1. Introduction

Banco Group (Banco Products (India) Limited, Banco Gaskets (India) Limited, Banco New Energy Cooling Systems Limited) herein referred to as “Company”, “we”, “our” or “us”, is committed to protecting the privacy and personal data of individuals who interact with us through our website, business operations and related services.

We work with customers, automotive manufacturers, suppliers, business partners, employees, job applicants, contractors and other stakeholders. This Privacy Policy explains how we collect, use, disclose, store and protect personal data in connection with our business activities.

We process personal data in accordance with applicable Indian data protection laws, including the Digital Personal Data Protection Act, 2023, and the Digital Personal Data Protection Rules, 2025, to the extent applicable and in force. We also maintain information security and data protection practices aligned with applicable customer requirements and relevant TISAX assessment objectives.

2. Scope of This Policy

This Privacy Policy applies to personal data collected through our website, enquiries, recruitment activities, business communications, customer and supplier interactions, and other related business processes.

It applies to customers, prospective customers, supplier and business partner representatives, website visitors, job applicants, contractors, visitors to our premises and other individuals whose personal data we process.

This Policy does not replace separate contractual confidentiality, information security or data processing obligations applicable to customer information, technical documentation, product designs, prototypes or other confidential business information.

3. Personal Data We Collect

Depending on the nature of our interaction with you, we may collect the following categories of personal data:

3.1 Identification and Contact Information

• Name, business designation and department.
• Business email address, telephone number and business address.
• Other contact details voluntarily provided to us.

3.2 Business and Transaction Information

• Company or organisation name and professional contact details.
• Enquiry details, correspondence, quotations, purchase orders and transaction-related records.
• Information required for supplier registration, customer onboarding and business relationship management.

3.3 Recruitment and Employment Information

• Information provided in applications, resumes and supporting documents.
• Educational qualifications, professional experience, employment history and references.
• Other information necessary for recruitment, employment administration or related legal obligations.

3.4 Website and Technical Information

• Internet Protocol (IP) address, browser type, device information and operating system.
• Website access logs, pages visited, timestamps and diagnostic information.
• Cookie identifiers and related information, where applicable.

3.5 Visitor and Security Information

Where applicable, we may process visitor registration details, identity verification information, access records, photographs or CCTV footage for premises security, safety and access management.

We collect only personal data that is reasonably necessary for the relevant purpose, subject to applicable legal requirements.

4. Sources of Personal Data

We may obtain personal data directly from individuals through website forms, emails, telephone calls, business meetings, recruitment applications and other communications.

We may also receive personal data from the organisations with which individuals are associated, authorised representatives, recruitment agencies, service providers and other lawful sources, where necessary for our business activities.

Where personal data is received from another source, we handle it in accordance with applicable legal requirements and the purpose for which it was provided.

5. Purposes of Processing

We process personal data for the following purposes, as applicable:

• Responding to website enquiries, requests for information and business communications.
• Managing customer relationships, supplier relationships and business transactions.
• Preparing quotations, processing orders and coordinating deliveries and related services.
• Meeting customer requirements, contractual obligations, quality requirements and applicable automotive supply-chain requirements.
• Managing recruitment, employment administration and related activities.
• Controlling access to our premises and maintaining workplace safety and security.
• Operating, maintaining and improving our website and information systems.
• Detecting and investigating security incidents, misuse, fraud or unauthorised access.
• Establishing, exercising or defending legal claims and complying with applicable laws and lawful requests from competent authorities.

We do not use personal data for purposes unrelated to the original purpose of collection unless permitted by applicable law or supported by a valid legal basis.

6. Legal Basis for Processing

We process personal data on the basis permitted under applicable law, including valid consent where required and the other lawful grounds recognised by the DPDP Act.

Where consent is required, we will provide appropriate information about the purpose of processing and seek consent through an appropriate method. Individuals may withdraw their consent in accordance with applicable law.

Where processing is necessary for a permitted legitimate use, compliance with a legal obligation or another lawful basis recognised under applicable law, we will process the data within the limits of that basis.

Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal. It may affect our ability to provide certain services or continue particular activities.

7. Disclosure and Sharing of Personal Data

We may share personal data, where necessary and permitted by applicable law, with:

• Customers, business partners and authorised representatives involved in a business transaction.
• Suppliers, contractors and service providers supporting our business operations.
• Information technology, hosting, communication and security service providers.
• Recruitment agencies and professional advisers.
• Auditors, insurers and legal or compliance advisers.
• Government authorities, courts, regulators and law enforcement agencies where disclosure is legally required or otherwise permitted.

Where third parties process personal data on our behalf, we seek to establish appropriate contractual and organisational safeguards, including confidentiality and security obligations.

We do not sell personal data to third parties.

8. Information Security and Confidentiality

We recognise the importance of protecting personal data and confidential information against unauthorised access, disclosure, alteration, loss or misuse.

Depending on the nature of the information and associated risks, we implement appropriate technical and organisational measures, which may include:

• Access restrictions based on business requirements and authorised responsibilities.
• Authentication and access management controls.
• Protection of information systems and business records.
• Confidentiality obligations for relevant personnel and service providers.
• Security monitoring, backup and recovery measures, where applicable.
• Procedures for identifying, reporting and responding to information security incidents.
• Appropriate handling of customer information, technical data and other confidential automotive supply-chain information.

Our information security practices are intended to support applicable legal obligations, contractual commitments and relevant customer security requirements.

9. Data Retention and Deletion

We retain personal data only for as long as necessary to fulfil the purpose for which it was collected, comply with applicable legal and regulatory requirements, meet contractual obligations, resolve disputes or establish, exercise or defend legal claims.

Retention periods may vary depending on the category of data, the nature of the business relationship and applicable statutory or contractual requirements.

When personal data is no longer required, we take appropriate steps to delete it or otherwise dispose of it securely, subject to applicable legal retention obligations and any other lawful basis for continued retention.

10. Cookies and Website Technologies

Our website may use cookies or similar technologies to support website functionality, security, performance and user experience.

Where applicable, such technologies may collect technical information, including browser details, device information and website usage data.

You may be able to manage cookies through your browser settings. Disabling certain cookies may affect the functionality of parts of the website.

Where consent is required for particular cookies or tracking technologies, we will obtain consent in accordance with applicable requirements.

11. International Data Transfers

In the course of our business, personal data may be accessed or processed outside India where necessary for business operations, customer requirements or the use of authorised service providers.

Any such transfer will be subject to applicable Indian data protection laws, restrictions imposed by the Government of India and relevant contractual or regulatory requirements.

We take appropriate steps to ensure that personal data is handled with suitable safeguards when it is shared with authorised recipients in other jurisdictions.

12. Rights of Individuals

Subject to applicable law, individuals may have the right to:

• Obtain information about the personal data being processed and the processing activities, as provided under applicable law.
• Request correction or updating of inaccurate or incomplete personal data.
• Request erasure of personal data where permitted by applicable law.
• Withdraw consent where processing is based on consent.
• Seek information about available grievance redressal mechanisms.
• Nominate another individual to exercise applicable rights in the event of death or incapacity, as provided under applicable law.
• Raise a complaint with the competent authority, including the Data Protection Board of India, where applicable.

Requests will be handled in accordance with applicable law, verification requirements and any relevant legal or regulatory restrictions.

13. Grievance Redressal

Individuals may raise questions, concerns or grievances relating to the processing of their personal data by contacting us using the details provided below.

We will review and address grievances within the timelines prescribed under applicable law and our applicable grievance redressal procedures.

Privacy and Grievance Contact

Company Name: Banco Products (India) Limited
Email: investor@bancoindia.com
Postal Address: Bil, Padra Road, Near Bhaili Railway Station, Dist. Vadodara- 391410, Guj.
Subject Line: Privacy Policy / Personal Data Grievance

Where a complaint remains unresolved, individuals may pursue the remedies available under applicable law.

14. Children’s Personal Data

Our website and business activities are primarily intended for business and professional interactions. We do not knowingly seek to collect children’s personal data through our website unless necessary for a lawful and specific purpose.

Where the processing of children’s personal data is undertaken, we will comply with applicable requirements concerning children’s personal data, including parental or lawful guardian consent where required by law and any applicable restrictions.

15. Third-Party Websites

Our website may contain links to third-party websites or services. Such websites operate under their own privacy policies and practices.

We are not responsible for the privacy practices, content or security of third-party websites. Individuals are encouraged to review the applicable privacy policies before providing personal data to those websites.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our business activities, website functionality, applicable legal requirements or data protection practices.

The revised Policy will be published on our website with an updated revision date. Where required by applicable law, we will provide additional notice or seek consent for changes in processing activities.

17. Contact Information

For questions regarding this Privacy Policy, the processing of personal data or the exercise of applicable privacy rights, please contact:

Email: info@bancoindia.com
Telephone: (0265) 2318100
Website: https://bancoindia.com/

This Privacy Policy is effective from the date stated and applies subject to applicable laws and regulations.