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.
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.
The meaning of some of the terms in use in the Policy are explained below:
|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.|
|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:
We process your personal data based on the following reasons:
7. Processing Sensitive Personal Data
We may, where legally permissible, process your Sensitive Personal Data on the following lawful bases:
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:
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:
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:
We have implemented the following safeguards to ensure the security of the data we collect, store, process, and share:
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
Data Privacy Officer for Linkites Corporation (US) and European Representative:
Avani Jain – email@example.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
15. List of Linkites Entities
We may transfer your personal data to Linkites Corporation, and its subsidiaries.