This Privacy Policy (“Policy”) was last updated on June 01, 2026 (“Effective Date”).
Sentiments Creative Labs LLP (“Sentiments”, “we”, “our”, or “us”) is committed to respecting the privacy and safeguarding the personal data of its customers, website visitors, and all other stakeholders who interact with www.sentimentsindia.com (“the Site”). As a direct-to-consumer footwear brand, we recognise the importance of transparency, consent, and data protection in building lasting customer trust.
This Policy is formulated in compliance with the Digital Personal Data Protection Act, 2023 (“DPDP Act”), the Information Technology Act, 2000, and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
WHEREAS
A. Sentiments operates a direct-to-consumer footwear business under the SENTIMENTS brand and is committed to protecting the personal data and privacy rights of its customers and website visitors.
B. The DPDP Act and applicable Information Technology law require data fiduciaries such as Sentiments to establish clear privacy practices, implement reasonable security safeguards, and provide mechanisms for informed consent and grievance redressal.
C. Sentiments aims to foster customer trust and legal compliance by adopting this Policy, so that every individual who browses, purchases from, or otherwise interacts with the Site is informed of their rights, our obligations, and the mechanisms available to them for grievance redressal.
NOW THEREFORE,
Sentiments hereby adopts this Privacy Policy to provide a clear, lawful, and user-friendly framework for the collection, processing, storage, and protection of personal data, and to reinforce its commitment to privacy and responsible data stewardship.
1. DEFINITIONS AND INTERPRETATION
1.1 Definitions
In this Policy, unless the context otherwise requires, the following words and expressions shall bear the meanings assigned to them below.
a) “Data Principal” shall mean the individual to whom personal data relates, including any customer, website visitor, or other individual whose personal data is processed by us.
b) “Data Fiduciary” shall mean Sentiments Creative Labs LLP, which determines the purpose and means of processing personal data in its capacity as a data fiduciary under the DPDP Act.
c) “Personal Data” shall mean any data about an individual who is identifiable by or in relation to such data, whether directly or indirectly.
d) “Sensitive Personal Data” shall mean personal data relating to passwords and financial information, to the extent such data is collected by us.
e) “Processing” shall mean any operation performed on personal data, including collection, storage, use, disclosure, or erasure.
f) “Consent” shall mean a freely given, specific, informed, and unambiguous indication of the Data Principal’s agreement to processing, given through a clear affirmative action.
g) “Grievance Officer” shall mean the individual appointed by us to address privacy-related grievances in accordance with this Policy.
h) “Third Parties” shall mean external service providers, including hosting, payment, logistics, and analytics providers, with whom personal data may be shared for business purposes.
i) “Data Breach” shall mean any unauthorised or accidental disclosure, alteration, loss, access, or destruction of personal data that compromises its confidentiality, integrity, or availability.
j) “Site” shall mean www.sentimentsindia.com, including any associated mobile-optimised interfaces.
1.2 Interpretation
a) Section headings are for convenience only and do not affect the construction of this Policy.
b) Words denoting the singular include the plural and vice versa, and words denoting any gender include all genders, unless the context otherwise requires.
c) References to this Policy include any amendments published on our website from time to time.
2. PURPOSE AND SCOPE
a) This Policy applies to all personal data collected, processed, stored, or disclosed by Sentiments through the Site, and governs our privacy practices in relation to anyone who browses the Site, places an Order, creates an account, or otherwise contacts us.
b) This Policy applies regardless of the device used to access the Site, including desktops, mobiles, and tablets.
c) This Policy does not apply to anonymised or aggregated information that does not identify an individual, or to third-party websites linked from the Site, which are governed by their own privacy policies.
d) By accessing the Site, creating an account, or submitting information to us, you acknowledge and consent to the terms of this Policy.
3. CATEGORIES OF PERSONAL DATA COLLECTED
We may collect the following categories of personal data, either directly from you or automatically as you use the Site:
a) Identity and Contact Information: name, title, gender, date of birth, email address, phone number, and billing or shipping address.
b) Device Information: IP address, browser type, device ID, operating system, time zone, referral source, and general site usage data, collected automatically.
c) Order and Payment Data: purchase history and invoices. Our payment gateway processes and stores payment details (card, UPI, or wallet); we do not store full card details in our systems and receive only transaction references and status.
d) Profile Data: login credentials, screen name, saved addresses, and stated preferences, where you create an account.
e) Location Data: GPS or approximate location, where required to facilitate delivery.
f) Customer Support Data: chat logs, complaint details, and other communications with our support team.
g) User Content: reviews, feedback, survey responses, or comments you voluntarily submit.
h) Media: a profile photo or images you choose to share with us, where applicable.
You may browse the Site anonymously without creating an account. Personal data is collected only when you log in, place an Order, or contact us.
4. PURPOSE OF DATA COLLECTION AND USE
We collect and process personal data only for specified, lawful purposes, including to:
a) process and fulfil Orders, including shipping, delivery, returns, and refunds;
b) process secure payments through third-party gateways;
c) provide customer service and respond to inquiries;
d) verify identity, detect fraud, and enhance security;
e) maintain and improve the Site, our products, and services;
f) send order confirmations and other transactional messages;
g) send promotional offers, newsletters, and marketing communications, where you have opted in;
h) personalise your experience on the Site and show relevant advertising, onsite and offsite;
i) conduct research, polls, and surveys to improve our offerings; and
j) comply with applicable laws and regulations.
We do not use personal data for any purpose other than those stated above without providing appropriate notice and, where applicable, obtaining your specific consent.
5. LEGAL BASIS FOR PROCESSING
We process personal data only where a lawful basis exists under the DPDP Act, including one or more of the following:
a) Consent: where we rely on your consent, for example for marketing communications or optional profile details, we obtain it through a clear affirmative action. You may withdraw such consent at any time as described in Clause 6 below.
b) Performance of a contract: where processing is necessary to fulfil an Order, arrange delivery and payment, or provide support in connection with your purchase.
c) Compliance with a legal obligation: where we are required to process data under applicable law, such as taxation, invoicing, or a lawful request from a government or law enforcement authority.
d) Legitimate use: in limited circumstances recognised under the DPDP Act, such as where you have voluntarily provided data for a specified purpose (for example, contacting customer support), or where processing is necessary to establish, exercise, or defend a legal claim.
Where our reliance on a legal basis changes, we will notify you and, where required, obtain fresh consent before continuing to process your data.
6. CONSENT MANAGEMENT
a) We obtain your free, specific, informed, and unambiguous consent before collecting or processing personal data for a purpose that is not otherwise covered by Clause 5(b) or 5(c) above.
b) Consent is sought at the point of collection, such as during account registration, checkout, subscription to marketing communications, or acceptance of cookies. We do not use pre-ticked boxes or bundled consent; consent must be given through a clear affirmative action.
c) You may withdraw consent at any time by using the unsubscribe link in our emails, updating your preferences in your account, or contacting our Grievance Officer, without affecting your ability to use essential features of the Site such as placing an Order. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
d) We maintain a record of consent obtained, including when and for what purpose it was given, which may be made available to the Data Protection Board of India or another competent authority upon a lawful request.
7. CHILDREN’S DATA
a) The Site is intended for use by individuals who are 18 years of age or older. We do not knowingly collect personal data from anyone below the age of 18 without verifiable consent of a parent or lawful guardian, in accordance with Section 9 of the DPDP Act.
b) We do not engage in behavioural tracking, profiling, or targeted advertising directed at children, whether directly or indirectly.
c) If we become aware that personal data of a child has been collected without verifiable parental or guardian consent, we will promptly delete such data and, where identifiable, notify the parent or guardian of the deletion.
8. COOKIES, TRACKING AND ADVERTISING
a) We use cookies, clear GIFs, pixel tags, and similar technologies to keep you logged in, save your cart, and process checkout; track browsing behaviour, ad clicks, and email response rates; improve analytics and measure campaign performance; and show personalised advertising across Google, Meta (Facebook and Instagram), and other networks.
b) You may disable cookies in your browser settings at any time. Certain features of the Site, such as cart persistence, may not function fully without them.
c) Cookies used purely for marketing and advertising purposes are non-essential; where feasible, we aim to limit such tracking to instances where you have not opted out, and we will introduce a more granular cookie-consent mechanism as our systems evolve.
9. DATA SHARING AND THIRD-PARTY TRANSFERS
a) We do not sell or rent your personal data to any third party for commercial gain.
b) We may share personal data with the following categories of third parties, strictly for the purposes described in this Policy: hosting and website providers (WordPress, WooCommerce, and our server host); payment gateways (Razorpay, Stripe, PayU, and UPI providers); logistics and courier partners, for shipping and returns; analytics and marketing partners (Google Analytics, Meta Ads, Mailchimp, and the WhatsApp Business API); and legal or regulatory authorities, where required by law.
c) These third parties are permitted to process personal data only for the specified purpose for which it was shared, and are contractually or otherwise required to maintain its confidentiality and security.
d) Cross-border transfer: some of the third parties listed above may process personal data on servers located outside India. Any such transfer is carried out in accordance with Section 16 of the DPDP Act and applicable government notifications on cross-border data transfer.
e) In the event of a merger, acquisition, or business transfer, your personal data may be shared with the new entity, which will continue to be bound by the terms of this Policy unless you are notified of a material change.
10. DATA RETENTION AND STORAGE
a) We retain personal data only for as long as reasonably necessary to fulfil the purpose for which it was collected, comply with a legal obligation, resolve a dispute, or enforce our agreements. In particular:
b) identity and contact data is generally retained for as long as your account remains active, and for a reasonable period after your last transaction to enable customer support and dispute resolution;
c) order and transaction data, including invoices, is retained for the period required under applicable tax and accounting law;
d) payment data is retained by our payment gateway in accordance with RBI guidelines applicable to payment aggregators; we do not separately retain full payment details;
e) customer support and complaint records are retained for a reasonable period after the matter is resolved, to support quality assurance and dispute resolution;
f) marketing preference data is retained until you withdraw consent or your account becomes inactive for an extended period;
g) account credentials are retained until you delete your account or request its closure.
h) Closed accounts may retain certain data for fraud prevention, dispute resolution, and legal compliance, even after account closure.
i) Upon expiry of the applicable retention period, personal data is either securely deleted or anonymised such that it can no longer be linked to you.
j) Personal data is stored on secure servers, with periodic backups maintained to ensure recoverability in the event of a system failure.
11. REASONABLE SECURITY PRACTICES
a) In line with Rule 8 of the IT (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and Section 8(5) of the DPDP Act, we implement technical and organisational safeguards to protect personal data against accidental loss, unauthorised access, misuse, or disclosure.
b) These safeguards include SSL/TLS encryption of data in transit, firewalls, secure servers, access controls limiting internal access to personal data on a need-to-know basis, and reliance on PCI-DSS-compliant payment gateways for payment processing.
c) We may request proof of identity before disclosing personal data or acting on a request relating to your account.
d) You are responsible for maintaining the confidentiality of your account credentials and password, and for notifying us promptly of any suspected unauthorised use of your account.
12. NOTIFICATION OF PERSONAL DATA BREACH
a) A personal data breach means any unauthorised or accidental disclosure, alteration, loss, destruction, or access to personal data that compromises its confidentiality, integrity, or availability.
b) In the event of a suspected or confirmed personal data breach, we will investigate the matter without undue delay, take reasonable steps to contain and mitigate its impact, and notify the Data Protection Board of India and affected individuals where required, within the timeframe prescribed under the DPDP Act and its rules.
c) Where notification to affected individuals is required, we will inform you of the nature of the breach, the categories of data likely affected, the risk this poses to you, and the steps we are taking to address it.
d) If you become aware of any suspected compromise of your account, such as unauthorised login attempts or suspicious transactions, please report it immediately to support@sentimentsindia.com, and we will investigate as a priority.
13. RIGHTS OF DATA PRINCIPALS
Depending on your jurisdiction, you may have the following rights in relation to your personal data:
a) Right to access: to know whether we process your personal data, and to request details of the categories, purpose, and retention period of such data. We aim to respond within 15 business days.
b) Right to correction: to request correction or updating of inaccurate, outdated, or incomplete personal data. We aim to respond within 15 business days.
c) Right to erasure: to request deletion of personal data that is no longer necessary for the purpose it was collected, or that was unlawfully processed, subject to our retention obligations under Clause 10. We aim to respond within 15 business days.
d) Right to withdraw consent: to withdraw consent for marketing communications or other consent-based processing at any time, as described in Clause 6.
e) Right to data portability: to request your data in a portable format, where technically feasible.
f) Right to grievance redressal: to raise a complaint regarding the handling of your personal data, as described in Clause 14 below.
You may update most account details by logging into your account. For deletion, correction, or other requests, please contact our Grievance Officer using the details in Clause 14.
14. GRIEVANCE REDRESSAL MECHANISM
a) In accordance with the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 and the Digital Personal Data Protection Act, 2023, we have appointed a Grievance Officer to address complaints relating to this Policy.
Grievance Redressal Officer Email: support@sentimentsindia.com
Registered Address: Sentiments Creative Labs LLP, V-28, Eldeco Regalia, Lucknow, Uttar Pradesh, India 226020
b) Complaints will be acknowledged within 48 hours and resolved within 15 business days.
c) If you are dissatisfied with our resolution, or do not receive a response within the stated period, you may escalate the matter to the Data Protection Board of India.
15. GENERAL PROVISIONS
15.1 Force Majeure
We are not liable for a delay in performing our obligations under this Policy, including responding to a rights request or breach notification, arising from a cause beyond our reasonable control, including natural disasters, pandemics, governmental action, or a cyberattack.
15.2 Governing Law and Jurisdiction
This Policy is governed by the laws of India. Any dispute arising out of or in connection with this Policy is subject to the exclusive jurisdiction of the courts at Lucknow, Uttar Pradesh.
15.3 Change in Ownership
In the event of a merger, acquisition, or sale of our business, personal data held by us may be transferred to the successor entity, which will continue to be bound by this Policy unless you are notified of a material change.
15.4 Policy Updates
We may update this Policy from time to time to reflect changes in legal requirements or business practices. Material changes will be reflected by updating the “last updated” date at the top of this Policy, and we encourage you to review it periodically.
15.5 Contact Us
If you have questions about this Policy or how we handle your personal data, please contact:
Sentiments Creative Labs LLP,
V-28, Eldeco Regalia, Lucknow, Uttar Pradesh 226020, India
Email: support@sentimentsindia.com
By using the Site, creating an account, or making a purchase, you consent to the collection, storage, use, and disclosure of your personal data in accordance with this Policy.
