Privacy Statement

Atradius India Credit Management Services (P) Limited (“Atradius India” or “We” or “Our” or “Us”), is a credit management agency incorporated and registered under the provisions of applicable law in India. Atradius India is a subsidiary of Atradius N.V. (“Atradius”) who is a global provider of credit insurance, surety, reinsurance, debt collections and business information/intelligence services.

This privacy statement (“Privacy Statement”) applies to your use of this website at www.atradius.in (“Website”), owned and operated by Atradius, its affiliated companies and subsidiaries. The Website is a platform that facilitates the purchase/use of the products and services offered by Atradius India (“Services”). In this regard, please note that Our customers also include customers of Our business partners that have availed Our Services but only to the extent of availing Our Services.

This Privacy Statement describes the privacy policy of Atradius India. It is published in compliance with India’s Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 ( “SPI Rules”).

When providing the Services, Atradius India acts as a “data controller”. We collect and process data/information of companies and businesses. However, in the process of doing so, We also process data/information that may be qualified as “personal information or data”, or “sensitive personal information or data” under the SPI Rules, where it is information relating to natural persons (e.g. a sole trader, a company director, a beneficial owner, a professional contact etc). This Privacy Policy applies to such natural persons who are visitors on the Website and/or representatives or contact persons of (i) prospective customers through the use of the Website, (ii) any existing customers who have agreed to obtain the Services, (iii) parties that trade with Our customers, (iv) parties that do business with Us as business partner or supplier (hereinafter, referred to as “You” or “Your” or “Yourself” or “User”). In this regard, please note that the term “personal data/information” refers to information relating to a natural person that is capable of identifying such person and includes any “sensitive personal information”. In addition, in recognition that Atradius India may need to process or control the personal data of European Union residents and in this regard please refer to Our Privacy Statement made in accordance with applicable law.

In this Privacy Statement, We provide information that We are required to give in relation to the processing of personal data/information under Indian law. We explain for instance the purposes and grounds of the processing of personal data/information, the categories of personal data/information concerned, the categories of the sources and the recipients of the personal data/information, sharing of the personal data/information, data retention and Your rights as data subject/provider of information.

Atradius India is committed to maintain confidentiality, integrity and availability of all information We collects from You. In this regard, We have implemented reasonable security practices and procedures that are commensurate with the information assets being protected and with the nature of Our business per applicable law.

Please read the Privacy Statement carefully before proceeding to use the Website. By using the Website, You agree to be legally bound by the terms and conditions of this Privacy Statement with immediate effect. If You do not agree, then please do not continue to access or use the Website, and do not complete any registration process available on the Website.

Updates/Modifications

We strive for continuous improvement in the Services, processes and protecting Your personal data, so We may update this Privacy Statement from time to time. In this regard, Atradius India reserves the right to change or modify this Privacy Statement, in whole or in part, with or without prior notice, from time to time. Therefore, We advise You to check this Privacy Statement on a regular basis. This Privacy Statement was updated on 10 May 2023.

Any changes to the Privacy Statement will become effective upon posting of the revised Privacy Statement on the Website. Access or use of the Website following the posting of the Privacy Statement will be considered as Your acceptance of the revised Privacy Statement. You should periodically review the “last updated” date at the top of this Privacy Statement so that You can familiarise Yourself with any changes, as they are binding on You. In case You no longer wish to use the Website on such revised Privacy Statement, You are entitled to terminate Your relationship with Atradius India by ceasing to use this Website any further.

When do We collect personal data/information and when does this privacy statement apply?

1. If You use our Website

1.1. What data/information do We collect?

We may process the following data/information on Your company or business:

Any personal data/information including sensitive personal data/information that You submit such as Your name, (work) address, telephone number, email address, login details, or other information provided during registration for any of the Services;
We may also collect Your personal data/information if You contact Us by phone, email or through the Website;
Information that allows Us to remember You and Your preferences in using this Website. We use cookies and similar tracking technologies to collect this type of information. Further details on this are available on Our Cookie Information page including how to decline/disable cookies.
We may also receive and/or hold information about Your browsing history, Internet Protocol (IP) address of Your electronic device (or the proxy server), operating system, type of web browser, language, time zone, region and other specifications of Your electronic device for anonymous statistical purposes including advertisements, administration of the Website and associated servers, and to improve the Services.
Your subscriptions to any promotional materials such as newsletters, email updates, country reports, updated trade or economic information, etc made via the Website.

1.2. Why do We collect this data/information?

We may use Your data/information for the following purposes:

To provide and improve the Services, maintain contact with You and handle complaints/disputes;
To optimise the Services, for (direct) marketing purposes and market research; and
To administer the Website and related servers and to manage and protect Our information technology infrastructure.

1.3. Legal grounds for using Your data/information

We process Your data/information including personal data/information only if this is allowed under one of the legal processing grounds. We rely on one or more of the following legal grounds for the processing of Your personal data/information:

Consent
- We request Your consent for the usage of certain cookies via the Website. See Our Cookie Information page for more details on this.
Legitimate interests
We may process Your personal data/information as necessary for achieving Our legitimate interests.
- For the usage of some cookies, We do not require Your consent. Here, Atradius India has a legitimate interest to make a functional website available to You. See Our Cookie Information page for further information on this.
- In certain cases, We do not require Your consent to use Your personal data/information to contact You. This is, for instance, the case if You requested Us to contact You via a contact form. We furthermore do not always require Your consent to use Your personal data/information for marketing purposes. This may for instance be the case if Atradius India obtained Your email address in the context of providing the Services, and We use this address for direct marketing of Our own similar Services.

1.4. Where did We obtain Your data/information?

We automatically obtain some data/information when You visit Our website. We collect such data/information via cookies. See Our Cookie Information page for more details on this.

We obtain other data/information when You actively provide it to Us. This is, for example, the case when You sign up for any newsletters, email updates, country reports, updated trade or economic information, etc. via the Website. See also the information on Our marketing activities in Section 2 below.

1.5. Who will have access to Your data/information?

We may disclose Your data/information including personal data/information to fulfil Our purposes to:

Atradius’s group companies, branches, affiliates, business partners and service providers.

2. Marketing

2.1. What data/information do We collect for marketing purposes?

In the context of Our marketing activities, We may process the below data/information about You:

Contact details such as Your name, title, phone number, email, (work) address, contact history;
Information for which You have provided Your consent to use Your personal data/information for marketing purposes, e.g. in the form of subscriptions to any promotional materials such as newsletters, email updates, business publications, survey reports, and white papers;
Information on Your interests e.g. based on Your subscriptions for Our publications for specific topics or industries;
Information regarding any of Your questions, complaints or disputes; and
Other personal data/information provided by You.

2.2. Why do We collect this data/information?

We may use Your data/information including personal data/information for the following purposes:

To get into and maintain contact with You;
To promote and inform You about the (new) Services;
To organise events and other promotional activities;
To analyse Your interests and possible business opportunities for Us;
To obtain Your views on certain matters, e.g. via (customer satisfaction) surveys; and
To deal with questions, complaints or disputes.

2.3. Legal grounds for using Your data/information

Consent
- If required, we request Your consent for processing Your personal data/information for Our marketing activities. You can withdraw Your consent at any time by clicking on the opt-out link in Our emails or by submitting a form online. If You withdraw Your consent, this will not affect the lawfulness of Our use of Your personal data/information before Your withdrawal.
Legitimate interests
- We may process Your information as necessary for achieving Our legitimate interests when performing Our marketing activities. For Our business interests We may for example gather, analyse and interpret information about Our customers in order to find new opportunities to sell and develop Services to satisfy the preferences and needs of Our customers.

2.4. Where did We obtain Your data/information?

For marketing purposes, We primarily obtain data/information concerning You from Yourself. In other instances, We may obtain Your personal data/information from the various sources displayed below:

Parties who refer Us to You, or to whom You provided consent to share Your data with Us;
Third parties engaged by Us in the context of Our marketing activities;
The internet (incl. social media) for as far as allowed under the applicable law.

2.5. Who will have access to Your personal data/information?

Atradius may disclose Your data/information including personal data/information to:

Atradius’s group companies, branches, affiliates, business partners and service providers.

3. If You are Our customer or any person who uses our Services, or any business partner or supplier

3.1. What data/information do We collect?

We may process the following data/information of Your business, which may qualify as personal data/information if it relates to a natural person (e.g. a sole trader, company director, (ultimate) beneficial owner, shareholder, beneficiary, professional contact etc.).

Personal data/information such as. Your name, title, function, phone number, email, (work) address, country, date and place of birth, ID details, entity name.
If Your company is not a legal entity, We may also process Your financial information (such as bank account details), VAT/GST number, details of the agreement with You.

3.2. Why do We collect this data/information?

We may process data/information of Your business, which may qualify as personal data/information, for the following purposes:

To execute and provide the Services in relation to the agreements. This may entail: processing transactions, communicating with You, assessing (trade) insurance risks and coverage, recovery actions, providing credit (risk) management and business intelligence services and products, conducting debt collections, providing customer support services, handling complaints and disputes;
To perform “know your counterparty”, fraud, terrorism, sanctions list checks and other compliance checks;
To optimise Our Services, conduct (market) research and statistical analyses;
To administer the Website and related servers and to manage and protect Our information technology infrastructure;
For marketing purposes: see Section 2 above for further details;
To establish, exercise or defend legal claims; and
To comply with an order of a regulatory/governmental authority or an obligation under relevant laws or regulations or (voluntary) regulatory, industry or sector codes or guidelines.

3.3. Legal grounds for using Your data/information

We process Your data/information including personal data/information only if this is allowed under one of the legal processing grounds. We rely on one or more the following legal grounds for the processing of Your data/information:

Legitimate interests
We may process Your data/information including personal data/information as necessary for achieving Our legitimate interests, when performing Our business activities.
- Offering and developing credit management services, surety, and debt collections products and services, as well as business intelligence services, which aim to help companies around the world understand and protect against the default risks associated with the selling of goods and services.
- As necessary for entering into and the performance of agreements with the company or business that You are associated with.
Performance of a contract
If You are a sole trader company, we need to process your personal data/information for entering into and the performance of agreements.
Legal obligation
We may process your personal data/information if necessary to comply with one of Our legal obligations, for instance to perform compliance checks or to comply with orders of a regulatory/ governmental authority, or follow obligations under industry or sector codes.

3.4. Where did We obtain Your data/information?

The data/information including personal data/information that Atradius India processes may originate from various sources:

Directly from You or the company You are associated with, including those representing or authorised by You or such company;
From Atradius companies, branches, affiliates or business partners;
From (publicly) available sources; and
From information/data vendors.

3.5. Who may have access to Your data/information?

We may disclose Your data/information including personal data/information to fulfil Our purposes to:

Parties authorised by You or the company You are associated with;
Atradius’s group companies, branches, affiliates;
Third parties such as crime or fraud detection and prevention agencies, reinsurers, other insurers, banks, business partners, auditors, lawyers, debt collectors and other service providers;
Advisers or other professional parties, to establish exercise or defend legal claims or to protect Our business operations or legal rights;
Law enforcement agencies, regulatory/governmental authorities: when required by law, or as necessary to protect Our rights; and

4. If You or Your company trade with Our customers (a “buyer”, “debtor” or “beneficiary”)

4.1. What data/information do We collect?

We may process the following data/information of Your business, which may qualify as personal data/information, in so far as it relates to data/information relating to a natural person(e.g. a sole trader, company director, (ultimate) beneficial owner, shareholder, professional contact etc.).

Personal data/information such asYour name, title, function, phone number, email, (work) address, country, date and place of birth, ID details, entity name;
If Your company is not a legal entity, We may also process financial information (such as bank account details), trade registration, VAT/GST number, , insolvency status, sources of wealth.

4.2. Why do We collect this data/information?

We may process data/information on Your business, which may qualify as personal data, for the following purposes:

To execute and provide the Services in relation to the agreements We have with Our customers. For example: processing transactions, communicating with You, reviewing (trade) insurance risks and coverage, recovery actions, providing credit (risk) management and business intelligence services and products, conducting debt collections, handling complaints and disputes;
To perform fraud, money laundering, terrorism and sanctions list checks and other compliance checks.
To optimise Our Services, conduct (market) research and statistical analyses.
To administer the Website and related servers and to manage and protect Our information technology infrastructure.
To establish, exercise or defend legal claims.
To comply with an order of a regulatory/governmental authority, or an obligation under relevant laws or regulations or (voluntary) regulatory, industry or sector codes or guidelines.

4.3. Legal grounds for using Your data/information

Legitimate interests
We may process Your personal data/information as necessary for achieving Our legitimate interests, when performing Our business activities.
- Offering and developing credit management services, surety and debt collections products as well as credit (risk) management, business intelligence services, which aim to help companies around the world understand and protect against the default risks associated with the selling of goods and services;
- As necessary for entering into and the performance of agreements with Our customers;
- To establish, exercise or defend legal claims;
Legal obligation
We may process Your data/information including personal data/information to comply with Our legal obligations, for instance to perform compliance checks or to comply with orders of a regulatory/governmental authority, or follow obligations under industry or sector codes.

4.4. Where did We obtain Your data/information?

The data/information including personal data/information that We process may originate from various sources:

Directly from Our customers or from You, including those representing the customer or You;
From Atradius’s group companies, branches, affiliates or business partners;
From (publicly) available sources; and
From information/data vendors.

4.5. Who may have access to Your data/information?

We may disclose personal data/information to fulfil Our purposes to:

Our customers and parties authorised by the customer (such as intermediaries, representatives, companies belonging to the customer’s group);
Atradius’s group companies, branches, affiliates;
Third parties such as crime or fraud detection and prevention agencies, reinsurers, other insurers, banks, business partners, auditors, lawyers, debt collections and other service providers;
Advisers or other professional parties, to establish exercise or defend legal claims or to protect Our business operations or legal rights: and
Law enforcement agencies, regulatory/governmental authorities: when required by law, or as necessary to protect Our rights.

5. How do We transfer Your personal data/information outside India?

The processing of Your personal data/information may entail the transfer of Your personal data/information to group entities of Atradius or to selected third parties. The group entities of Atradius or selected third parties may be located outside India. We ensure that transfer of personal data to a third party or abroad, happens only in compliance with the provisions of the applicable law.

We have taken the appropriate safeguards to ensure that any personal data/information including sensitive personal data/information transferred to a third party or abroad by Atradius India or any person on Our behalf maintains the same level of data protection that is adhered to by Atradius India. However, We cannot guarantee absolute security of Your personal data/information and shall not be liable for any breach of security by an outside third party.

6. How do We protect Your data/information?

We are committed to ensuring that Your data/information including personal data/information is kept secure. In order to prevent unauthorised access, modification, destruction, or disclosure, We have put in place reasonable security practices and procedures to include, physical, technical, operational, managerial and organisational measures that are commensurate with information assets and with the nature of business.

You are responsible for maintaining confidentiality and security of Your username and password and may not disclose these credentials to any third party

7. How long do We retain Your data/information?

We generally shall retain any personal data/information including sensitive personal data/information only: (i) for the period required to serve the applicable business purpose; (ii) to the extent reasonably necessary to comply with any applicable legal requirements; or (iii) as advisable in light of an applicable statute of limitations. Atradius may specify (e.g., in, notice or records retention schedule) a time period for which certain categories of personal data/information will be kept.

However, We may continue to store Your personal information in anonymised form and non-personally identifiable format for analytical and research purposes.

8. How can you contact Us to amend or delete Your data/information?

All information including personal information provided to Atradius India by You is voluntary.
Atradius India shall not be responsible in any manner for the authenticity of any information supplied by You. We may, at Our sole discretion, discontinue the Services to You, if You provide, or if We have reasonable grounds to suspect, that any personal information provided including any sensitive personal information is inaccurate, untrue, out of date or incomplete.
As a data subject/provider of information, You have certain rights concerning Our processing of Your personal data. You can:
- request access to Your personal data held by Us;
- ask Us to modify, rectify or delete Your information if You believe that Your personal data/information is inaccurate or incomplete;
- withdraw consent for certain personal data/information;
- ask Us to restrict or object the processing of Your personal data/information.
If You update Your information, Atradius India may keep a copy of the older information in its archives;
If You choose to withdraw consent, Atradius India reserves the right not to provide the Services or to withdraw the Services for which the information was sought/collected from You. However, please note that any withdrawal of Your consent shall not be treated on a retrospective basis.

9. Age of Consent

By using the Website, You represent that You are at least the age of majority in Your jurisdiction and You have given Us Your consent to allow any of Your minor dependents to use this site.

We do not knowingly collect any personal information from children, without verifiable consent of their legal representatives.

10. Third Party Links

On the Website, if permitted by applicable law, certain links to third party websites may be provided which are operated by the third partiesand are not controlled by, or affiliated to, or associated with Atradius India unless expressly specified on the Website. If You access any such links, We request You to review the third party’s privacy policy.

We are not responsible for the policies or practices of such third-party links and accordingly We do not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor do We guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, messages or other materials available on such websites.

11. Payment information

All payment transactions happen using secure server software through third party payment gateways engaged by either Atradius India directly or by other third parties. Atradius India does not have end-to-end control over such transactions and shall in no way be responsible or liable for any loss or damage due to any disclosure of Your payment related information.

Atradius India hereby disclaims all its liability and shall in no way be liable or responsible for any loss or damage caused to You on account of intentional or unintentional disclosure of any personal data/information concerning Your account and/or any data/information with respect to any online payment transaction handled by third party payment gateways using the credit card/debit card/cash card/net-banking/mobile wallet/UPI etc, and/or the payment verification process.

12. Governing Law and Disputes Resolution

This Privacy Statement shall be governed by the laws of India. Any and all disputes arising under or in relation to this Privacy Statement shall be subject to the exclusive jurisdiction of courts in 30 July 2023.

13. Grievance Officer

For any queries related to this Privacy Statement, correction or modification or deletion of any personal data/information provided by You or for making a complaint about breach of privacy, please contact Our Grievance Officer on the following details and We will handle your request carefully and in line with the applicable data protection laws:

Name: Nazim Tamboli
Email: dpo@atradius.com

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