PRIVACY POLICY We, Syngenta India Private Limited (“Syngenta”, “We”, “Company”) are the owners of the mobile application named “Sumridhi” (the “App”). The App facilitates retailer engagement and provides Users with information about loyalty program and reward points. Users can scan Syngenta products through the App. The Users can also view the details of the territory manager and market development officer through the App.

We respect data privacy rights and are committed to protecting personal information collected on the App. This privacy policy (“Privacy Policy”) sets forth how we collect, use and protect the personal information collected on this App.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY CONTINUING TO USE THE APP, PROVIDING US PERSONAL INFORMATION, YOU CONSENT TO OUR USE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MAY WITHDRAW YOUR CONSENT OR ALTERNATIVELY CHOOSE NOT TO PROVIDE YOUR PERSONAL INFORMATION ON THE APP. SUCH AN INTIMATION TO WITHDRAW YOUR CONSENT CAN BE PROVIDED BY EMAIL TO COMMUNICATION DETAILS MENTIONED BELOW. 

This Privacy Policy is an electronic record in the form of an electronic contract being compliant and construed in accordance with The Indian Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 under The Information Technology Act 2000 (“Privacy Rules”) that require publishing of privacy policy for the collection, use, storage and transfer of sensitive personal data. 

1. Definition
   

“User(s)”, “you”, “your” shall include retailers of Syngenta products that use the App. 




2. Personal Data that Syngenta Collects
   

For the purposes of this Privacy Policy, “Personal Data” means information that can be used to personally identify an individual, including but not limited to the name, mobile number, email address, location details, photographs, gender details, GST numbers, shop and establishment license details and other license details as applicable. 

1. Personal Data collected through the App- In connection with your use of the App, the retailer is required to share the mobile number, one-time password (OTP) will be generated, and upon completion of the OTP verification process, the Retailer can sign in to the App. Upon sign-in the App syncs with Syngenta’s Saksham App and imports Personal Data of the retailer and details of the territory manager and market development officer as available in the Saksham App.
   
2. Location Data- The App may contain functionality that collects information about your location, such as via GPS (global positioning systems), your mobile network, or Bluetooth beacon. Company may collect and use your precise (or GPS) location information collected from the App to enhance your use of the App by providing you with sessions and meetings nearby.  Location information may be used to verify your location and deliver content based on your location.
   
3. Log Data - Company may also collect the mobile device IP address or other unique identifier ("Device Identifier") for any mobile phone, tablet, or other device (any, a "Device") used to access the App. A Device Identifier is automatically assigned to your Device, and our servers identify your Device by its Device Identifier.
   
4. Photos and Camera: Syngenta will not access your photos or camera without first getting your explicit permission. If you give us permission to access photos or your camera, Syngenta will only use images that you specifically choose to share with us. You may use the App to select the photo or photos you choose to share, but Syngenta will never import the photos you review except those you explicitly share. At any time, you can manage your Photos and Camera preferences by turning off this feature in the Device Settings of your mobile device.
   




3. Cookies
   

We use cookies and/or similar in-house and third-party tracking tools to track user traffic patterns. Tracking tools also used are beacons, tags and scripts to collect and track information and to improve and analyze our App. You may choose to disable cookies through your browser settings. For more information, please refer to our cookie policy <insert link of the cookie policy>

4. Accuracy of information
   

User undertakes that he shall be solely responsible for the accuracy, correctness, or truthfulness of the Personal Data shared with us whether of its own or any third party. In the event the User is sharing any Personal Data on behalf of a third person, the User represents and warrants that he has the necessary authority to share such Personal Information with the Company, obtained a written consent from such third party and the Company shall not be responsible for verifying the same. The User understands and acknowledges that such Personal Information shall be subject to the terms and conditions of this Privacy Policy. 




5. How Syngenta Use the Personal Data
   

Syngenta may use the Personal Data Syngenta obtains about you in connection with the App to:

• Provide you with information about the event that you are attending, including via email and push notification on your mobile device;
  
• Display content you post within the App to other users of the App;
  
• Create and manage your online account, provide our products and services, and respond to your inquiries;
  
• Communicate with you through the App, by email, or by other means;
  
• Protect against and prevent fraud; unauthorized activity; and claims and other liabilities; and manage risk exposure and franchise quality;
  
• Operate, evaluate, and improve our business (including by developing new products and services; managing our communications; determining the effectiveness of our advertising; analyzing our products, services, and websites; facilitating the functionality of our websites and mobile applications; and performing accounting, auditing, billing, reconciliation, and collection activities);
  
• Assist third parties in the provision of products or services that you request from third parties;
  
• Monitor the use of and improve our interactive assets;
  
• Perform data analyses (including anonymization of personal information) to determine, among other measurements, business performance, number of registrants, channels, and app performance;
  
• to provide you with a better experience when you access our App;
  
• Comply with applicable legal requirements and industry standards and our policies;
  
• Respond to and process inquiries, complaints, disputes; and
  
• Perform auditing, research, and analysis in order to maintain, protect, and improve our services.
  

Syngenta also may use the information in other ways for which Syngenta provides specific notice at the time of collection.

6. Personal Data Syngenta Shares
   

Syngenta does not sell or otherwise disclose Personal Data Syngenta collects about you, except as described in this Privacy Policy or otherwise disclosed to you at the time the data is collected. However, in course of providing access to the App we may share your Personal Data. Accordingly, you expressly give your free consent to us to disclose or share your Personal Information in the following cases:

1. Service Providers: Syngenta may share Personal Data with our service providers who perform services on our behalf, such as companies that develop and support the operation of the App, and send email or other electronic communications. In some instances, these service providers may collect information directly from you on our behalf. Syngenta does not authorize these service providers to use or disclose the Personal Data except as necessary to perform certain services on our behalf or comply with legal requirements. Syngenta require these service providers by contract to appropriately safeguard the privacy and security of personal data they process on our behalf.
   
2. Other App Users:  Other App users may be able to view your profile within the App (which typically will contain your name and company) on a list of attendees at the meeting. The App allows users of the App (such as conference attendees and invitees) to interact with each other. All posts you make within the App (such as posting a status update, photo, or check-in) are visible to other attendees and invitees. 
   
3. Administrative and Legal Reasons: Syngenta also may disclose data about you: (i) if Syngenta is required to do so by law or legal process, (ii) to law enforcement authorities or other government officials, or (iii) when Syngenta believes disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.
   
4. Affiliates and Business Transitions: Syngenta may transfer personal data to Syngenta affiliates for business and operational purposes. Syngenta also reserves the right to transfer personal data Syngenta has about you in the event Syngenta sells or transfers all or a portion of Syngenta’s business or assets (including in the event of a reorganization, dissolution, or liquidation). Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to Syngenta in a manner that is consistent with this Privacy Notice.
   
7. Your Rights and Choices
   

You may have certain rights under applicable law regarding the Personal Data we maintain about you. We offer you certain choices about what Personal Data we collect from you, how Syngenta uses that information, and how Syngenta communicates with you.

You can access your account by logging into your account profile in the App, where you can view your personal details. You can inform Syngenta not to send you marketing communications by e-mail by clicking on the unsubscribe link within the marketing e-mails you receive from Syngenta. Syngenta will apply your preferences going forward. In some circumstances, withdrawing your consent to our use or disclosure of your personal data may mean that you cannot take advantage of certain products or services.

Where required by law, Syngenta obtains your prior opt-in consent at the time of collection for the processing of (i) Personal Data for marketing purposes and (ii) Personal Data deemed sensitive pursuant to applicable law.

Subject to applicable law, you may have the right to request access to and receive information about the Personal Data we maintain about you, update and correct inaccuracies in your Personal Data, and have the information blocked or deleted, as appropriate. The right to access Personal Data may be limited in some circumstances by local law requirements. To update your preferences, ask us to remove your Personal Data from our mailing lists or submit an access request, please contact us as specified in these terms and conditions.




8. How Syngenta Protects Personal Data
   

   Your Personal Data is stored on public cloud infrastructure hosted namely Azure DB. Although we provide appropriate firewalls and protections, we cannot warrant the security of Personal Information transmitted as these systems are not hack proof. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible, and we will take necessary measures to mitigate such events.

   Syngenta will never ask you for your password in any unsolicited communication (including unsolicited correspondence, such as letters, phone calls, or e-mail messages). If you believe your user name and password have been compromised, please contact us by following the instructions provided in these terms and conditions.

   
   

9. Data Transfers
   

Syngenta may transfer Personal Data to countries other than the country in which the data was originally collected. These countries may not have the same data protection laws as the country in which you initially provided the information. When Syngenta transfers your Personal Data to other countries, Syngenta will protect that information as described in this Privacy Policy.




10.  Data Retention
    

We will retain User’s Personal Data as long as it is required to be retained for the purpose of your usage of the App. We may also retain and use User’s Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

11. Governing laws
    

This Privacy Policy shall in all respects be governed by and construed and enforced in accordance with the laws of Pune and the courts of Pune shall have exclusive jurisdiction to adjudicate any subject matter under this Privacy Policy.




12. Changes to this policy
    

Please revisit this page periodically to stay aware of any changes to this Privacy Policy, which we may update from time to time. If we modify this Privacy Policy, we will make it available through the App and indicate the date of the latest revision. If such modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change via email or through our App.

This Privacy Policy was last modified on 30th November 2022 




13. Contact Us
    

If you have any questions or concerns or grievances regarding this Privacy Policy, or wish to withdraw your consent in relation to the processing of your Personal Information you can reach out via email at Sumridhi.support@syngenta.com