PRIVACY POLICY

Important notice. This Privacy Policy governs the collection, use, storage, processing, transfer, disclosure, and disposal of Personal Data by PSM Orechem in connection with the website psmgroup.co.in and any services accessed through it. By accessing or using this website, by submitting any information through any form on this website, or by communicating with us in any manner referenced below, you confirm that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with any part of this Policy, you must not access or use this website or submit any information to us.

1. Introduction & Scope

This Privacy Policy is issued by PSM Orechem, an operating name used by [Gajanan Ores Pvt Ltd], a company incorporated under the Companies Act, 2013, having its registered/operating address at 3D, Shanti Hari Awasan, 1 Inner Circle Road, Bistupur, Jamshedpur, Jharkhand 831001, India ("PSM Orechem", "we", "our", or "us"). This Policy applies to all persons who visit the website psmgroup.co.in, including any sub-domain owned or operated by us, who submit information to us through any digital or offline channel, who request a quotation, audit, sample, or consultation, who register for the FURNEX platform, and who otherwise interact with our digital properties (collectively, "you" or "Data Principal").

This Policy is published in accordance with the requirements of the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the Information Technology Act, 2000 ("IT Act"), the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules"), the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, and all other applicable Indian laws, rules, regulations, and notifications as amended from time to time.

2. Definitions

For the purposes of this Policy, the following terms shall have the meanings ascribed below:

• "Personal Data" means any data about an individual who is identifiable by or in relation to such data, as defined under Section 2(t) of the DPDP Act, 2023.
• "Sensitive Personal Data or Information" ("SPDI") has the meaning ascribed under Rule 3 of the SPDI Rules, 2011, including but not limited to financial information, passwords, biometric information, and physical, physiological, and mental health condition.
• "Processing" means a wholly or partly automated operation or set of operations performed on Personal Data, including collection, recording, organisation, structuring, storage, adaptation, retrieval, use, alignment or combination, indexing, sharing, disclosure by transmission, dissemination or otherwise making available, restriction, erasure, or destruction.
• "Data Fiduciary" means any person who alone or in conjunction with other persons determines the purpose and means of Processing of Personal Data. PSM Orechem is the Data Fiduciary in respect of Personal Data collected through this website.
• "Data Processor" means any person who Processes Personal Data on behalf of a Data Fiduciary.
• "Data Principal" means the individual to whom the Personal Data relates.
• "Consent" means the free, specific, informed, unconditional, and unambiguous indication of the Data Principal's wishes, by which the Data Principal, by a clear affirmative action, signifies agreement to the Processing of their Personal Data for the specified purpose.
• "Cookies" means small data files stored on your device that allow our website to recognise your browser and improve your experience.
• "FURNEX Platform" means the AI-powered furnace intelligence platform operated by PSM Orechem at furnex.psmgroup.co.in and any associated sub-domains, applications, or services.

3. Categories of Information We Collect

3.1 Information You Provide Directly

• Identification & contact details: full name, designation, company or organisation name, postal address, email address, telephone or mobile number, and country of residence, submitted through our contact form, quotation request form, FURNEX registration form, or any other form on this website.
• Furnace Pulse audit data: furnace capacity, frequency, number of furnaces, operating temperature, lining life, monthly consumption, furnace hours, tap-to-tap time, current refractory supplier, charge mix composition (scrap %, DRI %, additives, additional materials), challenges experienced, and any additional operational notes submitted through our furnace audit form.
• FURNEX platform information: any account credentials you create or are issued, heat logs you upload, charge mix data, plant configuration data, kWh and cost data, and any other information you input into the FURNEX Platform.
• Communication content: the substance of any email, message, telephone call recording (where permitted by law), or written correspondence you direct to us.
• Transactional information: details of any quotation, order, sample request, invoice, payment instrument (where shared by you), shipping address, GSTIN, and tax identification numbers shared in the course of commercial dealings.

3.2 Information Collected Automatically

• Device & technical information: Internet Protocol (IP) address, browser type and version, operating system, device identifier, screen resolution, time zone setting, language preference.
• Usage information: pages visited, referring URLs, time and duration of visit, click paths, scroll depth, navigation patterns, and search terms used on the website.
• Cookies and similar technologies: as described in Section 7 below.
• Server logs: standard web server access logs retained for security, abuse-prevention, and operational integrity purposes.

3.3 Information From Third Parties

• Information received from analytics service providers (Google Analytics, Google Search Console, and similar industry-standard tools).
• Information received from advertising platforms where you have consented to share such information with us.
• Information received from B2B directory platforms (such as IndiaMART, TradeIndia, JustDial, Google Business Profile) when you submit an enquiry to PSM Orechem through such platforms.
• Publicly available information from regulatory filings, the Ministry of Corporate Affairs database, GST registrations, and other public records, used solely for the purpose of verifying business identity and creditworthiness in the course of B2B dealings.

4. Lawful Basis & Purposes of Processing

We Process your Personal Data only on the following lawful bases under the DPDP Act and other applicable laws:

• Consent for purposes for which you have provided clear affirmative consent, including subscribing to communications and creating an account on the FURNEX Platform.
• Legitimate Use in connection with the performance of a contract or the steps preceding entry into a contract (such as responding to quotation requests).
• Legal Obligation to comply with applicable law, including tax, accounting, and statutory record-keeping requirements.
• Legitimate Interest in operating, securing, and improving our website and services, preventing fraud and abuse, and protecting our legal rights.

We use Personal Data for the following purposes:

• To respond to enquiries, prepare and dispatch quotations, technical recommendations, and sample requests.
• To deliver, fulfil, invoice, and support orders for silica ramming mass, silica grains, and any other product or service offered.
• To assess and provide Furnace Pulse audit reports and recommendations.
• To register, operate, and support your access to the FURNEX Platform.
• To compute, generate, and improve AI-based predictions and analytics on the FURNEX Platform.
• To comply with applicable laws and respond to lawful requests from public authorities, courts, or regulators.
• To monitor, prevent, detect, investigate, and respond to fraud, abuse, security incidents, and unauthorised activity.
• To maintain, secure, and improve our website, infrastructure, and services.
• To send service communications, transactional notifications, and (where you have consented) marketing communications about our products and services.
• To enforce our Terms of Use, defend legal claims, and protect our rights, property, and the safety of others.

5. Disclosure & Sharing of Personal Data

We do not sell, rent, or trade your Personal Data. We disclose Personal Data only in the following circumstances:

• Service providers and Data Processors: we engage trusted third-party service providers — including web hosting providers, email service providers, payment gateways, cloud-storage providers, analytics providers, courier and logistics partners — who Process Personal Data on our behalf under written agreements that require confidentiality, security, and use restrictions consistent with this Policy.
• Business partners: where reasonably necessary to provide a quotation, supply a product, or fulfil an order, we may share limited Personal Data with manufacturing partners, logistics providers, or financial intermediaries.
• Legal compliance and protection of rights: to comply with any applicable law, court order, subpoena, or lawful request from a governmental, regulatory, or law-enforcement authority; to enforce our Terms of Use; to protect our rights, property, or safety, or those of our customers, employees, or any third party; and to detect, prevent, or address fraud, security, or technical issues.
• Corporate transactions: in connection with a contemplated or completed merger, acquisition, reorganisation, financing, sale of assets, or insolvency event involving PSM Orechem, in which Personal Data may be transferred as part of the transaction. The receiving party shall remain bound by terms no less protective than this Policy.
• With your consent: for any other purpose disclosed at the time of collection or for which you provide your explicit consent.
• Aggregated or de-identified data: we may share aggregated, anonymised, or de-identified data that cannot reasonably be used to identify any individual, including for research, benchmarking, and industry-trend publications.

6. International Data Transfers

Your Personal Data is primarily stored and Processed within India. Where we use service providers whose infrastructure is located outside India (for example, cloud-based email or analytics platforms), we transfer Personal Data only to jurisdictions notified or otherwise permitted under the DPDP Act and applicable rules, and we ensure that the recipient is bound by contractual safeguards substantially equivalent to those required under Indian law.

7. Cookies & Similar Tracking Technologies

We use cookies, web beacons, pixel tags, and similar tracking technologies on this website to enable basic website functionality, remember your preferences, analyse traffic and usage patterns, and (where you have consented) deliver personalised advertising.

Types of cookies we use:

• Strictly necessary cookies: required for the website to function and cannot be switched off in our systems.
• Performance and analytics cookies: allow us to count visits and traffic sources so we can measure and improve performance (e.g., Google Analytics).
• Functional cookies: enable enhanced functionality and personalisation.
• Marketing or targeting cookies: set through our site by advertising partners, where applicable and with your consent.

You may set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may then become inaccessible or not function properly.

8. Your Rights as a Data Principal

Subject to applicable law and reasonable verification of your identity, you have the following rights under the DPDP Act:

• Right to access information: to obtain a summary of the Personal Data we are Processing about you and the Processing activities undertaken.
• Right to correction and erasure: to request correction of inaccurate or misleading Personal Data, completion of incomplete Personal Data, updating of Personal Data, and erasure of Personal Data that is no longer necessary for the purposes for which it was Processed.
• Right of grievance redressal: to make a complaint to our Grievance Officer (see Section 14 below).
• Right to nominate: to nominate any other individual to exercise your rights under the DPDP Act in the event of your death or incapacity.
• Right to withdraw consent: where Processing is based on consent, you may withdraw such consent at any time. Withdrawal will not affect the lawfulness of Processing based on consent before its withdrawal, nor will it apply where Processing is required to comply with any law for the time being in force.

To exercise any of these rights, please contact us using the details in Section 14. We will respond to verified requests within the timeframes prescribed under the DPDP Act and applicable rules. We may retain certain Personal Data for as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, even after a request for erasure.

9. Data Security & Reasonable Security Practices

We implement and maintain reasonable security practices and procedures consistent with international standards such as ISO/IEC 27001 to the extent applicable, in compliance with the SPDI Rules, 2011, and the DPDP Act. These include but are not limited to:

• Transport-layer encryption (HTTPS/TLS) for data transmitted through our website.
• Access controls, role-based permissions, and authentication for systems containing Personal Data.
• Logging, monitoring, and intrusion detection on our hosting infrastructure.
• Regular security review and prompt patching of identified vulnerabilities.
• Contractual safeguards and confidentiality obligations imposed on our service providers and Data Processors.

However, no method of transmission over the Internet or method of electronic storage is fully secure. Whilst we use commercially reasonable means to protect your Personal Data, we cannot guarantee absolute security. You acknowledge and accept this inherent risk when submitting information through this website.

10. Data Retention

We retain Personal Data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of complying with our legal, accounting, tax, regulatory, or reporting requirements, resolving disputes, defending or asserting legal claims, and enforcing our agreements.

Indicative retention periods (subject to extension where required by law or for legitimate operational needs):

• Contact form submissions: up to 36 months after the last interaction.
• Furnace audit submissions: up to 60 months for technical and product-development purposes.
• Transactional records (orders, invoices): minimum 8 years from the end of the relevant financial year, as required under the Companies Act, 2013, the GST Act, and the Income Tax Act, 1961.
• FURNEX Platform data: for the duration of your active account plus 36 months thereafter, subject to anonymisation for ongoing model training.
• Server logs and analytics: typically 13 to 26 months in aggregated or de-identified form.

Upon expiry of the applicable retention period, Personal Data is securely deleted, anonymised, or archived in accordance with our internal data-disposal procedures.

11. Children's Personal Data

This website and our services are intended for business and professional users in the steel, foundry, refractory, and allied industries, and are not directed to children. We do not knowingly collect Personal Data from any person under the age of 18 years without the verifiable consent of a lawful parent or guardian, as required under Section 9 of the DPDP Act. If you are under 18 years of age, please do not submit any Personal Data through this website. If we learn that we have inadvertently collected Personal Data from a person under 18 without verifiable parental consent, we will take reasonable steps to delete such information.

12. Third-Party Links & Services

This website may contain links to third-party websites, plug-ins, applications, advertisements, and services (including but not limited to social-media platforms, B2B directories, payment gateways, and embedded media). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites or services and are not responsible for their privacy practices. We encourage you to read the privacy policy of every website or service you visit.

13. Changes to this Privacy Policy

We may update or revise this Privacy Policy from time to time in our sole discretion to reflect changes in our practices, technology, legal requirements, or other factors. The "Last updated" date at the top of this Policy indicates when it was most recently revised. We will notify you of material changes by posting a prominent notice on this website or by sending a notification to your registered email address where reasonable. Your continued use of the website following the posting of revisions constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically.

14. Grievance Officer & Contact

In accordance with the IT Act, 2000, the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, and the DPDP Act, 2023, we have designated a Grievance Officer to address any concerns, complaints, or requests in relation to this Privacy Policy or the Processing of your Personal Data.

Grievance Officer
PSM Orechem
3D, Shanti Hari Awasan,
1 Inner Circle Road, Bistupur,
Jamshedpur, Jharkhand 831001, India
Email: info@psmgroup.co.in
Phone: +91 99429 95507
Subject line: "Grievance — Privacy Policy"

The Grievance Officer shall acknowledge your complaint within 48 (forty-eight) hours of receipt and shall endeavour to resolve the complaint within 30 (thirty) days from the date of receipt, in accordance with applicable law.

15. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the Republic of India. Any dispute arising out of or in connection with this Policy shall be subject to the exclusive jurisdiction of the competent courts at Jamshedpur, Jharkhand, India, without prejudice to any rights of appeal or any mandatory arbitration provisions contained in our Terms of Use.

16. Acknowledgement

By accessing, browsing, or using this website or submitting Personal Data through any form on this website, you acknowledge that you have read, understood, and agreed to be bound by this Privacy Policy and to the collection, use, storage, Processing, transfer, disclosure, and disposal of your Personal Data as described herein.