UNO MINDA Privacy Policy

Date created: 29 July 2022

By accessing this website and/or by availing any of the services, you agree to the terms of this Data Privacy and Protection Policy.

Terms used in this policy

In this Data Privacy and Protection Policy:

• "GDPR" means the EU General Data Protection Regulation.
• "Personal Data" means any information relating to an identified or identifiable natural person.
• "Policy" means this Data Privacy and Protection Policy.
• "Service" refers to a service that UNO MINDA provides, for a fee or gratis. You are using our Service when you actively sign up or sign in to get access to any Service provided by us.
• "we", "us", "our", and "Uno Minda" refer to Minda Industries Limited and its group companies in India and outside India.
• "Website" refers to websites of Minda Industries Limited and its group companies. You are using our "website" when you are visiting our website
• "you" refers to you, as a user or subscriber of the services provided by us.

Our commitment towards protecting personal information

Minda Industries Limited and its group companies, hereinafter referred to as the "Company" or "Uno Minda", is committed to keeping your personal data private. We are committed to safeguarding the privacy of our website visitors and service users. The Privacy Statement (“Statement”) enumerated below, provides information that we gather through the Service, how we use such information, and the steps we take to protect such information. By visiting the Site, or by purchasing or using the Service, you accept the privacy practices described in this Policy.

Our commitment to protecting privacy goes beyond the minimum legal and regulatory requirements. We strive for best-in-class data protection and privacy management, which requires a sound data privacy governance structure and effective data privacy compliance and best practices program to ensure that we meet ever-changing and increasingly-complex regulatory standards and all contractually agreed privacy obligations.

We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website. Please link to Cookies Policy.

Scope

This Policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

This Policy applies to all the Company-owned websites, domains, and services and those of our wholly owned subsidiaries ("the Company sites or services"), except that a privacy policy or statement specific to a particular the Company service or program may supersede or supplement this Privacy Policy Statement.

Personal information concerning the Company and its customers, including outsourcing and other services clients, business partners, employees, former employees, and applicants for employment (“covered individuals”) collected and processed offline is also governed by this Privacy Policy Statement except where the contract with a covered individual defines different requirements which will take precedence over this Privacy Policy Statement.

Privacy policy statement

Your privacy is important to us. We will use your personal information only in the manner set out in this Policy. We act in accordance with the applicable data protection laws, including GDPR. We are committed to safeguarding the privacy of our website visitors, clients, prospects, and research participants.

This Policy sets out how we deal with your personal information.

Our commitment towards protecting your personal information includes the following obligations:

• We promise to protect your privacy and treat the information you give us as confidential.
• The information you provide to us will be used by us only for the purpose for which it was sought.
• We will not release your personal information to any third party without your consent unless such disclosure is required by any law, rule or regulation or was in response to a valid order of a court or authorized agency of government or other legal process.
• We will never try to sell you anything and we will never sell your personal data to anyone.
• Your decision to provide or not to provide any information will be respected without question.

What data do we collect or process about you, and for what purpose?

• We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of your visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your Service use. The source of the usage data is our analytics tracking system. In addition, we may use third-party analytics tracking services such as Google Analytics and Facebook Pixel. This usage data may be processed for the purposes of analyzing the use of the Website and Services in order to improve our performance metrices, and for communicating with you. The legal basis for this processing is your consent as per Article 6(1)(a) of the GDPR. In some cases, the legal basis for this processing is our legitimate interests, namely monitoring and improving our Website and Services.
• We may process your data that is provided to us during the course of our surveys ("response data"). The response data may include your name, age, area of residence, mobile number, email address, your responses to the questions that we may ask you. The source of the response data is you. The response data may be processed for the purposes of providing our services, ensuring the integrity of our operations and processes, maintaining back-ups of our databases, and for communicating with you. The legal basis for this processing is your consent.
• We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone/mobile number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details, employment details and parental status. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services and for communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our Website and Services.
• We may process your personal data that are provided in the course of the use of our Services ("service data"). The service data may include your name, address, telephone number, email address. The source of the service data is you or your employer. The service data may be processed for the purposes of providing our Services, ensuring the security of our Website and Services, maintaining back-ups of our databases, and for communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our Website and business. In some cases, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
• We may process information that you post for publication on our Website or through our Services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our Website and Services. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our Website and business. In some cases, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
• We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you and for and for communicating with you. The legal basis for this processing is your consent.
• We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications, promoting our products and services to customers, and for communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our Website and business. In some cases, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
• We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your banking details, your credit card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services, keeping proper records of those transactions, and for communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our business. In some cases, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
• We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters, and for communicating with you. The legal basis for this processing is your consent.
• We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our Website and business and communications with our business counterparts.

In addition to the specific purposes for which we may process your personal data set out in this Section, we may process any of your personal data identified in this Policy where necessary for:

• the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
• the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
• compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Whom do we share your data with?

• We may disclose your personal data to any of our employees, officers, and agents as long as such disclosure is reasonably necessary for the purposes, and on the legal bases, set out in this Policy.
• We may disclose your personal data to any member of our group of companies (this means our ultimate holding company and all its subsidiaries and joint venture partners) with appropriate safeguards as long as such disclosure is reasonably necessary for the purposes, and on the legal bases, set out in this Policy.
• We may disclose your personal data to our insurers and professional advisers with appropriate safeguards as long as such disclosure is reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure and for protecting other legitimate interest of the Company.
• We may disclose your personal data to our suppliers or subcontractors as long as such disclosure is reasonably necessary for providing Services to you.
• Financial transactions relating to our Website and Services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
• We may disclose your personal data to third party suppliers of goods and services with appropriate safeguards for the purpose of enabling them to contact you so that they can offer, market and sell to you the relevant goods and/or services.
• In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

We will not sell, share, rent or otherwise intentionally transfer your name, address, telephone number or e-mail address to market research companies, direct marketing companies or anyone else. The only exceptions when we may disclose your personal information to third parties are as follows:

• You request us to share, or consent to us sharing, your data with the third parties for a specified purpose
• We provide your responses to a third party who is contractually bound to keep the information confidential and use it only for research or statistical purposes
• In the rare but possible circumstance that the information is subject to disclosure pursuant to judicial or other government subpoenas, warrants, orders or for similar legal or regulatory requirements.

How long do we retain your data?

Your Personal Data processed by Uno Minda are kept for no longer than is necessary for the purposes for which the Personal Data are processed in line with legal, regulatory or statutory obligations. At the expiry of such periods, your Personal Data will be deleted or archived to comply with legal retention obligations or in accordance with applicable statutory limitation periods.

In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

Notwithstanding the foregoing provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

What are your rights regarding your data with us?

This Section summarizes the rights that you have under data protection law. Please note that some of the rights available to you are convoluted and may not be represented in detail in this Policy. We advise you to peruse the relevant laws for a complete understanding your rights. Your principal rights concerning your Personal Data under GDPR are as below:

• Right to access: You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data.

  Subject to the condition that the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can request your personal data with us, by emailing us on privacy@unominda.com.

• Right to rectification: You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

• Right to erasure: In certain circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data provided to us is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed.

  However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

  Right to restrict processing: In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you do not desire erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

• Right to object to processing: You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

  You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

  You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

• Right to data portability: To the extent that the legal basis for our processing of your personal data is: (a) consent; or (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format.

  However, this right does not apply where it would adversely affect the rights and freedoms of others.

• Right to complain to a supervisory authority: If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

• Right to withdraw consent: To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

  You may exercise any of your rights in relation to your personal data by a written notice to us on privacy@unominda.com. In order for us to comply with your request, your notice must clearly state the right that you wish to exercise and identify your information in respect of which you wish to exercise such right. Please note that as a security measure, we may require you to verify your identity before accepting any request concerning your Personal Data.

How do we use cookies?

A cookie is a file containing a unique identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, that is, when the web browser is closed.

Cookies do not typically contain any information that personally identifies you, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

We use cookies for the following purposes:

• Advertising. We use cookies to help us to display advertisements that will be relevant to you.
• Analysis. We use cookies to help us to analyze the use and performance of our website and services.
• Authentication. We use cookies to identify you when you visit our website and as you navigate our website.
• Cookie consent. We use cookies to store your preferences in relation to the use of cookies more generally.
• Personalization. We use cookies to store information about your preferences and to personalize the website for you.
• Security. We use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally.
• Status. We use cookies to help us to determine if you are logged into our website.

In addition to the cookies mentioned above, additional cookies may be used by third-party service providers. Such third-party service providers use cookies and those cookies may be stored on your computer when you visit our website.

• We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.
• We publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behavior on our website and on other websites across the web using cookies. You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative's multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies. This means that if you clear the cookies from your browser, your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

• Chrome: https://support.google.com/chrome/answer/95647?hl=en
• Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
• Opera: http://www.opera.com/help/tutorials/security/cookies/
• Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
• Safari: https://support.apple.com/kb/PH21411
• Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy

Contact us

• This Website is owned and operated by Minda Industries Limited
• We are registered in India under registration number (GST): 07AAACM1152C2Z4
  • Our registered office address is; B-64/1, Wazirpur, Industrial Area, North West Delhi, Delhi, 110052
• You can contact us (a) by post: at our registered office address provided above; (b) by email: on grievance.redressal@mindagroup.com; (c) by telephone: on the contact number published on our Website from time to time; (d) by Website: by using our website contact form on https://www.unomindakart.com/contact-us