Privacy Policy

 If you are under the age of 18, you are required to obtain the consent of your parents, guardian or person who has parental responsibility over you before providing us with your personal data (for example, your name, address, and email address).

The types of personal data we collect or obtain may vary according to our relationship with you and may include the following:

1. Direct Consumers/End Users/Customers: Name, telephone number, email address, address, banking information, Aadhar Number, PAN, photo, location, PIN Code, other official identifiers in case of customers outside India, credit checks, KYC details.
2. Business Partners (including third parties) and Dealer/Distributors: Name, telephone number, email Address, address, Aadhar, Aadhar Number, PAN, GST number, banking information, other official identifiers in case of business partners outside India, any recordings captured through our communication platform(s) (such as telephone recordings, Microsoft Teams, Zoom, etc.), details contained in business registration documents, third party due diligence documents, trade references and credit checks.
3. For Visitors to Any of Our Premises or Events: contact information (such as name, address, email address, and telephone number), identification information (such as national identification number, passport identification number, etc.), business information (such as name of organization, etc.), reason for visit, date and time of visit, biometrics and facial recognition, security notes (special instructions and access restrictions), any photographic and/or video footage captured or recorded by our surveillance camera (CCTV) system or any other recording system.
4. Applicants, Candidates and Beneficiaries: contact information (such as name, address, email address, and telephone number), identification information (such as national identification number, Aadhar and Aadhar Number, passport identification number, tax registration number, date of birth and any other identification information), demographic information (such as age range, marital status, gender, .), financial information (such as parents’ incomes, beneficiaries’ incomes, bank account name and number, .), education information (such as field of studies, university, country of study, academic scores and achievements, professional certifications, etc.), employment information (such as employer name, address, email address, telephone number, position employed, employment tenure, etc.), health information, any photograph(s) or video footage(s) (such as profile pictures, contest submissions, .)
5. Personal data that is automatically collected pursuant to your visit to the Website (refer Section E for further details).

1. Direct Consumers/End Users/Customers:
   • To enable GCL and its group entities to reach out to you in relation to programmes managed by them or products or services offered by them;
   • To enable us to improve products & services, as well as that of the other GCL entities;
   • To process your requests (such as replying to your queries or complaints);
   • To provide you with the credit service;
   • To process your subsidy requests;
   • To sell any products that GCL deals in;
   • Regulatory Obligations, including for auditing purposes.
2. Business Partner and Dealer/Distributors:
   • business execution;
   • organization and management of the business;
   • compliance with laws and/or contractual and/or regulatory obligations, including for auditing purposes;
   • protecting or exercising our legal, contractual and/or regulatory rights and remedies;
   • protecting our assets and interests;
   • any other purpose within the scope of the agreement signed between GCL and its Business Partners and Dealers/Distributors.
3. For Visitors to Any of Our Premises or Events:
   • providing access to our network, systems and/or services;
   • compliance with laws and/or contractual and/or regulatory obligations, including for auditing purposes (if applicable);
   • protecting or exercising our legal, contractual and/or regulatory rights and remedies.
4. Applicants, Candidates and Beneficiaries:
   • To evaluate your candidature for prospective career opportunities with us;
   • To enable us to provide you with the prospective benefits.
5. For smooth functioning of Website, our services, conducting market research and analysis.

GCL may collect your personal data for instance:

• When you contact us through the Website (through any form, e mail address, hyperlink, or social media address posted therein);
• When you register with us to receive products and/or services of any of the GCL entities;
• When you complete surveys conducted by or for us;
• When you elect to receive any communications (including any newsletter, promotional offers) from us and information as may be voluntarily provided by you;
• When you contact us for any service requests, queries through a toll-free number/email provided in the product;
• When you connect with our sales officer or personnel at the dealers/distributors for credit services;
• Through the dealers for any subsidy approvals, product enquiries;
• When we have partnered with you for any business use;
• When you contact us on email or career platforms for job applications.

We automatically collect some information about you by virtue of your visit to the Website. This information helps us to make improvements to Website content and navigation and includes your IP address and the way you use and interact with Website content, namely:

1. Our web servers or affiliates who provide analytics and performance enhancement services collect IP address, operating system details, browsing details, device details and language settings. This information is aggregated to measure the number of visits, average time spent on the site, pages viewed and similar information. GCL uses this information to measure the site usage, improve content and to ensure safety and security, as well enhance performance of the Website.
2. We may collect your personal data automatically via Cookies, in line with the cookie settings on your browser. This website may place and access certain Cookies on your computer/device and uses them to improve your experience of using the Website. “Cookies” are small files placed on your hard drive that assist us in providing our services. We offer certain features that are only available using a “cookie”. Cookies can also help us provide information that is targeted to your interests. Most cookies are “session cookies,” meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline/delete our cookies if your browser permits, although in that case you may not be able to use certain features on the Website and if the Website provides for account creation, you may be required to re-enter your password more frequently during a session.
   
   Additionally, you may encounter “cookies” or other similar devices on certain pages of the Website that are placed by third parties. We do not control the use of cookies by third parties. We may use cookies from third party partners such as Google Analytics for marketing and analytical purposes. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies, but this can be changed.

We may share personal data with different GCL entities to inform you of relevant and customized offers, features, services, and products. It is possible that any such entities or a combination of them could merge with or be acquired by another business entity. Should such a combination occur, you should expect that GCL would share some or all your personal data to continue to maintain and provide GCL services.

To enable us to provide you enhanced and secured services, we may enter into contract with various third parties from time to time. Such engagement may involve sharing of your personal data. To the extent a third party has access to your personal data, we will ask them to treat it at least as protectively as they treat personal data they obtain from their other authorized sources and to ensure that such data is treated in accordance with the applicable laws. This obligation is also documented by us in our contracts with such third parties. We do not sell your personal data to any third party. We have various partners for storing, securing your personal data, network of marketing agencies, analytics third parties, etc. The third parties GCL has contracted with are aligned as per purposes stated in this Privacy Notice.

The personal data that we collect from you is stored in India but may be transferred to and stored at locations that may or not be in India. Where your personal data has been transferred to any subsidiary and/or to third parties located outside of India, the transfer of your personal data is carried out under organizational, contractual, and legal measures and with adequate levels of protection implemented as well as in compliance with any additional local legal requirements for the parties receiving this information to safeguard your personal data.

We may collect and store your personal data in electronic and/or physical form, depending on the requirement. Information may be stored at our and third-party premises within IT Systems (e.g., external cloud storages, internal or third-party management systems, e-mails, databases, hard drives), document warehouses, etc.

We endeavor to process your personal data in a safe environment by preventing any unauthorized or unlawful processing of personal data or accidental loss or destruction of, or damage to, such information. We have implemented various physical, technical, and administrative security measures to protect your personal data and our network from unauthorized access. Some of these measures include:

• Encryption; We use SHA-256 mechanism wherever necessary.
• strict adherence to privacy and security practices;
• periodic security assessment and reviews to upgrade our practices;
• restriction of access of personal data to GCL employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations

We will retain your personal data only for as long as such information is necessary for the purposes it was collected for. The retention period for personal data may also be affected by the requirements of applicable laws. In all cases information may be held for a longer period where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for legal or regulatory purpose) or subject to law, a shorter period where the individual objects to the processing of their personal data. We shall take reasonable steps to destroy or permanently delete personal data that is no longer needed, including communicating the same to third parties engaged by GCL from time to time who process personal data on behalf of GCL

You, as a data principal have certain rights with respect to personal data belonging to you collected by GCL for the purposes mentioned in this Privacy Notice. The rights available to you as per Digital Personal Data Protection Act, 2023 and/or other applicable laws are:

1. Right to access information You have the right to request for:
   • a summary of personal data which is being processed and the processing activities undertaken with respect to such personal data;
   • the identities of all other Data Fiduciaries and Data Processors with whom the personal data has been shared by GCL, along with a description of the personal data so shared;
   • any other information related to the personal data and its processing, as may be prescribed;
2. Right to correction and erasure You have the right to request for
   • Correct the inaccurate or misleading personal data
   • Complete the incomplete personal data
   • Update personal data
   • Erasure of personal data
3. Right to nominate
   You have the right to nominate a representative in your place to in case of an inability to exercise your rights under the DPDPA attributable to (i) unsoundness of mind or infirmity of body, or (ii) death.
4. Right of grievance redressal
   You have the right to have readily available means of grievance redressal provided by a Data Fiduciary or Consent Manager. The Data Fiduciary or Consent Manager shall respond to any grievances within the time period prescribed from the date of it’s receipt for any class of Data Fiduciaries. If you have any further questions about the process to exercise these rights or any grievance with respect to how GCL is handling your personal data, you may contact the Responsible Privacy Personnel at privacypolicy_website@greavescotton.com. If you are unsatisfied by how your request has been processed by GCL, you have the right to raise your grievance with the Data Protection Board of India, or such other body established by the Central Government under the Digital Personal Data Protection Act, 2023.or any rule(s) thereunder.

We reserve the right to amend, modify, vary, or update this Privacy Notice, at our sole discretion from time to time, as and when the need arises. The most recently published Privacy Notice shall prevail over any of its previous versions. You are encouraged to check this Privacy Notice from time to time to stay informed of any changes.

To protect your privacy, as stated above, we will take the best efforts and adopt the best industry standards of information practice, however you understand that 100% security does not exist over the internet. You are responsible for protecting your personal data and you should not share your login credentials and/or leave your personal devices unattended while you are accessing the Website, etc. GCL does not guarantee, and you should not expect in the event of malware attack or negligence on your part, that your personal data will remain private.

1. You have read and understood this Privacy Notice and agree and consent to the use, processing and transfer of personal data as set out herein; and
2. All information and representation provided by you are true and correct to the best of your knowledge, and you have not knowingly omitted any relevant information which may have an adverse effect.

If you have any questions, please feel free to contact us at: privacypolicy_website@greavescotton.com.

This Privacy Notice was last updated on 17th May, 2024.