Privacy Policy

1. Introduction

Welcome to the official website of Popular Autoworks Pvt Ltd an authorised dealer of Jaguar Land Rover vehicles in India having its registered office at Kuttukaran Centre, Mamangalam, Kochi – 682025 (hereinafter referred to as “PAWL”, or the “Company”).
This Privacy Policy (“Policy”) describes the manner in which PAWL collects, receives, uses, stores, shares, discloses, retains and otherwise processes the Personal Data of individuals (“Data Principals”) who access or use PAWL’s website, digital platforms or otherwise avail themselves of the products and services offered by PAWL.
PAWL is committed to protecting the privacy and security of Personal Data entrusted to it and ensuring that such Personal Data is processed in a lawful, fair and transparent manner in accordance with the Digital Personal Data Protection Act, 2023 (“DPDP Act”), the rules made thereunder, and the other applicable law relating to Privacy, data protection and information security in India, including the Information Technology Act, 2000, wherever applicable.
This Policy provides information regarding the categories of Personal Data collected by PAWL, the purposes for which such Personal Data is processed, the manner in which such Personal Data is protected, the circumstances under which such Personal Data may be disclosed, and the rights available to Data Principals under applicable law.
This Policy applies to individuals who visit or interact with PAWL official website (“www.pawl.in”), submit enquiries, request test drives, book vehicles, avail vehicle servicing facilities, communicate with PAWL, or otherwise provide their Personal Data to PAWL through any authorised channel.
Users are also requested to read PAWL’s Terms and Conditions applicable to specific products, services, offers and promotional programmes. By accessing or using PAWL’s website or services, users acknowledge that they have read and understood this Privacy Policy. Where consent is required under applicable law, PAWL shall obtain such consent before processing Personal Data in accordance with this Policy.

2. Objective

The objective of this Privacy Policy is to establish a transparent and accountable framework for the collection, processing, use, storage, disclosure and protection of Personal Data by PAWL in accordance with applicable data protection laws, including the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and rules made thereunder, as applicable from time to time.

3. Scope and Applicability

This Policy applies to Personal Data processed by PAWL in connection with its products, services and business activities, including Personal Data relating to:
a. Customers and prospective customers;
b. Vehicle owners and users;
c. Website and digital platform users;
d. Persons requesting information, test drives or services;
e. Vendors, contractors and business partners; and
f. Other individuals whose Personal Data is lawfully processed by PAWL.
Personal Data may be collected through PAWL’s website and digital platforms, enquiries, test drive requests, vehicle bookings and purchases, delivery and registration processes, servicing, maintenance, warranty and after-sales activities, customer communications, feedback, grievances and authorised third-party channels.

4. Definitions

For the purpose of this Privacy Policy, unless the context otherwise requires, the following terms shall have the meanings assigned below

  • “Act” – Means the Digital Personal Data Protection Act, 2023, as amended, supplemented, modified or replaced from time to time.
  • “Applicable Law” – Means all applicable laws, statutes, rules, regulations, notifications, circulars, directions, guidelines and governmental requirements applicable to the processing and protection of Personal Data, including the Digital Personal Data Protection Act, 2023 and rules made thereunder.
  • “Company” / “PAWL” – Means Popular Autoworks Ltd., an authorised dealer of Jaguar Land Rover vehicles in India, having its registered office at Kuttukaran Centre, Mamangalam, Kochi – 682025.
  • “Data Fiduciary” – Means any person who, alone or in conjunction with other persons, determines the purpose and means of processing Personal Data. For the purposes of this Privacy Policy, PAWL acts as the Data Fiduciary responsible for determining the purposes and means of processing Personal Data collected and processed by PAWL.
  • “Data Principal” – Means the individual to whom the Personal Data relates.
  • “Digital Personal Data” – Means Personal Data in digital form.
  • “Personal Data”- Means any data about an individual who is identifiable by or in relation to such data.
  • “Processing” – Means any operation or set of operations performed on Personal Data, including collection, recording, organisation, storage, use, sharing, disclosure, adaptation, retrieval, alteration, restriction, erasure or destruction of such Personal Data.
  • “Consent” – Means any freely given, specific, informed and unambiguous indication of the wishes of the Data Principal by which the Data Principal agrees to the processing of Personal Data for a specified purpose.
  • “Personal Data Breach” – Means any unauthorised processing of Personal Data or accidental disclosure, acquisition, sharing, use, alteration, loss, destruction or access to Personal Data that compromises the confidentiality, integrity or availability of such Personal Data.
  • “Data Processor” – Means any person who processes Personal Data on behalf of a Data Fiduciary.
  • “Website” – Means the official website, digital platforms, applications or online services operated or controlled by PAWL through which individuals may access information or avail products and services offered by PAWL.
  • “Third Party”- Means any person, entity, organisation, service provider, contractor, business partner or other party who is not PAWL or the Data Principal.

Main Aspects of Privacy Policy

PAWL recognises that protection of Personal Data is an important responsibility and is committed to ensuring that Personal Data is collected, processed, stored, disclosed and protected in a lawful, fair and transparent manner.

PAWL adopts appropriate policies, procedures and safeguards to ensure responsible handling of Personal Data throughout its lifecycle. This section describes the manner in which PAWL processes Personal Data, including the categories of Personal Data collected, purposes of processing, consent management, sharing practices, security measures and mechanisms available to Data Principals for exercising their rights.

  • Collection of Personal Data
    PAWL may collect Personal Data directly from Data Principals or through authorised and lawful sources.
    Depending on the nature of the interaction, Personal Data may include:
    Identification and Contact Details: Name, address, telephone number, email address, date of birth and other identification details.
    Vehicle Information: Vehicle registration number, vehicle identification number, ownership details, service history, warranty and insurance information.
    Transaction Information: Booking details, invoices, payment records, financing and insurance-related information.
    Government Identification: Government-issued identification information where necessary and permitted by law.
    Digital and Technical Information: IP address, device and browser information, website usage information, cookies and similar technical information.
    Communication Information: Enquiries, feedback, service requests, communications and other information provided during interactions with PAWL.
    Location Information: Location information where required for a specific service and permitted by the Data Principal or applicable law. PAWL shall collect only Personal Data that is adequate, relevant and reasonably necessary for the relevant purpose.
  • Data Minimisation
    PAWL shall limit collection and processing of Personal Data to information necessary for the specified purpose and shall avoid excessive or unrelated collection.
  • Purposes of Processing
    PAWL may process Personal Data for the following purposes:
    Providing information regarding vehicles, products and services;
    Processing enquiries, quotations and test drive requests;
    Processing vehicle bookings, purchases, deliveries and registrations;
    Providing servicing, maintenance, warranty and after-sales services;
    Managing customer relationships and communications;
    Processing payments and maintaining transaction and accounting records;
    Sending service-related and, where consented to, marketing communications;
    Complying with legal, regulatory and statutory obligations;
    Preventing fraud, misuse and security incidents;
    Maintaining and improving products, services and customer experience; and
    Other lawful purposes communicated to the Data Principal.
    PAWL shall not process Personal Data for purposes incompatible with the purpose for which it was collected, except where permitted under applicable law.
  • Cookies and Other Trackers
    PAWL’s website may use cookies, pixels, tags, web beacons and similar technologies to maintain website functionality, improve user experience, analyse usage, enhance security and provide relevant services.
    These technologies may collect information such as IP address, browser type, device information, pages visited and website interaction.
    Cookies may be:
    a. Necessary Cookies – required for basic website operation and security;
    b. Analytics Cookies – used to understand website usage and improve performance;
    c. Functional Cookies – used to remember preferences; and
    d. Marketing Cookies – where applicable, used for promotional and advertising purposes.PAWL may use authorised third-party service providers for analytics and other digital services.
    Users may manage or disable cookies through their browser settings or available cookie-management tools. Disabling certain cookies may affect website functionality.
    Where required by law, PAWL shall obtain consent before using non-essential cookies.
  • Consent and Withdrawal of Consent
    Where processing is based on consent, PAWL shall obtain consent that is free, specific, informed and unambiguous. PAWL shall provide information regarding the Personal Data proposed to be processed, the purpose of processing and the manner in which consent may be provided or withdrawn.
    Data Principals may withdraw consent at any time where processing is based on consent. Withdrawal shall be as easy as providing consent. Withdrawal shall not affect the legality of processing carried out before withdrawal. PAWL may continue processing where such processing is otherwise permitted or required by law.
    PAWL may reasonably verify the identity of a Data Principal before acting upon a consent withdrawal or privacy request.
    Marketing or promotional communications through email, SMS, telephone, WhatsApp or similar channels shall be sent only where appropriate consent has been obtained or otherwise permitted by applicable law. Data Principals may opt out through the available unsubscribe mechanism or by contacting PAWL.
    PAWL shall maintain appropriate records of consent and withdrawal, wherever applicable.
  • Maintenance of Consent Records
    PAWL shall maintain appropriate records of consent obtained from Data Principals, including the nature of consent provided, purpose of processing and withdrawal requests, wherever applicable.
    PAWL shall ensure that consent mechanisms enable Data Principals to provide, review and withdraw consent in accordance with applicable law.
  • Rights of Data Principals
    Subject to the DPDP Act and applicable law, Data Principals may exercise the following rights:
    Right to Information – To obtain information regarding Personal Data processed by PAWL, including relevant categories and purposes of processing.
    Right to Correction, Completion, Updating and Erasure – To request correction, completion, updating or erasure of Personal Data where permitted under applicable law.
    Right to Withdraw Consent- To withdraw consent where processing is based on consent.
    Right to Grievance Redressal – To raise concerns or complaints regarding processing of Personal Data.
    Right to Nominate – To nominate another individual to exercise the Data Principal’s rights in the event of death or incapacity, in accordance with applicable law.
    Consent Manager – Where a Consent Manager is available under applicable law, Data Principals may manage consent through such Consent Manager – Requests may be made through the contact details provided in this Policy. PAWL may verify the identity of the requester and shall process valid requests within applicable timelines, subject to legal requirements and exemptions.
    5.8 Safeguarding the Privacy of Children
    PAWL shall process children’s Personal Data in accordance with the DPDP Act and applicable laws.
    PAWL shall not knowingly process children’s Personal Data except where permitted by law and appropriate parental or lawful guardian consent is obtained where required.
    PAWL shall take reasonable measures against:
    Processing likely to cause detrimental effects on children’s well-being;
    Tracking or behavioural monitoring of children; and
    Targeted advertising directed towards children were prohibited by lawParents or lawful guardians may contact PAWL through the grievance mechanism regarding children’s Personal Data.
  • Aadhaar and Government-Issued Identification Information
    PAWL shall not require Aadhaar details except where permitted by applicable law.
    Aadhaar or other government-issued identification information may be processed where necessary for lawful purposes, including customer verification, vehicle purchase or registration, legal or regulatory compliance and fraud prevention.
    Such information shall be collected, used and retained only to the extent necessary for the specified purpose and protected through appropriate safeguards. It shall not be used for unrelated purposes except as permitted by law.
  • Disclosure and Transfer of Personal Data
    PAWL may disclose or transfer Personal Data where necessary for providing products and services, fulfilling contractual obligations, complying with law or for another lawful purpose.
    Personal Data may be shared with:Jaguar Land Rover India and authorised entities for vehicle sales, warranty, service, customer assistance, recalls, product improvement and related activities;

    Service providers, vendors and Data Processors providing IT, cloud storage, CRM, payment, communication, registration, logistics and other authorised services;

    Government and regulatory authorities, courts and law enforcement agencies where legally required;

    Professional advisors, including legal advisors, auditors, consultants and insurers, where necessary; and

    Successors or authorised parties in connection with mergers, acquisitions, restructuring, business transfers or sale of assets, subject to applicable law.

    Data Processors shall process Personal Data only for authorised purposes and in accordance with PAWL’s instructions, contractual obligations and applicable law.

    PAWL shall take reasonable steps to ensure confidentiality and appropriate security of Personal Data shared with third parties.

  • Security Safeguards
    PAWL shall implement appropriate technical, organisational and physical safeguards to protect Personal Data against unauthorised access, disclosure, misuse, alteration, loss or destruction. Such safeguards may include access controls, authentication, secure storage and transmission, monitoring, employee confidentiality measures and appropriate security requirements for Data Processors and service providers. Personal Data shall be retained only for as long as necessary for the relevant purpose or as required by law and shall thereafter be securely deleted, anonymised or disposed of.
  • Personal Data Breach Management
    PAWL shall maintain appropriate procedures to identify, assess, contain and manage Personal Data Breaches. In the event of a suspected or actual breach, PAWL shall take reasonable steps to contain and mitigate the breach, assess its impact, investigate and document the incident, notify the Data Protection Board of India and affected Data Principals where required by applicable law, and implement appropriate corrective and preventive measures.
  • Accuracy of Personal Data
    PAWL shall take reasonable measures to ensure that Personal Data is accurate, complete and updated for the purposes for which it is processed. Data Principals are encouraged to provide accurate information and notify PAWL of any changes. PAWL shall retain Personal Data only for as long as necessary for the relevant purpose or as required by applicable law and shall thereafter securely delete, anonymise or dispose of it.6.13 Grievance Redressal Mechanism
  • Grievance Redressal Mechanism
    Data Principals may raise grievances regarding the collection, processing, use, disclosure or protection of their Personal Data, withdrawal of consent, correction, updating or erasure, or exercise of their rights under the DPDP Act. PAWL shall verify and investigate the grievance, take appropriate action and communicate the outcome within the applicable timeline, endeavouring to resolve privacy-related grievances within 15 business days. Where a Data Principal is dissatisfied with the response, further remedies available under the DPDP Act and other applicable laws may be exercised.

Online Vehicle Booking & Refund Policy

PAWL may provide online vehicle booking through its website or authorised digital platforms. Personal Data and payment information collected during booking shall be processed in accordance with this Policy and applicable law. Online bookings are subject to vehicle availability, customer verification, documentation, payment requirements and applicable booking terms. Cancellation, refund and other commercial terms shall be governed by the applicable booking terms and conditions.

Third Party Websites, External Links and Indemnity

Any Personal Data shared by users with third-party websites shall be processed in accordance with the privacy policies and practices of such third parties. PAWL shall not be responsible for any collection, use, disclosure, storage, loss, misuse or unauthorised processing of Personal Data by such third parties.

The inclusion of any third-party link on PAWL’s website shall not be construed as an endorsement, approval or recommendation of such third-party website, service or platform.

Amendments to this Privacy Policy

PAWL may amend or update this Policy to reflect changes in its business, technology, products, services, applicable laws, regulatory requirements or privacy practices.

Updated versions shall be published on PAWL’s official website with the revised effective date.
Where a material change significantly affects processing of Personal Data, PAWL may provide appropriate notice and obtain consent wherever required by law.
Users are encouraged to review this Policy periodically.

Governing Law and Jurisdiction

This Policy shall be governed by the laws of India, including applicable privacy and data protection laws.
Processing of Personal Data shall be carried out in accordance with the DPDP Act, rules made thereunder and other applicable laws.

Any dispute arising from or relating to this Policy shall be subject to the jurisdiction of the competent courts at Kochi, Kerala, unless otherwise provided under applicable law.

Nothing in this clause shall restrict statutory rights or remedies available to Data Principals.

Disclaimer

This Policy applies to Personal Data collected and processed by PAWL in connection with its products, services, website, digital platforms and authorised business activities.
PAWL endeavours to keep this Policy accurate and updated. This Policy describes PAWL’s privacy practices and does not create contractual rights beyond those provided under applicable law.
PAWL shall not be responsible for the privacy practices, content, security or data processing activities of third-party websites, applications or platforms.

Contact Details of Grievance Officer

AWL has appointed a Grievance Officer to address queries, concerns, requests and complaints relating to the processing of Personal Data and the exercise of rights available to Data Principals under applicable data protection laws.
Data Principals may contact the Grievance Officer in relation to privacy-related matters, including requests for correction, updating, withdrawal of consent, grievance resolution or any other concerns relating to the processing of Personal Data.
The details of the Grievance Officer are provided below:
Popular Autoworks Pvt. Ltd. (Authorised Dealer of Jaguar Land Rover Vehicles in India)
Registered Office: Kuttukaran Centre, Mamangalam, Kochi – 682025, Kerala, India
Telephone:
Fax:
Website: www.pawl.in
Designated Grievance Officer / Data Privacy Protection Officer (DPPO): Srinivas Nakella (Compliance Officer / CEO of Popular Autoworks Private Limited)
Email: srinivas.nakkella@pawl.in
PAWL shall endeavour to resolve privacy-related grievances received from Data Principals within fifteen (15) business days from the date of receipt of such grievance.
Where additional information or verification is required, PAWL may request such information from the Data Principal to facilitate appropriate review and resolution of the grievance.
For privacy and data protection purposes, communications sent to the Grievance Officer’s email address shall be restricted to matters relating to Personal Data, privacy rights, consent, data processing or grievances under applicable data protection laws.
Queries, complaints or requests relating to vehicle sales, servicing, repairs, warranty, insurance, finance or other business-related services shall be addressed through the respective customer support channels provided by PAWL.
Important Notice: The Grievance Officer’s email address is intended only for privacy, data protection and Personal Data-related queries or complaints. Queries, complaints or requests relating to vehicle sales, servicing, repairs, warranty, finance, insurance or other business services should be directed through the respective customer support channels provided by PAWL.

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