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PRIVACY POLICY
I. INTRODUCTION
Ethos Lifestyle Private Limited (hereinafter "ETHOS") recognizes the importance of privacy of its users and of maintaining confidentiality of the information provided by its users, as a responsible data controller and/or data processor, as the case may be. This Privacy Policy sets out ETHOS’s practices for collection, handling, using, storing, sharing and securing a user’s Personal Information (defined below) in connection with purchases made through the RIMOWA e-commerce point of sale at rimowa.com/in (the "Website"), on which ETHOS acts as the Seller of Record for sales of RIMOWA products in India, and in connection with ETHOS’s offline channels for sale of RIMOWA products in India including stores, call centres and offices (collectively, "Sales Channels").
This Policy applies after you click checkout on the Website ("Checkout Initiation") and provide your Personal Information to ETHOS for order placement, payment, delivery, returns, refunds, warranty, and after-sales interactions. RIMOWA operates the Website and is responsible for your experience up to Checkout Initiation. Your activity on the Website prior to Checkout Initiation (i.e. browsing, product discovery, account creation, wishlist, and cart activity) is governed by RIMOWA’s own privacy policy, available on the Website separately.
For the purpose of this Privacy Policy, "you" or "your" means the User, and "we", "us", "our" means ETHOS. By clicking checkout on the Website you agree to the terms and conditions of this Privacy Policy. If you disagree with this Privacy Policy, please do not proceed with your purchase. This Privacy Policy does not apply to any website, mobile site, or mobile app of a third party, including RIMOWA’s own site, even where linked to or from the Website. You are requested to review RIMOWA’s privacy policy separately on how RIMOWA handles your Personal Information prior to Checkout Initiation.
This Privacy Policy describes only how we as Seller of Record, handle your Personal Information after Checkout Initiation. It does not intend to nor governs the RIMOWA’S data practices prior to Checkout Initiation, which are addressed in the RIMOWA’S own privacy policy.
II. APPLICABLE LAW
Personal Information collected by us under this Policy is processed in accordance with applicable Indian law including the Digital Personal Data Protection Act, 2023 ("DPDPA") and the Digital Personal Data Protection Rules, 2025, the Information Technology Act, 2000 read with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, the Consumer Protection Act, 2019 and the Consumer Protection (E-Commerce) Rules, 2020, as amended by the Consumer Protection (E-Commerce) (Amendment) Rules, 2026 (effective 1 January 2027).
III. ETHOS ENTITY AND GRIEVANCE OFFICER/CONSENT MANAGER
- Ethos Lifestyle Private Limited:[registered address] — CIN: [insert]
- Grievance Officer/Consent Manager:[name, email, phone — to be inserted]
Response Timeline and Procedure
- Response timeline:We will acknowledge your grievance within Forty-eight (48) hours and resolve it within thirty (30) days, or such other period as prescribed by applicable law.
- Copy of your complaint:On request, we will provide you a copy of your complaint as recorded by our Grievance Officer.
IV. DATA PROCESSING
Data shared with us is primarily processed in India. However, we may transfer, store, or process your Personal Information outside India, including with service providers such as our cloud hosting, payment gateway, or customer support partners located in other jurisdictions or to RIMOWA Middle East ("RME") acting as a data processor. Such transfers are permitted under Section 16 of the Digital Personal Data Protection Act, 2023, except where the Central Government has notified restrictions on transfers to specific countries or territories, in which case we will comply with such restrictions. Where required, we implement appropriate contractual and organisational safeguards with the recipient to protect your Personal Information to a standard consistent with this Policy.
If you have concerns about such cross border processing of your Personal Information and wish to withdraw your consent, you may write to sushil.aggarwal@ethoswatches.com. However, if such processing is essential to fulfil your order, withdrawal of consent may mean we are unable to complete or service your order. You agree that ETHOS shall not be liable for not being able to complete or service your order due to the withdrawal of your consent as above.
V. TYPE OF INFORMATION WE COLLECT
"Personal Information" of a User includes information shared by the User with us on and after Checkout Initiation and collected by us for the following purposes:
- Order and account information:name, email address, phone number, billing and shipping address, and order details (items, quantities, prices, order number).
- Payment information:Payment confirmation status and transaction reference (we do not receive or store your full card/UPI/bank credentials) — payment is directly processed through PayU under a merchant account held in ETHOS’s own name. ETHOS does not permit RME or the RIMOWA Group to collect, hold, or process any cardholder data or payment credentials — payment flows are directed exclusively to ETHOS’s merchant account.
- KYC and identity information:for orders of ₹2,00,000 or more, Applicable Law requires identity verification before payment can be completed. You will be asked to complete a KYC form hosted by ETHOS, confirming your PAN and identity, before your order can proceed to payment. Your order cannot be completed until this verification is successful.
- GST/Invoicing detailswhere necessary.
- Delivery, returns, and after-sales information:information relating to delivery, returns, refunds, exchanges, warranty claims, and repair requests, including any images or documents you provide in connection with such a request.
- Other information you provide directly:such as information shared when you contact our client service team, or when you place an order on behalf of another customer through your ETHOS account (in which case you confirm that such customer has agreed to their information being shared by you and used by us as described in this Policy) or information from payment gateways confirming successful payment or information from logistics/delivery partners regarding shipment status/tracking data or any information provided to us by RIMOWA strictly to enable order fulfillment.
- Feedback or complaints:Any feedback or complaint you submit about your order.
We may use your post-purchase data for our own marketing communications, on the basis described in Section [*]; this is separate from, and does not affect, any marketing consent you have given to RIMOWA, which remains governed by RIMOWA’S own privacy policy.
VI. HOW WE USE YOUR PERSONAL INFORMATION AND LEGAL BASIS
We process your Personal Information, as Seller of Record, on the basis of information voluntarily provided by you for the specified purpose of completing a purchase in case of an abandoned checkout and/or on the basis of the contract of sale formed when you complete your purchase for legitimate use such as fulfilling your order and our compliance obligations under Indian law.
We use your Personal Information to:
- confirm and process your order and issue sales and tax invoices;
- process/verify your payment through PayU;
- complete KYC verification where your order value requires it;
- keep you informed of order and delivery status, including via SMS, WhatsApp, or other messaging services;
- arrange delivery of your order, and manage returns, refunds, and exchanges;
- provide client service, warranty administration, and after-sales/repair support, including referring your case to RIMOWA’s regional technical support team where our own repair personnel are unable to resolve it;
- validate and authenticate your account and prevent misuse or fraud;
- comply with our obligations as Seller of Record under Indian law;
- send you order-related communications and, where you have separately opted in, promotional offers relating to your purchase history with us.
We do not use abandoned-checkout data to send you marketing or cart-recovery communications unless you have separately opted in to marketing. Where you have opted in to marketing, we may send you a reminder about your incomplete order. Abandoned-checkout data is retained only for the period described in Section VII.
Separately from the above, where you give us your specific, opt-in consent, we may use your post-purchase data — such as your order history — to send you our own marketing communications, including product recommendations, offers, and promotions relating to your purchase. This consent is collected independently of, and is never bundled with, your order/checkout process, and you may withdraw it at any time as easily as you gave it — for example, by using the unsubscribe link in any marketing communication or updating your preferences at [link/contact]. Declining or withdrawing marketing consent does not affect your ability to complete purchases or receive transactional communications. This marketing consent is separate from, and does not affect, any marketing consent you have given RIMOWA, which RIMOWA manages under its own privacy policy.
VII. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
- We retain your Personal Information for as long as reasonably necessary to fulfil your order, handle any returns, refunds, warranty, or after-sales matter, and meet our legal, tax, and accounting retention obligations, after which it is securely deleted or anonymised.
- Abandoned checkout:Where you initiate Checkout Initiation but do not complete your order, we retain the personal data collected up to that point for thirty (30) days from the date of abandonment, after which it is deleted, unless a longer period is necessary for fraud-prevention purposes or otherwise required by law.
X. HOW WE PROTECT YOUR PERSONAL INFORMATION
Payment and checkout data is transmitted using TLS encryption. We maintain appropriate technical and organisational measures to protect your Personal Information against unauthorised access, loss, or alteration. If we become aware of a security incident affecting your Personal Information, we will notify the Data Protection Board of India and affected individuals as required under the applicable Indian law.
XI. WITHDRAWAL OF CONSENT AND PERMISSION
You may withdraw your consent to provide Personal Information at any time by writing to [legal contact email — to be inserted]. Doing so may limit our ability to complete or service your order.
XII. YOUR RIGHTS OVER PERSONAL INFORMATION
You may request access to, correction of, or erasure of your Personal Information (subject to statutory retention requirements) or nominate another individual (to exercise these rights on your behalf in the event of your death or incapacity) by contacting our Grievance Officer at the details above. Where a request requires information held on RME’s systems, we will coordinate with RME to respond to you.
We will respond within sixty (60) days from the date of receipt of your request.
XIII. ELIGIBILITY TO TRANSACT WITH ETHOS
You must be at least 18 years of age to transact with ETHOS and to consent to the processing of your Personal data. We do not knowingly collect personal data of children without verifiable parental consent. If we become aware that we have collected a child's data without such consent, we will delete it promptly.
XIV. CLIENT SERVICE
Our dedicated client service contact for the Website is available Monday–Saturday, 10:00–18:30 IST (concierge service until 19:00 IST); closed Sundays.
XV. GOVERNING LAW AND JURISDICTION
This Policy is governed by the laws of India. Any disputes arising out of or in connection with this Policy shall be subject to the exclusive jurisdiction of the courts at Chandigarh.
XVI. CHANGES TO THE PRIVACY POLICY
We may revise this Privacy Policy from time to time to reflect legal, business, or customer requirements, and will notify you of material changes on the Website. You may submit questions or concerns regarding this Privacy Policy to sushil.aggarwal@ethoswatches.com.