Introduction and Purpose

These policies are published under the provisions of Rule 4(1) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 which requires the publishing of a privacy policy for handling of or dealing in personal information including sensitive personal data.

The website located at www.think-gas.com (“Site”) is owned and operated by THINK Gas Distribution Private Limited, a private company incorporated under the laws of India, having its registered office at 306, Plot H-1, Garg Tower, Netaji Subhash Place, Pitampura, New Delhi – 110034, India (hereinafter referred to as “THINK Gas” “we” “us” or “our”).

THINK Gas has created this privacy policy to demonstrate our commitment to your privacy (“Privacy Policy”). This Privacy Policy explains our data collection and use practices and outlines the types of personal information we receive and collect when you use our products, services and Sites, as well as some of the steps we take to safeguard information.

Any reference to “you” or “your” in this Privacy Policy, means you as a user of the Site accessing the Site and/or availing the services rendered by THINK Gas (“User”).

Please read this Privacy Policy carefully. As a User, your access or use of the Site is conditional upon your acceptance of and continued compliance with this Privacy Policy. By accessing or using the Site, you agree to be bound by this Privacy Policy and all rules, guidelines, policies including the terms of use applicable to the Site being operated by THINK Gas (“Policies”), as may be modified by THINK Gas from time to time, unconditionally and at all times and further agree and confirm that you consent to provide THINK Gas with information about yourself for the purpose set out below and you understand that such collection, storage and handling is lawful, necessary and permissible under applicable laws. If you do not agree to this Privacy Policy you shall not access or otherwise use the Site.

Requirement for Collection of Information

We may collect information about you in several circumstances:

• when you register with us, apply to use any of our services, become our client, or contact us in person, by telephone, by email or by post;
• when you provide feedback or complete a contact form on our website;
• when you or your organisation offer to provide or provide services to us.

The information collected is relevant and necessary to understand you or your online browsing pattern. The information is collected to provide you with a customized site experience, provide updated information, provide help regarding the usage of the Site or any of our services, carry out follow-ups, assist with customer service or technical support issues, troubleshoot problems, enforce the terms of use and other related Policies or to prevent fraud and unlawful use. It may be noted that THINK Gas has strict guidelines concerning unauthorized access to information provided by the User (as enumerated below).

The information collected will be used to provide you with the services and/or information requested by you. You may opt-out of these services whenever you wish to by writing to us.

Collection of Information

This Privacy Policy contains provisions regarding the collection, storage and handling of personal and non-personal information that you share on the Site. Personal and Non-Personal Information: When using the Site, you may be asked to provide, or you may choose to provide us with or upload, certain personally identifiable information about yourself (“Personal Information”), including but not limited to, your name, email address, address, company name and telephone number. Personal Information is data that can be used to uniquely identify or contact a single person. We do not collect personally identifiable information (including Personal Information) about you, except when you specifically provide such information voluntarily.

We may also collect non-personally identifiable information (“Non-Personal Information”), such as details of the services you request from us; details of your visit to any of our offices or other visits to third party locations as may be organised depending upon the nature of services provided by us; log file, internet protocol (“IP”) host address, pages viewed, browser type, internet service provider, referring/exit pages, platform type, date/time stamp, number of clicks and other data, and may aggregate any information collected in a manner which does not identify any individual (“Aggregate Information”).

From time to time, we may ask you for your opinion about the services rendered by THINK Gas. When we do surveys, wherein we may use cookies or other on-device storage and may combine the information collected by those cookies or other on-device storage with your answers. We will make sure that the survey results do not identify you, or anyone else who fills in our surveys.

What we know about you we get mostly from you, but we may also have to find out more about you from other sources to verify the information submitted by you and to make sure that what we know about you is correct and complete. This kind of verification is primarily done to address various security concerns and to ensure that you comply with the provisions of applicable laws, and the terms of use and other terms and conditions as may be prescribed by us from time to time. We do not collect personally identifiable information (including Personal Information) about you, except when you specifically provide such information voluntarily.

By using or accessing the Site, you accept the terms of this Privacy Policy and the fact that we store and process your Personal Information and Non-Personal Information under this Privacy Policy.

Information Usage

We are sensitive towards your information including your Personal Information and Non-Personal Information provided at the time of using or accessing the Site and/or services. Unless disclosed otherwise at the time of collection, we do not share any Personal Information you submit through our Site with any unaffiliated third party, unless it is necessary to respond to your inquiry or to comply with applicable law.

We may use your Personal Information:

• to assist in and administer the services rendered by THINK Gas to you;
• to process and deal with any complaints or enquiries;
• for auditing, research and analysis to operate and improve the services rendered by THINK Gas;
• to comply with our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• to help protect your information and prevent unauthorized access to it;
• to deal with any queries, complaints or problems reported by you;
• if required to do so by law and to the extent necessary for the proper operation of our systems, to protect us/our customers, or for the enforcement of any agreement between you and us;
• to notify you of changes to our services; and
• to help improve the services we provide to you

We may use Aggregate Information to improve and enhance the Site, analyze trends, administer the Site and for our market research activities, generate statistics relating to the use of our Site, such as the popularity of certain features or services. For example, we may share Aggregate Information with unaffiliated third parties, such as business partners, distributors and suppliers, in an aggregated, anonymous form, which means that the shared information will not contain nor be linked to any Personal Information (we cannot identify you personally in this way). We will never sell your Personal Information to any third party not affiliated with us without your consent except in connection with the sale or merger, wholly or partly, of our company or the division responsible for such services. We could also share information with third parties in limited circumstances, including when complying with legal processes, preventing fraud or imminent harm and ensuring the security of our network and services.

When we use third parties to assist us in processing your Personal Information, we require that they comply with this Privacy Policy and any other appropriate confidentiality and security measures.

Please note that we reserve the right to access and/or disclose Personal Information and Non-Personal Information we gather as required by the police, regulatory bodies, legal advisers, courts or administrative agencies and to the extent required to permit us to investigate suspected fraud, harassment, money laundering, terrorism or other crimes or violations of any law, rule or regulation, breach of the Site’s Policies, or the rights of third parties or to investigate any suspected conduct which we deem improper otherwise relating to you or where required by law and we will co-operate with any law enforcement authorities or court order requesting or directing us to disclose the identity of or locate anyone violating or breaching the aforementioned laws and/or Policies or otherwise for the prevention or detection of crime or the apprehension or prosecution of offenders or to protect the safety or security of Users of the Site. We may also disclose your Personal Information to any other organization if such organization is engaged by us to perform tasks on our behalf. Generally, we will disclose only the information we consider reasonably necessary to disclose.

Where and where requested/agreed by you, or we have assessed that there is a legitimate interest for us to send you the communication, we will:

• send you and keep you updated with information by email, telephone (including SMS) or mail about existing and new products or services and special offers from us or to provide information about THINK Gas by way of newsletters or email;
• send you information by email, telephone or mail about related products or services of selected third parties that may be of interest to you; and
• use the information for marketing and for market research purposes, including internal demographic studies, to improve, enhance and administer the Site, provide, optimize and personalize our products and services and send you newsletters and information about the products and services.

When assessing legitimate interest, we will balance our interests with your rights and will only send communications where you would reasonably expect to hear from us. You may opt-out of receiving this information when we collect details or at any time by contacting us on gaurav.madaan@think-gas.com.

Please note that if you “do not agree” to, or “opt-out” from, providing Personal Information or Non-Personal Information as requested by us, you may not be able to access certain areas of the Site and/or avail of certain services. However, it may be noted that THINK Gas reserves the right to send service-related communication without offering you the facility to opt out. At your request, THINK Gas can also remove/block your Personal Information from its database/ Site. However, this information may remain in our archive even after deletion or termination of your account as required by law and the handling of the same as per the provisions of the applicable law and as intimated by the government agency from time to time.

Use of Information for Marketing

In line with any permission given by you to us, we may send you direct marketing communications about our own, or selected third party services and disclose your information to other organizations who may send direct marketing communications to you. In addition, you can unsubscribe from email communications via unsubscribe links provided in communications sent to you.

Cookies

While using or accessing the Site, our servers may collect information indirectly and automatically about your activities on the Site by way of cookies. “Cookies” are pieces of information that may be placed on your computer or other media device by a website, while you are accessing, using, viewing or interacting with the website, to facilitate and enhance your communication and interaction with that website. Many websites use cookies for these purposes. We may use cookies to customize your visit to the Site and for other purposes to make your visit more convenient or to enable us to enhance our service. You may either accept or stop or restrict the placement of cookies on your computer/ other device or flush them from your browser, by adjusting your web browser settings, in which case you may still use our Site, but it may interfere with some of its functionality.

THINK GAS could use log files including IP addresses, browser type, internet service provider, pages viewed, referring/exit pages, platform type, date/time stamp, and the number of clicks to analyze trends, administer the Site, track user movement and gather broad demographic information for aggregate use.

This information is not linked to your Personal Information and is maintained distinctly. We do not use cookies to retrieve Personal Information from your computer or another device for purposes that are unrelated to the Site or your interaction with the Site. It is clarified that we store information including Personal Information only in the manner contained herein and under the provisions of applicable law.

Clickstream Data

As you use the internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as “clickstream data”, can be collected and stored by a website’s server. Clickstream data can tell us the type of computer or other device and browsing software you use and the address of the website from which you linked to the Site. We may collect and use clickstream data as a form of Aggregate Information to anonymously determine how much time visitors spend on each page of our Site, how visitors navigate throughout the Site and how we may tailor our web pages to better meet the needs of visitors. This information will be used to improve our Site and our services. Any collection or use of clickstream data will be anonymous and aggregate, and will not intentionally contain any Personal Information.

Security

THINK Gas will take reasonable precautions to protect personal data in its possession (including reasonable physical, electronic, and managerial procedures) against the risk of loss, misuse, unauthorized access, disclosure, alteration and destruction under applicable laws.

However, we feel prudent to inform you that due to the inherent open nature of the Internet, no website can fully eliminate security risks, enforcement of privacy laws are at a developing stage in some parts of the world and, therefore, we cannot guarantee that communications between you and us, or information stored on the Site or our servers, will be free from unauthorized access by third parties such as hackers and your use of the Site demonstrates your assumption of this risk. Further, by using or accessing our Site and accepting this Privacy Policy, you agree and confirm that THINK Gas is not liable for any disclosure due to errors in transmission or unauthorized acts of third parties or third-party websites.

Notwithstanding anything contained herein, THINK Gas shall not be liable for any loss, damage or misuse of your Personal Information due to a force majeure event. A force majeure event for this Privacy Policy shall mean any event that is beyond the reasonable control of THINK Gas and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, unauthorised access to computer data and storage device, computer viruses breach of security and encryption or any other cause beyond the control of THINK Gas.

Protection for Children

We have no intention of collecting Personal Information from children under the age of 18 (Eighteen) years. If and when we become aware that Personal Information from a child under the age of 18(Eighteen) years has been collected without such child’s parent or guardian’s consent, we will use all reasonable efforts to delete such Personal Information from our database.

Other Web Sites

Please note that this Privacy Policy does not cover any third-party websites to which we may provide links. Other websites may also reference or link to our Site. These sites may have their own privacy policies and/or terms and conditions of use. THINK Gas may provide links to such third-party websites on the Site, but does not provide any Personal Information to these third sites. We feel prudent to encourage you to be aware when you leave our Site, or browse the internet, and to inform you to read the privacy statements of every third party website that you visit. We clarify that such websites are operated by third parties and are not under the control of or affiliation or association of THINK Gas unless specifically expressed by THINK Gas and we are not responsible for the privacy practices/ policies or the content of or form of transmission adopted and material received from such web sites and their owners/ operators. We are not liable and do not represent anything regarding the privacy policies and practices adopted by such third party sites and other owners/operators. Also, we are not in a position to control or guarantee the accuracy, integrity or quality of the information, data, text, software, media, graphics, messages or other relevant materials available on such third party sites.

You should be aware that Personal Information that you voluntarily include and transmit anywhere online may be viewed and used by others if the terms and conditions and/or privacy policies of the online platforms, on which you make such inclusion and transmission, permit the same. In addition, Personal Information that you post to chat rooms, message boards, blogs or other publicly accessible forums may be viewed and used by anyone with access to such forums. We are unable to control such uses of your Personal Information, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties.

Providing links to third party sites does not imply or convey any endorsement by THINK Gas in any manner or of the contents of the said websites. You are aware that the information you provide on the third-party sites shall be governed by the policies of the said websites which you view. THINK Gas does not have the power or authority to prevent misuse of your information through such third-party websites. Such third party webs sites may also use technology to send advertisements directly to your browser because of which the third-party websites automatically receive your IP address. They may use cookies, javascript, web beacons and other technologies to measure the effectiveness of their advertisements and to personalize advertising content. THINK Gas has no access or control over cookies or other features of the third-party websites and are not governed by this Privacy Policy.

Acceptance to Terms

By using or accessing the Site, you are deemed to have agreed to the terms of this Privacy Policy. This Privacy Policy should be at all times read along with the Policies of the Site. This Privacy Policy applies to all information, including Personal Information.

By using or accessing the Site, you agree and acknowledge that your Personal Information may be transferred across national boundaries and stored and processed in any country around the world in accordance with applicable laws. You acknowledge that in the process of providing the services concerning the Site, some activities relating to the handling of information collected under this Privacy Policy may be done by THINK Gas’s trusted third-party vendors or agents, web hosting providers, communication services, and web analytic providers.

Storage and Disclosure of Information

THINK Gas does not rent, sell or share your personal or sensitive information and does not disclose any of your Personal Information to third parties unless you have permitted THINK Gas to do so. However, we may pass your Personal Information to other third parties in the following scenarios:

• to help us process questions you may have about our services or other inquiry you may have;
• to confirm or correct what we know about you;
• we may pass your Personal Information to our employees, contractors, suppliers, service providers and/or agents to administer the services provided to you by us now or in the future;
• to help us or law enforcement agencies prevent fraud, money laundering, terrorism and other crimes. Also, we may disclose your Personal Information to the police, regulatory bodies or legal advisers in connection with any alleged criminal offence or suspected breach of this Privacy Policy and or the breach of other terms and conditions otherwise relating to you or otherwise where required by law and we will co-operate with any law enforcement authorities or court order requesting or directing us to disclose the identity of or locate anyone breaching this Privacy Policy or otherwise for the prevention or detection of crime or the apprehension or prosecution of offenders;
• assisting an agency in undertaking information for us;
• if another organization is engaged by us to perform tasks on our behalf;
• compliance with an audit on our business;
• if we sell all or any part of our business or merge with another company;
• if it is necessary for legal proceedings and when we believe in good faith that any applicable law, regulation, government, regulatory or other authority, agency or officer requires it or to protect the safety or security of users of the site;
• if we use third party processors to administer and process your Personal Information for the purposes notified in this Privacy Policy, e.g. For hosting activities related to the use of the Site or services; and
• to obtain advice from third parties such as auditors or legal advisors.

Generally, we will disclose only the information we consider reasonably necessary to disclose. Also, some general statistical information about the site user base, traffic volumes and related matters may be passed on to reputable third parties but these details will not include information personally identifying you.

Further, it may be noted that we may share your information with the associates of THINK Gas. Associates for this Privacy Policy shall mean a company in which THINK Gas directly or indirectly, owns or controls, or is owned or controlled by, or is under common ownership or control with THINK Gas; wherein ‘own’ means the beneficial ownership of or the ability to direct the voting of more than 20% (twenty per cent) of the total share capital or rights to distributions on account of equity of THINK Gas and ‘control’ shall include the right to appoint a majority of the directors or to control the management or policy decisions exercisable by a person or persons acting individually or in concert, directly or indirectly, including under their shareholding or management rights or shareholders agreements or voting agreements or in any other manner.

Personal Data About Other People

If you provide personal data to us about someone else (such as one of your directors or employees, or someone with whom you have business dealings) you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Policy. In particular, you must ensure the individual concerned is aware of the various matters detailed in this Privacy Policy, as those matters relate to that individual, including our identity, how to contact us, our purposes of collection, our personal data disclosure practices (including disclosure to overseas recipients), the individual’s right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences of the personal data is not provided (such as our inability to provide services).

Changes to Policy; Rights and Opt-out Process

We may change this Privacy Policy from time to time and we will post the latest version on the Site. You are expected to keep reading the Policies, including this Privacy Policy, at regular intervals to keep yourself updated.

We reserve the right, at our sole discretion, to change, modify, add or remove portions from this Privacy Policy at any time without notice, and it is your responsibility to review this Privacy Policy from time to time, to keep track and take note of the changes. However, if at any time in the future we plan to use Personal Information in a way that differs from this Privacy Policy, we will post such changes here and provide you with the opportunity to opt-out of such differing uses. Your continued use of the Site following the posting of any changes to this Privacy Policy means you accept such changes. We will not file or store a copy of these terms for each interaction by you via the Site. We, therefore, recommend that you save a copy of this Privacy Policy for future reference and ensure that such copies can be reliably verified as being effective (i.e. published on the Site) on a particular date.

You have the right to request a copy of the Personal Information about you, which we hold, to have any inaccurate information corrected and to object to or restrict our using your Personal Information. We may request you to prove your identity by providing us with a copy of a valid means of identification for us to comply with our security obligations and to prevent unauthorised disclosure of data. When we receive a request we will endeavour to provide you with the details within a reasonable time.

If you receive an unwanted email from us, you can simply reply and ask not to receive future emails. We also give you the option to remove your Personal Information from our list of active users completely. All unsubscribe or opt-out requests should be sent to us at gaurav.madaan@think-gas.com and we will process your request within a reasonable time after receipt. We are not responsible for removing your Personal Information from the lists of any third party websites that have been provided with your information under this Privacy Policy, such as a business partner.

Retention Period

We will retain your information provided for as long as required to perform the purposes for which the data was collected, depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations require us to retain it.

In general terms, this will mean that your information will be kept for the duration of our relationship with you and:

• the period required by tax and company laws and other applicable laws; and
• as long as it is necessary for you to be able to bring a claim against us and for us to be able to defend ourselves against any legal claims. This will generally be the length of the relationship plus the length of any applicable statutory limitation period under applicable law.

Communications With Us

By providing your email address to us, you expressly consent to receive emails from us. We may use email to communicate with you, to send information that you have requested or to send information about other products or services developed or provided by us, provided that, we will not give your email address to another party to promote their products or services directly to you.

Any communication or material you transmit to us by email or otherwise, including any data, questions, comments, suggestions, or the like is and will be treated as, non-confidential and non-proprietary. Except to the extent expressly covered by this Privacy Policy, anything you transmit or post may be used by us for any purpose, including but not limited to, reproduction, disclosure, transmission, publication, broadcast and posting. Furthermore, you expressly agree that we are free to use any ideas, concepts, know-how, or techniques contained in any communication you send to us without compensation and for any purpose whatsoever, including but not limited to, developing, manufacturing and marketing products and services using such information.

Contact

Thank you for reading this Privacy Policy and thank you for choosing our services. For any questions, queries, complaints or concerns relating to privacy, we can be contacted at siddhesh.redkar@think-gas.com.

Disputes

Any disputes over inter alia collection, storage and handling of Personal Information will be governed by this Privacy Policy and by the laws of India and courts of Noida, Uttar Pradesh, India, shall have exclusive jurisdiction.