Privacy Policy

January 1st, 2021

This Privacy Policy applies to residents of India.

This Privacy Policy explains how NV Group handles personal information that we collect online, through our websites and applications (apps) and through our offline interactions with you (collectively, the “NV Group”).

This Privacy Policy does not apply to information collected from residents of countries other than India, or to third-party websites to which NV Group may link. Your use of NV Group which link to this Privacy Policy are subject to this Privacy Policy and the terms & Conditions of Use.

Please read this Privacy Policy before using the NV Group Services or submitting personal information to us.

On occasion, NV Group may offer apps, special programs, activities, events or promotions (“Programs”) that have unique or additional specific terms, privacy notices and/or consent forms that explain how any information you provide will be processed in connection with the Programs. You should review the applicable terms before interacting or participating in the Programs.

PERSONAL INFORMATION

“Personal information” is information that identifies you as an individual or relates to an identifiable individual. Examples of personal information include your name, your postal address and your telephone number.

HOW DOES NV GROUP COLLECT PERSONAL INFORMATION?

NV Group collects information in a few different ways:

• Information you submit or choose to provide
• Information you give us permission to collect from you or another source
• From employee, Consultant, Contractors or other legal and Financial Professionals
• Through our websites and mobile apps,
• From contract research organizations and experimental trial, tasting events and any investigators.
• From your participation in NV Group programs or experimental trials, tasting session
• From third party service providers, data brokers or business partners
• From industry and related groups and associations
• Automatically from devices you use to connect to NV Group Services (See “Cookies and Other Tools” below)
• Information provided by NV Group partners.
• From public sources including, but not limited to, social media and other websites that enable social sharing
• Information from government agencies, public or third party information sources

From time to time, we may use or augment the personal information we have about you obtained from other sources, such as public databases, social media platforms and other third parties. We may also combine information we get from a third-party with information we already have, and we may combine information that we have collected offline with information we collect online.

If you choose to submit any personal information relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Policy.

INFORMATION NV GROUP COLLECTS

NV Group may collect the following information, depending on what product and service you use:

• Contact information and preferences (such as name, email address, mailing address, phone number, and emergency contact information)
• Biographical and demographic information (such as date of birth, age, gender, ethnicity, marital status, and sexual orientation)
• Health and medical information (such as medical insurance details, information about physical and mental health conditions and diagnoses, treatments for medical conditions, genetic information, family medical history and medications an individual may take, including the dosage, timing, and frequency) we collect in connection with Insurance Policies for company employees, if any. conducting research, providing medical & health support programs for employees and Community for any CSR Events, distributing and marketing our products, managing compassionate use and expanded access programs and tracking adverse event reports
• Information regarding parents or legal guardians
• Any information you provide in connection with applying to or participating in a assistance or support program (such as financial need information)
• Payment-related information we need to complete a transaction (such as credit card number and financial account information)
• Username and password that you may select in connection with establishing an account on our websites or mobile apps
• Your photograph, social media handle or digital or electronic signature
• Publicly available information or available at other platform and not under any restriction imposed by such platform.
• Internet activity, such as your Internet Protocol (“IP”) address, browsing history, your search history and information on your interaction with the NV Group Services and our advertisements
• Device information
• Geolocation data, e.g., your physical location or movements (See “Cookies and Other Tools” below)
• Inferences drawn from other personal information listed above, to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes
• If you are accessing NV Group websites or apps on your mobile device, you may also choose to provide us with location data. To protect your privacy, you should not provide NV Group with any information that is not specifically requested
• Any adverse event information
• IF YOU ARE A NV Employee / consultant / CONTRACTOR, WE MAY ALSO COLLECT:
• Professional credentials, educational and professional history, institutional and government affiliations, information included on a resume or curriculum vitae, education and work history (such as work experience, education and languages spoken)
• Information about the NV Group programs, products and activities with which you have engaged
• Details about our interactions with you, your prescribing of our products and the agreements you have executed with us; including remittance or other financial information
• Any information you choose to provide about yourself or your household
• Information collected in connection with NV Group hosted events or activities you attend or participate in
• Publicly-available information related to your practice, such as license information, disciplinary history, prior litigation and regulatory proceedings, and other due diligence related information

We may use the personal information we collect about you with information obtained from other sources, such as public databases, social media platforms and other third parties. For example, we may use public information to confirm contact or financial information, to verify licensure from related Govt. Dept. or to better understand your interests by associating demographic information with the information you have provided.

HOW DOES NV GROUP USE PERSONAL INFORMATION?

How NV Group uses your information depends on how you interact with the NV Group Services. Generally, NV Group may also use your information to:

• Provide our products and services to you and make them better
• Develop new products and services
• Fulfill your requests
• Provide customer service
• Send you administrative communications regarding NV’s products or NV Group Services
• Notify you about special promotions or offers that may be of interest to you
• Invite you to participate in surveys about our products or services
• Better understand the interests of our customers and visitors who use NV Group Services
• Maintain NV Group online services such as websites and apps
• Monitor, detect and prevent fraud, improper activity and ensure NV’s policy compliance
• Conduct research including secondary and follow-on research
• Determine an individual’s eligibility to participate in NV Group programs or experimental trials
• Process payments
• Evaluate how you and other users interact with our online services
• Protect NV Group and our users
• Secure our online services including our network, websites and apps
• Conduct audits related to our current interactions with you
• Debug the site and service to identify and repair errors that impair existing intended functionality
• Defend ourselves in litigation and investigations and to prosecute litigations
• Comply with our legal and regulatory obligations
• NV Group may also use information collected from you or about you to offer you customized content, including to:
• Recognize new or past visitors to our websites or apps
• Remember your personal preferences
• Show you more relevant and meaningful advertisements based on your interests

NV Group may also use your information for other purposes disclosed to you from time to time.

In addition, some of our applications and mobile-optimized sites may have location-based features. To deliver these features, we may collect and use location data provided by your mobile device. For example, we may offer shopping features that allow you to get information about local merchants. By using such applications, you consent to the collection and use of your mobile device location data for purposes of delivering these location-based features.

We may use personal information collected from any of the sources listed in the “How Does NV Group Collect Personal Information?” section of this policy for our internal business purposes, such as data analysis, audits, developing new products, enhancing our websites and apps, improving our NV Group Services, identifying usage trends and determining the effectiveness of our promotional campaigns.

We may aggregate and/or de-identify data about customers and site visitors and use it for any purpose, including product and service development and improvement activities.

DOES NV GROUP SHARE PERSONAL INFORMATION?

NV Group may share your information within the NV Group family.

We do not sell your personal information. However, we share personal information with our vendors, contractors, business and service partners, or other third parties (collectively, “Service Providers”). Examples of Service Providers include analysis firms, advertisers, payment processing companies, customer service and support providers, email, IT services and SMS vendors, web hosting and development companies and fulfillment companies. Service Providers also include our co-promotion partners for products that we jointly develop and/or market with other companies.

Some Service Providers may collect personal data on behalf of NV. These third parties may be provided with access to personal data needed to perform their functions. In addition, NV’s practice is to require its Service Providers to keep your personal information confidential and to use personal information only to perform functions for NV Group.

If NV Group sells all or part of one of its product lines or divisions, your information may be transferred to the buyer. NV Group reserves the right to disclose your information to respond to authorized information requests from government authorities, to respond to valid judicial requests, to address national security situations, to provide security and investigate potential fraud, or when otherwise required by applicable law.

NV Group may also disclose your personal information as required by law to any competent law enforcement body, regulatory or government agency, court or other third party where we believe the disclosure is necessary or appropriate to comply with a regulatory requirement, judicial proceeding, court order, government request or legal process served on us, or to protect the safety, rights, or property of our customers, the public, NV Group or others, and to exercise, establish or defend NV’s legal rights.

NV Group may also disclose aggregate or de-identified data that is not personally identifiable to third parties for any purpose.

COOKIES AND OTHER TOOLS

NV Group and its Service Providers collect information about you by using cookies, tracking pixels, web beacons and other technologies (collectively, “Tools”). We use this information to better understand, customize and improve user experience with our websites, services and offerings as well as to manage our advertising. This information can make your use of our NV Group Services easier and more meaningful by allowing NV Group and our Service Providers to provide better service, customize sites based on consumer preferences, compile statistics, provide you with more relevant advertisements based on your interests, analyze trends and otherwise administer and improve our NV Group Services. If we have collected your personal information, we may associate this personal data with information gathered through the Tools.

Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies.

You can also control Flash cookies which we may use on certain NV Group websites and apps from time to time. Why? Because Flash cookies cannot be controlled through your browser settings. Choices you make are both browser and device-specific.

Here are some of the types of information collected when visiting NV Group Websites:

Log data: When you use NV Group websites and apps, our server’s automatically record information (“log data”), including information that your browser sends whenever you visit a website or app or your mobile app sends when you are using it. This log data may include your Internet Protocol address, the address of the webpages you visited that had NV Group features, browser type and settings, the date and time of your request, how you used websites and cookie data.

Cookie data: Depending on how you are accessing NV’s online Services, we and our Service Providers may use “cookies” (a small text file sent by your computer each time you visit our sites, unique to your NV Group account or your browser) or similar technologies, to record log data. When we use cookies, we may use “session” cookies (that last until you close your browser) or “persistent” cookies (that last until you and/or your browser delete them). For example, we may use cookies to remember your personal preferences, such as sections of the website that you visit frequently, your user ID, or other settings so you do not have to set them up every time you visit, and we may use cookies to serve you relevant advertising tailored to your interests. Some of the cookies we use are associated with your NV Group account (including personal information about you, such as the email address you gave us), and other cookies are not.

Social media plugins and data: In addition, our websites and apps may use social media plugins (e.g., the Facebook “Like” button, ‘”Share to Twitter”‘ button) to enable you to easily share information with others. When you visit any of our online NV Group Services, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our websites. If you are logged into the social media website (e.g., Facebook, Twitter, Instagram, LinkedIn) while browsing on our NV Group Services, the social plugins allow that social media website to receive information that you have visited our NV Group Services. The social plugins also allow the social media website to share information about your activities on NV Group with other users of their social media website. NV Group does not control any of the content from the social plugins. For more information about social plugins from other social media websites you should refer to those sites’ privacy and data sharing statements.

If you choose to link your social media account to NV, this allows us to obtain information from those accounts (such as your friends or contacts). The information we obtain from these services often depends on your settings or the applicable provider’s privacy policies, so please check these policies before granting us access. You agree that we are not responsible for any acts or omissions by these social media service providers. If you give us permission to access this information, we will use it for the purposes described in this Privacy Policy.

Device information:” In addition to log data, we may also collect information about the device you are using to access our NV Group Services, including what type of device it is, what operating system you are using, device settings, unique device identifiers and crash data. Whether we collect some or all of this information often depends on what type of device you are using and its settings. For example, different types of information are available depending on whether you are using a Mac or a PC, or an iPhone or an Android phone. To learn more about what information your device may make available to us, please also check the policies of your device manufacturer or software provider.

Interest Based Events & related advertising: NV Group hopes to deliver to you advertising for products and services you need or want. NV GROUP, its vendors and partners, use common tracking tools, such as cookies, pixels, and similar technologies, to automatically collect information about users for purposes of enhancing their online experience and delivering more meaningful advertisements. Like many companies, NV Group may also utilize third-party advertising vendors and other partners to collect this information.

Like most companies, we place advertisements where we think they will be most relevant to customers. One way we do so is by allowing network advertising companies with whom we work to place their own Tools when an individual visits NV Group websites and apps. This enables the network advertising company to recognize individuals who have previously visited NV Group websites and apps and to serve you ads based on your web browsing activity, purchases, interests and/or other information.

These advertising companies may also use these types of technologies to recognize you across the devices you use, such as a mobile phone or a laptop, and serve you ads on websites you visit and applications you use.

NV Group Do Not Track Policy. Some browsers have Do Not Track (“DNT”) features that allow you to tell a website not to track you. These features are not all uniform, and some browsers may not be set up to honor such requests. Please be aware that limiting the ability of websites to set cookies, however, may worsen your overall user experience, and in some cases the sites will not work properly without cookies, local storage and similar technologies.

WHAT CHOICES DO I HAVE ABOUT HOW NV GROUP COLLECTS AND USES INFORMATION ABOUT ME?

Certain NV Group Services may ask whether you wish to opt-out or opt into our contact lists for offers, promotions and additional services that may be of interest to you.

MARKETING AND OTHER COMMUNICATION You may receive notifications and emails from us on the contact address/es registered with us. If you no longer wish to receive such materials from us on a going-forward basis, you may opt-out of receiving such materials. You may unsubscribe by following the instructions included in the notification or email. We will endeavor to comply with your request as soon as reasonably practicable.

However, even if you opt out of receiving such communications, we retain the right to send you non-marketing communications (such as security alerts, administrative messages and information about changes to our Privacy Policy or Terms of Use).

YOUR PRIVACY CHOICES

You may have certain rights and choices regarding our processing of your personal data. Depending on your jurisdiction, applicable law may entitle you to additional consumer rights, including the right (with certain limitations and exceptions) to:

• Know the categories and/or specific pieces of personal information collected about you, including whether your personal information is sold or disclosed, and with whom your personal information was shared
• Access a copy of the personal information we retain about you
• Request deletion of your personal information

We reserve the right to verify your identity in connection with any requests regarding personal information to help ensure that we provide the information we maintain to the individuals to whom it pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information. If you are an authorized agent making a request on behalf of a consumer, we may require and request additional information to verify that you are authorized to make that request.

We reserve the right to deny your request if we cannot verify your identify. Where we deny your request in whole or in part, we will endeavor to inform you of the denial and provide an explanation of our actions and the reasons for the denial.

We will not restrict or deny you access to our NV Group Services because of choices and requests you make in connection with your personal information. Please note, certain choices may affect our ability to deliver the NV Group Services. For example, if you sign up to receive marketing communications by email, then ask NV Group to delete all of your information, we will be unable to send you marketing communications. You may exercise any of your rights in relation to your personal information by contacting us using the details provided under the “How can I contact “NV Group” section below.

HOW DOES NV GROUP SECURE INFORMATION?

It is NV’s practice to take steps to secure our NV Group Services; however, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the Internet, especially personal information related to your health & information of your family members. NV Group cannot guarantee that unauthorized third parties will not gain access to your information; therefore, when submitting personal information to NV Group websites or apps, you must weigh both the benefits and the risks. NV Group websites or apps may link to third-party websites that are not controlled by NV Group or subject to an NV Group privacy policy. You should check the privacy policies of such third-party websites before submitting personal information. This Website is Not for Children

NV Group does not knowingly collect or use any information from children (we define “children” as minors younger than 18). We do not knowingly allow children to order our products, communicate with us, or use any of our online services. If you are a parent and become aware that your child has provided us with information, please contact us using one of the methods specified below and we will work with you to address this issue. Third party sites

We may provide links to websites and other third-party content that is not owned or operated by NV GROUP. The websites and third-party content to which we link may have separate privacy notices or policies. NV Group is not responsible for the privacy practices of any entity that it does not own or control.

If you provide any personal through a third-party site, your interaction and your personal information will be collected by, and controlled by the privacy policy of, that third party site. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties, which are not governed by this privacy policy.

HOW CAN I CONTACT NV?

If you have questions about your information, please contact us by clicking on the “Contact Us” link on the website you are visiting or by e-mailing us at info@nvgroup.co.in Alternatively, you may send a letter to the following address:

NV Group 10th Floor, Vandana Building, 11, Tolstoy Rd, Atul Grove Road, Janpath, Connaught Place, New Delhi – 110001

In all communications to NV Group, please include the email address used for registration (if applicable), the website address or the specific NV Group program to which you provided personal information (e.g. Nvgroup.co.in, smokewear.in, etc.) and a detailed explanation of your request. We will do our best to respond to all reasonable requests in a timely manner.

HOW WILL I KNOW WHETHER NV GROUP HAS UPDATED THIS POLICY?

NV Group reserves the right to amend this Privacy Policy at any time. If NV Group changes its privacy practices, a new Privacy Policy will reflect those changes and the effective date of the revised Privacy Policy will be set forth in this paragraph. This Privacy Policy is effective from 1st Jan 2021.