Privacy Policy
We know that you care about your Personal Data and how it is used, and we want you to trust that Kllydsa Lifestyle Private Limited (“Truegrade”) uses your Personal Data carefully. This Privacy Policy will help you understand what Personal Data we collect, why we collect it and what we do with it. This Policy also constitutes a privacy policy for the purposes of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
Please take a moment to familiarise yourself with our privacy practices and let us know if you have any questions by sending us an email at info@thetruegrade.com or call us at +91 8448667957.
You have the right to withdraw your Consent for uses of your Personal Data based on Consent provided by you. See what your rights are and how you can exercise them in the sections below.
Who Is Collecting It?
Any Personal Data provided to or collected by Kllydsa Lifestyle Private Limited (“Truegrade”) is controlled by Truegrade, the Data Fiduciary.
This Privacy Policy applies to Personal Data collected by Kllydsa Lifestyle Private Limited (“Truegrade”) in connection with the products and services we offer, including through our website, mobile interfaces, and marketing communications.
This Privacy Policy also applies to our marketing content, including offers and advertisements for Kllydsa Lifestyle Private Limited (“Truegrade”) products and services, which we (or a service provider acting on our behalf) may display to you on third-party websites and platforms based on your site usage information. Those third-party websites have their own privacy policies. We encourage you to read them before using those websites.
Key Terms You Should Know
Consent
Any freely given, specific, informed and unambiguous indication, by way of a written declaration or affirmative action, signifying a data subject's agreement to the processing of Personal Data relating to them.
Cookies
Small text files stored on a user's device by a website. They allow web servers to track browser activity and connect individual web requests into a session.
Data Fiduciary / Data Controller
Any natural or legal person, public authority, agency or body that alone or jointly with others determines the purposes and means of the processing of Personal Data.
Data Principal / Data Subject
An identified or identifiable natural person, alive or deceased, to whom the Personal Data relates.
Personal Data
Any information that can identify a data subject directly or indirectly, including name, identification number, location data, or one or more factors specific to their physical, physiological, genetic, psychological, economic, cultural or social identity.
Personal Data Breach
Any act or omission that results in accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data.
Processor
A natural or legal person or entity that processes Personal Data on behalf of the Data Fiduciary.
Special Categories of Personal Data
Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, Financial Data, Genetic Data, Biometric Data, health data, or data concerning a natural person's sex life or sexual orientation.
What Personal Data Is Being Collected?
You are not required to provide Kllydsa Lifestyle Private Limited (“Truegrade”) with the Personal Data that we request. However, if you choose not to do so, we may not be able to provide you with our products, services, or a high quality of service, or respond to any queries you may have.
Personal Data You Give Us Directly
We collect Personal Data when you:
• Register an account or place an order on our website
• Subscribe to our newsletter or marketing communications
• Complete a survey, quiz, or our AI Skin Analysis feature
• Contact us through our website, email, WhatsApp, or phone
• Participate in promotions or loyalty programmes
This may include your name, gender, date of birth, address, email address, telephone number, skin type, health information (such as allergies), and payment transaction data. We will obtain your explicit Consent before collecting any Special Categories of Personal Data.
Personal Data We Collect Automatically
When you interact with our website, we may automatically collect:
• IP address and device identifiers
• Browser type, version, and settings
• Pages visited, time on site, and interaction data
• Purchase history and browsing behaviour
• Location data (where enabled)
We use Cookies and similar tracking technologies to collect this information.
Personal Data We Collect from Other Sources
We may also receive Personal Data from trusted third-party partners, social media platforms, advertising networks, and data enrichment providers, where permitted by applicable law.
Why Do We Collect Your Personal Data?
Kllydsa Lifestyle Private Limited (“Truegrade”) collects, processes and discloses your Personal Data only for specific and limited purposes. These include:
• Processing your orders and managing your account
• Responding to your inquiries and providing customer support
• Sending you order confirmations, updates, and relevant communications
• Providing personalised product recommendations and routine suggestions based on your skin type and concerns
• Improving our products, website, and services
• Managing newsletter subscriptions and marketing communications (with your Consent)
• Administering our AI Skin Analysis feature
• Fraud prevention, security, and legal compliance
• Conducting analysis and profiling to improve your experience (see Section 5)
We do not collect, store or process your full payment instrument details (such as card numbers or UPI IDs). Payments are processed directly by third-party payment service providers, subject to their own privacy policies. We may receive limited transaction data such as payment confirmation, transaction ID, and payment status for order fulfilment purposes.
Where appropriate, we will ask for your Consent before processing your Personal Data. You may withdraw this Consent at any time, though doing so may affect our ability to provide certain services.
Profiling
Kllydsa Lifestyle Private Limited (“Truegrade”) may use your Personal Data to build profiles based on your browsing, searching, and purchasing behaviour, and your interactions with our brand communications. We use this information to:
• Personalise website content and product recommendations
• Display relevant offers and advertisements on our platforms and third-party websites
• Send you communications tailored to your interests and skin concerns
For example, if you frequently view our Niacinamide Serum, we may send you relevant content about managing pigmentation or oily skin. With your Consent, we may use your location to serve promotions relevant to your area.
How We Use Cookies
We use Cookies to:
• Identify which pages are being used and analyse website traffic
• Improve our website and tailor it to customer needs
• Remember your preferences and login status
• Enable targeted advertising based on your browsing behaviour
Cookies do not give us access to your device or any information beyond what you choose to share with us. You can choose to accept or decline Cookies through your browser settings. Declining Cookies may limit certain functionality on our website.
Whom Will Your Data Be Shared With?
Kllydsa Lifestyle Private Limited (“Truegrade”) may share your Personal Data in the following circumstances:
Third-Party Service Providers
We share Personal Data with trusted third-party service providers who perform functions on our behalf, including website hosting, payment processing, data analytics, customer service, delivery, and fulfilment. These providers may only use your Personal Data to perform their designated functions and must process it in accordance with this Policy and applicable law.
Advertising and Analytics Partners
We may share data with advertising networks, social media platforms, and analytics companies to deliver relevant marketing and measure campaign effectiveness. Where third parties use this data independently, they must have a valid legal basis to do so.
Business Transfers
In the event that Kllydsa Lifestyle Private Limited (“Truegrade”) undergoes a merger, acquisition, or sale of assets, your Personal Data may be transferred as part of that transaction. You will be notified of any such change and your data will remain protected in accordance with this Policy.
Legal Disclosure
We may disclose your Personal Data to comply with a legal obligation, respond to a court order, investigate fraud or security breaches, or protect the rights and safety of our customers, staff, or the public.
International Data Transfers
Kllydsa Lifestyle Private Limited (“Truegrade”) may transfer Personal Data across international borders where necessary for the purposes described in this Policy. Any such transfer will be made in accordance with applicable Indian and international data protection regulations, and with appropriate safeguards in place to protect your data.
How Do We Protect Your Personal Data?
Kllydsa Lifestyle Private Limited (“Truegrade”) takes the security of your Personal Data seriously. We implement appropriate technical and organisational measures to protect your data from misuse, loss, unauthorised access, modification or disclosure. These include:
• Encrypted data transmission (SSL/HTTPS)
• Access controls and role-based permissions
• Pseudonymisation and anonymisation where possible
• Regular security reviews and vendor assessments
Access to your Personal Data is restricted to employees and agents on a need-to-know basis, subject to strict confidentiality obligations.
How Long Do We Keep Your Personal Data?
We retain your Personal Data only for as long as necessary for the purpose for which it was collected, or as required by law. For example:
• Order and transaction data is retained for as long as required to fulfil the contract and handle any post-purchase queries or disputes
• Marketing data is retained until you withdraw Consent or unsubscribe
• Skin analysis and skin profile data is retained for as long as your account is active
When Personal Data is no longer required, we delete it securely or anonymise it. If you withdraw Consent, we will take steps to delete your Personal Data within a reasonable timeframe, unless retention is required for another lawful purpose.
Your Rights
Where we process your Personal Data, you have the following rights:
Right to Be Informed
You have the right to clear, transparent information about how your Personal Data is used. This Policy fulfils that obligation.
Right to Access, Update and Rectification
You may request access to the Personal Data we hold about you, or ask us to correct inaccurate information at any time.
Right to Erasure
You may request deletion of your Personal Data where it is no longer necessary for the purpose it was collected, or where you have withdrawn Consent and no other lawful basis applies.
Right to Object
You may object to the processing of your Personal Data for Direct Marketing at any time, including opting out of emails, SMS, or WhatsApp communications.
Right to Withdraw Consent
Where we rely on Consent as the basis for processing, you may withdraw that Consent at any time. Withdrawal will not affect the lawfulness of processing carried out before withdrawal.
Right to Nominate
You may nominate another individual to exercise rights over your Personal Data in the event of your death or incapacitation, as permitted under applicable law.
Right to Grievance Redressal
You have the right to raise a grievance regarding the processing of your Personal Data. Please contact us at info@thetruegrade.com or call us at +91 8448667957.
Right to Lodge a Complaint
You have the right to lodge a complaint with the Data Protection Board of India or any other applicable Supervisory Authority.
How to Contact Us
If you have any questions, requests, or grievances regarding this Privacy Policy or the processing of your Personal Data, please contact us:
Email: info@thetruegrade.com
Phone / WhatsApp: +91 8448667957
We aim to respond to all privacy-related inquiries within 5 business days. If you are dissatisfied with our response, you may escalate your complaint to the relevant Supervisory Authority.
Updates to This Policy
Kllydsa Lifestyle Private Limited (“Truegrade”) will update this Privacy Policy from time to time to reflect changes in our practices, products, or applicable law. When we make material changes, we will update the "Last Updated" date at the top of this Policy and, where appropriate, notify you by email or a prominent notice on our website.
Your continued use of our website or services after any update constitutes acceptance of the revised Policy. We encourage you to review this Policy periodically.