Privacy Policy
How we collect, use, store, and protect your personal data — written for the Digital Personal Data Protection Act, 2023 and the Digital Personal Data Protection Rules, 2025 (India).
Section 01
Who We Are
This Privacy Policy applies to LEINOS ORGANIC PAINTS PVT. LTD. (“LEINOS India”, “we”, “us”), the authorised distributor of LEINOS natural paints (manufactured by Reincke Naturfarben GmbH, Germany) for the Indian market.
For the purposes of the Digital Personal Data Protection Act, 2023 (“DPDPA”) and the Digital Personal Data Protection Rules, 2025 (“DPDP Rules”), LEINOS India is the Data Fiduciary in respect of personal data collected through this website (https://www.leinos.in) and associated channels (email, telephone, WhatsApp).
Registered office: Khasra No. 646/1, Road No. Zero, Bakshi Farm Road, Ghitorni, 110030 New Delhi, India
GSTIN: 07AAFCL0615C1Z3
Email: sales@leinos.in
Phone: +91 999 789 7474
Section 02
What Personal Data We Collect
We collect personal data only when you voluntarily provide it — through inquiry forms, sample requests, dealer applications, workshop sign-ups, email, or WhatsApp. The categories of personal data we may collect:
- Name
- Email address
- Phone number (mobile / WhatsApp)
- City, region, or pincode (to refer you to a local dealer)
- Professional context (company, role, project type) — for B2B and dealer enquiries
- Free-text notes you choose to include (project description, surface, timeline, questions)
- Technical data automatically logged by web servers and analytics (see Section 09 — Cookies & Analytics)
We do not knowingly collect sensitive personal data such as Aadhaar or other government IDs, financial details, health information, biometric data, sexual orientation, religious or political beliefs. Please do not share such information through our forms or messages.
Section 03
Why We Process Your Data
We process the data you give us only for specific, declared purposes:
- Responding to your inquiry, question, or sample request
- Connecting you with an authorised LEINOS dealer or specifier in your region
- Scheduling a workshop, factory visit, dealer onboarding call, or specifier consultation
- Sending the technical documents you requested (TDS, SDS, calculator output, shade reference, project deck)
- Following up on an active project, sample shipment, or pending order until the matter is closed
- Improving the website, content, and customer experience (aggregate analytics — see Section 09)
- Complying with applicable Indian law (record-keeping, tax, complaint handling)
We do not use your data for automated decision-making, profiling, behavioural advertising, or unsolicited marketing.
Section 04
Legal Basis — Your Consent
Under the DPDPA, we process your personal data on the basis of your free, specific, informed, unconditional, and unambiguous consent, given when you submit a form, send an email, or initiate a WhatsApp conversation with us.
Where the law permits (for example, certain legitimate uses defined in Section 7 of the DPDPA, including responding to a specific request you have made), we may process limited data without a separate consent request.
You can withdraw your consent at any time by writing to our Grievance Officer (Section 13). Withdrawal does not affect the lawfulness of processing already done under your earlier consent, and may limit our ability to keep responding to your enquiry.
Section 06
International Data Transfers
Some of the processors listed in Section 05 (WhatsApp Business, email providers, Reincke Naturfarben GmbH in Germany, certain hosting infrastructure) may process your data outside India. Such transfers happen only in jurisdictions not restricted by the Government of India under Section 16 of the DPDPA, and only as necessary to deliver the service you requested.
If the Central Government later restricts transfers to any of these countries, we will relocate the affected processing or update this Policy and notify you.
Section 07
How Long We Keep Your Data
We keep your inquiry data for one (1) year from the date of our last meaningful interaction with you (last reply, last message, or last project milestone).
After that period, we either delete the data, anonymise it for aggregate reporting, or retain only the minimum needed to comply with statutory record-keeping obligations under Indian law (for example, tax records, where applicable).
You may ask us to erase your data sooner at any time — see Section 08.
Section 08
Your Rights as a Data Principal
Under Sections 11 to 14 of the DPDPA, you have the following rights:
- Access — obtain a summary of the personal data we hold about you and how we are processing it
- Correction and updating — ask us to correct, complete, or update inaccurate or outdated data
- Erasure — ask us to delete your personal data when it is no longer necessary for the purposes for which it was collected
- Withdrawal of consent — revoke a previously given consent
- Nominate — designate another individual to exercise your rights in the event of death or incapacity
- Grievance redressal — a readily-available means of raising concerns (Section 13)
- Complaint to the Board — escalate your concern to the Data Protection Board of India if, in your view, we have not addressed your grievance satisfactorily
To exercise any of these rights, write to privacy@leinos.in with enough detail to let us identify your record (the email, phone, or approximate date you contacted us). We will acknowledge your request within seven (7) working days and respond substantively within thirty (30) days, in line with the DPDP Rules.
Section 10
Children's Data
Our website and services are intended for adult professionals, homeowners, and trade buyers. We do not knowingly process personal data of children below the age of 18 or of persons with disabilities who have a lawful guardian, without the verifiable consent of the parent or lawful guardian, as required by Section 9 of the DPDPA.
If you believe a child has shared personal data with us, please write to privacy@leinos.in and we will delete it promptly.
Section 11
Security Safeguards
We use reasonable technical and organisational measures to protect your personal data — HTTPS for all traffic to and from the site, access controls inside our customer-relationship platform, the principle of least privilege for staff access, and contractual security commitments from our processors.
No transmission or storage system on the internet is perfectly secure. In the unlikely event of a personal data breach affecting your rights, we will notify the Data Protection Board and you in accordance with the DPDP Rules.
Section 12
Links to Other Sites
Our website links to third-party resources — the global LEINOS site (leinos.de), certifying bodies, dealer pages, and social media. Those sites have their own privacy notices. We are not responsible for their practices.
Section 13
Grievance Officer
In accordance with the DPDPA, we have appointed a Grievance Officer to address any questions, requests, or complaints about how we handle your personal data.
Oleg Zaporozhets
Grievance Officer — LEINOS India
Email: privacy@leinos.in
Postal address: Khasra No. 646/1, Road No. Zero, Bakshi Farm Road, Ghitorni, 110030 New Delhi, India
We will acknowledge your complaint within seven (7) working days and aim to resolve it within thirty (30) days. If you are not satisfied with our response, you have the right to escalate the matter to the Data Protection Board of India.
Section 14
Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, the products we offer, or applicable law. The “Last updated” date below indicates the latest revision. Where the change is material, we will take additional steps to notify you (for example, an in-page notice or an email).
We recommend you review this page periodically. Continued use of the website after a change indicates your acceptance of the updated Policy.
This Privacy Policy is governed by the laws of India, including the Digital Personal Data Protection Act, 2023 and the Digital Personal Data Protection Rules, 2025. Disputes are subject to the exclusive jurisdiction of the courts of New Delhi, India.
Last updated: May 2026