Privacy Policy

This Privacy Policy ("Policy") is published by The Bare Minimum Club (the "Site", "we", "us", or "our"), a sole proprietorship registered in India, operating through the website www.thebareminimumclub.com (the "Website"). This Policy governs the collection, use, storage, disclosure, and protection of personal data obtained through the Website and any related services, transactions, or communications conducted therewith.

By accessing or using the Website or placing an order, you ("you", "your", or "Data Principal") acknowledge that you have read and understood this Policy. If you do not agree to this Policy, please discontinue use of the Website.

1. SCOPE AND APPLICABILITY

This Policy applies to all visitors, users, and customers of the Website. The Website is globally accessible and our products are marketed through social media platforms including Facebook, Youtube, Instagram and Whatsapp which may be accessed by individuals worldwide. However, our goods and services are offered and shipped exclusively to customers located within the territory of India, and this Policy is framed primarily under Indian law.

Visitors accessing the Website from outside India acknowledge that their data may be incidentally collected through standard website and social media tools. We do not actively target individuals in the European Union (EU), United Kingdom (UK), or other jurisdictions for the purpose of selling goods, and we do not assume obligations under foreign privacy laws such as the General Data Protection Regulation (GDPR). 

2. DEFINITIONS

For the purposes of this Policy:

•   "Personal Data" or "Personal Information" means any data about an individual who is identifiable by or in relation to such data, including but not limited to name, email address, postal address, phone number, and device identifiers.

•   "Data Principal" refers to the individual to whom the personal data relates, i.e., the customer or visitor.

•   "Third-Party Service Provider" means any external entity engaged by us to perform functions in connection with the Website or our services, such as payment processors and e-commerce platform providers.

3. CATEGORIES OF PERSONAL DATA COLLECTED

We collect the following categories of personal data:

3.1 Data Provided Directly by You

•   Identity Data: Full name, username or similar identifier.

•   Contact Data: Email address, telephone number, billing address, and shipping address.

•   Account Data: Login credentials including username and password.

•   Transaction Data: Details of products purchased, order history, and payment records.

•   Payment Data: Payment card details, UPI identifiers, or other financial information submitted at checkout. Payment data is processed directly by our payment gateway partner, Razorpay, and is not stored on our servers.

•   Communications Data: Any correspondence you send to us, including queries, complaints, or feedback.

3.2 Data Collected Automatically

•   Technical Data: Internet Protocol (IP) address, approximate location derived from IP address, browser type and version, time zone setting, browser plug-in types, operating system and platform.

•   Usage Data: Information about how you use the Website, including pages visited, links clicked, and time spent on pages.

•   Cookie and Tracking Data: Data collected through cookies and similar tracking technologies as described in Section 8 of this Policy.

3.3 Data Collected from Third Parties:

We may receive certain data from third-party service providers in connection with your use of our Website and our marketing activities. This includes:

  • Analytics and usage data from Shopify regarding how visitors interact with our Website.

  • Advertising performance data from Meta Platforms (Facebook and Instagram) and Google (YouTube), including audience insights and interaction data related to our advertisements.

Any data received from third parties is handled in accordance with this Policy and is used solely for the purposes described in Section 4.

3.4 Data We Do Not Collect

We do not collect racial or ethnic origin data, political opinions, religious beliefs, or genetic or biometric data.

4. PURPOSE AND LEGAL BASIS FOR PROCESSING

We process your personal data on the following lawful bases: (a) your free, specific, informed, unconditional, and unambiguous consent; (b) the necessity of processing to perform a contract with you; and (c) compliance with applicable law. The specific purposes for which we process your data are set out below:

  • Order Fulfillment: To process, confirm, and deliver your orders, facilitate returns and exchanges, and share your address and contact details with our logistics partners as necessary to complete the order. 

  • Account Management: To create and maintain your customer account on the Website.

  • Payment Processing: To facilitate secure payment transactions through Razorpay, our authorised payment gateway. 

  • Customer Support: To respond to your queries, complaints, and requests, and to maintain records of such communications. 

  • Legal Compliance: To comply with applicable laws, regulations, court orders, or governmental directives. 

  • Website Operations: To administer the Website, including troubleshooting, data analysis, testing, and system maintenance, conducted through our e-commerce platform, Shopify.

  • Analytics: To understand how visitors interact with our Website, improve our offerings, and monitor Website performance. 

  • Marketing Communications: To send you promotional communications through the following channels, subject to your express consent:

  1. Email communications regarding new collections, offers, and updates.

  2. SMS messages to your registered mobile number. 

  3. WhatsApp messages through WhatsApp Business.

  4. Advertisements and branded content on Facebook, Instagram, and Youtube.  

This may include using your data to show you retargeted advertisements on social media platforms and other websites based on your prior interaction with our Website. 

You may withdraw your consent to any or all of these communications at any time by contacting us at supporttbmc@gmail.com  or by using the opt-out option provided in the respective communication. To opt out of targeted advertising on social media platforms, please refer to Section 8 of this Policy.

  • Fraud Prevention: To detect, investigate, and prevent fraudulent transactions and other illegal activities.

We shall not process your personal data for any purpose beyond those specified herein without obtaining fresh consent from you.

5. DISCLOSURE TO THIRD PARTIES

We do not sell, rent, or trade your personal data to any third party. We may share your data with the following categories of Third Party Service Providers solely to the extent necessary to fulfil the purposes stated in this Policy:

5.1 Payment Gateway - Razorpay

We use Razorpay (operated by Razorpay Software Private Limited) to process payments. When you make a purchase, your payment information is transmitted directly to Razorpay and is governed by Razorpay's own privacy policy. We do not receive or store your full payment card details. Razorpay is a licensed payment aggregator regulated by the Reserve Bank of India (RBI). 

5.2 E-Commerce Platform - Shopify

Our Website is hosted and operated on the Shopify platform (operated by Shopify Inc.). Shopify processes certain personal data on our behalf, including order data, account information, and browsing behaviour, as a data processor. Shopify's processing is governed by their Data Processing Addendum and Privacy Policy. Shopify may process data on servers located outside India. However, such transfers are governed by Shopify's contractual safeguards.

5.3 Social Media Platforms

  • Facebook, Instagram and WhatsApp Business - We maintain a brand presence on Facebook and Instagram, and use WhatsApp Business for promotional communications (all operated by Meta Platforms, Inc.). When you interact with our content or advertisements on these platforms, Meta may collect and process your personal data in accordance with their own Privacy Policy. We do not control Meta's data practices. If you click through to our Website from a Meta platform, standard website tracking tools may record that visit. Promotional communications sent via WhatsApp Business are governed by Meta's Business Messaging Policy (Facebook) (Whatsapp Business) and are only sent to customers who have explicitly opted in.

  • Youtube - We maintain a brand presence on YouTube (operated by Google LLC). When you interact with our content or advertisements on YouTube, Google may collect and process your personal data in accordance with Google's Privacy Policy. We do not control Google's data practices. If you click through to our Website from YouTube, standard website tracking tools may record that visit.

5.4 SMS Service Provider 

We use authorised third party SMS service providers to send transactional and promotional messages to customers who have opted in to receive such communications. These providers process your mobile number solely for the purpose of message delivery.

5.5 Logistics and Delivery Partners

We share your name, phone number, and delivery address with our courier and logistics partners-  Delhivery Limited solely for the purpose of fulfilling your order and effecting delivery within India. 

5.6 Legal and Regulatory Authorities

We may disclose your personal data to governmental authorities, law enforcement agencies, or courts of competent jurisdiction if required to do so by law, regulation, legal process, or enforceable governmental request, or to protect the rights, property, or safety of the Site, its customers, or others.

5.7 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred to the successor entity. We will notify you of any such transfer and the applicable privacy terms via email or a prominent notice on the Website.

5.8 Third-Party Links

The Website may contain links to third-party websites or platforms, including social media pages. If you follow such links, you should review the privacy and security policies of those websites independently. We are not responsible for the privacy practices, accuracy, or content of any third-party websites, and our inclusion of such links does not constitute an endorsement.

6. DATA RETENTION

We retain your personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law, whichever is longer. The following retention principles apply:

  • Account data is retained for as long as your account remains active. Upon account deletion, your personal data will be erased within a reasonable period, unless retention is required by law.

  • Marketing data is retained until you withdraw consent or opt out of marketing communications.

  • Cookie and analytics data is retained for periods as specified in Section 8.

Upon expiry of the applicable retention period, or upon withdrawal of consent where no other lawful basis exists, we will securely delete or anonymise your personal data.

7. YOUR RIGHTS AS A DATA PRINCIPAL

Under the Digital Personal Data Protection Act, 2023, you have the following rights with respect to your personal data:

7.1 Right to Access

You have the right to obtain a summary of your personal data being processed by us and the purposes for which it is being processed.

7.2 Right to Correction, Completion and Erasure

You have the right to correct inaccurate personal data, request completion or updating of incomplete personal data, and request erasure of your personal data where it is no longer necessary for the purpose for which it was collected or where you have withdrawn your consent.

7.3 Right to Grievance Redressal

You have the right to have your grievances addressed in a time-bound and effective manner. Please refer to Section 10 for details of our Grievance Officer.

7.4 Right to Nominate

You have the right to nominate another individual to exercise your data rights on your behalf in the event of your death or incapacity.

7.5 Right to Withdraw Consent

You may withdraw your consent to the processing of your personal data at any time. Such withdrawal shall not affect the lawfulness of processing carried out prior to the withdrawal. Please note that withdrawal of consent may affect your ability to use certain features of the Website or receive our services.

7.6 Right to Appeal

If we decline to process your data rights request, you may appeal that decision by contacting us at supporttbmc@gmail.com.  If your grievance remains unresolved, you may escalate the matter to the Data Protection Board of India once operational.

7.7 How to Exercise Your Rights

To exercise any of the above rights, please contact us at supporttbmc@gmail.com with the subject line "Data Rights Request". We will acknowledge your request within forty-eight (48) hours and endeavour to resolve it within thirty (30) days.

8. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies on the Website to enhance your browsing experience and collect usage data. Cookies are small data files placed on your device when you visit our Website.

8.1 Types of Cookies We Use

•   Strictly Necessary Cookies: Required for the Website to function properly, including maintaining your session and cart.

•   Analytics Cookies: Used to understand how visitors interact with the Website, processed via tools embedded in the Shopify platform.

•   Marketing/Preference Cookies: Used to remember your preferences and, where you have consented, to deliver relevant marketing content.

8.2 Third-Party Cookies

Third Party Service Providers such as Shopify, Razorpay, Meta (Facebook/Instagram/WhatsApp Business), and Google (Youtube) may set cookies on our Website for functional, security, and advertising purposes. For specific information about the cookies Shopify uses, please see https://www.shopify.com/in/legal/cookies. These cookies are governed by the respective privacy policies of those providers.

8.3 Cookie Consent and Management

By continuing to use our Website, you consent to our use of necessary cookies. For non-essential cookies, we will seek your explicit consent. You may withdraw cookie consent or manage your preferences at any time through your browser settings. Please note that disabling cookies may affect the functionality of the Website.

The retention periods for cookies used on this Website are as follows:

  • Strictly Necessary Cookies: Retained for the duration of your browsing session and cleared when you close your browser, or up to 30 days for session continuity.

  • Analytics Cookies: Retained for up to 13 months from the date of collection, after which they are automatically deleted or anonymised.

  • Marketing/Preference Cookies: Retained for up to 90 days, or until you withdraw consent, whichever is earlier.

Third-party cookies set by Shopify, Razorpay, Meta, and Google are governed by the respective retention policies of those providers.

8.4 Behavioural Advertising and Opt-Out

We may use tracking tools including Meta Pixel (for Facebook and Instagram) and Google tracking technologies (for YouTube) to show you targeted advertisements based on your interaction with our Website. You can opt out of targeted advertising through the following platform settings:

Please note that opting out does not mean you will stop seeing advertisements. It means the advertisements you see will no longer be tailored to your browsing behaviour.

9. DATA SECURITY

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, alteration, or disclosure. These include SSL encryption, restricted access controls, and reliance on the security infrastructure of our service providers Shopify and Razorpay.

In the event of a personal data breach, we will notify the Data Protection Board of India and the affected Data Principals promptly and in accordance with applicable law.

No method of transmission over the internet or electronic storage is entirely secure. You use the Website at your own risk and are encouraged to access it through a secure environment.

10. GRIEVANCE REDRESSAL

In compliance with applicable Indian law, we have designated the following Grievance Officer to address any complaints or concerns regarding this Policy or the processing of your personal data:

Grievance Officer: Saumya Karani

Designation: Proprietor, The Bare Minimum Club

Email: supporttbmc@gmail.com 

Website: www.thebareminimumclub.com

All complaints or queries shall be acknowledged within forty-eight (48) hours of receipt and resolved within thirty (30) days. If your grievance is not resolved to your satisfaction, you may escalate the matter to the Data Protection Board of India (once operational) or approach the appropriate consumer forum under the Consumer Protection Act, 2019.

11. CHILDREN'S PRIVACY

The Website and our services are not directed at individuals under the age of eighteen (18) years. We do not knowingly collect personal data from minors, and we do not engage in tracking, behavioral monitoring, or targeted advertising directed at minors.

We require verifiable parental or guardian consent before a minor uses this Website or provides any personal data. If we become aware that personal data has been collected from a minor without such consent, we will take immediate steps to delete it. 

If you are a parent or guardian and believe that your child has provided personal data to us, please contact us immediately at supporttbmc@gmail.com. 

12. CROSS-BORDER DATA TRANSFERS

Certain third-party service providers we engage, including Shopify Inc. (Canada), Meta Platforms, Inc. (USA) and and Google LLC (USA) may process or store your personal data on servers located outside India. Such transfers are necessary for the provision of our services and are carried out subject to contractual safeguards with those providers.

We comply with applicable Indian law regarding cross-border data transfers and will not transfer your personal data to any country that has been restricted by the Government of India through official notification. 

13. AMENDMENTS TO THIS POLICY

We reserve the right to amend or update this Policy at any time to reflect changes in applicable law, our business practices, or operational requirements. Any changes will be posted on the Website with a revised "Last Updated" date at the top of this Policy. Your continued use of the Website following the posting of any changes constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically.

14. CONTACT US

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact us at:

The Bare Minimum Club

Operated by: Saumya Karani

Address: D-3/206, Vasupujya Apt., Jain Mandir Road, Sarvodaya Nagar, Mulund West, Mumbai 400080

Email: supporttbmc@gmail.com 

Website: www.thebareminimumclub.com