Privacy Policy

1. Introduction Your privacy is important to us. Linkites Infotech Pvt Ltd and its group companies hereinafter referred as ‘Linkites,’ is committed to respecting your privacy while using our website. This policy, called the Linkites Data Privacy Policy (“Policy”) outlines our requirements for complying with applicable data privacy laws and regulations related to the collection, […]

1. Introduction
Your privacy is important to us. Linkites Infotech Pvt Ltd and its group companies hereinafter referred as ‘Linkites,’ is committed to respecting your privacy while using our website. This policy, called the Linkites Data Privacy Policy (“Policy”) outlines our requirements for complying with applicable data privacy laws and regulations related to the collection, use, and transmission of personal data and sensitive personal data for information collected by us about you.

Protecting the privacy rights of individuals and safeguarding their Personal Data is now being treated as a basic right of an individual and a legal requirement in many parts of world. Linkites, being a global organization, respects the privacy of data subjects and is committed to complying with the applicable data privacy laws and legislations (including but not limited to EU General Data Protection Regulation 2016/679, California Consumer Privacy Act, The Privacy Act 1988 (Australia) including the Australian Privacy Principles (APP), Data Protection Act 2018 (UK), Information Technology Act 2000 read along with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and Personal Data Protection Act 2012 (Singapore) and other applicable privacy laws to the extent that they apply to the data processing and business operations of Linkites.) (the “Data Privacy Laws”)

2. Policy Statement
This Policy is designed to explain and set out Linkites procedures and policies when processing Personal Data and Sensitive Personal Data (the meaning of which are set out below) by the organization. This policy defines the requirements to ensure compliance with the Data Privacy Laws applicable to Linkites’ collection, use, and transmission of Personal Data and Sensitive Personal Data.

3. Scope
The scope of this Policy applies to Linkites, its affiliates, business partners, employees, and Third Parties providing services to Linkites (together “Linkites”, “we” or “us”). It covers Processing (including but not limited to collection, storage, usage, transmission and destruction) of Personal Data and Sensitive Personal Data of current and previous employees of Linkites, prospective candidates, current and previous customers, current and previous partners/vendors, website visitors, sub-contractors and visitors, (together “you”/ “your”) by Linkites during the course of its business activities.

Linkites acts as a Data Controller with respect to any Personal Data or Sensitive Personal Data it holds about you. Linkites is responsible for ensuring that it uses your Personal Data in compliance with the Data Privacy Laws. The relevant entities that may act as the Data Controller are listed in Section 23 of this Policy.

This Policy sets out the basis on which any Personal Data, Personal Information and Sensitive Personal Data about you that you provide to us, that we create, or that we obtain about you from other sources, will be processed by us.

4. Definitions
The meaning of some of the terms in use in the Policy are explained below:

Term Description
Personal Data Any information of Data Subject which can reasonably associate or link to an identifiable natural person or could include anyone who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, economic, cultural or social identity of that natural person.
Personal Information (applicable only to California residents) Information pertaining to residents of California that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, but does not include information that is lawfully made available from federal, state or local government records, nor does it include “deidentified” or “aggregate customer information” as those terms are defined pursuant to the CCPA. Linkites does not collect Personal Information from California residents that are under the age of 16.
Sensitive Personal Data Defined as any information revealing an identified or identifiable natural per-son’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and the processing of genetic information, biometric information for the purpose of uniquely identifying a natural person, data concerning health, or information concerning an individual’s sex life or sexual orientation, and data relating to offenses, or criminal convictions. With respect to California residents, in addition to the preceding, the term also includes national origin or ancestry, sexual orientation, sex (including, gender, gender identity, and gender expression), pregnancy, childbirth and medical conditions related to same, age, physical or mental disability, veteran status, genetic information and citizenship.
Process, Processes, Processed or Processing Means any operation or set of operations which is performed on Personal Data or Personal Information or Sensitive Personal Data or on sets of Personal Data or Personal Information or Sensitive Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
Consent Any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which the Processing of their Personal Data, Personal Information and/or Sensitive Personal Data via a statement or by a clear affirmative action, signifies agreement to the processing of their Personal Data, Personal Information and/or Sensitive Personal Data.
Data Subject Relates to a particular natural person (i.e. an identified or identifiable natural person to whom the Personal Data relates. In case of a minor/ individual with mental disabilities, the data subject would be represented by a legal representative (parent/ guardian). For the purpose of clarity of this Policy, “Data Subject” means Linkites current and previous employees, candidates, current and previous customers, current and previous partner/vendor personnel, website visitors, sub-contractors and visitors. Linkites does not collect Personal Data/ Personal Information and Sensitive Personal Information from Data Subjects that are under the age of 18. For the purpose of CCPA, Data Subject shall include California residents
Data Controller Means a person or organization who (either alone, or jointly, or in common) determines the purposes for which and the manner in which any Personal Data are, or are to be, Processed. For the purposes of this Policy, references to Data Controller shall mean references to Linkites and its affiliates, where relevant.
Data Processor Is a person or organization who Processes the Personal Data on behalf of and under the instruction of the Data Controller
Third Party In relation to Personal Data or Personal Information or Sensitive Personal Data means any person other than the Data Subject, the Data Controller, or any Data Processor or other person authorized to process data for the Data Controller
“Sell,” “selling,” “sale,” or “sold,” Means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Data or Personal Information by the business to another business or a Third Party for monetary or other valuable consideration.

5. How we collect your Personal Data/ Personal Information / Sensitive Personal Data
We will collect and process the following Personal Data / Personal Information/ Sensitive Personal Data about you as follows:

Data Elements / Categories How we collect your data
Customer Personal Data or Personal Information in Projects During the course of providing services to you, Linkites may directly collect data or information from you.
Business Partner/Vendor Personal Data or Personal Information We may collect data or information directly from you when Linkites is receiving services from you.
Prospective Candidates We may collect prospective candidate information from third-party sources, such as recruitment agencies or through Linkites employee referrals. However, this will only be done to the extent that is legally permissible and necessary to fulfill the position in question. Additionally, we may collect information directly from you if you apply for a position through our website.
Employee Data Directly from you during the course of your employment.
   Visitor information     Directly from you at the time of visiting our premises.
Website Data When you voluntarily fill out specific forms on our website to receive information from us or to contact us, we collect your identity information and contact details, such as your first and last name, work email, and company name. You can browse our website without providing any Personal Data about yourself. Additionally, we do not collect any of your Sensitive Personal Information on our website.
Website Cookies Please refer to our Cookie Policy for information about our website cookies.
Marketing Data, Events and Initiatives We may collect your information when you interact with Linkites representatives through various channels, such as our website, events, conferences, workshops, surveys, by telephone, email, online portal, in person, or via professional networking platforms like LinkedIn or Twitter.
Prospective Customers and business partners/ vendors We may collect information from customers, business partners, and vendor referrals. Also referred to as “website data”, “Marketing Data, Events and Initiatives”.

If Personal Information is collected from any electronic source, including the internet, or by using a pen and paper, an algorithm, or any other means, this applies only to California residents and in addition to the preceding statement.

6. Purpose and Lawful basis of Processing
We store and process your personal data for the following lawful purposes:

  • Reviewing and processing job applications and (where legally permissible and necessary to assess suitability for the relevant role) conducting background screening checks on job applicants.
  • Carrying out activities relating to employment contracts, such as processing salaries, administering benefits, providing training relevant to your role, and managing employee performance.
  • Providing products and services to customers.
  • Complying with legal and regulatory obligations.
  • Establishing, exercising, or defending our legal rights or for legal proceedings.
  • Recording and monitoring use of our premises and/or information technology systems by employees or visitors for security purposes.
  • Operating our website, managing our business efficiently, conducting marketing activities to improve the products and services we offer, and administering the security of our business (Legitimate Business Interests).
  • Preventing and responding to actual or potential fraud or illegal activities.
  • Internal research for technological development and demonstration.
  • Transferring personal information as an asset through a merger, acquisition, bankruptcy, or other transaction in which a third party assumes control of the business in whole or in part.

We process your personal data based on the following reasons:

  • Performance of Contract: We process your personal data where necessary to enter into or perform obligations under a contract with you.
  • Consent: Where permitted by applicable laws, we may process your personal data based on your prior consent. You may withdraw your consent at any time by contacting us. In certain limited circumstances, even after withdrawal of your consent, we may continue processing your personal data if we have a legal basis for doing so.
  • Legitimate Interests: We may process your Personal Data and Personal Information when it is necessary for our legitimate business interests, as outlined above.
  • Legal Obligations: We may process your Personal Data and Personal Information when it is necessary to comply with applicable legal and regulatory obligations, establish, exercise or defend our legal rights, or for legal proceedings, and to prevent and respond to actual or potential fraud or illegal activities. 
  • Other “Public Interest” Grounds: We may process your Personal Data and Personal Information (or, where relevant, your Sensitive Personal Data) on other public interest grounds subject to regulatory requirements, where processing is necessary for the performance of a task mandated by governmental, regulatory, or law enforcement authorities in the public interest.

7. Processing Sensitive Personal Data
We may, where legally permissible, process your Sensitive Personal Data on the following lawful bases:

  • Explicit Consent: When explicit consent is obtained from you where required under applicable local laws, or in specific circumstances where you are physically or legally incapable of giving consent, but processing is necessary to protect your vital interest, for example, when emergency medical care is needed.
  • Without Explicit Consent: When processing is specifically authorized or mandated by applicable local Data Privacy Laws, including but not limited to circumstances where Linkites is permitted to process Sensitive Personal Data.

8. Personal Data of Individuals below 18 years
We may process Personal Data or Sensitive Personal Data of individuals below the age of 18 years only for travel and immigration purposes. If we are required to process Personal Data or Sensitive Personal Data of such individuals, we shall do so by taking explicit written consent from their legal guardians. If it comes to your attention that we have unintentionally collected or received Personal Data or Sensitive Personal Information about an individual below the age of 18 years directly from them, immediately notify us in the contact details provided in this Policy, and we will delete such information accordingly.

Note: If you are below the age of 18 years, we do not want you to provide any of your Personal Data on our website.

9. How we will be using your Personal Data/Personal Information for Direct Marketing
For direct marketing purposes, we will use your Personal Data/Personal Information in the following ways, to the extent that it complies with applicable local laws:

  • Manage and maintain our relationship with you, including responding to your inquiries, questions, or comments.
  • Engage in marketing and business development activities to improve the products and services of Linkites.
  • Improve the products and services we offer to you and administer the security of our business.
  • Conduct analysis and market research to improve this website.
  • Inform you about our service offerings by communicating through email, SMS, phone, and any other similar means of communication.
  • Respond to any legal process or as required by law in response to any court order, subpoena or law enforcement agency, defending us in case of legal disputes or to take action against any illegal activity and to address any potential threat to the physical safety of a person.
  • California residents who provide Personal Information are entitled to request information about themselves that we shared with Third Parties for their own direct marketing purposes (if applicable), including the categories of information and the names and addresses of those businesses. We do not currently share the Personal Information of California residents with Third Parties for their own direct marketing purposes.

10. Events and Initiatives
We organize and participate in events and initiatives. In such cases, this Policy applies to participants and speakers together with any other supplementary information provided in relation to each event. In the event we appoint any Third Parties to conduct or organize such events and initiatives, your Personal Data or Personal Information shall be shared with such Third Parties under contractual obligations with them in compliance with applicable Data Privacy Laws. The processing of Personal Data/Personal Information by such Third Parties shall be governed by their respective privacy policies and the contractual obligations entered into with us.

11. Retention and Disposal of Personal Data/Personal Information
How long we continue to hold your Personal Data/Personal Information will vary depending principally on:

  • Purposes identified in this Policy for using the Personal Data/Personal Information/Sensitive Personal Information – we will need to keep the information for as long as is necessary for the relevant purpose; and
  • Legal obligations – laws or regulations may set a minimum period for which we will have to keep your Personal Data/Personal Information/Sensitive Personal Information.

Disposal of Personal Data/Personal Information/Sensitive Personal Information shall be handled with utmost care and shall be governed in accordance with reasonable data security practices as detailed in our internal policies governing data disposal. Personal Data/Personal Information/Sensitive Personal Data shall only be processed for the period necessary for the purposes for which it was originally collected, as per the Linkites Retention Policy.

12. Security of Personal Data/Personal Information/Sensitive Personal Data
To comply with our data security obligations under applicable Data Privacy Laws, we have adopted the following physical, technical, and organizational security measures to ensure the security of your Personal Data/Personal Information and Sensitive Personal Data:

  • Prevention of alteration, damage, loss, unauthorized processing, or access to Personal Data/Personal Information and Sensitive Personal Data, taking into account the nature of the data and the risks associated with human action or the physical or natural environment.
  • Compliance with security safeguards as per our contractual and statutory requirements in consultation with our internal IT department.
  • Regular assessment of security measures implemented to safeguard Personal Data/Personal Information and Sensitive Personal Data by the Office of Data Privacy and Chief Information Security Officer, and update as necessary.
  • All employees and contractors must undergo mandatory Privacy training (e.g., Training on Embedding Privacy in Software Development, etc.). Furthermore, confidentiality agreements and Non-Disclosure Agreements must be signed by all employees and contractors on or before their joining date with Linkites.

We have implemented the following safeguards to ensure the security of the data we collect, store, process, and share:

  • Physical Security Controls
    • Facility Perimeter, HD access reader, Data Centre, Video surveillance
  • IT Infrastructure Controls
    • Encryption, DLP, Data masking, controlled Portable ports, Access Control, Unauthorized software check, Data destruction, System Hygiene measures, Monitoring, User Access Management, Patch Management, Vulnerability Management

We have implemented an incident and breach management procedure to ensure that exceptions in data privacy compliance are promptly reported to the Office of the Data Privacy.

Global Data Privacy Officer for Linkites Infotech Pvt Ltd:

Data Privacy Office:6th Floor Crystal IT Park, Indore ( M.P),India

Attention: Lisa Jain 

Phone- +919806719331

Data Privacy Officer for Linkites Corporation (US) and European Representative:

Avani Jain – avani@linkites.com

13. CCTV Surveillance
Where permitted by applicable local laws, we may monitor the activities of individuals, including visitors in our common areas, through CCTV footage. Such data shall be kept in accordance with Linkites Retention Policy, after considering other statutory compliance requirements.

14. Policy Revisions and Publication

  • This Policy may be revised and updated from time to time.
  • The most recent version of this Policy is available on this web page.

15. List of Linkites Entities
We may transfer your personal data to Linkites Corporation, and its subsidiaries.