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Privacy Policy
At PGP Glass Private Limited (“Company”, “PGP”, “we“, “us“, and “our“), we take your privacy very seriously and are committed to protecting your personal data. This privacy policy (“Privacy Policy”) sets out the way in which we collect, use, disclose, transfer, and store your personal data when you use our website ‘www.pgpfirst.com’ or other digital platforms (the “Website“), when you request marketing or promotional materials for us, inquire about any of our products or when you avail any other services from us (“collectively referred to as “Services”). Users, customers, visitors and vendors are collectively referred to as “you” or “your”.
You are advised to carefully read the Privacy Policy before using this Website. This Privacy Policy governs your access to and use of the Website and/or the Services. This Privacy Policy is published in compliance with, inter alia:
(a) Section 43A of the Information Technology Act, 2000 (“IT Act”); and
(b) Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPDI Rules”).
GENERAL TERMS
(a) By accessing or using the Website or the Services, or by otherwise giving us your information, you confirm that you have the capacity to enter into a legally binding contract under the Indian Contract Act, 1872, and have read, understood, and agree with the privacy practices described in this Privacy Policy and the terms and the collection, storage and processing of your personal information (“Personal Information”) in accordance with them. Please go through this Privacy Policy in detail and contact us if you have any questions or require any clarifications.
(b) The collection and processing of Personal Information in the course of our delivery of Services, or other contractual or commercial engagements that we may enter into, will be done in accordance with the specific terms applicable thereto, and will override the terms in this Privacy Policy.
(c) You represent that the Personal Information you provide from time to time is and shall be correct, current and updated and you have all the rights, permissions and consents to provide such information or data. Your providing the Personal Information is voluntary and you hereby consent to our collection, storage, processing, use, sharing, disclosure, or transfer of your Personal Information as described in this Privacy Policy. In the event of a change in the law applicable to data protection in India, you expressly consent to our continued use, storage, collection and disclosure of your Personal Information and agree to provide such additional consents and approvals, in such form and manner, as may be requested by us. Should you choose to not provide us with such additional consents and approvals, we may be unable to provide you access to the website or provide the Services.
(d) You further represent that to the extent you provide us with personal information or sensitive personal data or information of any other person, you have obtained adequate consent from such person for sharing such information with us and our storage, processing and sharing of such information with any other person, under the terms hereof.
(e) If you are accessing or using our Services or the Website from an overseas location, you do so at your own risk, and shall be solely liable for compliance with any applicable local laws.
1. COLLECTION OF PERSONAL INFORMATION
All Personal Information that we collect about you will be recorded, used, and protected by us in accordance with applicable data protection legislation and this Privacy Policy. You may choose to not provide us with any or all information, but in the event that you do so, we may be unable to provide you with our Services or modify the nature of our relationship with you.
We strive to only collect Personal Information that is adequate, relevant, and limited to achieve the purpose(s) for which it was collected. If you are a user visiting our Website, visiting any of our office locations or availing our Services, you understand that certain personal information in the nature of your name, address, delivery address, email address, telephone number and Aadhaar details may be collected from you.
We may also collect Personal Information that you provide to us on our Website, register with us for availing the Services, inquire about our Services, post feedback, participate in any online survey, interact with us on social media, fill out any contact forms for us to assist you on the request raised by you, provide it to us directly such as through interactions with you.
Contact Forms: The Company provides you the possibility of contacting it by means of electronic contact forms. Using the form requires providing Personal Information necessary to contact you and answer the inquiry. You may also provide other Personal Information to facilitate contact or service of the inquiry. Providing data marked as mandatory is required in order to accept and handle the inquiry, and failure to do so results in the inability to process it. Providing other data is voluntary.
(a) Information collected through a User of Services
We may collect Personal Information when you avail our Services and schedule a delivery to an individual or an organization and provide us with such individual or company representative’s contact information such as name, email address, phone number and delivery address.
(b) Information collected automatically
Cookies and other tracking technologies
Similar to other website operators, we use standard technology called ‘cookies’ on our Website. Cookies are small pieces of information that are stored by your browser on your computer’s hard drive and they are used to record how you navigate this website on each visit. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
Tracking technologies may record information such as internet domain and host names, internet protocol (IP) addresses, browser software and operating system types, stream patterns, and dates and times that the Website is accessed. Our use of cookies and other tracking technologies allow us to improve our Website and your experience.
At all times, you may refuse all cookies on your browser by changing your settings to the extent permissible on your device. However, by doing so, you may not be able to use certain features on the Website or take full advantage of all the offerings and interest-based advertising.
Location Information
We may also infer your country of location from the IP address you have used to access our digital platforms and we may analyse which marketing activity led to your taking specific action on our digital platforms (e.g., downloading the app).
Personal Information
The IT Act and the SPDI Rules regulate the collection, usage, retention and disclosure of Personal Information, which is defined under the SPDI Rules as any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying such person. All Personal Information is provided by you to us voluntarily. By providing us your Personal Information, you provide your express consent to us to collect, store, process, transfer and disclose to third parties your Personal Information in accordance with the terms of this Privacy Policy.
2. USE OF PERSONAL INFORMATION
We use the Personal Information we collect to provide our Services to you and make them more effective. We may also use your Personal Information for the following purposes:
(a) to administer and provide products and services you request or have expressed an interest in and to run and improve our Website and Services as well as to help you use our Website and Services;
(b) for business purposes;
(c) to communicate with you in the event that any products or services you have requested are unavailable;
(d) for fraud screening and prevention purposes;
(e) for record keeping purposes;
(f) to carry out market research and product development purposes so that we can improve the products and services we offer;
(g) to track your activity on our Website;
(h) to personalise and improve your experience on our Website, and tailor any communications we may send you;
(i) to conduct audits and quality assessment procedures;
(j) to support our relationship with you, including customer or technical support services, and accounting and billing services;
(k) to the extent necessary, for any regulatory filing or for responding to government authorities;
(l) responding to judicial process or claims, and provide information to law enforcement agencies; or
(m) for any other purposes that are permissible under applicable law.
(collectively “Purposes”).
When you interact with our Website, we may also automatically collect the following information including Personal Information about your visit. This is primarily to help us better understand how you use our Website to enable us to create better content and more relevant communications:
(a) how you have reached our Website and the internet protocol (IP) address you have used;
(b) your browser type, versions and plug-ins and your operating system;
(c) your journey through our Website, including which links you click on and any searches you made, how long you stayed on a page, and other page interaction information;
(d) what content you like or share;
(e) which adverts you saw and responded to;
(f) which pop up or push messages you might have seen and responded to;
(g) your subscription status; and
(h) information collected in any forms you complete.
3. MARKETING COMMUNICATION
We want you to be the first to know about new products and services, and occasional offers from our partners. We may share these offers and any other marketing communication with you only with your prior consent. You can unsubscribe from receiving these offers by emailing us at privacy@pgpfirst.com. Please note, if you don’t choose to receive this information, we will be unable to keep you informed of new services, products, events or special offers that may interest you. An up-to-date list of our sponsors and partners is available by writing to us at privacy@pgpfirst.com.
4. DISCLOSURE AND TRANSFER OF YOUR PERSONAL INFORMATION
As a global business, PGP may share your personal data with PGP group companies including following any internal reorganisation, partners, associates, advisors, service providers, affiliates and trusted third parties based outside the country in which you live so that they may process that data on our behalf as necessary, in connection with providing our products and services to you, fulfilling contractual arrangements and legal or regulatory requirements. PGP requires that its service providers and other third parties keep your personal data confidential and that they only use the personal data in furtherance of the specific purpose for which it was provided to them.
We may disclose/ transfer your Personal Information to our group companies, partners, associates, advisors, service providers, affiliates and third parties as necessary or appropriate:
(a) For business purposes;
(b) To provide you our Services and understand how users use our Website or engage with us on the Website and enable us to create a better overall experience for you;
(c) To comply with legal process, whether local or foreign, or to respond to requests from law enforcement or government authorities where they have followed due legal process to request us to disclose the information, including public and government authorities outside your country of residence;
(d) To third party providers of services, If you have any queries about our third-party service providers or web analytics took providers, then you may contact us at privacy@pgpfirst.com. To web analytics tool providers; if you have any queries about our web analytics tool providers, then you may contact us at privacy@pgpfirst.com;
(e) To potential investors, or if we sell or buy any business or assets then a potential seller or buyer as a part of a potential sale or reorganization of business or assets, in part or as a whole, other arrangements as well as exploratory exercises in relation thereto, reorganization or a sale of our assets or business to such third party. Any third party to which we transfer or sell our assets will have the right to continue to use such Personal Information;
(f) To our auditors, legal advisers and other professional advisers; and
(g) To anyone that we must disclose information to in order to protect our rights, property or safety, our customers, or other third parties and to enforce our rights under this Privacy Policy or under any agreement with you. This includes exchanging information with other companies and organisations for the purposes of detecting and preventing fraud, credit risk and cyber-crime.
5. TRANSFERRING YOUR PERSONAL DATA
We may transfer your Personal Information, to servers located outside the country in which you live or to affiliates/ members of the PGP group companies or other trusted third parties based in other countries so that they may process personal data on our behalf. We will reasonably ensure that anyone processing your Personal Information, outside your country of origin is required to implement measures to protect it and is only entitled to process it in accordance with specific purposes.
Many countries do not provide the same legal protection to personal data as you might enjoy in your country of origin. While your personal data is in another country, it may be accessed by the courts, law enforcement and national security authorities in that country in accordance with its laws.
By using the Website or our Services, you accept the terms hereof and hereby consent to us sharing with and/or processing of your Personal Information by our group companies, affiliates, service providers, consultants, or third parties, including in any location outside India, provided that they ensure that your Personal Information is protected in compliance with standards that are comparable to the standards of protection afforded to it in India.
6. PLUG-INS FROM SOCIAL MEDIA PLATFORMS
Our Website may also use plug-ins from social media platforms. When you visit our Website that contains a plug-in, your browser will create a direct link to the servers of the social media platforms. They may receive information (including the Personal Information) about you, the fact that you have visited our Website, your IP-address and whether you have interacted with their plug-in at our Website. This data will be stored with the social media companies in the countries where they are located, including in the USA. The social media companies will receive the information whether you are a user on their social media platform or not.
You can prevent the social media plug-ins from loading by using a script-blocker add-on, which you can download for your browser.
We do not have any influence on the collection or processing of Personal Information that is carried out by social media platforms.
You can read more regarding how social media platforms process your data by reviewing the respective platforms’ privacy policies.
7. RETENTION OF PERSONAL INFORMATION
We will retain your Personal Information for the period necessary to fulfil the Purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.
8. SAFEGUARDING YOUR PERSONAL INFORMATION
We take all reasonable precautions to keep your Personal Information secure and require any third parties that handle or process your Personal Information for us to do the same. Access to your Personal Information is restricted to prevent unauthorised access, modification or misuse and is only permitted among our employees and agents on a need-to-know basis.
In order to protect your Personal Information in line with the applicable data privacy laws and regulations, we have implemented all appropriate technical and organizational measures as required under applicable law. Please be aware that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted through the Website. Once we have received your information, we will use strict physical, electronic, and procedural safeguards to try to prevent unauthorised access. We request that you cooperate with us in protecting your Personal Information and comply with the following personal security measures:
(i) Do not give third parties access to your computer or other devices when you access the Website;
(ii) Update your antivirus software when requested by your antivirus software provider; and
(iii) Do not send any confidential information by using the Website and/ or through our Services, unless specifically provided for in this Privacy Policy.
You agree that the security measures adopted by us are reasonable to protect your Personal Information. We disclaim any liability as a result of any breach of security or unintended loss or disclosure of your Personal Information. Notwithstanding anything contained in this Privacy Policy or elsewhere, we shall not be held responsible for any loss, damage or misuse of your data/information, if such loss, damage or misuse is attributable to a Force Majeure Event. A “Force Majeure Event” shall mean any event that is beyond our reasonable control and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, etc.
9. YOUR PRIVACY RIGHTS AND WHO TO CONTACT
We provide you with reasonable access to view and review your Personal Information and request correction and deletion where appropriate or withdraw your consent. In order to protect your privacy, we will take reasonable steps to verify your identity before granting access to your Personal
Information.
You have the right to tell us if you:
(a) Would like to withdraw your consent from the collection, processing and storage of your Personal Information which must be withdrawn in writing and in accordance with the terms of the Privacy Policy. Please note that withdrawal of consent will not be retrospective in nature and shall be applicable prospectively. In case you do not provide your information or consent for usage of Personal Information or subsequently withdraw your consent for usage Personal Information the Company reserves the right to discontinue the services for which the said information was sought;
(b) don’t want to be contacted in the future by us;
(c) would like a copy of the Personal Information which we hold about you;
(d) would like to delete or modify your Personal Information in our records;
(e) wish to report any misuse of your Personal Information; or
(f) would like to have your Personal Information transferred to a third party.
You agree and acknowledge that in respect of any data or information which cannot be corrected or amended pursuant to any applicable law, law enforcement requests or judicial proceedings or the like, the aforementioned rights will not be available.
Should you choose to update your Personal Information or modify it in a way that is not verifiable by us, or leads to such information being incorrect, we will be unable to provide you with access to our Website or the Services. We reserve the right to verify and authenticate your identity and your Personal Information in order to ensure that we are able to offer you all our Services. We can only keep your Personal Information up-to-date and accurate to the extent you provide us with the necessary information, and we are not responsible for the authenticity of such information provided by you. It is your responsibility to notify us of any changes in your Personal Information. Access to or correction, updating or deletion of your Personal Information may be denied or limited by us if it would violate another person’s rights and/or is not otherwise permitted by applicable law. You should be aware that some of the Personal Information that may have been shared on third-party websites may still continue to be available as we do not have control over these websites. Your Personal Information may also appear in online searches. Other Personal Information that you have shared with others, or that other users have copied, may also remain visible. You should only share Personal Information with people that you trust because they will be able to save it or re-share it with others, including when they sync the Personal Information to a device. In certain circumstances, we are not required to comply with your request due to exemptions or where applicable law does not require us to comply.
10. CHILDREN’S PRIVACY POLICY
Use of the Website or our Services is available only to persons who can form a legally binding contract under the Indian Contract Act, 1872. If you are under 18 (eighteen) years of age, then please do not use or access the Service(s) at any time or in any manner. If you are a parent or guardian and discover that your child under 18 (eighteen) years of age has visited the Website or otherwise accessed the Services, then you may alert us at privacy@pgpfirst.com and request that we delete that child’s Personal Information from our systems.
We do not knowingly collect Personal Information from users who are less than 18 (eighteen) years of age. Upon discovery of any Personal Information of any child, we shall purge such Personal Information in accordance with applicable law.
11. GRIEVANCE REDRESSAL AND CONTACT US
If you have questions about this Privacy Policy or any grievances in relation to the collection and processing of your Personal Information, you can contact us at:
Attention:
Grievance Officer: Mr. Sudip Mazumder
Email address: sudip.mazumder@pgpfirst.com
12. MISCELLANEOUS
(a) Disclaimer: We cannot ensure that all of your Personal Information will never be disclosed in ways not otherwise described in this Privacy Policy. Therefore, although we are committed to protecting your privacy, we do not promise, and you should not expect, that your information (including Personal Information) or private communications will always remain private. As a user of the Website or our Services, you understand and agree that you assume all responsibility and risk for your use of the Website, the internet generally, and the information you post or access and for your conduct on and off the Website.
(b) Indemnity: You agree and undertake to indemnify us in any suit or dispute by any third party arising out of disclosure of information by you to third parties either through our Website or otherwise and your use and access of websites, applications and resources of third parties.
(c) Severability: Each clause of this Privacy Policy shall be and remain separate from and independent of and severable from all and any other clauses herein, except where otherwise expressly indicated or indicated by the context of the Privacy Policy. The decision or declaration that one or more clauses are null and void shall have no effect on remaining clauses of this Privacy Policy.
(d) Limitation of Liability: The Company shall not be liable for any consequential, incidental, special, indirect, exemplary or punitive damages, or damages for any loss of profits, revenue or business, regardless of the nature of the claim, even the Company has been notified of the possibility of such damages.
(e) Governing Law and Jurisdiction: This Privacy Policy shall be governed by the laws of India as applicable between residents of India without regard to any principles of conflict of laws. Any and all disputes arising hereunder shall be subject to the exclusive jurisdiction of the courts at Mumbai, India.
13. CHANGES TO OUR PRIVACY POLICY
We reserve the right to change, modify, add or delete portions of this Privacy Policy and may do so from time to time and upload the updated version of the same on our Website. We encourage you to visit frequently to stay informed about how we use your Personal Information. If we make a significant change to the way we use your Personal Information, we will use reasonable efforts to contact you to tell you. Your continued use of the Website and/or the Services means that you accept and agree to the changes in the Privacy Policy.
14. HANDLING PRIVACY CONCERNS
If you have any questions about this Privacy Notice or concerns about how we handle your personal data, then you may contact us at privacy@pgpfirst.com.
| Version Control | ||||
|---|---|---|---|---|
| Version No. | Effective Date | Prepared By | Approved By | Description |
| 1.0 | February 16, 2024 | IT Team | Board | Policy adoption |
