This is the privacy statement of Eva-Excelsior Solutions Pvt. Ltd and its controlled entities. We recognize the importance of protecting the privacy and the rights of individuals in relation to their personal information in compliance with data protection laws.
Please note, if you are a prospective or current employee, separate privacy information may be made available to you during the recruitment process, and/or via your Eva-Excelsior Solutions Pvt. Ltd’s HR Business Partner. If you are a contractor, separate privacy information may be made available to you.
The laws governing collection and use of your personal information may vary from country to country. As we operate globally, we may adopt stricter practices to protect your personal information than is required by law in your country. This statement sets out general principles with respect to Eva-Excelsior Solutions Pvt. Ltd’s practice on the collection, use, and disclosure of personal information that applies to the use of Eva-Excelsior Solutions Pvt. Ltd websites and other interactions with Eva-Excelsior Solutions Pvt. Ltd.
By visiting our website or using our products and services, you acknowledge the terms of this statement and the use and disclosure of your personal information as set out in this statement.
Our contact details are set out herein below.
This privacy statement was last updated in June 2020.
1. What is your personal information and what personal information is collected by Eva-Excelsior Solutions Pvt.Ltd?
When we refer in this statement to “personal information” we are referring to any information that can be used to identify you. The types of personal information that we collect from you will depend on how you interact with Eva-Excelsior Solutions Pvt. Ltd. We collect your personal information from you in the following ways.?
1.1. Personal information we collect directly from you
We generally collect your personal information directly from you when you act on behalf of a purchasing organization. When your organization purchases products or services from us, you will be asked to provide personal information. This information is likely to include your name, employer name, contact title, phone, email, and other business contact details (this is not an exhaustive list). We will also collect information on your interests, preferences, and survey and feedback responses as part of our business interest in developing and enhancing our services for our customers.
1.2. Business contacts and suppliers
We collect certain limited personal information about our business contacts, including subcontractors and individuals associated with our contractors and subcontractors, and service providers (including professional advisors and individuals associated with our service providers). Personal information collected in this context usually includes (but may not exclusively be) name, employer name, contact title, phone, email, and other business contact details. Depending on the nature of the services the individuals associated with our contractors and subcontractors, and service providers provide to us, we may also require from those individuals sensitive personal information and other personal information which includes information on the individual’s nationality and right to work, any criminal records, and health and medical screening information (for example, the results of drug and alcohol testing). Where required by applicable law, we will request your consent to the processing your sensitive personal information.?
1.3. Eva-Excelsior Solutions Pvt. Ltd website
When you visit our website, we may collect the following information from you directly and/or automatically. This is to say (the list is not limited to or exhaustive): information you provide to us if you contact us, for example, to request general business and product/service information; and details of visits made to our website such as the volume of traffic received, the domain name used, type of browser used, referring website, resources accessed and other logs (including, server address, the internet protocol (IP) address, location of the device connecting to our website, and other identifiers about the device and the date, time and nature of the visit).
1.4. Incident data
If you are involved in an incident at one of our sites, you will be required to submit personal information (including name and contact details) in order to assist us in managing our response to the incident.
1.5. Other query data
If you are lodging a query or complaint, you will be invited to submit personal information (including name and contact details) in order to assist us in responding to you.
2. For what purpose do we collect, hold and use your personal information?
We use your personal information for the following non-exhaustive list of purposes:
2.1. Providing our products and services
We use your personal information in order to carry out our obligations as a result of any contract entered into between your organization and us and to provide your organization with the products and services that you request from us.
2.2. Receiving services
We process personal information in relation to our suppliers, service providers, and their staff as necessary to receive the services in question. For example, where a supplier is providing us with facilities management or other outsourced services, we will process personal information about those individuals that are providing services to us.
We also use personal information in relation to our suppliers, service providers, and their staff to maintain up to date records of appropriate qualifications and experience of third parties, with respect to transport, handling or storage of goods sold by us.
2.3. Administering, managing and developing our businesses and services
We process personal information in order to run our business, including:
managing our relationship with customers;
our businesses and services (such as identifying customer needs and improvements in products and service delivery);
promoting our products and services;
maintaining our own accounts and records;
maintaining and using IT systems;
hosting or facilitating the hosting of events; and
administering and managing our website and systems and applications.
2.4. Providing our clients with information about us and our range of products and services
We use customer business contact details to provide those individuals with information that we think will be of interest about us and our products, services and business operations, and information on safe use and handling of products. For example, industry updates and insights, other services that may be relevant and invite to events and training.
2.5. Complying with any requirement of law, regulation or a professional body of which we are a member
We are subject to legal, regulatory and professional obligations. We need to keep certain records to demonstrate that we are in compliance with those obligations and those records may contain personal information, for example in order to:
comply with laws and regulations relating to access to security-sensitive products;
participate in document disclosure processes mandated by law, such as discovery in court proceedings, or responding to subpoena or notices to produce information issued by competent authorities (for example, in some circumstances, a law enforcement agency or other government agency may exercise its legal authority to inspect personal information held by us); and
notify or report to emergency services and other regulatory bodies.
2.6. Improving our products and services
We are continually looking for ways to help our customers and improve our products and services. We may use information that we receive in the course of providing our products services for other lawful purposes, including analysis, research and development to better understand a particular issue, industry or sector, provide insights back to our customers, to improve our business, service delivery and products and to develop new technologies and offerings.
We may also use your personal information to undertake research on enhancing safety, health, environment and security management, including longitudinal studies based on historic incidents.
We may contact you for direct marketing purposes, in order to provide you with information about our products and services that we consider may be of interest to you. These marketing communications may be sent either directly by Eva-Excelsior Solutions Pvt. Ltd or through appointed third-parties in various forms, including but not limited to email, mail, telephone, SMS or fax. We may seek your consent to send you marketing communications where we are required to do so to comply with applicable laws (for further information please see the relevant section below).
At any time you may opt-out of receiving marketing communications from us by:
contacting us at the contact details set out in the section below;
contacting our third-party vendors whom you are receiving the communication from; or
clicking on the unsubscribe link on any marketing communication that you receive from us.
Please note that if you opt-out of receiving marketing communications from us, we will still send you safety, security, or service-related messages to the extent permitted by applicable laws.
We will only use your contact details to market Eva-Excelsior Solutions Pvt Ltd’s products and services. We do not provide your personal information to other organizations for the purpose of allowing them to market their products and services to you.
We may contact you to participate in surveys, in order to enhance the quality of Eva-Excelsior Solutions Pvt Ltd’s products and services to our customers. These survey communications may be sent either directly by Eva-Excelsior Solutions Pvt Ltd or through appointed third-parties in various forms, including but not limited to email, mail, telephone, SMS or fax. We may seek your consent to send you to survey communications where we are required to do so to comply with applicable laws (for further information please see the relevant section below).
At any time you may opt-out of receiving survey communications from us by:
contacting us at the contact details set out in the section below;
contacting our third-party vendors whom you are receiving the communication from; or
clicking on the unsubscribe link on any survey communication that you receive from us.
Please note that if you opt-out of receiving survey communications from us, we will still send you safety, security, or service-related messages to the extent permitted by applicable laws.
2.9. The processing required by law
We may use your personal information if we believe doing so is required or appropriate to:
comply with law enforcement or national security requests and legal processes, such as a court order or subpoena;
respond to your requests;
protect yours’, ours’ or others’ rights, property, or safety;
to enforce our policies or contracts;
to collect amounts owed to us; or
when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity.
3. Practical consequences of not providing your personal information
If you do not provide us with the personal information described in the section above, or we do not disclose it as described in the section of this statement, then we may not be able to perform the activities for which we collect personal information as effectively, through your use of this website, as described in section 2 of this statement. For example:
we may not be able to provide the requested products or services, or important information about them, to you or your organization, either at all or to the same standards;
we may be limited in our ability to consider you or your organization as a service provider for us, or we may not be able to respond to your questions or complaints promptly and effectively.
4. To whom may we disclose your information?
We may share your personal information with the following categories of recipients:
4.1. Other companies within the Eva-Excelsior Solutions Pvt Ltd’s Group
Your personal information will be used by us and disclosed to other companies within the Eva-Excelsior Solutions Pvt Ltd’s Group (including our head office and all of its subsidiaries).
If you are buying products or services from us on behalf of an organisation, your personal information will be used by us and disclosed to the organization which you represent.
4.3. Service providers
We may disclose your personal information to third party service providers who require access to such information for the purpose of providing specific services to us. These third parties will generally only be able to access your data in order to provide us with their services and will not be able to use it for their own purposes. Such services will include archival, auditing, accounting, community relations, customer or investor contact, legal, business consulting, banking, debt collection (including to list overdue debt with credit rating agencies where permitted by law), human resources, payment, delivery, data processing, research, training, website or technology services.
4.4. Regulatory bodies
We may disclose your personal information:
to regulators, law enforcement agencies, government agencies, and judicial or administrative bodies;
to data protection regulatory authorities; and to other regulatory authorities with jurisdiction over our activities.
4.5. Professional advisers, auditors and other third parties
We may disclose your personal information to professional advisors (such as legal advisors and accountants), auditors or other third parties for the purpose of providing professional services to us, or to enable us to enforce or defend our rights, only to the extent reasonably necessary, including without limitation to a rights holder in connection with an allegation of intellectual property infringement or other breach of a legal, equitable, or contractual obligation.
5. Disclosure of your personal information overseas
Our principal operations are in India, but we interact with people all over the world. The information that we collect from you may be transferred to, and stored at, destinations both within and outside India.
In compliance with data protection laws, we want to make sure that your personal information is stored and transferred in a way which is secure. We will therefore only transfer information overseas where it is compliant with data protection laws and the means of transfer provides adequate safeguards in relation to your information.
We are subject to a range of requirements, which require us to take steps to protect the security of personal information, and we take reasonable steps to ensure your personal information is protected from misuse, interference and loss, and from unauthorised access, modification or disclosure. The measures we employ include firewalls, encryption secure premises and data access controls.
Unfortunately, there is always risk involved in transmitting any data electronically, and any information, which you transmit to us online is transmitted entirely at your own risk (you also need to take active steps to protect against security risks on any system that you use). Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted over the internet and we do not warrant the security of any information, including personal information, which you transmit to us over the internet.
Please contact us using the details, if you become aware of any breach of security or privacy of your personal information.
6.1. Right to rectification
You have the right to request that we rectify any inaccurate or incomplete personal information that we hold about you. If we have shared this personal information with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. You may also request details of the third parties that we have disclosed the inaccurate or incomplete personal information to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
6.2. Where using your information is in our legitimate interests
We are allowed to use your personal information where it is in our interests to do so, and those interests aren’t outweighed by any potential prejudice to you.
We believe that our use of your personal information is within a number of our legitimate interests, including but not limited to:
to enable us to provide our products and services to our customers;
to provide you with marketing communications about our products and services;
to help us understand our customers better and provide better, more relevant products and services to them; and
to help us keep our systems secure and prevent unauthorised access or cyber-attacks.
We do not believe that any of the activities set out in this statement will prejudice you in any way.
6.3. Where using your personal information is necessary for us to carry out our obligations under our contract with you
We are allowed to use your personal information when it is necessary to do so for the performance of our contract with you. For example, we need to collect your payment details in order to be able to process payments for our services.
6.4. Where processing your personal information is necessary for us to carry out our legal obligations
As well as our contractual obligations to you, we also have other legal obligations that we need to comply with and we are permitted to use your personal information when we are required to do so, in order to comply with those other legal obligations.
6.5. Where processing your personal information is necessary for us to establish, exercise or defend legal claims
Sometimes it may be necessary for us to process personal information and sensitive personal information in connection with exercising or defending legal claims. Applicable data protection law may allow us to do this where the processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.
6.6. Where processing your personal information is necessary in order to protect your vital interests or the vital interests of another natural person
Sometimes it may be necessary for us to process personal information and sensitive personal information in connection with protecting your vital interests or the vital interests of another natural person.
11. How to contact us
If you have any questions about this statement, any concerns or complaints regarding the treatment of your privacy, or would like to notify us of a possible infringement of your privacy, please contact us at:
Address/ E mail – firstname.lastname@example.org
Please ensure that your email includes the country that you are based in so that we can best respond, as in some countries there are separate specific personnel tasked with data governance issues for that region.
We will attempt to confirm, as appropriate and necessary with you, your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will inform you whether we will conduct an investigation and the estimated completion date for the investigation process.
After we have completed our inquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, we will assess it and advise if we have changed our view.
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