to this Privacy Notice, will be deemed as your acceptance to such modification(s). If the changes are significant or sensitive, we will provide a more prominent notice (including, for certain services, email notification of Privacy Notice changes).

Additional Privacy Terms or Notices

In addition to this Privacy Notice, there may be specific campaigns or promotions which will be governed by additional privacy terms or notices. We encourage you to read these additional terms or notices before participating in any such campaigns or promotions as you will be required to comply with them if you participate. Any additional privacy terms or notices will be made prominently available to you.

Grievance Redressal Mechanism

In compliance with the provisions of the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”), and other applicable laws, Fresabbit Hygiene Private Limited has established a structured grievance redressal mechanism for addressing concerns relating to the processing of Personal Data. Any discrepancies, grievances, complaints, or concerns with respect to the collection, use, disclosure, storage, or processing of Personal Data may be addressed to the designated Grievance Officer appointed by the Company.

The details of the Grievance Officer are as follows:

Name: Nimisha Goyal
Designation: Grievance Officer

Company: Fresabbit Hygiene Private Limited

Corporate Office: 2202, Basement, DLF Phase 4, Gurugram, Haryana – 122009, India

Email: nimisha@habbits.in
Contact Number: +91-8767114711
The Grievance Officer shall acknowledge receipt of any complaint within Forty Eight (48) hours and shall endeavour to resolve such complaint within fifteen (15) days from the date of receipt, in accordance with applicable law. The Company reserves the right to seek additional information from the complainant to verify identity and ensure proper resolution of the grievance. All complaints shall be handled in a fair, impartial, and time-bound manner.

Cross-Border Transfer of Personal Data

The Company may, in the course of providing its products and services, transfer Personal Data, including Sensitive Personal Data or Information (if any), to third-party service providers, affiliates, or business partners located outside India. Such transfers may occur for purposes including but not limited to data hosting, cloud storage, payment processing, analytics, customer relationship management, technical support, and other operational requirements necessary for the provision of services.

In the event of any cross-border transfer of Personal Data, the Company shall ensure that such transfer is carried out in accordance with applicable Indian laws, including the Information Technology Act, 2000 and the SPDI Rules, 2011. The Company shall take reasonable steps to ensure that the recipient of such Personal Data provides the same level of data protection that is adhered to by the Company under applicable law. This shall include appropriate contractual safeguards, confidentiality obligations, data protection covenants, and security standards designed to ensure that Personal Data is processed solely for lawful purposes and is protected against unauthorised access, disclosure, alteration, or destruction.

Such cross-border transfer shall be undertaken only where it is necessary for the performance of a lawful contract between the Company and the data subject, or between the Company and a third party acting on its behalf, or where the data subject has provided consent for such transfer, or where otherwise permitted under applicable law. By using the Company’s website or services and providing Personal Data, the data subject acknowledges and consents to such cross-border transfers in accordance with this Privacy Policy.

Governing Law and Exclusive Jurisdiction

This Privacy Policy, and any dispute, claim, or controversy arising out of or relating to the collection, processing, use, disclosure, or protection of Personal Data under this Policy, shall be governed by and construed in accordance with the laws of India, without regard to its conflict of law principles.

The parties agree that any legal action, suit, or proceeding arising out of or relating to this Privacy Policy shall be subject to the exclusive jurisdiction of the competent courts situated at Bhopal, Madhya Pradesh, India. The data subject expressly agrees to submit to the jurisdiction of such courts and waives any objection with respect to the venue or forum on the grounds of inconvenience or otherwise.