Privacy Policy


Hinduja Global Solutions

Last Updated: September 5, 2023

Hinduja Global Solution Limited is a company incorporated under the laws of India and operates, through various subsidiaries, within and outside of India. Hinduja Global Solutions is committed to the appropriate protection and use of Data that it collects and processes in compliance with applicable Regulations.

Hinduja Global Solutions and its branch office, subsidiaries, and affiliates (“HGS”) intent is to collect only such Data that is provided voluntarily, to enable HGS to offer its Services and for Processing any requests received. Please review this Privacy Policy (“Policy”) to learn more about how HGS manages Data.

Scope

This Policy describes how it collects, stores, processes, uses, transfers, and destructs the Data received from or shared by employees, candidates, interns, customers, vendors, contractors, sub-contractors, website visitors and any other third party (“You” and the term “Your” shall be interpreted accordingly) in course of HGS’s business activities. For country specific Privacy Policy please refer to the links mentioned in this policy.

Key Definitions

“Consent” means freely given, specific, informed, and unambiguous indication of the Data Subject’s wishes via a statement or by a clear affirmative action, signifying agreement to the Processing of Data.

“Data” means Personal Data, Sensitive Personal Data, Digitized Personal Data and any other data or information covered under the Regulation.

“Data Subject” means an identified or identifiable natural person or wherever applicable legal guardian or parents of Data Subject to whom the Data relates. For the purpose of CPRA, 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 way any Data is to be Processed. For the purposes of this Policy, references to Data Controller shall mean references to HGS, its branch offices, subsidiaries, and its affiliates, where relevant.

“Data Processor” means a person or organization who Processes the Data on behalf of and under the instruction of the Data Controller.

“Policy” means this Privacy Statement and Cookie Policy.

“Process”, “Processes”, “Processed”, or “Processing” refers to any operation or set of operations which is performed on Data or on sets of Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

“Profiling” means any form of automated processing of Data to evaluate certain personal aspects relating to a natural person, including but not limited to work performance, health, reliability, etc.

“Personal Data” refers to any information of Data Subject which can be reasonably associated with or linked to an identifiable natural person or anyone who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location, an online identifier or to one or more factors specific to the physical, physiological, economic, cultural or social identity of that natural person, and also includes personal information as prescribed under the Regulations including California Consumer Privacy Act (CCPA) & California Privacy Rights Act (CPRA).

“Personal Information” (applicable only to California residents) refers to 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 & CPRA. HGS does not collect Personal Information from California residents that are under the age of 16.

“Profiling” means any form of automated processing of Data to evaluate certain personal aspects relating to a natural person, including but not limited to work performance, health, reliability, etc.

“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 Data Subjects Data by the business to another business or a Third Party for monetary or other valuable consideration.

“Sensitive Personal Data” refers to such Data being defined as any information revealing an identified or identifiable natural person’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, and includes information as may be prescribed under the Regulations. With respect to California residents, in addition to the preceding, the term also includes national origin or ancestry, sexual orientation, sex (including, gen-der, gender identity, and gender expression), pregnancy, childbirth and medical conditions related to same, age, physical or mental disability, veteran status, genetic information and citizenship.

“Regulations” means all applicable privacy laws and Regulations applicable in countries where HGS operates, as may be in force from time to time.

“Services” refers to services offered by HGS.

“Third-Party” 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.

Core Privacy Principles

This Policy address the core data privacy principles to emphasize our commitment to Privacy :

  1. Lawfulness, Fairness, and Transparency – collect Data that is required for lawful purpose
  2. Limitations on Purposes of Collection, Processing, and Storage – clear purpose for which Data will be used
  3. Data Minimization and Accuracy – collect only that is necessary
  4. Data Security and confidentiality – secure and limit access to Data
  5. Data Storage Limits – consider the purpose when determining archiving
  6. Accountability – be responsible for Data collected

Collection and Use of Personal Information

What Information Do We Collect?

HGS may collect Data about You if you choose to provide it through any means including access and use of HGS’s websites, social media, physical and electronic/online documents, forms, etc.

The category of Data collected and processed will differ based on Your interaction with HGS and the purpose for which the Data is shared with HGS.

HGS Process three broad categories of Data:

Information Provided Directly By You – Data provided by customer/clients, business partners , vendors, prospective candidates, employees , website visitors’ information, collected via any and all modes and will include names, email, employment details, demographics, audio-visual information, video /audio recordings, including Your comments, feedback, correspondence etc.

Information Received from Third Parties – Data provided by potential employees, and other sources like recruitment agencies, referral program, LinkedIn profiles/URLs (or similar professional Data set). Additionally, HGS may collect certain Data points based on the categories of Data Subject and their relationship with HGS , other customer/ business partner and vendor referral.

Information Collected Automatically – In some instances, HGS and its service providers use Cookies, web beacons and other technologies to automatically collect certain types of information when You visit us online, as well as through emails exchanged. HGS may also collect IP addresses, login credentials, such as username and passwords, when You register for any Services. The collection of this information allows HGS to customize Your online experience, improve the performance, usability, and effectiveness of HGS’s online presence, and to measure the effectiveness of HGS marketing activities.

Cookie – A Cookie is a small data file containing a string of characters that is sent to Your computer when You visit a website. When You visit the website again, the Cookie allows that site to recognize Your browser and device. The length of time a Cookie will stay on Your computer or mobile device depends on whether it is a “persistent” or “session” Cookie. Session Cookies will only stay on Your device until You stop browsing. Persistent Cookies stay on Your computer or mobile device until they expire or are deleted.

In some instances, HGS and its service providers use Cookies, web beacons and other technologies to automatically collect certain types of information when You visit HGS online, as well as through emails that You may exchange with HGS.

The collection of this information allows us to customize Your online experience, improve the performance, usability, and effectiveness of HGS’s online presence, and to measure the effectiveness of our marketing activities.

Strictly Necessary Cookies – Some cookies are essential for You to be able to experience the full functionality of our site. These cookies are necessary for the website to function and cannot be switched off in our systems. Please note that without these cookies, our web site may not be displayed optimally, and some functions are no longer technically available. These cookies also enable services You have specifically asked for. For example, when you subscribe to one of our Internet Products, we use session cookies to signal that You are logged in so that You are able to use subscriber features of the website, and persistent cookies to provide automatic login.

Performance Cookies – These cookies collect anonymous information about how You use the website. HGS uses performance cookies for web analytics, which allow HGS to statistically monitor how people are using our website, to help us improve our online offerings as well as to test different design ideas for particular pages. HGS may work with independent measurement and research companies to perform these services for HGS, so some of these cookies may be set by a third-party company. You have a right to allow these cookies to be placed on Your browser. If You do not allow these cookies HGS will not know when You have visited HGS site and will not be able to monitor its performance.

Functionality Cookies – These cookies allow HGS website to remember choices You make to improve Your experience (such as Your unit of measurement preferences) and to provide enhanced, more personal features (such as information about Your browser and whether You have configured your website tools), and to improve response speed and efficiency by storing certainly frequently accessed information. You have a right to allow these cookies to be placed on Your browser. If you do not allow these cookies we will not know when You have visited our site and will not be able to provide You enhanced functionality and personalisation such as allowing the website to remember the choices, You make. On some pages of HGS site, third parties may also set their own anonymous cookies, for the purposes of tracking the success of their application or customizing the application for You. HGS cannot access these cookies, nor can third parties access the data in our cookies.

Advertising And Targeting Cookies – Subject to Your consent, HGS may use cookies to track the effectiveness of advertising purchased on third party sites, and to support our affiliate program by letting our affiliate sites know that a visitor to one of their sites later purchased a product or service on our site. HGS will process Data for the purpose of providing targeted advertisement to You on other websites based on Your visit to our websites and to monitor Your preferences on our website. HGS will also determine how effective its advertising efforts to You have been. You may provide your consent to ‘Targeting cookies’ via the cookie banner that will allow HGS to receive Your Data.

HGS also use cookies to assist in targeted advertising. HGS website’s advertisements may be displayed or served by a third party, and many of the advertisements You see on HGS website are generated by third parties.

Some HGS third-party advertisers use their own anonymous cookies to track how many people have seen a particular ad, or to track how many people have seen it more than once. The companies that generate these cookies have their own privacy policies, and HGS has no access to these cookies. These third-party ad cookies may be used by those third parties to anonymously target advertising to You on other websites, based on Your visit to our website.

HGS also set anonymous cookies on certain other sites that HGS advertises on. If You receive one of those cookies, HGS may then use it to identify You as having visited that site if You later visit HGS site and will serve targeted advertising based on this information.

Remarketing And Targeting Technologies – When You visit HGS web pages and consent to tracking cookies, HGS may recognize Your browser or terminal device (e.g., a so-called browser fingerprint), evaluate Your IP address, store, or read recognition features on Your terminal device (e.g., cookies) or gain access to individual tracking pixels. For this purpose, HGS would like to process the following Data categories:

  • Visitor IP address;
  • Visitor X-Forwarded For;
  • Timestamp;
  • Referrer;
  • Page URL;
  • Cookie ID

HGS can also use these individual features to recognize Your terminal device on HGS websites. Using this tracking technology, HGS may display advertisements on third-party websites to You based on the pages You visited on HGS website.

Important: Kindly note that Your consent provided through the selection of tracking cookies is voluntary. If You want to revoke Your consent at any time or update cookie configurations, You can adapt Your settings by re-opening the cookie banner.

IP Addresses – An IP address is a number assigned to Your computer whenever You access the internet. It allows computers and servers to recognize and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.

Consent to Use Cookies – Note that Your Consent provided for the selection of tracking Cookies is voluntary. However, if You reject cookies, certain products, offerings, features, or resources of our website (including certain Internet Products) may not work properly and You may experience some loss of convenience. You can withdraw Your Consent to the use of Cookies in the future and adjust Your cookie settings on HGS Cookie banner at any time.

To turn off targeting by advertisers, networks, or providers of analytics, You may use the opt-out by accessing the third-party links provided above.

In addition, You can also choose to customise your choices regarding cookies You want to accept. You may configure Your browser to accept all cookies or to alert You every time a cookie is offered by a website’s server. Most browsers automatically accept cookies. You can set Your browser option so that You will not receive cookies and You can also delete existing cookies from Your browser. Please be aware that some parts of the site will not function properly if you have disabled cookies.

The links below set out information about how to change Your browser settings for some of the most used web browsers:

  • Google Chrome
  • Mozilla Firefox
  • Microsoft Internet Explorer
  • Apple Safari

Some browsers, such as Chrome and Firefox, allow You to change Your settings to browse in ‘incognito’ mode, limiting the amount of data placed on Your system/ device and automatically deleting any persistent Cookies placed on Your system/ device when you finish Your browsing session.

To clear Cookies that have previously been placed on Your browser, You should select the option to clear Your browsing history and ensure that the option to delete or clear Cookies is included when You do so.

Use of Cookies – Cookies may be placed on Your computer or internet-enabled device whenever You visit us online. This allows the site to remember Your computer or device and serves several purposes.

On some of HGS web sites, a notification banner will appear requiring Your Consent to collect Cookies. If You do not provide Consent, Your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of Cookie referred to as “user-input” Cookies may still be required for necessary functionality. Such Cookies will not be blocked through this notification banner. Your selection will be saved in a cookie and valid for 90 days (about 3 months). If You wish to revoke Your selection, You may do so by clearing Your browser’s Cookies.

Although most browsers automatically accept Cookies, You can choose whether to accept Cookies via Your browser’s settings (often found in Your browser’s Tools or Preferences menu). You may also delete Cookies from Your device at any time. However, please be aware that if You do not accept Cookies, You may not be able to fully experience some of our web sites’ features.

Further information about managing cookies can be found in Your browser’s help file or through sites such as www.allaboutcookies.org

Other third-party tools and widgets may be used on HGS’s individual web pages to provide additional functionality. Use of these tools or widgets may place a Cookie on Your device to make its service easier to use and ensure Your interaction is displayed on HGS webpages properly.

Cookies themselves do not tell us Your email address or otherwise identify You personally. In HGS’s analytical reports, HGS may obtain other identifiers including IP addresses, but this is to identify the number of unique visitors to HGS web sites and geographic origin of visitor trends, and not to identify individual visitors.

By navigating on HGS web sites or entering Your login details to access areas reserved for registered users, You agree that HGS can place these Cookies on Your computer or internet-enabled device.

Google Analytics – HGS uses Google Analytics. More information about how Google Analytics used by HGS can be found here: http://www.google.com/analytics/learn/privacy.html
To provide website visitors with more choice on how their Data is collected by Google Analytics, Google has developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services.

Web Beacons – A web beacon is a small image file on a web page that can be used to collect certain information from Your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of Cookies previously set by the same server.

HGS or its service providers may use web beacons to track the effectiveness of third-party web sites that provide HGS with recruiting or marketing services or to gather aggregate visitor statistics and manage Cookies.

You have the option to render some web beacons unusable by rejecting their associated Cookies. The web beacon may still record an anonymous visit from Your IP address, but cookie information will not be recorded.

In some of HGS newsletters and other communications, HGS may monitor recipient actions such as email open rates through embedded links within the messages. HGS collects this information to gauge user interest and to enhance future user experiences.

Location-Based Tools – HGS may collect and use the geographical location of Your computer or mobile device. This location Data is collected for the purpose of providing You with information regarding Services which we believe may be of interest to You based on Your geographic location, and to improve our location-based Services.

Social Media Widgets and Applications – HGS web sites may include functionality to enable sharing via third-party social media applications, such as the Facebook Like button and Twitter widget. These social media applications may collect and use information regarding Your use of HGS web sites. Any Data that You provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. HGS does not have control over, or responsibility for, those companies or their use of Your information.

In addition, HGS web sites may host blogs, forums, and other applications or services (collectively “social media features”). The purpose of social media features is to facilitate the sharing of knowledge and content. Any Data that You provide on any HGS social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom HGS may have limited or no control.

The provider of the social media platform uses web tracking methods. Web tracking may also take place independently of whether You are logged in or registered on the social media platform. Unfortunately, HGS cannot influence or restrict the web tracking methods of the social media platform.

Please be aware that the platform provider may use Your profile and behavioral data to evaluate, among other things, Your habits, personal relationships, and preferences. HGS has no influence on the processing of Your Data by the platform provider.

Please refer to the privacy policies of the platform provider for more information on the purpose and scope of Data collection and Data analysis undertaken by the social network as well as Your options to modify settings and how to protect Your privacy.

Other sources of Data HGS may collect include Data shared with HGS (its employees, Data shared while visiting any HGS premise) public websites, social media, cookies & tracking technologies, events, workshops, seminars etc.

Lawful Grounds for Processing Data

HGS collects only the Data necessary to fulfil Your request. Where additional, optional information is sought, You will be notified of this at the point of collection. The applicable Regulations provide for certain justifiable grounds for collection and Processing of Data, commonly referred to as legal basis of Processing.

HGS we will use this information in the manner outlined in this Policy. Your Data is not used for other purposes, unless HGS obtains Your Consent, or unless otherwise required or permitted by law or professional standards.

We use the Data for the following purpose:

  • To provide the Services and related support, process transactions, manage Your user account and respond to Your requests.
  • To the extent permitted by applicable law, and for certain legitimate interests, including cloud service providers, business partners, vendors, consultants, government bodies including statutory, regulatory authorities, law enforcement agencies (where applicable), auditors (internal/ external), clients based on contractual obligations or legitimate business purposes.
  • To meet our corporate and social responsibility obligations.
  • To conduct and to analyze HGS’s marketing activity.
  • To exercise HGS’s fundamental right to conduct business and right to property in jurisdictions where applicable.
  • In the event that HGS sell or buy any business, assets, or shares in part or whole, to disclose Your personal details to such relevant third parties involved on a need-to-know basis.
  • To ensure that HGS can comply and fulfil its legal and regulatory obligations including those regarding Your account, for example, the verification of the accuracy of any information You give us.
  • To investigate, and assist with the investigation of, suspected unlawful, fraudulent, or other improper activity connected with the Services (including, where appropriate, dealing with requests from regulatory bodies for the sharing of information).
  • To establish, exercise or defend HGS’s legal rights or for the purpose of legal proceedings.
  • To utilise for assessing or finalizing potential employment or engagement with HGS.
  • To carry out activities relating to Your employment contract with HGS (including, but not limited to, processing your salary, administering statutory and other benefits, managing Your performance and career prospects and growth with HGS).
  • To carry out internal research for technological development and demonstration.
  • For marketing and advertising, including sending You updates and information about new products and services, upcoming events or other promotions or news, including by email or push notification, as permitted by law.
  • Useability, troubleshooting, site maintenance, track website visits (which part visited frequently).

Performance of Contract: This is when the Processing of Your Data is necessary to perform HGS’s obligations under a contract; e.g., Processing Data for employment purposes (such as processing your salary, administering benefits) or providing Services to HGS customers which are necessary to perform the contract.

Consent: In some cases, HGS will ask You for specific permission to process some of Your Data and HGS will only Process Your Data in this way if You agree to HGS doing so. You may withdraw Your Consent at any time by contacting HGS on the details mentioned under ‘CONTACT OUR DATA PROTECTION OFFICER’.

Legitimate Interests: HGS may Process Your Data where it is necessary for legitimate business interests.

Legal Obligations: HGS may Process Your Data where it is necessary to comply with applicable legal and/or Regulations , establish, exercise, or defend HGS’s legal rights or for the purpose of legal proceedings and to prevent and respond to actual or potential fraud or illegal activities.

Vital interest: HGS may Process Your Data to protect Your vital interests or that of another natural person.

Other “Public Interest” Grounds: HGS may Process Your Data on other public interest grounds where it is subject to regulatory requirements where Processing is necessary for the performance of a task mandated by governmental authorities, regulatory authorities or any other law enforcing authorities in the public interest.

Processing Sensitive Personal Data

HGS may, where legally permissible, process your Sensitive Personal Data on the following lawful bases:

  • Explicit consent;
  • Legal Obligations;
  • Protect Your vital interests or of another natural person where the person is physically or legally incapable of giving consent;
  • Legitimate Interests;
  • Data manifestly made public by the Data Subject;
  • Establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity;
  • Public interest or health;
  • Preventive or occupational medicine; and/or
  • Archiving purposes in the public interest, scientific or historical research purposes or statistical purposes.

Change Of Purpose: HGS Processes Your Data when it is necessary for the purposes of a legitimate interest pursued by HGS or based on Your Consent, wherever applicable. If HGS needs to use Your Data for an unrelated purpose, HGS will notify You and HGS will explain the legal basis which allows HGS to do so. Please note that HGS may Process Your Data without Your knowledge or Consent, in compliance with the Regulations or permitted by law.

If You choose not to provide Your Data that is mandatory to process Your request, HGS may not be able to provide the corresponding Service.

Sharing and Transfer of Personal Information

HGS may share Data with its subsidiaries; affiliates, business partners; service providers, vendors; authorized third-party agents; or contractors.

Transfer within HGS

HGS shares Data with its subsidiaries, affiliates, and other members of the HGS entities , existing anywhere in the world including but not limited to those in Australia, Canada, Colombia, Jamaica, Philippines, UK, and USA. Affiliates and subsidiaries of HGS may provide services to HGS and You, for example hosting and supporting IT applications, client engagement services and otherwise as required to continue to run HGS’s business.

HGS will ensure that Data is protected and transferred consistent with applicable Regulations. This can be done in several diverse ways, for instance:

  • The country to which HGS sends the Data may be approved by the European Commission as a jurisdiction offering an “adequate” level of Data Privacy Laws;
  • Where applicable, HGS has implemented additional (technical, contractual (inter-company transfer agreements and standard contractual clauses) and/or organizational measures to secure the transfer of Data;
  • The recipient organisation has signed a contract based on approved “model contractual clauses” obliging them to protect the Data.
  • Any transfer of Data will be compliant with applicable Regulations.

In the event of any high-risk processing activity, DPIA / PIA will be conducted before the beginning of such processing. This helps in screening of potential widespread or serious impact on individuals.

Transfers To Third Parties

HGS does not share Data with third parties, except as necessary for legitimate professional and business needs, to carry out Your requests, and/or as required or permitted by applicable law or professional standards.

HGS will not transfer the Data to any third parties for their own direct marketing use.

Disclosure of Data

In compliance with applicable laws, access to Your Data is restricted to only necessary persons/entities on a strictly need-to-know basis.

We may disclose some of Your Data with the following recipients:

  • Any company within the HGS and its related group;
  • Internal departments, including with Your reporting manager, managers in the business areas, IT team, Admin Team, or any other team;
  • Third parties with whom we have a contractual relationship, including clients, payroll vendor, law firms, etc.
  • In the event that HGS sells or buys any business, assets, or shares HGS may disclose Your Data to such relevant third parties involved, to meet its contractual and legal obligations.
  • Disclosure to any supervisory authority as required by applicable laws.

With respect to disclosing Data to Third Parties, written contracts with Third Parties will include restrictions prohibiting the Third-Party from retaining, using, or disclosing Data for any purpose except performing the services specified in the contract or as otherwise permitted by applicable laws.

HGS will seek to use Data Processors or Sub-Processors that can provide sufficient security measures in accordance with applicable Regulations and shall put in place contractual mechanisms to ensure that the relevant Data Processor or Sub-Processor takes reasonable steps to ensure compliance with those measures.

Choices

In general, You are not required to submit any Data to HGS, but HGS may require You to provide certain Data for You to receive additional information about HGS Services and events. HGS may also ask for Your permission or Consent for certain uses of Your Data, and You can agree to or decline those uses. If You opt-in for Services or communications, such as an e-newsletter, You will be able to unsubscribe at any time by following the instructions included in each communication. If You decide to unsubscribe from a service or communication, HGS will try to remove Your information promptly, although HGS may require additional information before we can process your request.

Data Subject Rights

In accordance with the applicable law and Regulations, Data Subjects have rights that include the following:

  • The right to be informed
  • The right to access the Data
  • The right to rectification of any Data that is inaccurate or incomplete
  • The right to erasure of Data (also known as ‘the right to be forgotten’)
  • The right to object/ opt-out to the Processing of Data
  • The right to Data portability
  • Rights in relation to automated decision making and profiling
  • The right to restrict the Processing of Data
  • The right to be indemnified for damages due to inaccurate Data

HGS will handle all Your requests in accordance with applicable laws and Regulations. Please note that there may be circumstances in which HGS is legally entitled to refuse some of these requests. You will not have to pay a fee to access Your Data (or to exercise any of the other rights). However, HGS may charge a reasonable fee if Your request for access is clearly unfounded or excessive. Alternatively, HGS may refuse to comply with the request in such circumstances.

For exercising Your rights, HGS may need to request certain information for ascertaining Your identity and confirming that You are entitled to exercise the same. You may raise a request by contacting HGS on the details mentioned under ‘CONTACT OUR DATA PROTECTION OFFICER.’

Personal Data of Individuals Below 13 Years

If we are required to process Data of individuals under 13, we shall do so by getting explicit written Consent from their parents/legal guardians.

Note: If you are below the age of 13 years, then we do not want you to provide any of Your Data.

Data Security

To comply with Data security obligations under Regulations, HGS adopted ISO 27001 Standards.

Data Retention

HGS make reasonable efforts to retain Data only for so long

  1. it is necessary to comply with an individual’s request,
  2. it’s necessary to comply with legal, regulatory, internal business or policy requirements, or
  3. information is deleted by HGS or at request of Data Subject
  4. Data will be retained until necessary to fulfill the purposes outlined in this notice unless a longer retention period is required or permitted by applicable law.

The period for which Data is retained will depend on the specific nature and circumstances under which the information was collected; however, subject to requirements of i)-iii) above. The deletion of Data shall be handled with utmost care and shall be governed in accordance with reasonable security practices as detailed by HGS’s internal policies.

Data Breach Management

If You are concerned about an alleged breach of privacy by HGS, please contact our HGS Data Privacy officer email ID is listed below.

The breach will be investigated by the Data Protection Officers in accordance with our internal procedures and processes.

Our procedure for investigating and dealing with privacy breaches is to ascertain all relevant facts and correspond with those involved (including where relevant our clients), reach a view as to the existence, scope, and cause of the issue, and where relevant and appropriate, implement corrective or rectification measures.

HGS may require reporting any incident causing Data breach within a reasonable time after noticing such incidents or being brought to notice about such incidents to the supervisory authority as well as the Data Subject as per the requirements of the applicable laws in the various jurisdictions in which HGS operates.

Below are some timelines within which Data Protection incidents need to report to supervisory authority.

  • India within 6 hours
  • Jamaica- within 72 hours
  • Australia- within ‘reasonable time period’
  • Canada- within ‘reasonable time period’
  • United Kingdom and EU- within 72 hours
  • Philippines- within 72 hours
  • Colombia – within 15 business days

Contact Our Data Protection Officer

Please contact your country DPO listed here

  • You can ask general question about how HGS protects Your Data.
  • You can exercise your rights in relation to Your Data.
  • You can make a complaint about HGS’s use of Your Data.

HGS will try and acknowledge Your email within 3 working days and seek to resolve Your concern at earliest.

Changes to This Statement

HGS may modify this Policy to reflect our current privacy practices. When HGS changes to this Policy, HGS will revise the “updated” date at the top of this page.

Other HGS Policies