DigiPro Privacy Policy

 

HAVELLS’ PRIVACY POLICY

 

1.                                 INTRODUCTION

This Privacy Policy is an extension of our Terms of Use (“Terms”) which govern the use of our Services, including the Smart Products and access to our Website, as provided by Havells Hvac LLC (“Havells” “our” “us” or “we”). We request you to read it carefully before sharing any personal information with us. For clarity, capitalized terms used in the Terms shall have the meanings set forth in the Terms unless specifically amended herein.

2.                                 SCOPE OF THIS PRIVACY POLICY

“Personal Data” (in this Privacy Policy also referred to as “data” or “information”) means any information or set of information from which we are able, directly or indirectly, to personally identify you, in particular by reference to an identifier, e.g. name and surname, email address, phone number, etc. This Privacy Policy covers how we use your personal information which we gather when you (1) visit or use any of the functionalities of our Smart Products or Website, (2) register or create an account on our Application or Website, (3) participate or sign up for our promotional or other marketing activities, (4) reach out to us for inquiries, feedback, concerns, or other purposes, or (5) otherwise interact with us through any other means.

For Services (including website or app-based functionality(s)) that may involve specific processing of your data, this Privacy Policy might be supplemented by our product specific notices and/or disclaimer (including emails, and in-application prompts) which provide additional information on the processing of your data related to the Product and/or Service.

3.                                 COLLECTION OF PERSONAL INFORMATION

3.1.                            Depending on the Services provided to you by Havells, and how you interact with the Services, Havells may process different data about you. We may collect data (i) directly; to illustrate, when you visit or use our Website, Application, or social media channels, purchase of our Products, Smart Products, Services, systems, contact our customer support, promotions and surveys or otherwise interact with us, or (ii) through our partners or through (iii) legally accessible publicly available sources.

3.2.                            Below you will find an overview of the categories of data that we may collect directly:

 

Category and Sources of Information	Examples	Business or Commercial Purpose	Disclosure, Sell, or Share	Retention Period
Identifiers   We collect this information from our customers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	Business – To register your account on our Application and Website, to communicate with you for queries and feedback, and to understand how your devices interact with our Smart Products.   Commercial - To improve our Services and marketing purposes.	We may disclose this information to our service providers and vendors. We may share this information with our business partners and vendors, as may be required for provisioning of the Services. We do not sell this information.	We only retain as long necessary to fulfil the purpose outlined herein, unless required otherwise by the applicable law.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))   We collect this information from our users and customers.	Real name, signature, address, telephone number bank account number, credit card number, debit card number, or any other financial information.	Business – To enable the use of our Smart Products and Website, to communicate with you, and to make it easier for you to make repeat purchases of our products.   Commercial – (1) To improve our Service Offerings, and (2) for marketing purposes. However, financial information will not be used for any commercial purpose.	We disclose this information to our service providers and vendors. We may share this information with our business partners and vendors, as may be required for the provisioning of Services. We do not sell this information.	We only retain as long necessary to fulfil the purpose outlined herein, unless required otherwise by the applicable law.
Commercial Information   We collect this information from our users, customers, service providers, and vendors.	Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Business – To communicate with you concerning the product that you purchased or inquired about.   Commercial – (1) To analyze purchasing patterns and consumer interest, enabling us to develop new products and improve existing ones to better meet customer needs and preferences, and (2) to tailor marketing efforts and recommendations based on your purchasing history and preferences, thereby enhancing your user experience.	We disclose this information to our service providers who run data analytics on our behalf and vendors who sell our products. We may share this information with our vendors and business partners as may be required for the provisioning of Services. We do not sell this information.	We only retain as long necessary to fulfil the purpose outlined herein, unless required otherwise by the applicable law.
Internet or other electronic network activity information   We collect this information from our service providers and business partners.	Browsing history, search history, and information on consumer's interaction with website, application, or other content. Hardware model, IMEI number and other unique device identifiers, operating system version, device settings used to access the services, and device configuration. Time, duration and manner of use of our products and services or products and services connected to ours	We do not use it for any business purposes.   Commercial - To improve our Services.	We disclose this information to our service providers who help us in behavior analytics and business partners. We may share this information with our vendors and business partners as may be required for the provisioning of Services. We do not sell this information.	We only retain as long necessary to fulfil the purpose outlined herein, unless required otherwise by the applicable law.
Geolocation Data   We collect this information from our users, customers, and service providers.	Your location (derived from your IP address, Bluetooth beacons or identifiers, or other location-based technologies), that may be collected when you enable location-based products or features such as through our apps	Business – (1) To deliver Services to your location, and (2) to provide the location-based features in our Application.   We will not use this information for any commercial purpose.	We disclose this information to our vendors. We may share this information with our vendors and business partners as may be required for the provisioning of Services. We do not sell this information.	We only retain as long necessary to fulfil the purpose outlined herein, unless required otherwise by the applicable law.
Sensory Information   We collect this information from our users and service providers.	Audio information	Business – To run the third-party voice assistants integrated into our Application, however, we do not use this information to personally identify the users.	We disclose this information to the integrated third-party voice assistants who process this information as per their terms and conditions. We may share this information with our vendors and business partners as may be required for the provisioning of Services. We do not sell this information.	We only retain as long necessary to fulfil the purpose outlined herein, unless required otherwise by the applicable law.
Inferences drawn from any of the information identified.   We collect this information from our service providers.	A profile about a consumer reflecting the consumer's preferences, characteristics, trends, and behavior in relation to the Services, specifically the Smart Products.	We do not use this information for any business purpose. Commercial – To improve our offerings.	We disclose this information to our service providers and business partners. This includes entities with whom we have contractual relationships to perform services on our behalf. We may share this information with our business partners and vendors as may be required for the provisioning of Services. We do not sell this information.	We only retain as long necessary to fulfil the purpose outlined herein, unless required otherwise by the applicable law.
Sensitive Personal Information   We collect this information from our users, customers, and state administration.	Personal information that reveals: (a) financial account, debit card, or credit card number along with password or credentials, and (b) precise geolocation.	Business – We use this information to (1) deliver Services, (2) store user’s financial data for purchasing products,   Commercial – To improve our offerings.	We disclose this information to our service providers who run data analytics on our behalf and vendors who sell our products. However, we do not disclose financial information to any third party. We may share this information with our vendors and business partners as may be required for the provisioning of Services. We do not sell this information.	We only retain as long necessary to fulfil the purpose outlined herein, unless required otherwise by the applicable law.

 

3.3.                            Information we may collect from other sources

To the extent permitted by applicable law, in addition to our Services inter alia Websites, Application and other digital channels, we may also obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms, and other third parties.

3.4.                            Information we may aggregate from different sources to your profile

If you have indicated to us that you wish to receive personalized direct marketing communications, we might aggregate data from different sources (both internally and externally) to have a better understanding of your preference and interests, and be able to serve you with more relevant communications. You can always object to these activities by opposing this. In particular, you can always opt-out from receiving marketing-related emails by following the unsubscribe instructions provided in emails. You can always contact us (you will find the contact details below) to opt-out from receiving marketing-related communications.

3.5.                            We will inform you via your email and pop-up notification on the Application if we collect any additional categories of personal information or change our business/commercial purpose.

4.                                 DISCLOSURE/SALE/SHARE OF PERSONAL INFORMATION

The categories of personal information specified in Section 4 of this Privacy Policy have been disclosed and shared with our business partners, service providers, and vendors for the specified purposes, and if required, to the enforcement agencies.

However, in the preceding twelve (12) months, we have not sold your personal information to any third party.

5.                                 USE OF THIRD-PARTY ANALYTICS TOOLS

We use analytics tools provided by our service providers to track and analyze how you interact with our Smart Products and Website. These tools help us understand user behavior, measure performance, and improve our Services. By collecting data on aspects such as page views, session duration, and other usage patterns, we gain insights into user preferences and identify areas for enhancement. The information gathered through these analytics tools is used to optimize the user experience, improve the Smart Product's functionality, and tailor our offerings to better meet your needs.

6.                                 INTERNATIONAL DATA TRANSFER

Havells may transfer your personal information to various entities, including its parent company located in India, as well as to business partners, service providers, and affiliates in different jurisdictions worldwide. These transfers may occur to facilitate the services we provide, ensure efficient business operations, and comply with legal or regulatory requirements. By providing your personal information, you consent to these transfers, which may involve moving your data to countries with different data protection standards than those in your home country. We take appropriate measures to safeguard your personal information during these transfers, ensuring it is handled securely and in accordance with applicable data protection laws. You may obtain more information by reaching us at the contact details provided at the end of this policy.

7.                                 CHILDREN’S PRIVACY

We do not intentionally collect personal information from individuals below the legal contracting age, or otherwise under parental supervision. Our Smart Products and Services are designed with the intention of being used by individuals above the legal contracting age. As such, we do not knowingly solicit or collect information from anyone below this age. Furthermore, we do not have any knowledge or reason to believe that our Services are being accessed or used by individuals under the legal contracting age. If we become aware that we have inadvertently collected personal information from someone below this age, we will take prompt action to delete such information and ensure that it is not retained or used in any manner.

8.                                 YOUR RIGHTS

Under the state-specific privacy laws in the United States, you may be allowed to ask us certain information from us on our data processing activities. If you would like to exercise any of these rights, you may reach out to us through the methods specified in the next section.

Depending on applicable state privacy laws in the United States, you may be provided with the following rights:

a.                                 Right to delete personal information.

b.                                Right to correct inaccurate information.

c.                                 Right to know what personal information is being collected.

d.                                Right to know the source from which the personal information is being collected.

e.                                 Right to know the business or commercial purpose for collecting, sharing, or selling personal information.

f.                                  Right to limit use of sensitive personal information.

g.                                Right to know the categories of third parties to whom the business discloses personal information.

h.                                Right to know the specific pieces of personal information the business has collected about you.

i.                                  Right to non-discrimination/no-retaliation following opting out of a processing activity.

j.                                   Right to know if you are being subjected to automated decision-making.

k.                                Right to appeal.

l.                                  Right to object to processing for receiving commercial information on email.

m.                              Right to data portability; and

n.                                Right to complain to the relevant authorities.

Your sensitive personal information, if collected by us, may be used for business purposes as specified above, you may click “Limit the Use of My Sensitive Personal Information” to exercise your right to limit the use of your sensitive personal information as under the applicable law.

While we do not sell your personal information, we may share it with our vendors and business partners for the purposes specified above. You may click “Do Not Sell or Share My Personal Information” to stop sharing your personal information. Alternatively, we also respond to your opt-out preference signals in a frictionless manner.

9.                                 EXERCISE YOUR RIGHTS

We aim to provide you with complete control over your privacy. You or your authorized agent may exercise the above-stated rights, if applicable, by reaching out to us either by: (1) contacting us at 844-986-1668, or (2) emailing us at dpousa@havellshvac.com. To verify your identity, we may ask you for the following: (1) email address, (2) phone number, (3) device model, and (4) registration time, and cross-verify it with the information available in our system. California residents may exercise their rights through an authorized agent, by submitting a copy of your written permission to us. For this, we may first verify your identity. You may not be required to submit a copy of your written permission, if the authorized agent has power of attorney pursuant to California Probate Code sections 4121 to 4130.

Colorado residents may also exercise their rights through an authorized agent, by submitting a copy of their written permission and verifying their identity to us.

We will not respond to your request if we cannot verify your identity or authority to make the request and confirm that the personal information belongs to you.

Privacy Management within the Application

Opt-Out Mechanism

We prioritize ensuring you have complete control over your data and privacy settings within the Application. If you wish to opt out of data sharing, you may navigate to ‘Settings’, select ‘Privacy Settings’, and disable the ‘Service Maintenance & Improvement Activity’ toggle. Please note that enabling ‘Service Maintenance & Improvement Activity’ helps the Application function seamlessly and efficiently by allowing us to collect data related to the usage of our Smart Products and while core functionality will remain unaffected, opting out may limit certain features designed to improve your overall interaction with the Application.

Your controls and choices

Account/Data Deletion: If you wish to delete your account, which will also delete your personal information, navigate to ‘Settings’, select ‘Account and Security’, and then choose ‘Delete Account’. Upon selecting this option, a page will display the date and time when your personal information will be deleted. Please note that once the deletion process is completed, it cannot be undone. All your personal information will be permanently removed from our systems, and retrieval will not be possible under any circumstances. You can also personalize your privacy settings for various features within the Application through the ‘Settings’ menu to provide you with flexibility and control. The following settings allow you to tailor your privacy to your needs and enhance your user experience:

a.                                 Personalized Recommendations: Personalize how recommendations are tailored to you by navigating to ‘Privacy Settings’ and adjusting the toggle for ‘Personalized Recommendations’ based on your privacy needs.

b.                                Notifications: Set your alert preferences by accessing ‘Privacy Settings’ and selecting ‘Notifications', choosing the types of alerts and notifications that are most relevant to you to ensure you receive only what you need.

c.                                 Location: Control the Application’s access to your location data by navigating to ‘Privacy Settings’ and selecting ‘Location’, this way you can determine when your location information is shared with us.

d.                                Camera and Microphone: Manage access to your camera and microphone for features by going to ‘Privacy Settings’ and selecting ‘Camera’ or ‘Microphone’, adjusting permissions as needed to maintain control over these functionalities.

e.                                 Nearby Devices Access: Decide how the Application interacts with nearby Bluetooth-enabled devices by navigating to ‘Privacy Settings’ and selecting ‘Access to Nearby Devices Permissions’. This feature enables you to manage connections for activities such as device pairing or network configuration.

f.                                  Full-Screen Notifications: Customize your preferences for full-screen alerts by going to ‘Privacy Settings’ and selecting ‘Access to Full-Screen Notifications’, you can enable or disable this feature to tailor notifications to your preferred level of visibility.

1. RESPONSE TIMING AND FORMAT

We aim to respond to verifiable consumer or access requests within forty-five (45) days of receipt, or sooner if required by applicable law. If additional time is needed (up to a total of 90 days), we will notify you in writing of the reason and extension period, where permitted by law. Opt-out requests will be processed as quickly as possible, but no later than 15 days from receipt. If you have an account with us, we will send our written response to your account. If you do not have an account, we will deliver our response by mail or electronically, based on your preference.

Disclosures in response to verifiable consumer requests will cover the 12-month period preceding the request unless otherwise required by law. Our response will also explain any reasons we cannot comply with a request, if applicable. For information portability requests, we will provide your personal information in a readily usable format that allows transmission from one entity to another without hindrance.

We do not charge a fee for processing or responding to verifiable consumer or access requests unless they are excessive, repetitive, or manifestly unfounded. If a fee is warranted, we will explain the reason and provide a cost estimate before completing your request.

10.                              RIGHT TO NON-DISCRIMINATION

We will not discriminate against you for exercising your rights, by (1) denying goods or services, (2) charging different prices for goods or services, (3) providing a different level of quality of goods or services, or (4) suggesting that you will receive a different price or quality of goods or services.

11.                              ANONYMIZED INFORMATION

We may anonymize your personal information in a way that it can no longer be used to identify you and use, aggregate, and share such anonymized information for a legally compliant purpose without your prior knowledge or consent.

12.                              REASONABLE SECURITY SAFEGUARDS

We are committed to protecting your personal information and implementing reasonable security measures to ensure its confidentiality, integrity, and security. These measures include employee training and data protection policies, and technical protections like encryption and firewalls. While we strive to use commercially acceptable and reasonable means to protect your data, we cannot guarantee its absolute security.

13.                              DATA RETENTION

We delete personal data when it is no longer necessary for the purposes described in this Privacy Policy.

In any case, unless indicated otherwise in this Privacy Policy, the criteria we use to decide our retention periods include: (i) whether we need your personal data to safeguard our legitimate interest, to perform a contract to which you are subject or to respond to your questions or provide to you the required service or support; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

14.                              CHANGES TO PRIVACY POLICY

In case of any change to this policy, we shall inform you via your registered e-mail address and a notice on the landing page of the Application.

15.                              CONTACT INFORMATION

To obtain more information or for suggestions or complaints regarding processing your personal information, you may reach us by emailing our Data Protection Officer at dpousa@havellshvac.com or contacting 844-986-1668.

 

This Privacy Policy was last updated on 7^th January 2025.