For processes relating to customers of Perfect Companion India (Animal Feed Business)
In compliance with the Information Technology Act 2000 and rules made there under, including any future amendments (“Information Technology Act”), Perfect Companion India (Animal Feed Business) (“the Company”) has prepared this Privacy Notice for processes relating to its customers (“the Notice”) to explain to you how the Company handles data that can identify you, or may identify you, directly or indirectly, in accordance with the Information Technology Act 2000 (“Personal Data”). This includes the methods of collecting, using, disclosing, or processing Personal Data, whether automatically or not, such as recording, organizing, storing, modifying or altering, retrieving, transmitting, transferring, publishing or making accessible or available by any means, arranging, combining, restricting or prohibiting access, deleting or destroying (“Processing”), and to inform you of the purposes of processing and the retention period of Personal Data. As well as your rights as a data subject, the company recommends that you read and understand the various provisions under this announcement, which are detailed as follows:
Under this announcement, the groups or categories of individuals from whom the company collects and processes personal data include:
• “Customer” refers to any natural person who purchases goods and/or services from the Company, or may purchase goods and/or services from the Company or any other person in a similar manner, such as participants in activities, seminars, or events; website users; application users; those who contact the Company for information or services; those who receive product samples; those who win prizes from participating in Company activities; those who are sample groups in market research; and those who respond to questionnaires about the Company’s products and/or services, etc.
• “Persons related to customers” refers to natural persons related to customers, or who are representatives or personnel of legal entities that are or may be customers of the Company, such as executives, directors, employees, coordinators, agents, or personnel of the customer company, and also includes natural persons whose personal information appears in various documents related to the relevant processes, such as managers, purchasers, recipients of goods, check issuers, guarantors of purchases, landowners, spouses of landowners, mortgagors who secure purchases, and witnesses, etc.
• The Company collects and receives your personal information through various channels as follows:
• Personal information that you provide directly to the Company
• When you contact, communicate, inquire about information, give opinions or feedback to the Company, whether in written or verbal form. Through the website, application (such as PCIN Shop Online or Official Line Account: PCIN), telephone, email, fax, mail, direct meeting, or any other method.
• When you express your intention to purchase goods or services from the company, enter into a contract with the company, or submit documents containing personal information to the company, and when you participate in marketing activities, raffles, events, or other activities organized by or on behalf of the company, etc.
• Personal information that the company automatically collects from you.
The company may automatically collect your personal information through various channels, such as the use of cookies or similar technologies. For more details, please see the Cookie Policy.
• Personal information received by the company from other sources or third parties.
The company may receive your personal information from other sources or third parties, such as:
• In the case of corporate clients, the company may receive your personal information through agents or personnel of the corporate entity you are affiliated with, who act as liaisons with the company.
• Personal information may also be obtained from responsible departments under other companies within the Charoen Pokphand Group (CP Group).
• We may obtain your personal information from our business partners, retailers, or service providers, such as retailers who are clients of media agencies that organize events or conduct research for our company, website providers, application providers, e-commerce platform providers such as Amazon.in, flipkart.com and supertails.com, etc.
• We may also obtain information from customer service centers (call centers), public relations and product/service promotion providers, and data collection service providers, etc.
• In some cases, the company may collect your personal information from public sources, sources related to your business, or commercial sources, whether you disclose the personal information yourself or have given consent to anyone to disclose such personal information.
• In collecting your personal data, you will be informed of all details as specified in this notice, including but not limited to the purposes and legal basis for collecting, using, disclosing, and/or processing personal data. If, under the Personal Data Protection Act, your consent is required for any processing of personal data, the Company will obtain your express consent.
• If the Company collected your personal data before the Information Technology Act 2000 came into effect, the Company will continue to collect and use your personal data for the original purposes for which it collected it. However, after the Information Technology Act 2000 and rules made there under, in relation to the collection, use, or disclosure of personal data, comes into effect, if you do not wish for the Company to collect and use such personal data and the Company relies on your consent to process your personal data, you can contact the Company to revoke your consent using the contact details specified in Clause 9 of this Announcement. The Company reserves the right to consider your request to revoke consent and to act in accordance with the Information Technology Act 2000.
Your personal data collected and processed under this announcement, whether personal data you provide directly to the company, personal data the company automatically collects from you, or personal data the company receives from third parties, includes:
• Personal information such as name, surname, nickname, date of birth, age, gender, national identification number, passport number, nationality, educational background, occupation, workplace, professional license number, income, hobbies, photograph, and signature, etc.
• Contact information includes details such as address as stated on the national ID card, registered address, delivery address, document delivery address, telephone number, fax number, email address, and LINE application user ID, etc.
• Information about the customer’s business, such as company name, agency or organization name, job title, and details about the customer’s store (e.g., name, registration number, location, map, store coordinates (latitude, longitude), store photos and contact information, etc.).
• Information regarding sales transactions, such as customer ID, order details (e.g., desired items, quantity, quality, and promotions or discount codes used), and details of product complaints (e.g., order date, product type, relevant branch, and the problem encountered), etc.
• Payment information such as the amount, credit limit, payment terms, bank account number, personal information appearing on the first page of the bank passbook, invoices, tax invoices, receipts, payment vouchers, and debit slips, etc.
• Information used as supporting evidence for customer registration with the company or for various transactions includes: personal information as shown in copies of national ID cards, passports, work permits, visas, house registration certificates, name change certificates, marriage certificates, spouse consent letters, veterinary licenses, animal hospital establishment certificates, registration forms, gift redemption forms, delivery notes, receipts, copies of land title deeds, customer account opening applications, power of attorney documents, copies of company registration certificates, copies of business registration certificates, copies of GST registration certificates, maps, collateral documents (such as land title deeds, bank guarantees, and personal guarantees), advertising space rental/tax application forms, service usage application forms, and sales contracts or any other contracts related to transactions, etc.
• Sensitive personal data, such as religious information and/or blood type appearing on copies of national identity cards, health information appearing on medical certificates, and/or any other information that similarly affects the data subject as determined by the Personal Data Protection Committee, etc.
• Technical information includes data such as computer traffic logs, computer serial numbers (IP addresses), and information collected by the company through cookies or similar technologies.
• Other information includes purchasing behavior or trends for goods and/or services (e.g., currently used products, purchasing choices, information channels and media, and selected product samples), personal behavior related to products, or used in research and/or development to improve the company’s service quality, pet-related behavior (e.g., animal type, breed, age of pet, pet care and feeding habits), recorded conversations, and still and moving images captured via closed-circuit television (CCTV), etc.
• The Company processes your personal data for various purposes under the following legal basis (collectively referred to as “Defined Purposes”).
| Number | Defined Objectives | Legal Basis for Processing |
|---|---|---|
| 1 | For the purpose of verifying the identity of the customer or individuals related to the customer. | • Legitimate Interest Basis: The processing of personal data of customers or individuals related to customers is necessary for the company’s legitimate interests in verifying the identity of such individuals. • Consent Basis: The processing of sensitive personal data appearing on copies of national identity cards, such as religious information and/or blood type, during the process of verifying the identity of customers or individuals related to customers, where it is unavoidable to obscure, cross out, or avoid collecting such data, will be done with the consent obtained from such individuals. |
| 2 | For registering a subscription or opening a customer account. | • Contractual Basis: The processing of customers’ personal data is necessary to fulfill customer requests for new customer registration or account opening through the company’s website or various service channels such as Smart Soft, Winfeed, Program Cash Van, PCIN, and https://pcgshoponline.com, or at various events (such as Pet Fair, On Tour events, and office building activities), etc. • Legitimate Interest Basis: In the case of a legal entity customer, the processing of personal data of individuals related to the customer is necessary for the legitimate interests in conducting the company’s business, such as account management, customer identity verification, IT system entry, and customer database creation, etc. |
| 3 | For entering into contracts and providing security deposits. | • Contractual Basis: The processing of customers’ personal data is necessary for entering into contracts and other processes related to contract entering into, such as verifying supporting documents for contracts, considering the amount and conditions of product purchases, and the provision of security deposits, etc. • Legitimate Interest Basis: In the case where the customer is a legal entity, the processing of personal data of individuals related to the customer is necessary for the legitimate interests in the operation of the company’s business, such as verifying the signing authority of directors according to the company registration certificate, managing contracts, and assessing customer qualifications, etc. |
| 4 | For the purpose of managing customer orders and performing other related tasks. | • Contractual Basis: The processing of customers’ personal data is necessary to fulfill the obligations of the sales and service contracts to which the customer is a party, such as product delivery, collection of display and advertising space fees, billing, confirmation of outstanding debts, issuance of receipts, transfer of payment rights, and refunding of money to customers, etc. • Legitimate Interest Basis: In the case where the customer is a legal entity, the processing of personal data of individuals related to the customer is necessary for the legitimate interests in conducting the company’s business, such as managing customer orders and communicating with customers, etc. |
| 5 | For the purpose of fulfilling various customer requests. | • Contractual Basis: The processing of customers’ personal data is necessary to fulfill various customer requests. |
| 6 | For the purpose of receiving complaints from customers or persons related to customers. | • Legitimate Interest: The processing of personal data of customers or individuals related to customers is necessary for the legitimate interests of the company in handling complaints, conducting internal audits, resolving issues, and developing the quality of the company’s products and services. |
| 7 | For the purpose of managing customer benefits. | • Legitimate Interest: Processing customers’ personal data is necessary for the legitimate interest in managing customer benefits, such as loyalty points programs, reward redemption, and prize distribution for participation in various activities, etc. |
| 8 | For the purpose of public relations and marketing activities of the company. | • Consent Basis: For any marketing activities undertaken by the company, such as sending marketing messages to customers, providing product samples, or requesting still or moving images from customers for processing and promotional purposes across various media channels, the company may require consent from the data subject under the Information Technology Act 2000 and rules made there under. In such cases, the company will proceed based on the consent obtained from you. |
| 9 | For the purpose of surveying your behavior, analyzing your usage of the website, application, or other channels, in order to improve the quality of the company’s services, and/or for marketing purposes. | • Legitimate Interest: The processing of your personal data from your purchasing behavior, website usage, application usage, or other channels is necessary for the company’s legitimate interests in conducting business and developing the quality of its services, such as improving the website, application, or other channels; developing the quality of products and services; and correcting defects and problems related to products and services. • Consent Basis: In cases where the company requests an interview, observes your behavior, and/or collects and processes data on your purchasing behavior, website usage, application usage, or other channels for behavioral analysis and targeted advertising or direct marketing, or for use in marketing strategies, or in cases where personal data protection laws require your consent, the company will proceed based on your consent. |
| 10 | For the purpose of communicating with customers or individuals related to customers. | • Legitimate Interest: The processing of personal data is necessary for legitimate interests in order to communicate with you regarding the company’s various services. |
| 11 | For the purpose of complying with laws relating to the company’s business and lawful orders from courts, government agencies, and relevant officials. | • Legal Compliance: To comply with applicable laws to the Company, such as tax laws, personal data protection laws, computer-related crime laws, emergency administration laws, and lawful orders from courts, government agencies, and relevant officials, such as the Revenue Department and the Personal Data Protection Commission, etc. • Legal Compliance Basis for Achieving Public Health Objectives: In some cases, the processing of your sensitive personal data (e.g., body temperature measurements) is necessary to comply with laws in order to achieve public health objectives, such as health protection from dangerous infectious diseases or epidemics. |
| 12 | For the purpose of establishing a legal claim, complying with or exercising a legal claim, or raising a defense against a legal claim. | • Legitimate Interest: The processing of personal data is necessary for the establishment of legal claims, the compliance with or exercise of legal claims, or the defense of legal claims in various legal procedures, such as preparing debt confirmation letters and conducting debt collection, investigation and/or inquiry by government officials, case preparation, litigation, and/or defense in court, etc. |
| 13 | For the purpose of monitoring and maintaining peace and order and ensuring the safety of individuals and company property. | • Basis for the prevention or mitigation of harm to the life, body, or health of individuals: The processing of personal data is necessary for the purpose of monitoring, preventing, or mitigating any events that may endanger the life, body, or health of individuals, such as screening for the spread of the Coronavirus 2019 (COVID-19), etc. • Basis for legitimate interest: The processing of personal data is necessary for legitimate interests in maintaining peace and order and ensuring the security of the company’s assets, for initial screening of information regarding entry into the company’s premises, or for using CCTV footage to prevent loss or damage to company assets, or to track down and recover assets or claim compensation in the event that company assets are lost or damaged, etc. |
| 14 | For any actions that are necessary and beneficial to the Company or any other person or legal entity, or directly related to any of the objectives stated above. | • Legitimate Interest Basis: The processing of personal data is necessary for the legitimate interests of the Company or other individuals or entities in carrying out any actions that are necessary and/or beneficial to the Company or other individuals or entities, or directly related to the objectives stated above.
However, if the Information Technology Act 2000 and rules made there under requires your consent for the processing of any personal data, the Company will obtain your express consent. |
| 15 | For other purposes that the company will inform you about. | • The company will inform you of any other purposes that may require the company to process your personal data beyond those stated above, or when the company changes the original purposes specified. However, if the Information Technology Act 2000 and rules made there under Acts requires your consent for the processing of any personal data, the company will obtain your express consent. |
• Because the personal data that the Company will process for the purposes specified in Clause 1 above, in relation to compliance with laws or contracts, or necessary to enter into a contract with you, is essential to achieving such purposes, if you do not wish to provide such personal data to the Company, there may be legal consequences, or the Company may be unable to fulfill its obligations under the contract entered into with you, or may not be able to enter into a contract with you (as the case may be). In such cases, the Company may need to refuse to enter into a contract with you, or cancel the sale or services related to you, in whole or in part.
• In the event that the Company processes your personal data in a manner and/or for purposes that are inconsistent with the purposes stated above, the Company will provide an additional data protection policy or notice and/or send a letter to you explaining such data processing. You should read the relevant additional policy or notice in conjunction with this notice and/or such letter (as applicable).
• The Company may disclose your personal information, under specified purposes and in accordance with legal requirements, to the following individuals and entities:
• Companies within the Charoen Pokphand Group (CP Group), including executives, directors, employees, and/or internal personnel of the said companies to the extent relevant and necessary for the processing of your personal information.
• Business partners, service providers, and data processors assigned or contracted by the Company to manage/process personal information for the Company in providing various services such as information technology services, data storage services, payment services, transportation services, postal and parcel services, printing services, data analysis services, media services (e.g., Media Agency), travel management services, research services, marketing services, legal services, or any other services that may be beneficial to you or related to the Company’s business operations.
• The Company’s consultants, such as legal consultants, lawyers, auditors, or other experts, both internal and external to the Company.
• Courts and government agencies with regulatory duties under the law, or those requesting disclosure of personal information based on legal authority, or related to legal processes, or authorized under relevant laws, such as the Revenue Department, the Ministry of Commerce, Veterinary Council of India, the Trade Competition Commission. And the Office of the Attorney General, etc.
• Any other person or organization to whom you consent to the disclosure of your personal information, such as the disclosure of processed images of company activities through various media channels to the general public, etc.
• The disclosure of your personal information to other parties will only be carried out for specified purposes or other purposes permitted by law. If the law requires your consent, the company will obtain your consent beforehand.
• When disclosing your personal information to other parties, the company will take appropriate measures to protect the disclosed personal information and to comply with the data protection standards and obligations as stipulated by the Data Protection Act. In cases where the company sends or transfers your personal information abroad, the company will take steps to ensure that the destination country, international organization, or recipient abroad has adequate data protection standards or to ensure that the sending or transfer of your personal information abroad complies with the criteria stipulated by the Data Protection Act. In some cases, the company may request your consent for the sending or transfer of your personal information to such foreign country.
The company will retain your personal data for the period necessary to achieve the purposes specified for processing that personal data. The retention period will vary depending on the purposes specified for processing that personal data. In addition, the company will retain personal data for the period prescribed by applicable laws (if any), taking into account the statute of limitations for any legal proceedings that may arise from or relate to the documents or personal data collected by the company for each item, and taking into account the company’s and the practices of the relevant industry regarding each type of personal data.
The company will retain your personal data for a period of [no more than 10 years] from the date the legal relationship between you and the company ends. However, the company may retain your personal data for a period longer than that if permitted by law or if such retention is necessary to establish the company’s legal claims.
After the aforementioned retention period has expired, the Company will delete or destroy such personal data from its storage or systems and from any other parties providing services to the Company (if any), or render your personal data unidentifiable, unless the Company is able to continue retaining such personal data as required by the Information Technology Act 2000 or other relevant laws. For further details regarding the retention period of your personal data, you can contact the Company using the contact details specified in Clause 9 of this Announcement.
As a data subject, you have the following rights regarding your personal data, subject to the principles, methods, and conditions governed by the Information Technology Act 2000. If you wish to exercise your rights, you can contact the company using the contact details provided in Clause 9 of this announcement.
• Right to Access Personal Data
You have the right to access your personal data and request the company to provide you with a copy of such data, as required by the Information Technology Act 2000.
• Right to Portability of Personal Data
You have the right to request personal data about yourself, including the right to request the transfer of your personal data to another data controller or to yourself, unless it is not possible by its nature, as required by the Information Technology Act 2000.
• Right to Object to the Processing of Personal Data
You have the right to object to the processing of your personal data in cases where required by the Information Technology Act 2000.
• Right to Delete Personal Data
You may request the company to delete, destroy, or anonymize your personal data in cases where required by the Information Technology Act 2000.
• Right to Suspend the Use of Personal Data
You have the right to request the company to suspend the processing of your personal data in cases where required by the Personal Data Protection Act.
• Right to Correct Personal Data
You have the right to request the correction of your personal data if it is inaccurate, outdated, incomplete, or misleading.
• Right to Withdraw Consent
In cases where the company relies on your consent to process your personal data, you have the right to withdraw your consent to the processing of your personal data that you have given to the company.
• Right to File a Complaint
If you have any concerns or questions regarding the company’s practices concerning your personal data, please contact the company using the contact details provided in Clause of this Announcement. Furthermore, if there is reason to believe that the company has violated the Information Technology Act 2000, you have the right to file a complaint with the expert committee appointed by the in accordance with the rules and procedures prescribed by the Information Technology Act 2000.
The company reserves the right to consider your request to exercise your rights and to act in accordance with the Information Technology Act 2000.
If you have any questions or wish to exercise your rights as stipulated in this announcement, you can contact the company through the following channels:
Perfect Companion India (Animal Feed Business)
Email: care.smartheart@gmail.com, care.meoindia@gmail.com
Contact information: Plot No 26, Industrial Area, Kasna, Ecotech 1 Extn, GREATER NOIDA, Gautam Buddha Nagar, Uttar Pradesh, 201308
Telephone number: +91-99406-25518
The Company may amend this Notice from time to time to comply with any changes relating to the processing of your personal data and as required by the Information Technology Act 2000 or other relevant laws. The Company will notify you of any significant amendments to this Notice along with the updated Notice through appropriate channels. The Company recommends that you check for changes to this Notice periodically.
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