Privacy Policies
This Privacy Policy (“Policy”) is issued by Lion Services Limited, a company incorporated under the Companies Act, 2013 (“Company”, “LSL”, “we”, “us”, or “our”).
This Policy governs the manner in which the Company collects, receives, stores, processes, uses, discloses, transfers and protects Personal Data and Sensitive Personal Data or Information of users accessing or using the Company's website www.lionservice.com (“Website”).
This Policy is framed in compliance with applicable provisions of:
- The Information Technology Act, 2000;
- The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”);
- The Digital Personal Data Protection Act, 2023 (“DPDP Act”), to the extent applicable;
- The Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“SEBI LODR Regulations”);
- The Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018 (“SEBI ICDR Regulations”); and
- Other applicable laws, rules, regulations and regulatory guidelines for the time being in force.
By accessing or using the Website, you expressly consent to the collection, storage, use, processing and disclosure of your information in accordance with this Policy. If you do not agree with this Policy, you are advised to discontinue use of the Website immediately.
1. DEFINITIONS AND INTERPRETATION
Unless the context otherwise requires:
- “Personal Data” shall have the meaning assigned under the DPDP Act and includes any data about an individual who is identifiable by or in relation to such data.
- “Sensitive Personal Data or Information (SPDI)” shall mean such categories of information as defined under the SPDI Rules, 2011.
- “Data Principal”, “Data Fiduciary” and “Data Processor” shall have the meanings assigned under the DPDP Act, 2023.
- “User” / “You” means any individual, entity or organisation accessing or using the Website.
- “Applicable Law” means all statutes, rules, regulations, circulars, notifications, guidelines and amendments in force in India relating to privacy and data protection.
Interpretation principles relating to headings, singular/plural usage, and statutory references shall apply mutatis mutandis.
2. NATURE OF INFORMATION COLLECTED
2.1 Categories of Information
The Company may collect the following categories of Personal Data from Users:
- Name, designation and organisation details;
- Contact information including email address and mobile/telephone number;
- Information voluntarily submitted through enquiry / contact forms or communications sent to us;
- Technical and device-related data including IP address, browser type, device identifier, operating system, pages visited and access logs;
- Any other information voluntarily provided by the User.
2.2 Collection of SPDI
The Company does not knowingly collect Sensitive Personal Data or Information, unless expressly required for legitimate purposes and only in accordance with Applicable Law.
3. PURPOSE OF COLLECTION AND USE
Personal Data collected may be used strictly for the following lawful purposes:
- Responding to User queries, communications and service-related requests;
- Business development, client communication and relationship management;
- Investor relations, statutory and regulatory communication, wherever applicable;
- Website operation, administration, diagnostics, enhancement and security monitoring;
- Compliance with Applicable Law, regulatory requirements, law enforcement requests or judicial proceedings;
- Internal records, audit, risk management and corporate governance purposes.
No Personal Data shall be used for unlawful, misleading, discriminatory or unauthorised purposes.
4. DISCLOSURE OF INFORMATION
4.1 Permissible Disclosures
The Company may disclose Personal Data, strictly on a need-to-know basis, to:
- Regulatory, governmental or statutory authorities including SEBI, stock exchanges, enforcement agencies, courts or other competent bodies, pursuant to legal or regulatory obligations;
- Professional advisors such as auditors, legal counsel, merchant bankers, consultants, or other advisors engaged by the Company;
- Third-party service providers engaged for information technology, hosting, communication management or data processing activities, under appropriate confidentiality obligations.
4.2 Prohibition on Sale
The Company does not sell, trade, rent or commercially exploit Personal Data under any circumstances.
5. INVESTOR AND SECURITIES LAW DISCLAIMER
5.1 Any Personal Data collected through the Website shall not be construed as solicitation for investment, securities subscription, trading or financial transactions.
5.2 Any disclosures relating to securities, corporate announcements or investor information shall be governed exclusively by statutory disclosures and filings under SEBI ICDR Regulations and SEBI LODR Regulations.
5.3 Information available on the Website or collected therefrom shall not constitute Unpublished Price Sensitive Information (UPSI).
6. DATA RETENTION
6.1 Personal Data shall be retained only for such duration as is reasonably necessary to fulfill the lawful purposes for which it is collected or as required under Applicable Law.
6.2 Upon expiry of the retention period, Personal Data shall be securely deleted, destroyed or anonymised in accordance with Applicable Law and the Company's data retention policies.
7. DATA SECURITY PRACTICES
7.1 The Company adopts reasonable security practices and procedures, including but not limited to:
- Administrative, organisational, technical and physical safeguards;
- Access control and authentication measures;
- Secure system monitoring and periodic security assessments/audits.
7.2 While the Company implements industry-standard safeguards, it does not guarantee absolute data security, and disclaims liability for any unauthorised access, breach, cyber incident or disclosure arising beyond its reasonable control.
8. USER RIGHTS
Subject to Applicable Law, Users may:
- Request access to their Personal Data held by the Company;
- Request correction, updating or completion of inaccurate or incomplete data;
- Withdraw consent for processing, where processing is based on consent, subject to legal limitations.
Requests may be addressed to the Grievance Officer as detailed in Clause 12. The Company reserves the right to verify identity before processing such requests.
9. THIRD-PARTY WEBSITES
The Website may contain links to third-party websites. The Company does not control and shall not be responsible for the privacy practices, content, data handling or security measures of such third-party websites. Users are advised to review respective privacy policies before accessing such websites.
10. CHILDREN'S DATA
The Website is not intended for individuals below 18 years of age. The Company does not knowingly collect Personal Data from minors. If it is discovered that data relating to a minor has been collected inadvertently, the Company may delete such data in accordance with Applicable Law.
11. WEBSITE DATA BREACH & INCIDENT RESPONSE
11.1 The Company maintains appropriate incident detection, prevention and response mechanisms to address any actual or suspected data security breach involving personal data.
11.2 In the event of any personal data breach, accidental disclosure, unauthorised access, alteration, destruction or loss of data, the Company shall:
• Promptly investigate and assess the nature and extent of the breach;
• Take immediate corrective and mitigation measures;
• Maintain internal records of such incidents;
• Notify the affected Users and/or relevant authorities, where required under Applicable Law;
• Cooperate with regulatory authorities in accordance with statutory obligations.
11.3 The Company shall not be liable for any breach caused due to events beyond reasonable control including hacking incidents, cyber-attacks, force majeure events, or third-party system failures, provided reasonable security practices were adhered to.
12. CONSENT NOTICE
12.1 By accessing, browsing, or using the Website, providing information voluntarily, or submitting information through forms or communication channels available on the Website, you explicitly:
Consent to the collection, storage, processing, use, disclosure and retention of your personal data in accordance with this Policy;
• Acknowledge that such consent is freely given, informed, specific and unambiguous;
• Confirm that the information provided is true, correct and duly authorised.
12.2 Users may withdraw consent by writing to the Grievance Officer; however, withdrawal of consent may restrict access to certain Website functionalities or services.
13. PRIVACY BANNER & WEBSITE DISCLAIMER
The Website shall prominently display the following notice at the point of access:
Privacy Notice & Disclaimer
By continuing to browse or use this Website, you acknowledge that:
• You have read, understood and agree to this Privacy Policy;
• You consent to the collection and use of your information as described herein;
• Use of this Website does not constitute any offer, solicitation, financial advice or creation of contractual rights;
• Information made available is for informational purposes only and may be subject to regulatory constraints.
If you do not agree, please discontinue using the Website.
14. COOKIE POLICY
14.1 The Website may use cookies, web beacons, pixels and similar tracking technologies to enhance User experience, improve Website performance, analyse usage trends and provide customised content.
14.2 Types of Cookies Used:
• Strictly Necessary Cookies - essential for Website functioning;
• Functional Cookies - enhance usability and personalisation;
• Analytical / Performance Cookies - assist in performance monitoring and analytics;
• Third-Party Cookies - may be deployed by authorised service providers subject to contractual safeguards.
14.3 Users may manage or disable cookies through browser settings; however, certain Website features may not function correctly if cookies are disabled.
14.4 No cookies shall be used for unlawful profiling or tracking contrary to Applicable Law.
15. CHANGES TO THIS POLICY
The Company reserves the right to review, revise, update or amend this Policy at any time, without prior notice, to reflect legal, regulatory or operational requirements. Continued use of the Website after publication of revised Policy shall constitute deemed acceptance of such modifications.
16. GOVERNING LAW AND JURISDICTION
This Policy shall be governed by and construed in accordance with the laws of India. Courts at New Delhi shall have exclusive jurisdiction over any dispute arising out of or in connection with this Policy.
17. ACKNOWLEDGEMENT
By using the Website, Users acknowledge that they have read and understood this Policy and agree to be bound by its terms.
18. GRIEVANCE REDRESSAL
In accordance with Applicable Law, the Company has designated the following Grievance Officer for redressal of privacy-related complaints, requests or concerns:
Grievance Officer
Lion Services Limited
Registered Office: Second Floor, Plot No. 210, Padma Tower-II, 22, Rajendra Place, New Delhi - 110008, India
Email: corp.affairs@globalexcellence.in
Designated Grievance Officer (Website/Data Protection): Anubha Mathur
Contact Number: 7669241777
The Grievance Officer shall endeavour to acknowledge and address grievances within the timelines prescribed under Applicable Law.