Cholamandalam Investment and Finance Company Limited (hereinafter referred to as “CIFCL”) is concerned about the privacy of data and information of the Users (as defined below) accessing, selling, offering or purchasing products or services on the website www.gaadibazaar.in, mobile applications or otherwise doing business with CIFCL. This Privacy Policy (“Privacy Policy”) describes the information which shall be collected by CIFCL from the Users during the course of offering services/products. This Privacy Policy helps the User understand how CIFCL collects, uses, stores, processes, transfers and protects all the User information when the User visits the website  www.gaadibazaar.in, mobile applications and avail the products and services offered therein, which will help the User take an informed decision.

This Privacy Policy is an electronic contract formed under the Information Technology Act, 2000 and Rules made thereunder and the relevant amendments made thereon. This Privacy Policy does not require any physical, digital, or electronic signature. This Privacy Policy is published in accordance with the provisions of Rule 3 of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, which requires intermediaries to publish the rules and regulations, privacy policy and user agreement for access or usage of its computer resource by any person.

This Privacy Policy of the website available at www.gaadibazaar.in, “Gaadibazaar” mobile applications (individually and collectively referred to as “Website”) is applicable to the guest users or registered users of the Website (each, hereinafter referred to as the "User").

The User is advised to read this Privacy Policy to learn more about the ways in which CIFCL shall use and protect the personal information of the User. By visiting this Website, the User agrees to be bound by the terms and conditions of this Privacy Policy. If the User disagrees with the terms and conditions of the Privacy Policy, the User shall not use or access this Website.

By accepting this Privacy Policy on registration, the User expressly consents to (i) be bound by the terms and conditions of this Privacy Policy; and (ii) CIFCL’s use and disclosure of the User’s Personal Information (as defined below) and Sensitive Personal Information (as defined below) in accordance with this Privacy Policy. This Privacy Policy shall be read along with the terms of User Agreement - www.gaadibazaar.in/user-agreement (“Agreement”) available on the Website.

CIFCL may develop new or offer additional services. If the introduction of these new or additional services results in any material change to the way CIFCL collects or processes the User Personal Information and Sensitive Personal information, CIFCL will provide the User with more information or additional terms and policies. User is requested to review this page periodically, to remain aware of any changes.

1. Nature of Information collected on the Website

I. Information provided by the User:

a) All information provided to CIFCL when the User registers, subscribes to services or purchase goods or services on the Website, including name, address, telephone number, email address, gender, and any other information, either directly or indirectly, in combination with other information available or likely to be available with CIFCL, which is capable of identifying such User (collectively referred to as “Personal Information”).

b)  All information that the User chooses to share on the Website such as photos, videos, comments, events, tags or other user generated content that the User may upload on the Website.

c)  “Sensitive Personal Information”, i.e., passwords and all financial information provided at the time of purchase of goods and services on the Website, such as credit card, debit card or other payment instrument information etc.

The User can browse the Website without providing their information, including Personal or Sensitive Personal Information. When the User provides his/her Personal Information, he/she is not an anonymous User of the Website.

II. Information collected by CIFCL:

a)  Technical information such as the User’s IP Address, login information, operating system, browser type, the page served, time preceding page viewed, purchase history, search history, length of visits, metadata (data about other information collected, such as date, time, size etc).

b)  Log file information, namely, information automatically reported by the User’s browser upon accessing the Website.

c)  Device Identifiers, i.e., small bits of data which identifies remote devices such as mobile phones, computers, tablets or other devices (collectively referred to as ‘Devices’) used to access the Website. Some mobile service providers may also provide CIFCL with the physical location of the Device used to access the Website.

d) Demographic data, profile data about users and behavioral information such as advertisements clicked on, products viewed, reviews read, details of the URL that the User just came from (whether this URL is on the Website or not) etc. This information shall be compiled and analyzed on an aggregated basis.

e)  CIFCL may automatically track some specific information of the User based on his/her behavior on the Website. Likewise, CIFCL may use the said information to perform internal research on the User's interests, behaviour and demographics for better understanding, protecting and serving the User.

f)  If the User chooses to buy or sell vehicles/equipment and/or purchase other products/ services offered on the Website, then CIFCL shall collect information about the User’s buying and selling behaviour.

g) CIFCL also collects other users' comments about the User in the feedback column of the Website. In the event of the User choosing to provide feedback on other Users of the Website, CIFCL shall collect that information.

III .For fully using the Website and availing the product/Services provided therein, the User needs to register with the Website by providing his/her contact, identity information and other personal information as indicated on the Website. If the User is not willing to provide his/her personal information, he/she must opt out from registering with the Website.

III. Cookies

CIFCL shall use data collection devices such as "cookies" on certain pages of the Website to analyze such web page flow, measure effectiveness of promotional activities and promote safety and trust. "Cookies" are small files placed on the hard drive, which will assist CIFCL in providing better services. CIFCL offers certain features that are only available through the use of "cookies". CIFCL also uses cookies to allow the User to enter his/her password less frequently during a session. Further, cookies also help CIFCL in providing information that is targeted to the interests of the User. Most of the cookies are "session cookies", which will be deleted automatically from the hard drive at the end of a session. The User is always free to decline the cookies, if his/her browser permits, although in that case the User may not be able to use certain features of the Website and the User may be required to re-enter his/her password more frequently during a session.

CIFCL shall retain information as necessary to resolve disputes, troubleshoot problems and provide customer support to the extent permitted by law. If a User sends personal correspondence to CIFCL, such as emails or letters, or if other users or third parties send correspondence to CIFCL about the activities of User or postings on the Site, CIFCL may collect and store such information into a file specific to the said User.

2. Purpose of Collection and Use of User Information:

CIFCL uses the Personal Information and Sensitive Personal Information of the User in the following ways and for the following purposes:

a)  To improve the services/products offered on the Website.

b)  The Personal Information and other information of the User, which CIFCL obtains from the User’s current and past activities on the Website, shall be used by CIFCL to measure User’s interest in the services/products provided on the Website.

c)  To inform the User about online and offline offers, products, services, and updates.

d)  To customize User experience; help promote safe trading; detect and protect CIFCL against error, fraud, and other criminal activity; resolve disputes; troubleshoot problems and collect fees owed.

e)  To enforce our User Agreement.

f)  To analyze the information shared by various Users to identify the Users using multiple User IDs. CIFCL may compare and review User’s Personal Information for errors, omissions and for accuracy.

g)  To bill the User and provide required support if the User chooses to list a vehicle/equipment for sale on the Website.

h)  To analyze usage of the Website.

i)  To improve CIFCL’s marketing and promotional efforts.

j)  To improve the Website’s content and product/service offerings and customize the Website’s content, layout and services.

k)  To contact the User and deliver information such as targeted banner advertisements, administrative notices, product offerings and communications relevant to his/her use of the Website. The User agrees to receive the said information on acceptance of the User Agreement and Privacy Policy. The User may opt out of the receipt of the said communications in his/her profile. The User may make changes to his/her profile at any time.

l)  For internal operations such as troubleshooting, data analysis, research, testing and quality improvement of our service;

m)  To respond to judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law;

n)  For any other purpose a described to the User at the time of collection of information. By visiting, accessing and/or using the Website and/ or submitting Personal Information or Sensitive Personal Information, the User consents to such use of his/her Personal Information and Sensitive Personal Information by CIFCL.

By using the Website and providing the required information, the User authorizes CIFCL & both its present and future associates to communicate with him/her via Email, Phone, SMS or any other means to offer the User their and CIFCL’s services, offer promotional offers, impart product knowledge as listed on the Website & offers of CIFCL’s associates regardless of the User’s DNC or DND status.

3. Disclosure of User information

CIFCL may reveal the general statistical information about the Website and Users, such as number of Users, number and type of products and services provided, etc from time to time.

CIFCL may also use the information collected from the User to deliver information to User that are targeted to User’s interests, such as new services and promotions.

The following are examples of some categories of persons to whom CIFCL may share User’s information, including Personal Information, Sensitive Personal Information, from time-to-time.

a. Listing of Advertisements

a.  Where the User enters information on any form hosted by an advertiser on the Website, such information shall simultaneously be collected by CIFCL and the advertiser (including dealers, car manufacturers, valuers, insurers etc). The information shall be used by CIFCL in accordance with this Privacy Policy and the advertiser shall be bound to use such information as per its prevalent privacy policies. As CIFCL cannot have control over the privacy policies/practices of the advertisers, the User should evaluate the advertiser’s privacy policy/practices before deciding to provide the said information.

CIFCL may aggregate the Personal Information of Users available on the Website and share such information in a non-personally identifiable manner to the advertisers and third parties for marketing and promotional purposes of Website. The User can opt out of sharing such information by reaching out to unsubscribe@gaadibazaar.in

b. Listing of Classifieds

a.  On the listing of a classified advertisement by a User, and another User expressing his interest on the advertisement, the User who expresses interest over the advertisement will be provided with the contact information of the User listing the classified advertisement.

b.  Likewise, the contact information of a User who expresses interest in a classified advertisement shall be shared with the User who has listed the said advertisement.

c.  Third Party Products and Services offered on the Website

There are certain services for which third parties may request the information of User before rendering the service (example: Personal Information and Sensitive Personal Information, vehicle particulars for valuation of such Vehicle), such information shall simultaneously be collected by CIFCL and the third party. The information shall be used by CIFCL in accordance with this Privacy Policy and the third party shall be bound to use such information as per its prevalent privacy policies. As CIFCL cannot have control over the privacy policies/practices of third parties, the User should evaluate such third party’s privacy policy/practices before deciding to provide the said information.

d. Third Parties as Internal Service Providers of CIFCL

To facilitate or outsource certain aspects of the business, service operations and products which are provided by CIFCL to the User through this Website (e.g., search technology, rewards programs etc.,), CIFCL may use third parties who will be referred to as internal service providers and therefore CIFCL may share the information, including Personal Information and Sensitive Personal Information, of User directly to these internal service providers. The internal service providers are subject to nondisclosure agreements with CIFCL and other legal restrictions that prohibit their use of the information which shall be provided to them to perform the specific outsourced Website related operation, unless the User has explicitly agreed or given his/her prior permission to the internal service providers for additional uses. On certain occasions, the internal service provider may collect information directly from the User. In such event, the User will be notified of the involvement of the internal service provider, and all additional information the User shall provide to the internal service provider/s and their additional uses will be up to the discretion of the User. If the User provides additional information to an internal service provider directly, then the use of such additional information is governed by the privacy policy of such internal service provider.

e. Affiliates and Subsidiaries

CIFCL shall share the User information, including their Personal Information and Sensitive Personal Information, with its affiliates, subsidiaries, and joint ventures that are committed to serve the User through the Website and other modes. These entities shall protect the information on par with the information which they obtain from their users.

CIFCL, its affiliates, subsidiaries, joint ventures, or any combination of such, may share some or all of Personal Information and Sensitive Personal Information of User with another business entity with whom CIFCL, its affiliates, subsidiaries and/or joint ventures plan to, merge with, or be acquired by that business entity. On happening of such merger of acquisition, CIFCL shall request the new entity to follow this Privacy Policy with respect to such User’s Personal Information.

f. Sharing of Information on Legal/Regulatory Requirements

CIFCL may share the User’s information, including Personal Information and Sensitive Personal Information, to third parties if CIFCL is under a duty to disclose or share such information, in order to comply with any legal obligation, or where CIFCL believes in good faith that the law requires it, or at the request of Governmental authorities conducting an investigation or in order to enforce, verify or apply our User Agreement and other agreements or policies, or to protect CIFCL’s rights, property, or safety and the rights, property or safety of the other Users.

If there are any cyber security incidents, CIFCL may share the User’s Information, including Personal Information and Sensitive Personal Information, with the Indian Computer Emergency Response Team in accordance with the policies and procedures mentioned in the Information Technology (The Indian Computer Emergency Response Team and Manner of Performing Functions and Duties) Rules, 2013.

CIFCL shall comply with the directions of law enforcement agencies, statutory, judicial and non-judicial authorities and cooperate in the inquiries. Therefore, in response to a direction of law enforcement, regulatory or other such government authority, relating to an investigation, we shall disclose the User’s name, contact details, his/her behaviour/ activity on the Website with or without a subpoena or summon.

CIFCL ensures that the Website is secured through reasonable security practices as enumerated in clause 12 of this Privacy Policy. However, third parties may unlawfully intercept or access transmissions or private communications or other Users may abuse or misuse Personal Information of a User that they access in the Website. Therefore, CIFCL does not promise, and User shall not expect, that his/her Personal Information or private communications will always remain confidential.

4. Transfer to other countries

CIFCL may share a copy of the User’s Personal Information and Sensitive Personal Information globally in order to carry out various activities specified in this Privacy Policy. The User’s Personal Information and Sensitive Personal Information may therefore be subject to the privacy laws that are different from the User country. CIFCL shall ensure that the transfer of User’s Personal Information and Sensitive Personal Information is carried out in accordance with the applicable privacy laws and is in compliance with the provisions applicable for transfer of Sensitive Personal Information and any other appropriate contractual, technical, and organisational measures that are in place, such as, for example, the Standard Contractual Clauses approved by the EU Commission. Provided that CIFCL may, during its business and for the various activities specified in this Privacy Policy, enter into agreement(s) with third-party vendors that involves the transfer of User’s Personal Information and Sensitive Personal Information globally. In this case, CIFCL shall take all steps, that are within its control, to ensure that the transfer of User’s Personal Information and Sensitive Personal Information complies with the applicable privacy laws.

By visiting, accessing and/or using this Website and/or submitting the information, the User consents to such transfer and disclosure of Personal Information and Sensitive Personal Information.

5. Obligations of User

The User agrees, undertakes and confirms that while providing his/her information on the Website, the User shall not upload, display, host, publish, modify, update, transmit or share any information that:-

a)  belongs to another person and to which the User does not have any right;
b)  is defamatory, obscene, pornographic, paedophilic, invasive of another’s privacy, including bodily privacy, insulting or harassing on the basis of gender, libellous, racially or ethnically objectionable, relating or encouraging money laundering or gambling, or otherwise inconsistent with or contrary to the laws in force;
c)  is harmful to a child/children;
d)  infringes any patent, trademark, copyright or other proprietary rights;
e)  violates any law for the time being in force;
f)  deceives or misleads the addressee about the origin of the message or knowingly and intentionally communicates any information which is patently false or misleading in nature but may reasonably be perceived as a fact;
g)  impersonates another person;
h)  threatens the unity, integrity, defence, security or sovereignty of India, friendly relations with foreign States, or public order, or causes incitement to the commission of any cognisable offence or prevents investigation of any offence or is insulting other nation;
i)  contains software virus or any other computer code, file or program designed to interrupt, destroy or limit the functionality of any computer resource; or
j)  is patently false and untrue, and is written or published in any form, with the intent to mislead or harass a person, entity or agency for financial gain or to cause any injury to any person;

6. Storage and Retention of information

a)  The User’s information collected by CIFCL is stored in India by CIFCL or its affiliates, business partners, suppliers and sub-contractors, in an easily retrievable format.

b)  The User’s Personal Information shall be stored only for the period necessary for the purposes specified in clause 2 above, and shall be retained in the manner prescribed under applicable law.

c)  Records containing Personal Information and Sensitive Personal Information will only be retained as long as necessary to provide the User with CIFCL Services and for legitimate and essential business purposes, such as maintaining the performance of the service, making data-driven business decisions about new features and offerings, complying with legal obligations and resolving disputes. (“Information Retention Obligation”). Some Personal Information may be retained as long as a person is the User of a Service. CIFCL shall retain the information shared by the User, including Personal Information, only for a period of one hundred and eighty days (180) days after any cancellation or withdrawal of his/her registration or for such longer period as may be required under applicable laws, including laws applicable to non-banking financial companies.

d)  In accordance with the Information Retention Obligation, all Personal Information and Sensitive Personal Information collected and processed by CIFCL shall be deleted when the retention is no longer necessary.

e)  Upon User’s request, CIFCL will delete or anonymise User Personal Information and Sensitive Personal Information, so that it no longer identifies the User, except in the following circumstances:

i)  CIFCL is legally allowed to or maintain certain Personal Information or Sensitive Personal Information;
ii)  Requirement to retain the Personal information or Sensitive Personal Information on legitimate business; interests such as fraud prevention or maintaining the security of the users
iii)  Retention for legal, tax, audit and accounting obligations for the period allowed by law.

f)  By visiting, accessing and/or using this Website and/or submitting information, the User consents to such storage of information, including Personal Information and Sensitive Personal Information

7. User's Rights

a)  Right to access: User has the right to be informed of and request access to, the Personal Information and Sensitive Personal Information processed about the User.

b)  Right to Opt Out: The User has the right to opt out of providing any of the information mentioned in clause 1. I However, in such event CIFCL reserves the right to refuse or limit the User’s access and use of the Website and its features, including goods and services offered on the Website.

c)  Right to Withdraw Consent: The User has the right to withdraw consent to the use, disclosure, or transfer of his/her information mentioned in clause 1.I. However, in such event CIFCL reserves the right to refuse or limit the User’s access and use of the Website and its features, including goods and services offered on the Website.

d)  Right to rectification: The User has the right to update or correct his/her information provided under clause 1.I. The User may exercise such right by raising service request in gaadibazaar application or mail to feedback@gaaibazaar.in or support@gaadibazaar.in

e)  Right to unsubscribe: The User has the right to unsubscribe from any commercial communication, which is not essential for CIFCL to provide its goods or services. You may exercise such right by clicking on the following link unsubscribe@gaadibazaar.in

8. Usage of Other Users' Information

To facilitate the communication and interaction among the Users of Website, CIFCL allows the User to access other Users' contact details. As a Seller, a User shall receive the contact details of the intending Buyer(s) via email/ short messaging service (SMS) and as an intending Buyer; a User shall receive the contact details of the Seller(s) via email/SMS. By entering into the User Agreement hosted in this Website, the User agrees that, with respect to other User's Personal Information or Sensitive Personal Information that the User obtains through the Website or through a related communication from Website or Website facilitated transaction, the Website hereby permits the User a license to use such information only for:

a)  availing services offered through the Website,

b)  any other purpose that the User expressly opts by providing adequate disclosures. The User shall give adequate opportunity to other Users to remove themselves from his/her database and an option to review the information collected by such User about other Users.

No User shall disclose Personal Information or Sensitive Personal Information of another User to a third party without the specific consent of that another User and CIFCL.

The Website shall not tolerate spam. Hence, no User shall add another User to his/her email or physical mail lists in any circumstance without the express consent of that another User.

9. Change of Personal Information by User

CIFCL shall verify the identity of User before granting access or making changes to his/her Personal Information. Subsequent to the registration of profile by a User on the Website, the User ID and Password will be required by the Website to access the said User’s profile.

10. User’s consent

By using the Website, the User consents to the collection and use of information disclosed by him/her in the Website.

a) Personal Information of children:

CIFCL does not knowingly collect, maintain or use Personal Information or Sensitive Personal Information from children under 18 years of age. If the User is under the age limit of their respective local legislations, the User is requested to not provide their Personal Information to CFCIL.
If the User is a parent of a child under the age limit of their respective local jurisdiction and become aware that their child has provided Personal Information or Sensitive Personal Information to this Website without their consent ,the User needs to contact CIFCL through the mode described under paragraph 14(a) . CIFCL will promptly take steps to delete such Personal Information or Sensitive Personal Information and terminate the child’s account.

11. Grievance Officer

The name and contact details of the Grievance Officer of CIFCL is as provided below: Name: Krishnakumar.K.P
Designation: Sr. Associate VP-Operations
Contact number: 1800-102-4565
Customer Care Email ID: feedback@gaaibazaar.in or support@gaadibazaar.in

The Grievance Officer may be contacted with respect to any complaints or concerns including those pertaining to breach of our User Agreement and Privacy Policy.

12. Security Practices

a.  CIFCL strives to ensure the security, integrity, and privacy of the User’s information and to protect the User’s information against unauthorized access or disclosure, alteration, or destruction.

b.  For the above purpose, CIFCL has adopted internal reviews of the data collection, storage, and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where the User’s information is stored.

c.  CIFCL also has a comprehensive and robust information and cyber security policy, information technology and other mechanisms in accordance with the applicable law to ensure the security of the User’s information.

13. Amendment to Privacy Policy

On amending the Privacy Policy, CIFCL shall notify the User, in the Website, at least 10 days in advance of implementation, about the details of such amendment.

This privacy policy was last updated on 07 October 2021

14. Notices

Except when explicitly stated otherwise, any notices shall be sent by email to feedback@gaaibazaar.in or support@gaadibazaar.in

Notice/any communication shall be sent to the User either to the email address, if any provided by the User on the Website.

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