Data Privacy Policy

Objective

The objective of this policy is to provide a framework for Supreme Audiotronics for notice, consent, collection, usage, disclosure, storage, and disposal of personal information of a natural person acquired for business purpose (s). The policy also outlines the responsibilities of the Data Protection Officer (DPO) regarding the handling of personal data in the possession of Supreme Audiotronics.

Scope

The scope of this policy is India.

Applicability

This policy is applicable to all workforce members of Supreme Audiotronics including business partners, and vendors. This policy is also applicable to all persons who collect, store, and process the data of a natural person on behalf of Supreme Audiotronics.

Definitions

Personal data - Personal data refers to any information that relates to an identified or identifiable individual. It includes details that can directly identify a person (such as a name, identification number, or contact information) or information that, when combined with other data, can indirectly identify an individual. It also includes sensitive information (such as gender, ethnicity, race, medical history etc.). Data fiduciary - The company or entity determining the purposes and means of Processing.

Policy Framework

a) Notice

§ The identity and contact details of the data fiduciary.

§ The purposes for processing the data.

§ The legal basis for processing.

§ Categories of personal data being processed.

§ Recipients of the data (if applicable).

§ Data retention periods

§ Data Principals' rights and how to exercise them.

§ The right to lodge a complaint with a supervisory authority.

b) Consent

§ Consent is a lawful basis for processing personal data. It shall be recorded.

§ In case of minor, verifiable parent/ guardian consent shall be recorded.

§ In case of physically challenged, verifiable legal guardian consent shall be recorded.

c) Collection of Information:

The information is collected for a lawful purpose connected with a function or activity of the respective Supreme Audiotronics or any person on its behalf; and the collection of sensitive personal data or information is considered necessary for that purpose. While collecting information directly from the person concerned, Supreme Audiotronics or any person/entity on its behalf shall take such steps that are, in the circumstances, reasonable to ensure that the person concerned is having the knowledge of the name and address of — (i) the entity that is collecting the information; and (ii) the entity that will retain the information.

i) Type of informaFon collected

For products and services, Supreme Audiotronics may/will collect personal information, as applicable, personal identifiable information, financial information, and health information such as name, date of birth, address, age, income, health data along with other relevant sensitive personal information.

ii) Mode of collecFon of informaFon

Supreme Audiotronics may collect information through - Online Forms and surveys, Customer Service Interactions (through phone calls, emails, chat support etc), information received from internal sources within Supreme Audiotronics, Social Media Platforms, Mobile Apps, Email Communications, Surveillance and CCTV, Biometric Data Collection, Public Records and Directories, Cookies and Tracking Technologies, Information collected offline and subsequently digitized, Employment Records, Healthcare Records, Government and Regulatory Reporting, etc. Any other mode of collection of information, along with the consent of the provider of the information.

iii) Purpose of Data CollecFon

The data processor shall collect and process personal data solely for the purposes defined by the data fiduciary. The information shall be used for such purposes connected with the functions or activities of respective Supreme Audiotronics’s business requirement (s). or to meet the legal and regulatory requirements.

d) Storage limitation:

Supreme Audiotronics or any person/entity on its behalf holding personal data or information shall not retain that information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force. The Supreme Audiotronics shall retain the data only in accordance with the terms agreed with the data provider at the time of obtaining the same and as per regulatory guidelines.

e) Purpose limitation:

Supreme Audiotronics shall utilize the collected information for the specific purposes for which it was obtained.

f) Personal data accurate and update:

Supreme Audiotronics or any person/entity on its behalf permit the providers of information, as and when requested by them, to review the information they had provided and ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible. Supreme Audiotronics shall make reasonable efforts to ensure that personal data is accurate and complete.

g) Consent withdrawals:

Supreme Audiotronics or any person on its behalf shall, prior to the collection of information including sensitive personal data or information, provide an option to the provider of the information to not to provide the data or information sought to be collected. The provider of information shall at any time while availing the services or otherwise, also have an option to withdraw its consent given earlier to Supreme Audiotronics. Such withdrawal of consent shall be sent in writing to Supreme Audiotronics. In the case of provider of information not providing or later withdrawing his consent, the Supreme Audiotronics shall have the option not to provide goods or services for which the said information was sought.

h) Disclosure of Information:

Disclosure of sensitive personal information by the Supreme Audiotronics to any third party shall require prior permission from the provider of such information, who has provided such information under lawful contract or otherwise, unless such disclosure has been agreed to in the contract between the Supreme Audiotronics and provider of information, or where the disclosure is necessary for compliance of a legal obligation. The sharing/disclosure of data shall only be in accordance with the terms agreed with the data provider at the time of obtaining the same.

i) Complying to government noFficaFons:

Information shall be shared, without obtaining prior consent from provider of information, with Government agencies mandated under the law to obtain information including sensitive personal data or information for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offenses; provided the request from Government agency is received in writing.

j) Disclosed to third party:

Any sensitive personal data on Information shall be disclosed to any third party by an order under the law for the time being in force.

k) Transfer of information:

The Supreme Audiotronics or any person on its behalf may transfer personal data or information including to any other body corporate or a person in India, or located in any other country (legitimate for data transfer), that ensures the same level of data protection that is adhered to by the Supreme Audiotronics. The transfer may be allowed only if it is necessary for the performance of the lawful contract between Supreme Audiotronics or any person on its behalf and provider of information or where such person has consented to data transfer.

l) Reasonable Security Practices and Procedures:

Supreme Audiotronics or a person on its behalf shall implement such security practices and standards and have a comprehensive documented information security program and information security policies that contain managerial, technical, operational, and physical security control measures that are commensurate with the information assets being protected with the nature of business. In the event of an information security breach, the Supreme Audiotronics or a person on its behalf shall demonstrate, as and when called upon to do so by the agency mandated under the law, that the Supreme Audiotronics or a person on its behalf has implemented security control measures as per their documented information security program and information security policies. Access to customer account(s) information is given to only those employees involved in providing the services to the customers on a ‘need to know’ basis. All Supreme Audiotronics employees are required to keep all customers’ information confidential in according to the terms of employment.

m) Non-Personal Data Collected Automatically:

When the customer accesses Supreme Audiotronics Website or mobile applications, Supreme Audiotronics may automatically (i.e., not by registration) collect non- personal data (e.g. type of Internet browser and operating system used, domain name of the website from which the customer visited the website, number of visits, average time spent on the site, pages viewed, etc.). Supreme Audiotronics may use this data and share it with its affiliates to monitor the utility and attractiveness of its websites and improve their performance or content.

n) Cookies

Information stored automatically on your computer: When a customer views Supreme Audiotronics Website, Supreme Audiotronics may store some data on customer’s computer in the form of a "cookie" to automatically recognize the computer the next time the customer visits the Supreme Audiotronics website. Cookies can help Supreme Audiotronics in many ways, for example, by allowing Supreme Audiotronics to tailor a website to better match customer interests or to store passwords to save customers the trouble of having to re enter it each time. If the customer does not wish to receive cookies, the customer may configure his/her Internet browser to erase all cookies from his/her computer's hard drive, block all cookies or to receive a warning before a cookie is stored.

o) Obligation of Provider of Information

By using any Supreme Audiotronics’s instrument for collecting data from the provider of the information or providing information through website or mobile applications provided by Supreme Audiotronics or providing information by any other means, the provider of the information acknowledges that he/she in his/her individual capacity or representing any entity / organization /firm /company understands and agrees to be bound by this Privacy Policy.

p) Jurisdiction and Applicable Law:

This Data Privacy Policy shall be governed by the laws of India.

q) Display on website:

A copy of the approved privacy policy will be displayed on the website of Supreme Audiotronics as per regulations, for ease of reference of its customers/vendors/third parties/business partners and any individual availing the services and/or products of Supreme Audiotronics.

r) Changes to this Policy:

Supreme Audiotronics reserves the right to modify this Data Privacy Policy from time to time, without any notice, in order to ensure that it accurately reflects the regulatory/statutory environment and our data collection needs. When material changes are made to this Data Privacy Policy, Supreme Audiotronics will post the revised Policy on its website.

s) Changes to the Policy

Not Applicable

t)Periodicity of Review of the Policy:

The Board will review this policy on a need basis and as may be required under the regulations/statutes that may be issued in future.