Security & Privacy Policy

1. Introduction

1.1 parts.jcb.com/in and the website ‘JCB Parts Online’ (collectively the “Platform”) are owned, operated, and maintained by JCB India Ltd., an Indian company with its registered office at B-1/I-1, 2nd Floor, Mohan Co-operative Industrial Estate, Mathura Road, New Delhi 110044, India (hereinafter referred to as “we”, “us”, “our”, “Company”, or “JCB” including its permitted assigns and successors).  

1.2 JCB is committed to protecting your personal information and complying with all applicable data protection laws, including the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”). Accordingly, this privacy notice (“Privacy Notice”) provides information about our practices and processes around collection, use, storage, disclosure, and processing of User’s personal information when they access or use the Platform or otherwise provide us with personal information outside of the Platform.  

1.3 Application: This Privacy Notice applies to all Users of the Platform and covers all information that can be used directly or indirectly, standalone or in combination with other data sets to identify the natural person to whom the information belongs (hereinafter “PI”) provided to us by the Users through the Platform. Further, please note that processing refers to any automated or semi-automated dealing with your PI including collection, storage, disclosure, organization, and archiving. 

1.4 Scope and effect: This Privacy Notice forms an integral part of the Platform’s terms and conditions and upon your acceptance of the Terms in the manner provided therein, you signify your acceptance to the terms of this Privacy Notice and agree to be bound by them as a binding contract with us. 

1.4.1 It is important that you read and understand this Privacy Notice before signifying your acceptance to the Terms or prior to submitting any information to us through the Platform or otherwise. If you do not wish to accept this Privacy Notice, you cannot accept the Terms or access/use the Platform and Services enabled therein and should not use the Platform. In the event the User does not provide their PI, we may not be able to provide some or all of our Services.

1.4.2 Please note that this Privacy Notice does not cover processing of PI of employees, consultants, or other personnel engaged with JCB who shall be/are provided with separate privacy notices. 

1.4.3 This Privacy Notice does not elaborate or control the manner in which your PI will be processed by Dealers or any other third party service provider including processing and informational privacy practices of third party payment service providers and websites/links that you access through the Platform. You are advised to reach out to such third parties for understanding their informational privacy and data processing practices before providing any PI to such third parties. 

1.5 Other privacy notices: We reserve the right to provide you with additional privacy statements/notices for specific kinds of processing and for compliance with Applicable Laws, and this Privacy Notice does not supersede such specific notices/statements. In the event of any inconsistency between any term contained in such specific notices/statements and this Privacy Notice, the conflicting term in the specific notice/statement shall prevail over this Privacy Notice only to the extent relevant for the limited scope of the specific statement/notice and not otherwise. 

1.6 Capitalized terms used herein but not defined specifically shall have the same meaning as ascribed to them in the Terms and its constituents or as provided under Applicable Law, and if no such meaning is attributed in the Terms or Applicable law, the terms will be understood in general parlance. 

2. What Personal Information do we collect and how do we collect it?

2.1 Direct collection: You directly provide your PI to us when you:

(a) access and use the Platform and the Services;

(b) create an User Account;

(c) search for Products or Services; 

(d) execute any contract with us;

(e) in course of us performing due diligence on Users of the Platform;

(f) place an Order through the Platform;

(g) provide information in your User Account; 

(h) communicate with us by phone, e-mail or other available means;

(i) subscribe to our marketing and promotional content;

(j) participate at any of our events and meets; and

(k) complete any questionnaire or other document provided by us.

2.2 Indirect collection: Additionally, we collect PI indirectly from other sources such as cookies, web beacons, website traffic, information available in public domain through internet searches, analytic studies, and other information that we may derive while processing PI. To learn more about how cookies function, please access the Cookie Policy here.

2.2.2 When we collect PI indirectly i.e., from third parties, you represent that you have consented for such third party to transfer your PI to JCB, and you agree and undertake that JCB shall not be liable for any consequences arising from any unauthorized transfer of your PI to JCB by such third party. Further, you expressly waive your rights for seeking relief or raising any claim under law, contract, or equity against JCB and its group entities, their officers, employees, agents, personnel, and other representatives (“JCB Representatives”) for unauthorized access, except your right to write to us seeking deletion of your PI and cessation of processing that has been unauthorizedly transferred to JCB.

2.3 Types of PI collected and processed. JCB may collect and process the following types of PI about you, some of which may be considered as sensitive PI as per SPDI Rules:

(a) Basic identification information like contact forename and surname, name of organization; 

(b) Identification information like identity proof and tax identification information;

(c) Contact information like e-mail address, telephone number, address (billing address, delivery address) and country of residence;

(d) Log-in details for your User Account including password;

(e) Financial and payment information like payment method details, bank account information, tax registrations, and payment details;

(f) Location information;

(g) Technical information such as device and hardware information, information about your system’s operating systems;

(h) Information on how you use the Platform through our or third party cookies such as duration of your visit, Products viewed, other location and technical information, content interaction information, usage metrics, purchase history, browsing history; to know more about use of cookies, please review our Cookie Policy here;

(i) Social media information such as social media URL, feedback therein;

(j) Details of the Order and Products and Services that you require information on or wish to purchase or have purchased;

(k) Information that is required for compliance with applicable law;

(l) Feedback and survey responses;

(m) Preferred dealer when utilising the sub-sections of the site for procurement from a Dealer;

(n) Your preference regarding receipt of marketing from us;

(o) Information that you provide to us in the process of entering or performing any contract with JCB.

2.4 Whenever you use our Platform or in case of an error, we collect data and information on your device called Log Data. This Log Data may include information such as IP address, device name, operating system version, the time and date of your use of the Platform, and other statistics. 

2.5 In order for us to be able to provide the Services to the Users, we may seek permission of the Users on whether we may obtain access to contact list/phone book on their device, device location, camera, microphone and other sensitive device data. When this permission is sought, the Users shall have the control wherein they can select to ‘allow’ us to access such data or ‘deny’ us the permission to access the said data. 

2.6 While we shall make reasonable endeavours to ensure that your PI is duly protected by undertaking reasonable security measures that commensurate with the nature of our operations and information assets sought to be protected, you are strongly advised to exercise discretion while providing your PI and using the Platform, given that the internet is susceptible to security breaches.

3. How Do We Use your Personal Information?

3.1 We collect and process PI, directly or indirectly through engaged third parties and data processors, for varied purpose including the following:

(a) allowing creation of User Account and managing them on the Platform;

(b) verification of Users visiting and/or accessing the Platform and offline verification of contracting parties;

(c) providing, operating, and maintaining the Platform and Services;

(d) contracting for the purposes of offering the Platform and Services;

(e) administering your Order with the Dealer including enabling transactions with the Dealer and managing payments through payment service providers;

(f) sharing reports, articles, and other communication regarding Products and Services;

(g) promotion, marketing, analytics, and advertising including providing customized internet-based ads; please note that for internet-based ads, we do not use identifiable PI 

(h) processing User feedbacks, complaints, grievance, reviews, and similar information provided to use for improving our operations, Platform, Services, customer experience, and grievance resolution;

(i) analyzing and communicating with Users and other persons in relation to our dealings with them;

(j) sharing invitations and other communication for participation in our events and shows;

(k) connecting and enabling transactions between Buyers and Dealers as well as enabling financing facilities for Dealers through financiers;

(l) providing customer support;

(m) understanding what JCB products you may be interested in and improve JCB products or services;

(n) conducting market research, surveys, trend research, analytics to understand your need for using the Platform, demand for Services, updates, upgrades and other Platform feature requirements;

(o) administering and protecting our operations and the Platform;

(p) creating, improving, and developing our Platform;

(q) protecting and securing your PI;

(r) detecting and handling data breach and security incident scenarios;

(s) periodically reviewing PI collected to adhere with your requests regarding your rights and legal obligations under Applicable Law;

(t) maintaining secure personal information management system;

(u) archiving, statistical analysis, survey, R&D activities;

(v) compliance with Applicable Law and contractual obligations;

(w) sharing with third parties; and

(x) defending or initiating legal, contractual, and other equitable relief should such situation arise

4. How Do We Process Your Personal Information?

4.1 We collect, record, organise, structure, align, retrieve, adapt, access, review, archive, analyse, pseudonymize, encrypt, decrypt, profile, transfer, perform other related technological and manual processing activities.

4.2 Governing principles for processing of your PI: We process your PI in accordance with fair, accountable, and transparent processing principles as required under Applicable Law. Governing principles that we follow for processing are:

(a) process lawfully, fairly, and with transparency; 

(b) process only for purposes communicated, or those which are reasonably expected to be connected with the purposes, or for purposes which are compatible with them, or as allowed under Applicable Law;

(c) minimize collection only as much is adequate, relevant, and necessary; 

(d) take reasonable steps to maintain accuracy in light of the processing purposes 

(e) retain in such form bearing in mind the processing purposes;

(f) use physical, technical, operational, and organizational security measures to protect PI and prevent data breach or unauthorized processing; 

(g) prevent accidental loss, unlawful destruction, or access, or damage;

(h) maintain confidentiality and integrity of your PI.

4.3 Profiling: Profiling means automated processing of PI to evaluate certain personal attributes about you. This aims at analysing your behaviour while using the Platform. There will be no profiling by automated means that will affect your PI protection rights and privacy. 

5. THIRD PARTY SHARING AND DISCLOSURE OF PERSONAL INFORMATION

5.1 We disclose your PI on a strict need-to-know basis. In such cases, we exercise reasonable due diligence on information processing and security practices implemented by the receiving party, and in certain cases, also require them to execute contracts with us that obligates them to provide similar or higher standards of protection as is provided by JCB, allow JCB to conduct audits and call for information, maintain confidentiality, and limit processing for the specified purposes as directed by JCB. Alongside, we require them to refrain from further sharing of your PI to any third party without obtaining our prior written consent. 

5.2 Third parties to whom we disclose PI include: 

(a) the Dealer with whom you have placed an Order and other third parties who are necessary for concluding your transactions on the Platform including payment service providers;

(b) JCB group entities and JCB Representatives to provide you with the Platform, the Services, and support in relation to them or on connection with the Products; 

(c) Other JCB group entities who undertake marketing for the Products;

(d) our service providers who perform services on our behalf, such as IT service providers who manage the Platform and its performance, our customer service enquiry service provider who handle correspondence received and direct it appropriately, our customer survey providers who we use to obtain feedback from customers on our behalf, and our marketing fulfilment agencies for any marketing;

(e) those with whom we are required to transfer information to comply with Applicable Law or to enforce our Terms and policies including with government and regulatory bodies; and

(f) third parties in case of corporate restructuring transactions involving JCB such as mergers, slump sales, etc.

6. Where do we store your Personal Information?

6.1 JCBI primarily stores Users’s Data including PI in India. To facilitate JCBI’s global operations, JCBI may transfer to and access such information from around the world, including to/from other countries in which JCBI or its parent, affiliates, subsidiaries and joint ventures have operations and other JCBI group entities globally. This Privacy Policy shall apply even if JCBI transfers Data about Users to other countries and the Users hereby consent to such transfer. Our parent, affiliates, subsidiaries, and joint ventures follow privacy practices no less protective of all users than our practices described in this document, in compliance with applicable law.

7. How Do We Protect Your Personal Information?

7.1 JCB takes the safety of your PI and its confidentiality, integrity, and availability very seriously and is committed to providing reasonable security safeguards commensurate with the nature of operations and the sensitivity of PI being handled, including but not limited to implementation of reasonable technical, organizational, managerial and physical safeguards.

7.2 Some measures used include access control, use of privacy enhancement tools, and where needed encryption and masking tools for protection of your PI. 

7.3 We regularly carry out assessments to ensure the security of PI collected by us. 

7.4 All staff, personnel, officers, and JCB Representatives receive appropriate and on-going training to ensure they are fully aware of their obligation to uphold confidentiality, protect PI, and respect your privacy. 

7.5 Only limited authorized personnel and approved third parties including the Dealers have access to your PI on a need-to-know basis and only for specific purposes. However, please note that there is no guarantee that PI may not be accessed, disclosed, altered, or destroyed on account of breach incidents by malicious actors. Additionally, you are responsible for maintaining the confidentiality of the username, password and other details related to your User Account on the Platform and for all the activities that occur on the account.

8. Data Transfers OUTSIDE INDIA

Your PI may be transferred to other JCB group entities or third parties based and operating outside India. JCB will use appropriate safeguards to ensure that such data importer provides similar level of data protection that is provided by JCB under Applicable Law and this Privacy Notice, and that such transfer only happens if it is necessary for the processing purposes listed in this Privacy Notice, or in compliance with Applicable Laws. 

9. Data Retention

Your PI will be held in the Parts Online system and, where we have corresponded with you via e-mail, will be held within our relevant IT systems, for as long as it is required to be stored for the purposes set out in this Privacy Notice or until such time you withdraw your consent, or as necessary to comply with legal obligations. We will carry out periodic data cleanses of this information to ensure that it is up to date and accurate and to remove any obsolete data. When we no longer need to use your PI and there is no need for us to keep it to comply with our legal obligations, we will delete it from our systems.

10. Your rights

10.1 You have the following rights in connection with your PI processed by JCB:

(a) Access: you can request access to your PI and further details about how your personal information is handled and processed by JCB. 

(b) Rectification: You can request rectification of any incorrect or inaccurate PI, or completion of incomplete PI held about you. You may change any of your PI in your User Account at any time. We encourage you to promptly update your information if it changes.

(c) Erasure: You can request erasure of any PI where the processing isn’t necessary for the purposes of the contract between us, or where you withdraw your consent for processing of PI. If you exercise this right, it may may have a bearing on using and accessing the Platform and availing our Services and we shall not be liable for such consequences. 

(d) Withdraw consent: You have the right at any time to withdraw consent, and this will not affect processing that has taken place prior to the date you request such withdrawal. If withdrawal has a bearing on you accessing the Platform or availing our Services, and we shall not be liable for such consequences.

10.2 To exercise your rights, please contact us at We will try our best to provide the necessary information within 30 days from receipt of the request. 

11. Third Party Sites 

The Platform may occasionally contain links to third party websites. If a User clicks on any such links, the User will leave our Platform and JCB will not be responsible for the content of these third party websites or for the security of the User’s PI when the User uses these third party websites. This Privacy Notice does not govern PI processed by third party websites. Third party websites may have their own privacy policies governing processing of PI and the User is urged to review them. 

12. Changes to our privacy policy

JCB reserves the right to revise this Privacy Notice or any part of it from time to time as it may deem necessary or as may be required under Applicable Law. Any changes will be immediately posted on the Platform along with the date of the modification and if the User continues to use this Platform, they are deemed to have accepted the terms of the revised Privacy Notice.

13. Contact Details

For any complaints, queries, and communications in respect of this Privacy Notice, please reach out to Richard Ruben - richard.ruben@jcb.com the designated grievance officer who will acknowledge and attempt to address your complaints or queries within 30 days from when you contact us. 

14. How will we contact you?

JCB and its third-party service providers (customer survey providers) will contact you by post, telephone, email and/or text message depending on the reason for correspondence and only in accordance with the Terms and this Privacy Notice. JCB may contact you with marketing communications by post, telephone, email and/or text message, unless you have told us not to or have registered with the telephone or post preference services.