September 1, 2023

This privacy policy describes the privacy practices of Birla Carbon so when we mention “we”, “us” or “our” in this privacy notice, we are referring to the relevant part of Birla Carbon responsible for processing your data. We are committed to respecting the privacy of visitors (“you”) to this website and the Birla Carbon apps (“Sites”) and we have adopted this policy to explain what information we collect through our Sites, how we collect that information, what we use that information for, and to whom we disclose that information.

Residents of People’s Republic of China please refer to Birla Carbon’s Privacy Policy for China.

Visitors who are unable to review or access this Privacy Policy due to a disability may contact us using the methods set forth in the “Contact Us” section below to access this Privacy Policy in an alternative format.

Please read this policy carefully before you use our website. If you do not agree with our use of your Personal Information as described in this policy, please do not use our Sites or otherwise provide Personal Information to us. We retain the right to update this policy at our discretion and at any time. When we make material changes to this policy, we will post an updated policy on our website with the effective date. Therefore, you may want to check back from time to time to read our updated privacy policy.

Information Gathering

 We collect two types of information from you: (1) Information passively collected upon your visit to our website, and (2) Information provided by you in order to receive requested information and/or services. The Information we collect may contain Personal Information, which means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. In some jurisdictions, this is also known as “personal data.”

Passively Collected Information

When you visit our website, we may automatically collect some network activity data such as browsing history, search history, cookie data, referring/exiting URL, clickstream data, time spent on webpage or advertisement, and other information regarding your interaction with an internet website, application, email or advertisement. This type of information may include Personal Information.

Our website makes use of “cookies” to automatically collect the above information. Cookies are small text files placed on your computer to keep track of information about your browsing on the site, some of which may be considered your Personal Information. Some cookies are essential for the operation of our Sites. Other cookies allow us to enhance your experience and to create tailored web applications. You can update your preference to accept or disable the non-essential cookies at any time by changing your browser setting or device setting. Your decision to accept or disable those cookies is a personal choice, but our Sites may not work as designed if you disable all non-essential cookies.

Your browser or device may have setting that allows you to indicate a “Do Not Track” or other opt-out preference signal. Our website does not respond to “Do Not Track” signals or other similar mechanisms.

 Information Provided by You

We may collect other information that you voluntarily provide to us, such as when you create an account, submit quote inquiries, information requests, online forms, or otherwise attempt to contact us. If you do not provide such information, it may affect the quality of our services but you should still be able to use basic functions of services delivered by our Sites.

We typically receive the following categories of Personal Information about visitors to our Sites:

• Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
• Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Financial Information, such as bank account number, credit card number, debit card number, or any other financial information.
• Professional or employment-related information.
• Inferences drawn from any of the categories identified above.

However, you may voluntarily provide other types of Personal Information to us during your interactions with us. Should you choose to provide us with any Personal Information, we will use such information only as described in this privacy policy. If you submit Personal Information relating to other people to us, you represent that you have the authority to do so, and to permit us to use that information in accordance with this Privacy Policy.

Information Use – Legal Bases and Purposes

 We may collect and use your Personal Information on one or more of the following legal bases to the extent permitted by applicable local privacy laws:

• Processing is necessary for the execution or performance of a contract with you;
• Processing is necessary for our compliance with a legal obligation;
• Processing is necessary for our legitimate interests in pursuing these business or commercial purposes:
  • Determine product and service eligibility and coverage.
  • Provide our products and services to you.
  • Administer, manage, analyze, and improve our products and services.
  • Issue invoices and collect payments.
  • Fulfill payment obligations.
  • Communicate with you regarding our products and services.
  • Procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations.
  • Analyze and better understand your needs, preferences, and interests.
  • Conduct internal business analysis and market research.
  • Advertise and promote products, including by contacting you regarding products, services, and topics that may be of interest to you.
  • Engage in joint marketing initiatives.
  • Comply with legal and regulatory obligations.
  • Administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices.
  • Provide access to, monitor, and secure our facilities, equipment, and other property.
  • Detect security incidents and other fraudulent activity.
  • Monitor, investigate, and enforce compliance with our policies, product, service, or lease terms and conditions, and other legal and regulatory requirements.
  • To identify you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with products, services, and advertisements for such purposes.
• In situations where none of the above legal bases would apply, we will process your Personal Information only after we have obtained your consent.

We may also aggregate or de-identify collected Personal Information and analyze it for statistical or any other purposes.

 Disclosure of Collected Information

We may disclose your Personal Information in the following situations:

• To employees, officials or departments within our organization for internal use or to provide you with requested information and services.
• To government or judicial authorities to comply with a subpoena, court order, governmental inquiry, legal processes, legal obligations, or to protect the rights, property or safety of other users or the public.
• To protect our rights, defend or pursue a legal claim, or investigate or prosecute illegal activities.
• To a successor entity or a purchaser upon a merger, consolidation, or other corporate reorganization in which we participate, a sale of all or a portion of our assets, or pursuant to a financing arrangement. In this situation, such successor entity or purchaser will be bound by terms and conditions reasonably similar to this policy.
• To vendors who process your Personal Information on our behalf or who provide us with necessary services under all of the above situations.
• To any other entities when the disclosure of aggregated or de-identified data is permitted by applicable laws.

We have not sold or shared Personal Information about consumers in the past twelve months. Relatedly, we do not have actual knowledge that we sell or share Personal Information of California consumers under 16 years of age. A “sale” is the disclosure of Personal Information to a Third Party for monetary or other valuable consideration, and a “share” is the disclosure of Personal Information to a Third Party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

We do not distribute your Personal Information to other entities for their own direct marketing purposes.

Your Privacy Rights

You may have one or more of the following rights under local privacy laws (including the European Union’s General Data Protection Regulation, the California Consumer Privacy Act as amended by the California Privacy Rights Act, and the General Personal Data Protection Law of Brazil) with respect to the Personal Information that we collect from you.

• Right to Notice. Before or at the time we collect Personal Information from you, you have the right to receive notice of the Personal Information to be collected and the purposes for which we use it. This Notice is intended to satisfy this requirement.
• Right to Know. You also have the right to request that we disclose to you the categories of Personal Information we have collected about you in the preceding 12 months, along with the categories of sources from which the Personal Information was collected, the purpose for collecting or selling the Personal Information, the categories of third parties with whom we shared the Personal Information, and the categories of third parties to whom we sold the Personal Information.
• Right of Access. You have the right to request that we disclose or provide you with access to the specific pieces of Personal Information we have collected about you in the preceding 12 months. In some jurisdictions, this is also called “right to data portability.”
• Right to Correct Inaccurate Personal Information. You have the right to request that we correct any Personal Information we collect from you if it is inaccurate. In some jurisdictions, this is also called “right to rectification.”
• Right to Deletion. You have the right to request that we delete the Personal Information we collect from you. In some jurisdictions, this is also called “right to erasure” or “right to be forgotten.” However, in certain situations we are not required to delete your Personal Information, such as when the information is necessary in order to complete the transaction for which the Personal Information was collected, to provide a good or service requested by you, to comply with a legal obligation, to engage in research, to secure our websites or other online services, or to otherwise use your Personal Information internally in a lawful manner that is compatible with the context in which you provided the information.
• Right to Restrict or Object to Processing: You may request us to suppress or cease the processing of some of your Personal Information but we may still store your Personal Information.
• Right to Lodge a Complaint: You have the right to file a complaint with your local data protection authority if you consider that the processing of Personal Information relating to you infringes upon your rights.
• Right to Withdraw Consent: To the extent that our processing of your Personal Information is solely based on your consent, you may withdraw that consent at any time.
• Right Not to Be Subject to Discrimination. You have the right to be free from discrimination or retaliation for exercising any of your rights under applicable local privacy laws.

We may request information from you to verify your identity before complying with your data subject request. You may also authorize an agent to make data subject requests on your behalf. If you make the request through an agent, we may require the agent to provide proof of signed permission from you to submit the request, or we may ask you to designate your agent directly with us or confirm that you authorized the agent to submit the request. In some instances, we may decline to honor part or all of your request if an exception applies or if compliance is not required under applicable law. We will respond to your request consistent with applicable law.

Financial Incentives Programs

We do not provide financial incentives to visitors who allow us to collect, retain, sell, or share their Personal Information. We will describe such programs to you if and when we offer them to you.

Cross-Border Data Transfers

 We are co-headquartered in the United States and India and operate in a dozen jurisdictions. As such, we may store and process Personal Information outside the jurisdiction where you reside. Please note that some of those jurisdictions may have different privacy laws and may not provide equivalent levels of data protection as your home jurisdiction. Where required by local laws, we implement the applicable cross-border data transfer mechanisms and comply with associated requirements to protect your Personal Information, including providing you with a separate privacy notice or obtaining your consent if necessary.

Personal Information of Minors – Opting In 

Our Sites are not intended for persons we know to be under age 18 and is not designed to attract anyone under age 18. If you are under 18 years old, please do not provide your Personal Information to us unless your parent or guardian directly provides that information to us. If you are the parent or guardian of a minor and believe that we have collected Personal Information about your child in error, please contact us immediately at bc.dpo@birlacarbon.com so we can make reasonable efforts to remove all Personal Information related to the minor.

Outside Links on Our Website

Our website may contain links to other websites owned by other entities as a convenience to you. If you decide to use these links, you will leave our Sites. We are not responsible for the privacy practices or the content of such websites and do not make any representations or endorsements about them. If you decide to leave the website and access other sites, it will be at your own risk, and you should be aware that this policy will no longer govern. You should review the applicable terms and policies, including privacy and data gathering practices, of any other site when you navigate away from our Sites.

If you use any integrated social media tools that may be available on our Sites to share Personal Information or you otherwise interact with social media features on our Sites, those social media companies may collect information about you and may use and distribute such information in accordance with your social media account settings, including by distributing such information with the general public. We do not control any of the content from social media plug-ins. Your interactions with third-party social media companies and your use of their services are governed by the privacy policies of the social media companies that provide those services.  We encourage you to carefully read the privacy policies of any social media accounts you create and use.

Your Personal Account

If you choose to register and use an online account on our Sites, you are responsible for maintaining the confidentiality of your account and password and for restricting access to your computer. You also agree to accept responsibility for all activities that occur under your account or password. When you post information on or otherwise interact with our website, this information may become public on the Internet.

Data Retention

We will retain information about you for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required by law.

Security

We implement reasonable security measures to promote the confidentiality, integrity and availability of information in our possession or control. Such measures are designed to protect your Personal Information from loss, unauthorized access, disclosure, alteration, or destruction. However, while the security of your Personal Information is of the utmost importance to us, we cannot guarantee the security of any information you choose to disclose online. Specifically, email is a non-encrypted form of Internet communications that may be accessed or viewed by other Internet users without your knowledge or permission while in transit to us. For that reason, in order to protect your privacy, please do not use email to communicate information to us that you consider confidential. Any information you choose to disclose to us is done at your own risk.

Contact Us

Call toll-free at the applicable local Hotline number listed in the Appendix to Birla Carbon’s Code of Global Business Ethics and Compliance Standards (which you may access at the following link: https://www.birlacarbon.com/policies-codes-and-certificates/#a12a105082cb0db37) or contact us via our online form (which is available at: https://www.birlacarbon.com/contact-us/) with questions or concerns regarding this Privacy Policy or our privacy practices.

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