Data Protection Policy of Trelleborg India Pvt Ltd

SCOPE AND PURPOSE

This policy is applicable to the processing of customers' Personal Data by us. The purpose of this policy is to provide our current, former and potential customers (jointly referred to as "customers" or "you") with a general understanding of:

The circumstances under which we collect and process your Personal Data
The types of Personal Data we collect
The reasons for collecting your Personal Data
Distribution of responsibility for the Processing of Personal Data
Our contact details so you can receive information about and claim your rights in relation to our processing of your Personal Data.

The Privacy Policy covers both “online” and “offline” activities in relation to providing for sale to our business customers, sealing solutions and product offerings which include but are not limited to O-Rings, hydraulic seals, rotary shaft seals, oil seals, static seals, pneumatic seals, mechanical face seals (collectively referenced as the “Products and Services”).

This policy is updated continuously to reflect the measures taken by us in relation to your Personal Data.

DEFINITIONS

The following term which are used in this policy along with their definition are provided as below:

Anonymous data or anonymized data - This is the category of data which is not identifiable to a natural person. Even if coupled with other information, identification of such natural person is not possible.
Consent – Any freely given, informed and unambiguous statement which maybe given by a clear affirmative action maybe referred to as consent.
Cookies – A cookie is a small piece of data given to a web browser by a web server. The browser stores the data in a text file so it can be sent back to the server each time the browser requests a page from the server. Cookies have the capacity to store some of your personal data. For more details on what cookies we use and what personal data we store through the use of cookies you may refer to our cookie policy here.
Data Subject or Information Provider – This refers to the natural person to whom the personal or sensitive personal data relates to.
Data Controller or Body Corporate – This refers to the Company who is determining the means and purposes of data processing. For the purposes of this policy, Trelleborg India Pvt. Ltd. will be considered as the “Data Controller” or “Body Corporate”.
Personal data – This refers to any information that relates to you, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person. Any information collected by us, which cannot be identified directly or indirectly to a natural person, is outside the purview of this Policy.
Processing- It means any operation or set of operations, performed on personal data or sets of personal data, including but not limited to processing by automated means. This may include collection, recording, structuring, alteration, adaptation, organization, use, disclosure, dissemination, alignment or combination and analysis of your personal data. Anonymization of data is also a form of processing.
Pseudonymization – A processing technique where the processed data is not identifiable to a natural person unless coupled with some other information. This data is kept separately with technical and security standards since this data may be converted personal data.
Sensitive personal data – This refers to data which includes certain sensitive information such as a person’s password, financial information, physical, physiological and mental health conditions, sexual orientation, medical records and history, biometric information, etc. We wish to share that we do not collect or process any of your sensitive personal data.
Third Party - third party’ means a natural or legal person, public authority, agency or body other than the data principal, data fiduciary, processor and persons who, under the direct authority of the data fiduciary or processor, are authorized to process personal data.

DETAILS OF THE ENTITY COLLECTING OR PROCESSING PERSONAL DATA

Trelleborg India Pvt. Ltd. and its affiliates (the ‘Company’, ‘we’ or ‘us’) having its registered office at 22/9, Beratana Agrahara, Hosur Main Road, Bangalore 560100, is the Data Controller or Body Corporate (i.e., the entity which would be collecting and processing personal data) under this Privacy Policy. Our range of products includes O-Rings, hydraulic seals, rotary shaft seals, oil seals, static seals, pneumatic seals, mechanical face seals and such.

Trelleborg India Pvt. Ltd. uses technical and organizational security measures in order to protect your data managed by us from accidental or intentional manipulation, loss, destruction or access by unauthorized persons. Our security measures will be improved continually according to the technological developments. You may take a look at our security policy here.

If you have any queries under this Privacy Policy or want clarification about our processing of your personal information, you can connect with our data officer at TSS.India.DataProtection@trelleborg.com. We will resolve your queries within one calendar month.

TYPE OF PERSONAL INFORMATION AND MANNER OF COLLECTION

We may collect and process certain personal information pertaining to you. The type of information we may require may change depending on whether you have just created an account, or whether you are using the Self-Service Portal for creating a quotation, placing your order, reviewing/tracking your order, or intending to initiate a return of the order. We may also collect personal information in case you wish to change your account particulars, settings or payment information.

We wish to assure you that your personal information is safe with us. We will only process your personal information lawfully and for purposes, details of which we have provided in the next section

The following are the types of personal information pertaining to you:

Full Name of the individual placing the order
Name, Billing and Shipping Address of Business Entity on whose behalf an order is placed
Phone Number
Email Address
System related information which includes:
- the web browser you used to access our website,
- the operating system used,
- the domain name of the internet service provider,
- the truncated IP address of the computer you use,
- the website from which you visit us,
- the page you visit on our site and
- the date and duration of the visit

Of the above types of personal information, only the name and phone number are considered to be personal data. Other particulars constituting business information is not personal data. We wish to share that the system related information cannot be used to identify you as an individual user. We only evaluate the data statistically and use it only to improve attractiveness, contents and functions of our websites.

The personal information may have been provided by you, may have been collected by us during our interaction with you, or may have been obtained by us from third parties or from our affiliates.

Personal information you give to us: This is information about you that you give to us by entering information via our Self-Service Portal, or by corresponding with us by phone, email or otherwise and is provided entirely voluntarily. The information you give to us includes your name, contact details (such as phone number, email address and address), etc., for example provided at the time of registering with for our Self-Service Portal.

Personal Information we collect about you: Some additional information may be collected via your computing device or system when you are using our Self-Service Portal or when you visit our Website. When you visit our Website, usage data may be collected automatically through the Website. Such usage data can include the type of device, the IP address, and location. This is for security reasons; in particular, to prevent and detect attacks on our websites or attempts at fraud. We also collect information about your click and search behaviour. We use this data to adjust the Website or enhance our Products and Services. We may collect information through cookies for the purposes of advertising and analytics. We collect usage data by using various types of cookies (small pieces of data stored in your device) and other tracking tools.

You are free to opt-in or opt-out to the use of cookies when you first visit the Website or use the App. You can choose, at the time of opting in, for what purposes are the Cookies used. Consent, once provided, can be withdrawn at any time by altering your cookie preferences in the browser or in your App. The retention period of cookies is limited and differs per cookie. Disabling cookie collection through your browser or device or changing your consent but this may result in some features of the Services not functioning properly and we will not be able to send customized and relevant communication or promotional messages to you. The Cookie privacy policy may be accessed here. [[link to be provided]]

Personal information we may receive from other sources: We may also receive information from our subsidiaries, affiliates, or parent companies or other third-party companies with whom you may have engaged previously.

In any instance, we will use the personal information we obtain from these sources for the purposes as mentioned below. The remaining provisions of this policy also apply to any personal information we obtain from these sources as well.

PURPOSE OF COLLECTION AND PROCESSING OF PERSONAL INFORMATION

Your personal information is collected at one or more of the following stages:

When you create a user account and provide us your information (the “User Account”);
When you visit our website (the “Website”);
When you check for product availability;
Email Address
When you are creating your quotation
When you wish to check and confirm your order;
When you wish to check your order status or when you wish to track your order;
When you wish to cancel or initiate a return request;
When you wish to change any particulars in the User Account;
When we undertake activities such as servicing;
When we communicate our promotional activities or offerings, etc.

Your personal information will generally be used to enable us to serve you better. This may include the following:

to provide you with Products and Services, which include:
- Processing and completing your order;
- Providing you with information about various models and Product offerings;
- Providing you with information and updates about your order;
to offer you additional offers or Product offerings while using the website;
to inform you of updates to, or changes in, our Products and Services;
to share any changes to our Terms and Conditions and policies;
to inform you of new Products, Services, Offerings and Events;
to provide support and servicing in an efficient and timely manner;
to respond to specific queries for which you may have contacted us;
for product development purposes, for example seeking feedback to improve performance, quality and safety of our Products;
to evaluate and improve our offering to, and communication with you and other customers;
to comply with legal requirements or lawful authority requests;
to inform you about our Products and Services and identify those that may be of interest to you;
to carry out market research;
for analysis and customer profiling purposes (online and social included) performed by our Analytics Partner.

Where reasonably practical or if required by applicable law, we will obtain your consent prior to collecting or using your Personal Information. The request for your consent will be clear and specific and provide you with a reasonable basis on which to make your decision. We will make sure that you can provide your consent in a clear and transparent manner. Your consent is voluntary and may always be revoked, for example by terminating a particular service or contacting our representative in the manner indicated in later sections. As mentioned before, where your consent is required and you do not give your consent, it may not be possible for you to avail the Services being offered by us.

HOW INFORMATION IS PROCESSED

The information may be processed by our Self-Service Platform, Website or through our partners for completing your order and/or complying with your requests. Your Personal Information is processed by us under different circumstances and under different lawful basis. The same is provided below for your information:

Where you have provided CONSENT

We may use and process your personal information where you have consented for us to do so for the following purposes:

Process your name, contact information, such as your email ID and contact number to create a user account on our platform
Process your personal information, such as your name, contact information and an address for purposes of billing and shipping the Products that you may have ordered;
Where you have requested a call back for further information about our Products and Services. Such information may be further processed when you have inquired about a Product or have purchased a Product;
Process your personal information, such as contact information, for processing and completing your purchase order;
Processing personal information as indicated above to process a return, if you are not happy with your order,
Enable processing of payments (or refunds as the case may be) on your behalf by using personal information;
If you have opted for periodic updates, sending you regular intimations regarding your order;
Processing personal information for servicing and/or repair activities;
To supply brochures and other material you have specifically requested from us;
Where you have opted in, to be contacted by us or by our authorised dealers or our recommended third-party partners via email, text message, post or telephone with marketing information about their Products and Services (see Marketing section below for further details); and
Complete and perform other processing activities that you have expressly requested us to complete or you have expressly agreed to us performing, as the case may be. In such cases, we will again be taking your consent for such requested processing activities.

Your data is yours – if you wish to withdraw your consent at any time, you can let us know at TSS.India.DataProtection@trelleborg.com.

WHERE REQUIRED TO PERFORM A CONTRACT WITH YOU

When you place an order for one or more Products, you enter into a legally binding contract. We may use and process your personal information where it is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract with you including, but not limited to, for the following purposes.

To provide information pertaining to your purchase in order to complete your order;

For post-sale activities, as contractually agreed, in relation to your Product or order;

For contacting or sharing information to assist you with any information in relation to your order; and

To share your contact information with our Delivery Partner for having your order delivered to you.

WHERE IT IS NECESSARY IN EMERGENT SITUATIONS

We may use your personal information to reach to you if there are any urgent safety or product recall notices to communicate to you to ensure your safety.

WHERE THERE IS A LEGITIMATE INTEREST OR FOR OTHER REASONABLE PURPOSES

We may use and process your personal information where it is necessary for us to pursue our legitimate interests and for other reasonable purposes as a business without compromising your privacy for the following purposes:

for analysis which will aid our marketing strategy;
to improve, enhance and personalise your customer experience while visiting or interacting with our Website or Self-Service Portal;
for market research in order to continually improve the products and services that we offer to you;
to manage and maintain our websites, and for internal practices, including troubleshooting, testing for security, statistical purposes, and for prevention of any misuse or fraud;
for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access of your personal information, and for ensuring that the underlying systems operate with efficiency;
for marketing activities (other than where we rely on your consent), e.g., to tailor marketing communications or send targeted marketing messages via social media and other third-party platforms;
to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our ‘marketing black lists’ in order to be able to comply with your request. Please refer to our Marketing Section for more details); and
to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings.

FOR COMPLIANCE WITH EXISTING OR APPLICABLE LAWS

Wherever the law mandates us to process certain data for compliance or other legal purposes, we will have to collect your information to abide by it.

MARKETING

MARKETING BASED ON VOLUNTARILY PROVIDED DATA

We may from time to time run promotional campaigns at different locations or have salespeople designated for brand outreach. Any data voluntarily provided by you during the afore-stated interactions shall be presumed to be based on consent. This data shall be used to reach out to you for promotional offers/direct marketing campaigns run by us. The legal basis for such markets is based on your consent. Such consent may be revoked at any time by reaching out to us.

MARKETING BASED ON YOUR ONLINE WEB BEHAVIOUR DATA

When you visit our website(s), and if you consent to the use of cookies, we collect and process your IP address, information on your browsing on our website, e.g. product interest and configuration, device information, unique online identifiers and interaction in relation to our ads on third-party websites (your “Online Web Behaviour Data”). Such data is collected by cookies that we and third parties place on our website and in our app. For more information regarding the cookies used, please consult our cookie policy

The legal ground for placing, collecting and having access to information from cookies is your consent. The purpose of our processing of the Online Web Behaviour Data is to identify you as return visitor to our website, to analyze the behaviour of the visitors to our website, to enhance our communication and structure of our website and to build a profile of your interests to be able to show you relevant adverts for our products and services also on other websites. The profiles we create based on your Online Web Behaviour Data can for example include, “people who wishes to be contacted via email rather than phone". The profiles we create may also be based on few criteria, such as your behaviour on our website and product interest.

All data that we store about you for these purposes may also be stored in pseudonymised form, meaning that the information stored about you is connected to an online identifier. The data that we use has been collected by cookies and we always ask for your consent to place these cookies before collecting and storing the data. To this end, we have a legitimate interest to process your personal data for these purposes. You always have the possibility to object to this processing by withdrawing your consent to the use of cookies. For instructions to do so, please refer our cookie policy which is accessible at ___________.

MARKETING BASED ON YOUR PERSONAL DATA, THIRD-PARTY DATA AND ONLINE WEB BEHAVIOUR DATA

If you consent, we may combine your Online Web Behaviour Data with data obtained from third-party data providers. If you provide your consent when interacting with us, e.g., when signing up for a newsletter, information about our products and other updates, we will combine the personal data that you have provided when interacting with us with your Online Web Behaviour Data and with data obtained from third-party data providers. Further, if any personal data has been voluntarily provided to us during our physical promotional activities or at our affiliate stores/sites evincing your interest in our products, we will use this data and reconcile it with your online web behaviour data and data obtained from third parties wherever possible. Thus, for such processing the legal basis will be consent.

The data obtained from third parties consist of data that have been collected through cookies and may include information regarding your personal preferences, demographics and content consumption including your browser history.

The Personal Data that you have provided in connection with your interaction with us may consist of name, email address, and phone number. If you consent, we may combine this data with your Online Web Behaviour Data for the purposes of sending you targeted marketing through email, on our websites and other websites you visit By doing this, we will for example be able to send you personalised marketing by email.

SHARING/TRANSFER OF PERSONAL DATA

We might share your personal information with our partners in order to improve our service. We make sure that they are as committed as we are to protect your data and information.

OUR BUSINESS OUTLETS

Our outlets may use your information to better fulfil your order, handling special requests, offering personalised offers, and keeping you informed of relevant information and news.

SERVICE PARTNERS AND ANALYTICS PARTNERS

We share information with companies that provide services on our behalf. This includes:

Website hosting
Email services
Marketing
to manage and maintain our websites, and for internal practices, including troubleshooting, testing for security, statistical purposes, and for prevention of any misuse or fraud;
Processing customer orders
Data analytics
Customer service
Customer research and satisfaction surveys
Auditing
Contests and promotions

These companies all have strict obligations to protect your information.

CORPORATE AFFILIATES

We may share information with other group companies and transfer it to a third party in case of a merger or reorganisation.

COMPLIANCE AND SECURITY

It may be necessary for us to disclose your personal data to governmental and public authorities for reasons of national security, law enforcement or other issues of public importance. Where legally permitted we will inform you ahead of such transfer.

We may also disclose personal information if we determine in good faith that disclosure is necessary to protect our rights, resolve legal conflict, enforce our terms and conditions, investigate fraud or protect our users.

INTERNATIONAL TRANSFERS

We may transfer your Personal Data to recipients in countries outside India. In such instances, we will ensure that such countries have equivalent or more comprehensive data protection framework so that your data remains safe. For example, your data may be stored in servers located in Stuttgart, Germany which are managed by our parent entity. We may transfer your Personal Data to recipients in countries that may not have an adequate level of protection for Personal Data. In those instances, we will ensure that appropriate safeguards are in place for that transfer and storage.

RETENTION

We will only retain your Personal Data for as long as it is necessary to fulfil the purposes outlined in this policy or the purposes of which you have otherwise been informed. This means that when you have consented to our Processing of your Personal Data, we will retain the data for as long as the customer relationship lasts (and, where applicable, until the expiry of the warranty period) or until you withdraw your consent. If you have revoked your consent, we may nevertheless retain certain Personal Data for the period required in order for us to meet our legal obligations and defend ourselves in legal disputes. If we have not received your consent for Processing, the Personal Data will only be retained to the extent we are permitted to do so by law.

RIGHTS OF INDIVIDUALS

If you live anywhere in India, the law has various rights bestowed on you in relation to your personal data. We will have to confirm your identity, wherever applicable, to ensure that your rights are being exercised appropriately. To exercise these rights you will have to write to us at TSS.India.DataProtection@trelleborg.com. Except in exceptional circumstances, we will respond to your request within 30 days from the date we receive your email. We may charge a minor sum to comply with your exercise of these rights to aid the cost we incur for this compliance. You will be informed of these charges once you write to us. You have the following rights under applicable laws in your country -

1. ACCESSING YOUR PERSONAL INFORMATION

You have the right to access a copy your personal information that we hold in a standard form that will be easy and understandable. In rare occasions we may not provide you with a copy of your information in which case we will convey you this message with appropriate reasons. Generally, we can only deny you your right of access if it concerns the right of other individuals or we have another lawful reason to withhold that information and not otherwise. You also have the right to access in one place the identities of the data fiduciaries with whom your personal data has been shared by us together with the categories of personal data shared with them,

2. VERIFY AND RECTIFY

Accuracy is an important principle of data protection and you have the right to verify your information with us and ask us to rectify it if it is inaccurate. You can correct, complete and update your name, address, contact details and other personal information you give us.

LODGING OF COMPLAINT

UPON ACCEPTANCE OF THIS PRIVACY POLICY OR BY CONTINUING TO USE THE WEBSITE OR APP, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY.