1. How we handle your personal data

ALF takes privacy and the protection of integrity seriously. When you interact with ALF, you should feel confident that ALF respects your privacy when processing information that identifies you as an individual (“Personal Data”) and adheres to applicable laws and regulations, including but not limited to the General Data Protection Regulation (the “GDPR”). ALF collects a range of Personal Data about you when you interact with ALF, for example when you visit the ALF website, use online or web services, participate at an ALF event, visit our premises, purchase and/or sell goods and services to/from ALF.

ALF invites you to carefully read this Privacy Policy which describes how ALF shall process Personal Data, including categories of Personal Data processed, the nature and the methods of the processing, the data retention period, any recipients, transfer to third countries as well as your data subject rights.
In addition to this Privacy Policy, you can also find specific Privacy Notices below (or any specific Privacy Notice for the relevant interaction) that may be relevant to you depending on your role and the context in which you come into contact with ALF.

2. Data Controller

Data Controller (“Controller”) means the ALF Legal Entity which, alone or jointly with another one, determines the purposes and means of the processing of personal data.
ALF is primarily responsible as Controller for the processing of Personal Data within the scope of this Privacy Policy if nothing else is stated in a specific Privacy Notice. The responsibility for the privacy of your data may be shared with subsidiaries and affiliates of the ALF Group. The information provided in this Privacy Policy applies if ALF has not communicated otherwise at the time of the collection of the Personal Data. Please contact us if you have any questions or concerns, or if you want to exercise any of your legal rights in relation to our processing of your Personal Data. See contact details below:

Address: Mavdi Bypass Main Road,
Soldier Bakery Street, Rajkot – 360004 (GUJ), India
Phone: +91 9099993739 / +91 9825078365

3. What personal information we collect

When you interact with ALF, we may collect Personal Data directly or indirectly relates to you as a natural living person, it means:
– Identification and contact details (such as name, surname, date of birth, e-mail address, telephone number, etc.), in order for you to be contacted, to receive a specific service, or as part of business relationship, or as visitor of our plants.
– Professional information (such as your curriculum vitae, your job profile, etc.).
– Browsing data, IT identification, or data arising from you interacting with our website (such as IP address, location, country, access time on the website, pages visited from the user, system log).
– Data collected via the cookies installed on your computer or mobile device (please refer to the Cookie Policy, which explains the use of the web tracking via our website).
– Images and videos.
– Contributions you have provided to ALF, via survey or shared on the ALF social network pages managed directly by the third parties providing the services.
– Other personal information you provide us during an interaction.

In some cases, ALF can collect Personal Data about you from a third party (e.g., you have addressed us, or a third party who meets with ALF personnel, visits ALF’s websites, opens newsletters, downloads ALF materials, uses ALF’s products and services), or from public records. We protect Personal Data obtained from such sources according to the practices described in this Privacy Policy.

ALF does not generally process special categories of Personal Data, nevertheless ALF may be aware about more sensitive information. In these cases, you will be informed, and such Personal Data may be processed if requested by law, and/or where you have given your explicit consent.

4. Why we collect your Personal Data and legal basis of processing

All processes of Personal Data have a lawful legal basis, that could be:
• Contract. The data subject has a contract or is about to enter into a contract with ALF.
• Legal obligation. There are laws and regulations that oblige ALF to process certain Personal Data in our activities.
• Legitimate interest. When the processing of your Personal Data is necessary for the purpose pursued by the Controller, or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of Personal Data.
• Consent. The data subject has consented to the Personal Data processing.

On a general basis, ALF collects and processes Personal Data for the following purposes:

PURPOSE	DATA COLLECTED	LEGAL BASIS
Registration on the website, and applications enabling users to access to different kind of services on a voluntary base	Identification, contact details and professional information	Perform of an agreement, also under pre-contractual measures to which the data subject is party. Legitimate interest of ALF to improve the user experience and the content of such services.
Analysis: compiling statistics related to patterns and trends of browsing on ALF web pages or use of other applications or software and to analyze sales data and how a Partner interacts with ALF’s products and services	Information collected via cookies	Legitimate interest of ALF to improve the user experience and the content of such products and services. Consent of the data subject which can be withdrawn at any time.
Profiling: analyzing and predicting user preferences, habits, choices to offer products, services, promotions, and customized commercial communications	Identification, browsing data and information collected via cookies	Legitimate interest of ALF to maintain and improve our business operations and customer experience. Consent of the data subject which can be withdrawn at any time.
Managing requests when you contact us regarding ALF’s products and services, or other requests	Identification and contact details and professional information	Legitimate interest of ALF to maintain and improve our business operations and user experience.
Management of the relationship with business entities and consultants	Identification and contact details and professional information	Perform of a contract also under pre-contractual measures to which the data subject is party.
Marketing and commercial communications, as well as to invite you to take part in our promotional initiatives, to participate in our events and to register for our newsletter	Identification and contact details, images, and videos	Consent of the data subject which can be withdrawn at any time. Our legitimate interest in managing relationships and events.
Asking for your feedback; performing surveys; giving comments also via social network (Access via the use of social networks may involve your personal data processing based on their policies)	Identification, contact details, professional information, browsing data and information collected via cookies, images, videos, and contributions	Your consent to receive surveys, which can be withdrawn at any time. Our legitimate interest in improving our business operations and customer experience.
Managing mandatory safety requirements, also visiting our premises	Identification and contact details, images, and videos	Legitimate interest of ALF to be compliant with internal security and safety procedures.
Advertising, taking part in physical events, fairs, and exhibitions	Identification and contact details, images, and videos	Legitimate interest of ALF to provide more relevant advertising and promote initiatives.
Career and job application	Identification, contact details and professional information, photos, other information the candidate would like to provide	Perform a contract (if specifically entered into by ALF as part of the employment relationship), also under pre-contractual or pre-employment measures. Your consent to manage and store information, which can be withdrawn at any time.
Whistleblowing and other reporting channels	All personal information you would like to provide to us	Legal obligation

In addition to this Privacy Policy, if more specific information is necessary about processing of Personal Data, please refer to the relevant Privacy Notices.

5. The nature and methods of the processing

The nature of the processing means any operation such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of data.

The processing of data is carried out through IT procedures and automated means, or hard copies, by internal or external personnel, specifically appointed and committed to confidentiality. The data is protected by the technical and organizational security measures aimed at preventing unauthorized access, data loss, breach, or destruction.
Furthermore, ALF applies standard security practices and works with companies providing leading security services to technically protect your Personal Data.

The failure to provide your Personal Data may result in the impossibility to use certain services or achieve the purpose for which data is collected.

6. Sharing of Personal Data

Your Personal Data may be shared with various entities for business, organizational, legal, or other specific reasons. In any case, we share only Personal Data necessary to reach the relevant purposes, as described below.

ALF is an international company, so your Personal Data may be shared with and transferred to other companies of the ALF Group worldwide for different purposes, mainly: operation of the website; IT system activities; business support; analysis, profiling, and marketing activities; career and job applications; reporting channels and data storage.

ALF Group Legal Entities

• ALF is an international company, so your Personal Data may be shared with and transferred to other companies of the ALF Group worldwide for different purposes, mainly: operation of the website; IT system activities; business support; analysis, profiling, and marketing activities; career and job applications; reporting channels and data storage.
• Any transfers of your Personal Data between ALF affiliates will be governed by an intracompany agreement based on EU approved Standard Contractual Clauses, or such other mechanisms as have been recognized by the relevant authorities.
• The ALF Legal Entities act as Controllers, or Processors.

Third Parties

ALF processes your Personal Data either directly as data controller or by asking third parties to process Personal Data on ALF’s behalf (delegation) under specific contractual obligations. In general, ALF delegates some tasks to IT suppliers for systems support and data storing.

ALF may also share some of your Personal Data with other third parties that act more independently from us and process your Personal Data as controllers of your Personal Data, according to local legislations.

ALF may also be required to share your Personal Data with other third parties, including public and governmental authorities or insurance companies, and situations where such disclosure is required by law, disputes, requests/orders/decisions, or to exercise a Company right before judicial authorities.

7. Transfer of Personal Data to third countries

In case Personal Data of European citizens is transferred outside of the EU/EEA, we perform a Transfer Impact Assessment, and we use appropriate safeguards to guarantee a high level of protection according to GDPR; it means:
– Confirming if the relevant country is on the list of adequacy decisions provided by the European Commission.
– Subscribing agreements based on the Standard Contractual Clauses issued by the European Commission and on other possible regulations if required by relevant authorities.
– Ensuring the implementation of adequate technical and organizational security measures.

For transfers of Personal Data involving ALF Legal Entities to which the EU Data Protection legislation does not apply, the applicable rules shall be enacted and the ALF internal procedures will be adapted and followed.

8. Retention of Personal Data

ALF retains your Personal Data only as long as it is necessary to fulfil the purposes for which it was collected. The current retention periods are set on a purpose basis or legal grounds, and the information is available in the specific Privacy Notices that may be relevant to you depending on your role and the context in which you interact with ALF.

On a general basis, Personal Data you have provided registering to the Website will be retained for the entire period that you are registered, but after a period of inactivity depending on the application, we will reach out to you to understand if you are still interested in receiving our services. However, at any time, you may either request to be forgotten, or you can Delete Your Account under the dedicated menu.

Regarding Data collected via the cookies installed on your computer or mobile device more details are available in the cookie policy/banner.
Data collected to manage and answer requests about the products and services will be stored for the period necessary to carry out the requests and will subsequently be cancelled if there is no further contact, except for administrative requirements.

When the purposes of processing your Personal Data have been accomplished, the information is deleted or stored in a form that prevents the identification of the concerned people.

However, ALF retains Personal Data over longer periods of time for compliance reasons, e.g., book-keeping purposes, or for as long as there are rights or obligations according to an agreement.

Furthermore, ALF retains Personal Data to be able to handle claims and to protect ALF’s legal rights and other obligations required of ALF according to applicable laws.

9. Your rights

You have the right to know if we process Personal Data about you. If we do, you also have the right to:
– Request and receive information about the Personal Data we process and why we do it. In addition, you may receive a copy of all Personal Data we have about you together with information on how the data have been collected, processed, shared, etc.
– Have erroneous data corrected. If the Personal Data we process about you is incorrect, you have the right to have it corrected. You also have the right to supplement incomplete Personal Data with additional information that may be needed for the Personal Data to be correct.
– Have data deleted. In some cases, you have the right to have your Personal Data deleted, such as: (i) if data is no longer needed for the purpose for which it was collected; (ii) you oppose use that is based on our legitimate interest, and we cannot show compelling grounds that outweigh your interests; (iii) the Personal Data has been used illegally; (iv) deletion is required to fulfil a legal obligation.
– Request of restriction. It applies: (i) when you believe the Personal Data is incorrect and you have requested correction. If so, you can also request that we limit our use while we investigate if the Personal Data is correct or not; (ii) if the processing is illegal but you do not want the Personal Data to be deleted; (iii) when we no longer need the Personal Data for the purposes for which we collected it, but you need it to be able to establish, assert or defend legal claims; (iv) if you object to the processing. If so, you can request that we limit our processing while we investigate if our interest in processing your Personal Data outweighs your interests. Even if you have asked us to restrict our processing of your Personal Data, we have the right to process it for storage, if we have obtained your consent to use it. We may also use the information to assert or defend legal claims or to protect someone else’s rights or use the information for reasons relating to an important public interest.
– Data portability. You have the right to receive your Personal Data, that you have provided us with, in a structured, commonly used, and machine-readable format, and transfer this Personal Data to another controller, provided that the processing is based on a contract to which you are a party.
– Objecting to data use. You have the right to object to processing that is based on our legitimate interest. If you object to the processing, we will, based on your situation, evaluate if our interests in using the data outweigh your interests in the data not being used for that purpose. This means we will no longer process the Personal Data for the purpose that you object to, unless we can demonstrate compelling legitimate grounds that outweigh your rights and freedoms. However, we may still use the Personal Data to establish, exercise or defend legal claims. If you object to the processing, you also have the right to request that we restrict our processing during the time we investigate the matter.
Lodge a complaint. Please let us know if you do not agree with the way we are processing your Personal Data, you can lodge a complaint, directly or via a legal representative if required, writing an e-mail to support@alfbearings.com. Obviously, you can always lodge a complaint with the supervisory authority in the country where you live, work or where you believe the infringement has taken place, but in this case, we would appreciate it if you pre-inform us to allow us to try to solve the matter together.
Consent. To the extent we are processing your Personal Data based on your consent, you have the right to withdraw your consent at any time. Such withdrawal does not affect the legality of the processing of data before the consent was withdrawn. You can withdraw your consent by following the instructions mentioned in the consent banner or following the procedures of the specific Privacy Notices Visit our Cookie banner and Policy for more information on how you can change your cookie preferences and settings.

10. Contact information

For any queries, complaints or corrections related to ALF’s processing of your Personal Data including where you find ALF not to have acted according to appliable laws, you are welcome to contact ALF by using the information below:
The Data Protection Officer is part of ALF’s Ethics and Compliance department, directly reporting to the ALF Group General Counsel and may be reached by:
Email: support@alfbearings.com
Address: Mavdi Bypass Main Road,
Soldier Bakery Street, Rajkot – 360004 (GUJ), India

11. Updates to the ALF Privacy information

ALF may update the information displayed on this Privacy Policy and the Privacy Notices from time to time and we document the date of the last revision at the bottom of the document. So, we encourage you to check the privacy information regularly.