Privacy Policy – ITC’s Papyra Mobile Application and Website
ITC Limited respects an individual’s right to privacy. This policy lays down our practices with respect to confidentiality and disclosure of personal information. Please familiarize yourself with our privacy practices, as given below and read this privacy policy along with Term of Use carefully before using the Application or any of Services. Your use of the Application or any of the Services in connection with the Application through any means or modes signifies your acceptance of this privacy policy and Terms of Use and You shall be legally bound by the same. Should you choose to share your personal information with ITC Limited, it will be assumed that you have no objection to the terms of this privacy policy.
This Privacy Policy covers the information collected, processed, accessed, stored and controlled by ITC Limited having its registered office at 37, Jawaharlal Nehru Road, Kolkata 700071 either by itself or through its third party vendors (hereinafter referred to as ‘ITC’) from the user(s) (“User(s)” and/or “You”) of ITC’s Papyra Mobile Application and Website (“Application”) and/or the Services provided by ITC on the Application (as defined in the Terms of Use – “Terms of Use”), which Services can be used or accessed on the Application
The Application provides its users a platform to access content relating to papers, paperboards and specialty papers marketed by ITC and facilitate placement of request for samples.
ITC Limited has also adopted reasonable security practices and procedures comprising of managerial, technical, operational and physical security control measures with a view to ensure confidentiality and prevent unauthorized disclosure of personal information and such measures are commensurate with the information being protected with the nature of business. ITC Limited uses the personal information only for the purpose for which the same has been furnished. In order to make the best use of Application/Service and enable information provided by You to be captured accurately, it is essential that you log in using your credentials only .
This Privacy Policy should be read in conjunction and together with the Terms of Use available on the Application. Personal Information of a User(s) is collected if the User(s) registers with the Application, accesses the Application or takes any action on the Application or uses or accesses the Services as defined in the Terms of Use. The terms ‘Personal Information’, ‘Sensitive Personal Data’ and ‘Information’ shall have the meaning ascribed to it under the Information Technology Act, 2000 (India) and the Rules and Regulations framed thereunder. Your use of our Services offered on the Application is constructed to mean that You consent to our collection, storage, processing and transfer of your Personal Information or Sensitive Personal Data or Information in accordance with this Privacy Policy and You consent to the terms and conditions of this Privacy Policy. ITC Limited shall not be responsible in any manner whatsoever for any violation or misuse of your Personal Information by unauthorised persons consequent to misuse of the internet environment.
Here are our privacy principles:
1. Collection Of Information And Use
The Personal Information or Sensitive Personal Data or Information which You may provide to the Application and/or which We may collect as part of the information provided is or could be the following:
Your registration details which may include your name, e-mail address, mobile/contact details, location provided by You/your comments or other content that You share on the Application. If you access or engage with the Application or Services associated with the Application through a social media service, we may collect your user id or user name, any information You have permitted the social media service to share with Us, and any information You have made public with the social media service.
We may also collect your usage behaviour of the Application or interests, other traceable activities online, on apps and on mobile such as destinations visited or content consumed; details of the mobile operating system or mobile operating network which You use to visit the Application and undertake any activity on the Application , such as a unique device identifier, session identifiers from device ID, commercially available services, data aggregator platforms; user preferences (e.g., preferred language settings); operating system, browser type, browser version, browser configuration, and other types of mobile and connection related information relevant to identifying your type of device, connecting to the Application, enabling data exchange with You and your device, and ensuring a convenient use of the application; the uniform resource locator (“URL”) and IP address of the website from which you accessed, or were directed to our Application, including date and time; subpages visited while on Our Application, links followed on the Application, including date and time; the full URL click stream to, through and from the Application, including date and time; service requests; search terms entered; services viewed or searched for on the Application; information collected by cookies or similar technologies (as described in the next paragraph); newsletter subscriptions, enrolment for promotions, use of special offers, etc; consents, authorizations, etc. granted; survey answers, reviews, ratings and other types of feedback provided; content of any communication sent through the Application, including any information posted in social communities on the Application or otherwise shared with Application and/or other users, as well as chat messages and chat transcripts; information on software downloaded from the Application; and any other information that you enter on, or upload to, the Application (e.g., content that you fill into an online form, a photo that you upload).
Our primary purposes in collecting information including Personal Information or Sensitive Personal Data or Information from You is to allow You to use the Application and various features and Services on or in relation to the Application or any Sites, contact you for any Services provided by the ITC Limited or its affiliates or its various service providers or business partners and advertisers; to record Your information and details as permitted and required under applicable laws, statutory direction or judicial orders; to serve various promotion materials and advertising materials to You; and such other uses as provided in the Terms of Use and this Privacy Policy. We may also use the Personal Information or Sensitive Personal Data or Information provided by You or collected by ITC for content recommendations, transactional emails or to provide You with information, direct marketing, online and offline advertising and other materials regarding products, services and other offers from time to time in connection with the ITC Limited or its subsidiary and affiliated companies (“Platform Entities”) and its joint ventures.
We may also collect information or Personal Information to track User behaviour and preferences for internal analytics of all Users of the Application. We may also use your information or Personal Information: (i) to evaluate your eligibility for certain types of offers, products or services; (ii) to perform analytics and conduct customer research, including general market research or surveying our customers' needs and opinions on specific issues, generating sales and traffic patterns, and to analyze advertising effectiveness, both on an anonymous basis (e.g., by aggregating data) or on an individual basis (as allowed under law);
This Personal Information or Sensitive Personal Data or Information is collected through the use of server log files and tracking technologies to analyze certain types of technical information. We may also collect and process information about your location using GPS technology in the mobile. You can stop all collection of information by the Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.
We may combine Your Personal Information or Sensitive Personal Data or Information, other information and information collected from tracking technologies and aggregate it with information collected from other Users using our Application to attempt to provide You with the Services and a better experience on the Application.
You understand, agree and acknowledge that our collection, storage and processing of your Personal Information or Sensitive Personal Data or Information is for a lawful purpose connected with a function or activity of the Platform Entities and its joint ventures. You hereby consent to the collection, storage, use, disclosure, transfer, of the Personal Information or Sensitive Personal Data or Information by ITC Limited for the purposes set out herein. You further understand, agree and acknowledge that Your Personal Information which is classified as Sensitive Personal Data or Information as per applicable laws is considered necessary for ITC Limited to provide various Services on its Application to You and for Your usage of the Application and other services provided by ITC Limited in relation to the Application and you affirmatively consent to its collection, storage, transfer and processing.
Legal Basis: The legal basis for the processing of your personal data is the consent provided by You and/or any other applicable legal basis, such as our legitimate interest in engaging in commerce and offering products and services of value to you.
2. Information Sharing And Disclosure
ITC Limited is the recipient of Your Personal Information or Sensitive Personal Data or Information and shall exercise reasonable commercial endeavours for the prevention of unauthorized disclosure of the Personal Information including any Sensitive Personal Data or Information provided by the Users. We may enable access of Your Personal Information or Sensitive Personal Data or Information to the Platform Entities, joint ventures, business partners, agents or third parties for the purposes of the services provided by them, including third party analytics partners or for any other marketing related activity undertaken by or on behalf of the Platform Entities and/or its joint ventures, and/or for the purposes of enhancing the quality of the Services provided to You on the Application, and You expressly consent to the same.
We shall endeavour that the third parties and agents engaged by us to whom we may provide access to Your Personal Information or Sensitive Personal Data or Information for the purposes set out herein are under a contractual obligation to protect Your Personal Information or Sensitive Personal Data or Information in accordance with the same standard as ITC Limited has agreed to be subject to in this Privacy Policy.
3. Compliance With Laws And Law Enforcement
ITC Limited cooperates with mandated government and law enforcement agencies or to any third parties by an order under law for the time being in force to enforce and comply with the law. We will also disclose any information including Sensitive Personal Data or Information about You to government and law enforcement agencies without your permission as We, in our sole discretion, believe necessary or appropriate to respond to valid claims and legal process, to protect the property and rights of ITC Limited or a third party, to protect the safety of the public or any person, or to prevent or stop any illegal, unethical or legally actionable activity. ITC Limited may also provide Your Personal Information including Sensitive Personal Data or Information to various governmental authorities including tax authorities upon any demand or request from them with/without any notice/intimation to You.
4. Email Policies
ITC Limited may use Your Personal Information or Sensitive Personal Data or Information for the purposes mentioned in this Privacy Policy including sending promotional emails. You have full control regarding which emails You want to receive. If You decide at any time that You no longer wish to receive such communications from the Platform Entities, please follow the unsubscribe instructions provided in any of the communications. Please note that once we receive Your request, it may take an additional period of time for Your opt-out to become effective.
5. Data Security
We understand the importance of data security and We want your user experience with Us to be as safe as possible. We have implemented reasonable safeguards and precautions to protect Your Personal Information or Sensitive Personal Data or Information, including technical and organizational measures against unauthorized access, improper use, alteration, unlawful or accidental destruction, and accidental loss, both in an online and offline context and such measures are commensurate with the information being protected with the nature of business.
We have adopted reasonable security practices and procedure and We maintain technical and organizational security measures and procedures to protect the security of Your Personal Information or Sensitive Personal Data or Information, which are consistent with measures used by other similar applications.
Please understand that, while We strive to protect Your Personal Information or Sensitive Personal Data or Information against potential risks and exposures, there is no absolute security in the online sphere. Hence, We ask you to support our IT security efforts by not disclosing any of Your Personal Information or Sensitive Personal Data or Information data on Our Application that is particularly sensitive or not required in the specific context. Furthermore, You can help us protecting your personal data by signing off when you finish using login-protected areas of the Application.
6. Data Retention
We retain Personal Information or Sensitive Personal Data or Information only for as long as We believe it to be necessary for purposes set out herein for which the Personal Information or Sensitive Personal Data or Information was collected, subject to any legal requirements for the data to be retained for longer periods of time. All information including Personal Information or Sensitive Personal Data or Information shall be collected by ITC Limited having its registered office at 37, Jawaharlal Nehru, Kolkata – 700071 and shall be retained by ITC Limited having its registered address at 37, Jawaharlal Nehru, Kolkata – 700071.
7. Deleting Your Information
If You wish to have the Personal Information or Sensitive Personal Data or Information that You have provided to us deleted, You can always do so by sending a request to us to us at marketing.itcpspd@Itc.in. You may note that deletion of certain Personal Information may lead to cancellation of your registration with the Application and/or your access to certain features of the Application can be restricted and may also lead to complete cessation of Your access to the Application.
8. Links To Other Sites / Financial Data
We may provide links to other websites and portals for your convenience and information (“Other Websites”). Please note that while you transact with Other Websites, the Platform does not directly collect any details from You. Such Other Websites are not controlled by us. When you visit such Other Websites, You do so at your own risk. These Other Websites may have their own privacy policies in place, which we recommend You review if You visit any such Other Websites. We do not assume any responsibility or liability for such Other Websites, the content of such Other Websites and their privacy practices, nor do we endorse them. We encourage you to familiarize yourself with the privacy statements provided by such Other Websites prior to providing them with information about you or entering into any transactions on them.
While transacting with these Other Websites, You may provide Your financial information including without limitation Your bank account details, credit card account details or your details pertaining to any payment settlement or pre-paid instrument service provider. You understand, agree and acknowledge that the Application and ITC Limited never receives any such information from these Other Websites. Your Personal Information, Sensitive Personal Data or Information and financial information will be dealt with by these Other Websites in accordance with their respective privacy policies and other terms and conditions and the ITC Limited shall not be liable, accountable or responsible for Your Personal Information, Sensitive Personal Data or Information and financial information which You provide to these Other Websites.
9. Security
We are concerned about safeguarding the confidentiality of your information. ITC Limited uses commercially reasonable security practices and procedures designed to help keep your Personal Information or Sensitive Personal Data or Information safe. For example, We limit access to this information to authorized employees and contractors or any other third party who need to know that information in order to operate, develop or improve our Application.
This Application is available for users residing in India only. If you are located outside India, please note that You information may be transferred to or may be maintained on computers, computer systems and computer resources located outside of Your state or country where the privacy laws may be different as those where you live. If You are located outside India and choose to provide information to us, please be aware that the Application is hosted in India and that Platform keeps or transfers information to and from India for storage and processing. Your submission of such information represents your agreement to that transfer.
Unfortunately, the transmission of information over the Internet is not completely secure. Although We strive to protect your personal data, We cannot guarantee the security of your data while it is being transmitted to our Application; any transmission is at your own risk. Once We have received your information, We have commercially reasonable procedures and security practices in place to reasonably endeavour to prevent unauthorized access.
10. Your rights as a Data Subject
As a data subject affected by the data processing activity, You have the following rights with regard to your data
Right of access to data/request for a copy of the data
Right to rectification of errors in the data
Right to deletion of data
Right to object to the processing of data
Right to withdraw consent
Right to object or opt-out of marketing communication
Right to data portability
11. Changes In Privacy Policy
ITC Limited reserves its right to revise this privacy policy from time to time at its sole discretion. Such privacy policy as may be revised will be available on the Application.
Your continued use of our Application and the Services constitutes Your acceptance of the then-current Privacy Policy and Terms of Use so We encourage You to visit this page periodically to review any changes.
12. Contact Us
If You have any questions about this Privacy Policy or the Application, You can contact us at or via the links at the bottom of the page. Email id: Marketing.itcpspd@Itc.in
13. Grievance Officer
In accordance with the Information Technology Act, 2000 and the Rules framed thereunder, the name and contact details of the Grievance Officer (Data Protection Officer “DPO”) are provided below:-
Grievance Officer: Mr. Rama Narala
Email id: Grievance.itcpspd@itc.in
14. Review/Amend/Rectify information provided
You may review the information including personal information and sensitive personal data or information as provided by You from time to time on the Application. In case there is any inaccuracy or deficiency in the information provided by You and You wish to amend/rectify the same, please reach out to marketing.itcpspd@itc.in.
15. Alerts/Notifications
We may alertYou by email/SMS/notification through the Application to inform You about the Services on the Application or any new offering which in our opinion may be useful for You.