Privacy Policy Effective On DATE: 15-08-2024
At Godrej & Boyce Manufacturing Company Limited (hereinafter referred to as “Godrej” or
“We”), we take your privacy very seriously and are committed to protect your personal data. The
connected hotel lock solution (“Product”), which is a locking solutions device that is to be
operated through the Advantis Smartlocks. This Privacy Policy covers the aspect of privacy for
the Product and the App and constitutes how we collect, use, disclose, process, transfer, and
store your personal data when you use the Product and the App. In order to use the App, you will
be required to accept and consent to the terms of this Privacy Policy and your use of the App
signifies your continued acceptance thereof. It is important that you fully understand our personal
data and information collection and usage practices and ensure that you are ultimately able to
exercise control over the personal data and information you provide to us. You are advised to
carefully read the Privacy Policy before using the App.

Please note that the App may contain links to third party applications / digital platforms which are
provided for your convenience. We are only responsible for the privacy practices and security of
our own App. We recommend that you check the privacy and security policies and procedures of
each and every other application / digital platform that you visit.

1 COLLECTION AND USE OF PERSONAL DATA AND INFORMATION
A. Personal data and information is data that can be used to identify or contact an

individual/s, either from that information alone or in conjunction with other related
information including but not limited to name, address, e-mail address, user name,
telephone number, age, gender, nationality, information, posts and other content you
submit to our App. A Communication device means and includes cell phones, computer,
laptop, personal digital assistance or combination of both or any other device used by
you to communicate, send and/or transmit any text, video, audio or image. Personal data
and information is collected from you in order to provide you with our products and/or
services. Please note, if you don’t choose to provide us with the requested personal data,
we will be unable to offer you our products or services. All personal data and information
that we collect about you will be recorded, used, and protected by us in accordance with
applicable data protection legislation and this Privacy Notice.

B. When you use and/or register on the App through any communication device, the
following information is collected from you and stored securely on AWS cloud managed
by our third-party service provider (‘Servers’) – (i) email; and/or (ii) mobile number;
and/or (iii) Profile picture; and/or (iv) Address and/or (vi) GST number and/or (vii) Product
serial number during registration and/or (viii) audio-video, images and/or (ix) your Wi-Fi
information, internet connection and/or (x) the equipment you use to access the App.

C. Information that may be collected automatically and/or manually from the computer or
mobile devices you use to access the App shall include:

i. Your Wi-Fi Router details including name and password and/or server’s IP address
from where the App is being accessed, the type of browser (Internet Explorer,
Firefox, Opera, Google Chrome etc.), the operating system of Your system and the
website you last visited before visiting to Platform, and your computer, Internet
connection and mobile device, other browsing information (connection, speed,
connection type etc.), device type, device’s unique device identifier, mobile network
information and the device’s telephone number;

ii. Details of your use of the App, including location data, traffic data, logs and other
communication data and the resources that you use and access on or through the
App;

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iii. We also may seek permission to access metadata and other information associated
with other files stored on your mobile device. This may include, for example,
personal contacts and address book information;

iv. We may also collect real-time information about the location of your device, as
permitted by you;

v. Unique mobile device identifier (e.g. IDFA or other device IDs on Apple devices like
the iPhone and iPad), if you’re using the App on a mobile device, we may use mobile
device IDs (the unique identifier assigned to a device by the manufacturer), instead
of cookies, to recognize you. Unlike cookies, mobile device IDs cannot be deleted
from records. We may share it with advertising companies and they may use device
IDs to track your use of App, track the number of advertisements displayed, measure
advertising performance and display advertisements that are more relevant to you.
We may also share it with analytics companies which may use mobile device IDs to
track your usage of the App;

vi. Other information relating to your activity on the App, such as your search queries,
comments, domain names, search results selected, number of clicks, pages viewed
and the order of those pages, how long you visited the App, the date and time you
used the App, error logs, and other similar information;

vii. Your locations details including the latitude, longitude or altitude of your mobile
device, GPS location;

viii. Bluetooth related information including Godrej locks visible nearby;
ix. In case of mobile application users, the online or offline status of your App.

D. We may supplement the information that you provide with other information that we
obtain from our dealings with you or which we receive from other organisations, for
example, our sponsors, vendors and partners.

E. In broad terms, we use your personal data for the following purposes:
i. to administer and provide products and services you request or have expressed an

interest in;
ii. to communicate with you in the event that any products or services you have

requested are unavailable;
iii. for fraud screening and prevention purposes;
iv. for record keeping purposes;
v. to carry out market research so that we can improve the products and services we

offer;
vi. to track your activity on our App,digital platforms;
vii. to create an individual profile for you so that we can understand and respect your

preferences;
viii. to personalise and improve your experience on our App,digital platforms;
ix. to personalise and/ tailor any communications that we may send you;
x. for profiling purposes to enable us to personalise and/or tailor any marketing

communications that you may consent to receive from us.
F. When we provide you with products or services we may collect and store any personal

data and information that you provide to us. We may, for example, keep a record of your
name, address, delivery address, email address, and the telephone number. We may
also record details of any disability or health needs that you may have. Such collected
information will be used in accordance with the terms of this notice.

G. When information is collected from you such as your name, e-mail address (Personal
Data), we will use it in accordance with the terms of this notice and for the purpose of
fulfilling your requirement. This information may be shared with other Godrej and Boyce
Manufacturing Company Limited businesses and/or its vendors and partners, but only if
necessary to fulfill your request or for related purposes.

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H. All personal information collected from you at the time of registration and subsequently
will be retained for as long as your account remains in existence. All application
generated log information which is collected will be retained on the mobile device for a
period of 30 days from the date of collection after which it will be purged from the App. All
other information collected and uploaded to the cloud server will be purged from this
server 90 days after being uploaded. The customer profile data and information such as
name, profile detail, email id, mobile number and address shall remain retained in the
Server.

2. DEVICE INFORMATION COLLECTION
A. We collect information from the communication device you use to access our App and

the information that we obtain from these communication device.

B. When you sign up with us for an online account, register to receive marketing
communications from us (and/or our sponsors and partners), fill in one of our forms
(whether online or offline) or otherwise expressly provide us with your personal data, we
may collect and store any personal data that you provide to us and may use it to
personalise and improve your experience on our App, provide products and services you
request from us, and carry out profiling and market research.

C. When you interact with our App /digital platforms, we may also automatically collect the
following information about your visit. This is primarily to help us better understand how
you use our digital platforms to enable us create better content and more relevant
communications:

i. how you have reached our App, digital platform and the internet protocol (IP) address
you have used

ii. your browser type, versions and plug-ins, and your operating system
iii. your journey through our digital platform, including which links you click on and any

searches you made, how long you stayed on a page, and other page interaction
information

iv. what content you like or share
v. which adverts you saw and responded to

vi. which pop up or push messages you might have seen and responded to
vii. your subscription status
viii. information collected in any forms you complete

D. We may also infer your country of location from the IP address you have used to access
our digital platforms and we may analyse which marketing activity led to your taking
specific action on our digital platforms (e.g. downloading the app).

3. OFFERS AND OPPORTUNTIES FROM US AND OUR PARTNERS
A. We want you to be the first to know about new products and services, and occasional

offers from our partners. We may share these offers with you only with your prior consent.
You can unsubscribe from receiving these offers by emailing us. Please note, if you don’t
choose to receive this information, we will be unable to keep you informed of new
services, products, events or special offers that may interest you and our ability to inform
you of ticketing opportunities may be affected.

4. LEGITIMATE PROCESSING OF INFORMATION:

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A. We may process your personal information for legitimate interests, including providing
you with services and for service improvement purposes.

B. It may be deemed necessary to process personal information for the following (but not
limited to) purposes of legitimate interests by us or our third parties such as:
i. To deliver services in respect to requests raised by you.
ii. To prevent misuse or fraudulent activities on our platforms.
iii. To uphold performance of contracts to which the data subject is a part of .
iv. In interests deemed to protect the vital interest of the data subject.
v. In order to maintain compliance with legal obligations to which Godrej is a subject or

where required by law.
C. We take special consideration to ensure that the legitimate processing of information do

not override the fundamental rights and freedoms of the data subjects.
5. CHILDREN

A. We understand the importance of taking extra precautions to protect the privacy and
safety of children using Godrej’s products and services. The App does not provide
information or any products specifically targeting children.

B. If you are under the age of 16, you must first tell your parent or legal guardian that you
wish to register on our digital platforms and get their consent. You must make sure that
your parent or legal guardian knows and agrees each time before you:

i. email us, or ask us to email anything to you;
ii. send any information to us;
iii. enter any competition or game that requires information about you or offers a

prize;
iv. purchase an official membership; or
v. offer or agree to buy anything online.

C. Once we receive appropriate authorization or consent from your parents or legal
guardian, we may collect your date of birth and retain that with your name and other
details you may provide. This is so we can ensure we treat you in an age appropriate
way in line with this Privacy Notice.

6. WHO DO WE SHARE YOUR PERSONAL DATA WITH?
A. As a global business, Godrej may share your personal data with Godrej’s subsidaries,

vendors, partners, service providers and other trusted third parties based within and
outside the country in which you live so that they may process that data on our behalf as
necessary, in connection with providing our products and services to you, fulfilling
contractual arrangements and legal or regulatory requirements. Godrej requires that its
service providers and such other third parties keep your personal data confidential and
that they only use the personal data in furtherance of the specific purpose for which it
was disclosed.

B. We may share your personal data with:
i. law enforcement or government authorities where they have followed due legal

process to request us to disclose the information
ii. third party providers of services and web analytics tool providers, if you have any

queries about our third party service providers, then you may contact us. (contact
details included in the later part of this notice).

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7. TRANSFERRING YOUR PERSONAL DATA
A. We may transfer your personal data to servers located outside the country in which you

live or to affiliates or other trusted third parties based in other countries so that they may
process personal data on our behalf. By using a Godrej site or otherwise providing
Godrej with personal data, you agree to us doing so in accordance with the terms of this
Privacy Notice and applicable data protection laws and regulations. Godrej will ensure to
a reasonable extent that anyone processing your personal data outside your country of
origin is required to implement measures to protect it and is only entitled to process it in
accordance with Godrej’s instructions.

8. DATA SECURITY
A. The App is equipped with industry standard security features to protect the confidentiality

and security of your information. All the back-end APIs are secured with SSL certificates .All
the data communications happen over secured channels.

9. RETENTION OF PERSONAL DATA
A. You are responsible for providing the App/Godrej with accurate and complete personal

data. Please notify us of any changes to your personal data. Godrej shall take
reasonable steps to ensure that your personal data is kept accurate, complete, and
current.

B. We will retain your personal data for the period necessary to fulfil the purposes outlined
in this Privacy Notice unless a longer retention period is required or permitted by law.

10. COOKIES
A. In common with many other App operators, we use standard technology called 'cookies'

on our App and the same is also used by third party applications. Cookies are small
pieces of information available on our App and/or third party applications that are stored
by your browser on your computer's hard drive and they are used to record how you
navigate this App on each visit.

B. We automatically collect and temporarily store the following information about your visit:
i. the name of the domain you use to access the Internet;
ii. the date and time of your visit;
iii. the pages you use via App; and
iv. the address of the web App you came from when you came to visit

C. We use this information for statistical purposes and to help us make our App more useful
to visitors. Unless it is specifically stated otherwise, no additional information will be
collected about you.

11. SAFEGUARDING YOUR PERSONAL DATA
A. We take all reasonable precautions to keep your personal data secure and require any

third parties that handle or process your personal data for us to do the same. Access to
your personal data is restricted to prevent unauthorised access, modification or misuse
and is only permitted among our employees and authorised agents on a need-to-know
basis.

12. YOUR PRIVACY RIGHTS AND WHO TO CONTACT
A. We provide you with reasonable access to view and review your personal data and

request correction and deletion where appropriate. In order to protect your privacy, we

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will take reasonable steps to verify your identity before granting access to your personal
data.

B. If you have any questions, comments or concerns about how we handle your personal
data, then you may contact us–at gdpr@godrej.com.

C. You have the right to tell us if you:
i. don't want to be contacted in the future by us
ii. would like a copy of the personal data which we hold about you
iii. would like to delete your personal data in our records
iv. wish to report any misuse or unauthorized use of your personal data including but not

limited to any illegal action or omission done by any third party
v. would like to correct or update your personal data

D. To exercise any of the above listed rights you may contact us to assist us in dealing with
your request, please provide your full name, address, date of birth and email address.

E. If you have subscribed to receive marketing communications, you can unsubscribe by
contacting our Privacy Officer.

13. CHANGES TO OUR PRIVACY NOTICE
A. We may change our Privacy Notice from time to time and post the updated version of the

same. We encourage you to visit frequently to stay informed about how we use your
personal data.

14. HANDLING PRIVACY CONCERNS
A. If you have any questions about this Privacy Notice or if you believe that your personal

data is not handled in accordance with the applicable law or this notice, then you may
contact us at gdpr@godrej.com.

Effective on - 16-08-2024

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