PLEASE READ THIS PRIVACY STATEMENT/PRIVACY POLICY CAREFULLY. “YOU” AND “YOUR” SHALL REFER TO THE CUSTOMER OR VISITOR OF THE GRAPHENE WEBSITE. “WE,” “OUR” OR “US” SHALL REFER TO GRAPHENE, PROVIDING OR OFFERING SERVICES TO YOU OR CUSTOMER OF GRAPHENE.

Graphene is committed to protecting the privacy of personal information of our customers and visitors which has been provided to us or collected by us when you use our products and services or visit our website. Our Privacy Statement is designed and developed to understand the privacy and security of customers’ or visitors’ personal information.

This Privacy Statement/Policy explains the collection, use, protection, disclosure, sharing and transfer, if any, of “personal information” by Graphene. Graphene reserves its right to amend this Privacy Policy from time to time based on changes as per the business, legal and regulatory requirements and applicable laws and the same shall be updated on this website. You are encouraged to periodically visit this page to review the policy and any changes. By using our website or our products/services or otherwise providing information to us through this website, you consent that your personal information may be used and handled as described in this Privacy Statement.

This Privacy Policy is subject to changes as per applicable laws and regulations and shall stand amended from time to time.

Definition of Personal Information

Personal Information includes:

Personally Identifiable Information (hereinafter referred to as PII): “Personally Identifiable Information” is information that is about, or can be related to, an identifiable individual. It includes any information that can be linked to an already identified individual or used to directly or indirectly identify an individual. Personal information does not include information that is anonymous, aggregated, or is no longer identifiable to a specific person.

Sensitive Personal Data or Information (hereinafter referred to as SPDI): “Sensitive Personal data or Information” means personal information which is more sensitive in nature viz. financial information such as Bank account or credit card or debit card or other payment instrument details, Biometric details, passwords or authentication information for any of our products or services etc.

For the purposes of this Privacy Statement, sensitive personal data or information has been considered as a part of Personal Information.

This Privacy Statement describes the Personal Information which we may collect and our approach towards handling or dealing with the same. This Privacy Statement is designed to enable you understand:

• Personal information that we collect and methods of collection
• Purposes of collection and usage of personal information
• Measures taken by us to protect your personal information
• Usage of Cookies, Device Identifiers and other similar technologies
• Disclosure, Sharing and Transfer of your Personal Information
• Ways by which you can access and update your Personal Information

This Privacy Statement is provided for your information and is not intended to limit or exclude your rights under laws and regulations.

1. Collection of Personal Information:

Graphene and its authorized Third Parties will collect information pertaining to your identity, demographics, and related evidentiary documentation. For the purposes of this document, a ‘Third Party(ies)’ is a service provider which is associated with Graphene and is involved in handling, managing, storing, processing, protecting and transmitting information on behalf of Graphene. This definition also includes all sub-contractors, consultants and/or representatives of the Third party.

The information we collect about you will depend on our products and services you use and/or subscribe to. We may hold information relating to you that we may have obtained from another source such as our suppliers or from marketing organizations. We may also collect your personal information when you use our services, websites, and applications or otherwise interact with us during the course of our relationship.

The information we may collect includes, but is not limited to, the following:

• Your name, date of birth, current and previous addresses, telephone number, mobile phone number, email address, and any such information.
• Information that gets generated during your use of our website, products and your browsing history (including the date, time and duration of your internet session), application and feature usage, and your preferences (i.e. tracking our website and application usage information) and other information that you may provide to us from time to time for the services that you receive from Graphene.
• We may use cookies and other techniques, such as web beacons, to collect information about how you use our websites, and web-related products and services. This allows us to customize our website for you so that it is relevant to your interests and needs.
• Your preferences for particular products, services or lifestyle activities when you tell us what they are or when we assume what they are based on how you use our products and services.
• Your contact with us, such as: a call you make to one of our offices, an email or letter you send to us and other records of any contact you have with us.
• As per data protection rules, we shall seek explicit consent from you while we collect your Sensitive Personal Data or Information (SPDI).

2. Use of Personal Information:

The information that we collect from you is held in accordance with applicable laws and regulations in the jurisdiction where we collect such information. It may be used by us for a number of purposes connected with our business operations and functions. We may use this information to contact you regarding matters relevant to the underlying service provided. Further we may use and analyze your personal information for various lawful purposes and enrichment of service experience. If required for business and to provide better services to you, we may acquire your information from our business partners and third parties (during our business association with them), while you are availing their service through us.

The purposes for which your personal information may be used includes, but is not limited to:

• Provide, maintain and improve our products and services.
• Verify your identity as mandated by laws and regulations.
• Process your orders and applications.
• Keep you informed about new products and services unless you do not want to receive our marketing messages.
• Data Analytics that help us get valuable insights to enhance customer experience as well as improve upon service delivery.
• Provide the relevant service or product to you, which includes other services not included in your agreement with us and to contact you with service-related messages about changes to the service or product.
• Administer your account and bill you for using our products or services or to take appropriate amounts for the products or services rendered to you.
• Respond to any questions or concerns that you may have about using our products or services.
• Contact you (including by post, email, fax, short text message (SMS), or telephone) with offers and promotions about the products and services of carefully selected third parties which we think may be of interest to you (unless you ask us in writing not to) and who have been contracted with us to keep the information confidential, or who are subject to obligations to protect your personal information. For completeness we note that where such contact is via electronic means, our terms and conditions record our agreement with you that the electronic marketing messages we and our selected third parties send need not include an unsubscribe facility.
• Carry out research and statistical analysis and monitor customer use of our products and services on an anonymous or personalized basis.
• Carry out any activity in connection with a legal, governmental or regulatory requirement on us or in connection with legal proceedings, crime or fraud prevention, detection or prosecution.
• Other usages that you may consent to.
• Graphene will retain your information for as long as we have to by law and as per directions of the regulatory & law enforcement authorities. If there is no legal requirement, we will only store your information for as long as we have the justified business requirement and we need it for providing services to you. After that, Graphene will destroy it by making it unreadable or undecipherable.

3. How We Protect Your Personal Information:

We adopt reasonable security practices and procedures, in line with international standard IS/ISO/IEC 27001, to include, technical, operational, managerial and physical security controls in order to protect your personal information from unauthorized access, or disclosure while it is under our control.

• To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we maintain appropriate physical, electronic, and managerial procedures to safeguard and secure the information and data stored on our system.
• Our security practices and procedures limit access to personal information on a need to know basis. Further, our employees, to the extent they may have limited access to your personal information on a need to know basis, are bound by Graphene Code of Conduct and confidentiality policies which obligate them to protect the confidentiality of your personal information.
• We take steps to ensure that our contracted third parties adopt reasonable level of security practices and procedures to ensure security of personal information. We cannot protect any information that you make available to the general public in any publicly accessible area of our website or any other media.
• When we dispose of your personal information, we use reasonable procedures to erase it or render it unreadable
• No data transmission over the Internet is completely secure and for reasons outside of our control, security risks may still arise. Any personal information transmitted to us or from our online products or services will therefore be at your own risk. However, we will strive to ensure the security of your information. We observe reasonable security measures to protect your personal information against hacking and virus dissemination.

4. Use of Cookies and similar technologies:

We may use cookies and other interactive techniques to collect personal and non-personal information about you. The cookies mean that our website platforms may remember you to personalize the content and how you’ve used the site every time you come back; understand what you like and use about our website; understand what you do not like and do not use on our website; provide a more enjoyable, customized service and experience, and help us develop and deliver better products and services tailored to our customers’ interests and needs.

We may sometimes use a persistent cookie to record details such as a unique user identity and general registration details on your PC. This helps us recognize you on subsequent visits to this website so that you don’t have to re-enter your registration details each time you visit us and allows us to carry out the activities mentioned above.

Using cookies and device identifiers, we may compile information about where you, or others who are using your computer or mobile devices, saw the advertisements and determine which advertisements are clicked. This information allows our advertising partners to deliver targeted advertisements that they believe will be of most interest to you.

Graphene does not have access to or control of the cookies /device identifiers that may be placed and used by third party applications, websites or platforms. These third party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these third party sites. Nonetheless, we seek to protect the integrity of our website/applications.

Most browser technologies (such as Internet Explorer, Chrome, etc.) allow you to choose whether to accept cookies or not – you can either refuse all cookies or you can set your browser to alert you each time that a website tries to set a cookie.

5. Disclosure, Sharing and Transfer of Personal Information:

Authorized Third Parties: Graphene may at its discretion employ, contract or include third parties external to itself for strategic, tactical and operational purposes. We may disclose and/or transfer your personal information or other information collected (as defined in section 1: Collection of personal information), stored and processed by us to such third parties. Such third parties though external to the Company, will always be entities which are covered by contractual agreements. These agreements in turn include Graphene’s guidelines to the management, treatment and secrecy of personal information. This may also include:

• Sharing your Sensitive Personal Data or Information (SPDI). However, as per Rules, we shall seek explicit consent from you at the time of collection if we intend to share your Sensitive Personal Data or Information (SPDI) with third parties.
• Sharing aggregated & anonymized information about the subscriber with authorized third parties in order to provide better product & services (now or in future).

Authorized third-parties include our subsidiaries, divisions, and third-party business affiliates but not limited to:

• Partners or agents who are involved in delivering the products and services you have ordered or used.
• Our Business partners involved in delivering and improving our services.
• Our IT vendors hosting our websites and applications; operating various features available on the website and applications; sending emails; analyzing data; providing search results and links and assisting in fulfilling your orders.

Government Agencies: Graphene may also share your personal information with Government agencies or other authorized law enforcement agencies (LEAs) mandated under law to obtain such information for the purpose of verification of identity or for prevention, detection, investigation including but not limited to cyber incidents, prosecution, and punishment of offences. This may also include sharing your Sensitive Personal Data or Information (SPDI).

Marketing Agencies: If you have opted to receive marketing material from us, we may also provide your personal or anonymized information to carefully selected third parties who we reasonably believe provide products or services that may be of interest to you and who have been contracted with Graphene to keep the information confidential, or who are subject to obligations to protect your personal information.

We will never share your Sensitive Personal Data or Information (SPDI) with any Marketing agencies.

Data Analytics: We may permit certain authorized third parties to track your usage, and analyze your personal data. Data Analytics is performed in order to better understand our products and services usage, and enhance them by helping us make better decisions.

Other Scenarios: We may transfer personally identifiable information as an asset in connection with a merger or sale (including any transfers made as part of an insolvency or bankruptcy proceeding) involving all or part of our business or as part of a corporate reorganization, stock sale or other change in control. Graphene may disclose Contact Information in special cases where we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our terms and conditions of use or may be causing injury or interference with our rights, property, our customers or anyone who could be harmed by such activities.

6. Update of Personal Information:

We strive to keep our records updated with your latest information. To this end, if you see any discrepancy in your personal information or if a part of your personal information changes, we request you to reach out to us and communicate the change(s) for updating our records.

7. Notification of Changes:

Graphene reserves the right to amend / alter / modify and/or change this Privacy Statement at its sole discretion as needed based on change in technology, laws, rules and regulations both national and international as may be applicable, orders and instructions from judicial, quasi-judicial , administrative authorities apart from business exigencies. If there is such change to our Privacy Statement, the same shall be updated on the Company website and from such date of updation the Privacy policy will be displayed on the website and shall be applicable.

Contact Us
We are committed to safeguarding your personal information collected and handled by us and look forward to your continued support for the same. In case of any feedback or concern regarding protection of your personal information, you may reach us by contacting us.