PRIVACY POLICY (SUMAIRO)

This Privacy policy has been designed to control any misuse of the Privacy of information of the Users / business entities while availing the services provided by the Sumairo Platform. Further this policy should be read along with the “Terms of Use” document and any terms not defined specifically in this policy shall have the same meaning as ascribed in the “Terms of Use” as updated from time to time.

The User by accessing or using the Sumairo Platform or even otherwise sharing some information shall be deemed to have read, understood and agreed to the terms of the polices detailed in this Privacy Policy. The policy provide in depth details on the procedure followed by Sumairo platform as part of providing services, the procedure for collecting, processing, using the Users Information shared for accessing the platform or availing any services. The policy also defines the process onto which the information collected in any way i.e. telephone, email or personally, is disclosed or shared by the platform. It is submitted that Users on accessing the platform have automatically been deemed to not only have agreed but also given their consent to all the terms and processes followed by the Privacy Policy and Terms of Use.

The User’s visit to and / or use of the Platform and any dispute over privacy is subject to this Privacy Policy and the Terms of Use. Sumairo may update this Privacy Policy at any time, with or without advance notice to the Users.

This policy is owned and operated by Sumairo which is owned by KLJ (The Company)

The “Platform” shall mean this internet based electronic B2B e-commerce platform Sumairo, and / or an application in the form of mobile application, website and/or web page or any other mode or application.

This Privacy Policy governs the usage of information and the ways in which User can protect Users privacy. This Privacy Policy is published in pursuant to

• Section 43A of the Information Technology Act, 2000:
• Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011:
• Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPDI Rules”), is applicable to all users of the Platform and visitors of the Platform.

As part of the journey of being associated with the Sumairo Platform and / or Mobile Application, Sumairo would be privy to User personal information, which may or may not be of a confidential in nature or which may be personal or information available in public domain or acquired by platform during the transaction process. Sumairo is further committed to protecting the privacy of all the Users for which it has taken/will take all necessary measures to maintain the confidentiality of the User information, interaction with platform and its transmission. Sumairo shall not be held liable for disclosure of the confidential information if such disclosure is in accordance with this Privacy Policy or in accordance with the terms of any agreements entered with the users. Sumairo asserts not to disclose all information, except in circumstances as detailed later in the policy organizations that visit the platform and provide information through any of the modes. According to the prevalent rules, any sensitive personal data or information of a person means and includes such personal information about that person relating to:

• Each User’s use of and access to the Platform, is primary based on acceptance of the “Terms of Use”, and the terms of this Privacy Policy. Any User who does not agree with any provisions of the Terms of Use or this Privacy Policy is advised not to use the Platform. It is to be clearly understood that the User shall be wholly responsible for the accuracy and correctness of the information shared with platform having no liability pertaining to its genuineness and shall not be liable for any wrongful information or negligence on the part of the User. Further all information disclosed is with Users consent which is specific, unconditional and is deemed to disclosed willingly without coercion.
• User as part of REGISTRATION PROCESS for creating an account is required to share details of profile such as
  • a. User Name and KYC details for Body Corporate, Firm/LLP, HUF, Individual, etc.
  • b. Email id and website
  • Nature of business activity, industry segment/type
  • Mobile no./Landline/Office no. of authorised person
  • GST, PAN, TAN, CIN etc. of User
  • Country of residence, operating locations
  • Billing Address or other demographic Information such Postal code, IP location etc.
  • Gender in case of individual
  • Products and services of interest
  • Details of authorised employees in case of corporate or non-corporate entity.
  • Compliance especially Chemical Licences status
  • Any other document(s)
• As part of providing platform transactions of purchase/sale of products and provision of services, User may be required to provide details of payment modes in the form of Debit or Credit card, electronic-transfer, or other applicable modes of payments, third-party payment gateway platforms (in Sumairo platform) or to regular bank account of the Platform. In addition, in order to get financing of transactions, User may need to both in terms of eligibility and credit exposure options, may be required to share additional information to Sumairo or to other potential financing partners (NBFC) which inter alia would require financial information like credit / debit card details, bank account details, bank statements for specified period, annual reports, GST data, PAN, Credit Rating, Tax payment status if any, etc. All such Financial and other Information collected from the Users’ by Sumairo’ or its third-party payment gateway providers or financiers will be used for billing/payment processes besides to evaluate/provide financing exposures options.
• The platform also collects other information by using various technologies including third party technologies or as part of communication with the User. This collection of information assists in understanding the needs of the Users which are continuously enhanced to match the present and future needs of the User. Sumairo may collect personal and non-personal information by accessing any social media sites regarding of the User. Sumairo also collects information based on Users purchase order details for product and services including both present and past, pricing information and completed transaction references. The User shall submit such personal information as belongs to the User as part of terms of the Privacy policy. In case the User uses the Platform on behalf of someone else or entity, User shall provide documents to represent that User has authorised and accepts this Privacy Policy and its use by other person. The User also represents that it is expressly providing such consent on behalf of such entity to Sumairo collection, use, sharing, processing and disclosure of such entity’s information as described in this Privacy Policy. All the above personal information may also be provided to third party in connection with enhancement of experience of the platform and its services. As part of the process of providing timely information of services and product portfolio, Sumairo may create certain algorithms and use Artificial intelligence in order to provide and predict certain preferences, Product behavior patterns, Users choices & pursuits, social value systems or such attributes. These are derived based on the analysis of Users use and patterns of use which may not be complete, accurate or correct but will help in providing better service. Sumairo also collects information based on Usage, viewing technical and other data at the platform by the User, or when User visits our sites of use applications, or uses third party sites linked to platform, or open mails sent by us. This includes the areas of the Platform that User visit besides information without limitation, Users Internet protocol address, computer hardware, operating system type, browser types, domain name, IP address, domain name, geographic location, product details, operating system type, access time etc.
• Sumairo as part of process may do Call recordings to Customer care or other executives, SMS, mails, Whatsapp and Chats recordings etc. Sumairo shall keep records of all communications including personal calls, communications through Chat bot for the purposes of improving its services, increasing business intelligence, part of administration of platform, for business development by way of providing mailers and offers etc. Sumairo may also resort to certain surveys, applications, contest for gathering further information in order to understand needs and users of the Users.
• The personal information collected from User is valuable by the Platform and we shall ensure adequate level of protection by way of security policies to prevent any unauthorized access or use of the same. The security measures include technical process as required under applicable law including creating firewalls and other physical/electronic security measures to protect the any unauthorized access or use of information collected. However, Sumairo shall not be responsible for any breach of security or for any action of any third parties that receive Users’ personal data or events that are beyond its reasonable control. Sumairo shall also not be responsible for Government policy changes, hacking of platform, accidental loss of information, any unauthorized modification of collected information. Sumairo shall also be bound to share this information in case of any restructuring of its business by way of merger, demergers, slump sale etc. and the new entity so emerging shall be entitled for use of transferred information. Sumairo may be required to disclose Personal or Financial Information to government authorities or institutions on such requisition under any law or judicial decree or when Sumairo deems it necessary in order to protect its own rights or the rights of others associated with the platform, to prevent fraud and credit risk, or to enforce or apply the Terms of Use.
• The User consents to Sumairo’s reproducing or editing any or all documents given by the User, whether on the Platform or social media platforms, or in any other manner in relation to Sumairo or any of the Products including mobile applications, together with the User’s name and location, on the Platform, in such manner as Sumairo may determine.
• All the information provided to Sumairo by a User, including Information, is voluntary and is being provided for accessing the products and services offered by the platform and/or mobile application. The User does have the right to request for withdrawal of content at any time, in accordance with the terms of this Privacy Policy and the Terms of Use. Sumairo does not endorse the content, messages or information found in any Services and therefore, specifically disclaims any liability with regard to the Services and any actions resulting from the User’s participation in any Services. It may be noted that any information that is freely available in the public domain or accessible under the Right to Information Act, 2005, or any other law will not be regarded as sensitive personal data or information, or as personally identifiable information.

Use of Personal/non-personal information and Derived data

Sumairo or its subsidiaries, if any, may use User’s Information unless prohibited under applicable law, for use on their own behalf for the following purposes:

• Provide services to User, to understand Users needs of products and services:
• Create and administer Users accounts in order to improve the quality and experience on the platform and its services including not limited to resolving any grievance:
• To monitor Users activities on the platform with a view to customize User experience and provide services of interest of User;
• To meet legal and regulatory requirements and to promote safety of Users data;
• To resolve any technical issues and problems;
• To help Sumairo in collecting amounts from Users for transactions carried out on the Platform and/or mobile application, fees for using services availed by Users and to facilitate financing of Users transactions;
• To send promotional mails, messages, emails, communicate with Users for existing of new transactions/services. To provide User with target advertising or alternatively increase communication with Users for existing or new services including third party services products/services, offers or other features of platform and/or mobile application or SAAS information which may be of use of the User;
• To provide aggregate services or demand for products based on tenders and to provide summary of business done or possible opportunities in order to maximize trade of the User with platform.
• To increase communication with users of the platform about Users account or transactions with platform and send information about other features of platform and/or mobile application or SAAS services;
• To provide information to the Users and respond to any query of the User in order to personalize content and experience with Users;
• To increase networking of the user by providing engagement with Other Users;
• To operate, understand, develop or improve Sumairo applications, products, services and operations; to detect and prevent activities that may violate Users policies or pose safety issues or frauds etc.

Sumairo assumes that after coming on the platform you agree expressly to receive targeted offers, mails, advertisement and communications relevant to your use at the platform

Disclosure of the information

Platform We may disclose User’s information to third parties already engaged with the Platform as part of the agreement signed by the User in the following form:

• Users listed on the Platform for delivery of orders viz both product and services; providing credit period for settling payment for the orders executed by the Users or providing options to Financers for getting financing options for purchases of products/services;
• Disclosing User’s Information to other entities within the group or third parties authorized by platform to undertake action on behalf of platform companies, agencies, individuals and other third parties who are authorize by us to perform functions on our behalf.
• Platform may provide Users information to a third party for improving the product and services offered to Users which may include sellers, agents, affiliates, service providers etc.
• Disclosing User information to platform partners, manufacturers and traders on the engaged in the platform to generate increasing business mutually and to provide better overall services to all engaged on the platform
• Platform may disclose User Information if legally required to do so. Platform may also, subject to applicable laws, share information or data with other entities for storage and processing of information for which the User having accepted the terms of use has hereby given its consent automatically. However, the platform shall ensure that there is data protection of the same level as provided by the platform.

Changes to Your Information

The platform may provide User the ability to seek certain choices or rights regarding the information collected or being provided by the platform, which may include the following-

• User may update, review, change or seek deletion of User Account Information or User Information on the Platform. The right to delete the User account or to make it unusable rests with the Platform. Sumairo can delete any part of the User Information or the entire account on receiving request to delete from User, which platform may do, subject to keeping information for legal or compliance purposes.
• User may choose to change choices in connection with newsletter or alerts or advertisement or targeted advertising or promotional campaigns for various products or products which the platform think would be of interest to the User.
• User may request for removal of User’s personal information on platform or any third party platform or any of the site or application of the platform.
• The User can exercise these rights by contacting the Customer Service or the designated Grievance Officer, however, the decision of the platform shall be final on the choices made by the User. It is to be understood that collection of personal information for Sumairo platform is mandatory keeping in view the nature of business handled and services provided, however, after accepting this policy and terms of use, the User shall be deemed to have given the permission to Sumairo to collect the same.
• Sumairo reserve the right to verify and authenticate User identity and account information in order to ensure accurate delivery of Services. It is clearly being stated that access to or correction, updating or deletion of User Account Information may be denied or limited by Sumairo if it is felt that it violates other person’s rights and/or is not otherwise permitted by applicable law.

Data Security, Integrity of User’s Information

Sumairo takes the onus to provide data integrity and security to provide physical, technical and procedural safeguards required to protect User’s Information against any loss, misuse, change, copying, damage or modification and unauthorized access or disclosure. Sumairo review User’s information collection, usage, storage, processing and disclosure practices, including physical security measures, to guard against unauthorized access to systems;

Sumairo shall store/stored all the information of the User in secure servers in a destination in India or outside or on cloud systems. The User having given the information sought for by platform agrees to this transfer, storing, sharing to connected third parties on the platform and processing of the data too. However, Sumairo platform does not assume any liability for disclosure of information due to unauthorized third-party access or other acts of third parties, or acts or omissions beyond its reasonable control. The User further agrees not to hold Sumairo responsible for any breach of security unless such breach has been caused as a direct result of gross negligence or willful default by Sumairo. By using the platform and/or mobile application, the Users is aware of the implications of transmission of data through various means through the Internet and Sumairo shall not guarantee that the entire process if secure and integrated.

Sumairo restricts access to User Information to platform employees, agents and partners in general, however certain administrative people having controlling powers or data processors who are part of the system would automatically have access to the information provided by the user, but they would however by bound by the confidentiality clauses for not disclosing Users financial or personal information. Thus the platform will ensure that the information is available to people who need to know the information in order to process the transaction. Sumairo shall ensure that all the information is kept confidential and disclosure of any or all information shall be in line with the terms of use and the privacy policy of the platform.

Sumairo platform uses temporary files called “cookies” to collect and store certain data. Use of cookies is to confirm the identity of customers logged into the platform and/or mobile application without User having to use passwords for browsing each page of the platform. Sumairo does not store personally identifiable information in the cookies, however information so collected by using cookies may be used by the Sumairo Platform or third party service providers for administration, research, statistical and other purposes.

The cookies generally are deleted once the customer closes the browser and a User can also be able to disable or delete them by changing browsers setting. However, if the User chooses to disable cookies out of device of mobile device or any other device used for connecting with platform, the User may not be able to use the entire services available on the platform. By default, Sumairo uses a persistent cookie that stores customer login ID (but not password) to make it easier for the customer to login when returning to the website. Sumairo encodes its cookies so that only it can interpret the information stored in them. The user may remove or block this cookie using the user’s browser settings to disable the feature. Merely closing the web browser should ordinarily clear all temporary cookies installed by Sumairo, however, Users are encouraged to use the “clear cookies” functionality of their browsers to ensure deletion. Sumairo’s Privacy Policy does not cover the use of cookies by its partners and affiliates as the platform does not have access or control over these cookies.

External links on the Platform

Sumairo may allow other companies or entities to serve advertisements, research and news to Users and on the Platform. These companies or entities include third party advertisement servers, advertisement agencies, advertisement technology vendors and research and news firms. Sumairo does not use personally identifiable information to target advertisements to specific Users. Sumairo does not exercise control over the third-party websites displayed as links from within the Platform. These third party sites may collect data including Personal Information or Financial Information from the Users, for which Sumairo shall not be held responsible or liable and neither Sumairo make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, Sumairo does guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, messages or other materials available on such websites. Their inclusion or exclusion does not imply any endorsement by Sumairo of such websites, the websites’ provider, or the information on the website.

Referrals

If the user wishes to introduce Sumairo and/or mobile application to any other person / entity, the user will be asked to provide such person / entity’s name and email address. Sumairo takes on the mandate to either call or not to call the said person or entity.

Changes to Policy

In the event Sumairo amends this Privacy Policy, the same will be updated on the platform and website of the platform. This policy may be changed, but any changes will be posted, and changes will only apply to activities and information on a going forward, not retroactive basis. The users are encouraged to periodically review this page for the latest information on its privacy practices. In case of any material changes to the Policy, the users will be notified by email (sent to the email address specified in the user’s account) or by means of a notice on this website prior to the change becoming effective.

Severability

Sumairo has made every effort to ensure that this Policy adheres with the applicable laws. The invalidity or unenforceability of any part of this Policy shall not prejudice or affect the validity or enforceability of the remainder of this Policy.

No Waiver

The rights and remedies available under this Policy may be exercised as often as necessary and are cumulative and not exclusive of rights or remedies provided by law. It may be waived only in writing. Delay in exercising or non-exercise of any such right or remedy does not constitute a waiver of that right or remedy, or any other right or remedy.

Opt-Out Policy

User agree and consent to receive all communications, including but not limited to text messaging services or over-the-top communication services (including inter alia WhatsApp, Facebook Messenger, Telegram, Google, Signal, JioChat), at the mobile number provided by User, or any such number which may be provided to Sumairo from time to time, even if such mobile number is registered under DND/NCPR list under the Telecom Regulatory Authority of India (TRAI) regulations. Notwithstanding User’s registration with the National Do Not Call Registry (in the fully or partly blocked category under National Customer Preference Register set up by TRAI), User hereby express interest and accord informed consent to receive communications (including commercial communications) in relation to Sumairo's services. User confirms that no communication from Sumairo or on behalf of Sumairo shall be construed as “unsolicited commercial communication” under Regulation 2(bw) of the Telecom Commercial Communications Customer Preference Regulations, 2018. User further authorises Sumairo to share or disclose the information to any third party service provider or any affiliates, group companies, their authorised agents or third party service providers of Sumairo.

Grievance Officer and Contact information

Users can access, modify, correct and eliminate the data about him/her/it which has been collected pursuant to his /her/its decision to become a User. If you believe that your rights are being infringed or you have any grievances, complaints or concerns, including in relation to the information shared by the User with Sumairo on the Platform, you may reach out to our grievance officer through telephonic or electronic mode in the following manner:

Address:

Email: cp@sidhepetrochemical.com

Phone Number: +91 9311892146

Sumairo officer shall respond expeditiously to rights owners and their agents who communicate their concerns about any alleged infringement in the manner provided under this Privacy Policy.

Applicable Law and Dispute Resolution

The Privacy Policy and applicable additional terms / policies shall be governed by and interpreted and construed in accordance with the laws of India. Any disputes pertaining to the Privacy Policy shall be subject to the dispute resolution provisions provided for under the Terms of Use.