Privacy Policy

1. Introduction and applicability

1.1 This Privacy Policy ("Policy") describes how the organisation operating the Pon Pure Chemicals Group corporate website at www.pure-chemical.com ("Website") collects, uses, discloses, retains and safeguards personal data. For this Policy, "Pon Pure", "we", "us" and "our" refer to the relevant Pon Pure group entity identified in clause 17. Website use is separately governed by our Terms & Conditions, available at https://www.pure-chemical.com/terms-and-conditions.

1.2 This Policy applies to individuals visiting the Website; submitting product, quotation, distribution, partnership, logistics, technical-support or general enquiries; registering for events or communications; applying for employment; or using our AI-powered chat assistant, Lyra, and related digital contact channels. It applies to personal data collected through these interactions, including follow-up email, telephone or messaging communications related to a request.

1.3 Separate websites, transactional platforms or applications operated by group companies, including ibuychemikals.com, vooki.in, alonge.in and ponpurelogistics.com may have their own privacy policies. Their collection and verification arrangements are not automatically incorporated into this corporate Website Policy. The Website Terms & Conditions do not supersede the separate transaction terms of any e-commerce platform.

1.4 This Policy is issued in accordance with applicable Indian privacy and cybersecurity law, including the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011; the directions issued by the Indian Computer Emergency Response Team dated 28 April 2022; and the Digital Personal Data Protection Act, 2023 read with the Digital Personal Data Protection Rules, 2025. The provisions of that Act and those Rules commence in phases: the institutional provisions and the Data Protection Board took effect on 13 November 2025, the Consent Manager provisions on 13 November 2026, and the principal processing obligations, including notice, consent, data principal rights and penalties, on 13 May 2027. Where the law of another jurisdiction applies to a particular visitor or interaction, additional requirements may apply.

2. Definitions

2.1 "Personal Data" means any data about an individual who is identifiable by or in relation to that data. "Processing", "Data Principal", "Data Fiduciary" and "Data Processor" have the meanings given in the Digital Personal Data Protection Act, 2023. Information about a company or other legal entity is not Personal Data. The details of a named individual acting in a business capacity, including a business contact’s name, job title, work email address and telephone number, are Personal Data and are treated as such under this Policy.

2.2 "Consent" means a free, specific, informed, unconditional and unambiguous indication of agreement given by a clear affirmative action, which signifies agreement to the processing of Personal Data for the specified purpose and is limited to the Personal Data necessary for that purpose. "Non-essential cookies" means analytics, advertising and optional functionality technologies that are not required to deliver the service the visitor has requested; this is an operational classification used to manage visitor choice and does not import any statutory exemption.

3. Personal Data we collect

3.1 The categories below depend on how you interact with the Website. We ask only for details reasonably required for the relevant purpose.

3.2 Where you have given consent to receive marketing communications, we may share the Personal Data you provide with other Pon Pure group companies and brands so that they may contact you for the purposes to which you consented. We do not share your details with group companies for marketing where you have not consented. Sharing for the purpose of answering an enquiry is dealt with separately in clause 8.1.

3.3 Do not submit personal financial credentials, identity-document numbers, special-category or sensitive details, confidential formulas, unpublished technical specifications or other information not requested through general website forms or Lyra. If a specific regulated transaction requires additional information, it should be collected through an appropriately disclosed and secured process.

3.4 We may receive the professional contact details of business contacts from their employer, other group entities, events, authorised business partners or public business sources, where permitted by law, and we will give an appropriate notice where one is required. This clause applies to business contacts. The sources we use in recruitment, and the checks we carry out on candidates, are described in clause 13.

4. Purposes of processing

4.1 We use Personal Data for specified purposes: (a) responding to enquiries and preparing quotations; (b) routing an enquiry to the relevant business division, regional office or authorised sales representative; (c) communicating about product specifications, availability, samples, services and technical meetings; (d) managing customer, supplier, distributor and other business relationships; (e) evaluating employment applications and communicating with candidates; (f) administering events, requested subscriptions and service communications; (g) running, securing, diagnosing and improving the Website; (h) investigating misuse or security incidents; and (i) complying with legal obligations and lawful requests.

4.2 Where you separately opt in, we may send marketing communications about Pon Pure products, applications, events and updates by the channels you select, or use optional analytics and advertising technologies to measure or tailor campaigns. We do not treat submission of an ordinary enquiry as blanket consent to unrelated marketing.

4.3 If processing is based on consent, we provide the relevant notice at or before collection and request an affirmative choice. Where another processing ground is available under applicable law, we rely on that ground only to the extent its statutory conditions are met.

5. Notices, consent and withdrawal

5.1 At relevant collection points, our notice will identify the Personal Data requested, the specified purposes, the means to exercise rights or withdraw consent, and how to raise grievances. Required fields will be marked, and consent for optional marketing will be distinct from the action needed to submit an enquiry.

5.2 Optional choices are unticked by default. You may decline marketing or non-essential tracking without losing the ability to browse the Website or make an ordinary enquiry. Your decision may affect only the optional functionality concerned.

5.3 You may withdraw consent using an unsubscribe link, the Website’s privacy or cookie settings where provided, or by contacting the privacy contact in clause 17. Withdrawal applies prospectively; records may still be retained or used to the extent required or permitted by applicable law. We will make withdrawal no more difficult than providing consent where the relevant statutory duty applies.

6. Cookies, analytics and advertising

6.1 The Website may use: (a) strictly necessary cookies for security, session and consent preferences; (b) functionality cookies for optional features; (c) analytics cookies to understand traffic and performance; and (d) advertising cookies or pixels to measure campaigns or show relevant advertising, where implemented.

6.2 We provide a cookie choice mechanism that permits visitors to accept, reject and revise non-essential categories. Non-essential tags are not activated before the required choice is recorded. Visitors may also manage cookies through browser controls, though disabling essential cookies may impair the Website.

6.3 The cookie list, providers, identifiers and storage periods are displayed through a Cookie Policy or privacy-preference centre, which is linked from the cookie banner and from this Policy, and which is kept current.

6.4 We keep a record of the cookie choices you make, including the categories accepted or rejected, the version of the notice shown and the date and time of your choice, so that your preferences can be honoured and demonstrated.

7. Lyra – our AI-powered chat assistant

7.1 The Website may offer Lyra, our AI-enabled chat assistant, to help visitors find corporate, product and service information. Interactions may include chat text, session details, technical metadata and any contact information you voluntarily provide for follow-up. Where an external technology provider processes these records, we will apply appropriate contractual and security controls.

7.2 Lyra’s responses are automated and may be incomplete or incorrect. They are general information, not binding quotations, product warranties, or professional chemical-handling, safety, legal or regulatory advice. Before use of any chemical, consult the current product Safety Data Sheet and Technical Data Sheet and obtain confirmation from authorised company personnel where necessary.

7.3 Avoid entering confidential business information or sensitive personal information into Lyra. Where chats are retained for service quality, security or response follow-up, we will limit access and retention as described in this Policy and in any chat-specific notice.

8. Sharing of Personal Data

8.1 We may share relevant information with the appropriate Pon Pure group company or team handling an enquiry; authorised sales or distribution representatives where needed to respond; and contracted providers of hosting, email, CRM, recruitment systems, analytics, security, the Lyra chat assistant, communications and related support services.

8.2 Providers processing Personal Data on our behalf are expected to use it for documented purposes, implement appropriate security measures and comply with applicable contractual requirements. We may also disclose data to auditors, advisers, regulators, courts or law enforcement authorities when lawfully required or otherwise permitted by law.

8.3 We do not sell or rent Personal Data as a stand-alone commercial database. We do not share a visitor’s contact details with unrelated advertisers for their own direct marketing without a lawful basis and appropriate notice or consent.

8.4 Where you accept advertising or analytics cookies, the providers of those technologies may receive data about your use of the Website and may process it for their own purposes as well as ours. The providers in use, and links to their own privacy information, are listed in the Cookie Policy referred to in clause 6.3.

9. International storage and transfers

9.1 Pon Pure operates with international business contacts. Personal Data may be accessed or processed by authorised group teams or service providers in India or other countries where relevant services and business functions are located.

9.2 Cross-border transfers will be subject to applicable Indian restrictions when operative and to any other law that governs the relevant data. Where EU/UK law applies, required transfer mechanisms and additional disclosures will be addressed as appropriate; this Policy does not imply that GDPR applies to every Website visit.

10. Information security and breach response

10.1 We use reasonable technical and organisational measures appropriate to the risks, including secure communications, restricted access, authentication, security monitoring, backup and incident handling, as implemented in our systems. Access to enquiries and candidate records is limited to personnel and providers with a business need.

10.2 No internet transmission or storage system can be guaranteed completely secure. If a relevant breach occurs, we will investigate, contain and provide any required notices to individuals, regulators or CERT-In under the requirements and deadlines applicable to the incident at that time.

11. Retention and deletion

11.1 We retain Personal Data only for the purpose for which it was collected, a lawful related purpose or a statutory retention requirement. Enquiry and customer relationship records, candidate applications, security logs, cookie preferences and chat transcripts can have different retention periods.

11.2 We will establish documented schedules for each category based on operational needs, applicable Indian recordkeeping and cybersecurity directions, and relevant DPDP requirements when in force. On expiry, records are securely deleted or anonymised unless legally required for a longer period.

11.3 Unless a longer period is required by law, we retain job applications for [•] months from the close of the relevant recruitment, security and access logs for the period required under applicable cybersecurity directions, and cookie consent records for [•] months.

12. Your privacy choices and rights

12.1 Subject to the provisions of law applicable at the time of your request, you may ask for information about the Personal Data we process, request correction, completion or updating, request erasure where applicable, withdraw consent, and lodge a grievance.

12.2 When the corresponding provisions of the Digital Personal Data Protection Act, 2023 commence, expected on 13 May 2027, eligible Data Principals will have statutory rights including access to prescribed information, correction and erasure, grievance redressal and nomination in case of death or incapacity, subject to statutory conditions and exceptions.

12.3 To exercise a right, contact the address in clause 17 and provide enough information to identify the relevant interaction. We may take reasonable steps to verify your identity and will respond in accordance with applicable timelines. Some data cannot be erased immediately if a legal obligation to retain it applies.

13. Recruitment and career submissions

13.1 When you apply for a role, we use the information you provide to assess suitability, schedule interviews, communicate decisions, conduct permitted reference checks and maintain recruitment records. Relevant applications may be shared with authorised hiring managers and recruitment support providers.

13.2 If you are not selected, we retain your application for the period stated in clause 11.3 so that we may consider you for other suitable vacancies. If you would prefer us not to, or would prefer not to receive talent-pool communications, tell us at the contact in clause 17 and we will remove your details.

13.3 In recruitment we may also collect Personal Data about you from sources other than you: referees you nominate; background verification agencies engaged by us; recruitment consultants; and professional or job-portal profiles you have made available. We will not contact your current employer without your consent. Where we engage a background verification agency, we will tell you before the check begins and what it covers.

13.4 We ask applicants not to include sensitive personal information that we have not requested. Where we are required to collect particular information, such as category details for statutory reporting or health information to arrange reasonable adjustments, we will tell you why it is needed and how it will be used.

14. Children

14.1 The Website primarily serves industrial, professional and business audiences and is not designed to solicit Personal Data from persons under 18. We do not knowingly use children’s Personal Data for targeted advertising or behavioural monitoring. If we learn that data from a child has been collected inappropriately, we will address it under applicable law.

15. Third-party sites and embedded services

15.1 The Website may link to separate group sites, social networks, maps, video platforms or external websites. When you follow a link, that destination’s own terms and privacy practices may apply. Optional third-party embeds are enabled in a way consistent with our consent mechanism and the provider’s actual data flows.

16. Changes to this Policy

16.1 We may revise this Policy for changes in law, technology, business practices or Website functions. The current version and date will appear on the Website. Where a material change requires a new notice or fresh consent, we will provide it before the relevant changed processing occurs.

17. Privacy contact and grievance redressal

17.1 Privacy enquiries, withdrawal requests and grievances may be directed to:

17.2 We will acknowledge and resolve grievances in accordance with requirements applicable to the particular request. Where the DPDP statutory complaint mechanism is operative and applicable, a Data Principal may approach the Data Protection Board of India after using the company grievance process as required by law.

18. Governing law

18.1 This Policy is governed by applicable laws of India, without limiting mandatory rights or remedies available to a Data Principal under other applicable privacy laws or before the competent statutory authority.