At Finolex Industries Limited (FIL), FIL respects the privacy of individual and is committed to take reasonable precautions to protect information consisting of Personal information and `Sensitive Personal Data or Information’ (SPDI) of such information provider and comply with all legal, regulatory and/or contractual obligations related to privacy. FIL has adopted the “Privacy by Default” principles in its approach to data privacy i.e. privacy of data and information is upheld first by default.
This policy covers the processing, storage and access to Information as required under lawful and/or contractual activities with FIL or otherwise required in the normal course of business. It describes FIL’s policies and procedures on the collection, usage and disclosure of Information provided/received by natural persons and meets the requirements established under:
• The Information Technology Act, 2000 – Section 43A;
• The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011.
This policy applies to all all persons who provide their SPDI to FIL.
2. Information covered by this Policy
This policy applies to Information collected and processed by FIL consisting of following:
2.1 Personal information is SPDI that could reasonably allow SPDI provider to be identified. Personal information may consist of full name, personal contact numbers, residential address, email address, gender or date of birth. While information such as date of birth in isolation may not be enough to uniquely identify the SPDI provider, a combination of full name and date of birth may be sufficient to do so.
2.2 Sensitive personal data or information (“SPDI”) is such personal information that is collected, received, stored, transmitted or processed by FIL, consisting of:
• Name of the individual
• Address of the individual
• E-mail address or phone or other contact details
• Financial information such as bank account or credit card or debit card or other payment instrument details;
• Physical, physiological and mental health condition;
• Sexual orientation;
• Medical records and history;
• Biometric information;
• Any detail relating to the above personal information categories as provided to FIL for providing service; and
• Any of the information received under above personal information categories by FIL for processing, stored or processed under lawful contract or otherwise.
Please note that any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as SPDI.
FIL shall collect and use Information for legitimate business purposes in order:
• that a SPDI provider may download product information, order products and take advantage of certain other features provided by FIL;
• to provide information or interactive services through this website or in any other way, to the SPDI provider’s e-mail address or, where the SPDI provider wishes it to be sent by post, to the SPDI provider’s postal address;
• to seek the SPDI provider’s feedback or to contact the SPDI provider in relation to the services offered on FIL’s website or in any other social media or in any other way;
• to process orders or applications submitted by the SPDI provider;
• to administer or otherwise carry out FIL’s obligations in relation to any agreement that the SPDI provider may have with FIL;
• to anticipate and resolve problems with any goods or services supplied to the SPDI provider;
• to create products or services that may meet the SPDI provider’s needs;
• to process and respond to requests, improve FIL’s operations, and communicate with SPDI providers about FIL’s products, services and businesses; and
• to allow the SPDI providers to subscribe to FIL’s news alerts.
• to allow call centres/ authorised representatives of FIL to make calls and /or email to ensure the SPDI provider finds the information satisfactory and also to impart product knowledge, inform about promotional offers irrespective of the fact that you have registered yourself under DND or DNC or NCPR service (This will override registry on DND/NDNC) and may seek feedback to further improve our offers and or services.
4. Collection of Information
Only minimum Information required to meet the purposes mentioned in this policy shall be collected from the SPDI providers. Neither FIL nor its representatives shall be responsible for the authenticity of such Information provided by the SPDI providers. As normal business practice, FIL may collect Information in order to enable the secure online authentication, interaction and transaction with natural persons. This may include the installation of cookies and the collection of other session data.
5. Access, Correction of Information and withdrawal of consent
Any modifications / corrections required to the Information can be carried out. In the event SPDI provider is unable to do so due to lack of functionality in FIL’s website and / or the SPDI provider wants to withdraw his / her consent to provide SPDI, the SPDI provider may contact the Grievance officer, the details whereof are provided in clause 9 of this policy.
6. Retention, Processing and storage of Information:
6.1 FIL shall retain Information for only as long as necessary to meet legal or regulatory requirements or for legitimate business purposes as mentioned in this policy.
6.2 FIL has implemented required security practices and standards in line with the global standards and have a comprehensive documented information security program and policy in place, which contains managerial, technical, operational and physical security control measures that commensurate with the information assets being protected with FIL’s nature of business. It is being reviewed periodically to keep pace with business, technology and regulatory changes.
7. Disclosure of Information
7.1 FIL shall not use or disclose Information for purposes other than as mentioned in this policy, except with the consent of SPDI providers providing such Information or as required by law. However, FIL may be legally required to disclose the Information in the following cases:
• Where the disclosure is necessary for compliance of a legal obligation;
• Where mandated under the law by government agencies to disclose such Information.
• The SPDI provider has an option of unsubscribing to our marketing related information and they can unsubscribe at any time.
7.2 Where necessary, FIL may disclose Information to business partners or third parties during the normal course of business for the purposes mentioned in this policy. In such cases, FIL will only share Information related data when FIL is assured that:
•The Information is processed legitimately and appropriately by the business partner or third party in line with the established consent or in line with legal requirements.
• The business partner or third party has adopted a reasonable and equivalent level of security practices and procedures to ensure security of the Information shared.
• FIL would not be selling the SPDI collected to any other party.
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9. Feedback or Concern
For feedback or concern, if any, kindly contact:
Email Id: firstname.lastname@example.org