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PRIVACY POLICY

Last Updated: 15th October 2025

Lucas Indian Service Limited having its registered office at No.11 & 13, Patullos Road, Chennai – 600 002, Tamil Nadu, India (hereinafter referred to as “We”/ “Us”/ “Our”), on behalf of itself and its affiliates/group companies under the brand ‘LIS’, operates the website https://www.lucas-service.com/ and the web application https://lisportal.lissap.in/ (together referred to as “Portal”).

This Privacy Policy (hereinafter referred to as “Policy”), helps Our registered dealers (“You”/ “Your”) using/accessing the Portal and other related applications and to understand the type of information collected, the purpose for which the information is collected; how the information is used; the intended recipients of such information; when it might be disclosed and how You can control the collection, correction and/or deletion of Your information; and how the information is protected to the extent applicable to the respective users. We take protection and proper use of Your information seriously and are committed to protecting such information in Our possession. We advise You to read this Policy carefully prior to Your access of the Portal, appointment of Our authorized dealer of the Products or creation of an Account on the Portal, as the case may be. If You do not agree to this Policy, please do not access Our Portal, or create an Account in Our Portal. In addition to this Privacy Policy, You shall also be bound by the Terms of Use available at [insert the hyperlink of LIS Dealer’s terms of use].

If We learn that We have collected the Personal Information (defined below) from an user who is under the age of 18, We will promptly delete such information. If You believe that We have collected Personal Information from someone under the age of 18, please contact us at [email protected]

This Policy is published and shall be construed to be in accordance with the provisions of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data of Information) Rules, 2011 (“SPDI Rules”) and Information Technology (Intermediaries Guidelines And Digital Media Ethics Code) Rules, 2021 (“Intermediaries Rules”) under the Information Technology Act, 2000 and other applicable laws that require publishing of the privacy notice for collection, usage, storage, disclosure and transfer of sensitive personal data or information (“Indian Data Privacy Laws”).

If You are registered user from a country outside India, this Policy is published and shall be construed to be in accordance with the provisions of the relevant legislations, laws, enactments, rules, and regulations enacted by the statutory authority with respect Personal Data and Sensitive Personal Data in Your jurisdiction (“Other Data Privacy Laws”).

For the purpose of this Policy, (1) Indian Data Privacy Laws, and (2) Other Data Privacy Laws, shall collective be referred as “Applicable Laws”.

Any capitalized terms used herein without definition shall have the meanings assigned to them in Our Terms of Use or in Applicable Laws.

1. INFORMATION COLLECTED BY US

When You access Our Portal or submit the form or create an Account with Us, We shall collect certain information from You, the details of which are provided hereinafter. The categories and sources of the Information collected by Us are as follows:

a. Personal Information

Any Information that relates to You as a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying You and any further information, including, without limitation, provided by You to Us when You submit the enquiry through the Portal or when You subscribe for any of Our Portal by signing-up, as the case may be, such as:

  • Your name
  • Your entity’s name
  • Your entity’s address
  • Your entity’s GSTIN
  • Your vehicle information
  • Your mobile number
  • Your email address
  • Any other identifiers and any other sensitive/personal information as defined under the Applicable Laws as amended from time to time (collectively referred as “Personal Information”).
b. Usage Information

Any information that is not Personal Information, but information collected in relation to Your use of the Portal or information required for the proper functioning and development of Portal, including, without limitation:

  • Time, date and extent of Your usage of the Portal
  • Your usage and search history within the Portal
  • Device keyboard settings
  • Time zone, language, screen resolution, and other usage preferences You select when using the Portal
  • The URL that may have directed You to the Portal
  • History of use or purchase of Products by You
  • Other device and Portal access information such as IP address, operating system, browser type, referring/exit pages, and other unique device identifiers, as well as Your push notification token.
c. Behavioral Information

We shall collect information which is connected with Your activity on the Portal across all Your devices using Your log-in details and opt-ins and communication preferences.

d. Cookies

We and Our service providers and business partners use cookies and other similar technologies (e.g. web beacons, flash cookies, etc.) (“Cookies”) to automatically collect information, measure and analyze which web pages You click on and how You use the Portal, enhance Your experience using the Portal and improve the Portal.

Cookies enable the Portal to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from Your computer or device.

e. Transaction and Payment Information

We, through our authorised payment gateway solution providers, collect information such as billing address or any other payment instrument details and transaction details or any other third-party payment information of the users.

f. Device Information

We collect information about computers, phones, and other connected devices with a web connection and the presence of Our Portal and integrate this information with the various devices You use. This information includes:

    Device features such as operating system, hardware and software versions, battery status, signal availability, available storage space, browser type, app or file names and types, and plug-ins Device activities such as activity and behavior of the device (e.g., in the background or in front of a window or with mouse movements, which help to distinguish humans from bots) Unique identifiers, device ID, games, apps, or accounts You use Bluetooth signals and related device information about nearby WiFi access points, beacons and cell towers, Information that We are permitted to collect by turning on access in device configuration, as well as providing access to GPS location, camera or photo, information such as Your mobile operator's name or ISP, language, time zone, mobile phone number, IP address, connection speed, and other devices near Your device or on the network.

    g. Third Party Information

    Information about You that We may receive from third parties services, such as partners, data providers and analytics providers.

    2. USAGE OF YOUR INFORMATION

    We use Your information to improve, support, and administer the Portal, to allow You to use its functionalities, and to fulfill and enforce Our Terms of Use. We may also use Your information to show suggestions and promote the Portal.

    a. General Usage

    We use the information We collect for the following purposes:

    • To support Portal functionality, internal operations, and quality assurance including troubleshooting, data analysis, testing, research, statistical, and survey purposes.
    • For capturing orders, invoicing, and billing processes.
    • To notify You about updates to Our services.
    • To gather feedback about Our services.
    • To verify Your identity in order to use certain features.
    • To improve and develop Our Portal and related services.
    • To maintain security and help detect abuse, fraud, or illegal activity on the Portal.
    • To understand how You use the Portal across Your devices.
    • To send promotional materials from Us or on behalf of Our affiliates and trusted third parties.
    • For any other purposes disclosed to You at the time of information collection or as per Your consent.
    b. Customer Communication

    If You have provided Us Your information, We may use it to:

    • Contact You for service feedback.
    • Process payment instructions through independent third-party service providers such as payment gateways, banks, or financial institutions.
    c. Data Sharing and Consent

    We do not sell or rent Your Personal Information to anyone, for any reason, at any time. However, We may share Your Personal Information with Our affiliates and business partners. We will always seek Your consent when legally required. We may process Your Personal Information without Your knowledge or consent only when mandated by Applicable Laws.

    d. Analytics and Cookies

    We use Google Analytics cookies to help improve Our Portal by collecting and reporting information on how You use it. The cookies collect data in a way that does not directly identify anyone. We also use cookies to collect aggregated information to understand Portal usage patterns and customize the experience for You. We ensure compliance with Google Analytics’ terms and conditions.

    3. SHARING YOUR INFORMATION

    When We disclose Personal Information for a business purpose, We enter into formal agreements that describe the purpose and require the recipient to maintain confidentiality and not use the information for any purpose other than performing the contractual obligations.

    We want You to be aware of the circumstances under which and with whom We might divulge the data we gather for business purposes. Your information might be shared with others who have a legitimate purpose for processing and accessing it in the following ways:

    a. Legal Reasons

    We may disclose your information to comply with legal obligations such as responding to court orders, government inquiries, or to protect our rights, users, and the public.

    b. Business Transfers

    Your information may be shared during business transactions such as mergers, acquisitions, or reorganizations.

    c. Service Providers and Business Partners

    We share information with partners for business purposes including payment processing, hosting, analytics, and marketing. All partners are bound by confidentiality obligations.

    d. Third Parties
    • We may disclose aggregated or non-personal data for analytics or reports.
    • We may engage third parties for customer support and web analytics.
    • Affiliates and subsidiaries may access data to enhance services.
    • We will seek your consent before sharing Personal Information for other purposes.

    4. Legal Basis for Processing of Your Personal Information

    Our legal basis for collecting, using, and sharing the Personal Information described above will depend on the Personal Information concerned and the context in which we collect it. However, we will normally collect and/or process your Personal Information pursuant to one or more of the following legal bases:

    • a. The processing is in our legitimate interests which do not override your data protection interests or fundamental rights and freedoms.
    • b. The processing is necessary to perform a contract with you.
    • c. The processing is necessary to comply with our legal obligations.
    • d. We may also seek your consent to process or retain your Personal Information in certain, limited circumstances that we clearly identify to you.
    • e. In some limited cases, we may need the Personal Information to protect your vital interests or those of another person; for example, we may need to share your Personal Information with third parties for security reasons (when we believe in good faith that disclosure is necessary to protect our rights, protect your or others’ safety, to investigate fraud, or respond to a related government request).

    If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and let you know whether the provision of your Personal Information is mandatory or not (as well as the possible consequences if you do not provide it).

    Similarly, if we collect and use your Personal Information in reliance on our legitimate interests (or those of a third party) that are not listed above, we will make clear to you at the relevant time what those legitimate interests are. If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided in the “Contact Us” clause below.

    5. India – Resident Specific Rights under SPDI

    In certain circumstances, you have the right to access the Personal Information that we hold about you and to correct, update, or request deletion of your Personal Information. Prior to the fulfilment of your request concerning your Personal Information, we will ask you to verify your identity before we can act upon your request. You have the following rights:

    • i. The right to request proper rectification, removal, or restriction of your Personal Information.
    • ii. The right to require free of charge (1) confirmation of whether we process your Personal Information and (2) access to a copy of the Personal Information retained.
    • iii. The right to take legal actions in relation to any breach of your rights regarding the processing of the Personal Information, as well as to lodge complaints before the competent data protection regulators.
    • iv. The right not to be subject to any automatic individual decisions which produce legal effects on you or similarly significantly affect you.
    • v. Where the processing of your Personal Information is based on your consent, the right to withdraw your consent at any time without impact to data processing activities that have taken place before such withdrawal or to any other existing legal justification of the processing activity in question.
    • vi. Where processing of your Personal Information is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the Personal Information concerning you in a structured, commonly used, and machine-readable format or to have your Personal Information transmitted directly to another company, where technically feasible (data portability).

      • b. As far as We process Your Personal Information on the basis of Our legitimate interests, You can object to processing at any time. You can find a detailed description of Our processing activities and the legal basis in the clauses above. If You object to such processing, We ask You to state the grounds of Your objection in order for Us to examine the processing of Your Personal Information and decide whether to adjust the processing accordingly

      6. Security

      a. We follow generally accepted standards to protect the Personal Information submitted to Us, both during transmission and once We receive it. Since no method of transmission over the Internet, or method of electronic storage, is 100% secure, therefore, We cannot guarantee its absolute security. If You have any questions about security on Our Portal, you can contact us at [email protected].

      b. We use a combination of firewalls, encryption techniques and authentication procedures, among others, to maintain the security of Your online session and to protect Our online accounts and systems from unauthorized access.

      c. When You register for the Service, We require a password from You for Your privacy. We transmit Your login ID via email to You.

      d. Our servers are in secure facilities where access requires multiple levels of authentication, including an identity card and biometrics recognition procedures. Security personnel monitor the facilities 7 days a week, 24 hours a day.

      e. Our databases are protected from general employee access both physically and logically. We encrypt Your Service password so that Your password cannot be recovered, even by Us. All backup drives and tapes also are encrypted.

      f. We enforce physical access controls to areas where Your Personal Information is stored or processed. We permit only authorized employees who are trained in the proper handling of customer information, to have access to aforesaid Personal Information.

      g. We shall also instruct all Our service providers, business partners, consultants, employees, and advisors given access to Your Personal Information to maintain confidentiality and to refrain from making unauthorized copies or commercially exploiting it. We shall maintain appropriate written agreements with our employees and consultants who have access to Your Personal Information to maintain confidentiality.

      7. Storage and Transfer of Information

      a. We make no representation or warranty with respect to any duty to permanently store any information You may provide or that We otherwise collect about You except as required by the Applicable Laws.

      b. We strive to keep Our processing activities with respect to Your Personal Information as limited as possible. In the absence of specific retention periods set out in this Policy, Your Personal Information will be retained only for as long as We need it to fulfil the purpose for which We have collected it and, if applicable, as long as required by statutory retention requirements and/or according to the timeframes set forth under the Applicable Laws.

      We make no representation or warranty with respect to any duty to permanently store any information You may provide or that We otherwise collect about You except as required under the Applicable Laws. Please note that statutory storage obligations or the need for legal actions that may arise from misconduct within the Portal can lead to a longer retention of Your Personal Information.

      By using the Portal and providing Us with information (including Personal Information), You waive any claims that may arise under Your own or any other local or national laws, rules, or regulations or international treaties. This Policy applies to Your information for as long as Your information is in Our possession, even if You terminate or discontinue Your use of the Portal.

      c. In the event that We undergo re-organization, are sold to, or merged with a third party, or sell all or substantially all of Our assets, any Personal Information We hold about You may be transferred to that reorganized entity or third party in compliance with applicable law.

      d. In the unlikely event of Our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, We may not be able to control how Your Personal Information is treated, transferred, or used.

      8. Link to Third Party Websites

      The Portal may include links to other websites, mobile applications, or services (“Third Party Sites”), whose privacy practices may differ from those set forth herein. Such links are not an endorsement by Us of those third-party Sites and/or the products or services they offer. If You visit Third Party Sites or submit Information to any of those Third-Party Sites, Your visit and Information is governed by their privacy policy.

      We encourage You to carefully read the privacy policy of any Third-Party Site You visit, as it may differ substantially from that of this Policy. We make no representations or warranties with respect to, nor are We responsible for the privacy policies of, any Third-Party Sites. If You decide to click on any such links or access any Third- Party Sites appearing on the Portal, You do so at Your own risk.

      9. Intimation by You Regarding Change in Personal Information

      If Your Personal Information provided to Us when You had registered yourself in Our Portal changes, You must update it as soon as possible. To review and update Your Personal Information, please send an email to [email protected].

      10. Email Notifications and Opt-Out

      We maintain a strict “no-spam” policy. By accepting the Terms of Use and this Policy, You expressly agree that We may use Your information to contact You by email in order to deliver You information that is relevant to Your use of the Portal such as administrative notices, product/service enhancements or newsletters, or that, in some cases, is targeted to Your interests.

      In the event of an intellectual property claim, We may transfer Your contact details with the claimant for contacting You to resolve the infringement claim directly with You. You may choose to stop receiving these email communications from Us by following the “unsubscribe” instructions included in such communications or by sending an email to [email protected].

      If a third-party vendor provides such newsletters, You may unsubscribe in accordance with the instructions provided by such third party. If You are having problems unsubscribing, please contact Us at [email protected] and You will be removed within seven (7) business days.

      11. Confidentiality of Your Login ID and Password

      You are responsible for maintaining the security of Your login ID and Password and must not provide these credentials to any third party. If You believe that they have been stolen or made known to others, You must contact Us immediately at [email protected].

      We are not responsible if someone else accesses Your account through the login credentials obtained from You or through a violation by You of this Policy or Our Terms of Use. If You have any security related concern, please contact Us at [email protected]. We will work closely with You to ensure a rapid and personal response to Your concerns.

      12. Privacy Officer / Data Protection Officer

      In case of any complaints or concerns with regard to the use, processing, and disclosure of Personal Information provided by You, or enquiries and feedback on Our data protection policies and procedures, and/or any breach of this Policy or any applicable laws should immediately be informed to [email protected].

      13. Changes to Policy

      We may update this Policy from time to time. When We update the Policy, We will notify You by updating the “Last Updated” date at the top of this Policy and posting the new Policy, as well as providing any other notice required by applicable laws. We recommend that You review the Policy each time You visit the Portal to stay informed of Our privacy practices.

      14. Contact Us

      In the event that You wish to make a complaint or request concerning Your Personal Information or Our privacy practices, or have questions, concerns, or comments about this Policy, please contact Us in the first instance at [email protected] and We will endeavor to deal with Your request as soon as possible.

      You can also write to Us at [email protected]. This is without prejudice to Your right to launch a claim with Your data protection authority or follow the dispute process set forth in the Terms of Use.