BACKGROUND:
Phoenix Mecano India Private Limited, understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our Clients, Business customers, Suppliers Service providers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information About Us
Company Name : Phoenix Mecano India Private Limited.
Registered address: 388, Bhare Taluka Mulshi, Pirangut Industrial Area, Pune, India, 412115.
Data Protection Officer: Mr Amit Dokania.
Email address: dpo@phoenixmecano.in
Telephone number: +91 (0)20 66745100
Postal address: 388, Bhare Taluka Mulshi, Pirangut Industrial Area, Pune, India, 412115.

2. What Does This Policy Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

3. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 216/679 ) (the “GDPR”) and collectively, “the data Protection Legislation”  including any applicable national laws, regulations, such as Information Technology Act 2000 and the Information Technology (Amendment) Act 2008, as amended, replaced, or updated from time to time; as  ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’ .
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.

4. What Are Your Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. we do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please inform us, as long as we have that data.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the appropriate authorities. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.

5. What Personal Data Do You Collect and How?
Depending upon your use of Our Site, we may collect, hold and use some or all of the personal data as mentioned below. We do not collect any ‘special category’ or ‘sensitive’ personal data.
1.information about your computer and about your visits to & use of our website including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, frequency of visit, page views, website navigation.
2.information that you provide to us for the purpose of registering with our services.
3.information that you provide to us for the purpose of subscribing to our website services, email notifications and/or newsletters

6. How Do We Use Your Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. We may use your personal data for:
– Business Communication and related transactions
– Supplying our products or services to you
– Managing payments for our products and services
– Personalizing and tailoring our products and services for you
– Information you subscribed
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or text message and/or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and you will always have the opportunity to opt-out.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

7. How Long Will We Keep Your Personal Data?
We may retain your Personal Data to fulfil the purposes it was collected for as long as needed, as allowed or as required by law. For instance, we may retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, prevent fraud and abuse and fulfil and enforce our agreements.

8. How and Where Do We Store or Transfer Your Personal Data?
All Personal Data supplied to us is stored on robust and reliable systems that are continually monitored and updated as per the latest security practices for data protection.
We may store or transfer some or all of your personal data in countries that are not part of the EEA. These are known as “”third countries” and may not have data protection laws that are as strong as those in the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the EU and under the Data Protection Legislation.
We share your data within our group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to the personal data usage.These are known as “binding corporate rule”.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
1.limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
2.procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or appropriate authorities where we are legally required to do so Please contact us using the details below in Part 11 for further information about the particular data protection mechanism(s) used by us when transferring your personal data to a third country.

9. Do We Share Your Personal Data?
We may share your personal data within our group of companies as a part of business communication to either explore new business opportunities or service your better. This includes Phoenix Mecano Group holding company and its subsidiaries.
We may sometimes contract with third parties to supply and services. If any of your personal data is shared with a third party, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations  under the law, as described above in Part8.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the EU and under the Data Protection Legislation, as explained above in Part 8.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

10. How Can You Access Your Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “Subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. You will need to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive'(for example,if you make reptitive request) a fee may be charged to cover our administrative costs.
We will respond to your subject access request within one month of receiving it. Normally we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of two months from the date we have receive your request. You will be kept fully informed of your request.

11. How Do You Contact Us?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details.
Contact Details of DPO
Data Protection Officer: Mr Amit Dokania.
Email address: dpo@phoenixmecano.in
Telephone number: +91 (0)20 66745100.
Postal address: Phoenix Macano (India) Pvt. Ltd., 388, Bhare Taluka Mulshi,
Pirangut Industrial Area, Pune , India, 412115.

12. Changes to this Privacy Policy
PMIL reserves the right to modify or amend this policy at any time as it may deem necessary. Should you have any questions in relation to this policy, please contact DPO.
This Privacy Policy was last updated on 16th April 2020

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