Privacy Policy
1. About This Policy
DENSO International India Private Limited, DENSO India Private Limited, DENSO Haryana Private Limited, DENSO Kirloskar Industries Private Limited, DENSO SUBROS Thermal Engineering Centre India Private Limited and other DENSO affiliates in India (“DENSO,” “we,” “us,” or “our”) will process your Personal Data (defined below) in compliance with applicable personal data protection laws, including Digital Personal Data Protection Act, 2023 (“DPDPA”) and any law that amend or replace them in the future. We pledge to manage your Personal Data by diligently pursuing the prevention of unauthorized use, accidental disclosure, sharing etc. of Personal Data about you.
In this Privacy Policy (this “Policy”), we provide information on our practices regarding the Processing your Personal Data and other information, within the meaning of DPDPA. Please read and understand this, Policy.
Definition of “Process” or “Processing”
“Process” or “Processing” in this Policy means a set of operations performed on personal data, and includes operations such as collection, recording, organization, structuring, storage, adaptation, retrieval, use, alignment, or combination, indexing, sharing, disclosure by transmission, dissemination or otherwise making available, restriction, erasure or destruction. In addition, “process” means an action of processing”.
Some categories of processing of Personal Data may be subject to more specific policies. In such cases, those specific policies shall supersede this Privacy Policy to the extent that the clauses set forth in those specific policies contradict the clauses set forth in this Privacy Policy.
If you are an individual in the European Economic Area (EEA), please read Addendum for Individuals in EEA for additional information.
If you are a California "consumer" within the meaning of the California Consumer Privacy Act of 2018, please read Addendum for California Consumer Privacy Act for additional information.
2. Contact Us
If you have inquiries or question regarding this Policy for companies listed below, please send email to us: ap_india_infoincident@ap.denso.com
(a) DENSO International India Private Limited.
(b) DENSO India Private Limited.
(c) DENSO Haryana Private Limited.
(d) DENSO Kirloskar Industries Private Limited.
(e) DENSO SUBROS Thermal Engineering Centre India Private Limited.
3. What is the Personal Data
“Personal Data” means any data about an individual who is identifiable or in relation to such data but excludes the data that is made or caused to be made publicly available by you; or any other person who is under an obligation under any law for the time being in force in India to make such Personal Data publicly available.
4. How We Collect Your Personal Data
We collect and process the following Personal Data about you:
(a) Personal Data you give us. This includes information about you that you give us through transactions, or by communicating with us, whether by e-mail, letter or otherwise. The Personal Data you give us is likely to include your contact information such as your name, address, e-mail address, phone number.
(b) Personal Data third parties give us. This includes information about you that third parties give us through transactions, or by communicating with us, whether by e-mail, letter or otherwise. The information third parties give us is likely to include your contact information such as your name, address, e-mail address, phone number.
(c) Personal Data we collect about you. When you use our products or services, some of our products or services automatically collect certain types of data related to you based on terms of use. These types of data include access logs or cookies, etc. These types of data may remain in your computer and continue to collect data.
5. Legal Basis for and Purpose of Processing Personal Data
We will process your Personal Data on the following legal bases unless such data processing will conflict with applicable laws and regulations:
(a) Contract. When we need to process your Personal Data to perform a contract, we enter with you.
(b) Legal Obligation. When we need to comply with a legal obligation.
(c) Legitimate Interests. When the processing of your Personal Data is necessary for the fulfilment of legitimate interests stipulated in Section 7 of DPDPA.
(d) Consent. When you have given consent for us to process your Personal Data. The withdrawal of your consent shall not affect the lawfulness of processing performed based on the consent before your withdrawal.
We process the Personal Data that we hold about you for the following purposes. We will only process your Personal Data to the extent that it is necessary to do so to fulfil the purposes described below. Further, we pledge that we do never process Personal Data of a child (means person under 18 years old) without valid individual consent.
(a) To provide products or services (including after sales services such as maintenance and repair) that you request (based on contract or legitimate interests)
(b) To help ensure security and integrity, we will use your Personal Data only to the extent that it is reasonably necessary and proportionate for such purpose.
(c) To improve our products or services we provide to you (based on legitimate interests)
(d) To provide information and communications; to conduct questionnaires relating to products, services, various events, campaigns, and similar matters (based on consent or legitimate interests)
(e) To conduct sales analysis, investigations, and research; to develop new products or services (based on consent or legitimate interests)
(f) To conduct web analytics
(g) (See our Cookie Policy: https://www.DENSO.com/global/en/cookie-policy/
(h) To improve the business operations, products and services: To make assessment, analysis, management, improvement, research, planning, surveying and statistical analysis in order to develop the quality system and safety of our products and services, such as product satisfaction, satisfaction about the product sales or services of DENSO, including the information about your preferences and interests in our products or services or to create aggregated and anonymous reports so as to learn about the problems and solutions or the staff training and the employee performance evaluation for businesses, products and services improvement.
(i) To ensure compliance with legal obligations (such as record keeping obligations), export control and customs, and our policies or industry standards (based on legal obligation or legitimate interests)
(j) To solve disputes, enforce our contractual agreements and to establish, exercise or defend legal claims (based on legal obligation or legitimate interests).
Providing your Personal Data is voluntary. However, you may experience disadvantages if you refuse to provide your Personal Data, such as being unable to make use of some of our services.
6. Disclosure of Personal Data to Recipients
We may share your Personal Data with the following categories of recipients.
(a) Affiliates. We may share your Personal Data with our affiliates for internal administrative purposes and for uses that are consistent with this Policy. The respective transfer of your Personal Data is based on legitimate interests. Legitimate interests are the transmission of Personal Data within the group of companies for internal administrative and support purposes. The access is limited to colleagues with a need to know.
(b) Service Providers. We may share your Personal Data with service providers, including network service providers, analytics service providers, and other service providers, who act as Data Processors of DENSO when providing their services. Service providers will be subject to contractual obligations, such as to implement appropriate technical and organizational security measures to safeguard the Personal Data and to process the Personal Data only as instructed.
(c) Other Recipients. DENSO may also transfer your Personal Data to law enforcement agencies, governmental authorities, legal counsel and external consultants in compliance with applicable laws. The legal basis for such processing is compliance with a legal obligation to which DENSO is subject to or are legitimate interests, such as exercise or defence of legal claims.
7. Cross-Border Transfers
The Personal Data that we hold about you may be transferred to, and stored by, a third party outside India. Such countries include the countries in which our affiliates or service providers above are located.
In the event that the recipients of your Personal Data are located outside India for which the Indian government has not made an adequacy decision to the effect that an adequate level of data protection exists in these third countries, we will take other measures to implement appropriate guarantees for the protection of your Personal Data in accordance with DPDPA.
Personal Data is only transferred to external recipients in third countries if, for example, they have concluded an appropriate and valid contract with us.
8. Storage Limit for Personal Data
Your Personal Data will be retained as long as necessary to provide you with the services requested. When DENSO no longer needs to use your Personal Data to comply with contractual or statutory obligations, we will remove it from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it, unless we need to keep your information, including Personal Data, to comply with legal or regulatory obligations to which DENSO is subject, e.g. statutory retention periods, or if we need it to preserve evidence within the statutes of limitation.
9. Career Pages
Through the career pages we seek to recruit new personnel for our organization. The career pages collect a variety of personal data, such as name, date of birth, correspondence address, e-mail address, telephone number, and other information from you. The personal data provided by any eligible applicants on the application form will be reviewed by our Human Resource Department. The Human Resource Department will also confirm receipt of the application and further correspondence may be sent to the applicants.
10. Your Rights
Pursuant to applicable data protection law you may have the right to: request access to your Personal Data, request correction of your Personal Data; request erasure of your Personal Data, request restriction of processing of your Personal Data, and object to the processing of your Personal Data. Please note that these rights might be limited under the applicable DPDPA. For further information on these rights please refer to the following Your Rights list.
If you have declared your consent for any Personal Data processing activities, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.
You can exercise your rights by contacting us using the information about us indicated in Section 2 of this Policy.
[Your Rights]
(a) Right of access
You may have the right to obtain from us confirmation as to whether or not Personal Data concerning you is processed, and, where that is the case, to request access to the Personal Data. The access information includes – inter alia – the purposes of the processing, the categories of Personal Data concerned, and the recipients or categories of recipients to whom the Personal Data have been or will be disclosed. However, this is not an absolute right, and the interests of other individuals may restrict your right of access. You may have the right to obtain a copy of the Personal Data undergoing processing.
(b) Right to correction
You may have the right to obtain from us the correction of inaccurate Personal Data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.
(c) Right to erasure ("right to be forgotten")
Under certain circumstances, you may have the right to obtain from us the erasure of Personal Data concerning you and we may be obliged to erase such Personal Data.
(d) Right to restriction of processing
Under certain circumstances, you may have the right to obtain from us restriction of processing your Personal Data. In this case, the respective data will be marked and may only be processed by us for certain purposes.
(e) Right to object
Under certain circumstances, you may have the right to object, on grounds relating to your situation, at any time to the processing of your Personal Data by us and we can be required to no longer process your Personal Data. Moreover, if your Personal Data is processed for direct marketing purposes, you have the right to object at any time to the processing of Personal Data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your Personal Data will no longer be processed for such purposes by us.
(f) Right to Nominate
Under certain circumstance, you may have the right to nominate any other individual, who shall, in the event of death or incapacity of yours, exercise your rights under DPDPA.
11. Security
To protect your Personal Data against accidental or unlawful destruction, loss, use, or alteration and against unauthorized disclosure or access, we use adequate organizational, human, physical, and technical security measures. No method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.
12. Changes to this Privacy Policy
We may modify this Privacy Policy from time to time and will post the updated Private Policy with a “Last Updated” effective date for the revisions. We recommend that you review this Privacy Policy periodically.