Privacy Policy

Landmark Group is an international, diversified retail and hospitality conglomerate operating various retail concepts in India such as Lifestyle, Max, Splash, Home Centre, Krispy Kreme and Spar. "Landmark Rewards", India's leading retail group loyalty program from the Landmark Group, provides members unique benefits and exclusive rewards and privilege to shop across Landmark Group stores in India.

We may solicit information from the members from time to time with the objective of providing you a safe, efficient, smooth and customized experience, services and features that most likely meet your needs, and to customize our program to provide you suitable offers and services. In addition, we may use the information for internal research on our users demographics, interests, and behaviour to better understand, protect and serve our users. You always have the option to not provide information by choosing not to use a particular service or feature or opting-out of the program completely. We are committed to protecting the privacy of our members and their transactions. This privacy policy ("Privacy Policy") governs your use of such information and explains how we protect and use your information in a safe, secure and responsible manner.

In this policy, the term "Landmark Group" means and includes Lifestyle International Private Limited, Splash Fashions India Private Limited, Citymax Hotels (India) Private Limited, Citymax Hospitality (India) Private Limited, Max Hypermarket India Private Limited, and one or more entities in India that are included as part of the Landmark Rewards program. The term "we" or "us" (including grammatical variations thereof) used in this Privacy Policy refers to Landmark Group or if the context so requires one or more companies forming part of the Landmark Group who is administering the Landmark Rewards program or using information as mentioned herein.

This privacy policy includes information about:

• Protecting information and making security of information a priority
• Collecting information
• Managing information
• Making sure the information is accurate
• Honouring your preferences

Protection of customer data is our priority and we safeguard your data by:

• Setting policies and procedures for carefully handling your information
• Limiting access to sensitive information
• Protecting against unauthorized access to customer data
• Authentication and virus detection technology
• Requiring service providers to comply with privacy laws

Information collected:

We collect and use various types of information to service your accounts, save your time and money, better respond to your needs, and manage risk. Customer information shall be collected under the following categories:

Personally Identifiable Information or (PII):

PII refers to any information that can be used to identify you as an individual in any way. Enrollment in the Inner Circle/ Landmark Rewards program is contingent upon your agreeing to the terms of service and providing basic registration information, including: first and last name, mobile number, email address, date of birth, gender, zip code and residential address. Members will need to provide us with the basic personal identification information, wherever required, to avail of all the benefits associated with the program.

Landmark Group will use your mobile phone number as an identifier, to manage your Landmark Rewards membership and to fulfill our rights and obligations as per the Terms and Conditions of the Landmark Rewards program.

Profiling Information:

Apart from the above we will also solicit and collect from the members from time to time details on their preferences, subscription to particular news segments or offers and other promotional activities we do. The decision to participate in such activities is at the sole discretion of the member and the member may opt out from providing such information by sending an email to feedback@landmarkrewards.in

Automatically Collected Information:

When you log on to the Landmark Rewards website or use your Landmark Rewards membership details at a group company, the server automatically recognizes you by your member id and other details like your IP address and related information. This member id acts as a unique identifier, which allows us to recognize you and authorize your transactions. If you so choose, this information may be added to your personal profile and used to target you with offers and advertisements that are most relevant to your interests.

Transaction history within the program:

Landmark Group is capable of and will collect information on transactions within one or more companies forming part of the Landmark Group in India and are required for processing of Landmark Rewards points and credits and debits to the member's accounts. By definition this shall include all transactions at any of the Landmark Group stores, all promotional campaigns through emails, SMS or any other communication channel.

All the above information is collected for:

• Better servicing of the members and account maintenance
• Making the offerings more relevant to the members and as desired by them ensuring no spam mails go through
• Keeping track of rewards points transactions, to help in case of any dispute situations processing your redemption requests dealing with enquiries, requests or complaints and other customer care related activities and all other general administrative and business purposes marketing products and services carrying out any activity in connection with a legal, governmental or regulatory requirement or in connection with legal proceedings, crime or fraud prevention, detection or prosecution
• To effectively administer and fulfil our obligations under any agreement we may have with you;
• To seek your feedback or to contact you in relation to those services offered;
• Registering your details and allocating or offering you rewards, discounts or other benefits as part of the program

You hereby expressly agree to share personally identifiable information for the above purposes. In the event, you do not wish that your personally identifiable information be used for the above mentioned purposes or you wish to withdraw consent for use of your personally identifiable information please e-mail us at feedback@landmarkrewards.in. In such events, we will not be in a position to provide you any benefits as part of the Landmark Rewards program

To collect the above information we shall use channels such as physical forms, call centre, website (including cookies), emails, promotional offers, surveys and mailers. Participation in some of these channels is optional but you may be required to provide your personal identification information in order to participate. We are not liable to verify the authenticity or accuracy of any information we collect from you.

From time to time we may ask the members to update their contact & personal information with the program on our authorized website, contact centre or through any other approved channels. This is to help keep you updated on any program changes and enhancements. We will not be liable for any failure to notify you of program changes if you fail to update such information in a timely manner.

Access to information:

We will share your information with third parties only in the ways that are described in this privacy statement.

We may disclose the Information collected and received under this Privacy Policy:

• With one or more of other corporate entities and affiliates forming part of Landmark Group globally to help detect and prevent identity theft, fraud and other potentially illegal acts; correlate related or multiple accounts to prevent abuse of our services; and to facilitate joint or co-branded services as part of the Landmark Rewards program.
• As required by law, such as to comply with a subpoena, or similar legal process, etc.;
• When we believe in good faith that disclosure is necessary to protect our rights and interests, protect your safety or the safety of others, investigate fraud, or respond to a government request and the like;
• With our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement.
• If any of the entities forming part of Landmark Group is involved in a merger, acquisition, or sale of all or a portion of its assets, the business entity that consequently acquires such information will receive and store the same as per this Privacy Policy.

Information Storage:

All information shall be stored by us or one or more of our vendors, who will be bound by a non-disclosure agreement with us. We reserve the rights to hold the members data indefinitely.

We may share our information with trusted third parties including data processors to organise, process, clean & analyse our data to help us better understand the trends and segments within our member base. We shall use this information with the purpose of enhancing the value of the program for the member base and to better tailor our offers to your specific interests. All such third parties shall be under non-disclosure agreements and strictly bound to maintain the confidentiality of the information shared and will not share the personal information any further or for purposes beyond our specific authorization.

Members may receive promotional offers and campaign details by email among other means. If you have opted to receive promotional offers there will be unsubscribe options with all such category of offers and members can choose to unsubscribe from such offers at any time by following the mentioned procedures.

Selectively, members may also receive program offers via your mobile number or postal mail. Such contacts may result in rewards being issued to the member. We also contact you via email for administrative purposes, such as program change notifications or if we update our privacy promise. While you can elect to stop receiving email for promotional offers (as described above), you cannot unsubscribe from these administrative messages while enrolled in the program.

Our member care department may also contact you in response to an inquiry you submit. Member care may also contact you with regard to a particular problem that may have occurred with your account or with an offer in which you may have participated. We may use this information to learn more about your participation in the program and make it more relevant to your interests.

Information access by member:

At Landmark Group, we respect your privacy and are committed to ensuring the confidentiality of your information with us. We may contact you with useful information on products and services through our telemarketing / telecalling activities, which may be beneficial for you. However, if you do not wish to be contacted through our telemarketing calls or messages, we request you to kindly register at our contact centre and give details of the telephone on which you do not wish to be contacted. However, we reserve the right to contact you through telecalling for services related to your Landmark Rewards account. Further, we are committed to follow the laws laid out with regards to telecalling and telemarketing and, follow the guidelines set by any regulatory authority like TRAI in cases of DND policy or any such similar rules which may be in force.

Once you have registered for any such DND policy, your telephone number(s) will be removed from all our telemarketing calling lists within 30 working days. We will ensure that you do not get any further telemarketing calls on the telephone number(s) that you have registered.

Voice Call Recordings at Contact Centre:

With a view to providing the best possible service to its customers, we will be:

1. Recording voice calls made to our customer care with a view to better provide our services
2. Monitoring the voice calls recorded;
3. Overseeing the services furnished by the customer call centres.
4. Sharing with one or more entities within the Landmark Group, all or any particular call recordings received from those customers who have been enrolled with the program and/or A report with details of the complaints, if any, received by the customer. The sharing of voice recordings received from the call centres with the applicable Landmark Group company will be done in due compliance of applicable privacy laws.

All of the aforesaid activities are done, inter alia, to:

• Improve customer satisfaction
• Assure quality management and customer experience
• Identify and analyze the patterns and the types of requests/complaints raised by customers frequently on a real time basis
• Initiate remedial measures to prevent the re-occurrence of such complaints/issues
• Retain a recording of the voice calls.
• Support any transactions that take place over the phone and/or if there is a dispute

Links to Other Sites:

The website of Landmark Rewards or any communication made under the program may contain features which link to other websites that may collect personally identifiable information about you. We are not responsible for the privacy practices or the content of those linked websites. In addition, such other websites may contain certain product and service offerings which are carried out independently by such third party websites. We are neither responsible for the working of such third party websites nor do we warrant or nor do we make any assurances of the existence, adequacy or functioning of security practices of any such third party websites.

Changes:

This Privacy Policy may be updated from time to time for any reason without notice. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.

Your Consent:

By being a member of the Landmark Rewards program, you agree to be bound by the terms and conditions of this Privacy Policy (as amended and in force from time to time) and you expressly consent to our use and disclosure of your personal and other information in accordance with this Privacy Policy (as amended from time to time).

If you do not agree to the terms of this Privacy Policy, you may exercise your opt-out rights as mentioned herein.

Opt out rights:

In the event, you do not wish that your personally identifiable information to be used for the purposes mentioned herein or you wish to withdraw consent for use of your personally identifiable information please e-mail us at feedback@landmarkrewards.in or call us on 1800-208-2444. In such events, we may not be in a position to provide you the benefits as part of the Landmark Rewards program. Also, in case you choose to not share your name and/or mobile number, your membership from the program will be terminated.

Anti-Spam Policy:

Since email is an integral part of the program, your sharing of email contact with us allows us to share the program information, offers and promotions via email with you. If you later decide you wish to cease participation in this portion of the program, you may do so at any time by unsubscribing to our communication. Please note that opting not to receive email does not exempt you from receiving administrative emails that include but are not limited to, notices about vital program and membership status changes or alterations to our terms of service or any other service requests.

Data Verification and Supplementation:

Data verification involves the use of third-party data processing services to standardize and clean your provided enrolment information so that it is easily identified and accessed in our database.

Guarding your own information: We recommend that you take the following precautions to guard against the disclosure and unauthorized use of your account and personal information

• never provide personal information that can be used to access your account over the phone unless you have initiated the call and know with whom you are speaking
• update any changes in addresses or contact information immediately through the proper channel
• report lost or stolen cards immediately

Security of information:

We maintain physical, electronic and procedural safeguards to protect customer information. Specific employees only are authorized to access customer information on a need to know basis for business purposes only.

Making sure information is accurate:

It is in your interest and it is our objective, for us to have accurate, current and complete information concerning you and your account. We have strict procedures that our employees abide by to meet this objective. While some procedures are required by central, state or RBI regulations, we have implemented additional procedures to maintain accurate, correct and complete financial information, including processes to update information and remove outdated information. If you believe that we have incorrect information about you or your accounts, please intimate us. We will correct any erroneous information as soon as possible.

Grievance Officer:

In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below:

Ms. Nirmala Nagesh

77° Town Centre, Building No. 3, West Wing,

Off HAL Airport Road, Yamlur P.O.,

Bangalore - 560 037, Karnataka, India

Phone: +91 (80) 41796565 Extn: 4103

Email:nirmala.nagesh@landmarkgroup.in

In case you have any discrepancies and grievances in connection with this Privacy Policy, you may please contact the Grievance Officer mentioned above.

If you have any other questions or clarifications regarding privacy, or have questions about our practices, please contact us via email at feedback@landmarkrewards.in