PRIVACY POLICY
I.
Introduction
This privacy policy (“Privacy
Policy”) governs the collection and utilization of PI and/or SPDI, by
Panasonic from End User(s). This Privacy Policy applies to all End Users residing
in India at the time of the collection of the PI and/or SPDI. If an End User resides
in any territory outside India, and this Privacy Policy is not acceptable to
the End User or the applicable law of the End User’s country of residence does
not allow the acceptance of this Privacy Policy then such End User should not
access and/or use the Product(s).
This Privacy Policy
should be read in conjunction with the terms of use applicable to the access MirAIe
app and use of the Products, available at www.panasonic.com/in/miraie/
This document is an electronic
record in terms of Information Technology Act, 2000 and rules thereunder, as
applicable and the amended provisions pertaining to electronic records in various
statutes as amended by the Information Technology Act, 2000. This electronic
record is generated by a computer system and does not require any physical or
digital signatures.
The End User’s access
and use of the Product(s) is deemed to constitute the End User’s unconditional
and irrevocable consent to the collection, possession, storage, processing,
dealing in, handling, transfer, sharing, and/or disclosure, of PI, and the End User’s
irrevocable consent to and acceptance of the terms of this Privacy Policy.
Definitions: For the purposes of
this Privacy Policy, the following terms shall have meaning(s) as ascribed
below:
(i)
“End
User(s)” means and includes all users of the Product(s), including the
following:
(a)
Users
using or benefitting from Panasonic’s customer service and/or training programs;
(b)
Users
using or benefitting from Panasonic’s sales and marketing programs.
(ii)
“Panasonic”
means Panasonic India Private Limited, its group companies, affiliates, subsidiaries,
in India.
(iii)
“PI”
bears the meaning ascribed to it under the Rules, and includes any SPDI
collected from End User(s) as detailed in this Privacy Policy. For the
avoidance of doubt, PI consists of any information that relates to an
identified or identifiable individual, including any information which does not
identify an individual but that Panasonic links to such individual.
(iv)
“Products”
means and includes the Panasonic IOT based Application named as ‘MirAIe’
application software, website, application, digital/online platform owned
and/or operated by Panasonic
(v)
“Rules” means the Information Technology
(Reasonable security practices and procedures and sensitive personal data or
information) Rules, 2011.
(vi)
“SPDI”
bears the meaning ascribed to it under the Rules.
II.
What Information does
Panasonic Collect from End Users
PI collected by
Panasonic and/or, as provided by the End User pursuant to or during the course
of access, use of any Product, may include the following:
(i)
Any
information provided by the End User, including information provided by an End
User to Panasonic’s customer service representatives. Panasonic may also create
logs/reports that are useful in diagnosing product or application performance
related issued, and capture information relating to the same;
(ii)
Contact
information including name, email id, address, contact number, location (based
on varying degree of accuracy based on GPS, IP address, sensor data from
device, things near to your device such as WiFi access point, cell towers and
Bluetooth enabled devices)
(iii)
Payment
details such as credit card/debit card details, banking related information,
information provided pursuant to cashless transaction(s);
(iv)
Uniform
resource locator, IP address, unique
device identifiers, settings of the device used by an End User to access the
Product(s);
(v)
Log
information such as the time and duration of End User’s use of the Product(s),
search query terms, any information stored in cookies;
(vi)
Business
contact details of the End User such as location of business premises, contact
number, fax number, contact number;
(vii)
Usage
behaviour including Product preferences;
(viii)
Operating
system, browser type, browser version, browser configuration, name of internet
service provider, and other types of computer and connection related information
relevant to identifying End User’s type of device;
(ix)
Pages,
links, websites visited or access during the course of access or use of the
Product(s);
(x)
Information
provided while subscribing to Panasonic’s promotional communications and
newsletters;
(xi)
Any
other information provided by an End User and/or collected by Panasonic.
III.
Why does Panasonic
collect PI from End Users?
Panasonic collects PI
from End User(s) for, inter alia, the purposes set out below. All collection of
PI is undertaken in compliance with the applicable laws in India.
(i)
To
make available the Products to the End User, including to enable End User(s) to
create a profile to use the Products;
(ii)
To
register End User(s) or their devices or products for any of Panasonic’s
Products;
(iii)
To
conduct surveys in connection with End User’s usage/experience with the
Products;
(iv)
To
improve the efficiency, quality, and to enhance the user experience of the
Products;
(v)
To
support and maintain the Products including for providing support to End Users;
(vi)
To
identify, assess, evaluate user behavior and preferences, in relation to
various products and services;
(vii)
To
generate and provide recommendations, marketing content, sponsored content, promotional
offers to the End User in connection with the Product(s);
(viii)
To
evaluate the End User(s) eligibility for certain Product(s), and the
suitability of certain Product(s) for an End User;
(ix)
To
ask for End User’s opinions or comments in relation to the Products;
(x)
To
assess and analyse Panasonic’s market, customers, devices, and Products;
(xi)
To
protect an End User’s vital interests of those of another natural person;
(xii)
To
create anonymous, aggregated statistics about the use of the Products;
(xiii)
To
protect the End Users (e.g. to prevent spam or attempts to defraud users of
Products); to operate and maintain the security of the Products (e.g. to
prevent or stop an attack on Panasonic’s systems or networks); or to protect
the rights or property of Panasonic, including enforcing any terms or
agreements governing the use of the Products;
(xiv)
To
communicate with the End User(s), including communicating with End User(s)
about the End User’s account, profiles or transactions with Panasonic, giving
the End User important information about Panasonic’s Products, endeavoring to
send the End User notice about any material changes to the Privacy Policy;
(xv)
To
manage corporate transactions involving Panasonic including reorganization,
merger, transfer, sale, joint venture, assignment or other disposition of all
or any portion of Panasonic’s business, assets or stock, including, without
limitation, in connection with any bankruptcy or similar proceeding;
(xvi)
To
accomplish Panasonic’s legitimate interests which include:
·
To
benefit from cost-effective Product(s) (e.g. Panasonic may opt to use certain
platforms offered by suppliers;
·
To
protect the security of Panasonic’s IT systems, architecture and networks and
protect its customers;
·
To
meet Panasonic’s corporate and social responsibility objectives.
(xvii)
Any
purpose as may be required by applicable laws.
(xviii)
For analytics and
measurement to understand how our services/ products are used.
Panasonic may combine
or aggregate any or all of the PI with personal data or information including
sensitive personal data or information, for any of the purposes set forth in
this Privacy Policy, and the End User expressly consents to the combination, aggregation
of the PI in the manner set forth herein.
IV.
What is the basis for
collection and use of PI by Panasonic?
Without limiting the
deemed consent pursuant to the use or access of the Products, the End User also
expressly, unconditionally, and irrevocable consents to the collection,
possession, storage, processing, dealing in, handling, transfer, sharing,
and/or disclosure, of SPDI by Panasonic.
The End User also
expressly, unconditionally, and irrevocable consents to the disclosure of PI
including SPDI by Panasonic as set forth in this Privacy Policy.
In the event the End
User does not wish to consent as per this paragraph, then the End User has the
option to not use/access the Product(s).
Panasonic will have
the right to retain PI including SPDI for as long as is necessary to fulfil the
‘purposes’ set forth in this Privacy Policy. The storage of PI including SPDI
for any longer period shall be undertaken in accordance with requirements of the
applicable laws in India.
V.
What are the terms
applicable for disclosure of PI by Panasonic?
The disclosure of the
PI including SPDI shall be governed by the following:
Panasonic shall use
commercially reasonable measures to protect PI from unauthorised use or
disclosure.
Panasonic however
reserves the right to disclose the PI including SPDI to, inter alia, its
partners, service providers, group companies, affiliates, vendors, customers,
employees, agents, third party service providers who assist Panasonic, in
connection with any of the ‘purposes’ set forth in this Privacy Policy or
otherwise. Panasonic will endeavor to ensure that the recipient of the PI or
SPDI utilizes the same level of protection measures as are used by Panasonic to
preserve the security of the PI including the SPDI. The End User acknowledges
that if the recipient is located in a country other than India, then the level
of protection afforded to PI and/or SPDI in such country may differ from the
level of protection mandated under the applicable laws in India, and the End
User expressly consents to the disclosure of the PI including SPDI to such
recipient(s) located outside the territory of India. For the avoidance of
doubt, PI shall not be ‘transferred’ by Panasonic to any person that does not
ensure the same level of data protection that is adhered to by Panasonic as
detailed in this Privacy Policy.
Panasonic may be
required to disclose PI including SPDI to in whole or in part, to a third
party, pursuant to a merger, reorganization, consolidation, acquisition, sale
of assets, or in the event of Panasonic’s bankruptcy. Panasonic will endeavor
to ensure that the recipient of the PI or SPDI utilizes the same level of
protection measures as are used by Panasonic to preserve the security of the PI
including the SPDI. The End User acknowledges that if the recipient is located
in a country other than India, then the level of protection afforded to PI
and/or SPDI in such country may differ from the level of protection mandated
under the applicable laws in India, and the End User expressly consents to the
disclosure of the PI including SPDI to such recipient(s) located outside the
territory of India. For the avoidance of doubt, PI shall not be ‘transferred’
by Panasonic to any person that does not ensure the same level of data
protection that is adhered to by Panasonic as detailed in this Privacy Policy.
Panasonic will have
the right, to be exercised in its reasonable discretion, to disclose or share
the PI including SPDI with law enforcement authorities, regulatory bodies,
and/or pursuant to any order of a regulatory or judicial authority, pursuant to
any legal claims, actions, proceedings, suits, and/or to prevent any form of
harm to a third party including injury to any person, and/or to prevent any
illegal or unlawful or legally actionable activity. Panasonic may also provide
PI including SPDI, in whole or in part, to any governmental, judicial, or
regulatory authorities, including any tax authorities, pursuant to a claim or
demand from them.
End Users acknowledge
and agree that PI including SPDI collected by Panasonic, may be stored by
Panasonic on its servers which may be located outside the End User’s country of
residence. By using Product(s), End
Users consent to the storage of the same by Pansonic at its server(s) including
storage and processing of PI outside of End Users’ country of residence
consistent with this Privacy Policy. Recipients of PI including SPDI may be
located in countries other than India, and the level of protection afforded to
PI including SPDI may differ under the applicable laws of such countries, and
hence the protection measures utilized by such recipients in territories
outside India may also differ from the standards deployed and maintained by
Panasonic. End User hereby expressly consents to the disclosure and/or transfer
of PI including SPDI, pursuant to this Privacy Policy, with recipients located
in countries other than India. For the avoidance of doubt, PI shall not be
‘transferred’ by Panasonic to any person that does not ensure the same level of
data protection that is adhered to by Panasonic as detailed in this Privacy
Policy.
VI.
Cookies
Panasonic
may use cookies to collect certain PI from an End User. A cookie is a small
file of letters and numbers that Panasonic puts on the End User’s device. The
cookies allow Panasonic to distinguish an End User from other users of the
Product(s), assist Panasonic to provide End Users with the best possible
experience when End Users browse the Products, and also allow Panasonic to make
improvements. Cookies improve an End User’s browsing experience by:
·
Remembering
settings, so an End User does not have to keep re-entering them whenever the End
User visits a new page;
·
Remembering
information given by an End User so that the End User does not have to keep
entering it;
·
Analyzing
how an End User uses the Products to improve the way it works, to make sure
that the End User finds what such End User is looking for easily, and to ensure
that it meets the End User’s needs;
·
Monitoring
the efficiency of Panasonic’s advertising.
If
the use of such cookies is not acceptable to the End User, then such End User
should adjust the browser settings (typically found in the ‘options’ or
‘preferences’ menu of the browser) or delete/disable the use of such cookies on
the End User’s device. The End User is however advised to take note that
Panasonic may be unable to provide, make available, any or all of the Products
if the End User chooses to disbar the use of cookies in accordance with the
terms of this paragraph.
The
End Users must take note that Panasonic sometimes uses external suppliers to
deliver services on Panasonic’s behalf, which means these cookies may be set by
a third party (third-party cookies). Panasonic does not control these cookies
so if an End User would like more information about them or information on how
to opt out, such End User must see their individual privacy and/or cookie policy.
VII.
Third Party Sites
End User acknowledges
that Panasonic may make available, provide, embed links, promotions,
notifications of third party websites, applications, platforms, products,
services (“Third Party Site(s)”), on
or through its Products, and that the access and use of such Third Party Sites
are governed by the terms of use made available by the operator, owner and
controller of such Third Party Site(s). In the event that any PI or SPDI is
collected, processed, dealt in, handled, transferred, shared, and/or disclosed
by such Third Party Site(s) or the controller, owner, operator of such Third
Party Site(s), then the End User acknowledges that the collection, processing,
dealing in, handling, transfer, sharing, and/or disclosure of such PI including
SPDI is governed by the privacy policy made available by the Third Party
Site(s). The End User expressly acknowledges and affirms that Panasonic is not
in any manner responsible or liable for any PI including SPDI that may be
collected by Third Party Site(s) and/or that may be provided by the End User to
such Third Party Site(s), and that Panasonic does not endorse or support such
Third Party Site(s) including any products, services, or content offered on
them.
VIII.
What Security Measures
does Panasonic use?
Security measures used
by Panasonic to protect the security of PI including SPDI are consistent with industry
standards and are commercially reasonable. The security measures implemented by
Panasonic, inter alia, take into account, the state of the art of the
technology, the costs of its implementation, the nature of the information, and
the risk of the processing. However, End Users should take note that security
measures cannot guarantee that the PI and/or SPDI provided by an End User will
be a hundred percent secure. End Users are therefore advised to use discretion
in providing SPDI to Panasonic and to refrain from providing SPDI if the same
is not expressly requested by Panasonic or if the nature of the request or the
purpose of provision does not necessitate the provision of any SPDI.
IX.
Queries and Concerns
Grievance
Officer
Manisha Saxena is
designated as the grievance officer for the purposes of this Privacy Policy (“Grievance
Officer”). If the End User has any concerns, grievances, queries concerning
this Privacy Policy or any term hereof, including any changes, deletions,
updates required to PI including SPDI of such End User, then all of the
foregoing should be addressed vide a written communication to the Grievance
Office by the End User at the contact details provided below:
Address: Panasonic
India Pvt Ltd,
12th Floor Ambience
Tower,
NH8, DLF Phase 3,
Sector 24,
Gurugram,
Haryana 122002
Ph: +919599186520
Email: manisha.pi@in.panasonic.com
All communications
addressed to the Grievance Officer will be dealt with within thirty (30) days
from the receipt of the communication. Any communication not marked to the
Grievance Officer will not be construed to be a communication covered by this
Privacy Policy.
Customer
Service
If the End User has
any queries concerning any of the Product(s), then such queries may be
addressed to Panasonic’s customer service personnel at:
Pooja Kashyap
Address: Panasonic
India Pvt Ltd,
12th Floor Ambience
Tower,
NH8, DLF Phase 3,
Sector 24,
Gurugram,
Haryana 122002
Ph: +918826818924
Email: pooja.kashyap@in.panasonic.com
Corrections
and Deletion
The End User will have
the right to rectify, correct, update, or delete any PI provided to Panasonic,
or collected by Panasonic, by addressing an appropriate written communication
to such effect to the Grievance Officer as per the details provided in
paragraph IX above. Panasonic will correct or amend such PI, as feasible. If
the End User chooses to delete any PI, then such End User agrees and
acknowledges that Panasonic may be unable make available or provide access to
any or all of the Product(s) pursuant to such deletion.
Changes
to Privacy Policy
Panasonic reserves the
right to update the Privacy Policy or any specific terms thereof from time to
time including to align the terms of the Privacy Policy with Panasonic’s then
current business practices and Products. Unfortunately, it will be infeasible
for Panasonic to notify End Users in the event of such update(s), and it will
be the End User(s) responsibility to review such updated Privacy Policy on this
page. End User’s continued use of the Products will be deemed to constitute the
End User’s unqualified and irrevocable acceptance of the updated Privacy
Policy.
Unsubscribe
If the End User wants
to stop receiving any email communications from Panasonic, then the End User
may do so by clicking on the ‘unsubscribe’ option. End User must be advised
that the withdrawal from receipt of such communications may not be immediate.
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