PRIVACY POLICY

This privacy policy (Privacy Policy) governs the collection, use, disclosure, transfer, retention or otherwise processing of personal data or sensitive personal data (collectively Information) by Lucro Plastecycle Private Limited (Lucro, us, we, our). This Privacy Policy shall be applicable to any person or entity (you, your) that accesses our website “www.lucro.in” (Website) or has shared any Information with us including Lucro retainers and staff. We value your privacy, and our organization is committed to safeguarding your information and ensuring its security. Rest assured that we will handle your data with utmost care and respect.

PURPOSE

This Privacy Policy is made in due compliance of the applicable provisions of the Information Technology Act, 2000, Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and other applicable laws. This Privacy Policy applies to current and former visitors to our website and sets out how we collect, use, disclose and protect your information in relation to this website and/or through offline documentation, either directly or indirectly through a third party acting on our behalf.

ACCEPTANCE OF PRIVACY POLICY

a. Any access or use of this website and/or the Services by you shall be deemed to be an express and unconditional acceptance by you of this Privacy Policy and this Privacy Policy shall be legally binding on you. By accessing or using this website, you are providing us with your consent for use, retention, collection, transfer and disclosure of Information in accordance with the terms of this Privacy Policy.

b. Lucro is entitled to retain all Information in its sole discretion for such length of time that it may deem fit, based on its requirement to serve the purpose for which the Information has been furnished.

c. Lucro has the right to update this Privacy Policy from time to time, without any prior notice. Any update made to this Privacy Policy shall become effective immediately upon it being published on this website.

THE INFORMATION THAT WE COLLECT

We collect your Information when you access our website or communicate with us through email or other digital channels. This information may include personal information as defined under applicable Indian data protection laws. The Information we collect includes, but is not restricted to, the following:

  • Name, qualifications, an identification number for our personnel, work and home contact details (email address, phone numbers, physical address), language(s) spoken, gender, date of birth, Voter ID, passport number, PAN Card, marital status, dependents, emergency contact information, photograph, biometric information, medical records, and history, information relating to your physical, physiological or mental health, and passwords.
  • Financial details: You may be required to provide us with financial information such as details of bank accounts.
  • Career management information, designation, contractual information, system and application access data, and device-related information.
  • Performance-related information: letters of application, resume / CV, or other provided documents, performance, and development reviews.
  • Data collected while using the Website or any mobile applications, including data collected automatically such as device ID, IP Address, web browser type, page views, operating system, timing and frequency of use of the Website or application, application/website navigation.
  • Any other Information that is collected pursuant to our contractual relations with service providers or clients while providing services or during onboarding.
  • Aadhaar information: You may provide your Aadhaar details for identification purposes. Please note that it is not mandatory for you to do so, and you may give other identification documents such as a PAN card, passport, or driving license. However, we may require Aadhaar information from you to comply with the requirements of applicable law. We shall inform you when such collection is mandatory.

We limit the data collected to what is strictly necessary to complete the purposes provided below.

We may also collect “special categories of personal data” for specific purpose with your explicit consent.

Special Categories of Personal Data may mean and include personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, financial data, biometric data, data concerning health, or data concerning a natural person's sex life or sexual orientation, personal data relating to offences, criminal proceedings and convictions, or personal data relating to a child or persons with disabilities.

Processing personal data of a child or person with disability with special care:

We do not intend to directly collect personal data from children below the age of (18). If we identify that we have unintentionally collected personal data from a child below the age of 18, we will remove that child's personal data from our records as soon as practical.

USES OF INFORMATION

We may use your data in manners including but not limited to:

Support:

  • For consumer service purposes including responding to your enquiries, examples include, order status, product support, product question/ complaint, and general feedback.
  • For product and service personalization based on your based interaction with us.

Events, campaigns and other marketing promotions:

  • To invite participation in competitions, contests, sweepstakes and communicate products promotions from Lucro.
  • To communicate information to you and to manage your subscription to our newsletter(s) or other promotional communications.
  • To reach out to you about offerings from Lucro.
  • To improve our future offerings, including products and services.
  • To track products, you buy when you click on one of our display adverts and go on to purchase something from a selection of our retail partners.
  • To understand your likes and dislikes to tailor our web content, products, and offerings.
  • Complying with legal requirements
  • Monitoring your use of our systems

Research & Other purposes:

  • To understand your impression about our products before they are launched.
  • For internal training and quality assurance purposes.

Consented Data from Third Parties:

  • We may also use personal data you have provided to selected third-parties and consented to be shared, like your age, gender, life stage, lifestyle and wider interests to identify people who we think will have similar interests to you and who we believe will be interested in similar advertising.
PERSONAL DATA SHARING AND DISCLOSURE FOR IDENTIFIED PURPOSE:

Within Lucro, we may share your personal data with our Brands for business and operational purposes and with third parties under the following circumstances:

Third Parties:

  • Third Party Service Providers help us run our business processes, for examples include, website hosting, research companies, support services, website development, etc.
  • Other Third Parties include advertisers, advertising networks, advertising servers, social media networks, and analytics companies or other third-parties in connection with marketing, promotional and other offers, as well as product information.
  • Third Party Service Providers are only allowed to process your personal data on our behalf for the specific purposes that they have been onboarded to perform.
  • Third Party Service Providers are required to protect and securely process any personal data shared by Lucro.

Business Transfers:

  • As Lucro continues to develop the business, it may sell or purchase assets, subsidiaries or business units. In such transactions, your personal data generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless you consent otherwise). If another entity acquires us, our businesses or substantially all or part of our assets, or assets related to websites, your personal data will be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets.

Legal purposes: We may disclose your personal data to comply with a legal obligation.

Regulatory requirement: We will share your personal data with local regulatory bodies for the purpose of investigation or compliance as and when requested.

SECURITY SAFEGUARDS FOR STORING PERSONAL DATA WITHIN OUR ECOSYSTEM:

We use technical and organizational measures to safeguard your personal data. We take every effort to protect your personal data from misuse, interference, loss, unauthorized access, modification, or disclosure.

We have implemented appropriate security safeguards to deal with any suspected personal data or security breach.

If you suspect any misuse or loss or unauthorized access to your personal data, please let us know immediately by contacting our grievance officer (details listed below).

LINKS TO THIRD PARTY SITE/ APPS

Our website may, from time to time, contain links to and from other websites or applications of third parties. Please note that if you follow a link to any of these websites or applications, such websites or application will apply different terms to the collection and privacy of your personal data, and we do not accept any responsibility or liability for these policies. When you leave our Site, we encourage you to read the privacy policy of every Website or application you visit.

RETAINING YOUR RECORDS:

We retain your personal data for as long as necessary to achieve our business purpose(s) specified in this privacy notice and to provide you access to and use of our website, your account(s) on our platform(s), or for other essential purposes such as complying with our legal obligations, resolving disputes, enforcing our agreements and as long as processing and retaining your data is necessary.

  • Even if we delete your personal data, including on account of exercise of your right to erasure, it may be stored within our backups or on archival media for the purpose of audit, legal, tax or regulatory purposes only.
  • The criteria used to determine our retention periods include:
  • The length of time we provide the services to you (for example, for as long as you have an account with us or keep using the services);
  • The length of time we have an ongoing relationship with you;
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); and
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, government investigations or regulatory considerations).
HONORING YOUR PRIVACY RIGHTS:

You have various rights in relation to your personal data that we hold about you. To get in touch with us about any of your rights under the Digital Personal Data Protection (DPDP) Act 2023, please reach out to our grievance officer. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

  • Right to access: Upon request, the following data about you shall be provided by us:
  • a summary of personal data which is being processed by us and the processing activities undertaken performed for such personal data;
  • details of all data processors with whom the personal data has been shared along with a detail of the personal data shared.
  • Right to correction and update: You may request correction of personal data where it is identified that your personal data records are inaccurate, misleading, incomplete or requires update.
  • Right to erasure: You may request for erasure of your personal data stored with us. Upon receipt of such a request, the personal data shall be erased from our system(s) unless retention of this data is necessary for any of the purpose(s) specified in this notice or for compliance with any law for the time being in force.
  • Right to grievance redressal: You may raise a grievance with us regarding the performance of our obligation in relation to your personal data or regarding the exercise of your rights pertaining to Data privacy. If your grievance is not addressed, you may further reach out to the Data Protection Board.
  • Right to nominate: You may exercise your right to nominate an individual who shall exercise data privacy rights on your behalf in the event of your death or incapacity. Incapacity here refers to the inability to exercise rights due to unsoundness of mind or infirmity of body.
  • Right to withdrawal of consent: Where we have obtained your consent to process your personal data for certain purposes, you may withdraw this consent at any time, and we will cease to carry out the activity that you previously consented to unless we consider that there is an alternative and strong compelling legal basis to justify our continued processing of your personal data for this purpose.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during the period for which we hold it.

NO WARRANTIES

By accessing, using, or relying on the Website, the User agrees that Lucro is not liable in tort, contract or otherwise for any direct, indirect, consequential, incidental or special damages accrued to the User due to access or use of the Website or the Content contained therein.

No material may be modified, edited or taken out of context such that its use creates a false or misleading statement or impression as to the position, statements or actions of Lucro.

Lucro does not represent or warrant that the Website will be available or will meet the User’s requirements, that access will be uninterrupted, that there will be no delays, failures, errors or omissions or loss of transmitted information, that no viruses or other contaminating or destructive properties will be transmitted or that no damage will occur to User’s computer system. The User has the sole responsibility for adequate protection and backup of data and/or equipment and to take reasonable and appropriate precautions to scan for computer viruses or other destructive properties.

NO LIABILITIES

Lucro is not responsible for and will not be liable to the User or anyone else for any damages or other amounts whatsoever (including but not limited to direct, indirect, incidental, special, consequential, exemplary or punitive damages) arising out of or in connection with User’s use of or inability to use the Website or the information contained therein, or any action or decision made by User in reliance on the Website or the information contained therein, or any unauthorized use or reproduction of the Website or the information therein, even if Lucro has been advised of the possibility of these damages.

The User understands that the Website is used by them solely at their own risk, cost and liability.

TERMINATION OF ACCESS

The User agrees that Lucro with or without any reason may immediately terminate their access to the Website without prior notice. Without limiting the foregoing, Lucro may terminate or temporarily suspend the User’s access to the Website if they (i) breaches or violates these Terms; (ii) there is a request by law enforcement or other government agencies; or (iii) in case of unexpected technical issues or problems.

Users agree that all terminations of access to the Website shall be made at the sole discretion of Lucro and that Lucro shall not be liable in any manner whatsoever to either him/ her or any third party for any termination of access to this Website.

JURISDICTION

Lucro controls and maintains this Website from India. Lucro makes no representations that the information and material contained in this Website are appropriate or permitted for use in jurisdictions outside India.

The Terms of Use are governed by the laws of India without giving effect to any principles of conflicts of laws.

The usage of the Website by the User is subject to the exclusive jurisdiction of the courts located in Mumbai, Maharashtra without prejudice to the right of Lucro to take action in any jurisdiction whatsoever.

INVESTIGATIONS

Lucro reserves the right to investigate complaints or reported violations of these Terms of Use and to take any action we deem necessary and appropriate. Such action may include but is not limited to reporting any suspected unlawful activity to law enforcement officials, regulators, or other third parties. In addition, we may take action to disclose any information necessary or appropriate to such persons or entities relating to the User’s profiles, e-mail addresses, usage history, IP addresses and traffic information.

LEGAL REMEDIES

Lucro reserves the right to seek all remedies available at law and in equity for violations of these Terms of Use by the User.

AVAILABLE TO ADDRESS YOUR PRIVACY QUERIES:

For any query or grievance with respect to this privacy statement or to exercise your privacy rights, you can reach out to our grievance officer. Details of the Grievance officer are:

Grievance Officer Name: Mr. Varun Karasia

Email address: varunkarasia@lucro.in

from: 10 AM to 6 PM from Monday to Friday except Public, National & Festival Holidays

KEEP YOUR EYE OUT FOR CHANGES TO OUR PRIVACY NOTICE:

We may change this privacy statement from time to time. If we make any changes to this policy, we will change the "last updated date" below. You agree that your continued use of our platform after such changes have been published will constitute your acceptance of such revised policy. We will notify you and seek additional consent before using your personal data for a new purpose that is inconsistent with the original purpose for which we collected it.

Last update date: 10 March, 2025