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UPL LIMITED ("we", "us", "UPL" or "our") takes data protection seriously. We recognise the trust that individuals place in us when they provide us with Personal Information and we are committed to protecting the privacy and security of Personal Information.
In this policy, the term "you" refers to any natural person whose Personal Information we collect and process in the course of operating this website.
This Privacy Policy is intended to help you understand our practices regarding the collection, use and disclosure of Personal Information. This Privacy Policy aligns with the highest standards of data protection, as defined by the European Union's General Data Protection Regulation (GDPR) and the United Kingdom's Data Protection Act. These standards ensure comprehensive protection of personal data. Due to the high level of protection, this applies to our websites worldwide. For data subjects in individual jurisdictions, the Appendix contains additional information that applies supplementally. The Appendix may be updated periodically to reflect any changes in international privacy standards.
To do this, we explain the following:
1. Who is responsible for the processing of your Personal Information
2. What Personal Information we collect from you
3. How we obtain your Personal Information
4. How we use cookies on this website
5. How we use your Personal Information
6. With whom we share your Personal Information
7. To which countries we transfer your Personal Information
8. How long we store your Personal Information
9. How we protect your Personal Information
10. What rights you have in relation to your Personal Information
11. How you can contact us
12. How we will update this Privacy Policy
By providing us with your Personal Information on this website, you agree to the processing set out in this Privacy Policy. Further notices highlighting specific uses of your Personal Information and the ability to opt in or out of selected uses may also be provided to you when we collect Personal Information from you.
This Privacy Policy is intended to help you understand our practices regarding the collection, use and disclosure of Personal Information. To do this, we explain the following:
1. Who is responsible for processing your Personal Information
The entity responsible for the processing of your Personal Information is
UPL LIMITED, at 3-11, GIDC, Vapi 396 195, Gujarat, India
2. What Personal Information we collect from you
Personal Information (hereinafter referred to as "Personal Information") is information (in any format) that relates to a living individual who can be identified from that information, either alone or when combined with other information held by us. Depending on the jurisdiction, the term "Personal Information" is also used. For the purposes of this Policy, the terms are synonymous.
We may collect and process various types of Personal Information in the course of operating this website. These include:
Technical data about your end device or internet connection such as IP address, browser information, language settings, information about the operating system;
Cookies and other identifiers that we store or read on your end device (see also section 4);
Basic Personal Information such as your name and contact details, such as your e-mail address, telephone number, country and state, if you provide us with this information via our contact form;
Information about your business, such as your company name and partner type, if you provide us with this information via the contact form;
Information about our products that you are interested in when you provide us with this information via the contact form;
All contents of messages that you send us via the contact form.
3. How we obtain your Personal Information
We may collect or receive your Personal Information in various ways:
We receive technical data automatically when you visit our website; we set and read cookies according to the settings you have made in the cookie settings (see section 4);
We receive data that you enter via the contact form when you send it.
4. How we use cookies on this website
To find out more about our use of cookies, visit our Cookie Policy.
5. How we use your Personal Information
We only use your Personal Information if we are authorised to do so under applicable law.
The main legal bases that justify our use of your Personal Information are:
Contract Fulfillment: If your data is required for the conclusion or fulfillment of our contract with you.
Legal Obligation: If we need to use your data to fulfill our legal obligations.
Legitimate Interests: Where we use your data to achieve a legitimate interest and our reasons for doing so outweigh any prejudice to your data protection rights.
Legal Claims: If your information is required for the defense, prosecution, or assertion of a claim against you, us, or a third party.
Consent: Where you have consented to our use of your data (you have been provided with a consent form or a consent notice in relation to such use and can withdraw your consent at any time).
Please find further information on the legal bases depending on the region you are located in the Appendix to this policy.
6. With whom we share your Personal Information
UPL is a global organisation. As such, any Personal Information that we collect or that you provide to us may be shared and processed with any UPL entity in our global network.
We may also share your Personal Information with third party service providers to whom we outsource certain functions such as information and document management, office support, technology and IT services, customer relationship management, word processing, photocopying and translation services. We have entered into agreements with these service providers to protect the confidentiality and security of the information (including Personal Information) shared with them.
We do not authorise our third-party providers to use your Personal Information for their own purposes, but only to process your Personal Information for specific purposes and in accordance with our instructions.
We may also process your Personal Information to comply with our regulatory requirements or as part of our dialogue with our regulators, which may include disclosing your Personal Information to governmental, regulatory or law enforcement authorities in connection with any request, proceeding or investigation by such parties anywhere in the world or where required. Where permitted or where it would not prejudice the prevention or detection of a criminal offence, we will make such a request to you or notify you before responding.
7. To which countries we transfer your Personal Information
As a global organisation, we cannot limit our processing of an individual's Personal Information to the country in which that individual is located. In the course of providing our services, we may need to transfer Personal Information to locations outside of the jurisdiction in which you provide it or in which you visit our website. If you are a resident of the United Kingdom (UK) or the European Economic Area (EEA), this means that your Personal Information may be transferred to, accessed from, and/or stored at a destination outside the UK/EEA where data protection laws may not be as comprehensive as those in the UK/EEA.
Regardless of where we process your Personal Information, we will apply the same data protection measures that we apply within the UK/EEA and take appropriate steps to ensure that your Personal Information is protected in accordance with applicable data protection laws. Similarly, where a third-party provider processes the Personal Information of EEA or UK residents on our behalf, we will ensure that appropriate measures are in place to ensure an adequate level of protection for your Personal Information, typically by including standard contractual clauses in our agreements with those third-party providers.
In the event that there is no adequacy decision in relation to the country to which your Personal Information is transferred, appropriate safeguards will be implemented in addition to the standard contractual clauses to ensure the protection of your Personal Information. These measures may be of a contractual, organizational, or technical nature.
Please contact us as set out below if you would like to see a copy of the specific safeguards in place for the export of your Personal Information.
8. How long we store your Personal Information
We will retain your Personal Information for as long as necessary to fulfill the purpose for which it was collected and any other permitted associated purposes. If your Personal Information is used for two purposes, we will store it until the purpose with the last period expires. However, we will no longer use it after this period for the purpose with a shorter period. Our retention periods are also based on our business requirements and best practices.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
Technical data that we process automatically for the display and use of the website is only stored temporarily during your website visit and then deleted. Data that you provide to us via the contact form will be stored by us for up to three years after the end of the communication. Data may be processed for longer if you have given your consent.
9. How we protect your Personal Information
We recognize that information security is an integral part of data protection. Although no data transmission (including over the internet or a website) can be guaranteed against intrusion, we implement a range of commercially reasonable physical, technical, and procedural measures to protect Personal Information from unauthorized access, use, disclosure, alteration, or destruction in accordance with data protection requirements.
Information you provide to us will be stored on our or our service providers' secure servers and accessed and used in accordance with our security policies and standards or the policies and standards agreed with our service providers.
Everyone at UPL and any third-party providers that we may engage to process Personal Information on our behalf (for the purposes listed above) are also contractually obliged to respect the confidentiality of Personal Information.
10. What rights you have in relation to your Personal Information
If you have any questions about our use of your Personal Information, you should contact us in the first instance using the contact details set out in section 11 below. In certain circumstances you may have specific data subject rights. An overview of the relevant data subject rights for the region in which you are located can be found in the Appendix to this Privacy Policy.
11. How you can contact us
If you have any questions about this Privacy Policy or the processing of your Personal Information, please contact our data protection officer by e-mail to: legal.europe@upl-ltd.com.
12. How we will update this Privacy Policy
We regularly review our Privacy Policy. Please do not hesitate to consult it regularly to be informed of the changes made.
This version was last updated on 1 November 2024.
1. California residents
I. If you are a resident of California, we shall handle your Personal Information in consonance with the California Consumer Privacy Act (CCPA). We will not, without your consent, disclose your Personal Information. You hereby give us consent to disclose your Personal Information for business purposes. You consent to and agree to direct us to and/or use the Services to intentionally disclose Personal Information or to intentionally interact with a third party.
II. We will not, without your consent, sell and/or disclose your Personal Information for valuable consideration. If you have given us your Personal Information, we have not sold and/or disclosed it for valuable consideration in the twelve (12) months immediately preceding the last update of this Privacy Statement.
III. You consent and agree that we may disclose the following categories of such Personal Information of consumers (as defined under the CCPA) in the 12 months immediately preceding the last update of this Privacy Statement:
a. Identifiers such as your name, email address etc.
b. Geolocation data such as the location of a consumer’s device or computer etc.
c. Internet or other electronic network information
d. Professional or employment- related information
e. Inferences drawn from any of the above information
IV. As a resident of California, you have certain additional rights in relation to your Personal Information;
a. Right to access – You have a right to and are allowed access to your data that we collect and process.
b. Right to deletion – You have a right to request deletion of your Personal Information. This right is a subjective right, we may not comply with a data deletion request if we are permitted and/or required under law.
c. Right to disclosure – You have a right to request us to disclose the categories of Personal Information collected, sources from which Personal Information is collected, purpose of collecting Personal Information, categories of third parties with whom Personal Information is shared.
d. You have a right not to be discriminated against for exercising certain rights under California law.
e. You may exercise your rights by contacting us at the contact details provided herein under.
2. EEA residents
I. This is applicable only to persons in the European Economic Area (EEA). We ensure that all your data that we collect, store, use and process is done in compliance with the General Data Protection Regulation (GDPR). Elucidated hereunder are Data Subject Rights applicable to citizens of the EEA.
II. Legal basis for processing your Personal Information:
We may use your Personal Information in the following ways. In each case, we note the legal basis we rely on when using your Personal Information.
| Purposes of the processing | Processing details | Type of Personal Information | Legal bases of processing |
|---|---|---|---|
| Displaying the contents of the website | To be able to display the information on this website on your device and to enable your interaction on the website | Technical data; cookies (in accordance with the more detailed provisions under section 4) | - Legitimate interests in operating our website |
| Security and fraud prevention | To prevent attacks on our website and combat fraud | Technical data without permanent storage | - Legitimate interests in protecting our website and IT infrastructure |
| Analysis and development purposes | To improve the content and user experience of our website | Cookies (in accordance with the more detailed provisions under section 4) | - Consent (for more details on Cookies see section 4) |
| For communication purposes | To answer your enquiries that you send us via our contact form | Basic Personal Information; contact details; information about our products; information about your business; content of your messages to us | - Legitimate interests to get in touch with you and answer your questions |
III. Residents of EEA have certain additional rights in relation to their Personal Information under the General Data Protection Regulation (GDPR);
a. Right to access – You have a right to and are allowed access to your Personal Information that is processed.
b. Right to erasure – You may request erasure of your Personal Information only under certain circumstances which include but are not limited to unlawful processing of your data, if your Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed, if you withdraw your consent etc. Please note, however, that we may need to retain certain information to comply with our legal obligations.
c. Right to rectification – You may at any time request for rectification of your Personal Information that we process. You may also complete Personal Information if it is incomplete.
d. Right to restriction of processing – You have a right to restrict the processing of Personal Information if you contest the accuracy of the data, lawfulness of processing and or if you have objected to processing of data or if the data is no longer needed for the purpose of processing. We will inform you when such restrictions are lifted.
e. Right to data portability – You have a right to receive the Personal Information you have provided to us in a structured, commonly used and machine-readable format. You are also entitled to the right to transmit your Personal Information to another controller to another where it is technically feasible.
f. Right to object – You have a right to object to the processing of your Personal Information. You have a right to object where your Personal Information is processed for marketing purposes.
g. Right to withdraw your consent - If you have given us your consent to process your Personal Information, you can withdraw this at any time. the lawfulness of the processing of the data processed up to that point remains unaffected.
If you contact us to exercise one of these rights, we will review your claim and usually respond within one month.
If you are not satisfied with our use of your Personal Information or our response to the exercise of these rights, you have the right to lodge a complaint with the competent supervisory authority (data protection authority). You can find the competent data protection authorities in Europe through the European Data Protection Board (EDPB) website, which provides a comprehensive list of national data protection authorities along with their contact information. The EDPB website can be accessed at: https://edpb.europa.eu/about-edpb/board/members_en.
3. UK residents
I. These Data Subject Rights shall be applicable to persons in the United Kingdom. We shall collect, use, store and process your Personal Information only in accordance with the Data Protection Act, 2018 and other regulations and guidelines on data privacy protection and data security. Elucidated hereunder are rights available to persons in the UK;
a. Right to access – You have a right to and are allowed access to your Personal Information that is processed.
b. Right to erasure – You may request erasure of your Personal Information only under certain circumstances which include but are not limited to unlawful processing of your data, if your Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed, if you withdraw your consent etc. Please note, however, that we may need to retain certain information to comply with our legal obligations.
c. Right to rectification – You may at any time request for rectification of your Personal Information that we process. You may also complete Personal Information if it is incomplete.
d. Right to restriction of processing – You have a right to restrict the processing of Personal Information if you contest the accuracy of the data, lawfulness of processing and or if you have objected to processing of data or if the data is no longer needed for the purpose of processing. We will inform you when such restrictions are lifted.
e. Right to data portability – You have a right to receive the Personal Information you have provided to us in a structured, commonly used and machine-readable format. You are also entitled to the right to transmit your Personal Information to another controller to another where it is technically feasible.
f. Right to object – You have a right to object to the processing of your Personal Information.
You may exercise any of the rights enlisted above by contacting us at the contact details provided below. In exercise of your rights you may be required to provide us with sufficient information for us to confirm your identity, which shall include but shall not be limited to your full name, address, username or registration details. In addition to the above you will also be required to confirm the right you wish to exercise and the Personal Information to which your request relates.
4. Singapore residents
I. If you are a resident of Singapore, we collect, use and process your data in accordance with the Personal Information Protection Act (PDPA), 2012. Details of our obligations, and your rights and other essential provisions are set out herein below.
II. Accuracy of your Personal Information: We will make all reasonable efforts to ensure that the Personal Information collected by us is accurate, complete and up-to-date. We shall adopt methods to verify and authenticate information provided by you. We shall make sure that any and/or all changes made or requested are updated in our records. We rely on the information you provide to us for performing our obligations/ Channels to you, you are required to provide us with accurate and complete information and to promptly update us in the event there are any changes to your Personal Information.
III. Your Rights
a. You shall, to the extent that the applicable law allows, have the right to request access to your Personal Information held by us.
b. You have a right to request correction/ rectification of your Personal Information entrusted to us or update your Personal Information held by us.
c. You have a right to request us at any time to limit the processing and use of your Personal Information.
d. You may by giving notice, withdraw any consent given to us for the collection, use or disclosure of your Personal Information. We shall upon receipt of such notice inform you of the repercussions of withdrawing your consent. We may not allow withdrawal of consent in circumstances where it is required or authorised under this Act or any other written law. It is essential to note that your withdrawal of consent could result in legal consequences arising from such withdrawal.
5. Indian Residents
I. These Data Subject Rights shall be applicable to processing activity within the territory of India or outside Indian when the processing activity is related to persons residing in the Republic of India. We shall collect, use, store and process your Personal Information only in accordance with the Digital Personal Information Protection Act, 2023 (to be referred to as “DPDPA”) and other regulations and guidelines on data privacy protection and data security that are and/or will be in force in India. Elucidated hereunder are rights available to persons residing in the Republic of India-
a. Right to access information about Personal Information- You have a right to access the following information-
i. A summary of Personal Information which is being processed by us and the processing activities undertaken by us with respect to such Personal Information;
ii. The identities of all other third persons with whom the Personal Information has been shared by us, along with a description of the Personal Information so shared; and
iii. Any other information related to your Personal Information and its processing, as may be prescribed by the relevant laws in force.
b. Right to correction and erasure of Personal Information- You shall have the right to correct, complete, update and erase your Personal Information for the processing of which you have previously given consent or provided deemed consent.
c. Right of grievance redressal. You shall have the right to readily available means of grievance redressal by us, with respect any of the rights that have been mentioned earlier or any of our obligations under the relevant Indian laws. We shall respond to your grievances as per the prescribed time periods as per the Indian laws or thirty (30) days, whichever is earlier. If your grievance has not been suitably redressed then you are entitled to approach the Data Protection Board of India.
d. Right to nominate.
i. You shall have the right to nominate, any other individual, who shall, in the event of your death or incapacity, exercise your rights in accordance with the provisions of the DPDPA and the rules made thereunder.
ii. The expression “incapacity” shall mean the inability to exercise your rights under the provisions of the DPDPA or the rules made thereunder due to unsoundness of mind or infirmity of body.
e. You are also entitled to withdraw consent to the processing of Personal Information which was collected from you with your consent. You will be informed of the consequences of such withdrawal of consent before we act upon the request for withdrawal of consent.
f. You shall have the right to have every request for consent from us or details of our concerned contact person on our behalf in either English or in any of the languages specified in the Eight Schedule of the Constitution of India.
II. The Personal Information of the residents residing in India, for the purpose of processing, shall be transferred outside India on the conditions that the measures of data security and protection as envisaged by the DPDPA are fulfilled and that the transfer of Personal Information to that other country or territory has not been restricted by the Central Government through notification. If any other law passed by the Parliament of India envisages a much higher degree of protection or restriction of transfer of Personal Information, then the requirements of such a law shall also be fulfilled by us.
6. Residents of Australia:
UPL LTD recognizes that individuals must have the option not to identify themselves, or to use a pseudonym when liaising with UPL LTD. We seek to provide this option to the extent possible. However, due to the nature of UPL LTD’s business operations, it is impracticable in most cases for UPL LTD to deal with individuals who have not identified themselves or who use a pseudonym. As a resident of Australia, you have the following rights:
I. The right to have your personal information de-identified and/or destroyed.
II. The right to require that any personal information held by UPL LTD is accurate, up-to-date, and complete. If the information is inaccurate, incomplete and/or out-of-date, you have the right to request that it is corrected.
III. The right to know when and how your personal information is collected, used and disclosed.
IV. The right to “opt out” of your personal information being used for direct marketing purposes.
V. The right to request Data Holders and accredited bodies to share information relating to yourself, with consent, in a standardized machine-readable format.
7. Residents of the Philippines:
I. The right to be informed that your Personal Information will be, has been, or is being collected and processed.
II. The right to access to your Personal Information.
III. The right to object to processing of your Personal Information if the Personal Information processing involved is based on consent or on legitimate interest.
IV. The right to erasure or blocking of your Personal Information under certain circumstances.
V. The right to damages under certain circumstances
VI. The right to file a complaint with the National Privacy Commission (NPC) if your personal information has been misused, maliciously disclosed, or improperly disposed, or that any of your data privacy rights have been violated.
VII. The right to rectify your Personal Information under certain circumstances.
VIII. The right to data portability.
8. Residents of Mexico:
I. The rights of access, rectification, cancellation and opposition under certain circumstances.
II. The right to revoke or request to limit, at any time, the consent you have granted and that is necessary for the processing of your Personal Information.
9. Residents of Brazil:
Residents of Brazil have the following rights:
I. The right to access to your data, as well as to correct incomplete, inaccurate or out-of-date data;
II. The right to anonymize block or delete unnecessary or excessive data or data that is not being processed in compliance with the LGPD;
III. The right to have your data deleted;
IV. The right to have information about public and private entities with which the controller has shared your data;
V. The right to data portability;
VI. The right to have information about the possibility of denying consent and the consequences;
VII. The right to revoke consent.
10. Residents of South Africa:
I. Request access to your Personal Information and request details of the processing activities conducted by UPL LTD and third parties, within a reasonable time and at a prescribed fee, if any.
II. Request that your Personal Information is rectified if it is inaccurate or incomplete, irrelevant, excessive, out of date, misleading or obtained unlawfully.
III. Request the destruction or de-identification of your Personal Information where UPL LTD is no longer authorised to retain the information.
IV. Request restriction of the processing of your Personal Information by UPL LTD in certain circumstances.
V. Object to the processing of your Personal Information in certain circumstances.
VI. Receive your Personal Information in a structured, commonly used and machine-readable format in certain circumstances.
VII. Lodge a complaint with the Information Regulator.
VIII. Object to, and not to be subject to a decision based solely on, automated processing (including profiling), which produces legal effects or significantly affects you.
IX. Withdraw any consent you have provided to us at any time by contacting us.
11. Residents of Argentina:
Rights conferred are as follows:
I. Data subjects have the right to request and obtain information on any Personal Information included in a database (section 14, Personal Information Protection Law 25,326 (PDPL).
II. Data subjects have the right to request that their data is rectified, updated or deleted from databases. The data controller must rectify, update or delete the Personal Information within the five-day period following a data subject's request.
12. Residents of Japan:
Rights Conferred are as follows:
I. Rights to access
II. Revise, correct, amend, or delete their Personal Information;
III. Request the cessation of use of their Personal Information if it is used for a purpose other than the one originally stated, or if it was acquired by fraudulent or other unlawful means;
IV. Access record of data transfers to third parties; and
V. Require to cease using Personal Information or to cease transferring Personal Information to third parties if no longer require.
13. Rights for Other Data Subject:
I. Request access to your Personal Information and request details of the processing activities conducted by UPL LTD and third parties, within a reasonable time.
II. Request that your Personal Information is rectified if it is inaccurate or incomplete, irrelevant, excessive, out of date, misleading or obtained unlawfully.
DISCLAIMER
“UPL and its subsidiaries have made every attempt to ensure accuracy of the information provided on this website. However, this is a global webpage with access to different geographies for wider reach and greater awareness of UPL. In the course of doing the same, UPL has used Weglot translator plugin to cover the language of this website from English to select regional languages.
UPL therefore, does not accept any responsibility or liability on the nature, standard or the accuracy of the translation and cannot take responsibility for any type of inaccurate contextual meaning in the event of a mismatch from English to a regional language.”