Introduction

This Privacy Policy statement describes the usage of information provided or collected, disclosed or transferred of your information by Nelco Limited including subsidiaries of Nelco Limited (hereinafter referred to as "NELCO", "We", "Us", "Our", "Company"). We follow this privacy policy in accordance with applicable law in the places where we operate. In some cases, we may provide additional data privacy notices specific to certain services.

It is important that you read this Privacy Notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing Personal data/Sensitive Personal Data or Information about you, so that you are fully aware of how and why we are using your information. This Privacy Notice supplements the other notices and is not intended to override them.

Scope of this Privacy Policy

Nelco is committed to protecting your privacy. This Privacy Policy explains what personal data we collect about you when conducting business transactions, when you communicate with us, when you use our website (www.nelco.in), when you visit our premises, or when you apply for a job with us.

Nelco reserves the right to modify this Privacy Policy at any time. Please periodically review this privacy policy so that you know, among other things, what personal data we collect, how we use it, and with whom we may share it.

By visiting the Site and continuing to use our services, you acknowledge that your Personal data/Sensitive Personal Data or Information will be handled as described in this Policy. As used herein, "Personal data/Sensitive Personal Data or Information" means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Nelco customer or vendor/supplier employee or consumer or his or her household. Your use of our Services and any dispute over privacy is subject to this Policy.

Glossary
  • Data principal i.e. you, the user. A data principal is essentially the person to whom the data 'belongs'
  • Data fiduciary i.e. the entity that controls the storage of the data and defines the permitted ways it can be processed
  • Data processor i.e. the entity that processes that data collected by a data fiduciary
  • Personal Data: This refers to data that may contain information about any characteristics or traits of a person and can be used to identify said person.
  • Sensitive Personal Data: This refers to certain categories of data such as: financial data, health data, official identifiers; data on sexual orientation and activity, biometric data, genetic data, transgender status, intersex status, caste or tribe status, and religious or political belief or affiliation.
How data is collected?

We collect information about you only if we need the information for some legitimate purpose. Nelco will have information about you only if (a) you have provided the information yourself, (b) Nelco has automatically collected the information or (c) Nelco has obtained the information from a third party.

Below we describe the various scenarios that fall under each of those three categories and the information collected in each one.

a) Information that you provide us

i. Personal data that you provide when you contact us:

When you contact us online, submits details through forms on our website, per e-mail, post or by phone or by any other means, we may process the following types of personal data: Name, email address, name of the organization you work for, details about your question, request, and other information you provide to us when you contact us.

ii. Personal data that we may process about you if you are our investor, customer or supplier:

When you interact with us as investor, customer or supplier, we may process the following types of Personal data/Personal data/Sensitive Personal Data or Information: Name, title, company name and address, email address, telephone number, bank details of the investor/company, unique administration number, supply and product information and other information you provide to us.

iii. Personal data that we may process about you when you apply for a job at Nelco:

We regularly post our vacancies online on external job listing websites. You may apply for a vacancy directly via our website or contact through third party vendors/job portals. We may also approach potential candidates by using other channels, such as external recruitment agencies, external job listing websites or social media websites. In order to process your application, we may process the following types of Personal data/Sensitive Personal Data or Information: Name, gender, religion, nationality, date of birth, health details, telephone number, email and mailing address, language(s), information included in your CV or resume (may include a photo), your information included on external job listing websites, education, professional background, working experience, salary expectations/current salary, attachments to the application such as certificates, etc.

When in the application process, we may also process notes taken during the interview(s), assessments, medical and other test results, results of background checks and reference checks.

b) Information that we collect automatically

i. Information from browsers, devices and servers:

When you visit our website, we collect following parameters using Google Analytics- Sessions, Users (unique & returning), average time spend, bounce rate, page views, exit pages, location (domestic & international), traffic source (organic, direct, social media, referral, others (paid campaigns, email, etc.) and device traffic (desktop, laptop, mobile or tablet).

ii. Information from third party cookies and tracking technologies:

We use only third-party cookies and tracking technologies on our website. You can learn more about the cookies used on our websites here.

c) Information that we collect from third party

As merchant on record:

When you buy from us inflight connectivity services, we as sub processor act as merchant on record. Any information provided by you while purchasing connectivity services either inflight or preflight to our processor or payment gateway is subject to their privacy policy and terms. In order to provide you service as sub processor we get information about you from our processor (like order Id, email ID, name, flight details, service details and amount) and from payment gateway (like order Id, amount and GST number). We need this information for payment reconciliation and provide you customer support services. We don’t collect/get credit card information or other payment account information.

Purposes and lawfulness of processing

We will only use Personal data/Sensitive Personal Data or Information about you where we have lawful basis. Lawful basis on which we would store and use your Personal data/Sensitive Personal Data or Information includes obtaining consent from you for "legitimate interests" or "legitimate purpose" where processing is necessary by us to provide you with services and/or business purpose.

Information use by NELCO

We may process your Personal data/Sensitive Personal Data or Information broadly for the following purposes and this is not an exhaustive list:

General

  • To offer and improve our goods and services;
  • Conducting satisfaction and market research surveys;
  • Promoting our company and our goods and services;
  • To ensure the continuity of our services;
  • To handle questions, requests and complaints;
  • To comply with our internal policies, establish Internal control, protecting our assets and the security and integrity of our systems and data;
  • To comply with our statutory obligations and requests of authorities.

Investors

  • To provide investors related services

Customers including potential customers

  • Facilitate a purchase / providing services, including making payment, or to otherwise conduct a business transaction, creating a customer account;
  • Notify you about status of delivery of your order;
  • Send you informational communications and maintaining contact with you;
  • Validate credentials, authenticate customers and prevent fraudulent transactions;

Suppliers

  • Administrating and managing supply chain fulfilling business requirement;
  • Administrating and managing purchases, executing and registration of agreements;
  • Maintaining contact with you.

Job applicants / candidates

  • Administering the recruitment process;
  • Handling job applications;
  • Assessment of suitability as a candidate, conducting background checks;
  • Inviting candidates for an interview and giving follow-up to the interview;
  • Informing applicants and candidates on the outcome of the recruitment process.

Users of our website

  • Operate and improve our website.

The Personal data/Sensitive Personal Data or Information supplied by you enables us to contact you and provision of products / services. All required information is subject to the dependent business processes and the Company may use the above said user Information to maintain, protect, and improve the products / services provided by the Company.

Any personally identifiable information provided by you will not be considered as sensitive if it is freely available and / or accessible in the public domain like any comments, messages, blogs, scribbles available on social platforms like Facebook, Twitter, LinkedIn, etc.

Any posted / uploaded conveyed / communication by users on the public sections of the websites / social media pages/s' becomes published content and is not considered personally identifiable information to this Privacy Notice.

In case you choose to decline to submit personally identifiable information, we may not be able to provide certain services to you. We will make reasonable efforts to notify you of the same for the associated business purpose. In any case, we will not be liable and / or responsible for the denial of certain services to you for lack of your providing the necessary Personal data/Sensitive Personal Data or Information.

When we process your information, we may contact you from time to time about updating your Personal data/Sensitive Personal Data or Information to provide you with information that we believe may benefit / interest you.

Retention and Disposal of Personal Data

We will only retain your Personal data/Sensitive Personal Data or Information as long as necessary to fulfill the purposes we collected it for, including the initiation of a contract, fulfillment of the contract, or for the purposes of satisfying any legal, accounting, or other regulatory reporting requirements.

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

We do not sell or distribute the Personal data/Sensitive Personal Data or Information for general or marketing purpose. We collect, store and use the Personal Data/Sensitive Personal Data or Information for business and service purpose for which the same is intended and as referred in this Notice.

External links on our websites

Some pages of our website may contain links to websites that are not linked to this Privacy Policy. If you submit your Personal data/Sensitive Personal Data or Information to any of these third-party sites, your Personal data/Sensitive Personal Data or Information is governed by their privacy policies. As a safety measure, we recommend that you not share any Personal data/Sensitive Personal Data or Information with these third parties unless you've checked their privacy policies and assured yourself of their privacy practices.

Social media widgets

Our websites include social media widgets such as LinkedIn "share" buttons that let you share articles and other information. Your interactions with these widgets are governed by the privacy policies of the companies providing them.

Your Rights

Data principals may have numerous rights in relation to their personal data.

  • Right to confirmation and access: Data principals may request in writing copies of their personal data. However, compliance with such requests is subject to certain limitations and exemptions and the rights of other individuals. You may also be required to submit a proof of your identity.
  • Right to correction: Data principals may request that we correct any inaccurate or incomplete personal data.
  • Right to be forgotten (restrict processing): Data principals may request that we restrict our processing of their personal data in various circumstances. We will comply, unless there is a lawful reason for not doing so, such as, a legal obligation to continue processing your personal data in a certain way.
  • Right to erasure: Data principals may request that we erase their personal data. We will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping the personal data, such as, our business record retention obligations that we have to comply with.

These rights can be exercised by sending us an e-mail to dpo@nelco.in.

Data Principal will have to attach a copy of your ID or equivalent details (where requested by us and permitted by law). If the request is submitted by a person other than you, without providing evidence that the request is legitimately made on your behalf, the request will be rejected. Please note that any identification information provided to us will only be processed in accordance with, and to the extent permitted by applicable laws.

Please note that, we may be required to retain some of your Personal Data after you have requested deletion, to satisfy our legal or contractual obligations. We may also be permitted by applicable laws to retain some of your Personal Data to fulfil our business requirements.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Data Security

We have put in place reasonable security measures to prevent your Personal data/Sensitive Personal Data or Information from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal data/Sensitive Personal Data or Information to those employees, vendors, third parties and business associates who have a business need to know. They will only process your Personal data/Sensitive Personal Data or Information on our instructions (as data processors), and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach. In the event we are required by law to inform you of any unauthorized access to your Personal data/Sensitive Personal Data or Information we may notify you electronically, in writing. We will also notify any applicable regulator of a breach where we are legally required to do so.

However, no method of transmission over the Internet, or method of electronic storage, is fully secure.

We use and apply all reasonable efforts to protect your Personal data/Sensitive Personal Data or Information from unauthorized access, use, or disclosure. However, we could not rule out seepage or breach that is beyond control or due to human error or due to any technological hindrance.

Changes to Privacy Notice

We may alter our privacy notice from time to time to incorporate necessary changes in technology, applicable law or any other variant. In any case, we reserve the right to change (at any point of time) the terms of this Privacy Notice. Any changes we make will be effective immediately on notice. Your use of the products / services offered after such notice will be deemed acceptance of such changes. We may also make reasonable efforts to inform you via electronic mail.

Contact Us

Support

If you require any information or clarification regarding the use of your Personal data/Sensitive Personal Data or Information or this privacy notice or grievances with respect to use of your Personal data/Sensitive Personal Data or Information, please contact dpo@nelco.in.

Complaints

If you have any queries, complaints regarding the collecting, processing, transfer of personal data/information or regarding this notice please contact us at dpo@nelco.in.

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