Thank you for your interest in our company. Data protection is of a particularly high priority for the management of CarTelSol India Private Limited. The CarTelSol India Private Limited website can generally be used without providing any personal data. However, if a data subject wishes to make use of our company's special services via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the person concerned. The processing of personal data, for example the name, address, e-mail address or telephone number of a person concerned, is always carried out in accordance with the Digital Personal Data Protection Act, 2023 (DPDP Act) and other applicable Indian data protection and privacy laws. By means of this data protection declaration, our company would like to inform the public about the type, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed about their rights by means of this data protection declaration. As the controller, CarTelSol India Private Limited has implemented numerous technical and organizational measures to ensure the most complete protection possible for personal data processed via this website. Nevertheless, Internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, every person concerned is free to transmit personal data to us in alternative ways, for example by telephone. 1. Key Definitions The data protection declaration of CarTelSol India Private Limited is based on the terms used by the Indian legislature under the Digital Personal Data Protection Act, 2023 (DPDP Act). Our data protection declaration should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance. We use the following terms in this data protection declaration: a) Personal data Personal data is all information that relates to an identified or identifiable natural person (hereinafter "data subject"). Under the DPDP Act, "personal data" means any data about an individual who is identifiable by or in relation to such data. A natural person is regarded as identifiable who, directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier or one or more special features that express the physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person can be identified. b) Data subject The data subject is any identified or identifiable natural person whose personal data is processed by the person responsible for processing. Under the DPDP Act, the data subject is referred to as the "Data Principal". c) Processing Processing is any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Under the DPDP Act, "processing" means wholly or partly automated operations or set of operations performed on digital personal data. d) Restriction of processing Restriction of processing is the marking of stored personal data with the aim of restricting their future processing. e) Profiling Profiling is any type of automated processing of personal data that consists of using this personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. f) Pseudonymisation Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person. g) Controller or Data Fiduciary Under the DPDP Act, the entity responsible for processing personal data is referred to as the "Data Fiduciary". The Data Fiduciary is the person who alone or in conjunction with other persons determines the purpose and means of processing of personal data. If the purposes and means of processing are specified by applicable law, the Data Fiduciary or the specific criteria for its nomination may be provided for by such law. h) Processor or Data Processor Under the DPDP Act, a "Data Processor" means any person who processes personal data on behalf of a Data Fiduciary. i) Recipient Recipient is a natural or legal person, public authority, agency or body to which the personal data are disclosed, whether a third party or not. However, authorities which may receive personal data in the framework of a particular inquiry in accordance with applicable law shall not be regarded as recipients. j) Third party A third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data. k) Consent Under the DPDP Act, "consent" means a free, specific, informed, unconditional and unambiguous indication of the Data Principal's wishes by a clear affirmative action, signifying agreement to the processing of their personal data for the specified purpose. Consent is revocable at any time by the data subject. 2. Details of the Data Fiduciary The Data Fiduciary within the meaning of the Digital Personal Data Protection Act, 2023 and other applicable Indian data protection laws is: CarTelSol India Private Limited AS 01-02, Covent Garden, Near DPS Kalinga, Phulnakhra, Cuttack – 754001, Odisha, India Tel.: +91 85914 14565
E-Mail: info@cartelsol.com Website: www.cartelsol.co.in 3. Data Collection and Usage The CarTelSol India Private Limited website collects a range of general data and information each time the website is accessed by a data subject or an automated system. These general data and information are stored in the server's log files. The (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the sub-websites that can be controlled via an accessing system on our website, (5) the date and time of access to the website, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system and (8) other similar data and information that serve to avert danger in the event of attacks on our information technology systems. When using this general data and information, CarTelSol India Private Limited does not draw any conclusions about the person concerned. Rather, this information is required to (1) correctly deliver the content of our website, (2) optimise the content of our website, (3) ensure the long-term functionality of our information technology systems and the technology of our website and (4) to provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack. CarTelSol India Private Limited therefore evaluates this anonymously collected data and information statistically and with the aim of increasing data protection and data security in our company, in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data in the server log files are stored separately from all personal data provided by a data subject. 4. Data Retention and Deletion The Data Fiduciary processes and stores personal data of the data subject only for the period of time necessary to achieve the storage purpose, or as specified by the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000, or any other applicable Indian law or regulation to which CarTelSol India Private Limited is subject. If the purpose of storage no longer applies or if a storage period prescribed by applicable Indian law expires, the personal data will be routinely blocked or deleted in accordance with statutory provisions. 5. Rights of the Data Principala) Right to confirmation Every data subject has the right to obtain confirmation from the Data Fiduciary as to whether personal data concerning them is being processed. This right is recognised under the DPDP Act. If a data subject wishes to exercise this right, they can contact us at any time. b) Right to information (Right of Access) Every data subject has the right to receive, free of charge, information about the personal data stored about them and a copy of this information from the Data Fiduciary. Under the DPDP Act, the Data Principal has the right to obtain a summary of the personal data being processed and the processing activities undertaken in respect of such data. This includes: • the purposes of processing • the categories of personal data that are processed • the recipients or categories of recipients to whom the personal data have been or will be disclosed • the period for which the personal data will be retained, or the criteria used to determine that period • the existence of a right to correction or erasure of personal data, or to restriction of processing by the Data Fiduciary, or a right to object to such processing • the right to file a complaint with the Data Protection Board of India • if the personal data are not collected directly from the data subject: all available information as to their source • the existence of automated decision-making • If a data subject wishes to exercise this right, they can contact us at any time. c) Right to correction and completion Every data subject has the right to obtain from the Data Fiduciary, without undue delay, the correction of inaccurate personal data concerning them. Under the DPDP Act, the Data Principal has the right to correction, completion and erasure of personal data. The data subject also has the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right, they can contact us at any time. d) Right to erasure Every data subject has the right to obtain from the Data Fiduciary the erasure of personal data concerning them without undue delay, where one of the following grounds applies: • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed. • The data subject withdraws consent on which the processing is based, and there is no other legal ground for the processing. • The data subject objects to the processing and there are no overriding legitimate grounds for the processing. • The personal data have been unlawfully processed. • The personal data must be erased for compliance with a legal obligation under applicable Indian law. • If one of the above grounds applies and a data subject wishes to request erasure of personal data held by CarTelSol India Private Limited, they can contact us at any time. We will arrange for the erasure request to be complied with promptly. e) Right to restriction of processing Every data subject has the right to obtain from the Data Fiduciary restriction of processing where one of the following applies: • The accuracy of the personal data is contested by the data subject, for a period enabling the Data Fiduciary to verify the accuracy. • The processing is unlawful and the data subject opposes erasure and requests restriction instead. • The Data Fiduciary no longer needs the personal data for processing purposes, but they are required by the data subject for the establishment, exercise or defence of legal claims. • The data subject has objected to processing, pending verification of whether the legitimate grounds of the Data Fiduciary override those of the data subject. • If a data subject wishes to exercise this right, they can contact us at any time. f) Right to data portability Every data subject has the right to receive the personal data concerning them, which they have provided to the Data Fiduciary, in a structured, commonly used and machine-readable format, and has the right to transmit those data to another controller without hindrance. The DPDP Act recognises the right of the Data Principal to data portability, subject to such conditions as may be prescribed. To exercise the right to data portability, the data subject can contact us at any time. g) Right to object / Right to grievance redressal Every data subject has the right to object to processing of personal data concerning them. Under the DPDP Act, the Data Principal has the right to have readily available means of grievance redressal provided by the Data Fiduciary. Any grievance must be addressed by the Data Fiduciary within such period as may be prescribed. Where personal data are processed for direct marketing purposes, the data subject has the right to object at any time to processing of personal data concerning them for such marketing. If the data subject objects to processing for direct marketing purposes, CarTelSol India Private Limited will no longer process the personal data for those purposes. To exercise this right, the data subject can contact us at any time. h) Automated decisions Every data subject has the right not to be subject to a decision based solely on automated processing — including profiling — which produces legal effects concerning them or similarly significantly affects them, where such decision is not necessary for the performance of a contract, not permitted by applicable law, or not based on the data subject's explicit consent. Where such decisions are made based on contract or consent, CarTelSol India Private Limited takes appropriate measures to safeguard the data subject's rights, including the right to obtain human intervention, to express their point of view and to contest the decision. i) Right to withdraw consent Every data subject has the right to withdraw their consent to the processing of their personal data at any time. Under the DPDP Act, withdrawal of consent shall be as easy as giving consent. Upon withdrawal, CarTelSol India Private Limited shall, within a reasonable time, cease and cause its Data Processors to cease processing the personal data, unless such processing is required or authorised under any law. To exercise the right to withdraw consent, the data subject can contact us at any time. j) Right to nominate Under the DPDP Act, a Data Principal has the right to nominate any other individual who shall, in the event of the death or incapacity of the Data Principal, exercise the rights of the Data Principal in accordance with the Act. 6. Legal Basis for Processing Under the DPDP Act, personal data may be processed on the basis of consent given by the Data Principal for a specified purpose. Personal data may also be processed for certain "legitimate uses" as specified in the Act, including processing necessary for the performance of a contract to which the Data Principal is a party, processing required under any law, processing for employment-related purposes, and processing for purposes related to public interest. Where CarTelSol India Private Limited processes personal data on the basis of consent, the Data Principal has the right to withdraw that consent at any time. Where processing is required by law (for example, under tax or corporate regulations applicable in India), the processing is carried out in accordance with such legal obligations. 7. Legitimate Use and Business Interests Where the processing of personal data is based on legitimate use under the DPDP Act, our legitimate interest is the conduct of our business activities for the benefit of all our employees and our shareholders. 8. Data Retention Period The criterion for the duration of storage of personal data is the applicable statutory retention period under Indian law, including the Companies Act, 2013, the Income Tax Act, 1961 and other applicable regulations. After the retention period has expired, the relevant data will be routinely deleted, provided it is no longer required to fulfil or initiate a contract. 9. Requirement to Provide Personal Data We inform you that the provision of personal data is partly required by law (e.g. tax regulations under the Income Tax Act, 1961 or GST laws) or may result from contractual requirements. In order to conclude a contract, it may be necessary for a data subject to provide us with personal data that we subsequently have to process. Failure to provide personal data would mean that the contract could not be concluded with the person concerned. Before providing personal data, the data subject is welcome to contact one of our employees, who will explain on a case-by-case basis whether the provision of personal data is required by law or contract, and what the consequences of non-provision would be. 10. Grievance Redressal Mechanism In accordance with the Information Technology Act, 2000 and the DPDP Act, CarTelSol India Private Limited has designated a Grievance Officer to address complaints and concerns regarding the processing of personal data. Data Principals may contact the Grievance Officer at: CarTelSol India Private Limited AS 01-02, Covent Garden, Near DPS Kalinga, Phulnakhra, Cuttack – 754001, Odisha, India Contacts : All grievances will be acknowledged and addressed within the period prescribed under applicable law. 11. Right to Lodge Complaint In the event that a Data Principal is not satisfied with our response to a grievance, they have the right to approach the Data Protection Board of India established under the DPDP Act. The Board has the authority to inquire into complaints, impose penalties and issue directions. 12. Automated Decision-Making As a responsible company, CarTelSol India Private Limited does not use automatic decision-making or profiling that produces significant legal effects concerning data subjects. This Privacy Notice has been prepared in accordance with the Digital Personal Data Protection Act, 2023 (DPDP Act), the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and other applicable Indian data protection laws. It will be updated as and when the law or our practices change.