Privacy Policy

Introduction

At Cultus Innovations Private Limited (“Cultus,” “we,” “our,” or “us”), we value your trust and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, share, and safeguard your information when you access or use our e-commerce website, mobile application, and related services (collectively, the “Platform”). By using the Platform, you consent to the practices described in this Privacy Policy. If you do not agree, please discontinue use of the Platform.

Information We Collect

Personal Information

We may collect personal details that you provide to us directly, including your name, gender, date of birth/age, contact details (such as address, phone number, and email), payment information (including encrypted credit/debit card details, UPI, and net banking), account login credentials (usernames, passwords, and security questions), as well as images voluntarily furnished, such as profile pictures.

Usage and Device Information

When you interact with our website, we may collect certain technical and usage-related data such as your IP address, device ID, MAC address, device model and manufacturer, operating system, browser type, usage statistics, time spent on the website, and the pages you view.

Transactional Information

We also collect information relating to your interactions with us, including order history, payment history, and any correspondence you have with our customer service team.

Cookies and Tracking

At present, our website does not use cookies or similar tracking technologies. While we do not use them currently, we may implement cookies or similar tools in the future to enhance your browsing experience and optimize our services. If we introduce cookies, we will update this Privacy Policy accordingly and provide you with clear notice, along with options to manage or decline non-essential cookies, in compliance with applicable data protection laws.

Purpose of Data Collection and Use

We use your personal data primarily to provide and improve the services you request on our platform. Your data allows us to process and deliver orders, facilitate secure payments, communicate updates, offers, or promotions, and enhance your experience by personalizing content and recommendations. We may also use your data for resolving disputes, troubleshooting issues, and offering customer support. To ensure safety and protect against fraud, error, or other malicious activities, your data helps us maintain the security of our services and comply with legal obligations, including reporting and audit requirements. If we use your personal data for marketing purposes, you will always have the ability to opt out of such communications. Occasionally, we may request permissions to access certain device features (such as messages, location, or contacts) to provide improved or additional services; you may decline these permissions, though this might limit your access to some features. We may also use your data to generate anonymized consumer insights, behavioral analytics, purchase trend reports, and category-level preference data that are shared with or licensed to brand partners, retailers, advertisers, and commercial collaborators on or outside the Platform. This helps brands understand demand patterns, improve product relevance, and design better offers for users. Where such use involves identifiable personal data, your explicit consent will be sought as described in Section 5A below. All data is handled according to applicable privacy regulations, with your rights and choices clearly respected at every stage.

Artificial Intelligence and Data Processing

We use Artificial Intelligence (AI) technologies and automated processing to enhance your experience on the Platform. This includes but is not limited to, providing personalized product recommendations based on your browsing activity, purchase history, and preferences, generating consumer insights and predictive analytics to improve product discovery and engagement, offering community engagement tools such as content or discussion recommendations, and supporting fraud detection, security monitoring, and overall service optimization.

Legal Basis and Consent

By visiting our Platform or by providing your information, you consent to the collection, use, storage, disclosure and otherwise processing of your information on the Platform in accordance with this Privacy Policy. If you disclose to us any personal data 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 Privacy Policy. You, while providing your personal data over the Platform or any partner platforms or establishments, consent to us (including our other corporate entities, affiliates, lending partners, technology partners, marketing channels, business partners and other third parties) to contact you through SMS, instant messaging apps, call and/or e-mail for the purposes specified in this Privacy Policy. You have an option to withdraw your consent that you have already provided by writing to the Grievance Officer at the contact information provided below. Please mention “Withdrawal of consent for processing personal data” in your subject line of your communication. We will verify such requests before acting on our request. Please note, however, that withdrawal of consent will not be retroactive and will be in accordance with the terms of this Privacy Policy, related terms of use and applicable laws. In the event you withdraw consent given to us under this Privacy Policy, we reserve the right to restrict or deny the provision of our services for which we consider such information to be necessary.

If we collect sensitive personal data (such as financial information, biometric identifiers, or health data), it will only be processed with your explicit consent and for purposes you have agreed to.

Commercial Data Partnerships and Consent

In addition to the uses described above, Cultus may use and share your data — in anonymized, aggregated, pseudonymized, or with your explicit separate consent, identifiable form — with brand partners, retailers, advertisers, and commercial collaborators whether or not they are listed or operating on the Platform (“Brand Partners“) for the following purposes:

  1. Providing Brand Partners with consumer insights, purchase trend analytics, category-level behavioral data, and audience segmentation reports to improve product offerings and marketing relevance;
  2. Enabling personalized or targeted advertising and promotional communications from Brand Partners whose products are available or featured on the Platform or elsewhere;
  3. Supporting co-branded campaigns, loyalty programs, sponsored content, or commercial partnerships between Cultus and Brand Partners, including Brand Partners outside the Cultus platform ecosystem;
  4. Licensing aggregated or anonymized datasets to retail analytics firms, market research companies, brands, and retailers for commercial research and audience targeting purposes.

Where such sharing involves identifiable personal data (such as your name, contact details, demographic profile, or purchase history linked to your profile), we will seek your explicit, separate, and freely given consent before doing so. You may provide or withdraw this consent at any time through your account settings under “Data & Privacy Preferences“ or by writing to our Grievance Officer. Where data is shared in anonymized or aggregated form such that no individual can be identified, such sharing does not require separate consent under applicable law, including the Digital Personal Data Protection Act, 2023. All Brand Partners receiving data under this section are contractually bound to use it only for the stated purposes, to maintain appropriate security standards, and to comply with all applicable data protection laws including the Digital Personal Data Protection Act, 2023.

Sharing and Disclosure of Data

We share your information to the extent necessary for providing our services, fulfilling commercial partnerships, complying with legal obligations, or safeguarding our rights. Your data may be shared in the following circumstances:

  1. With secure payment gateways and processors (in compliance with PCI-DSS standards) for processing transactions;
  2. With logistics and delivery partners to facilitate dispatches, returns, and order tracking;
  3. With our affiliates and trusted service providers who support us with technology, analytics, customer care, and backend operations;
  4. With government authorities, regulators, or law enforcement agencies when required under applicable laws or valid legal processes;
  5. In the event of a merger, acquisition, restructuring, or sale of business assets, your data may be transferred in accordance with law and subject to appropriate safeguards;
  6. With third-party analytics and AI service providers to process data on our behalf for improving recommendations, fraud detection, or customer insights. These service providers are contractually bound to handle your data securely and only for authorized purposes.

All third parties handling your data are bound by contractual and legal obligations to ensure that your information is processed securely and only for authorized purposes.

Sharing with Brand Partners and Retailers Outside Cultus

In addition to the sharing described in Section 6 above, Cultus may share, license, or transfer consumer data — including anonymized, aggregated, pseudonymized, or with your explicit consent, identifiable data — to brand partners, retailers, advertisers, and market research entities that may operate independently of or outside the Cultus platform (“External Brand Partners“). Such sharing may include:

  1. Aggregated purchase behavior, category preferences, and brand affinity data shared with FMCG companies, fashion brands, electronics retailers, beauty brands, and other consumer goods companies;
  2. Audience segment reports (e.g., “users aged 25-35 in Tier 1 cities who purchased sportswear in the last 90 days“) shared with advertising platforms or retail brands for targeting purposes — in anonymized form only unless you have provided explicit consent for identifiable sharing;
  3. Anonymized transaction-level datasets licensed to market research firms, retail analytics companies, or consumer intelligence platforms;
  4. Identifiable contact data (name, email, phone) shared with External Brand Partners for direct marketing only where you have explicitly opted in to receiving communications from such partners.

You may opt out of your data being shared with External Brand Partners at any time by visiting “Data & Privacy Preferences“ in your account settings or by contacting our Grievance Officer. Opting out will not affect your ability to use core Platform services

Data Retention and Deletion

We retain your personal data only for as long as necessary to provide our services or comply with legal obligations. You may delete your account anytime through Profile & Settings or by contacting us. Deleting your account will remove access to your order history, preferences, returns/refunds, coupons, and loyalty benefits, and you will need to register again to use Cultus. We may delay or refuse deletion if there are pending orders, grievances, or legal obligations. Accounts inactive for over two years may be deleted, unless data must be retained for fraud prevention, legal claims, or other legitimate purposes. In line with the Digital Personal Data Protection Act, 2023, Cultus does not retain personal data longer than required. Data no longer needed is securely erased or anonymized for analytics and research.

Choice / Opt-Out

We provide all users with the opportunity to opt-out of receiving non-essential (promotional, marketing-related) communications from us after setting up an account. If you do not wish to receive promotional communications from us, then please unsubscribe by clicking on the unsubscribe link in the email. 

Security Measures

We take the security of your personal data seriously and use reasonable safeguards such as encryption, secure servers, limited access, and regular monitoring to protect it against unauthorized access or misuse. These measures include encryption, firewalls, secure servers, role-based access controls, and periodic security audits in compliance with the Information Technology Act, 2000, the applicable SPDI Rules, and the Digital Personal Data Protection Act, 2023. Our AI systems are designed to improve user experience and are subject to periodic human oversight to ensure fairness, accuracy, and non-discrimination. We do not use AI for exploitative or harmful profiling.

User Rights

You have the right to:

  • Access your personal data held by Cultus
  • Request corrections or updates to your personal data
  • Request erasure of your personal data, subject to legal limitations
  • Withdraw consent for marketing communications at any time
  • Opt out of commercial data sharing with Brand Partners and External Brand Partners under Sections 5A and 6A
  • Request a summary of what data about you has been shared with third-party Brand Partners
  • File complaints with our Grievance Officer or with the appropriate data protection authority under applicable law

To exercise any of the above rights, please contact our Grievance Officer at the details provided in Section 14.

Data of Children

Use is restricted to adults who can form contracts under the Indian Contract Act, 1872. Minors must transact via a parent/guardian’s account.

Grievance Redressal

A designated Grievance Officer is available per Indian regulations. Contact details are published on our website, along with resolution timelines and escalation protocol.

Policy Updates

This Policy may be updated periodically. Updates will be communicated and published prominently; continued use after notification constitutes consent to revised terms.

Contact Information

Grievance Officer:

  • Email: clothingcultus@gmail.com
  • Address: SNo.169,170/5 Tushar Res., Pimple Saudagar RhNo.04, Pimpri Waghire, Pune City, Pune - 411017, Maharashtra

Queries

If you have a query, concern, or complaint in relation to collection or usage of your personal data under this Privacy Policy, please contact us at the contact information provided above.