YOUR PRIVACY 

Talwar Thakore and Associates (“TTA“, “us“, “we” or “our“) is committed to protecting your privacy and will take the relevant measures to safeguard your personal information in accordance with the Information Technology Act, 2000 (the “IT Act“) and The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (the SPDI Rules”) and other applicable laws (collectively referred to as the “Data Protection Laws”). This Data Protection Policy (the “Policy“) sets out how we use and protect the personal information you give us. “you” means any individual person including a partner, consultant, members of the support staff, job applicants or representatives of our clients or any other third party associated with us from whom we collect personal information. By providing us your information, you confirm that you have read, understood and agreed to the practices and policies outlined in this Privacy Policy.

1.1 Your personal data will be held by us in accordance with the Data Protection Laws.

2. YOUR PERSONAL DATA 

2.1  CATEGORIES OF PERSONAL DATA 

We, or a service provider engaged by us, may collect and process personal data from you. The personal data collected from you may include (but may not be limited to) personal data that falls into the following categories of data:

2.1.1  name;

2.1.2  personal, business, and emergency contact information (including home address, email address, phone number, gender, marital status);

2.1.3  date of birth;

2.1.4  signature;

2.1.5 any Government issued ID or passport number (or other identification numbers as appropriate, e.g. Aadhaar, voter ID/driving license/permanent account number);

2.1.6  nationality and place of birth;

2.1.7  other personal data as may be required from time to time for business planning and management; and

2.1.8 certain “sensitive personal data” regarding your  medical records and history, biometric information, passwords (including password selected by the applicant and applicant’s response to selected security question), financial information such as bank account, credit card, debit card or other prepayment instrument details, mental, physiological and physical health condition, religious beliefs and criminal convictions (if any);

 2.2  HOW WE COLLECT YOUR PERSONAL DATA

 We may collect and process your personal data in the ways set out below:

2.2.1  We may collect and process information that you provide by filling in forms for us (whether electronic or not). This includes information (such as your email address) provided at the time of responding to any request for information from us.

2.2.2  We may collect and process information that you provide us as part of a business relationship or contract or for recruitment purposes.

2.2.3 If you contact us, we may keep a record of that correspondence.

2.2.4 We may collect and process details of your visits to our website (if any) including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.

2.2.5 We may collect and process your personal data from third parties, our business partners or from publicly available sources.

3. PURPOSE OF PROCESSING AND USES MADE OF THE INFORMATION 

3.1   We collect and use information held about you in the following ways:

3.1.1 To provide you with any information that you request from us or which we feel may interest you, including information on networking and stakeholder events organised by us, as permitted under applicable law or where you have consented to be contacted for such purposes.

3.1.2  To carry out our obligations arising from any contracts entered into between you and us.

3.1.3 To evaluate your suitability to render the relevant services to us.

3.1.4 To comply with our obligations and any requests received regarding background and security screening, including KYC and AML screening.

3.1.5 To prepare and execute legal documents.

3.1.6 To process payments and comply with our accounting and tax obligations.

3.1.7  For administrative purposes.

3.1.8 For contact purposes.

3.1.9  To comply with our obligations regarding security and access within TTA.

3.1.10  To investigate complaints and suspected suspicious transactions.

3.2  Your information is necessary to us. If you do not provide all of the personal data that we request from you, we may not be able to fulfil all of the functions set out in paragraph 3.1 above.

4. WHERE WE STORE PERSONAL DATA AND DISCLOSURE OF YOUR DATA

 4.1 Where we transfer your sensitive personal data within or outside India, we will ensure that your sensitive personal data is transferred to only a person or a body corporate that ensures the same level of data protection that is adhered to by TTA under the Data Protection Laws and we will take reasonable steps to ensure that your data is treated securely and in accordance with the Data Protection Laws and this Policy.

4.2 Unless you specify otherwise, we may disclose your personal information to:

4.2.1 third parties in the follow circumstances including those outside of India:

(A) in the event that TTA has obtained your consent;

(B) agents, service providers and third parties who provide services relating to the purposes for which the personal data is collected and processed including data processing services, or for the purpose of providing network or administrative services, whether or not such agents, service providers and third parties are based in India;

(C)  any person who is under a duty of confidentiality and has undertaken to keep such data confidential; and

(D) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of TTA, our business partners or others.

4.3 We do not disclose your personal data to unaffiliated third parties without your consent.  However, we may disclose your personal data if required by law or in good faith, if such action is necessary to comply with any law enforcement agency requirements, court orders or legal processes.

4.4 Retention

If we no longer need to use your personal data for the purposes set out in paragraph 4 above and/or we are not legally required to retain your personal data, we will take reasonable steps to destroy your personal data or render it anonymous.

 5. SECURITY MEASURES

 5.1  We will take all reasonable precautions necessary to protect your personal data from:

5.1.1  misuse, interference and loss; and

5.1.2  unauthorised access, processing, modification or disclosure.

 5.2 We may use third party data storage providers (such as cloud service providers) to store personal information electronically. We take reasonable steps to ensure this information is held as securely as information stored on our own equipment.

5.3  Please note that, unfortunately, there is always risk involved in sending information through any channel over the internet. Any information you send to us over the internet is entirely at your own risk. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted over the internet and we do not warrant the security of any information, including personal data, which you transmit to us over the internet.

5.4 Where we transfer your sensitive personal data within or outside India, we will ensure that your sensitive personal data is transferred to only a person or body corporate that ensures the same level of data protection that is adhered to by TTA under the Data Protection Laws and we will take reasonable steps to ensure that your data is treated securely and in accordance with the Data Protection Laws and this Policy .

6. ACCESS, CORRECTIONS AND COMPLAINTS

You may access or correct your personal information by contacting our Grievance Officer, Ms. Deepa Christopher (deepa.christopher@tta.in) .

6.1 If you have a concern about how we have handled your personal data, please let us know so we can fix the problem.  You can contact Grievance Officer.

 6.2 To lodge a complaint, please send details to our Grievance Officer in writing.  We will attempt to respond within a reasonable time, usually 30 days from the date of receipt of the grievance.  We treat all privacy complaints seriously and any complaint will be assessed by our Grievance Officer with the aim of resolving any issue in a timely and efficient manner.  We request that you cooperate with us during this process and provide us with any relevant information that we may need to investigate the complaint appropriately.

7. PROCESSING IN LINE WITH YOUR RIGHTS

 7.1  We will inform you (before collecting your data) the purpose for which we intend to use your data or if we intend to disclose your information to any third party. You can exercise your right to prevent such processing by checking certain boxes on certain forms we use to collect your data. You can also exercise the right at any time by contacting our Grievance Officer.

7.2 Our forms and websites (if any) may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

8. MONITORING AND REVIEW OF POLICY

8.1 TTA may review and change this Policy from time to time to reflect changes in the law, our business practices, processes or structure. This Policy is not a contract, nor does it suggest any obligation on our part with another party.

8.2  Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to the Grievance officer.