Privacy Policy

Effective Date: September 2022

We, Havells India Ltd. (“we”, “us”, “our”, “”) are committed to protecting your privacy. This Privacy Policy (“Policy”) describes our practices in connection with information privacy on Personal Information we process through your individual use of our mobile application and the services.

In this Privacy Policy, “Personal Information” means information that can be used to identify an individual, either from that information alone, or from that information and other information we have access to about that individual. “App” refers to the mobile application that provides an elated user experience towards making home a smart home.

BY USING THE APP AND BY OTHERWISE GIVING US THE PERSONAL INFORMATION, YOU WILL BE DEEMED TO HAVE READ, UNDERSTOOD AND AGREED TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND AGREE TO BE BOUND BY THIS PRIVACY POLICY. YOU HEREBY CONSENT TO OUR COLLECTION, USE AND SHARING, DISCLOSURE OF THE PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. WE RESERVE THE RIGHT TO CHANGE, MODIFY, ADD OR DELETE PORTIONS OF THE TERMS OF THIS PRIVACY POLICY, AT OUR SOLE DISCRETION, AT ANY TIME. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AT ANY TIME, DO NOT USE ANY OF THE SERVICES OR PROVIDE US ANY PERSONAL INFORMATION

IF YOU AVAIL THE SERVICES ON BEHALF OF AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU HAVE BEEN AUTHORISED TO (I) ACCEPT THIS PRIVACY POLICY ON BEHALF OF SUCH PATIENT OR ENTITY, AND (II) THE PATIENT AND/OR ENTITY HAVE CONSENTED TO OUR COLLECTION, USE AND DISCLOSURE OF SUCH ENTITY’S INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.

WHY THIS PRIVACY POLICY?

This Privacy Policy is published in compliance with, inter alia:

i. Section 43A of the Information Technology Act, 2000;

ii. Regulation 3 and 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”).

What Personal Information do we collec

In order to provide our services to you, we will ask you to provide necessary Personal Information that is required to provide those services. If you do not provide your Personal Information, we may not be able to provide you with our Smart Products or services.

i. Information You Voluntarily Provide Us

· Account or Profile Data: When you register an account with us, we collect your name and contact details, such as your email address, phone number, user name, and login credentials. During your interaction with our Smart Products, we may further collect your nickname, profile picture, country code, language preference or time zone information into your account.

· We access your camera when you scan the bar code and register products in the App. We use photos and media for uploading invoices and update user profile.

· Feedback: When using feedback and suggestion features in our Smart Products, we will collect your email address, mobile phone number and your feedback content to address your problems and solve device failures on a timely basis.

ii. Information We Collect Automatically

· Device Information: When you interact with our Smart Product, we automatically collect device information, such as the MAC address of your devices, IP address, wireless connection information like bluetooth, wi-fi, operating system type and version, application version number, push notification identifier, log files, and mobile network information.

· Usage Data: During your interaction with our Sites and Services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our sites and services.

· Log Information: When you use our App, the system and exception log may be uploaded.

· Location Information: We may collect information about your real-time precise or non-precise geo-location when you use our specific Smart Products or services, such as robot cleaner and weather service.

· Contact list: We may access contacts when you opt to share the Device with family and friends.

iii. Smart Devices Related Information:

· Basic Information of smart devices: When you connect your smart devices with our Smart Products or services, we may collect basic information about your smart devices such as device name, device ID, online status, activation time, firmware version, and upgrade information.

Purposes and legal basis for processing Personal Information

The purpose for which we may process information about you are as follows:

· Provide You Services: We process your account and profile data, device information, usage data, location information, and Smart Device related information to provide you with our Smart Products and services that you have requested or purchased. The legal basis for this processing is to perform our contract with you according to our Terms of Use.

· Improve Our Services: We process your device information, usage data, location information and Smart Device related information to ensure the functions and safety of our Smart Products, to develop and improve our Smart Products and services, to analyze the efficiency of our operations, and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is to perform our contract with you according to our Terms of Use.

· Non-marketing Communication: We process your Personal Information to send you important information regarding the services, changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important, you may not opt-out of receiving such communications. The legal basis for this processing is to perform our contract with you according to our Terms of Use

· Marketing Communication: We may process your Personal Information to provide marketing and promotional materials to you on our Smart Products and services. If we do so, each communication we send you will contain instructions permitting you to opt-out of receiving future communications of that nature. The legal basis for this processing is your consent. Additionally, if you consent to participate in our lottery, contest or other promotions, we may use your Personal Information to manage such activities.

· Personalization: We may process your account and profile data, usage data, device information to personalize product design and to provide you with services tailored for you, such as recommending and displaying information and advertisements regarding products suited to you, and to invite you to participate in surveys relating to your use of our Smart Products. The legal basis for this processing is your consent.

· Legal Compliance: We may process your Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Who do we share Personal Information with?

We only share Personal Information in ways that we tell you about. We may share your Personal Information with the following recipients:

· To our third-party service providers who perform certain business-related functions for us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, and other similar services to enable them to provide services to us.

· To our customers and other business partners who provide you, directly or indirectly, with your smart devices, and/or networks and systems through which you access and use our sites and services.

· To an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings). In such an event, you will be notified via email and/or a prominent notice on our website of any change in ownership, incompatible new uses of your Personal Information, and choices you may have regarding your Personal Information

· As we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Except for the third parties described above, to third parties only with your consent.

International Transfer of Information Collected

To facilitate our operation, we may transfer, store and process your Personal Information in jurisdictions other than where you live. Laws in these countries may differ from the laws applicable to your country of residence. When we do so, we will ensure that an adequate level of protection is provided for the information by binding the party managing such information

If you would like further detail on the safeguards we have in place, you can contact us directly as described in this Privacy Policy.

Your Rights Relating to Your Personal Information

We respect your rights and control over your Personal Information. You may exercise any of the following rights:

· Request access to the Personal Information that we process about you;

· Request that we correct inaccurate or incomplete Personal Information about you;

· Request deletion of Personal Information about you;

· Request restrictions, temporarily or permanently, on our processing of some or all Personal Information about you;

· Request transfer of Personal Information to you or a third party where we process the data based on your consent or a contract with you, and where our processing is automated; and

· Opt-out or object to our use of Personal Information about you where our use is based on your consent or our legitimate interests.

Consent

Collection, use and disclosure of information which has been designated as Personal Information or Sensitive Personal Data or Information’ under the SPI Rules requires your express consent. By affirming your assent to this Privacy Policy, you provide your consent to such use, collection and disclosure as required under applicable law. If you do not agree to this Privacy Policy, you should discontinue using the App and/or Services and delete your account accordingly.

Security

We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Information. We provides various security strategies to effectively ensure data security of user and device. However, for any data loss or theft due to unauthorized access to the user’s electronic devices through which the user avails the services, we shall not be held liable for any loss whatsoever incurred by the user. As for data storage, all confidential information of users will be safely encrypted for storage. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you could immediately notify us of the problem by emailing customercare@havells.com

Data Retention

We process your Personal Information for the minimum period necessary for the purposes set out in this Privacy Policy, unless there is a specific legal requirement for us to keep the data for a longer retention period. We determine the appropriate retention period based on the amount, nature, and sensitivity of your Personal Information, and after the retention period ends, we will destruct your Personal Information. When we are unable to do so for technical reasons, we will ensure that appropriate measures are put in place to prevent any further such use of your Personal Information.

Changes to this Policy Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (send to the e-mail address specified in your account) or by means of a notice in the mobile applications prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us

If you have any questions about our practices or this Privacy Policy, please contact us as follows:

Email-ID: customercare@havells.com

Customer Care No : 08045771313

WhatApp Support: 9711773333