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Last updated on: 20 July 2026

This privacy policy (“Policy”) explains how TVS Supply Chain Solutions Limited, having registered office at 10, Jawahar Road, Chokkikulam, Madurai, Tamil Nadu – 625002, India (“We”, “Us”, “Our”, “TVS SCS”) Processes Personal Data collected from natural persons (“You”), as specified in clause 2 below, as a Controller when You use the Idea360 mobile application (“App”). The App is an internal enterprise platform through which authorised employees and contract staff of TVS SCS submit, track, review, and manage innovation ideas and suggestions.

1. DEFINITIONS

1.1 “Controller” means the natural or legal person, public authority, agency, or other body which alone or jointly with others determines the purposes and means of the Processing of Personal Data (referred to in some jurisdictions as a “Data Fiduciary”).

1.2 “Personal Data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier, or to one or more factors specific to the identity of that natural person.

1.3 “Process/Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, alignment or combination, restriction, erasure, or destruction.

1.4 “User” means a designated user of the App, being an authorised employee of TVS SCS or a contract employee holding a valid TVS SCS email address.

1.5 “Applicable Data Protection Laws” means the data protection and privacy laws and regulations applicable to Our Processing of Your Personal Data in connection with the App, as amended from time to time.

2. HOW WE COLLECT, USE, AND SHARE YOUR PERSONAL DATA

2.1 PERSONAL DATA THAT YOU PROVIDE US

When You are a(n) What Personal Data We Collect How We Use Your Personal Data Whom We Share Your Personal Data With
User who submits ideas or suggestions through the App, including drafts, comments, feedback, review actions, and file or image attachments. Information You provide as part of the submission — idea descriptions, categorisation, comments, feedback, and any attachments (including photos captured using the camera, where You choose to attach them).
  • To process, manage, and track idea and suggestion submissions.
  • To operate the structured review workflow (assignment, approval, rejection, resolution, closure).
  • To enable role-based tracking, search, and status visibility.
 Only within the TVS SCS organisation, on a need-to-know, role-based basis (e.g., reviewers, administrators, and managers involved in the innovation workflow).
User who contacts Us or raises a support request relating to the App. Your contact information, such as Your name and corporate email address, and the content of Your request.
  • To respond to Your comments, queries, or questions.
  • To provide technical and user support.
 Only within the TVS SCS organisation (IT Department / Information Security Team and support personnel).

2.2 PERSONAL DATA THAT WE COLLECT NOT PROVIDED DIRECTLY BY YOU

When You are a(n) What Personal Data We Collect How We Use Your Personal Data Whom We Share Your Personal Data With
User whose data is available with Us in Our corporate systems. The App does not require independent User registration. You sign in using Your TVS SCS corporate credentials through Microsoft Azure AD (Entra ID) Single Sign-On, and We use Personal Data already available with Us — Your name, corporate email address, employee ID, designation, and organisational data (entity, department, team, access level, and position in the organisational hierarchy).
  • To create and set up Your User account on the App.
  • To verify Your identity and authorise Your access.
  • To manage user accounts, roles, and TVS SCS’s organisational hierarchy within the App.
  • To communicate service updates, application changes, or operational alerts related to Your account.
 Only within the TVS SCS organisation. Authentication is performed through TVS SCS’s enterprise Microsoft Azure AD environment.
User who downloads and uses the App.
  • Your device information, such as login timestamps, Internet Protocol (IP) address, operating system version, App version, and session tokens.
  • Information relating to Your use of or interaction with the App, including usage logs and activity/audit logs.

The App does NOT collect Your location (foreground or background), contacts, microphone or audio data, health, biometric, or financial data, or government identifiers.
  • To develop, improve, support, and operate the App (internal analysis of usage logs only; no external analytics).
  • To protect the App from threats, violations, and breaches.
  • To maintain audit logs for security, accountability, and compliance.
 Only within the TVS SCS organisation (IT / Information Security), for the purposes stated.

If You provide Us with any Personal Data relating to other individuals (for example, within the content of an idea submission or attachment), You represent that You have the authority to do so and, where required, have obtained the necessary consent, and You acknowledge that it may be used in accordance with this Policy. Please avoid including unnecessary personal data, Your own or anyone else’s in submissions and attachments. If You believe that Personal Data has been provided to Us improperly, please contact Us using the information in clause 9 below.

2.3 In addition to the details provided in the tables above, We may also share Your Personal Data with:

1. an entity to which We divest all or a portion of Our business, or otherwise in connection with a merger, consolidation, change in control, reorganisation, or liquidation of all or a portion of Our business;

2. law enforcement authorities, government authorities, courts, dispute resolution bodies, regulators, auditors, and any party appointed or requested by applicable regulators to carry out investigations or audits of Our activities; and

3. professional advisors who advise and assist Us in enforcing Our contracts and policies, handling Our claims, effective management of Our company, and in relation to any disputes We may become involved in.

We do not sell Your Personal Data, and We do not share it with advertisers, marketing platforms, data brokers, or external analytics providers. We do not send You marketing communications through or in connection with the App.

3. LEGAL BASIS FOR PROCESSING

3.1 Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which We collect it, in accordance with Applicable Data Protection Laws.

3.2 We will normally Process Your Personal Data where it is needed for purposes related to Your employment or engagement with TVS SCS — including the operation of internal business systems and the governance of TVS SCS’s innovation programme — where the Processing is necessary for Our legitimate business interests and not overridden by Your interests or rights, where You have voluntarily provided the Personal Data for a specified purpose, where We have Your consent, or where We have a legal obligation to Process it.

3.3 Where We rely on Your consent for any specific Processing activity, You may withdraw that consent at any time by contacting Us using the details in clause 9. Withdrawal will not affect the lawfulness of Processing carried out before withdrawal, and may limit App features dependent on that Processing. If You have questions concerning the legal basis on which We Process Your Personal Data, please contact Us using the details provided under clause 9.

4. DATA STORAGE AND LOCATION

4.1 All Personal Data Processed through the App is stored on backend servers hosted in India within TVS SCS’s managed infrastructure. The App is operated for India, and Your Personal Data is not transferred outside India in connection with the App.

4.2 If TVS SCS extends the App to users or infrastructure outside India in the future, this Policy will be reviewed and updated, and any transfer safeguards required under applicable law will be put in place, before any such access or transfer takes place.

5. SECURITY OF PERSONAL DATA

We use appropriate technical and organisational measures, consistent with Applicable Data Protection Laws, to protect the Personal Data We collect and Process, including: encryption of data in transit (HTTPS/TLS 1.2 or higher); authentication via Microsoft Azure AD SSO with OAuth 2.0 and JWT-based session management; Role-Based Access Control restricting each User’s visibility and actions to their assigned role; secure API communication; secure session management; and comprehensive audit logging. If We become aware of a Personal Data breach affecting You, We will act in accordance with Applicable Data Protection Laws, including notification to the relevant authorities and affected individuals where required. If You have questions about the security of Your Personal Data, please contact Us using the details provided under clause 9.

6. RETENTION OF PERSONAL DATA

6.1 We will retain Your Personal Data for as long as reasonably necessary for the purposes for which it was collected as specified under clause 2, in accordance with TVS SCS’s records retention policy, or otherwise where permitted or required by applicable law. We will retain and use Your Personal Data as necessary to comply with Our legal obligations, resolve disputes, and enforce Our agreements.

6.2 When Your employment or engagement with TVS SCS ends, Your access to the App is deactivated as part of TVS SCS’s standard leaver process, and Your Personal Data is handled in accordance with TVS SCS’s retention policy. In the absence of a need to retain Personal Data under clause 6.1, We will either delete it or anonymise it or, if this is not possible, We will securely store Your Personal Data and isolate it from any further Processing until deletion is possible.

7. YOUR PRIVACY RIGHTS

7.1 Subject to Applicable Data Protection Laws, You are entitled to the following rights:

7.1.1 Access — You can request access to Your Personal Data and information about how it is Processed.

7.1.2 Correction and completion — You can request that We correct inaccurate or misleading Personal Data and complete incomplete Personal Data, subject to appropriate verification.

7.1.3 Erasure — You can request that We erase Personal Data that is no longer necessary for the purpose for which it was Processed, subject to certain exceptions and retention required by law.

7.1.4 Restriction and objection — You may, where provided under Applicable Data Protection Laws, request restriction of the Processing of Your Personal Data or object to certain Processing activities.

7.1.5 Grievance redressal — You can raise a grievance regarding the Processing of Your Personal Data, and We will respond within the timelines prescribed under Applicable Data Protection Laws.

7.1.6 Withdrawal of consent — where Processing is based on Your consent, You can withdraw it at any time; withdrawal will not affect the lawfulness of prior Processing or Processing based on grounds other than consent.

7.2 To exercise any of these rights, please contact Us using the details provided in clause 9. We will verify requests before acting on them and will respond within a reasonable timeframe in accordance with Applicable Data Protection Laws. We may decline a request where We are unable to verify Your identity (or an authorised agent’s authority) or where an exemption applies; where appropriate, We will explain the reason. We will not discriminate against You for exercising Your rights.

7.3 If You are not satisfied with Our response, You may lodge a complaint with the data protection authority or body having jurisdiction under Applicable Data Protection Laws, after first raising Your grievance with Us.

8. PRIVACY OF CHILDREN

The App is intended exclusively for authorised adult employees and contract staff of TVS SCS and is not directed to individuals under the age of 18. We do not knowingly request or collect any Personal Data from children under the age of 18. If We become aware that an individual under 18 has provided Us with Personal Data through the App, We will take steps to delete such data as soon as possible. If You believe a person under 18 has accessed the App, please contact Us at the details provided in clause 9.

9. CONTACT INFORMATION

You may contact Us if You have any inquiries, grievances, or feedback relating to this Policy or Our data protection practices:

Kind Attention: The Grievance Officer

Email Address: [email protected]

Department: IT Department / Information Security Team

Entity: TVS SCS Limited, registered office at 10, Jawahar Road, Chokkikulam, Madurai, Tamil Nadu – 625002, India

10. CHANGES TO THE POLICY

We may update this Policy from time to time in response to changing legal, technical, or business developments. When We update Our Policy, We will take appropriate measures to inform You, consistent with the significance of the changes We make — including notice through the App or other appropriate internal channels — and We will obtain Your consent to material changes if and where required by applicable law.

You can see when this Policy was last updated by checking the “Last Updated” date displayed at the top of this Policy.