Privacy Policy.

Who this policy covers

This policy applies to smpalgroup.com and the pages within it (the “Website”), including the pages for Pal Stone Industries, Pal Colonisers, Pal Frozen Foods (Pal Fresh and Frozzo), Pal Fresh Global Trading LLC and our car dealerships (Pal Skoda, Pal Nissan and Pal Ford).

In this policy, “SM Pal Group”, “we”, “us” and “our” mean the group of companies that run the Website, and “you” means anyone who visits it or contacts us through it.

It covers information collected through the Website and through enquiries that begin on it, including calls, emails and WhatsApp messages you send using the contact details we publish there.

Other websites run by our group companies, such as thepalgroup.in and palfrozenfoods.in, are separate and may have their own privacy policies. Information you give us offline—for example, at a showroom, project site, office or plant, or when you sign a booking form or agreement—is covered by the notices and terms we give you at that time.

The information we collect

Information you give us

When you use the “Start a conversation” form on our Contact page, we ask for your name, email address and message—meaning whatever you tell us about how we can help.

If you call us, email us or message us on WhatsApp, we also receive your phone number and anything you choose to share in that conversation. Enquiries often relate to something specific: a home or plot you are interested in, a car you would like to buy or service, a supply or distribution enquiry, or a job.

Please do not send sensitive information through the form or by email, such as Aadhaar or PAN numbers, bank or card details, passwords or health information. We do not need these to respond to an enquiry. If we need documents later, for example to process a booking, our team will tell you how to share them securely.

Information collected automatically

When you visit the Website, our servers and the tools we use collect some technical information automatically, such as:

• Your IP address and the approximate location (city or region) it indicates.
• Your browser type and version, device type and operating system.
• Your language preference and screen size.
• The page or link that brought you to the Website.
• The pages you view, links you click, how long you stay, and the date and time of your visit.

This information does not tell us your name. We use it to understand how people use the Website and to keep it secure and working properly.

How we use your information

We use personal data only for specific purposes that we have told you about or that the law allows. In particular, we use it:

• To respond to your enquiry and work out which of our businesses can help you best.
• To connect you with the right group company or team, such as Pal Colonisers for a property enquiry or Pal Skoda for a car enquiry.
• To arrange what you ask for, such as a site visit, test drive, service appointment, quote or call-back.
• To keep you updated if you ask us to, including project launches, vehicle launches or product news. You can stop these updates at any time.
• To improve the Website, keep it secure, and prevent spam, misuse and fraud.
• To meet legal obligations, respond to lawful requests, and protect our legal rights.

We will not use your personal data for a purpose that is very different from the one you gave it for without telling you first and, where the law requires, asking for your consent again.

Our legal basis for using your information

We handle personal data in line with Indian law, including the Information Technology Act, 2000 and the rules made under it, and the Digital Personal Data Protection Act, 2023 and the Digital Personal Data Protection Rules, 2025, as they come into force.

In practice, we process your personal data either with your consent—for example, when you submit the contact form after reading this policy or opt in to receive updates—or for a “legitimate use” the law recognises, such as when you voluntarily give us your details for a stated purpose and have not told us you object to our using them, or when we need to comply with the law.

You can withdraw your consent at any time. Withdrawing consent does not affect anything we lawfully did before you withdrew it, but it may mean we can no longer deal with your enquiry or send you updates.

Who we share your information with

We do not sell your personal data. We share it only in these situations:

• Within SM Pal Group: with the group company or team that can deal with your enquiry.
• With service providers: providers that help us run the Website and our communications, such as hosting, email and messaging, analytics and IT support. We ask them to protect your data and use it only for the services they provide to us.
• With authorities and advisers: when required by law, a court order or a lawful government request, or when we need advice from our lawyers, auditors or other professional advisers.
• In a business change: such as a restructuring or sale of part of a business. We will make sure your data stays protected and, where the law requires, tell you.

Cookies and similar technologies

A cookie is a small text file that a website saves on your device so that it can recognise your device and remember things about your visit. Depending on the page and how you use it, the Website may use:

• Essential cookies, which help the Website work properly and stay secure.
• Analytics cookies, which tell us how visitors use the Website. We use Google Tag Manager to manage these tools. Depending on how we set them up, they may include Google Analytics or similar services.
• Marketing and measurement cookies, if we run online campaigns, which help us understand whether a visit followed one of our campaigns.

You are in control. Most browsers let you block or delete cookies, and you can usually set them to warn you before a cookie is stored. Google also offers a browser add-on that lets you opt out of Google Analytics. If you block cookies, some parts of the Website may not work as well as they should.

This policy covers cookies set by us. We do not control cookies set by third parties, so please check their policies too.

Third-party links and services

The Website links to sites and services we do not operate, including LinkedIn, YouTube, WhatsApp and other websites in the Pal Group family, such as thepalgroup.in. When you click one of these links, you leave our Website and the other party’s privacy policy applies.

We are not responsible for their content or practices, and we encourage you to read their policies. If you message us on WhatsApp, WhatsApp’s own terms and privacy policy apply to that conversation in addition to this one.

How long we keep your information

We keep personal data only for as long as we need it for the purpose you gave it for, or for as long as the law requires. For example:

• Enquiry details: for as long as it takes us to deal with your enquiry, plus a reasonable period afterwards in case you come back with follow-up questions.
• Analytics data: in summary or anonymised form for as long as it is useful, or for the retention period set in the analytics tool.
• Records the law requires us to keep: for the period the law specifies.

When we no longer need your personal data, we delete it or make it anonymous.

How we protect your information

We use reasonable security safeguards to protect personal data from unauthorised access, loss, misuse and disclosure. These include encrypting data in transit using HTTPS, limiting access to team members who need it, and working with providers who maintain appropriate security standards.

No method of transmitting or storing data online is completely secure, so we cannot guarantee absolute security. If a personal data breach affects you, we will notify you and the Data Protection Board of India as the law requires.

Transfers outside India

Some tools we use, such as Google’s analytics services, may process data on servers outside India. We transfer personal data outside India only as Indian law allows, and we ask our providers to protect it.

Children’s privacy

The Website is meant for adults. We do not knowingly collect personal data from anyone under 18 without the verifiable consent of a parent or lawful guardian. If you believe a child has given us personal data without that consent, please tell us and we will delete it promptly.

Your rights and choices

Under Indian data protection law, you have the right to:

• Know what we hold: ask for a summary of the personal data we process about you, what we do with it, and who we have shared it with.
• Correct and update: ask us to correct inaccurate or misleading data, complete missing information, or update changed details.
• Erase: ask us to delete personal data we no longer need or that you no longer want us to hold, unless the law requires us to keep it.
• Withdraw consent: withdraw your consent at any time.
• Get your concerns resolved: raise a grievance with us and have it dealt with.
• Nominate someone: name another person to exercise your rights for you if you die or become unable to do so.

To use any of these rights, email marketing@smpalgroup.com with the subject line “Privacy request”, or write to us at the address below. We may ask you to confirm your identity so that we do not share your data with the wrong person. We will acknowledge your request within 7 days and aim to resolve it within 30 days. These rights are subject to the conditions and exceptions in the law.

In return, we ask that you give us accurate information, do not impersonate anyone else, and do not make false or frivolous complaints.

Grievance officer and how to contact us

If you have a question, concern or complaint about how we handle your personal data, please contact us:

We will look into your concern fairly and reply within the timelines above. If you are not satisfied with our response, you can complain to the Data Protection Board of India once that route is available to you. The law asks you to raise your concern with us first.