PRIVACY POLICY

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how IMS Group collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up for job alerts or newsletters, send an inquiry, or register as a candidate.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice that we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

DATA CONTROLLER

Interactive Manpower Solutions Private Limited (collectively referred to as “IMS Group” “we”, “us” or “our” in this privacy notice), provides outsourced recruitment services to our clients around the world. In most cases, we act as a data processor on behalf of your clients, who are data controllers. As data controllers, they are responsible for notifying you of your rights and you should refer to their privacy policies for information about how they process your data.

However, in some circumstances we may also act as a data controller in respect of your personal data. This Privacy Policy aims to give you information on how we collect and process your personal data, where we act as a data controller.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS

Our full details are:

Interactive Manpower Solutions Private Limited, trading as IMS Group:

Data privacy manager: Kunal Roy

Email address: [email protected]

Postal address: 1 / 2 Indraprasth Business Park, Near DAV School, Prahladnagar Extension, Makarba, Ahmedabad 380051.

Telephone number: +91 79 6827 4422

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 6^th August 2019 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Contact data including name, email address, phone number, organisation
• Device and browser data, such as IP address, information about your device and browser settings;
• Marketing and communications data, including your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Where we collect or process any other categories of personal data (including sensitive personal data) about you that are not listed above, we will send you a separate Privacy Notice regarding the processing of such data by us.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We may collect data about you when you register with us, visit our website, or when we communicate by email, SMS, phone or in person.

We use different methods to collect data from and about you from third parties:

• (a) social media platforms, such as LinkedIn and Facebook based outside the EU;
• (b) analytics providers such as Google based outside the EU;
• (c) advertising networks, such as Google based outside the EU;
• (d) search information providers, such as Google and Bing based outside the EU;
• (e) publicly available sources, such as press releases, company websites, social media networks like LinkedIn or Google Search;
• (f) Chat Service provider, Zendesk, based outside the EU;
• (g) mobile apps such as Whatsapp based both inside and outside the EU.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract, we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

MARKETING

We would like to use your contact details to contact you about news and information which we think may be of interest to you. However, we will not contact you with marketing material unless you consent to our doing so.

You may also receive marketing communications from us if you have previously requested information or services from us and you did not opt out of receiving marketing communications from us at the time.

You have the right to unsubscribe at any time, by clicking the link which appears in the email footers of marketing emails.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with third parties for marketing purposes.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Your personal information will be processed by our internal staff and subcontractors (including IT providers).

We may be required by law to share certain categories of your personal data with tax authorities and other government agencies.

We may also share your personal data with third parties to whom we may choose to transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We will not share your personal data with any other organisation unless it is necessary and in connection with providing our work-finding and recruitment services.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Your personal data will primarily be stored in India, which is outside the European Economic Area (EEA) on either local or cloud-based servers. We may also have access to the personal data of candidates held by our hirer clients, both within the EEA and outside it. We will take all reasonable steps to ensure that your data is subject to the same protection as that provided by the EU and that it is subject to technical and organisation safeguarding protection measures as provided by the EU. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.

Some categories of data may be transferred to our hirer clients in other countries outside the EEA. We will take all reasonable steps to ensure that your data is subject to the same protection as that provided by the EU and that it is subject to the same technical and organisational safeguarding protection measures, as follows:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries, or
• We will only transfer your personal data to or from organisations outside the EEA with whom we haveentered into an agreement containing specific contract clauses approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We will only transfer personal data to a third party if they agree to comply with those procedures and policies, or put in place adequate measures prior to receiving it. Maintaining data security means guaranteeing the confidentiality, integrity and availability (for authorised purposes) of the personal data.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

FOR HOW LONG WILL YOU USE OR RETAIN MY PERSONAL DATA?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

By law we have to keep certain information about candidates for 8 years. Where we have entered into a contract with you, we may also need to retain data for up to 8 years in order to ensure that we can meet our contractual obligations to you.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.