Privacy Policy

Emporia Gusto Private Limited (“Divas Club”, “us”, “we”, or “our”) operates the website divasclub.in, our styling platform at app.divasclub.in, and all associated subdomains and services (collectively, the “Service”). This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our personalised styling service.

By using our Service, you agree to the collection and use of information in accordance with this policy. If you do not agree with the terms of this Privacy Policy, please do not access the Service.

1. Information We Collect

1.1 Information You Provide

• Account Information: Name, email address, phone number, and postal address when you create an account or book a styling service.
• Photos: When you book a styling service, you upload photographs of yourself (face and full body) through our platform. These photos are used solely for the purpose of creating your personalised style analysis.
• Styling Preferences: Style preferences, lifestyle information, trip details, and comfort levels that you provide through our styling questionnaire.
• Payment Information: We do not store your credit card or banking details. All payment processing is handled by secure, PCI-DSS compliant third-party payment gateways. We only retain a transaction reference number.
• Communication: Any emails, WhatsApp messages, or support tickets you send to us.

1.2 Information Collected Automatically

• Log Data: IP address, browser type, browser version, pages visited, time and date of visit, time spent on pages, and device information.
• Cookies: We use cookies and similar tracking technologies to improve your experience. You can disable cookies in your browser settings, but some features may not function properly.
• Analytics: We may use services like Google Analytics to monitor and analyze usage patterns to improve our Service.

2. How We Use Your Information

• To create your personalised style analysis using our AI-powered styling system.
• To deliver and communicate about your styling service.
• To provide customer support through email, WhatsApp, and our AI assistant “Aarya.”
• To send newsletters, promotional offers, and service updates (you may opt out at any time).
• To improve and optimize our Service, styling algorithms, and user experience.
• To detect, prevent, and address technical issues, fraud, or security threats.
• To comply with applicable laws and regulations.

3. AI-Powered Styling Analysis

Divas Club uses Artificial Intelligence (AI) and machine learning models to analyze your uploaded photographs and questionnaire responses for the purpose of creating your personalised styling service. This includes analysis of your face shape, body type, skin tone, colour season, and related style attributes.

Important disclosures:

• The AI analysis is based on visual patterns and does not constitute medical, dermatological, or health advice.
• Style recommendations are suggestions only and should be considered as guidance, not definitive prescriptions.
• Results may vary based on the quality and angle of photographs submitted.
• AI models are periodically updated, which may result in slight variations in recommendations over time.

4. Data Storage & Security

4.1 Photo Handling

• Your uploaded photographs are used exclusively to create your personalised styling analysis.
• Photos are encrypted and stored on our secure Mumbai servers.
• We do not use your photos for training AI models, marketing materials, social media, or any purpose beyond your styling analysis.
• You may request permanent deletion of your photos at any time by emailing hello@divasclub.in.

4.2 Data Retention

• Account Data: Retained for as long as your account is active or as needed to provide the Service.
• Photographs: Retained for 90 days after styling analysis is delivered, after which they are automatically deleted unless you request earlier deletion.
• Styling Content: Your personalised styling analysis is retained for lifetime access through the platform.
• Transaction Records: Retained for 7 years as required under Indian tax and accounting laws.

5. Your Rights

Under the Digital Personal Data Protection Act, 2023 (DPDPA) and applicable Indian data protection laws, you have the right to:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate or incomplete personal data.
• Deletion: Request deletion of your personal data (subject to legal retention requirements).
• Withdrawal of Consent: Withdraw consent for data processing at any time by contacting us.
• Grievance Redressal: File a complaint with our Grievance Officer or the Data Protection Board of India.

To exercise any of these rights, please contact our Grievance Officer at hello@divasclub.in.

6. Third-Party Services

We may use the following categories of third-party services:

• Payment Gateways: PCI-DSS compliant processors for handling payments.
• Cloud Hosting: India-based cloud infrastructure providers for data storage and application hosting.
• Analytics: Google Analytics or similar services to understand usage patterns.
• Communication: Email and WhatsApp Business API for customer communication.

All third-party service providers are contractually obligated to handle your data in compliance with applicable Indian data protection laws and our privacy standards.

7. Children's Privacy

Our Service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we discover that we have collected data from a minor, we will delete it immediately.

8. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated policy on this page with a revised “Last updated” date. Your continued use of the Service after changes constitutes acceptance of the revised policy.

9. Grievance Officer

In accordance with the Information Technology Act, 2000 and the Digital Personal Data Protection Act, 2023, we have appointed a Grievance Officer to address any concerns regarding this Privacy Policy or our data practices.

Grievance Officer, Emporia Gusto Private Limited
Plot No. 1097, Sector 23-A, Faridabad, Haryana — 121001, India
CIN: U74999HR2018PTC076983
GSTIN: 06AAFCE2694G1ZL
Email: hello@divasclub.in
Phone: +91 8950914301
Response time: Within 30 business days of receiving a complaint.

10. Contact Us

For any questions about this Privacy Policy, please contact us at hello@divasclub.in or call +91 8950914301.