PRIVACY NOTICE

1. Introduction

Polycab India Limited, together with its group entities (“Polycab”, “we”, “us”, or “our”), is a market leader in wire and cable manufacturing in India and a fast-growing player in the FMEG (Fans, Lighting, Water Heaters, Switches and Accessories, Switchgears) and Industries (Cables, Renewables, EPC) segments. We value your trust and are committed to protecting your Personal Data in accordance with the Digital Personal Data Protection Act, 2023 (“DPDP Act”), the rules made thereunder, and other applicable data protection laws of India.

This Privacy Notice (“Notice”) explains how we, as a Data Fiduciary, collect, use, store, disclose, and protect the Personal Data of individuals (“Data Principals”, “you”, or “your”) who visit our website www.polycab.com, use our mobile application(s), book a home visit or Polycab Home Advisor consultation, purchase our products through dealers/retailers/e-commerce, interact with our customer care or WhatsApp channels, apply for employment with us, or otherwise engage with our products and services (collectively, the “Platforms”).

By accessing or using our Platforms, or by providing your Personal Data to us, you acknowledge that you have read and understood this Notice. Where we rely on your consent as the legal basis for processing, we will separately seek such consent through a clear affirmative action before or at the time of collection, as required under the DPDP Act.

2. Definitions

• Data Fiduciary means Polycab, who alone or jointly with others determines the purpose and means of processing Personal Data.
• Data Principal means the individual to whom the Personal Data relates, and where such individual is a child, includes the parent or lawful guardian of such child.
• Data Processor means any person who processes Personal Data on behalf of Polycab.
• Personal Data means any data about an individual who is identifiable by or in relation to such data.
• Processing means a wholly or partly automated operation or set of operations performed on Personal Data, including collection, recording, organisation, storage, use, sharing, disclosure, erasure, or destruction.
• Board means the Data Protection Board of India established under the DPDP Act.
• “personal data breach” means any unauthorised processing of personal data or accidental disclosure, acquisition, sharing, use, alteration, destruction or loss of access to personal data, that compromises the confidentiality, integrity or availability of personal data.

3. Lawful Basis for Processing Your Personal Data

Under the DPDP Act, Polycab may process your Personal Data only where such processing is backed by a valid lawful basis. In almost all cases, this will be one of the following grounds recognised under the DPDP Act:

3.1 Consent

In most cases, we process your Personal Data on the basis of your free, specific, informed, unconditional, and unambiguous consent, given through a clear affirmative action, for a specified purpose. This applies, for example, when you register an account, book a Home Visit, or opt in to receive marketing communications. You have the right to withdraw your consent at any time, as easily as it was given, and such withdrawal will not affect the lawfulness of processing carried out before withdrawal (see Section 11).

3.2 Voluntary Provision of Data for a Specified Purpose

Where you voluntarily provide your Personal Data to us for a specified purpose, such as raising a service request, submitting a warranty claim, or applying for employment, and it is reasonably expected that we would process such data for that purpose, we may process it as a legitimate use under the DPDP Act, without seeking separate consent, provided you have not indicated that you do not consent to such use.

3.3 Compliance with Law and Government Functions

We may process your Personal Data where necessary for Polycab to comply with any law for the time being in force in India, or to comply with any judgment, decree, or order of a court or tribunal, or where required by the State or its instrumentalities to perform a function authorised by law, including for the purposes of tax, corporate, and regulatory compliance.

3.4 Medical Emergencies and Health/Safety Threats

We may process your Personal Data, without consent, where necessary to respond to a medical emergency involving a threat to your life or bodily harm, to provide medical treatment during an epidemic or outbreak of disease, or to take measures to ensure safety of, or provide assistance during, any disaster or breakdown of public order.

3.5 Employment-Related Purposes

Where applicable, we may process the Personal Data of our employees and job applicants for purposes relating to employment, including safeguarding Polycab from loss or liability, such as prevention of corporate espionage, maintenance of confidentiality of trade secrets, and provision of any service or benefit to employees.

3.6 Other Legitimate Uses

We may also process your Personal Data for other legitimate uses recognised under the DPDP Act and its rules, such as for purposes reasonably expected by you in the context of your relationship with us, always subject to the safeguards and reasonable purpose limitations prescribed under the Act.

Section 6 below sets out how these lawful bases apply to each specific purpose for which Polycab processes your Personal Data.

4. Personal Data We Collect

The categories of Personal Data we collect may vary depending on the nature of your interaction with us, including when you browse our website, register a product warranty, book a home visit, purchase products through our dealers or distributors, apply for employment opportunities, contact customer care, or otherwise engage with our products and services. The categories of Personal Data we may collect include the following:

4.1 Identity and Contact Data

Name, mobile number, email address, postal address, pincode, city, state and country. We collect this when you submit a service request, dealership request, sales enquiry, export enquiry, quote or brochure request, Home Visit booking, programme enrolment, pledge or newsletter subscription.

4.2 Professional and Business Data

Company or organisation name, business type (corporate or individual), profession or role (for example, electrician, contractor, consultant, architect, builder, engineer or developer), and the industry and project details you share with us. We collect this when you make a sales, dealership or export enquiry, take the Electrical Safety Pledge, or subscribe to investor relations updates.

4.3 Enquiry, Service Request and Grievance Data

The product category and product details you are enquiring about, and the content of your messages, complaints, feedback or service requests. This includes anything you share through our website forms, WhatsApp (+91 7304485540), our toll-free number, email or social media channels. Please do not include any Personal Data in free-text fields beyond what your request needs.

4.4 Programme and Loyalty Data

If you enrol in our electrician or retailer loyalty and experts programmes, we collect your name, mobile number and pin code, along with your programme participation, reward points and benefits history. Where we need these additional details, we will ask for them separately and tell you why at that point.

4.5 Order, Warranty and Transaction Data

Details of products purchased, invoice and order numbers, warranty registration details, dealer/retailer information, installation and service history, and Home Advisor consultation records.

4.6 Technical and Device Data

We collect the following automatically through cookies and similar technologies when you use our Platforms, as described in Section 9:

• your IP address, browser type and version, operating system, and device identifiers
• access times, referring and exit pages, and approximate location derived from your IP address
• the pages you visit, the time you spend on them, and how you navigate and interact with our Platforms

4.7 Sage and Interaction Data

Pages visited and time spent, clicks, scrolls and navigation behaviour, search queries and product views, wishlist and cart interactions, product reviews and ratings, and interactions with our chatbot or WhatsApp support.

4.8 Recruitment Data

Educational qualifications, employment history, the contents of your resume or CV, your contact details and your references, if you apply for a position with Polycab directly or through a recruitment partner.

4.9 Queries, Feedback and Grievance Data

Any information you choose to share while raising a service request, complaint, or feedback through our website, WhatsApp (+91 73044855440) -free number, email, or social media channels.

5. How We Collect Your Personal Data

5.1 Direct Interactions

You may provide Personal Data directly when you:

• Register an account on our website or app, or book a Home Visit / Home Advisor consultation.
• Purchase products directly, through an authorised dealer, or via our e-commerce partners.
• Register a product for warranty or raise a service/complaint request.
• Contact our customer care, WhatsApp support, or interact with our chatbot.
• Apply for employment or respond to a Polycab job posting.
• Participate in a survey, contest, or promotional activity.

5.2 Indirect Interactions

We may also receive your Personal Data from:

• Authorised dealers, distributors, and retail partners who facilitate your purchase.
• Payment gateway and financial service providers.
• Recruitment agencies and professional references, in connection with a job application.
• Other individuals acting on your behalf, such as a family member booking a Home Visit for you.

5.3 Automated Technologies

As you interact with our Platforms, certain technical and usage data is automatically collected through cookies, web beacons, and similar tracking technologies. Please refer to Section 8 (Cookies and Tracking Technologies) below.

6. Purposes of Processing Your Personal Data

The sections below set out the specific purposes for which we process your Personal Data and the corresponding lawful basis, as described in Section 3 above. Where we rely on consent, you have the right to withdraw it at any time, as described in Section 11.

6.1 To Provide and Fulfil Our Products and Services

To process your orders, manage warranty registrations, schedule Home Visits and Home Advisor consultations, and provide after-sales service and support. Legal basis: performance of your request and your voluntary provision of data.

6.2 To Manage Your Account

To create and administer your account on our Platforms, authenticate you, and enable self-service features such as order tracking and wishlist. Legal basis: consent and performance of your request.

6.3 To Communicate With You

To send order confirmations, warranty and service updates, respond to inquiries, and provide customer support, including through WhatsApp and our toll-free helpline. Legal basis: performance of your request.

6.4 For Marketing Communications

With your consent, to send you information about new products, offers, and promotions through email, SMS, WhatsApp, or push notifications. You may withdraw this consent at any time; this will not affect transactional communications relating to services you have already availed.

6.5 To Improve Our Products, Services and Website

To analyse usage patterns, conduct market research, and improve the functionality, design, and content of our Platforms and offerings. Legal basis: certain Legitimate Uses and Consent under the DPDP Act.

6.6 To Detect and Prevent Fraud

To verify identity, validate transactions, and detect and prevent fraudulent activity, including in connection with warranty claims. Legal basis: certain Legitimate Uses under Section 7 of the DPDP Act.

6.7 To Process Recruitment Applications

To evaluate your suitability for a position and manage the recruitment process. Legal basis: your voluntary disclosure of data and, where applicable, consent.

6.8 To Comply with Legal Obligations

To comply with applicable law, respond to lawful requests from government or regulatory authorities, enforce our terms and policies, and establish, exercise, or defend legal claims. Legal basis: compliance with law.

7. Disclosure of Your Personal Data

We do not sell your Personal Data. We may share your Personal Data in the following circumstances:

• Authorised Dealers and Service Partners: to fulfil orders, installation, and after-sales service in your area.
• Third-Party Service Providers: including payment processors, logistics and courier partners, IT and cloud hosting providers, data analytics providers, and marketing agencies, engaged to perform services on our behalf under contractual confidentiality obligations.
• Group Companies and Affiliates: for internal administration and to provide a consistent experience across Polycab entities.
• Professional and Legal Advisors: including auditors, insurers, and legal counsel, where reasonably required.
• Government and Regulatory Authorities: where required by applicable law, to comply with a legal obligation, or to protect the rights, property, or safety of Polycab, our customers, or others.
• Business Transfers: in connection with a merger, acquisition, restructuring, or sale of assets, subject to appropriate confidentiality safeguards.
• With Your Consent: for marketing purposes with third parties, where you have provided consent, which you may withdraw at any time.

8. Data Retention and Erasure

We retain your Personal Data only for as long as necessary to fulfil the purpose for which it was collected, including to satisfy any legal, accounting, warranty, or reporting requirements. Where the purpose of processing is no longer being served and retention is not required under applicable law, we will erase your Personal Data, unless retention is necessary for the establishment, exercise, or defence of a legal claim.

Where feasible, we will notify you before erasing your Personal Data on account of withdrawal of consent or the purpose of processing no longer being served, in accordance with the DPDP Act.

9. Cookies and Tracking Technologies

We use cookies, web beacons, tracking pixels, and similar technologies on our Platforms to enhance your browsing experience and understand how visitors use our website.

• Essential Cookies: necessary for the website to function properly.
• Performance and Analytics Cookies: help us understand how visitors interact with our website so we can improve it.
• Advertising Cookies: where applicable, used to deliver more relevant advertisements.

You can manage your cookie preferences through the cookie consent banner on our website or through your browser settings, including choosing to block or delete cookies. Please note that disabling certain cookies may affect the functionality of our Platforms.

10. Personal Data of Children

Our Platforms are not directed at, and we do not knowingly collect Personal Data from, individuals under the age of 18 (“children”) without verifiable consent from a parent or lawful guardian. Where we are aware that a child’s Personal Data has been collected without such consent, we will take reasonable steps to promptly delete it. Consistent with the DPDP Act, we do not undertake tracking, behavioural monitoring, or targeted advertising directed at children. If you believe a child has provided us with Personal Data without appropriate consent, please contact our Data Protection Officer using the details in Section 16.1.

11. Your Rights as a Data Principal

Under the DPDP Act, you have the following rights in relation to your Personal Data:

• Right to Access Information: to obtain a summary of the Personal Data we hold about you and the processing activities undertaken.
• Right to Correction and Updating: to request that we correct inaccurate or misleading Personal Data, complete incomplete data, and update your Personal Data.
• Right to Erasure: to request deletion of your Personal Data that is no longer necessary for the purpose for which it was collected, subject to legal retention requirements.
• Right to Withdraw Consent: to withdraw previously given consent at any time, with the withdrawal being as easy as it was to give consent. Withdrawal will not affect the lawfulness of processing carried out before withdrawal.
• Right to Grievance Redressal: to have your grievances relating to processing of your Personal Data addressed by us in a reasonable and timely manner.
• Right to Nominate: to nominate another individual to exercise your rights under the DPDP Act in the event of your death or incapacity.

You may exercise these rights by writing to our Data Protection Officer at dpo@polycab.com. We may request information to verify your identity before acting on your request. If we are unable to fulfil a request, for instance where retention is required for legal compliance or the establishment of a legal claim, we will inform you of the reasons.

If you are not satisfied with our response, you have the right to file a complaint with the Data Protection Board of India.

12. Cross-Border Transfer of Personal Data

We may store and process your Personal Data on servers located within India or, where necessary for the purposes described in this Notice (for example, cloud hosting or analytics services), in other jurisdictions, subject to the terms of the DPDP Act and any restrictions notified by the Central Government from time to time. Where your Personal Data is transferred outside India, we take appropriate contractual and technical measures to ensure it continues to be protected in accordance with this Notice.

13. Security of Your Personal Data

We implement reasonable security safeguards, including administrative, technical, and physical measures, to protect your Personal Data against unauthorised access, alteration, disclosure, loss, or destruction. These include access controls, encryption of sensitive data in transit, and regular review of our security practices. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

14. Personal Data Breach Notification

In the event of a Personal Data breach, we will take prompt remedial action and notify the Data Protection Board of India and affected Data Principals in the manner and within the timelines prescribed under the DPDP Act and its rules.

15. Third-Party Websites and Links

Our Platforms may contain links to third-party websites, including dealer portals, payment gateways, or social media pages, that are not owned or controlled by Polycab. This Notice does not apply to such third-party websites. We encourage you to review the privacy policies of any third-party site you visit.

16. Grievance Redressal and Contact Information

16.1 Data Protection Officer

Email: dpo@polycab.com

16.2 Customer Support

WhatsApp: +91 73044855440

Toll-Free: 1800-267-0008

Email: customercare@polycab.com

16.3 Registered Office

16.4 Corporate Office

16.5 Company Secretary and Compliance Officer

Ms. Manita Carmen A Gonsalves

Email: cs@polycab.com

16.6 Data Protection Board of India

If you are not satisfied with our response to your grievance, you may approach the Data Protection Board of India, established under the Digital Personal Data Protection Act, 2023.

17. Updates to this Notice

We may update this Privacy Notice periodically to reflect changes in our practices or applicable law. Any updates will be reflected by updating the Effective Date mentioned in this Notice and will become effective upon publication on our website. We encourage you to review this Notice periodically. Material changes affecting the purpose or manner of processing may be separately notified to you where required by law.