General

This Privacy Policy (Policy) describes the policies and procedures on the collection, use, disclosure and protection of your information when you access and/or use the web portal HEGadvancedmaterials.com and the functions and features thereof (Website) owned and operated by HEG Advanced Materials Limited, a company incorporated under the Companies Act, 2013 bearing Corporate Identification Number CIN: L23109MP1972PLC008290 and having its registered office at Registered Office: Mandideep (Near Bhopal) Distt. Raisen – 462046 (Madhya Pradesh), India.

Any reference to you or your or user (if applicable) refers to you as the visitor, subscriber or user of the Website and/or any features or functionalities on the Website. Any reference to we, our and us shall refer to the Company.

Please read this Policy before accessing and/or using the Website or submitting any personal information to the Company. This Policy is a part of and is incorporated within, and is to be read along with the Terms and Conditions mentioned on the Website, which govern your access to and use of the Website and the activities, services, features, functionalities and/or resources available on the Website (Terms).

The Company values the trust users place in the Company. Therefore, the Company is committed to maintaining appropriate standards for secure communication and user information privacy.

Please read and understand this entire Policy carefully to learn about the Company’s information gathering, usage, storage, processing and dissemination practices. This Policy may be changed from time to time. To make sure you are aware of any changes, please review this Policy periodically.

Your Consent

By accessing and/or using the Website, you acknowledge and agree to this Policy. Where processing of Personal Data is based on consent, the Company will obtain such consent in the manner required by applicable law. The Company may also process Personal Data where otherwise permitted or required by applicable law. Where consent is relied upon, you may withdraw such consent in accordance with this Policy and applicable law.

If you do not agree with this Policy, please do not use or access the Website. You always have the option to not provide information by choosing not to use a service or feature or resource on the Website.

Protecting the Privacy

We are committed to complying with applicable laws relating to privacy and protection of Personal Data, including the Digital Personal Data Protection Act, 2023 (DPDP Act) and the Digital Personal Data Protection Rules, 2025 (DPDP Rules), to the extent applicable and in force from time to time. This Policy is intended to be interpreted consistently with applicable law.

All information submitted by users on the Website shall be safeguarded and protected. The Company is committed to protecting the privacy, confidentiality, accuracy and security of the personal information that it collects, uses, retains and discloses in the course of conducting business and providing services.

This Policy will protect the data provided by you and will be used for the purposes of providing services to you through the Website and any other administration purposes relevant to any products/services provided by the Company.

Web Browser Cookies

We may automatically receive and collect certain anonymous information in standard usage logs through our web server, including computer-identification information obtained from cookies.

Our Website may use cookies to enhance user experience. Your web browser places cookies on your hard drive for record-keeping purposes and sometimes to track information about you.

You may choose to set your web browser to refuse cookies. If you do so, note that some parts of the Website may not function properly.

1. Types of Information Collected

The Company may collect several types of information which is primarily used to serve you better and maintain authenticity of services by identifying you. Details of such information (collectively called Information) are as follows:

1.1 Personal Identification Information

Personal Data means any data about an individual who is identifiable by or in relation to such data, as defined under applicable law. References in this Policy to Personal Information shall, where applicable, be read as references to Personal Data.

We may collect personal identification information from you in a variety of ways, including, but not limited to, when you visit the Website, register on the Website, fill out a form, respond to a survey, or in connection with other activities, services, features or resources we make available on the Website.

We will collect personal information from you only if you voluntarily submit such information to us. You can always refuse to supply this information, except that it may prevent you from accessing or using any or all of the activities, services, features or resources available on the Website.

Please note that we do not knowingly collect or store personal data unless permitted by law or provided to us under a contract. If we learn that we have collected personally identifiable information from a child without lawful authorization or consent, we will delete that information from our database.The Company will process Personal Data only where permitted by applicable law. Where the processing of a child’s Personal Data is subject to specific requirements under applicable law, the Company will comply with those requirements, including any applicable requirements relating to verifiable parental consent and restrictions on processing.

1.2 Non-Personal Identification Information

We may collect non-personal identification information about you whenever you interact with our Website.

Non-personal identification information may include the browser name, the type of computer or other communication device and technical information about your means of connection to our Website, such as the operating system and the internet service provider utilized, an IP address assigned to the computer which you use, the domain server through which you access the Website, and other similar information.

This Non-Personal Information would not assist us to identify you personally.

1.3 Surveys

The Company may email you or post various surveys on the Website. The surveys may request your demographic information and your feedback on activities, services, features or resources available on the Website.

1.4 Customer Service Communications Information

The Company may collect Personal Information, Non-Personal Information or Other Information when you post or submit comments, questions, complaints or suggestions regarding products/services.

1.5 Other Information

The Company also collects information regarding your usage of the activities, services, features or resources available on the Website.

This other information includes, but is not limited to, patterns of use of the Website by you, pages visited, posts/comments made on any page of the Website, etc.

2. Mode of Collection of Information

2.1

When you use the Website, we collect and store your Information which is provided by you from time to time.

Our primary goal in doing so is to provide you a safe, efficient, smooth and customized experience. This allows us to provide activities, services, features or resources available on the Website in a customized manner to make your experience safer and easier.

2.2

In general, you can browse the Website without telling us who you are or revealing any Personal Information about yourself.

Once you give us your Personal Information, you are not anonymous to us. We may collect your Non-Personal Information simply by you browsing/downloading the Website.

When collecting Personal Information from you, we indicate which fields are required and which fields are optional. You always have the option to not provide information by choosing not to use a service or feature or resource on the Website.

We may automatically track certain information about you based upon your behaviour on the Website. We use this information to conduct internal research on our users’ demographics, interests and behaviour to better understand, protect and serve our users.

This information is compiled and analysed on an aggregated basis. This information may include the link/URL that you just came from, whether this URL is on our Website/app or not, which URL you next go to, whether this URL is on the Website or not, your computer browser information, and your IP address.

2.3

We may receive Personal Information about you from third parties, such as external APIs and social media services.

If you access the Website through an external API or a social media service or connect a service/page on the Website to a social media service, the information we collect may include your username associated with that social media service, any information or content the social media service has the right to share with us, such as your profile picture, email address or friends list, and any information you have made public in connection with that social media service.

When you access the Website or otherwise deal with the Company through external APIs or social media services, or when you connect the Website to social media services, you are authorizing the Company to collect, store, use and retain such information and content in accordance with this Privacy Policy.

2.4

We may use data collection devices such as cookies on certain pages of the Website to help analyse our web page flow, measure promotional effectiveness, and promote trust and safety.

We offer certain features that are only available through the use of a cookie. We also use cookies to allow you to enter your password less frequently during a session.

Most cookies are session cookies, meaning that they are automatically deleted from your device at the end of a session.

You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain services, features or resources on the Website and you may be required to re-enter your password more frequently during a session.

Additionally, you may encounter cookies or other similar devices on certain pages of the Website that are placed by third parties. We do not control the use of cookies by third parties.

2.5

If you transact with us, we collect some additional information, such as a billing address, a credit/debit card number and a credit/debit card expiration date and/or other payment instrument details and tracking information, as applicable.

2.6

If you choose to post messages on our message boards, if available, or other message areas or leave feedback, we will collect that information you provide to us.

We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.

2.7

If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Website, we may collect such information into a file specific to you.

2.8

We shall not collect, store, or process any sensitive personal data unless essential and consented to by you. All such sensitive personal data shall be collected and processed strictly in accordance with applicable laws.

3. Use of Information Collected

3.1

We process Personal Data only for specified purposes and on a basis permitted by applicable law, including where consent is required and obtained, or where processing is otherwise permitted or required by applicable law. The Company will not rely on a processing basis that is not available under the law applicable to the relevant processing activity.

3.2

The Company does not sell Personal Data as a standalone commercial product. The Company may disclose or share Personal Data with service providers, professional advisers, affiliates and other recipients where necessary for the purposes described in this Policy, where permitted or required by applicable law, or with consent where consent is required.

However, the Company reserves the right to disclose Information in good faith:

1. a) if required by law or any authority;
2. b) to protect and defend the rights and interests of the Company, employees/agents of the Company, other users or the general public;
3. c) to enforce the Terms of Use and other policies of the Company; or
4. d) to address concerns raised by a third party.

3.3

The Company uses Personal Information to market/provide its products/services.

To the extent the Company uses your Personal Information to market to you, we will provide you the ability to opt out of such uses.

We use your Personal Information to identify and authenticate users; understand your needs and confirm your application information and assess your eligibility for services; establish and maintain communication and respond to your inquiries; investigate and settle your claims/requests; resolve disputes; troubleshoot problems; help promote a safe service; billing and collection of money, where applicable; measure consumer interest in our products and services; inform you about services and updates; customize and improve your experience; detect and protect against error, fraud and other criminal activity; enforce our terms and conditions; meet regulatory requirements; and as otherwise specified in this Policy.

3.4

We collect passively tracked data primarily for purposes of administering, protecting and improving our Website and our systems, to better understand the preferences of our site visitors, to identify server problems, to compile aggregated statistics about site usage, and to help personalize your experience on our site.

3.5

We may also use Information to curate relevant articles and other content.

3.6

By using this Website, you hereby authorize the Company to contact you via calls, emails and/or text messages or by any other similar means using the contact details so provided, to furnish you with information regarding our various services currently available or as may be added or made available at any future date.

In the event you do not wish to receive such information, you may unsubscribe from the facility.

3.7

In our efforts to continually improve our product and service offerings, we collect and analyse demographic and profile data about our users’ activity on our Website.

3.8

We identify and use your IP address to help administer our Website. Your IP address may also be used to help identify you and to gather broad demographic information.

3.9

We may occasionally ask you to complete optional online surveys. These surveys may ask for contact information and demographic information.

We use this data to tailor your experience on the Website, provide you with content that we think you might be interested in and display content according to your preferences.

3.10

The Company may also use all the data and information generated in the course or on account of provision of products/services, on an anonymous basis for analytics purposes.

3.11

Information collected can be used by the Company within the Company or by its affiliates, contractors or agents for analysis and determination of statistics, demand and supply, patterns of usage, etc.

3.12

The Company may use the user’s data collected from external APIs for the purpose of allowing them to access and use the activities, services, features or resources available on the Website.

3.13

The Company will retain Personal Data only for as long as reasonably necessary for the purposes for which it was collected, to provide requested services, comply with legal or regulatory obligations, resolve disputes, establish or defend legal claims, prevent fraud or misuse, and for other lawful purposes. When retention is no longer necessary or legally required, the Company will delete, anonymise or otherwise dispose of the Personal Data in accordance with applicable law and its retention practices.

Please note that the user’s information may remain stored in archive on the Company’s servers even after termination of the user’s association with the Company.

All such data and information shall be processed and retained as long as needed or legally required and always in accordance with applicable laws.

4. Sharing of Information

4.1 With Service Providers

We may share your Information, on a need-to-know basis, with third parties that provide services to help with our business activities.

These third parties are authorized to use your Personal Information only as necessary to provide certain services to us, including but not limited to:

• Providing cloud infrastructure;
• Sending transactional and service communications and social media advertising services;
• Sending marketing communications;
• Providing customer service;
• Conducting research;
• Providing data analytics services;
• Providing safety and security services;
• Conducting research or performing surveys;
• Payment processing and facilitation, where applicable; or
• Other professionals engaged by the Company, including consultants, lawyers, accountants and other professional service providers.

4.2 With Other Third Parties

We may share your Information with other third-party business partners strictly on a need-to-know basis, for the purpose of enhancing our products/services or providing additional services on request.

If you do not want us to share your Personal Information with third-party business partners, please contact us at the contact information below.

Additionally, we may share your Information if we choose to sell, transfer, or merge parts of our business or our assets with third parties. Alternatively, we may seek to acquire other businesses or merge with them.

If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.

We may transfer Personal Data in connection with a merger, acquisition, restructuring, financing, sale of business or assets, or similar corporate transaction, subject to applicable law and appropriate confidentiality and data protection safeguards. Such transfer shall not be treated as a commercial sale of Personal Data.

4.3 With Consent

The Company may share a user’s personal data other than as described in this Policy, with the prior consent of such user.

5. Links to Other Websites

The Website may contain certain hyperlinks to other websites.

While the Company’s Website is subject to this Policy, we are not responsible for the privacy practices or the content of any other website that is linked to this Website.

Any information you provide to these other websites will be subject to their respective privacy policies. We therefore recommend that you read the privacy statement for each third-party site you visit.

6. Rights and Obligations of the Users

To help the Company protect Information, users are required to maintain the privacy of login credentials and other information required by them to access or use the Website.

Users are also prohibited from communicating information provided by the Company to a third party unless required by law or in compliance with agreements entered into between users and the Company.

Subject to applicable law, a Data Principal may exercise applicable rights in relation to Personal Data, including the rights to correction, completion, updating and erasure, withdrawal of consent, grievance redressal and nomination, as applicable. Requests may be made through the contact mechanism specified in this Policy and may be subject to reasonable verification and statutory limitations.

Where processing is based on consent, you may withdraw consent by using the mechanism specified by the Company or by contacting the Company at the details provided below. Withdrawal of consent shall not affect the lawfulness of processing based on consent before withdrawal. The Company may cease or restrict a service where withdrawal means that the service can no longer lawfully be provided.

8. Data Principal Rights and Grievance Redressal

Subject to applicable law, Data Principals may exercise their applicable rights in relation to their Personal Data, including correction, completion, updating and erasure, withdrawal of consent, grievance redressal and nomination, as applicable.

To exercise an applicable right or raise a grievance, a Data Principal may submit a request through the Company’s designated privacy/grievance contact mechanism specified in this Policy. The request should identify the Data Principal and clearly state the right or grievance being exercised. The Company may undertake reasonable verification to authenticate the request and may seek additional information where reasonably necessary.

The Company will acknowledge and process requests and grievances within the timelines and in the manner prescribed under applicable law. Where a request is granted, the Company will take the corresponding action within the applicable legal and operational timeframe. Where a request is declined or limited, the Company will provide the reason to the extent required or permitted by applicable law.

If a grievance is not satisfactorily resolved through the Company’s internal grievance mechanism, the Data Principal may pursue further remedies available under applicable law, including approaching the Data Protection Board of India where applicable and after following any mandatory internal grievance process.

In case you withdraw your consent for collection, storage and use of your information by the Company, the Company shall be entitled to restrict, control or terminate your access and use of all or any of the activities, services, features or resources available on the Website, subject to applicable law.

7. Disclaimer as to Loss

The Company implements reasonable technical and organisational security safeguards appropriate to the nature of the Personal Data and the risks associated with its processing. However, no method of transmission over the internet or electronic storage can be guaranteed to be completely secure. Nothing in this Policy limits or excludes any obligation or liability that cannot lawfully be limited or excluded under applicable law.

The Company assumes no liability whatsoever with respect to access to Information in case of a cyber-security incident, except to the extent required under applicable law.

9. Security Measures

9.1

The Company adopts generally accepted, reasonable data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your Information, username, password, transaction information and data stored on the Website.

9.2

The Company deploys reasonable security measures to protect against the loss, misuse and alteration of information under its control.

Once the user’s information is in the Company’s possession, the Company adheres to reasonable security guidelines, protecting it against unauthorized access.

9.3

In the event of a Personal Data breach or security incident, the Company will assess and respond to the incident and provide notice to affected Data Principals and/or the relevant authority, where and to the extent required by applicable law, within the applicable timelines and in the prescribed manner.

9.4

The user’s information will primarily be stored in electronic form; however, certain data may also be stored in physical form.

9.5

The Company may also use such Information for purposes of safety, security, fraud prevention and detection, and research and development for as long as it retains such information.

9.6

Only authorized personnel have access to your Information.

Our systems and procedures are designed to prevent the loss, misuse, unauthorized access, disclosure, alteration and destruction of your information.

Our commitment to security extends to the contracts and agreements that we sign with external suppliers and service providers.

We will retain your Information only as long as is required for the purposes for which it was collected and/or any legal or regulatory requirements.

We shall only make use of, disclose and/or store your Personal Information in a secure and confidential manner.

9.7

Security of Personal Information

We follow generally accepted industry standards and implement appropriate technical and organisational measures to protect personal information against unauthorised access, alteration, disclosure, loss, misuse or destruction. These measures may include appropriate access controls, authentication, secure transmission, monitoring, backup and other safeguards, having regard to the nature and risks associated with the personal information processed.

Access to personal information is restricted to authorised personnel, service providers and other persons who require such access for legitimate purposes and are subject to appropriate confidentiality and security obligations.

While we take reasonable steps to protect personal information, no method of transmission over the Internet or method of electronic storage can be guaranteed to be completely secure. In the event of a personal-data breach, we will take appropriate steps to contain, assess and respond to the incident and make any notification required under applicable law.

We periodically review our security measures and may update them as necessary to address changing risks, technologies and legal requirements.