DATA PROTECTION

We are very pleased about your interest in our company. Data protection is particularly important to the management of the NAAZ group of companies. It is generally possible to use the NAAZ Group's websites without providing any personal data. However, if a data subject wishes to use our company's special services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, such as the name, address, email address or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation and in accordance with the country-specific data protection regulations applicable to the NAAZ group of companies. By means of this data protection declaration, our company would like to inform the public about the type, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed about the rights to which they are entitled using this data protection declaration.

As the data controller, the NAAZ group of companies has implemented numerous technical and organizational measures to ensure the most complete protection possible for the personal data processed via this website. However, Internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.

1. DEFINITIONS

The data protection declaration of the NAAZ group of companies is based on the terms used by Indian, worldwide and especially the European legislator for directives and regulations when issuing the General Data Protection Regulation (GDPR). Our data protection declaration should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.

We use the following terms, among others, in this data protection declaration:

·      A) PERSONAL DATA

Personal data is any information that relates to an identified or identifiable natural person (hereinafter “data subject”). A natural person is considered to be identifiable if he or she can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more special characteristics that express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.

·      B) DATA SUBJECT

Data subject is any identified or identifiable natural person whose personal data is processed by the data controller.

·      C) PROCESSING

Processing is any operation or series of operations carried out on personal data, whether or not by automated means, such as the collection, recording, organisation, structuring, storage, adaptation or modification, reading, querying, use, disclosure by transmission, distribution or other form of provision, alignment or association, restriction, deletion or destruction.

·      D) RESTRICTION OF PROCESSING

Restriction of processing is the marking of stored personal data with the aim of restricting their future processing.

·      E) PROFILING

Profiling is any type of automated processing of personal data which consists in using these personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to work performance, economic situation, health, personal Analyze or predict the preferences, interests, reliability, behavior, location or movements of that natural person.

·      F) PSEUDONYMIZATION

Pseudonymization is the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without the use of additional information, provided that this additional information is kept separately and is subject to technical and organizational measures that ensure that the personal data not be assigned to an identified or identifiable natural person.

·      G) CONTROLLER OR CONTROLLER

The person responsible or responsible for processing is the natural or legal person, public authority, institution or other body which, alone or jointly with others, decides on the purposes and means of processing personal data. If the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

·      H) PROCESSOR

Processor is a natural or legal person, authority, institution or other body that processes personal data on behalf of the controller.

·      I) RECIPIENT

The recipient is a natural or legal person, public authority, institution or other body to which personal data is disclosed, regardless of whether it is a third party or not. However, public authorities which may receive personal data in the context of a specific investigative task under Union or Member State law shall not be considered as recipients.

·      J) THIRD PARTY

Third party is a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons authorized to process the personal data under the direct responsibility of the controller or the processor.

·      K) CONSENT

Consent is any voluntary, informed and unambiguous expression of wishes given by the data subject for a specific case, in the form of a statement or other unambiguous confirmatory act, by which the data subject indicates that he or she agrees to the processing of personal data concerning him or her is.

2. NAME AND ADDRESS OF THE PERSON RESPONSIBLE FOR PROCESSING

The person responsible within the meaning of the General Data Protection Regulation, other data protection laws applicable in the member states of the European Union and other provisions of a data protection nature is:

NAAZ group of companies

Ward 12B, Gandhidham, Kutch

Gujarat 370201

India

3. COOKIES

The Internet pages of the NAAZ group of companies use cookies. Cookies are text files that are stored and stored on a computer system via an Internet browser.

Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This enables the visited websites and servers to distinguish the individual browser of the data subject from other internet browsers that contain other cookies. A specific Internet browser can be recognized and identified via the unique cookie ID.

By using cookies, the NAAZ group of companies can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

Using a cookie, the information and offers on our website can be optimized for the user. As already mentioned, cookies enable us to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter their access data each time they visit the website because this is done by the website and the cookie stored on the user's computer system. Another example is the cookie of a shopping cart in the online shop. The online shop remembers the items that a customer has placed in the virtual shopping cart via a cookie.

The data subject can prevent the setting of cookies through our website at any time by means of an appropriate setting in the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.

4. COLLECTION OF GENERAL DATA AND INFORMATION

The website of the NAAZ group of companies collects a series of general data and information every time the website is accessed by a data subject or an automated system. This general data and information is stored in the server’s log files. What can be recorded are the (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrers), (4) the sub-websites which are accessible via an accessing system on our website is controlled, (5) the date and time of access to the website, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information that serves to protect against threats in the event of attacks on our information technology systems.

When using this general data and information, the NAAZ group of companies does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website and the advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website and ( 4) to provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber attack. This anonymously collected data and information is therefore evaluated by the NAAZ group of companies both statistically and with the aim of increasing data protection and data security in our company in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data in the server log files is stored separately from all personal data provided by a data subject.

5. CONTACT OPTION VIA THE WEBSITE

Due to legal regulations, the website of the NAAZ group of companies contains information that enables quick electronic contact with our company and direct communication with us, which also includes a general address for so-called electronic mail (e-mail address). If a data subject contacts the person responsible for processing by email or via a contact form, the personal data transmitted by the data subject will be automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller will be stored for the purposes of processing or contacting the data subject. This personal data will not be passed on to third parties.

6. ROUTINE DELETION AND BLOCKING OF PERSONAL DATA

The person responsible for processing processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage or if this is required by the European legislator or another legislator in laws or regulations which the person responsible for processing is subject to.

If the storage purpose no longer applies or if a storage period prescribed by the European legislator or another responsible legislator expires, the personal data will be blocked or deleted routinely and in accordance with legal regulations.

7. RIGHTS OF THE DATA SUBJECT

·      A) RIGHT TO CONFIRMATION

Every data subject has the right granted by the European legislator to obtain confirmation from the controller as to whether personal data concerning him or her is being processed. If a data subject would like to exercise this right of confirmation, they can contact an employee of the person responsible for processing at any time.

·      B) RIGHT TO INFORMATION

Every person affected by the processing of personal data has the right granted by the Indian legislator to obtain free information from the person responsible for processing at any time about the personal data stored about him and a copy of this information. Furthermore, the Indian legislator has granted the data subject access to the following information:

o   the processing purposes

o   the categories of personal data that are processed

o   the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations

o   if possible, the planned period for which the personal data will be stored or, if this is not possible, the criteria for determining that period

o   the existence of a right to rectification or deletion of personal data concerning you or to restriction of processing by the controller or a right to object to this processing

o   the existence of a right to lodge a complaint with a supervisory authority

o   if the personal data is not collected from the data subject: all available information about the origin of the data

o   the existence of automated decision-making including profiling in accordance with Article 22 Paragraphs 1 and 4 GDPR and - at least in these cases - meaningful information about the logic involved as well as the scope and intended effects of such processing for the data subject

The data subject also has the right to information as to whether personal data has been transmitted to a third country or to an international organization. If this is the case, the data subject also has the right to receive information about the appropriate guarantees in connection with the transfer.

If a data subject would like to exercise this right to information, they can contact an employee of the person responsible for processing at any time.

·      C) RIGHT TO RECTIFICATION

Every person affected by the processing of personal data has the right granted by the European legislator to request the immediate correction of incorrect personal data concerning them. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary statement, taking into account the purposes of the processing.

If a data subject would like to exercise this right to rectification, they can contact an employee of the data controller at any time.

·      D) RIGHT TO DELETION (RIGHT TO BE FORGOTTEN)

Every person affected by the processing of personal data has the right granted by the European legislator to request that the person responsible delete the personal data concerning him or her immediately if one of the following reasons applies and if the processing is not necessary:

o   The personal data was collected or otherwise processed for purposes for which it is no longer necessary.

o   The data subject revokes their consent on which the processing was based in accordance with Article 6 Paragraph 1 Letter a GDPR or Article 9 Paragraph 2 Letter a GDPR and there is no other legal basis for the processing.

o   The data subject objects to the processing in accordance with Article 21 (1) of the GDPR and there are no overriding legitimate reasons for the processing, or the data subject objects to the processing in accordance with Article 21 (2) of the GDPR processing.

o   The personal data was processed unlawfully.

o   The deletion of personal data is necessary to comply with a legal obligation under Union or Member State law to which the controller is subject.

o   The personal data was collected in relation to information society services offered in accordance with Article 8 Para. 1 GDPR.

If one of the reasons mentioned above applies and a data subject wishes to have personal data stored by the NAAZ group of companies deleted, they can contact an employee of the data controller at any time. The employee of the NAAZ group of companies will ensure that the deletion request is complied with immediately.

If the personal data has been made public by the NAAZ group of companies and our company, as the controller, is obliged to delete the personal data in accordance with Article 17 Para. 1 GDPR, the NAAZ group of companies will also take appropriate measures, taking into account the available technology and the implementation costs of a technical nature, in order to inform other data controllers who process the published personal data that the data subject requires these other data controllers to delete all links to these personal data or copies or replications of these personal data has requested, provided that processing is not necessary. The employee of the NAAZ group of companies will take the necessary measures in individual cases.

·      E) RIGHT TO RESTRICTION OF PROCESSING

Every person affected by the processing of personal data has the right granted by the European legislator to request that the controller restrict processing if one of the following conditions is met:

o   The accuracy of the personal data is contested by the data subject for a period enabling the controller to verify the accuracy of the personal data.

o   The processing is unlawful, the data subject refuses the deletion of the personal data and instead requests the restriction of the use of the personal data.

o   The controller no longer needs the personal data for the purposes of processing, but the data subject needs them to assert, exercise or defend legal claims.

o   The data subject has objected to the processing in accordance with Article 21 Paragraph 1 of the GDPR and it is not yet clear whether the legitimate reasons of the controller outweigh those of the data subject.

If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored by the NAAZ group of companies, they can contact an employee of the data controller at any time. The employee of the NAAZ group of companies will arrange for the processing to be restricted.

·      F) RIGHT TO DATA PORTABILITY

Every person affected by the processing of personal data has the right granted by the European legislator to receive the personal data concerning him or her, which the data subject has provided to a person responsible, in a structured, common and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, provided that the processing is based on consent in accordance with Article 6 Paragraph 1 Letter a of the GDPR or Article 9 Paragraph 2 letter a GDPR or on a contract in accordance with Article 6 paragraph 1 letter b GDPR and the processing is carried out using automated procedures, unless the processing is necessary for the performance of a task that is in the public interest or is carried out in the exercise of official authority, which has been transferred to the person responsible.

Furthermore, when exercising his or her right to data portability in accordance with Article 20 (1) of the GDPR, the data subject has the right to have the personal data transmitted directly from one person responsible to another person responsible, to the extent that this is technically feasible and provided that This does not affect the rights and freedoms of other people.

To assert the right to data portability, the data subject can contact an employee of the NAAZ group of companies at any time.

·      G) RIGHT TO OBJECT

Every person affected by the processing of personal data has the right granted by the European legislator to object at any time to the processing of personal data concerning him or her on the basis of Article 6 Paragraph 1 Letter e or f GDPR, to lodge an objection. This also applies to profiling based on these provisions.

The NAAZ group of companies will no longer process the personal data in the event of an objection, unless we can demonstrate compelling legitimate grounds for the processing that outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend of legal claims.

If the NAAZ group of companies processes personal data in order to conduct direct advertising, the data subject has the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling insofar as it is connected to such direct advertising. If the data subject objects to the NAAZ group of companies processing it for direct advertising purposes, the NAAZ group of companies will no longer process the personal data for these purposes.

In addition, the data subject has the right, for reasons arising from his or her particular situation, to object to the processing of personal data concerning him or her that is carried out by the NAAZ group of companies for scientific or historical research purposes or for statistical purposes in accordance with Article 89 (1) of the GDPR. GMOs take place, unless such processing is necessary to fulfill a task carried out in the public interest.

To exercise the right to object, the data subject may contact any employee of the NAAZ group of companies or another employee directly. Furthermore, in connection with the use of information society services, the data subject is free, notwithstanding Directive 2002/58/EC, to exercise his or her right to object by means of automated procedures using technical specifications.

·      H) AUTOMATED DECISIONS IN INDIVIDUAL CASES INCLUDING PROFILING

Every person affected by the processing of personal data has the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him, provided that the decision (1) is not necessary for entering into or performance of a contract between the data subject and the controller, or (2) is authorized by Union or Member State law to which the controller is subject and that legislation appropriates measures to safeguard the rights and freedoms as well as the legitimate interests of the data subject or (3) is carried out with the express consent of the data subject.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, the NAAZ Group shall implement appropriate measures to safeguard the rights and freedoms as well as those entitled to protect the interests of the data subject, which includes at least the right to obtain human intervention on the part of the person responsible, to express one's own point of view and to challenge the decision.

If the data subject would like to assert rights with regard to automated decisions, he or she can contact an employee of the data controller at any time.

·      I) RIGHT TO REVOKE CONSENT UNDER DATA PROTECTION LAW

Every person affected by the processing of personal data has the right granted by the European legislator to revoke consent to the processing of personal data at any time.

If the data subject would like to exercise their right to withdraw consent, they can contact an employee of the data controller at any time.

8. LEGAL BASIS FOR PROCESSING

Art. 6 I lit. a GDPR serves our company as the legal basis for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of any other service or consideration, the processing is based on Art. 6 I lit. b GDPR. The same applies to processing operations that are necessary to carry out pre-contractual measures, for example in cases of inquiries about our products or services. If our company is subject to a legal obligation that requires the processing of personal data, such as to fulfill tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance details or other vital information would then have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 I lit. d GDPR. Ultimately, processing operations could be based on Art. 6 I lit. f GDPR. Processing operations that are not covered by any of the above-mentioned legal bases are based on this legal basis if the processing is necessary to protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not prevail. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, he was of the opinion that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 Sentence 2 GDPR).

9. LEGITIMATE INTERESTS IN PROCESSING PURSUED BY THE CONTROLLER OR A THIRD PARTY

If the processing of personal data is based on Article 6 I lit. f GDPR, our legitimate interest is to carry out our business activities for the benefit of the well-being of all our employees and our shareholders.

10. DURATION FOR WHICH THE PERSONAL DATA WILL BE STORED

The criterion for the duration of storage of personal data is the respective statutory retention period. After the deadline has expired, the relevant data will be routinely deleted unless it is no longer required to fulfill the contract or initiate a contract.

11. LEGAL OR CONTRACTUAL REGULATIONS GOVERNING THE PROVISION OF PERSONAL DATA; NECESSITY FOR THE CONCLUSION OF THE CONTRACT; OBLIGATION OF THE DATA SUBJECT TO PROVIDE THE PERSONAL DATA; POSSIBLE CONSEQUENCES OF NON-PROVISION

We would like to clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). In order to conclude a contract, it may sometimes be necessary for a data subject to provide us with personal data, which must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company enters into a contract with them. Failure to provide the personal data would mean that the contract with the person concerned could not be concluded. Before the data subject provides personal data, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what consequences the non-provision of the personal data would have.

12. EXISTENCE OF AUTOMATED DECISION MAKING

As a responsible company, we do not use automatic decision-making or profiling.