1. Scope of this Privacy Policy

JK Lakshmi Cement Limited (“JK Lakshmi Cement”, “JKLC”, “we”, “us” or “our”) respects the privacy of individuals who visit our websites, interact with our digital platforms, submit enquiries, participate in our campaigns, or otherwise provide us with their personal data.

This Privacy Policy explains how we collect, use, disclose, store, protect and otherwise process personal data obtained through our websites, digital platforms, online forms, campaign landing pages, advertising and lead-generation campaigns, and other digital or offline interactions. This Policy is intended to provide transparency regarding our processing of personal data and should be read together with any specific privacy notice or consent statement presented at the point of data collection. This Policy is framed with reference to the Digital Personal Data Protection Act, 2023 and the Digital Personal Data Protection Rules, 2025 (“DPDP Rules”), and reflects JKLC’s commitment to the principles and obligations under this framework as it comes into force in a phased manner and is otherwise applicable from time to time.

This Privacy Policy applies to personal data collected through or in connection with:

• JK Lakshmi Cement websites and webpages;
• Website enquiry, contact-us, product enquiry and lead-generation forms;
• Campaign-specific landing pages and microsites;
• Digital marketing and advertising campaigns;
• Lead-generation forms provided through third-party advertising platforms, including Meta Lead Forms and Google lead-generation forms;
• Online registration, feedback and participation forms;
• Dealer, distributor, contractor, builder, architect and customer interactions;
• Social media and digital platforms operated or managed by JKLC;
• Cookies, analytics and similar technologies used on our websites;
• Communications with our customer service, sales, marketing or support teams; and
• Third-party service providers, agencies or platforms acting on our behalf.

Where a third-party platform independently processes personal data under its own privacy policy, that platform’s privacy policy may also apply to such processing.

2. Personal data we may collect

A. Information provided directly by you

• Name;
• Mobile/telephone number;
• Email address;
• State, city, district and/or PIN code;
• Address, where required;
• Product or service of interest;
• Type of user, such as homeowner, contractor, builder, architect, dealer or other relevant category;
• Nature of your enquiry or requirement;
• Information submitted through enquiry or lead forms;
• Feedback, requests or communications submitted by you; and
• Other information that you voluntarily provide for a specific purpose.

We seek to collect only information that is reasonably necessary for the purpose for which it is collected.

B. Information collected through digital campaigns

• Campaign name;
• Campaign ID;
• Advertisement or creative through which you interacted;
• Lead-form name/version;
• Platform/source, such as website, Meta or Google;
• Date and time of submission;
• Consent status;
• Consent notice/privacy-policy version presented to you;
• Relevant campaign attribution information, including UTM parameters where applicable; and
• Other technical or campaign information necessary for campaign measurement, lead management, fraud prevention and reporting.

3. Website and digital lead-generation forms

JKLC may operate digital campaigns through its websites, campaign landing pages, microsites and third-party advertising platforms.

If you submit your information through a JKLC website form, campaign landing page, Meta Lead Form, Google lead-generation form or another authorised campaign form, the information you provide may be transferred to JKLC or its authorised service providers for the purposes described in the applicable notice and this Privacy Policy, including to:

• Respond to your enquiry;
• Understand your product or service requirement;
• Connect you with an appropriate JKLC representative, dealer or authorised business partner, where applicable;
• Provide product, service or enquiry-related information;
• Follow up on your request;
• Manage and track leads;
• Improve our products, services and customer experience;
• Measure and optimise marketing campaigns;
• Prevent fraudulent or unauthorised activity; and
• Comply with applicable legal and regulatory requirements.

Where marketing communications are optional, we will seek the applicable consent separately from consent required to respond to your enquiry.

Processing of personal data collected by JKLC directly from an individual, or through a marketing communication or website lead, shall be limited to the purpose for which consent is given.

4. Purposes for which we process personal data

• To respond to enquiries and requests;
• To provide information regarding our products and services;
• To process and manage leads generated through our digital and offline campaigns;
• To connect prospective customers with relevant sales teams, dealers or authorised representatives;
• To provide customer support and follow-up;
• To send service-related communications;
• Where separately permitted or consented to, to send promotional and marketing communications;
• To conduct surveys, feedback and customer experience activities;
• To measure, analyse and improve digital marketing campaigns;
• To understand user preferences and improve our website and digital platforms;
• To maintain records of consent and preferences;
• To manage requests for withdrawal of consent and marketing opt-out;
• To detect, prevent and address security, fraud or misuse;
• To comply with applicable laws, regulations, legal processes or governmental requirements; and
• For other purposes specifically communicated to you at the time your personal data is collected.

We will not use personal data for purposes that are incompatible with the purpose communicated to you, except where otherwise permitted or required by applicable law.

5. Consent

Where consent is the basis for processing your personal data, JKLC will seek consent that is free, specific, informed, unconditional, unambiguous and given through a clear, affirmative action. Processing shall be strictly limited to the purpose for which consent is given, and consent shall not be made conditional upon the provision of personal data not necessary for that purpose.

The consent request will be presented in clear and understandable language and will identify, as applicable: the personal data being requested; the purpose for which the data is being processed; the relevant communication or service; how you can withdraw your consent; and the appropriate contact details for privacy-related queries or requests.

Where required, the communication link on JKLC’s website or app shall direct the individual to the legally mandated notice providing the details necessary to enable the individual to give specific and informed consent for the processing of their personal data for the specified purpose. Where applicable, such notice will specify that the personal data may be shared with another channel partner or Data Fiduciary to fulfil the purpose for which consent is given.

The individual’s personal data shall continue to be processed in accordance with the consent given, for the specified purpose, until such time as the individual withdraws that consent. Where the individual is a child or a person with disability, only their lawful guardian shall be competent to provide clear, verifiable consent to JKLC (see Section 19).

Consent for receiving marketing communications may be presented separately from consent required to respond to an enquiry.

For campaign-generated leads, JKLC or its authorised systems may maintain records including consent status, date and time of consent, source/platform, campaign and form identification, version of the consent notice/privacy notice presented, relevant lead identifier, and withdrawal or opt-out status.

Consent Manager: Where JKLC engages a Consent Manager registered with the Data Protection Board of India, details of such Consent Manager — including how the Consent Manager may be contacted for giving, reviewing or withdrawing consent — will be published here and in the applicable consent notice. This clause will be activated once a Consent Manager is engaged and registered.

6. Marketing communications

Where you provide the relevant consent or where otherwise permitted by applicable law, JKLC may contact you through telephone calls, SMS, WhatsApp or other messaging platforms, email, and/or other communication channels made available by JKLC.

You may withdraw marketing consent or opt out of promotional communications at any time.

7. Withdrawal of consent and opt-out

You may withdraw consent at any time where consent is the basis for processing. JKLC will endeavour to make withdrawal or opt-out reasonably accessible and comparable in ease to the manner in which consent was provided, including to:

• Withdrawal of consent;
• Opt-out from marketing communications;
• Stop promotional calls;
• Stop SMS communications;
• Stop WhatsApp or other messaging communications;
• Stop promotional emails;
• Correction of inaccurate personal data; and/or
• Deletion/erasure of personal data, where applicable under law.

Requests may be submitted through the privacy contact mechanism provided in Section 8.

For campaign-generated leads, an individual may identify themselves using information such as their registered mobile number, email address, lead reference or other reasonable verification information. JKLC may undertake reasonable verification before acting on a request.

Once a valid withdrawal/opt-out request is received and verified, JKLC will take reasonable steps to update its records and, where applicable, cause relevant authorised service providers, agencies, dealers or other processors acting on its behalf to reflect the withdrawal.

Where processing is required or authorised by law, withdrawal of consent may not require cessation of that particular processing.

8. Lead management and campaign sources

JKLC may use authorised customer relationship management systems, lead-management platforms and other technology to manage enquiries and campaign leads, including:

• Lead source;
• Advertising platform;
• Campaign name and ID;
• Form name and form version;
• Date and time of submission;
• Consent status;
• Consent notice/privacy policy version;
• Lead status;
• Follow-up status;
• Opt-out/withdrawal status; and
• Relevant attribution or campaign measurement information.

Such information may be used for lead management, customer service, campaign measurement, reporting, audit and compliance purposes.

9. Sharing of personal data

As a Data Fiduciary, JKLC is responsible for ensuring the accuracy and completeness of personal data it processes and for exercising reasonable care in that regard. We may share or provide access to personal data, where necessary and appropriate, with:

• our employees and authorised internal teams;
• dealers, distributors and authorised representatives where necessary to fulfil an enquiry;
• advertising and digital marketing agencies;
• CRM and lead-management service providers;
• website and technology service providers;
• analytics and measurement providers;
• telecalling, communication and customer-support service providers;
• cloud, hosting and infrastructure providers;
• professional advisers, auditors and consultants;
• government, regulatory or law-enforcement authorities where required or permitted by law; and
• other service providers or entities where such sharing is necessary for the purposes communicated to you or otherwise permitted by applicable law.

Personal data shall not be shared with any other Data Fiduciary or channel partner beyond the categories listed above unless specific consent has been obtained from the individual for that sharing.

Where third parties process personal data on behalf of JKLC, we will take appropriate contractual and organisational measures as required under applicable law.

10. Third-party advertising and digital platforms

JKLC may use third-party advertising and technology platforms for marketing, analytics, measurement and lead-generation activities. These may include platforms such as Meta and Google, as well as other service providers engaged by JKLC or its authorised agencies.

When you submit information directly through a third-party platform, such as a Meta Lead Form, that platform may process certain information independently in accordance with its own privacy terms and policies.

JKLC will process the information received from such platforms in accordance with the purpose communicated at the time of collection and this Privacy Policy.

11. Cookies and similar technologies

Our websites may use cookies, pixels, tags, web beacons, analytics tools and similar technologies to operate and secure the website; remember user preferences; understand website usage; measure website performance; improve user experience; measure advertising effectiveness; and support digital marketing and campaign analytics.

Where required, applicable consent or preference mechanisms will be provided. Further details may be provided through our Cookie Policy or cookie preference mechanism, where applicable.

12. Data retention

JKLC will retain personal data only for as long as reasonably necessary for the purpose for which it was collected, to provide requested services, manage ongoing relationships, comply with legal obligations, resolve disputes, enforce agreements, maintain appropriate business records, establish or defend legal claims, or for other lawful purposes.

As a general rule, and subject to specific legal, contractual or regulatory requirements that may require longer retention:

• Active enquiry and campaign-generated leads will be retained for up to 24 months from the date of last interaction, or until the purpose is fulfilled, whichever is earlier;
• Consent, withdrawal and audit records will be retained for up to 7 years to meet legal, audit and regulatory requirements;
• Suppression/“Do Not Contact” records will be retained for as long as necessary to honour the individual’s opt-out preference.

Where feasible, JKLC will provide prior notice to the data principal before personal data is erased upon expiry of the applicable retention period, so that the individual may, where they wish, request continued retention or processing.

When personal data is no longer required for the applicable purpose and there is no legal or other lawful requirement to retain it, JKLC will take reasonable steps to delete, erase, anonymise or otherwise appropriately dispose of such information.

Withdrawal of marketing consent may result in the individual’s information being placed on a suppression or “Do Not Contact” list so that the preference can be respected. Such limited information may be retained where necessary to honour the individual’s opt-out preference.

13. Data security

JKLC takes reasonable technical and organisational measures designed to protect personal data against unauthorised access, disclosure, alteration, loss, misuse or destruction, including:

• Access controls;
• Authentication mechanisms;
• Role-based access;
• Data security controls;
• Monitoring and logging;
• Vendor and processor controls;
• Secure data transfer mechanisms; and
• Other reasonable security measures appropriate to the nature and risk of processing.

No method of transmission or electronic storage can be guaranteed to be completely secure. However, JKLC will take reasonable measures to protect personal data in accordance with applicable requirements.

14. Personal data breach notification

In the event of a personal data breach, JKLC will notify affected data principals without delay, and will notify the Data Protection Board of India without delay with initial details, followed by a detailed report within the period prescribed under the Digital Personal Data Protection Rules, 2025 (currently 72 hours from becoming aware of the breach, extendable where permitted). Such notification will, where applicable, describe the nature, extent and timing of the breach, its likely consequences, the measures taken or proposed to mitigate the risk arising from it, and safety steps the individual may take.

15. Data principal rights and requests

Subject to applicable law, individuals may exercise the following rights in relation to their personal data:

• Right to access information — obtain a summary of personal data being processed by JKLC and the processing activities undertaken;
• Right to correction and erasure — request correction of inaccurate or incomplete personal data, updating of personal data, and erasure of personal data that is no longer necessary for the purpose for which it was processed;
• Right to grievance redressal — register a grievance with JKLC in respect of any act or omission regarding processing of personal data or the exercise of these rights (see Section 15);
• Right to nominate — nominate another individual to exercise these rights on the data principal’s behalf, in the event of death or incapacity (see Section 16); and
• Right to withdraw consent — withdraw consent at any time where consent is the basis of processing, with the same ease with which it was given (see Section 6).

Requests may be made through the privacy contact details provided in Section 15. JKLC may request reasonable information to verify the identity of the person making a request and to protect against unauthorised disclosure.

16. Grievance redressal

If you have any question, concern, complaint or grievance regarding the processing of your personal data, you may contact our designated privacy/grievance contact using the details below.

Designated Contact
Email: privacy@jkmail.com
Phone: 1800-102-5097
Postal Address: JK Lakshmi Cement Ltd., Ground Floor, Express Building, Bahadur Shah Zafar Marg, New Delhi – 110002

JKLC will acknowledge a grievance promptly upon receipt and will endeavour to resolve it within a reasonable period, not exceeding 90 (ninety) days of receipt, in accordance with the Digital Personal Data Protection Rules, 2025, or such other period as may be prescribed under applicable law. JKLC will process privacy-related requests and grievances in accordance with applicable law and its internal procedures.

If you are not satisfied with the resolution provided by JKLC, or do not receive a response within the applicable timeline, you may escalate your grievance to the Data Protection Board of India, in the manner prescribed under the DPDP Act and the Digital Personal Data Protection Rules, 2025.

17. Right of nomination

A data principal has the right to nominate, in the manner prescribed under applicable law, any other individual who may exercise their rights under the DPDP Act in the event of death or incapacity of the data principal. Such nomination may be recorded through the privacy contact mechanism provided in Section 15.

18. Language access

JKLC aims to provide important privacy information and consent notices in clear and understandable language.

Where applicable, privacy notices and consent requests may be made available in English and relevant Indian languages, including Hindi and Gujarati, depending on the campaign, user interface and nature of the interaction.

Where a campaign is specifically targeted to Hindi- or Gujarati-speaking audiences, JKLC may provide the relevant lead-form privacy notice and consent information in Hindi or Gujarati.

The Eighth Schedule to the Constitution of India recognises the following languages: Assamese, Bengali, Bodo, Dogri, Gujarati, Hindi, Kannada, Kashmiri, Konkani, Maithili, Malayalam, Manipuri, Marathi, Nepali, Odia, Punjabi, Sanskrit, Santhali, Sindhi, Tamil, Telugu and Urdu. While it may not be feasible to publish this Policy in all Eighth Schedule languages at present, JKLC will explore providing a mechanism or link through which an individual may access this notice in their preferred regional language, and will expand language coverage over time based on feasibility and campaign requirements.

19. Children’s personal data and persons with disability

Our services and marketing campaigns are not generally intended to collect personal data from children. Where JKLC processes personal data relating to a child, it will obtain verifiable consent of the child’s parent or lawful guardian before such processing, in accordance with applicable law.

JKLC shall not undertake tracking or behavioural monitoring of children, nor target advertising directed at children, except where such processing is permitted under applicable law and subject to any conditions prescribed.

Where personal data relates to a person with disability who has a lawful guardian, such processing shall be based on the consent given by the lawful guardian on behalf of that person with disability, in accordance with applicable law.

20. Duties of data principal

While exercising rights under applicable law, a data principal is expected to: comply with applicable law when exercising such rights; ensure that no false or frivolous grievance is registered; furnish only information that is verifiably authentic while exercising the right to correction or erasure; and not impersonate another person while providing personal data for a specified purpose.

21. International data processing

Where personal data is processed, stored or transferred outside India through JKLC’s authorised service providers or technology platforms, such processing will be undertaken subject to applicable legal requirements and appropriate safeguards.

22. Third-party websites and platforms

Our websites or digital communications may contain links to third-party websites, applications, social media platforms or other services. JKLC is not responsible for the privacy practices of third parties that operate independently from JKLC. We encourage users to review the privacy policies of such third parties before providing personal data.

23. Changes to this Privacy Policy

JKLC may update this Privacy Policy from time to time to reflect changes in our business activities, technology, legal requirements or data-processing practices. Any updated version will be published on our website with an updated “Last Updated” date. Where required by applicable law, JKLC will provide additional notice or seek consent for material changes to processing purposes.

24. Contact us

For questions, privacy requests, withdrawal of consent, marketing opt-out or complaints relating to your personal data, please contact:

Privacy Officer / Designated Privacy Contact
JK Lakshmi Cement Limited
Email: privacy@jkmail.com
Address: JK Lakshmi Cement Ltd., Ground Floor, Express Building, Bahadur Shah Zafar Marg, New Delhi – 110002

25. Campaign lead consent notice

By submitting this form, I agree that JK Lakshmi Cement may process the personal information provided by me to respond to my enquiry, understand my requirement and contact me regarding my request. I understand that I may withdraw my consent or opt out of marketing communications at any time. Please read our Privacy Policy for more information.

26. Optional marketing consent

I would like to receive promotional offers, product information, updates and marketing communications from JK Lakshmi Cement through phone, SMS, WhatsApp and/or email.

This marketing consent is optional unless otherwise expressly stated and legally justified.

27. Campaign lead consent record

For each campaign-generated lead, JKLC’s authorised systems should, where applicable, maintain an auditable record of:

• Lead ID;
• Name and contact information;
• Lead source/platform;
• Campaign name and campaign ID;
• Form name and form version;
• Consent status;
• Consent type/purpose;
• Consent timestamp;
• Consent notice/privacy policy version;
• Relevant attribution information;
• Marketing consent status;
• Withdrawal/opt-out status;
• Withdrawal date/time, where applicable; and
• Action taken following withdrawal/opt-out.

These records should be managed in accordance with JKLC’s approved data retention and information-security requirements, and in line with the retention periods set out in Section 11.

28. Effective date

This Privacy Policy is effective from 21/08/2026 and supersedes any previous version of the Privacy Policy to the extent applicable.

Last Updated: 21/08/2026
Policy Version: 1.0