Tata Sons Private Limited

Privacy Statement for Tata Sons' Social Media Platforms

Your privacy is important to us. Tata Sons Private Limited (“Tata Sons” or “we”) takes the privacy of your information seriously. This privacy statement describes how we treat personal information on our social media platforms (such as Twitter, Facebook, Instagram, LinkedIn YouTube, et al) (collectively, with blogs, the “Platforms”). 

Definitions

 1. In this privacy policy, the following definitions are used

Data

includes information that you submit to Tata Sons via the Platforms, and information which is accessed by Tata Sons when you follow Tata Sons on Platforms. 

Data Protection Laws

Data Protection Laws any applicable law relating to the processing of personal Data, including the GDPR and the Information Technology Act, 2000, as amended or substituted;

GDPR   

the General Data Protection Regulation (EU) 2016/679;

Tata Sons or us 

Tata Sons Private Limited, a company incorporated in India whose registered office is at Bombay House, 24 Homi Mody Street, Mumbai, India, 400001;

User or you        

the natural person who shares the Platforms

2. Scope

We host contests on the Platforms and collect data of users who use such Platforms.

You may also provide personal data directly when we ask you for your details via ‘Direct Message’ on the Platforms.

Data Collected

 3. We may collect information or pieces of information that could allow you to be identified, including:

 a. Contact information: We collect first and last name, email address, postal address, phone number, and other similar contact data (for instance, via ‘Direct Messaging’);

 b. A copy of a state-issued identity card (for instance, via ‘Direct Messaging’).

 c. Other information that we can collate from the Platform, such as from your social media account, corporate websites, news websites, forums, blogs and complaint sites

 4. How we Collect Data

We collect Data in the following ways:

 a. data is given to us by you on the Platform;

 b. data that is publicly available on your social media profile when you follow Tata Sons on the Platforms; and

 c. data that is publicly available on news websites, forums, blogs and complaint sites when you make a post about Tata Sons.

 5. Data shared by You

Tata Sons may collect your Data in several ways from your use of the Platforms.  For instance:

 a. when you contact us (through any form, e-mail, direct messaging on any Platform);

 b. when you enter a competition or promotion through a Platform;

 c. when you follow us on any Platform (data which is publicly available on your profile such as username, gender, location, age, follower count. etc.)

 d. from the information gathered when you visit our Platforms;

 e. information provided by you (such as submission of details after winning contests and quizzes, information provided by over direct messaging, etc) on our Platforms.

 6. Data that is Collected Automatically

We automatically collect some information which is publicly available on your profile) such as username, gender, location, age, your follower count, et al) on our Platforms.

 7. Our Use of Data

Any or all the above Data may be required by us from time to time. Specifically, Data may be used by us for the following reasons:

 a. to dispatch vouchers, gifts or tokens for winning social media contests;

 b. transmission by email or any other form of communication of marketing materials to you;

 c. contact for survey or feedback which may be done using email or mail;

 d. to enable our group entities to reach out to you in relation to their programmes managed by them / products or services offered by them;

 e. to process your requests (such as replying to your queries); and

 f. to execute other activities such as marketing campaign, promotional communications for which consent is taken appropriately.

We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).

 8. Who we share Data with

We may share your personal Data with:

 a. Tata Sons-controlled affiliates and subsidiaries and other entities within the Tata group of companies, to assist them to reach out to you in relation to their programs or campaigns (including marketing and sales) and to process your query / requests (such as details about winning a prize, etc.);

 b. our employees, vendors, agents and professional advisors working on our behalf for the purposes described in this policy statement; and

 c. service-providers who assist in protecting and securing our systems and provide services to us which require the processing of personal data, such as to process your information for data profiling and user analysis of followers.

We usually do not share other personal Data collected from you through the Platforms with other third parties.  However, this may happen if:

(a)    You request or authorize us to do so; or

(b)    We need to comply with applicable law or respond to valid legal process.

 9. Keeping Data secure

We will use technical and organisational measures to safeguard your Data and we store your Data on secure systems.

Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us by writing to us at groupsocialmedia@tata.com.

 10. Retention of Personal Data

Tata Sons typically purges data relating to your identity cards. Other details are retained for as long as necessary to for essential purposes such as ensuring contest winners are not repeated, complying with our legal obligations, etc. Because these needs can vary for different data types and purposes, actual retention periods can vary significantly.

 11. Your Rights

When we process Data about you, we do so with your consent and/or as necessary to provide the required service (gifts, tokens, etc.), or fulfil other legitimate interests of Tata Sons as described in this privacy statement.

Below, you will find additional privacy information that you may find important. Tata Sons adheres to applicable data protection laws (including laws in the European Economic Area), which if applicable includes the following rights in relation to your Data:

 a. Right to access - the right to request

(i)                 copies of the information we hold about you at any time, or

(ii)               that we modify, update or delete such information.

If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is manifestly unfounded or excessive. Where we are legally permitted to do so, we may refuse your request.  If we refuse your request, we will tell you the reasons why.

 b. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.

 c. Right to erase - the right to request that we delete or remove your Data from our systems.

 d. Right to restrict our use of your Data - the right to limit the way in which we can use it.

 e. Right to data portability - the right to request that we move, copy or transfer your Data.

 f. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it. You can contact us at groupsocialmedia@tata.com for any queries on your data.

 12. Security of Personal Data

Tata Sons is committed to protecting the security of your Data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure.

 13. Where We Store and Process Personal Data

In general, personal Data collected and processed under this statement is on systems in India.  We take steps to ensure that the Data we collect under this privacy statement is processed according to the provisions of this statement and the requirements of applicable law wherever the data is located.

To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with. This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.

General

 14. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

Changes to this Privacy Statement

Tata Sons reserves the right to change this privacy statement as it may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on this link and you are deemed to have accepted the terms of the privacy statement when you share your data with us on the Platforms.

You may contact Tata Sons social media team at groupsocialmedia@tata.com