Privacy policy
Effective Date: July 2026
Website: eslaitaly.in
Operating Company / Data Fiduciary: S K Haria Consumer Care Private Limited
1. OBJECTIVE, SCOPE AND APPLICABILITY
S K Haria Consumer Care Private Limited (operating ESLA Italy India, referred to as "Company," "we," "our," or "us") highly
values your privacy and is dedicated to safeguarding it. This Privacy Policy ("Policy") outlines how we collect, use, disclose,
store, transfer, and dispose of Personal Information on our controlled platforms, including eslaitaly.in and any associated mobile
or web applications (collectively referred to as the "Platform"), in the context of individuals who interact with our Platform, provide
information, or whose information we collect, receive, or process in connection with the sale of our haircare, scalp treatment, and
cosmetic products ("Products").
This Policy applies to all visitors, registered users, salon partners, and customers within India. It does not cover Personal
Information collected offline (unless otherwise specified), on Company platforms not linking directly to this Policy, or on third-
party websites linked to or from our Platform.
By accessing, browsing, or using our Platform and providing information as described in this Policy, you consent to the
collection, processing, and use of the information you disclose on the Platform in accordance with this Policy. If you do not agree
with any terms outlined herein, please discontinue using the Platform.
2. TELECOM & COMMERCIAL COMMUNICATIONS CONSENT (TRAI REGULATIONS)
You agree and consent to receive all transactional, service-related, and promotional communications on the mobile number you
provide to the Company, even if this number is registered under the National Do Not Call (NDNC) Registry, pursuant to
the Telecom Commercial Communications Customer Preference Regulations, 2018 ("TRAI Regulations").
You explicitly express your interest and accord informed consent to receive communications (including phone calls, SMS,
WhatsApp messages, and automated notifications) related to the Company’s products, orders, shipping updates, and offers. You
confirm that no communication sent by or on behalf of the Company shall be deemed an Unsolicited Commercial
Communication under Regulation 2(bw) of the TRAI Regulations. You may modify your communication preferences at any time
as outlined in Section 11 of this Policy.
3. WHAT PERSONAL INFORMATION DO WE COLLECT?
"Personal Information" refers to information that directly or indirectly, either on its own or when combined with other available
information in the Company's possession, is capable of identifying an individual. We limit the collection of Personal Information
to what is necessary to fulfill orders, deliver accurate services, process refunds, and continually improve our product offerings:
• Contact & Demographic Identifiers: Full name, email address, postal/shipping address, billing address, telephone/mobile
number, state, city, pincode, country, date of birth, and language preferences.
• Transactional & Order Data: Details of products ordered, invoices, GST numbers, order history, shipping tracking, return
logs, and customer service records.
• Recipient Details: Names, delivery addresses, and contact numbers of individuals to whom product shipments or
promotional packages are sent.
• Financial Data: Bank account details, credit card, debit card, or UPI transaction identifiers used to complete purchases on
our Platform. (Note: All payment transactions are processed through PCI-DSS compliant third-party payment gateways. The
Company does not store full credit/debit card numbers or CVVs on its servers).
• Hair & Scalp Profiles: Hair type, scalp concerns, opinions, product preferences, shade choices, and feedback shared
through surveys or hair analysis tools.
• Technical & System Data: IP address, browser type, device operating system, software version, unique device identifiers,
referral URLs, access timestamps, and location data.
• Publicly Open Data: Unrestricted feedback, reviews, or social media posts publicly available on open internet forums.
4. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
We collect and receive Personal Information through various channels: * Voluntary Submission on Our Platform: Information
provided directly by you during account creation, product checkout, newsletter sign-ups, customer service inquiries, contact
forms, live chat interactions, contest entries, or hair profile questionnaires. * Automatic Passive Collection: When you interact
with our Platform, technical information is automatically recorded via log files, cookies, web beacons, and pixel tags. These tools
analyze usage patterns, monitor site health, customize user experiences, and prevent cyber threats. * Third-Party Sources &
Social Media: We may receive updated address and delivery details from courier partners to correct our records and complete
shipments. Additionally, if you choose to interact with us via third-party social media platforms (such as Facebook or Instagram)
or log in via third-party tools, we may collect information authorized by those platforms.
5. PURPOSE AND LEGAL BASES FOR PROCESSING DATA
We process your Personal Information under the following recognized legal bases and operational purposes:
Legal Bases for Processing
1. Performance of a Contract: Processing required to fulfill our contractual obligations to you—such as processing payments,
delivering ordered products, and providing post-purchase support.
2. Legitimate Business Interests: Processing that serves our legitimate operational interests—such as improving product
formulations, securing our network, preventing fraud, and conducting customer satisfaction surveys.
3. Compliance with Legal Obligations: Processing necessary to comply with applicable statutory laws in India, tax audit
rules, e-commerce regulations, and lawful government orders.
4. Specific Consent: In instances where consent is explicitly required, processing occurs only after your affirmative opt-in. You
retain the right to withdraw consent at any time.
Operational Purposes
• Verifying identity and managing user accounts.
• Dispatching orders, managing logistics, and issuing tax invoices.
• Communicating order statuses, shipping updates, and service announcements.
• Responding to reviews, complaints, and customer service inquiries.
• Administering contests, promotional schemes, and brand loyalty rewards.
• Requesting product ratings and post-treatment hair care reviews.
• Measuring marketing campaign performance and conducting internal research on demographics.
• Preventing, detecting, and prosecuting cyber fraud, illegal acts, or breach of Platform terms.
6. COOKIES, ANALYTICS & THIRD-PARTY ADVERTISING
Our Platform uses cookies and tracking technologies to optimize performance and deliver tailored content: * Session Cookies:
Temporary cookies stored during an active browsing session to manage shopping cart contents. They expire upon closing your
browser. * Persistent Cookies: Stored on your device for up to 7 days (or until deleted) to recognize returning visitors and recall
user preferences. * Google Analytics (with IP Anonymization): We use Google Analytics to evaluate site performance. We
utilize the anonymizeIp protocol to mask user IP addresses before storage. You may opt out using the Google Analytics Opt-
Out Browser Add-On. * Google DoubleClick & GA Audiences: Serves interest-based ads across the Google Network based on past visits. Preferences can be managed via Google Ad Settings. * Meta Pixel (Facebook/Instagram Custom Audiences):
Analyzes user interactions to display relevant advertisements on Meta platforms. Data processing is governed by Meta’s privacy
policies.
7. EMPLOYMENT OPPORTUNITIES & RESUME SUBMISSIONS
If you submit your resume or employment applications through our Platform or email for career opportunities at S K Haria
Consumer Care Private Limited, the information provided will be treated as strictly confidential. We may retain your submission
on file for future hiring evaluations or contact you for additional details.
8. DATA STORAGE, RETENTION & DISPOSAL
• Secure Storage: Personal Information is stored on secure, encrypted on-site servers and certified cloud infrastructure
hosted within India. Cloud service providers are contractually bound to maintain security controls at least as protective as
ours.
• Retention Period: We retain Personal Information only for as long as necessary to fulfill the purposes for which it was
collected, or as required by applicable tax, statutory, accounting, or reporting laws in India.
• Safe Disposal: Upon expiry of the mandatory retention period or upon valid request for erasure, Personal Information is
securely overwritten, anonymized, or purged using industry-standard destruction protocols.
9. SECURITY SAFEGUARDS
We maintain multi-layered administrative, physical, and technical controls to protect Personal Information against loss,
unauthorized access, disclosure, or destruction: * Physical Measures: Secure facilities, locked record storage, and restricted
physical access controls. * Technical Safeguards: SSL 256-bit data encryption during transmission, firewall infrastructure, PCI-
DSS payment gateway integration, and periodic malware scanning. * Organizational Controls: Confidentiality agreements
(NDAs) signed by staff, strict need-to-know access controls, security training, and regular audits.
10. CUSTOMER COMMENTS & PUBLIC CONTENT
Any ratings, reviews, or comments you post publicly on our Platform can be read, collected, or used by third parties. To request
the removal of content you posted on a public review section, please contact care@skhariagroup.com. While we will attempt
to remove the content from active view, historical copies or web caches may temporarily remain.
11. YOUR RIGHTS & OPTING OUT
Under the Digital Personal Data Protection Act, 2023, you hold the following rights regarding your Personal Information: *
Access & Review: You can log into your account to review, edit, or update your personal details. * Marketing Unsubscribe:
You can opt out of promotional emails by clicking the "Unsubscribe" link at the bottom of any email or by adjusting your
preference settings. * Withdrawal of Consent: You may withdraw your consent for future data processing at any time by writing
to care@skhariagroup.com. Please note that withdrawal does not affect the lawfulness of processing carried out prior to
withdrawal, nor does it affect processing required under legal obligations.
12. SPECIAL NOTE FOR MINORS (< 18 YEARS)
Our Platform is intended for a general audience and is not directed at minors under 18 years of age. We do not knowingly collect
data directly from children. Minors may use our Platform or purchase Products only under the active supervision of a parent or
legal guardian.
13. GOVERNING LAW & JURISDICTION
This Policy shall be governed by and construed in accordance with the laws of the Republic of India. Any legal proceedings
arising out of or related to this Policy shall be subject to the exclusive jurisdiction of the competent courts in Mumbai,
Maharashtra, India.
14. POLICY REVIEW & UPDATES
We periodically review and update this Policy to reflect changing legal, operational, or technical requirements. Updates become
effective immediately upon posting on the Platform. Continued use of the Platform after changes are posted constitutes
acceptance of the modified terms.
15. GRIEVANCE REDRESSAL OFFICER
In compliance with the Information Technology Act, 2000, the Digital Personal Data Protection Act, 2023, and the
Consumer Protection (E-Commerce) Rules, 2020, the contact details for our designated Grievance Officer are:
• Operating Company: S K Haria Consumer Care Private Limited
• Grievance Officer: Aashi Haria
• Designation: Chief Marketing Officer (CMO)
• Email: care@skhariagroup.com
• Phone / WhatsApp: +91 7738190744
• Support Hours: 10:00 - 19:00 IST, Monday to Saturday
• Postal / Corporate Address: S K Haria Consumer Care Private Limited, Mumbai, Maharashtra, India.
We acknowledge customer grievances within 48 hours and endeavor to resolve them within 15 business days.