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Version – May, 2018

SCOPE

This Privacy Policy applies to any devices, website, applications or software, services offered by Havells Group (Havells, Crabtree, Lloyd, Standard, REO) that refers to or links to the Privacy Policy (collectively, our “Services”). The Privacy Policy applies to all employees, vendors, contractors, partners, consumers and influencers etc. regardless of whether you use a computer, mobile phone, tablet, TV, or other device to access our Services.

INFORMATION WE COLLECT

We collect various types of information in connection with the Services, including:
Information you provide directly to us;
Information we collect about your use of our Services; and
Information we obtain from third-party sources.

We also use the information we collect in ways described to you at the point of collection, or otherwise with your consent.

USE AND SHARING OF INFORMATION
We use the information we collect (and may combine it with other information about you) to, among other things:

Provide the Services you request;
Understand the way you use the Services so that we can improve your experience; and
Provide customized content and advertising.
We also use the information we collect in ways described to you at the point of collection, or otherwise with your consent.

We may share your information with:
Business partners—trusted companies that may provide information about products and services you might like.
Service providers—companies that provide services for or on behalf of the Havells Group.
Law enforcement—when we are required to do so or to protect Havells Group and its users.

HAVELLS PRIVACY POLICY

Havells India Limited and our affiliates (“Havells,” “we,” “us,” “our”) know how important is it to maintain the privacy of our customers, and we therefore are very cautious about how we collect, use, disclose, transfer and store your information. The Privacy Policy applies to the Havells Group devices, websites or online applications that refer to or link to the Privacy Policy (collectively, our “Services”).

This Privacy Policy applies to the Services, however any additional consent will be obtained for certain data processing activities.

Please note that the Privacy Policy applies to your usage of Havells Group devices (which are among the Services covered by this Privacy Policy, along with our websites, applications or software). It also applies regardless of whether you use a computer, mobile phone, tablet, TV, or other device to access our Services. It is important that you read the Privacy Policy carefully because anytime you use our Services, you consent to the practices we describe in the Privacy Policy. If you do not agree to the practices described in the Privacy Policy, you should not use our Services.

It also is important that you check back often for updates to the Privacy Policy. If we update the Privacy Policy, and we consider it to be material, we shall highlight the same by placing a note on relevant Services. By accessing or using our Services after we have placed such a notice, you consent to the new practice(s) identified in the update. The most current version of the Privacy Policy will always be available here . You can check the “effective date” posted at the top to see when the Privacy Policy was last updated.

What information do we collect about you?

Information you provide directly

Some Services enable you to give us information directly. For example:

A number of our Services enable users to create accounts or profiles. In connection with these Services, we may ask you to provide certain information about yourself to set up the account or profile. For example, you can submit certain information about yourself, such as your name and email address, when you create a login account with us.

Some of our Services enable you to communicate with other people. Those communications will be transmitted through and stored on our systems.

Information about your use of the Services

In addition to the information you provide, we may collect information about your use of our Services through software on your device and other means. For example, we may collect:

Device information—such as your hardware model and other unique device identifiers, MAC address, IP address, operating system version, and settings of the device you use to access the Services. Log information-such as the time and duration of your use of the Service, search query terms you enter through the Services, and any information stored in cookies that we have set on your device.

Location information—such as your device’s GPS signal or information about nearby WiFi access points and cell towers that may be transmitted to us when you use certain Services.

Other information about your use of the Services, such as the apps you use, the websites you visit, and how you interact with content offered through a Service.

Information from third-party sources - We may receive information about you from publicly and commercially available sources (as permitted by law), which we may combine with other information we receive from or about you. We also may receive information about you from third-party social networking services when you choose to connect with those services.

If you order a product or paid service online, the third-party sources managing online activities may ask for your name, contact information, shipping and billing address(es), and credit card information in order to process your order.

Other Information We Collect - We also may collect other information about you, your device, or your use of the Services in ways that we describe to you at the point of collection or otherwise with your consent which is taken at the time you start using our services.

You can choose not to provide us with certain types of information (e.g., information we request during account registration), but doing so may affect your ability to use some Services.

How do we use your information? - We may use information we collect for the following purposes to:

a. register you or your device for a Service;
b. provide a Service or feature you request;
c. provide customised content and make recommendations based on your past activities on our Services;
d. for advertising, such as providing customised advertisements and sponsored content (including through our advertising service, AdHub, whose practices you can learn more about here) and sending you promotional communications;
e. for assessment and analysis of our market, customers, products, and services (including asking you for your opinions on our products and services and carrying out customer surveys);
f. understand the way people use our Services so that we can improve them and develop new products and services;
g. provide maintenance services for your device;
h. conduct free prize drawings, prize competitions or promotions, as permitted by law; and otherwise with your consent.
i. combine information we collect from you and use it for purposes consistent with this Privacy Policy.

To whom do we disclose your information? - We will not disclose your information to third parties for their own independent marketing or business purposes without your consent. However, we may disclose your information to the following entities without your consent:

Affiliates. Your information may be shared amongst the Havells Group and affiliates.
Business Partners. We also may share your information with trusted business partners, including wireless carriers. These entities may use your information to provide you with services you request (e.g., video content provided by Netflix through SmartTV), make predictions about your interests and may provide you with promotional materials, advertisements and other materials.
Service Providers. We also may disclose your information to third parties that provide services for or on behalf of us, such as companies that run service centres, help us with billing or that send emails on our behalf. These entities are limited in their ability to use your information for purposes other than providing services for us.
Other Parties When Required by Law or as Necessary to Protect Our Services. There may be instances when we disclose your information to other parties to:
a. Comply with the law or respond to compulsory legal process (such as a search warrant or other court order, etc.);
b. verify or enforce compliance with the policies governing our Services; and
c. Protect the rights, property, or safety of Havells Group, or any of our respective affiliates, business partners, or customers.

Other Parties in Connection With Corporate Transactions. We may disclose your information to a third party as part of a merger or transfer, or in the event of a bankruptcy.

Other Parties With Your Consent or At Your Direction. In addition to the disclosures described in this Privacy Policy, we may share information about you with third parties when you consent to or request such sharing.

Your Choices. We offer a variety of choices about how we use your information. You can make choices about whether to receive promotional communications from us by following the unsubscribe instructions included in the communication. In addition, you can also generally make choices in your settings in your login account.

And you may be able to make choices in specific Services or when we give you a just-in-time notice.

What do we do to keep your information secure? We have put in place reasonable physical and technical measures to safeguard the information we collect in connection with the Services. However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system or wireless connection is completely secure.

Consent to International Transfer of Data: By using or participating in any Service and/or providing us with your information, you consent to the collection, transfer, storage and processing of your information outside of your country of residence, consistent with this Privacy Policy. Please note that the data protection and other laws of countries to which your information may be transferred might not be as comprehensive as those in your country.

Accessing Your Information: You may have the right to request details about the information we collect and to correct inaccuracies in that information. Any further statutory user rights remain unaffected. If permitted by law, we may charge you a small fee for providing you with this ability. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. If you would like to make a request to access your information, please contact our customer service department at www.havells.com.

Data Retention: We take reasonable steps to ensure that we retain information about you only for so long as is necessary for the purpose for which it was collected, or as required under any contract or by applicable law.

Third-Party Links and Products on Our Services: Our Services may link to third-party websites and services that are outside our control. We are not responsible for the security or privacy of any information collected by websites or other services. You should exercise caution, and review the privacy statements applicable to the third-party websites and services you use.

We also may make available to you certain products or services (e.g., apps available through app stores) developed by third parties. Havells Group is not responsible in any manner whatsoever for these third-party products or services.

Third Parties that Provide Content, Advertising or Functionality on Our Services: Some of the content, advertising, and functionality on our Services may be provided by third parties that are not affiliated with us. For example:
a. We enable you to watch video content provided by companies such as Netflix through SmartTV;
b. Third parties develop apps that we make available through the various apps of the Havells Group;
c. Certain third parties may serve advertising or keep track of which advertisements users see, how often they see those advertisements, and what users do in response to them; and
d. We enable you to share certain materials on the Services with others through social networking services such as Facebook, Twitter, Google +, and LinkedIn.
e. These third-parties may collect or receive certain information about your use of the Services, including through the use of cookies, beacons, and similar technologies, and this information may be collected over time and combined with information collected across different websites and online services. Some of these companies participate in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising.

If you connect with a social networking service, we may receive and store authentication information from that service to enable you to log in, as well as other information that you allow us to receive when you connect with these services.

Also, please note that if you choose to connect with a social networking service on a device used by people in addition to you, those other users may be able to see information stored or displayed in connection with your account on the social networking service(s) with which you connect.

Cookies, Beacons and Similar Technologies: We, as well as certain third parties that provide content, advertising, or other functionality on our Services, may use cookies, beacons, and other technologies such as internet of things (IOT), Blockchain, Artificial Intelligence (AI) etc.in certain areas of our Services.

Cookies: Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices, and/or browsing sessions.
Cookies serve many useful purposes. For example:

a. Cookies can remember your sign-in credentials so you don’t have to enter those credentials each time you log on to a service.
b. Cookies help us and third parties understand which parts of our Services are the most popular because they help us to see which pages and features visitors are accessing and how much time they are spending on the pages. By studying this kind of information, we are better able to adapt the Services and provide you with a better experience.
c. Cookies help us and third parties understand which ads you have seen so that you don’t receive the same ad each time you access a Service.
d. Cookies help us and third parties provide you with relevant content and advertising by collecting information about your use of our Services and other websites and apps.
When you use a web browser to access the Services, you can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. The operating system of your device may contain additional controls for cookies.

Please note, however, that some Services may be designed to work using cookies and that disabling cookies may affect your ability to use those Services, or certain parts of them.

Other Local Storage: We, along with certain third parties, may use other kinds of local storage technologies, such as Local Shared Objects (also referred to as “Flash cookies”) and HTML5 local storage, in connection with our Services. These technologies are similar to the cookies discussed above in that they are stored on your device and can be used to store certain information about your activities and preferences. However, these technologies may make use of different parts of your device from standard cookies, and so you might not be able to control them using standard browser tools and settings. For information about disabling or deleting information contained in Flash cookies, please click here.

Beacons: We, along with certain third parties, also may use technologies called beacons (or “pixels”) that communicate information from your device to a server. Beacons can be embedded in online content, videos, and emails, and can allow a server to read certain types of information from your device, know when you have viewed particular content or a particular email message, determine the time and date on which you viewed the beacon, and the IP address of your device. We and certain third parties use beacons for a variety of purposes, including to analyse the use of our Services and (in conjunction with cookies) to provide content and ads that are more relevant to you.

By accessing and using our Services, you consent to the storage of cookies, other local storage technologies, beacons and other information on your devices. You also consent to the access of such cookies, local storage technologies, beacons and information by us and by the third parties mentioned above.

If you wish to make a complaint about our handling of your personal information, you may contact us using the details set out in this Privacy Policy with your full name and contact details and a detailed description of your complaint. We will use reasonable efforts to respond to you as soon as possible to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint.

Further information

If you have any specific questions and:

a) If you are an external party such as customer, dealer etc. of Havells
You may choose to visit our site at any time to check or review or revise the following information or data provided by you by contacting us via email or customer helpline number given on our website www.havells.com.

b) If you are internal staff of Havells group, please contact your respective helpdesk

Provide customised content and make recommendations: We may use information we collect to provide you with customised content and make recommendations that are based in part on your past activities on our Services. For example, Your SmartTV provides recommendations about video content you might like. Please visit the settings menu on your device or service for information about privacy choices you may have available to you in connection with these services.

Improve them and develop new products and services: We may use information we collect to understand the way you use the products and services we offer so that we can improve them and develop new products and services. For example, we may use this information to make better-informed decisions about the design of our devices and the selection of Havells Group and third-party content that is accessible through our devices and services.

Affiliates: The term ‘affiliates’ refers to companies related to Havells India Ltd. by common ownership or control.