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HireMee Privacy Policy

  1. Purpose and Scope

    This Privacy Policy explains our policy regarding the collection, use, disclosure and transfer of your information by Karpaga Assessment App Matrix Services Pvt. Ltd, doing business as, HireMee, HireMee is a state-of-the-art online skill assessment portal provide Test and Video Resume feature. and/or its subsidiary(ies) and/or affiliate(s) (collectively referred to as the Company), which operates the website (“Site”), mobile applications (App) and other services including but not limited to delivery SMS, mobile application developed with the aim to connect companies with potential candidates and improve placements for colleges and related content via the site and application, any mobile or internet connected device or otherwise (collectively the “App Service”)

    The Company respects the privacy of the users of the HireMee platform Services and is committed to reasonably protect it in all respects. The information about the user as collected by the Company is: (a) information supplied by users and (b) information automatically tracked while using a mobile device having HireMee platform Services enabled (collectively referred to as Information).

    It is the policy of HireMee to comply with all applicable laws and regulatory requirements for the use, access and disclosure of Sensitive Information, to ensure the confidentiality and protection of Sensitive Information, and to prevent and mitigate any privacy incidents.

    All members of the Workforce shall be required to comply with this Policy and it is applicable to all HireMee global operations. Individuals who violate these requirements are subject to disciplinary action, up to and including termination or dismissal.

    The processing of data collected by us from a data subject, such as IP address, device, browser, GEO location, the associated search phrase and the CTR (click through ratio) shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to HireMee. By means of this data protection declaration, we would like to inform the general public of the nature, scope, and purpose of the data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

    As the controller, HireMee has implemented numerous technical and organizational measures to ensure the most complete protection of data processed through this website. However, Internet-based data transmissions may in principle have security gaps. Hence, absolute protection may not be guaranteed.

    1. Definitions

      The data protection declaration of HireMee is based on the terms used by the UK and European legislation for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration is legible and understandable for the general public, as well as our customers and business partners. To ensure this, we have explained below, the terminology used.

      1. Data subject

        Data subject is any identified or identifiable natural person, whose data is processed by the controller responsible for the processing.

      2. Processing

        Processing is any operation or set of operations which is performed on the 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.

      3. Restriction of processing

        Restriction of processing is the marking of stored data with the aim of limiting their processing in the future

      4. Controller or controller responsible for the processing

        Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

      5. Processor

        Processor is a natural or legal person, public authority, agency, or other body which processes data on behalf of the controller.

      6. Recipient

        Recipient is a natural or legal person, public authority, agency or another body, to which the data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

      7. Third party

        Third party is a natural or legal person, public authority, agency, or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process the data.

      8. Consent

        Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

    2. Name and Address of the controller

      Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union, and UK Data Protection Act 2018, and other provisions related to data protection is:

      Karpaga Assessment App Matrix Services(KAAMS) Pvt. Ltd D/B/A HireMee
      Seetha Complex, No. 483,
      HBCS Ideal Homes Layout 18th Main Road, Rajarajeswari Nagar,
      Bangalore-560098.
      Phone: +91-879 292 2796
      Email: info@hiremee.co.in
      Website: www.hiremee.co.in

    3. Name and Address of the Data Protection Officer

      The Data Protection Officer of the controller is:
      Vineeth Varma
      Karpaga Assessment App Matrix Services(KAAMS) Pvt. Ltd D/B/A HireMee
      Seetha Complex, No. 483,
      HBCS Ideal Homes Layout 18th Main Road, Rajarajeswari Nagar,
      Bangalore-560098
      Phone: +91-879 292 2796
      Email: privacyofficer@hiremee.co.in
      Website: www.hiremee.co.in
      Any data subject may, at any time, contact our Data Protection Officer directly with all questions and suggestions concerning data protection

  2. Information Supplied by Users

    To avail certain services of HireMee, users are required to provide some personally identifiable information for the registration process which may include:- a) your name, b) email address, c) phone number, d) access to your phone’s SMS inbox records d) bank account details e) Aadhaar details, f) PAN g) residential address etc. and any other such information as required. The Information as supplied by the users enables us to improve the services and provide you the most user-friendly experience. All required information is service dependent and the Company may use the above said user Information to maintain, protect, and improve the services and for developing new services.

    We may also use your phone number, email address or other personally identifiable information to send commercial or marketing messages without your consent [with an option to subscribe/unsubscribe (where feasible)]. We may, however, use your email address and phone number without further consent for non-marketing or administrative purposes (such as notifying you of major changes, for customer service purposes, providing information about updates to services, billing, etc.).

    Any personally identifiable information provided by you will not be considered as sensitive if it is freely available and/or accessible in the public domain. Further, any reviews, comments, messages, blogs posted/uploaded/conveyed/communicated by users on the public sections of the Site becomes published content and is not considered personally identifiable information subject to this Privacy Policy.

    In case you choose to decline to submit personally identifiable information on the App/Site, we may not be able to provide certain services on the App/Site to you. We will make reasonable efforts to notify you of the same at the appropriate time. In any case, we will not be liable and or responsible for the denial of certain services to you for lack of you providing the necessary personal information.

  3. Registration

    The data subject has to register on the website of the controller and open an account to log in to the website. By registering on the website of the controller, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offences. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

    The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data except the email id specified during the registration at any time, or to have them completely deleted from the data stock of the controller.

    When you register with the HireMee services, we may contact you from time to time about updation of your personal information to provide such features that we believe may benefit/interest you.

  4. Information automatically tracked while using the App or Site
    1. SMS Inbox Information

      The HireMee platform also access the User’s SMS inbox only for reading the OTP. The HireMee platform accesses business messages that originate from senders. The HireMee platform may read personal and OTP messages only if the SMS feature is privilege enabled, No personal SMSes or OTPs are backed up. The collection of such information is only limited to the extent that such data is available in the relevant messages. HireMee may also record the identity of the product or service and the price or fee paid or payable in respect thereof.

    2. Demographic and Related Information

      We may reference other sources of demographic and other information in order to provide you with more targeted communications and promotions. We use Google Analytics, among others, to track user behaviour on our website. Google Analytics specifically has been enabled to support display advertising to help us gain an understanding of our users’ Demographics and Interests. The reports are anonymous and cannot be associated with any individual personally identifiable information that you may have shared with us.

    3. Log File Information

      Our Servers automatically collect limited information about your device’s connection to the Internet, including your IP address, when you visit our Site or use the App. We automatically receive and log information from the App and/or your browser including but not limited to IP address, your device or computer’s name, and your operating system. We may also collect log information from your device, including but not limited to your location, IP address, your device’s name, device’s serial number or unique identification number (e.g. UDiD on your iOS device, Android ID or ADID on your Android Device), your device operating system, browser type and version, CPU speed, and connection speed etc.

    4. Cookies

      To improve the responsiveness of the Site for our users, we may use “cookies”, or similar electronic tools to collect information to assign each visitor a unique, random number as a User Identification (User ID) to understand the user’s individual interests using the identified computer. Our partners may also assign their own cookies to your browser, a process that we do not control.

    5. Links to Third Party Sites/Ad-Servers.

      The Site may include links to other websites. Such sites are governed by their respective privacy policies, which are beyond our control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your browser), use of any information you provide is governed by the privacy policy of the operator of the site you are visiting. That policy may differ from ours. If you can’t find the privacy policy of any of these sites via a link from the site’s homepage, you should contact the site directly for more information.

    6. Information Sharing

      The Company may share sensitive personal information with any third party without obtaining the prior consent of the User in the following limited circumstances:

      1. When it is requested or required by law or by any court or governmental agency or authority to disclose, for the purpose of verification of identity, or for the prevention, detection, investigation including cyber incidents, or for prosecution and punishment of offences. These disclosures are made in good faith and belief that such disclosure is reasonably necessary for enforcing these Terms or for complying with the applicable laws and regulations.
      2. We may share necessary information to prospective Recruiters or Agencies like AICTE, NCS, Government Agencies, with whom we have valid MoUs, and Third Parties as agreed in the MoUs.
      3. No personally identifiable data of an individual user such as name, phone number, email address, spends data, card details etc. would be shared with any other User and/or third party – unless explicitly approved by the concerned individual user in order to avail of certain services. However, if this conflicts with conditions mentioned in the immediate point above, this condition would become null and void.
    7. The Company may also present information related to user spends, patterns and user data tracked by the company only in the form of aggregated statistics on data such as user spends by category, date, time, bank balances, etc. within our app/site or to our partners.

    8. Accessing and Updating Personal Information

      When you use the HireMee platform Services Site (or any of its sub sites), we make efforts in good faith to provide you, as and when requested by you, with access to your personal information and shall further ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible, subject to any requirement for such personal information or sensitive personal data or information to be retained by law or for legitimate business purposes.

      We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required.

      In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Because of the way we maintain certain services, after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

    9. Information Storage and backup

      If enabled from the app, we take a backup of your data on HireMee platform on our Cloud database according to country specific compliance requirements. This is done for the purpose of enabling users to get their data back in case their phone’s data becomes unusable, if the phone is lost, or the user moves to a new phone device.

      We also use this backup to provide useful insights and information related to Active/inactive Loans and repayments.

    10. Information Security

      We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data. All information gathered on the HireMee platform is securely stored within the controlled database. Access to the servers is password-protected and is strictly limited.

  5. Exceptions to this Privacy Policy

    Exceptions to this Privacy Policy may be granted by the Privacy and Security Steering Committee (“PSSC”) or Information and Security Steering Committee(ISSC), in accordance with applicable laws.

  6. Rights of Data Subject

    HireMee has implemented the following fair information privacy principles that support individual rights and set guidelines for the protection of Sensitive Information:

    1. Notice

      HireMee shall provide notice regarding its privacy policies and procedures and include the purposes for which Sensitive Information is accessed, collected, used, retained, and disclosed. Notice may occur in a variety of formats including publication on HireMee’ internal and external websites and specified in internal and external contracts and agreements.

    2. Choice and Consent

      Where practical or required by law or contract, HireMee shall provide individuals with opportunity to consent to or authorize HireMee’ access, collection, use, retention, and disclosure of Sensitive Information. Consent or authorization shall be explicit and the PSSC shall advise the Business Units as to appropriate means of obtaining consent or authorization.

    3. Right to withdraw data protection consent

      Each data subject shall have the right to withdraw his or her consent to processing of his or her personal data at any time.

      If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact Data Protection Officer of HireMee

    4. Limited Collection

      Sensitive Information shall only be collected for the purposes identified in the notice.

    5. Right of Confirmation

      Each data subject shall have the right to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact Data Protection Officer of the controller

    6. Right of Access

      Each data subject shall have the right to obtain from the controller free information about his or her data stored at any time and

      a) the purposes of the processing;

      b) the categories of data concerned;

      c) the recipients or categories of recipients to whom the data have been or will be disclosed, in particular recipients in third countries or international organizations’;

      d) where possible, the envisaged period for which the data will be stored, or, if not possible, the criteria used to determine that period;

      e) the existence of the right to request from the controller rectification or erasure of data, or restriction of processing of data concerning the data subject, or to object to such processing;

      f) the existence of the right to lodge a complaint with a supervisory authority;

      g) where the personal data are not collected from the data subject, any available information as to their source;

      Furthermore, the data subject shall have a right to obtain information as to whether their personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

      If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact Data Protection Officer of the controller.

    7. Limited Use and Disclosure

      Sensitive Information shall only be used and/or disclosed to third parties for the purposes identified in the notice.

    8. Limited Retention

      The criteria used to determine the period of storage of personal data is the respective statutory retention period subject to a maximum of five years. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract. Sensitive Information may be retained only as long as necessary, including, but not limited to, as may be required by law or contract, to fulfill a valid business purpose. PII data in anonymous form may be retained by the data controller and used for statistical and reporting purposes.

    9. Accuracy

      HireMee shall maintain the accuracy and integrity of the Sensitive Information under its care.

    10. Right to Inspect/Correction

      Individuals may request access to their Sensitive Information. The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. and Individuals may request amendment to that Sensitive Information if such information is believed to be inaccurate. The data controller shall correct or erase personal any data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The PSSC shall provide guidance to Business Units regarding individual rights to access and/or amend Sensitive Information upon request by the Business Unit. Each data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

      If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any Data Protection Officer of the controller.

    11. Right to erasure (Right to be forgotten)

      Each data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

        a) The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

        b) The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.

        C) The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.

        d) The personal data have been unlawfully processed.

        e) The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

        f) The personal data have been collected in relation to the offer of information society services to a child referred to in Article 8(1) of the GDPR.

      If one of the afore mentioned reasons applies, and a data subject wishes to request the erasure of personal data stored by HireMee, he or she may, at any time, contact Data Protection Officer of the controller. The Data Protection Officer of HireMee shall promptly ensure that the erasure request is complied with immediately.

      If one of the afore mentioned reasons applies, and a data subject wishes to request the erasure of personal data stored by HireMee, he or she may, at any time, contact Data Protection Officer of the controller. The Data Protection Officer of HireMee shall promptly ensure that the erasure request is complied with immediately.

    12. Right of restriction of processing

      Each data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

      a) The accuracy of the data is contested by the data subject, for a period enabling the controller to verify the accuracy of the data.
      b) The processing is unlawful and the data subject opposes the erasure of the data and requests instead the restriction of their use instead.
      c) The controller no longer needs the data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
      d) The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

      If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of data stored by HireMee, he or she may at any time contact Data Protection Officer of the controller. The Data Protection Officer of HireMee will arrange the restriction of the processing.

    13. Right to data portability

      Each data subject shall have the right to receive the data which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

      Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have the data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

      In order to assert the right to data portability, the data subject may at any time contact Data Protection Officer of HireMee.

    14. Automated individual decision-making, including profiling

      Each data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and data controller, or (2) is not authorised by Union or applicable law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedom and legitimate interests, or (3) is not based on the data subject's explicit consent.

      If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, HireMee shall implement suitable measures to safeguard the data subject's rights and freedom and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

      If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact Data Protection Officer of HireMee

    15. Disposal

      HireMee shall dispose and destroy Sensitive Information, at the end of the applicable retention period, in a manner that prevents the likelihood of restoration of the Sensitive Information or in a manner required by law or contract.

    16. Training

      Workforce members shall be provided training on this Privacy Policy.

    17. Breach Notification

      Actual or suspected breaches of Sensitive Information shall be immediately reported in accordance with the Privacy and Security Incident Reporting Policy.

    18. Accountability

      Violations of this Privacy Policy may result in discipline up to and including termination, in compliance with Human Resources policies.

  7. Legal basis for the processing

    Art. 6(1) (a) of GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. In the case of inquiries concerning our products or services, the processing is based on Article 6(1) (b) of GDPR.

  8. Privacy Policy Requirements
    1. Policy Availability

      This Privacy Policy shall be made available to the Workforce through HireMee management, the Intranet, formal training programs, and other appropriate mechanisms.

    2. Review Cycle
      1. The PSSC shall review the privacy requirements for the organization based on the applicable laws. The PSSC shall be responsible for conducting an annual review of this Privacy Policy and all related corporate policies, standards, and procedures. The PSSC may grant an exception for an annual review of this Privacy Policy. A review shall also occur each time there is a significant and material change in laws or regulations regarding the privacy of Sensitive Information. The PSSC shall submit material changes or modifications for approval to the Senior Management, the CISO, and Legal team for review prior to presentation for final review and approval by the Privacy and Security Steering Committee (PSSC).

      2. Requests for changes or modifications to this Privacy Policy may be submitted by a member of the Workforce in writing to the PSSC. The PSSC and the CISO shall determine whether the requested change or modification should be included in the Privacy Policy.

    3. Policy Retention

      This Privacy Policy, as well as any procedures supporting this Privacy Policy, and all previous versions shall be maintained for a minimum of six (6) years after the latest effective date, even if superseded, or longer if required by a legal, regulatory, or contractual requirement.

  9. Privacy Requirements
    1. Executive Commitment

      HireMee’ executive leadership agrees that maintaining the privacy and security of HireMee, the Workforce, PII, PD, PI, Personal Health Information, and other Sensitive Information is essential to HireMee’ business and reputation and to operating in a responsible, compliant manner. Accordingly, the Executive Leadership affirmatively approves and supports this Privacy Policy, including the designation of a Chief Privacy Officer.

    2. Workforce Responsibilities

      Each member of the HireMee workforce is responsible for the security of Sensitive Information in his or her workspace. Workforce members take reasonable and appropriate precautions to safeguard access to Sensitive Information including, without limiting the generality of the following, compliance with security measures required by the Security Policy and other guidance issued by the Privacy and Security Steering Committee and Chief Information Security Officer.

      Each Workforce member shall be responsible for:

      1. Reading and understanding the contents of this Privacy Policy and its related policies and procedures;
      2. Ensuring that his or her actions comply with the requirements of this Privacy Policy and its related policies and procedures;
      3. Demonstrating his or her understanding of and compliance with this Privacy Policy and its related policies and procedures through the completion of annual training and certification or through any other means used by HireMee for such certification;
      4. Collaborating with all levels of the HireMee organization to ensure that an effective privacy program is implemented and maintained;
      5. Seeking assistance if uncertain how to comply with the requirements of this Privacy Policy and its related policies and procedures;
      6. Complying with the Security Policy and related policies and procedures and implementing and maintaining the Security Program;
      7. Reporting any violations of this Privacy Policy, related policies or procedures or the law or regulations to the PSSC, CISO, Human Resources representative, HireMee management,
    3. Managers’ Responsibilities

      In addition to responsibilities as a member of the Workforce, each HireMee manager shall be also be responsible for:

      1. Ensuring that all members of the Workforce reporting directly or indirectly to such manager have read, understand, been trained on, and comply with, this Privacy Policy and its related policies and procedures;
      2. Ensuring all members of the Workforce who report directly or indirectly to such manager have completed the required privacy training;
      3. Ensuring that this Privacy Policy, and its related policies and procedures, are fully implemented in his or her functional area of responsibility;
      4. Requesting guidance from Human Resources or the PSSC on implementing this Privacy Policy as a manager if needed.
    4. Business Units and Functional Areas

      In addition to responsibilities as a member of the Workforce, each Business Unit or functional area leader shall also be responsible for:

      1. Identifying any privacy-related contractual requirements mandated or requested by external clients or third-party vendors, and not previously approved by the legal team and the PSSC, and providing those requirements or requests to the legal team and the PSSC prior to contract execution;
      2. Identifying where Sensitive Information is located, and providing such information to the PSSC and/or CISO;
      3. Maintaining a list of all Workforce members who have access to Sensitive Information and approving access by Workforce members to any Sensitive Information in a manner consistent with such Workforce members’ duties and responsibilities;
      4. Documenting and maintaining procedures to implement this Privacy Policy within its own Business Unit.
    5. Privacy and Security Steering Committee

      The Privacy and Security Steering Committee shall be responsible for:

      1. Developing, implementing and maintaining this Privacy Policy and related policies and procedures;
      2. Coordinating with the CISO in the development and maintenance of security policies and programs to ensure that appropriate physical, administrative and technical safeguards are in place to protect the privacy and security of Sensitive Information;
      3. Upon request, reviewing, guiding, and approving Standard Operating Procedures (SOPs) for Business Units and functions, relating to Sensitive Information;
      4. In collaboration with Human Resources, designing and ensuring the provision of adequate training to all Workforce members, including to every new hire as a part of the on-boarding process, on this Privacy Policy, related policies and procedures, and the privacy and security laws and regulations of applicable jurisdictions;
      5. Receiving and reviewing complaints related to this Privacy Policy and related procedures or the requirements for the handling of Sensitive Information under any applicable law, including documenting the complaint and disposition thereof;
      6. Coordinating with Human Resources to recommend appropriate discipline for violations of this Privacy Policy;
      7. Reviewing and responding to requests from law enforcement and regulatory agencies for access to Sensitive Information, in coordination with others to the extent permitted and as appropriate;
      8. Ensuring that HireMee complies with applicable privacy laws, regulations, and contractual privacy requirements;
      9. May designate another individual to function in his/her capacity with regards to the requirements set forth in this Policy.
    6. Human Resources
      1. Together with the PSSC, designing, documenting, and enforcing a progressive disciplinary policy for non-compliance with or violation of this Privacy Policy and related policies and procedures;
      2. Ensuring that Workforce members reporting violations of this Privacy Policy, related policies or procedures or the law are protected from retaliation;
      3. Collaborating with hiring managers to ensure privacy and security obligations are specified in HireMee job and roles descriptions;
      4. Communicating job status changes, including termination of Workforce members, to IT Operations, so that access to systems with Sensitive Information is appropriately modified.
  10. Permitted Uses and Disclosures of Sensitive Information

    All members of the Workforce shall safeguard the confidentiality of and protect any Sensitive Information in accordance with the requirements of this Privacy Policy, other applicable policies and procedures, relevant contractual requirements, and as required by law.

    1. Consent and Authorization to Use Sensitive Information
      1. Limited Collection. Workforce members shall only collect, request, or access the minimum amount of Sensitive Information necessary to serve a valid business purpose and in accordance with the requirements of this Privacy Policy, other applicable policies and procedures, relevant contractual requirements, and as required by law.

      2. Limited Use. HireMee Workforce members shall only access, use, and disclose Sensitive Information in accordance with:

        1. the requirements of the consent or authorization provided by the subject or owner of the Sensitive Information;

        2. the requirements of this Privacy Policy, or other applicable policies and procedures;

        3. relevant contractual requirements; and

        4. relevant contractual requirements; and as required by law.

      3. All access, use and disclosure of Sensitive information shall be limited to the minimum amount of Sensitive Information necessary to accomplish a valid business purpose.

      4. All requests to limit or cease using Sensitive Information shall be directed to the PSSC for review.

    2. De-Identified Sensitive Information
      1. In certain cases, HireMee may receive consent or authorization to de-identify Sensitive Information. In these cases, once the Sensitive Information has been de-identified, Workforce members may use and disclose the de-identified Sensitive Information in accordance with the consent or authorization.

      2. Requests to de-identify Sensitive Information must be submitted, in writing, to the PSSC or her/his designee who will evaluate the scope and purpose of the request and the means of de-identification to ensure a low likelihood of re-identification of Sensitive Information and that applicable legal, contractual, and industry-standard requirements are met.

    3. Disclosures Required by Law

      HireMee may use or disclose Sensitive Information as required by law.

  11. Privacy Risk Assessment

    HireMee shall assess Privacy Risk annually pursuant to HireMee’ Risk Management Policy.

  12. Reporting and Handling of Privacy Complaints and Incidents

    For the purposes of this Privacy Policy, all privacy complaints and incidents shall follow Privacy and Security Incident Response Policy.

  13. Disposal of Sensitive Information

    All electronic media and paper copies containing Sensitive Information shall be retained in accordance with HireMee Records Management Policy and Retention Schedule, and properly disposed of once the intended use has been completed in accordance with the HireMee Information Classification and Handling Policy. All media or copies containing Sensitive Information from a client is either to be returned to the client, or destroyed, in accordance with the contractual agreement with the client.

  14. Human Resources Privacy Requirement
    1. Human Resources is responsible for ensuring that Workforce Members’ Sensitive Information is appropriately identified and protected in accordance with this Privacy Policy, contractual requirements, applicable laws and regulations of Government of India

    2. For countries like United States, United Kingdom, European Union, HireMee Human Resources will protect any health-related Sensitive Information obtained as a result of providing health-related benefits to employees in accordance with this Privacy Policy, applicable laws, regulations, and contractual requirements.

  15. Existence of automated decision-making

    As a responsible company, we do not use automatic decision-making or profiling.

  16. Use of emails under GDPR

    a) HireMee, wherever possible seeks your affirmative consent/permission to contact you through email.
    b) HireMee does not send email to anyone who has asked not to be contacted, unsubscribed from a list, or opted-out in any other way.
    c) If the email is between business and customer, HireMee contacts only such persons who have provided explicit prior consent or opt-in consent to contact them via email.
    d) HireMee sends emails to you offering products/services which are closely related to the product/service for which you had originally expressed your interest.
    e) You can opt-out from receiving emails any time you decide you do not want to receive such mails.
    f) HireMee may send marketing communications containing news, events, general updates, and white papers, and in various formats, about a product or service with opt-out provision.

  17. Complaints and Grievances

    In case you have any complaints and/or grievances in relation to the processing of your Personal Information you can send this via e-mail to our Privacy Officer privacyofficer@hiremee.co.in.

    We will revert to you on your clarification or requests or queries or complaints or grievance with in 48 working hours but not more than 72 working hours.

  18. General Definitions
    1. “Business Unit” is a formally defined area of HireMee representing a specific business function (such as Finance, Solutions Development, Sales, Support, etc.). This could be a department or subset of a department.
    2. “PSSC” means the Privacy and Security Steering Committee who is also the Chief Privacy Officer.
    3. “CISO” means the Chief Information Security Officer.
    4. “Information” is considered databases, data files, contracts, agreements, system documentation, research information, user manuals, training material, standard operating procedures, business continuity plans, disaster recovery plans, third-party data, audit trails, and archived information.
    5. “Privacy Guidelines” are documents that support this Privacy Policy but are not directive in nature. Guidelines are designed to provide members of the Workforce a recommended path to achieve compliance with HireMee’ policy.
    6. “Privacy Policy” refers to this formal statement by HireMee’ executive management outlining the overall intention and direction of the safeguarding and protection of Sensitive Information for HireMee, including, but not limited to, affiliates of HireMee. It is not intended to be detailed, but rather to serve as a capstone principle supported by subordinate documents (including, but not limited to, the Privacy Procedures and Privacy Standards).
    7. “Privacy Procedures” directly support this Privacy Policy and are a detailed set of instructions for various groups of individuals, such as the general Workforce, management, Human Resources, and Business Units. These procedures outline the detailed steps, establish timelines, and document specific behaviors for all Workforce members who are bound within this Privacy Policy’s scope to be in compliance.
    8. “Privacy Standards” support this Privacy Policy by providing specific boundaries. Privacy Standards are focused and serve to establish a set of mandatory decision criteria for systems and processes. Privacy Standards are intended for a limited audience and are mandatory by definition. Privacy Standards do not normally require executive management approval and therefore are more fluid and may adapt to technology changes.
    9. “Sensitive Information” is a class of data, that relates to an identified or identifiable individual or entity that is sensitive, confidential, or proprietary to such person or entity and may potentially cause harm to such person or entity if lost or accessed, or used or disclosed by unauthorized persons, either internal or external to HireMee. “Sensitive Information” includes, but is not limited to, Protected Health Information, Personal Information, Personal Health Information, Personal Data, and Personally Identifiable Information including other sensitive KYC (Know Your Customer) information collected as a part of OVD (Officially valid document (OVD) the passport, the driving license, the Permanent Account Number (PAN) Card, the Voter's Identity Card issued by the Election Commission of India, job card issued by NREGA (as those terms are defined in applicable law).
    10. “Systems” are any computing assets that may create, access, or store sensitive data, including those used internally and those developed and sold as a product.
    11. “Workforce” means full-time or temporary employees, contractors, third-party users, volunteers, interns, trainees, agents, and other persons whose conduct, in the performance of work for HireMee, is under the direct control of HireMee, whether they are on-site or off-site, and whether or not they are paid by HireMee.
  19. Appendix A – Applicable Regulatory Standards

    Laws and regulations relevant to this Policy include, but are not limited to, the following:

    1. Information Technology Act of 2000/2008 (India)
    2. Personal Data Protection Bill 2019 -PDP Bill 2019
    3. RBI Master Circular – 'Know Your Customer' (KYC) Guidelines-RBI/2015-16/108
    4. European Union Data Protection Directive (UK)
    5. General Data Protection Regulation (EU)
    6. Organization of Economic Cooperation and Development Guidelines

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