Tulio Privacy Policy
Introduction

For the purposes of this Privacy Policy ("Policy"), TULIO (hereinafter referred to as "we", "us" or "our") sets out the terms governing the collection, use, disclosure, and processing of personal data.

References to "Website" shall mean and include the website accessible at https://tulio.design/ along with all pages, sub-pages, and content contained therein.

References to "Services" shall mean and include all products, services, features, interactions, communications, and engagements, whether online or offline, offered or made available by us.

References to "you", "your", or "user" shall mean any individual who accesses or uses the Website and/or Services, and whose personal data is processed by us, whether such data is collected in digital form or collected physically and subsequently digitised.

References to "Applicable Law" shall include all applicable statutes, enactments, acts of legislature or parliament, laws, ordinances, rules, bye-laws, regulations, listing agreements, notifications, guidelines or policies of India and judicial, quasi-judicial and/or administrative decisions, interpretations, directions, directives, licenses, permits, judgments, writs, injunctions, arbitral awards, decrees, orders, terms and conditions of governmental or regulatory approvals or agreements with any governmental or regulatory authority.

We value and respect your privacy and are committed to protecting the confidentiality and security of your personal data and sensitive personal data. We may collect and use your personal data based on your consent, to fulfil bona fide contractual and/or legal obligations and/or to serve our legitimate business interests.

While we take reasonable steps to protect your personal data, you acknowledge that your use of the Services is voluntary and at your own risk. Except as expressly required by Applicable Law, we do not assume liability for any loss, unauthorized access, disclosure, alteration, or destruction of data arising from events beyond our reasonable control.

You are advised to read this Policy carefully to understand how your personal data is processed. By accessing or using the Website or Services, you acknowledge and agree to the collection, use, and disclosure of your data in the manner described herein. If you do not agree with this Policy, you are advised to refrain from accessing or using the Website or Services.

This Policy applies only to personal data that we collect, use, disclose, or process in connection with our Website and Services. It does not apply to our employees, service providers, vendors, or contractors, nor does it apply to offline operational records or internal business processes.

Unless the context otherwise requires, the terms defined in this Policy shall carry the same meaning throughout, and references to the singular shall include the plural, references to any gender shall include all genders, and references to persons shall include individuals, entities, and bodies corporate.

We collect personal data directly from you, when you use our Services, and from third parties, as necessary to operate our business, provide our Services, and improve user experience.

You are responsible for ensuring that all data you provide is accurate, complete, and updated. We shall not be responsible for any loss or inconvenience resulting from inaccurate, incomplete, or outdated information submitted by you.

The data we collect falls into the following categories:

Directly Provided Data

Unless otherwise agreed, we collect only the personal data necessary for the business relationship or to fulfil our contractual obligations. Such data may include:

  1. Basic contact details, including name, address, email address, and phone number.
  2. Account data and credentials.
  3. Order and transaction details, including billing and shipping addresses, payment confirmation, and details of purchases or other services rendered.
  4. Payment and financial data, including debit or credit card details (cardholder name, card number, expiration date), net-banking details (account number, bank name, branch), or other payment information, as required to process your orders.
  5. Business-related data, including details of Services, feedback, or any other information voluntarily shared with us during the course of business.
  6. Customer support data, including communications with us (via chat, email, or phone), call recordings, and related service interactions.

Certain features of our Services may require you to provide certain data; where such data is not provided, access to or use of those features may be limited.

Automatically Collected Data

When you visit or interact with our Website, we may collect certain data (hereinafter "Usage Data") through cookies, pixels, web beacons, software development kits, and similar technologies. Such Usage Data may include:

  1. Device and technical data, including IP address, browser type, operating system, device identifiers (for example, IMEI number or MAC address), mobile network information, and access times.
  2. Interaction data, including pages viewed, items added to your cart or wishlist, links clicked, search queries, time spent on the Website, and referring URLs.
  3. Customer service interactions, including the date and time of contact, reasons for inquiry, and transcripts of conversations.
  4. Market research and feedback, including any data voluntarily provided by you regarding your experience with our Services.

Data Received from Third Parties

We may also obtain your data from trusted third-party sources, who may include:

  • Vendors and service providers who assist in operating our Services.
  • Payment processors who collect and process your payment details to fulfil your orders.
  • Marketing and analytics partners who assist in understanding how users interact with our communications and advertisements.
  • Analytics and tracking tools used to analyse Website usage, improve Services, and enable remarketing. These tools may collect device and browsing data.

Any personal data received from third parties will be processed in accordance with this Policy. We do not control and are not responsible for how third parties process, store, or secure your data. Their processing is governed exclusively by their respective privacy practices, for which we disclaim responsibility to the fullest extent permitted by law.

As general standard procedures, we use cookies and similar technologies on our Website to enhance your browsing experience, improve our Services, and support key functions available on the Website. Cookies are small text files placed on your device that help us remember your preferences, understand how you interact with our Website, and provide you with a smoother and more personalized experience. We use the following types of cookies:

  • Necessary Cookies – These are essential for the operation of our Website and for enabling features such as logging in or processing transactions. Without these cookies, certain Services may not function properly.
  • Functionality Cookies – These remember your preferences and choices so you don't have to re-enter information each time you visit.
  • Analytics Cookies – These help us understand how you use our Website, measure performance, and improve our Services.
  • Advertising and Third-Party Cookies – We may allow service providers and partners to place cookies on our Website to help us deliver relevant content, tailor advertisements, and analyse user engagement across our Website and other websites.

You can control or disable cookies through your browser settings. You may also delete cookies already stored on your device at any time. However, note that disabling certain cookies, particularly those that are strictly necessary for the operation of the Website, may restrict some features or functionalities and could affect your overall browsing experience and your ability to use the Services, and we are not responsible for any resulting limitations, errors, or reduced functionality.

We collect, use and process your personal data including Usage Data for various business, operational, legal, and marketing purposes, depending on the nature of your relationship with us and the context in which the data is collected. These purposes include, but are not limited to, the following:

  1. Communicating with you regarding your account, orders, enquiries, feedback, or support requests.
  2. Providing, operating, and managing our Services and facilities, including processing payments, fulfilling orders, arranging shipping, handling returns or exchanges, and maintaining your account.
  3. Performing our contractual obligations and enforcing our terms of Service.
  4. Establishing and verifying your identity and background to ensure secure transactions.
  5. Maintaining and enhancing our relationship with users, business partners, and service providers.
  6. Responding to your enquiries, complaints, or disputes and ensuring effective resolution.
  7. Improving, personalizing, and developing our Website, application and Services through research, analysis, and user feedback.
  8. Conducting market research, internal analysis, and customer profiling to better understand customer preferences, trends, and behaviours.
  9. Managing internal record keeping, administration, audits, and compliance with internal policies and the Applicable Law.
  10. Sending you notifications, updates, and information about our Services, promotions, or events that may be of interest to you.
  11. Facilitating marketing, advertising, and promotional activities including personalized communications and offers, permitted under Applicable Law.
  12. Detecting, investigating, and preventing fraudulent, unauthorized, or illegal activities, and ensuring the security and integrity of our systems and users.
  13. Complying with applicable legal and regulatory requirements or responding to lawful requests from authorities.
  14. Any other purpose reasonably related to the above or for which you have provided explicit consent.

Where the processing of personal data is based on consent, such consent shall be obtained in accordance with the Applicable Law. You retain the right to withdraw your consent at any time and such withdrawal shall not affect the lawfulness of any processing undertaken prior to such withdrawal. However, withdrawing consent could limit or restrict our ability to provide you with certain Services or functionalities that rely on such processing. You acknowledge that our Services are provided on an "as-is" and "as-available" basis, and we make no representation or warranty regarding uninterrupted, error-free, or secure access to the Services, including where such limitations arise as a consequence of your withdrawal of consent or restricted data processing.

We may disclose your personal data to third parties in accordance with the Applicable Law and only for bona fide business, contractual, or legal purposes. Such disclosures may include the following circumstances:

  1. To affiliates, subsidiaries, and other entities, on a need-to-know basis, for purposes of internal administration, data processing, customer support, Service delivery, and business management. Where such affiliates operate in jurisdictions that do not provide an adequate level of data protection, we implement appropriate safeguards to ensure that your personal data is handled in accordance with the Applicable Law.
  2. To authorized personnel, vendors, agents, contractors, and service providers engaged by us to perform Services on our behalf, such as IT and infrastructure management, data analytics, payment processing, order fulfilment, logistics, marketing, advertising, customer service, cloud storage, and communications. Such third parties are required to process your personal data solely for the purposes for which it has been disclosed, and in compliance with contractual and statutory confidentiality obligations.
  3. To business and marketing partners with whom we collaborate to provide or promote our Services, subject to the Applicable Law. However, such partners are solely responsible for processing your data in accordance with their respective privacy policies and the Applicable Law.
  4. To credit reporting agencies, financial institutions, and debt collection entities, for the purposes of credit assessment, verification, or recovery of outstanding payments, where permitted by the Applicable Law.
  5. To public authorities, regulators, or law enforcement agencies, when such disclosure is required to comply with legal obligations, judicial or administrative processes, lawful requests, or for the administration of justice as directed by the Applicable Law.
  6. To protect and enforce our legal rights, including in connection with the prevention, detection, or investigation of fraud, unauthorized access, or other unlawful activities.
  7. In connection with a corporate transaction, such as a merger, acquisition, reorganization, sale, or transfer of all or part of our business, or in the event of insolvency or bankruptcy proceedings, where your personal data may be transferred as part of the business assets.
  8. Where you have expressly consented to such disclosure or have directed us to share your data and Usage Data with third parties, including through integrations with social media platforms or other online spaces.

Except to the extent mandated by Applicable Law, we shall not be liable for any actions or omissions of third parties who receive personal data in accordance with this Policy.

Any information you choose to publicly upload or share through the Website is done at your own discretion and risk. We disclaim all responsibility and liability for the security, use, misuse, or further dissemination of any information you make publicly accessible. We are under no obligation to monitor, control, or remove such content unless required by the Applicable Law.

The Services are not designed for use by any person who has not attained the age of majority. If you are under the age of 18 years, you may use our Services only with the supervision of an adult.

Where we become aware that personal data of a minor has been collected without the requisite consent, we may take appropriate measures to remove such data in accordance with the Applicable Law.

We rely on your representations and cannot independently verify the age of users. We disclaim responsibility for any misrepresentation made by users regarding their age. We do not knowingly sell, share, or disclose the personal data of minors and we shall implement appropriate safeguards to protect the privacy and security of any personal data of minors that we may lawfully process.

We retain your personal data only for as long as necessary to fulfil the purpose of its collection, meet contractual obligations, or comply with the Applicable Law.

We implement appropriate technical, administrative, and organizational measures to safeguard your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include, but are not limited to, encryption, secure storage systems, restricted access controls, and regular monitoring and assessment of our data security practices.

We implement reasonable administrative, technical, and organizational measures to safeguard your personal data; however, no system can guarantee absolute security. To the fullest extent permitted by the Applicable Law, we disclaim liability for any unauthorized access, disclosure, or loss that occurs despite such reasonable measures or that arises from circumstances beyond our reasonable control.

Subject to the Applicable Law, you may have certain rights with relation to your personal data that we hold. These rights are not absolute and may be subject to conditions or limitations as permitted by the Applicable Law. These rights may include the following:

  1. You may request correction or updating of inaccurate or incomplete personal data; however, such corrections or updates will be made only where reasonable, technically feasible, and where they do not adversely affect our operations or legitimate interests.
  2. You may request that we restrict our processing of your personal data in specific circumstances, including profiling, where applicable.
  3. You may withdraw any consent you have provided for the processing of your personal data, in whole or in part, while acknowledging that such withdrawal may affect our ability to provide Services to you.
  4. You may object to the processing of your personal data for direct marketing communications, while continuing to receive transactional or Service-related communications necessary for the provision of our Services.
  5. In case you request "do not track" signals, please note that our Website may not respond to certain signals from browsers. Where supported technologies permit, analytics and tracking tools may continue to operate based on your device and browser settings, subject to the configurations available through such tools and applicable privacy controls.
  6. We may use automated decision-making processes such as fraud-detection algorithms when assessing certain actions on your account, including order verification. These systems help us manage risk, but they are not infallible. If you believe a decision was made in error, you may contact us to request a manual review.
  7. You may request deletion of your user account and associated personal data by contacting us. Upon receiving your request, we will take reasonable steps to delete your account and personal data from our active databases, subject to any legal or contractual obligations that require us to retain certain data.

To exercise any of these rights, you may contact us using the details provided in this Policy. We shall take reasonable steps to verify your identity before acting upon any request, and where permitted, you may designate an authorized agent to make a request on your behalf, subject to proof of authorization.

We shall respond to requests in a timely manner in accordance with the Applicable Law. In certain cases, we may decline requests where fulfilling them is not required by law, is technically infeasible, compromises the rights of others, or imposes a disproportionate burden on us or operational risks.

Your personal data may be transferred, stored, and processed in jurisdictions whose data protection and privacy laws may differ. Such processing may be carried out by our personnel, affiliates, or third-party service providers. Where personal data is transferred across international borders, we shall ensure that such transfers are conducted in accordance with the Applicable Law.

By continuing to use the Website and/or Services, you acknowledge and agree that such international transfers may carry inherent risks, and we shall not be liable for the acts or omissions of foreign service providers or authorities. Further, you acknowledge and agree that such transfers may be necessary for the performance of contractual obligations and for the continued provision of our Services to you.

We reserve the right to amend, revise, or update this Policy at any time, in accordance with the Applicable Law and internal policy requirements. Any such changes will be reflected by updating the "Last Updated" date on the page containing this Policy and we are under no obligation to individually notify users of changes, unless expressly required by the Applicable Law.

We encourage you to review this Policy periodically, preferably each and every time you access and/or use our Services. Your continued use of the Services after any revision shall constitute your acknowledgment and acceptance of the amended Policy, and you acknowledge that it is your responsibility to review this Policy and remain aware of any updates or modifications.

If you have any questions, concerns, or complaints regarding the processing of your personal information, or if you wish to exercise any of your rights under the applicable laws, you may contact our designated Officer using the details provided below. We will make reasonable effort to respond to your complaint in a timely and fair manner, in accordance with the applicable laws.

Name: __________
Contact No.: __________
Email Id: __________
Address: __________