PRIVACY POLICY

Nuvoco Vistas Corporation Limited (hereinafter referred to as the ‘Company’) is committed to respecting the privacy of every person, including the employees of the Company, business partners as well as vendors, dealers and all others who share their personal data or information with the Company.

This privacy policy aims to give you information on how the Company collects and processes your personal data through (i) your use of this website and (ii) more generally, including the supply or receipt of goods/services, any data you may provide through this website when you sign up to any newsletter that we may launch, purchase a product or service or take part in a competition.

This website is not intended for children and we do not collect data relating to children through this website.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and is not intended to override them.

The purpose of this Policy, as amended from time to time, is to give you an understanding on how the Company intends to collect, receive, possess, store, transfer, handle, deal with and use the Personal Information provided by you.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes credit data, banking details of clients, suppliers and agents for the making of payments by us and to us in relation to the services we provide.
• Transaction Data includes details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing material from us.

We may also collect, use and share Aggregated Data such as economic, statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data by law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect the Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Apart from industry-wide or governmental surveys where we are obliged to take part, KYC details, and except while performing obligations pursuant to specific written contracts with clients, we do not normally collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

We use different methods to collect data from and about you through:

Direct interactions: You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• Apply online or otherwise for our products or services
• Contract to receive our services or provide services to us
• Read the online marketing information available on the Website
• Request marketing material to be sent to you
• Enter a competition, promotion or survey
• Give us feedback

Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Third parties or publicly available sources: We may receive personal data about you from various third party events and in pursuant to entering into a contractual arrangement with third parties.

1. Analytics providers such as Google
2. Affiliated marketing networks
3. Search information providers
4. Digital Portals
5. Social Media
6. Mobile/Web Applications

• Contact and Transaction Data from providers of technical, payment and delivery services. Identity and Contact Data from data brokers or aggregators.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register, statutory authority websites.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to supply goods or provide you with our services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you or to perform other legal obligations
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
• Where we need to comply with a legal or regulatory obligation

Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by Contacting us.

The Company may collect, use, receive, possess, store, disclose, process and transfer Sensitive Personal Information for various purposes, including but not limited to, the following:

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

The Company has adopted reasonable security practices and procedure to ensure that the Personal Information is collected and preserved in a secured manner. In case you wish to know more details about the adopted reasonable security practices and procedures, you may contact the designated person for the same.

While the Company will endeavor to take all reasonable and appropriate steps to keep secure any information and prevent its unauthorized access, the information providers agree and acknowledge that the Company cannot provide any absolute assurance regarding the security of the Personal Information. To the fullest extent permissible under applicable laws, the Company disclaims any liability in relation to any breach of security or loss or disclosure of information in relation to the Personal Information. If you need to access update or correct the Personal Information, you may contact the designated person for the same.

If you need to access update or correct the Personal Information, you may contact the designated person for the same.

We will only retain your personal data which shall be reasonably required to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Under the Indian law, we will normally have to keep basic information about our customers and agency-type services (including Contact, Identity and Transaction Data) for 7 years after they cease being customers. In relation to contractual services, this period may be extended to 15 years. [Thereafter, we will either destroy or return personal data to the client.]

We may also anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further policy to you.

The Company reserves the right to revise and update this Privacy Policy at any time without expressly informing you. Any such revisions will be effective on and from the date of posting the same to the intranet/internet website of the Company, and will apply to all information collected both prior to and following the effective date. You should visit the website and intranet periodically to review the current policies with regard to Personal Information.

Use of the website of the Company/intranet following any such revisions will be deemed acceptance by you of such revisions.