1. About the Association

Non-Conventional Fibres Association (NCFA) (“we”, “us” or “Association”) is a non-trading corporation registered under the Bombay Non-Trading Corporations Act, 1959, aimed at harnessing the power of non-conventional fibres and has its registered office at Amrit Niwas, 1st Floor, 14 Sarojini Road, Opp. Bhoshan Bldg, Santacruz (W), Mumbai 400054. The website of NCFA and any associated platforms, portals and/or applications (“Portal”) will enable users of the Portal (“Users”) to view content on the Portal, enrol for membership and view certain information about the same.

For the purposes of this Privacy Policy (“Policy”), unless defined hereunder, all capitalized terms shall have the meaning ascribed to them under the Terms of Use available at [●] (“Terms”).

This Policy reflects our approach to collect, record, organize, structure, use, hold, store, adapt, alter, retrieve, process, align, combine, structure, index, organize, use, transfer, restrict, erase, destroy, disclose, transmit, share, disseminate or otherwise make available (collectively “process”) your personal information in accordance with the Information Technology Act, 2000 (the “Act”), the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”) and other accompanying rules and regulations, including any laws that may replace the above from time to time (collectively “Indian Data Law”).

Please read this Policy carefully before using the Portal. You may withdraw your consent by writing to us, on the contact details provided below, at any point in time. If you do not agree with the terms of this Policy, do not use the Portal. This Policy is designed to give you an understanding about:

1. General Information;
2. Nature and categories of Personal Data collected; 
3. Purposes of collection and Legal basis;
4. Sharing, disclosure and retention of personal data;
5. Security Measures and Cross-Border Transfer;
6. Your rights regarding Personal Data; and
7. General Provisions & Grievance Redressal.

2. General Information

1. By accessing or using this Portal, you confirm that you are not a minor i.e., are of 18 (eighteen) years of age or above at the time of availing the Services and are competent to contract. If you are a minor, then you are not eligible to use the Services.
2. You hereby consent to our collection, use, sharing, and disclosure of your Information as described in this Policy. We reserve the right to change, modify, add or delete portions of the terms of this Policy and/or our data handling or consent practices or procedures, at our sole discretion, at any time, and any continued use of the Portal by you, following any such amendments to the Policy, will be deemed as an implicit (or express, if consent has been obtained from you, as the case may be) acceptance of the Policy in its amended form. If you are accessing or using the Portal from an overseas location, you do so at your own risk, and shall be solely liable for compliance with any applicable local laws.

3. Nature and categories of Personal Data collected

1. We may collect and process one or more of the following information pertaining to you, based on the actions performed on the website. For instance, if you use the Portal to fill the membership or contact form, we will process additional information. However, we would like you to note that certain information of the information we collect would be required for providing you with access to the Portal, if you choose to withdraw your consent for our processing of such information, we will not be able to provide you with the same. We are also required to collect certain personal information as required under applicable laws. In case you would not like to provide your personal information, then you may not be able to avail membership services and/or access to the Portal.
   1. We wish to assure you that your Information is safe with us. We will only process your Information lawfully and for the Purposes, details of which we have provided in the below section. The following are the types of personal data pertaining to you that we may collect:
   • Full name;
   • Email Address;
   • Gender;
   • Date of Birth;
   • Country of residence;
   • Blood Group;
   • Marital Status;
   • Messages that you wish to communicate to us;
   • Permanent and Present Address;
   • Payment details and/or reference numbers;
   • Government identity details;
   • Educational Qualifications;
   • Referee details; and
   • Such other Personal Data as may be required from time to time.
2. 
   

   (collectively “Personal Data”)

3. Collection of Sensitive Data: The existing Indian Data Law defines Sensitive Personal Data or Information (“SPDI”) as including any personal data that reveals passwords, financial information such as bank account details, payment instrument details, physical, physiological or mental health condition, sexual orientation, medical records or medical history or biometric information.
4. We do not intentionally collect any SPDI from you, through the Portal. We also request you to refrain from submitting any information which may qualify as SPDI through the contact form or any other transmission system to us, except as may be required for the purpose of providing you access to the Portal and/or for you to obtain a membership.
5. We wish to share that it is possible that the Government of India may categorize some of the other types of personal information as sensitive personal data. In such cases, we will inform you of the same and obtain your consent as, and if required.

4. Purposes of processing and Legal Basis

Purposes: We may process your Personal Data for the purposes set out below and disclose your Personal Data to third parties in accordance with this Privacy Policy for the purposes outlined below.

1. To facilitate receiving of membership applications, requests and associated purposes;
2. To facilitate your access to the Portal and content therein;
3. To engage with third party service providers in relation to processing of membership requests and features on the Portal; 
4. To contact you with regard to requests for membership or access to the Portal;
5. To enable you to initiate membership requests and utilize the Portal;
6. To operate and improve the Portal in order to foster a positive user experience and to improve our business as a whole, and for related research
7. For non-targeting reasons such as frequency capping, compliance, billing, ad reporting or delivery, market research or product development purposes
8. To comply with applicable laws
9. To conduct audits and quality assessment procedures for the Portal and features therein;
10. To analyze the use of our resources, troubleshooting problems and improving the Portal and/or membership experience;
11. To analyze data, website analytics, tracking trends, building algorithms, creating databases for rating systems, recommendation engines, feedback mechanisms, etc.
12. To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms, or as otherwise required by law
13. To respond to any queries that you may have, and to communicate information to you, including notifications of any promotions or alerts, any changes/updates to the Portal or
14. To contact you, by way of SMS, email and phone calls, from time to time to record your valuable feedback on our Portal, and/or any potential changes or improvements that may be offered in the future to the Portal or to our Products and Services.
15. To a third party in the event of any reorganization, restructuring, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

(collectively “Purposes”)

Where required by applicable law or reasonably practical, we will obtain your express consent prior to collecting or using your Personal Data. Our request for consent will be clear, informed, specific and you may provide your express consent for processing in a clear and transparent manner. In cases where you have provided the same, your consent is voluntary and may always be revoked, for example, by contacting our representative or consent manager in the manner indicated in later sections. As mentioned before, where your consent is required, and you do not give your consent, it may not be possible for us to provide you with specific membership benefits and such features or access to the Portal.

Legal Basis: Your Personal Data may be processed by us under different circumstances and different legal basis. The same is outlined below for your information:

1. Consent: We may collect and use your Personal Data where you have provided your consent for such use in a specific, informed and express manner in the manner and for the purposes outlined in this Policy. If we rely on your consent for processing your Personal Data, you may withdraw your consent at any time. However, we would not be able to provide you with access to membership benefits and/or the Portal, if you withdraw your consent. 
2. Legitimate Use: We may process your Personal Data for legitimate uses i.e., specifically if you voluntarily approach and provide us with your Personal Data for a specific purpose in respect of which you have not indicated denial of consent, for example, with regard to any enquiry or request for membership. We may process your Personal Data in such cases, for e.g., for the purpose of responding to you or for providing membership details or benefits to you. 
3. Legal Obligation: We may process your Personal Data for the purpose of complying with any obligations under law or for compliance with any judgment, direction, order issued under any law or other legal purposes. This includes situations where processing may be undertaken pursuant to directions issued or information solicited by the Government under applicable law.
4. Emergent Situations: We may process your Personal Data in case of emergent situations such as for responding to medical emergencies, taking measures to provide ensure safety, provide assistance or medical treatment, health services during epidemics, disasters, pandemics or other threats to public health or public order.
   
   
   Third Party Links: Through your use of the Portal, you may access third-party links to other services, which may require transmission of your personal data to third parties. We are not responsible for the collection or use of personal data in such applications or services provided by a third-party and recommend that you carefully review applicable terms for (and any integrity policy related to) such applications or services before you use them. If you have questions concerning a certain third party’s use of your personal data, please contact the third party directly.

5. Sharing and Retention of Personal Data

We may disclose your Personal Data to third parties in the manner and for the purposes outlined in this Privacy Policy, including the following:

1. To our affiliates or group companies for the purposes described in this Policy;
2. To third-party service providers such as hosting service providers, shipping agencies, agencies coordinating import, export and other activities, legal advisors and other service providers to enable them to provide services required for processing and delivery of Products and Services to you;
3. To our third-party service providers who provide services such as website hosting, email delivery, auditing, fraud detection and other services;
4. To third parties, to permit them to send you marketing communications, for the purpose of data or website analysis of the Portal, market research, sticky quotient, website analytics, advertising and development purposes consistent with your choices if you have opted into such sharing; and
5. Such data available in reports and other materials provided by you and/or your company may be shared pursuant to an engagement with another business partner and/or a supplier.

We may also use and disclose your Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law, which may include laws outside your country of residence, to respond to requests from public and government authorities, which may include authorities outside your country of residence, to cooperate with law enforcement or for other legal reasons; (b) to enforce our Terms; (c) to enforce or protect our contractual or other legal rights or to defend or bring legal proceedings, threats or notices of legal proceedings thereof; and (d) to protect the rights, privacy, safety or property, and/or that of our affiliates or other users.

Retention of Personal Data: We will only retain your Personal Data for as long as it is necessary to fulfil the purposes outlined in this Policy or the purposes of which you have otherwise been informed. While the exact period may vary in each individual case, this means that when you have consented to our processing of your Personal Data, we will retain the data for as long as we process and deliver our Products and Services or until you withdraw your consent or is otherwise legally required. If you have revoked your consent, we may nevertheless retain certain Personal Data for the period required in order for us to meet our legal obligations and defend ourselves in legal disputes.

6. Security Measures and Cross-Border Transfer

1. We strive to work towards the security, integrity and privacy of your Personal Data and to protect the same against unauthorized disclosure, access or destruction to the extent reasonably possible by us. We are in compliance with the reasonable security standards as prescribed by the applicable laws in India. Notwithstanding anything contained in this Policy or elsewhere, we shall not be held responsible for any loss, damage, or misuse of your Information, if such loss, damage, or misuse takes place as a result of a Force Majeure Event (as defined below).

2. A “Force Majeure Event” shall mean any event that is beyond our reasonable control and shall include, without limitation, fire, flood, explosion, acts of God, civil commotion, strikes, insurrection, war, epidemic, pandemic, acts of government, computer hacking, software failure and storage device, computer crashes etc.

3. Breach: We will promptly report and notify appropriate authorities about breach of any Personal Data processed by us, in accordance with applicable law, including to Data Protection Board (as and when constituted), Indian Computer Emergency Response Team (“CERT-IN”). We will take necessary directions and remedial measures directed by such authority to prevent further loss of information or mitigate harm, as may be specified. We may also contact you to report such breaches to you based on directions issued by authorities under applicable law.
4. Cross-border transfer: We may transfer your Personal Data to third parties, or process the same outside India, in accordance with and for the purposes described in this Privacy Policy, to the extent that the same is not restricted under applicable law. Where your consent is specifically required for transfer of such Personal Data outside India, we will request for your consent in a specific manner. We will undertake any and all transfers of your Personal Data outside India, in the manner permitted by applicable law, to third countries which extend the same or similar level of data protection adhered to by us under Indian law, in the event the same is required by law.

7. Your rights regarding Personal Data

If you live in India, the law has bestowed certain rights on you with regard to the processing of your Personal Data. We will have to confirm your identity, wherever applicable, to ensure that your rights are being exercised appropriately. We will respond to your request as soon as possible, in any case within 30 (thirty) days from receipt of your request. We may charge a minor sum to comply with your request if the same is voluminous or if we incur costs for compliance. 

Please be informed that you have the following rights under applicable laws in your country. In rare cases, we may not be able to comply with your directions of exercise of your rights due to some practical or legal reasons. We will inform you appropriately if such a situation occurs.

1. Access and rectification: You have the right to access a copy of your Personal Data we hold in a standard, easy and understandable form, except in rare occasions where we may not be able to provide you with a copy hereof. You have the right to review your Personal Data pursuant to such access, correct, complete, update and provide such information to us.
2. Withdrawal of Consent and Opt-Out: You have the right to withdraw your consent where we process your Personal Data on the basis of your consent. Upon such withdrawal, we will stop processing your Personal Data unless legally required to do so, or if we rely on other grounds of processing. Where you have withdrawn your consent for processing Personal Data, we may not be able to provide you with access to the Portal or membership benefits, should such data be required for the same.
3. Erasure: You have the right to request erasure of your Personal Data from our systems and we will comply with such request, unless laws specifically require or authorize us to retain your Personal Data for longer.
4. Grievance Redressal: You have the right to raise a grievance with us through the officer designated for the same in this Policy regarding our processing of your Personal Data. We will process the same, as soon as possible, and in any case within 1 (one) month of receiving the same. If you are unsatisfied with the resolution, you have the right to approach any Authority (such as the Data Protection Board) which is authorized under law.
5. Nomination: You have the right to nominate any other person who would exercise your rights under this Privacy Policy or under law, in the unfortunate event of death or incapacity. 

8. General Provisions and Grievance Redressal

Modifications: We reserve the right to change this Policy at any time and will provide updated details of the Policy on the Portal from time to time, in case of such changes. We may reach out to you to provide consent for processing your Personal Data in alignment with the updated policy, from time to time, if legally required. Else, your continued use of the Portal would be considered an acceptance of the Policy in its amended form.

Conflict: In the event of contradiction or inconsistency between this Privacy Policy, the service agreement or terms of membership shall prevail.

Assignment: You cannot assign or otherwise transfer your obligations under this Privacy Policy, or any right granted hereunder to any third-party. Our rights under this Privacy Policy are freely transferable to any third-party without the requirement of seeking your consent or providing an intimation to you.

Severability: If, for any reason, a court of competent jurisdiction finds any provision of this Privacy Policy, or portion thereof, to be unenforceable, that provision shall be enforced to the maximum extent permissible so as to give effect to the intent of the parties as reflected by that provision, and the remainder of this Privacy Policy shall continue in full force and effect.

Waiver: Any failure on our part to enforce or exercise any provision of the Terms, Service Agreement or this Policy or related rights shall not constitute a waiver of such provision or right by us.

Grievances: In the event that you have any questions, concerns or dealings with us and/or the Portal or with our processing of your Personal Data, please contact us using the information provided below. We will undertake reasonable efforts to address your grievance within 1 (one) month from receipt of the same. You also have a right to approach any authority under law in case you are dissatisfied with the resolution provided by us or by our officer.

Name of the Officer: Mr Aditya Mody

Email Address: info@ncfa.co.in

Contact Details: +91 9967045342