Scope

1. In this Privacy Policy, us, our, we, or HPCL means Hindustan Petroleum Corporation Limited, a company incorporated under Indian laws, having its registered office at [17, Jamshed ji Tata Road, Petroleum House Church Gate Mumbai 400020. All individuals whose personal information is either collected, received, processed, stored, transferred or shared by us is hereinafter referred to as “Data Subject” or “you”.
2. We produce and distribute a wide range of petroleum products. In doing so, we may collect, receive, process, store, transfer or share certain personal information about you. When we do so, we are regulated by the applicable laws in India including the Information Technology Act 2000, the Information Technology (Reasonable Security Practices and Procedures for Sensitive Personal Data and Information) Rules 2011, and the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act 2016 and related rules (collectively termed as “Applicable Laws”).
3. We ask that you read this Privacy Policy (“Privacy Policy”) carefully as it contains important information about who we are, how and why we collect, receive, process, store, transfer and share personal information, your rights in relation to your personal information, and how to contact us. This Privacy Policy should be read alongside, and in addition to any separate product or service agreement entered into between us or any other related terms of use, from time to time.
4. By accessing our products or services using any medium – website, mobile application or otherwise - you consent to us using your personal information in the way described in the Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not use or access our products and services.
5. By accessing / using or availing any of our products and services or by providing any information to us, you represent that you voluntarily provide us with information including Personal Information, and consent to their collection, use and disclosure in accordance with this Privacy Policy. You also represent that you are duly authorised by any third party whose information you may share with us.
6. This Privacy Policy is divided into the following sections:
   1. Important definitions
   2. How to contact us – Grievance Officer
   3. What Personal information we collect 
   4. How we collect Personal Information 
   5. Who does this Policy apply to
   6. Why we collect Personal Information 
   7. Who we share Personal Information with 
   8. How long we keep Personal Information
   9. Transfer of Personal Information outside India
   10. Your rights 
   11. Security practices  
   12. Updates to the Privacy Policy

Important Definitions

1. Agent: Any individual or entity which has a contractual relationship with HPCL, where HPCL is the principal and the other individual or entity is the agent, is hereinafter referred to as an "Agent". For instance, HPCL’s distributors, dealers, CFA, contractors, etc. will be considered Agents.
2. Personal Information: Personal information means any information of a natural person which can assist in identification of that person. Personal information of a Data Subject collected by HPCL under this Privacy Policy is hereinafter referred to as “Personal Information”. Such Personal Information includes, inter alia, sensitive personal data as defined under Information Technology (Reasonable Security Practices and Procedures for Sensitive Personal Data and Information) Rules 2011 if provided by you.
3. Third-Party and Business Partners: Any individual or entity over which HPCL does not have any control or ownership, and which operates independently on its own is hereinafter referred to as a “Third Party”.

How to contact us

If you have any questions, concerns or suggestions about how we handle your Personal Information, you can reach out to our Customer care support team.

What is “Personal Information”

Personal Information means and includes all information that can be linked to a specific individual and also includes Sensitive Personal Information (all Personal Information which requires heightened data protection measures due to its sensitive and personal nature), both, hereinafter referred to as “Personal Information”, excluding any information that is freely available or accessible in public domain. Please note, we do not offer any product/service under our Platform outside India. If you do not agree with this Privacy Policy, please do not use or access our Platform

What Personal Information we collect

We may collect your Personal Information when you use our services or Platform or otherwise interact with us during the course of our relationship. We collect Personal Information which is relevant and absolutely necessary for providing the services requested by you and to continually improve the our Platform

Below is a list of types of information that we may collect or receive when you use our products or services or access our website or mobile application.

Who does this Policy apply to

This Policy applies to all individuals whose Personal Information in course of use of or access to our products or services is either collected, received, processed, stored, dealt or handled by us.

How we collect Personal Information

1. We collect or receive Personal Information about you through the following means:
1. whenever you show an interest or elect to use our products or services on HP Pay application, website or portal, including information about our schemes, irrespective of whether such products or services are provided directly by us or by our Agents acting on our behalf;
2. through our network of Agents or a Third Party which collects such Personal Information and transfers it to us for a business requirement;
3. when you download our mobile applications or visit any of the websites owned by us and/or create an account on the mobile applications or the websites;
4. accessing links, e-mails, chat conversations, feedbacks, notifications sent or owned by HP Pay Platform and if you opt to participate in our occasional surveys

Why we collect Personal Information

1. We use your Personal Information to conduct our business and to provide you with the best possible products and services. We will only use your Personal Information based on this Privacy Policy, our understanding with you, or as required by Applicable Laws.
2. We will collect adequate, relevant and necessary Personal Information and will process such Personal Information fairly and lawfully for the purpose it is collected. Most commonly, we will use your Personal Information for the following purposes:
1. To create your account and verification purpose
2. Where we need to perform the obligations, we have promised you such as to provide a product or service to you and to enable your use of our products or services, including but not limited to dealing with enquiries and complaints made by or about you relating to the products or services provided by us and to improve and customise our products and services in accordance with your preferences;
3. Where we need to comply with a legal, accounting, business or reporting obligation, including compliance with requests from the Government of India or any Governmental Agency;
4. To send marketing as well as non-marketing commercial communications to you;
5. To send you notifications that you have specifically requested for as well as to send statements, invoices and payment reminders to you, and to process and collect payments from you;
6. To enhance user experience in various processes/submission of applications/availment of product/service offerings by analysing user behaviour on an aggregated basis
7. to monitor and review products/services from time to time; customize the services to make your experience safer and easier, and conducting audits
8. To provide Third Parties with anonymised statistical information about our customers and allow them to contact you for products and services availed/ requested by you on HP Pay;
9. to resolve disputes; troubleshoot problems; technical support and fixing bugs; help promote a safe service
10. To keep our websites, mobile applications and other systems secure, screenings and due diligence checks, detect and protect against error, fraud, money laundering and other money laundering activities and to enforce our Terms of Use;
11. To promote the mission and objectives of Skill Development in India and/or to provide and disseminate information about relevant programmes under the Skill Development Mission.
12. To manage your employment or applications for employment/engagement with us.
3. By providing your Personal Information, you agree that we may collect, use and share this Information with Third Parties for the purposes mentioned above from Paragraph 8.2(a) to (l)
4. We may not be able to perform the obligations we promised you, or we may be prevented from complying with our legal, accounting, business or reporting obligations if you fail to provide certain Personal Information when requested by us. In such a situation, we will not be held liable in any manner whatsoever if there is any delay or deficiency in our products or services. We and our Agents, employees, directors, associates, etc. will not be liable to you against any complaints, legal proceedings or claims filed or initiated by you or any Third Party against us in this regard.
5. We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider it necessary to use the Personal Information for another reason and that reason is compatible with the original purpose. We ensure to take appropriate steps to minimize the processing to the extent possible, making it less intrusive to your privacy

Who we share Personal Information with

1. We may disclose your Personal Information to any of our Agents or Third Parties insofar as reasonably necessary for the purposes set out in this Privacy Policy and for the purpose of providing our products and services to you. Such Agents and Third Parties are expected to provide a similar level of protection to your Personal Information as provided by us. We do not accept any responsibility or liability for usage of your Personal Information by these third parties or their policies.
2. In addition to this, we may disclose your Personal Information:
1. where it is mandated under law or sought by Governmental Agencies as well as meeting the Know Your Customer (KYC) requirements
2. to our group companies including affiliates, associates, joint ventures or are otherwise controlled by / under the common control of HPCL to enable us to assimilate the information and create singular profiles, which may enable us to offer personalized products or services, cross-sell products or services offered by other members of the group companies of HPCL, and undertake relevant marketing initiatives, etc., which are broadly in line with the purpose mentioned herein.
3. to our legal advisors, consultants, etc. if we determine in good faith that disclosure is reasonably necessary to protect our rights and pursue available remedies, enforce our terms and conditions, investigate fraud, or protect our operations or users
4. if requested by government authorities for government initiatives and benefits
5. for grievance redressal and resolution of disputes
6. for the purpose of processing your financial product subscription requests placed with us and ensuring that these requests reach the relevant financial institution whose service/product you have opted for
7. if it is required by financial institutions to verify, mitigate, or prevent fraud or to manage risk or recover funds in accordance with applicable laws/regulations
8. for services related to communication, marketing, data and information storage, transmission, security, analytics, fraud detection, risk assessment and research
9. enforce our Terms of Use or Privacy Policy; respond to claims that an advertisement, posting, or other content violates the rights of a third party; or protect the rights, property or personal safety of our users or the general public
10. should we (or our assets) plan to merge with, or be acquired by any business entity, or re-organization, amalgamation, restructuring of our business then with such other business entity

How long we keep Personal Information

1. We will keep your personal information as long as it is necessary to fulfil the purpose for which it was collected or for any other legal, accounting, reporting or business purposes.
2. To ensure compliance with Applicable Laws, we may need to retain information even after you have terminated your account (if any) with us or stopped using our products or services. We may also keep your contact information and other details for fraud prevention and for the exercise/defence of a legal claim or for providing evidence in legal proceedings.  It is clarified that in case your terminate your account (if any), we have no obligation to retain your Personal Information, and we may delete any or all of your data without liability and at our discretion.
3. Post termination, we may continue to use your anonymised data which is aggregated or combined with anonymised data of other users. We use this for analytics, research and other business purposes.

Third Party Products, Services or Website

When you are availing products and services of service providers on HP Pay Platform, Personal Information may be collected by respective service providers and such Personal Information shall be governed by their privacy policy. You may refer to their privacy policy and terms of service to understand how your Personal Information will be handled by such service providers.

Our services may include links to other websites or applications when you visit our Platform. Such websites or applications are governed by their respective privacy policies, which are beyond our control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your browser or on the m-site you are redirected to), use of any Personal Information that you provide on these websites or applications is governed by the privacy policy of the operator of the application/website, you are visiting. That policy may differ from ours and you are requested to review those policies or seek access to the policies from the domain owner before proceeding to use those applications or websites. We do not accept any responsibility or liability for usage of your Personal Information by these third parties or their policies.

Your rights

1. You will have the following rights with regard to your Personal Information and you can exercise these rights by writing to HP Pay Customer support
1. Confirmation: You can ask us to confirm if we are processing your Personal Information.
2. Review: You can ask us for a copy of your Personal Information held by us.
3. Rectification: You can inform us about changes to your Personal Information and ask that we correct any erroneous or incorrect data held by us. We are not responsible for the authenticity of the data you provide us. Please ensure you notify us without undue delay of any changes to the Personal Information that you have provided to us by updating your details on our websites or mobile applications or by contacting our Grievance Officer at the details provided in this Privacy Policy.
4. Restrictions on Processing: You can ask us to erase your Personal Information, block or restrict the processing of your Personal Information, or object about specific ways in which we use your Personal Information. We will endeavour to comply with your request and shall be obligated to do so only to the extent as may be required under the Applicable Laws.
5. Right to Opt Out: We or our service providers or Agents may communicate with you through voice calls, text messages, emails, app notifications, or other means. The communication may relate to (a) our products and services, (b) promotional offers, or (c) any other information that we may want to share with you. You may opt out of receiving information about promotional offers by writing to us. But even if you opt out of receiving information from us, we may still send you non- promotional communication.
2. You have the option to withdraw consent given to us for collection and processing of your Personal Information. In such cases, we reserve the right to stop providing products or services for which your Personal Information was sought. Your withdrawal will become effective when you receive an acknowledgment from us. You understand that despite your request to withdraw consent, we may still need to retain some data about you for complying with Applicable Laws and further that we are obligated to stop processing of your Personal Information only to the extent required under the Applicable Law.

Security Practices

We deploy adequate technical and organisational security measures to protect your Personal Information. Some of these include: firewalls, encryption, and access controls. However, we do not guarantee that your Personal Information will be completely protected. Any transmission of Personal Information by you is at your own risk.

Further, you are responsible for maintaining the confidentiality and security of your login. Please do not share your Mpin and OTP details with anybody. It shall be your responsibility to intimate us in case of any actual or suspected compromise to your Personal Information.

We have provided multiple levels of security to safeguard the HP Pay Application by login/logout option and HP Pay Biometric Login (“Enable Biometric Login”) that can be enabled by you. We have preventive controls implemented to ensure you use HP Pay Application on your device and the same login credentials cannot be used on different device without any additional authentication/OTP.

Updates to the Privacy Policy

We may update this Privacy Policy from time to time at our discretion. We urge you to keep visiting this page so you remain updated about the changes, if any. Your continued use of our products and services will be construed as your confirmation, consent and acceptance of the modifications to the Privacy Policy. We will never make changes to policies in order to make it less protective of Personal Information already shared by you