1. Introduction
1.1. ReachLocal Services Pvt. Ltd. (“RL India”), subject to the provisions of this Privacy Policy and applicable law, may collect, receive, store, deal in, handle and share Personal Information (as defined below) including Sensitive Personal Data (as defined below) pertaining to its employees (past and present) and prospective employees (hereinafter collectively referred to as the “Data Providers”). RL India is committed to protecting the privacy, confidentiality and security of such Personal Information of the Data Providers. Pursuant to such commitment, RL India has developed this Privacy Policy for the handling of or for dealing in the aforementioned information.
2. The Personal Information We Collect
2.1. For the purposes of this Privacy Policy,
(i) ‘Personal Information’ means any information relating to the Data Provider which, either directly or indirectly, in combination with other information available or likely to be available with RL India, is capable of identifying such Data Provider and includes Sensitive Personal Data (as defined below) of the Data Provider
(ii) ‘Sensitive Personal Data’ of a Data Provider means such personal data or information of a Data Provider which consists of information relating to:-
(a) password;
(b) financial information such as Bank account or credit card or debit card or other payment instrument details;
(c) physical, physiological and mental health condition;
(d) sexual orientation;
(e) medical records and history;
(f) biometric information;
(g) any detail relating to the above clauses as provided to RL India for providing service; and
(h) any of the information received under the above clauses by RL India for processing, stored or processed under lawful contract or otherwise:
provided that, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information for the purposes of this Privacy Policy.
2.2. [Typically, the Personal Information collected by RL India includes all information and data that is required by RL India or any third party on its behalf, for the usage noted in Clause 3 of this Privacy Policy and may include (without limitation) one or more of the following:
names, e-mail and residence addresses, telephone numbers, photographs, educational qualifications, details of relatives, all employment-related and compensation-related information, government-issued identification numbers, and any other related information.
Further, typically the Sensitive Personal Data collected by RL India includes financial and medical information of the Data Providers][1].
2.3. It is clarified that RL India may either directly procure, handle, manage, store, process, protect and transmit the Personal Information of the Data Provider or may authorize certain third party entities, persons and/ or agencies to do so on its behalf (including authorized sub-contractors, consultants and/or representatives of such persons) (“Authorised Persons”).
2.4. At the time of or prior to the collection of information including Personal Information by RL India or any Authorised Persons, the Data Provider has the right to not provide such information to RL India or any of the Authorized Persons. Further, the Data Provider, at any time subsequent to providing the information, also has the option to withdraw his/her consent given earlier to RL India or any Authorised Persons. The decision to not provide the information including any Personal Information or withdrawal of consent later shall be given in writing by the Data Provider to RL India or the Authorised Persons (as the case may be) and to the extent possible accompanied by reasons. [It is clarified that where a Data Provider chooses not to provide RL India or any Authorised Persons, the permission to collect, use or disclose such information or later on withdraws the consent for usage of such information including Personal Information so collected, RL India may not have sufficient information about the Data Provider to be able to offer or continue his/her employment with the company or to provide him/ her with the employee benefits under law and company’s internal policy. In such cases RL India reserves the right¸ at its sole discretion, to not offer employment to the Data Provider and/or withdraw his/her employment offer and/or terminate the Data Provider’s employment with the company and/or discontinue all or part of his/ her employment benefits and/or take any other action that RL India may decide in this regard.] 3. Use of Personal Information
3.1. RL India would use a Data Provider’s Personal Information for its human resource and employment related requirements (including for the purpose of recruitment and background check on the Data Provider and for providing employee benefits). It may procure, handle, manage, store, process, protect and transmit such Personal Information in accordance with this Privacy Policy.
4. Retention of Personal Information
4.1. Except as reasonably required or otherwise permitted or required by applicable law or regulatory requirements, RL India endeavors to retain the Data Provider’s Sensitive Personal Data only for as long as it believes is necessary to fulfill the purposes for which such information was collected (including, for the purpose of meeting any legal, administrative, accounting, regulatory or other reporting requirements or obligations). This information is safeguarded against inappropriate access and disclosure, as provided in paragraph 6 below.
5. Disclosing Personal Information
5.1 RL India shall not disclose to third parties or publish the Sensitive Personal Data provided by the Data Provider, except in the manner described under this Privacy Policy and in compliance with applicable law.
5.2. RL India and its Authorised Persons may share and transfer Data Providers’ Personal Information with RL India’s affiliated companies worldwide for compliance, risk management and operational purposes and with other Authorized Persons such as those providing professional, legal, accounting or other advice or services, including any third party agencies that perform background checks on a Data Provider. RL India may also disclose and transfer the Sensitive Personal Data to any other third party pursuant to the Data Provider’s express consent. Third parties are required to maintain strict standards of confidentiality for dealing in such Personal Information and to use it only in the course of providing services to RL India, in the manner and for the limited purposes authorized by RL India. Third parties receiving the Sensitive Personal Data under any of the circumstances described above are required to not disclose or disseminate such information further.
5.3. Notwithstanding the above and subject to applicable law, the Personal Information of the Data Providers may be shared, without their prior consent, with government agencies mandated under the law to obtain information including Sensitive Personal Data for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences. RL India may also disclose Personal Information to any third party pursuant to an order under the law in force, for instance, when responding to summons or similar legal process, to protect against fraud and to otherwise co-operate with law enforcement or regulatory authorities.
5.4. Subject to applicable law, RL India may, at its sole discretion, transfer Personal Information of the Data Provider to any other body corporate (as defined under the Information Technology Act, 2000) or a person in India, or located in any other country, that ensures at least the same level of data protection that is adhered to by RL India as provided for under this Privacy Policy and applicable Indian law provided such transfer is necessary for the performance of the lawful contract between RL India or any person on its behalf and provider of information or where the Data Provider has consented to the data transfer.
6. Information Security Practices and Procedures
6.1. RL India endeavors to maintain physical, technical and procedural safeguards that are appropriate to protect the Data Provider’s information against loss, misuse, copying, damage or modification and unauthorized access or disclosure.
7. Access to Personal Information
7.1. To receive a copy of the information in the company’s records, or to provide instructions to RL India on correcting or updating the Personal Information maintained by it, the Data Provider can send an e-mail to RL India at india.hr@reachlocal.com. The Data Provider is entitled to review the information provided by him/ her or on his/ her behalf and ensure that any inaccurate or deficient Personal Information is immediately corrected.
8. Grievances
8.1. In case of any privacy related concerns, feedback or grievance in relation to RL India’s Privacy Policy, you may contact Suyog Vankudre and/or Sachi Agarwal, our designated Grievance Officers fs purpose.
9. Revision to this Privacy Policy
9.1. RL India may from time to time make changes to this Privacy Policy based on its commercial or legal obligations. The Data Providers should check the website:
www.reachservices.co.in for the most updated versionis policy.
10. Interpretation of Privacy Policy
10.1. This Privacy Policy does not create or confer upon any individual any rights, or impose upon RL India any obligations outside of, or in addition to, any obligations imposed by the applicable Indian information security laws.
10.2. If and to the extent that this Privacy Policy is not in accordance with the applicable law, the provisions of applicable law shall be deemed to prevail.