Privacy Policy

Data Privacy Policy

By entering this website, the visitor consents to the terms of this
policy. By submitting his/her information to ZEP, the visitor will be
treated as having given his/her permission for processing the same in a
manner provided in this policy.

Introduction

ZEP respects the privacy of individual/visitor and is committed to
take reasonable precautions to protect information consisting of
Personal information and `Sensitive Personal Data or Information’ (SPDI)
(“Information”) of visitors of this ZEP website and
comply with all legal, regulatory and/or contractual obligations related
to privacy. ZEP has adopted the “Privacy by Default” principles in its
approach to data privacy i.e. privacy of data and information is upheld
first by default.

This policy covers the processing, storage and access to Information
as required under lawful and/or contractual activities with ZEP or
otherwise required in the normal course of business. It describes ZEP’s
policies and procedures on the collection, usage and disclosure of
Information provided/received by natural persons and meets the
requirements established under:

The Information Technology Act, 2000 – Section 43A;
The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011.

1. Scope

This policy applies to all visitors of this ZEP’s website.

2. Information covered by this Policy

This policy applies to Information collected and processed by ZEP consisting of following:

2.1 Personal information is information related to a visitor, or a
combination of pieces of information that could reasonably allow him to
be identified. Personal information may consist of full name, personal
contact numbers, residential address, email address, gender or date of
birth. While information such as date of birth in isolation may not be
enough to uniquely identify the visitor, a combination of full name and
date of birth may be sufficient to do so.

2.2 Sensitive personal data or information (“SPDI”) is such
personal information that is collected, received, stored, transmitted or
processed by ZEP, consisting of:

Password;
Financial information such as bank account or credit card or debit card or other payment instrument details;
Physical, physiological and mental health condition;
Sexual orientation;
Medical records and history;
Biometric information;
Any detail relating to the above personal information categories as provided to ZEP for providing service; and
Any of the information received under above personal information
categories by ZEP for processing, stored or processed under lawful
contract or otherwise.

Please note that any information that is freely available or
accessible in public domain or furnished under the Right to Information
Act, 2005 or any other law for the time being in force shall not be
regarded as sensitive personal information.

3. Purpose

ZEP shall collect and use Information for legitimate business purposes in order:

that a visitor may download product information, order products and take advantage of certain other features of ZEP’s website;
to provide information or interactive services through this
website, to the visitor’s e-mail address or, where the visitor wishes it
to be sent by post, to the visitor’s postal address;
to seek the visitor’s feedback or to contact the visitor in relation to the services offered on ZEP’s website;
to process orders or applications submitted by the visitor;
to administer or otherwise carry out ZEP’s obligations in relation to any agreement that the visitor may have with ZEP;
to anticipate and resolve problems with any goods or services supplied to the visitor;
to create products or services that may meet the visitor’s needs;
to process and respond to requests, improve ZEP’s operations, and
communicate with visitor/s about ZEP’s products, services and
businesses; and
to allow the visitor to subscribe to ZEP’s news alerts.

4. Collection of Information

Only minimum Information required to meet the purposes mentioned in
this policy shall be collected from the visitor/s. Neither ZEP nor its
representatives shall be responsible for the authenticity of such
Information provided by the visitor/s. As normal business practice, ZEP
may collect Information in order to enable the secure online
authentication, interaction and transaction with natural persons. This
may include the installation of cookies and the collection of other
session data.

5. Access, Correction of Information and withdrawal of consent

Any modifications / corrections required to the Information can be
carried out on the website. In the event the visitor is unable to do so
due to lack of functionality in ZEP’s website and / or the visitor wants
to withdraw his / her consent to provide SPDI, he / she may contact the
Grievanceofficer, the details whereof are provided in clause 8 of this
policy.

6. Retention, Processing and storage of Information:

6.1 ZEP shall retain Information for only as long as necessary to
meet legal or regulatory requirements or for legitimate business
purposes as mentioned in this policy.

6.2 ZEP has implemented required security practices and standards
in line with the global standards and have a comprehensive documented
information security program and policy in place, which contains
managerial, technical, operational and physical security control
measures that commensurate with the information assets being protected
with ZEP’s nature of business. It is being reviewed periodically to keep
pace with business, technology and regulatory changes.

7. Disclosure of Information

7.1 ZEP shall not use or disclose Information for purposes other
than as mentioned in this policy, except with the consent of visitor
providing such Information or as required by law. However, ZEP may be
legally required to disclose the Information in the following cases:

Where the disclosure is necessary for compliance of a legal obligation;
Where mandated under the law by government agencies to disclose such Information.

7.2 Where necessary, ZEP may disclose Information to business
partners or third parties during the normal course of business for the
purposes mentioned in this policy. In such cases, ZEP will only share
Information related data when ZEP is assured that:

The Information is processed legitimately and appropriately by the
business partner or third party in line with the established consent or
in line with legal requirements.
The business partner or third party has adopted a reasonable and
equivalent level of security practices and procedures to ensure security
of the Information shared.