PRIVACY POLICY

UNIFIED TITANIUM COMMON ASSOCIATION

Global Corporate Privacy Policy

UNIFIED TITANIUM COMMON ASSOCIATION and its subsidiaries (collectively or individually, as applicable, referred to as “UTCA” or “our” or “we” or “us”) respect your privacy and are committed to protecting your personal data. This Global Corporate Privacy Policy (“Global Privacy Policy” or “Privacy Policy”) describes how we look after your personal data. As described in this Privacy Policy, we may collect your personal data in many ways, including when you visit our website (regardless of where you visit it from) or use our mobile applications, apply for a job, apply for or use our products and services (collectively, including our website and mobile applications, the “Services”), or otherwise communicate with us. We also may collect your personal data from third party sources. This Privacy Policy tells you how we collect, store, use, disclose and process your personal data and tells you about your privacy rights and how the law protects you.

By accessing or using our Services or otherwise giving us your information, you will be deemed to have the capacity to enter into a legally binding contract in accordance with applicable law in the jurisdiction from which you are accessing our Services. You will consequently be deemed to have read, understood and agreed to the practices and procedures outlined in this Privacy Policy and agree to be bound by its terms.

INDEX

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW WE COLLECT YOUR PERSONAL DATA

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of This Privacy Policy

This Global Privacy Policy aims to give you information on how UTCA collects, stores, uses, discloses, and processes your personal data when we collect that personal data by any means. Our website is not intended for children and we do not knowingly collect data relating to children on our website. Generally, a child is a person under 16 years old (under EU law), but you may check to see if your local laws have a different age limit for legal purposes.

Our agreements with certain customers may contain provisions about the collection, use, storage and disposal of information. If a provision of a customer agreement conflicts or otherwise is inconsistent with a provision of this Privacy Policy, then the provision of the customer agreement will prevail.

About UTCA

UTCA (UNIFIED TITANIUM COMMON ASSOCIATION) IS AN ASSOCIAITON FOR WELFARE OF EARTH TITANIUM BUYERS.

Controller

UNIFIED TITANIUM COMMON ASSOCIATION provides this Privacy Policy as a controller to describe our practices regarding the collection, storage, use, disclosure and other processing of personal data.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the Privacy Office using the details set out below.

Contact Details

UNIFIED TITANIUM COMMON ASSOCIATION

Email address: CONTACT@TITANIUMNOIDA.COM

Postal address: 1^ST FLOOR, G-36, CONNAUGHT PLACE, NEW DELHI-110001

Changes To The Privacy Policy And Your Duty To Inform Us Of Changes To Your Personal Data

We review and update this Privacy Policy from time to time. When we do, we will note the date of the version on the Privacy Policy and post it on this website. You can tell when we last updated this Privacy Policy by checking the “Last Updated” date at the top of this Privacy Policy. You also may obtain historical versions of this Privacy Policy by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-Party Links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. This Privacy Policy does not apply to information that is collected by any third-party website or service that you may access through the Services.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). UTCA may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

· Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;

· Contact Data includes billing address, delivery address, email address and telephone numbers;

· Financial Data includes bank account and payment card details;

· Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us;

· Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website;

· Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;

· Usage Data includes information about how you use our website, products and services;

· Biometric Data includes an individual’s physiological, biological, or behavioral characteristics, including an individual’s deoxyribonucleic acid (DNA) that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

UTCA also collects, uses and shares Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

UTCA may collect certain Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic data and biometric data) if required under law or for your safety or to meet with customer requirements or to protect confidential information of UTCA or to implement any customer process. We may collect information about criminal convictions and offences in those jurisdictions where the processing of such information is legally admitted. Usually we will be relying on another legal basis of processing (and not require Explicit Consent to process) such Special Categories of Personal Data or criminal conviction data except in jurisdictions that require an explicit consent.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with or avail from you certain goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW WE COLLECT YOUR PERSONAL DATA

UTCA collects information, some of which is “personal data,” to deliver, promote or market UTCA’s products or services in connection with an existing or potential business or employment relationship with you.

We use different methods to collect data from and about you including through the following:

· Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

o apply for our products or services;

o apply for a job or gain employment with us or to do business with us;

o create an account on our website;

o use our mobile applications;

o disclose information on our social media pages, message boards, comment fields, chat areas or other community forums;

o subscribe to our service or publications;

o request marketing to be sent to you;

o enter a competition, promotion or survey; or

o give us some feedback.

· Automated technologies or interactions. As you interact with our website or mobile applications, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

· Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

o Public Forums. UTCA is not responsible or liable for personal data that you post in public forums or otherwise choose to make public. We have the right but not the obligation to monitor any activity and remove information from comment fields, message boards, events and other interactive sections of the Services.

o Technical Data from the following parties:

§ (a) analytics providers such as Google and Adobe based outside the EU. Generally, analytics services do not identify individual users. Many analytics services allow you to opt out of data collection;

§ (b) data collection technology which is deployed by UTCA when you visit or use the Services. This can be used to collect information such as IP address, browser type, browser language, time zone, language settings and operating system on your device, how long you spend on various webpages, which webpages you view, your search queries, error and performance reports, the webpages that you visited before and after using the Services. Other data collection technology is deployed by advertisers, other website operators (also known as ‘publishers’), and networks and other third parties with which UTCA partners to operate and provide the Services.

Data collection technology helps us improve your experience of the Services by, for example, storing your password so you do not have to re-enter it each time you use the Services, measuring the success of marketing campaigns, compiling statistics about use of the Services and helping us analyze technical and navigational information about the Services and to detect and prevent fraud; and

§ (c) search information providers:

§ Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU.

§ Identity and Contact Data from data brokers or aggregators based inside or outside the EU.

§ Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

· Where you have provided your consent to use such personal data.

· Where we need to perform the contract we are about to enter into or have entered into with you.

· Where it is necessary for our legitimate interests (or those of a third party) and such interests do not override your interests or fundamental rights which require protection of your personal data.

· Where we need to comply with a legal or regulatory obligation, or otherwise as required or permitted under applicable law.

Generally, except in those jurisdictions where consent is required by law, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. However, certain of our services may not be available if you do not consent, or if you withdraw your consent, to our use of your personal data.

Purposes for Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity Data

(b) Contact Data

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity Data

(b) Contact Data

(d) Transaction Data

(e) Marketing and Communications Data

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity Data

(b) Contact Data

(d) Biometric Data

(e) Marketing and Communications Data

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity Data

(b) Contact Data

(d) Usage Data

(e) Marketing and Communications Data

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity Data

(b) Contact Data

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business re-organisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity Data

(b) Contact Data

(d) Usage Data

(e) Marketing and Communications Data

(f) Technical Data

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical Data

(b) Usage Data

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity Data

(b) Contact Data

(d) Usage Data

(e) Profile Data

Necessary for our legitimate interests (to develop our products/services and grow our business)

To comply with applicable law, or for other purposes permitted by applicable law.

(a) Identity Data

(b) Contact Data

(d) Technical Data

(e) Usage Data

(f) Profile Data

Legal compliance

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside UTCA for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

We use cookies and similar tracking technology (collectively, “cookies”) to collect and use personal information and personal data about you, including to serve interest-based advertising. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

The Services use the following cookies:

· Strictly necessary cookies, which are required for the operation of the Services.

· Analytical/performance cookies, which allow UTCA to recognise and count the number of visitors, learn how visitors navigate the Services and improve the Services.

· Functionality cookies, which UTCA uses to recognise you when you return to the Services.

· Targeting cookies, which record your visits to the Services, the pages you visited and the links you followed. Targeting cookies helps UTCA deliver digital advertisements that are targeted to your interests (as inferred from your online activity). UTCA also shares information collected through targeting cookies with third parties that send you targeted advertisements.

· Interaction cookies, which allow you to recommend UTCA on social media.

For more information about the cookies we use, please see Cookie Policy on our website.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above, where this is required or permitted by law.

5. SHARING OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

· Internal Third Parties as set out in the Glossary.

· External Third Parties as set out in the Glossary.

· Third parties from whom we avail services for carrying out business activity.

· Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

UTCA requires all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS OF YOUR INFORMATION

UTCA stores and processes personal data, except Transaction Data, in its facilities or with service providers throughout the globe. Your personal information may be transferred to, and processed outside the country in which you are resident. These other jurisdictions may have data protection laws that are different from the laws of your country (and, in some cases, not as protective). When we transfer data from India, we require that the data are provided the same level of protection as we provide to the data in order to comply with Indian law, and you consent to such transfers.

UTCA has procedures to help ensure that personal data collected through the Services is used only for an authorised purpose and that the security, integrity and confidentiality of the personal data are respected and maintained. UTCA requires contractual obligations from any third party that receives personal data from UTCA to confirm that such third party also has procedures in place to ensure that personal data is used only for authorised purposes and that the confidentiality and security of the personal data are respected and maintained.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

UTCA has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

UTCA has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

You are responsible for maintaining the security of your account credentials and other authentication involved in obtaining access to password-protected or secure areas of the Services. UTCA will treat access to the Services through your account credentials as authorised by you. We shall bear no liability in respect of such unauthorised use of your account. Unauthorised access to password-protected or secure areas is prohibited and may lead to criminal prosecution. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided.

8. DATA RETENTION

We retain information for as long as necessary to fulfill the purposes for which you provided the information, including for the purposes of satisfying any legal, accounting, or reporting obligations, to resolve disputes, to enforce agreements and for such other purposes as are permitted under applicable law.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements that may permit retention for a longer duration.

In addition, in some cases applicable laws require us to retain certain information for regulatory or legal purposes. Please contact us for more information about the period of time for which we will process your personal information.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Your rights include the right to access, correct, update or request deletion of your personal data and withdraw the consent you have provided to us, subject to applicable data protection laws.

If you wish to exercise any of the rights set out above, you may contact our office at CONTACT@TITANIUMNOIDA.COM. You also have the right to reach out to the applicable data protection authority.

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, except when Argentine laws apply, we may charge a reasonable fee if your request is clearly unfounded repetitive or excessive, or we may refuse to comply with your request in such cases. When Argentine laws apply, we may charge you a reasonable fee for you to access your data more than once every six months unless you can show a legitimate need for your data.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within one month or within any such shorter period as is required by law. When a delay is both necessary and permitted by law, we will notify you and keep you updated.

Complaints

In the event that you wish to make a complaint about how we process your personal information, please contact us at CONTACT@TITANIUMNOIDA.COM and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.

10. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

INTERNAL THIRD PARTIES

Other companies in UTCA acting as joint controllers or processors and who are based India, US, Poland, Argentina, China, UK, Singapore, Switzerland and other jurisdictions where company has its operations and provide IT and system administration services and undertake leadership reporting.

EXTERNAL THIRD PARTIES

· Service providers based in India, US, Poland, Argentina, China, UK, Singapore, Switzerland and other jurisdictions where company has its operations who provide IT and system administration services.

· Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in India, US, Poland, Argentina, China, UK, Singapore, Switzerland and other jurisdictions where company has its operations who provide consultancy, banking, legal, insurance and accounting services.

· HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. You may contact UTCA using the Contact Information provided to update or correct your Personal Data whenever necessary.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data, by contacting us. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, UTCA may limit your access to the Services and/or not offer or provide you with the product or services or initiate or continue any relationship with you.