Website Privacy Policy

1. Scope and Applicability

This Privacy Policy applies to individuals who interact with our Services, including visitors and users ("you" or "your"). It does not apply to our employees, interns, or contractors, whose data is covered under a separate Employee Privacy Notice.

In instances where a privacy notice is not provided at any specific stage of the process, the privacy policy available on our website shall be deemed applicable and shall govern the collection, use, and processing of personal data. Users are encouraged to review the privacy policy on our website frequently.

2. Which categories of personal data do we collect and how do we process such personal data?

The Personal Data relating to you which we may collect, use, transfer, disclose or otherwise process, includes:

The above-mentioned list include examples and is not exhaustive.

3. Which legal basis do we use your personal data?

Your Personal data is collected and processed by HL MSI based on the following legal grounds depending upon the nature of Personal Data and the purposes for which it is processed:

Consent

By using our website or engaging with our services, we obtain your free and informed consent for the collection, use, and processing of your Personal Data as outlined in this Privacy Policy.

Where processing is based on consent, you have the right to withdraw consent at any time through the mechanisms provided in this Policy. However, withdrawal of consent shall not affect the lawfulness of processing carried out prior to such withdrawal.

For certain data processing activities (such as processing of children’s data, where applicable), parents’ consent will be obtained separately at the point of data collection if any data of children be collected, in compliance with the Digital Personal Data Protection Act, 2023.

If we process your Personal Data based on other lawful grounds, like that of legitimate interest, legal obligations, or statutory requirements, such processing shall continue as permitted under the applicable law.

4. Disclosure of personal data

HL MSI does not sell or rent your Personal Data. However, we may share your data with trusted third parties in the following circumstances:

I. Service Providers & Business Partners

We may share your Personal Data with third-party vendors, contractors, or service providers who assist us in delivering our services, such as:

1. IT infrastructure, analytics, and security providers
2. Cloud storage and data hosting providers.

II. Legal & Regulatory Compliance

We may disclose your Personal Data if required to:

1. Comply with applicable laws, regulations, or legal processes (including government and law enforcement requests)
2. Respond to court orders, notices, or regulatory authorities
3. Protect our legal rights, privacy, safety, or property (including fraud prevention and cybersecurity measures)

III. Business Transactions

In the event of a merger, acquisition, restructuring, or sale of assets, your Personal Data may be transferred as part of the business transaction, subject to appropriate privacy safeguards.

IV. Fraud Prevention & Security

We may share Personal Data with government agencies, financial institutions, or fraud prevention organizations to:

1. Detect, investigate, and prevent fraud, cyber threats, or security breaches
2. Ensure compliance with anti-money laundering (AML) and other regulatory requirements

V. International Data Transfers

If we transfer your Personal Data outside India, we ensure that such transfers comply with applicable laws and are subject to adequate safeguards, such as:

1. Contractual Clauses wherever applicable with the recipient ensuring data protection
2. Government-approved mechanisms for secure international data transfers
3. Transfers to jurisdictions not explicitly restricted by the Government of India

5. Accuracy of Personal Data

1. You are responsible for ensuring that the Personal Data you provide to HL MSI is accurate, complete, and up to date.
2. HL MSI takes reasonable steps to verify and maintain the accuracy of your personal data. To ensure the information we hold is current and accurate, we may periodically request updates where necessary. However, it is your responsibility to promptly inform us of any changes to your personal data, including contact details or preferences. This collaborative effort helps us provide you with uninterrupted services and remain compliant with the Digital Personal Data Protection Act, 2023.
3. If you believe any personal data we hold is inaccurate or incomplete, you may exercise your right to request corrections as outlined in the Grievance Redressal Mechanism section of this Privacy Policy.

6. Security measures

1. We implement appropriate technical, organizational, and security measures to protect your Personal Data from unauthorized access, loss, misuse, disclosure, or alteration.
2. While we take reasonable steps to protect your data, no system is completely secure. In case of any data breach affecting your Personal Data, we will notify you in compliance with applicable laws.
3. In case you as a user detect or suspect any breach of your data you can inform us by reaching out to go.dpdp@hlcompany.com.

7. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance user experience and analyse website traffic.

You can manage cookie preferences through your browser settings or our Cookie Preference Centre.

For more details, refer to our Cookie Policy.

8. Retention of Personal Data

HL MSI will retain your personal data in accordance with its Data Retention Policy and as required under applicable laws. We will only store your personal data for as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required for compliance with legal, tax, regulatory, or contractual obligations.

9. Data Principal Rights and Duties

Under the Digital Personal Data Protection Act, 2023 (DPDPA), you, as a Data Principal, have the following rights concerning your Personal Data:

i. Your Rights

1. Right to Access: You have the right to request a summary of the personal data that HL MSI holds about you.
2. Right to Correction and Erasure: You may request correction, completion, or erasure of your personal data if it is inaccurate or no longer necessary for processing.
3. Right to Grievance Redressal: If you believe your personal data is processed unlawfully or in violation of this Privacy Policy, you may file a grievance with HL MSI’s DPO/Grievance Officer. If unsatisfied with the resolution, you may escalate the matter to the Data Protection Board (DPB).
4. Right to Nominate: You have the right to nominate an individual who can exercise your rights under the Act in the event of your death or incapacity.
5. Right to Withdraw Consent: Where data processing is based on consent, you may withdraw your consent at any time. However, withdrawal will not affect the lawfulness of processing conducted before withdrawal.
6. Right to Be Informed: You have the right to receive clear, concise, and transparent information about how your personal data is collected and processed.

ii. Your Duties

As a Data Principal, you also have certain duties under the DPDPA, 2023:

• Provide accurate information: Ensure that any personal data you provide to HL MSI is accurate and up to date.
• Refrain from filing false or frivolous complaints: Misuse of rights under this Act may attract penalties as per applicable law.
• Comply with lawful processing: You must not attempt to access or modify personal data that you are not authorized to process.

iii. Method to Exercise Your Rights

To exercise any of your rights under this Privacy Policy, please submit a Data Principal Request to our DPO/Grievance Officer at go.dpdp@hlcompany.com. We will process your request and respond to you within 60 days from the date of receiving such request, in accordance with the applicable legal requirements.

10. Grievance Redressal Mechanism

If you have any concerns regarding the processing of your personal data, you can file a complaint with HL MSI’s Grievance Officer.

Escalation to the Data Protection Board (DPB)

If you are not satisfied with the resolution provided by the Grievance Officer, you have the right to escalate the matter to the Data Protection Board (DPB) of India, which is the regulatory authority established under the DPDPA, 2023 for handling data protection disputes and violations.

For more details on the DPB and how to escalate your complaint, please refer to the official government portal.

11. Updates to this Policy

HL MSI may update this Privacy Policy periodically to reflect changes in legal, regulatory, or operational requirements. We will notify you of any significant changes through appropriate means, such as updates on our website.

The latest version of this Privacy Policy will always be available at Website.