WHAT DATA WE COLLECT
SOE may through your employer collect your personal data, including, inter alia, name, date of birth, email, login user names, and your official data, including, inter alia, email, employee Id, department, designation, location, country, reporting manager, business unit, date of joining, details of employer (collectively, “Personal Data”) from the following sources:
documents and information voluntarily submitted by you to your employer or SOE;
your interactions with us through website, mobile applications or text messaging programs;
our communications with your employer.
Further, SOE may use certain technical information that does not permit the identification of an individual and which may be collected during your access or use of the websites, such as, log data, analytics code, IP address, browser type, browser language, date and time of your requests, your profile, websites/ links visited by you, search terms used (collectively, “Anonymous Data”).
HOW WE STORE YOUR PERSONAL DATA
Your Personal Data shall be securely stored on servers hosted by reputed Internet Service Provider (“ISP”) or Cloud Service Provider (“CSP”). Such ISP or CSP shall be liable to keep your Personal Data secure at all times and adopt such technical measures as may be required to meet your reasonable expectation of privacy. Currently, the data center is hosted with AWS in Singapore Region.
HOW LONG DO WE STORE YOUR DATA
Post closure of the service/termination of the agreement, all the user PII are removed after 30 days. Transactional data is also anonymised.
WHY WE COLLECT AND PROCESS YOUR PERSONAL DATA
SOE as a Data Processor collects and uses your personal data on instructions of your employer to help your employer engage its employees through various initiatives at work such as learning, productivity, engagement, and compliance and such other initiatives that support/further the mission, goals, values and initiatives of your organization and provide other related services. SOE shall ensure that the data collected from your employer shall be processed for the limited purposes provided below. You have the right to object any use of your data for purposes not listed below.
to notify you regarding activities on the Platforms, updates related to various programmes or initiatives that your employer may consider beneficial to its employees and matters incidental thereto;
to notify you about functionality and changes on our websites, new services and special offers that you may find of value;
to create and maintain your accounts with SOE, including your transaction details on the Platforms that are associated with your account.
WHETHER WE MAKE MARKETING COMMUNICATIONS
Except as otherwise consented by you, SOE does not sell or otherwise release your Personal Data to third parties to allow them to direct market their products and services to you, identify who you are or remember where you've been on the internet. However, SOE may use your Personal Data and/or Anonymous Data to provide you with relevant marketing communications such as information about SOE, its products and services, competitions and promotions based on your activities on our Platforms. In case you do not wish to receive such marketing information, please email us at firstname.lastname@example.org
WHEN WE CAN DISCLOSE/ SHARE YOUR PERSONAL DATA
SOE shall not disclose your Personal Data to any third party for any reason whatsoever, without your express consent to that effect. However, your Personal Data may be disclosed to or shared with a third party without your consent under the following circumstances:
pursuant to a valid and subsisting order of a court or other judicial, quasi judicial or government body under applicable laws or if, in SOE’s good faith judgement, such legal disclosure is reasonably necessary to comply with legal processes or respond to any claims;
change in control or management of SOE, a full or partial merger with, or acquisition of all or part of SOE by another company.
Further, SOE may share your Personal Data with its trusted affiliates or related companies for the limited purposes of providing services on the Platforms, processing of your Personal Data, on need to know basis and subject to confidentiality obligations as may be contractually agreed to between such third party and SOE in accordance with the provisions of GDPR.
HOW WE USE AND PROCESS YOUR PERSONAL DATA
SOE takes all reasonable steps to ensure fair, lawful and transparent processing of your Personal Data. In furtherance of this objective, SOE as a data processor will:
Process your Personal Data (i) on the written instructions from your employer and (ii) for the limited purposes of the provision of services;
Process your data by itself or another sub processor with prior notification to your employer.
Retain your Personal Data only as long as it is necessary for rendering the services on the Platforms except when otherwise required under applicable laws;
Meet your reasonable expectations of data privacy while processing your Personal Data;
Use reasonable efforts and security measures, including, a variety of security technologies and procedures to protect your Personal Data from any unauthorized access, use or disclosure;
Provide you all information related to processing of your Personal Data through your employer, for instance whether or not your Personal Data is being processed, the recipients or categories of recipients to whom the personal data has been or will be disclosed, the period for which the personal data will be stored, where it is processed and for what purpose it is processed, upon receipt of a written request from you.
On your request to your employer, provide a copy of the personal data undergoing processing.
Communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with this policy to each recipient to whom the personal data has been disclosed, unless this proves impossible or involves a disproportionate effort.
Adhere to approved codes of conduct in compliance with the GDPR.
Ensure regular tests, assessment, and evaluation of the effectiveness of technical and organisational measures for ensuring the security of the processing.
WHAT RIGHTS YOU CAN EXERCISE
Right to Access: You can access your Personal Data at all times during the subsistence of your account with SOE. You are free to review and modify your Personal Data and correct inaccuracies, if any, in your Personal Data, from time to time, after you login to the websites. In case you are unable to access, correct, or update any of your Personal Data, you may send us a request at email@example.com. You can also request us to provide your Personal Data collected by us in a structured and commonly used format. Upon receipt of such request, SOE will provide your Personal Data request free of charge within one month from the date of such request, unless such request is manifestly unfounded or excessive. However, SOE shall not be liable to retain or provide access to your Personal Data after three (3) months from the date of deactivation of your account with SOE.
Right to withdraw consent:In the event you wish to withdraw your consent for usage of your Personal Data for any particular activity of SOE and its affiliates at any time during the subsistence of your account with us, you can notify us in writing. Upon receipt of such notification, SOE shall not use or allow further dissemination of your Personal Data or part thereof, for the purpose mentioned therein.
Right of Erasure: If you wish to remove all or any part of your Personal Data collected by SOE, its affiliates or any of the related parties, you can raise a request to your employer. And receipt of such instruction from your employer, your Personal Data will be erased by SOE subject to any legal obligations which mandate retention of any part of your Personal Data under applicable laws and regulations. : (a) upon receipt of such request for erasure; (b) deactivation of your account with SOE.
Right of Rectify: SOE shall at all times ensure the accuracy of the data collected from you. In the event, you come across any inaccuracy in your Personal Data; you can raise a request to your employer or us by sending an email to firstname.lastname@example.org for rectification of your Personal data.
Right to object automated decision making:You may object being subjected to a decision based solely on automated processing, including profiling, which may significantly affect you by writing to your employer or us by sending an email to email@example.com. SOE shall implement suitable measures to safeguard your rights, freedoms and legitimate interests, and shall obtain human intervention to contest the decision.
THIRD PARTY LINKS/ EXTERNAL LINKS
Our websites may contain links to content or other functionality provided by third parties which are outside our control and are not covered by this Policy. Accordingly, SOE shall not be liable for any breach of your Personal Data which is attributable to the acts or omissions of such third parties.
SOE shall intimate any instances of data breach to you without any undue delay and, where feasible, within 72 hours of becoming aware of such breach, failing which SOE shall provide reasoned justification for the delay. However, SOE shall not be liable to notify you about any minor breach which is unlikely to result in a risk to your rights and freedoms related to your Personal Data. Further, SOE shall take all reasonable steps to curve such instances and take all corrective measure to minimize the impact of such data breach.
What are cookies: Cookies are small text files that are placed on your web browser by websites that you visit, in order to make websites work more efficiently and generate user specific content and tools.
What types of cookies we may use
Persistent Cookies: It helps recognise you as an existing user, and use our services without signing in again. After you sign in, it stays in your browser and will be read by SOE when you return to our websites after navigating to other websites or tabs.
Session Cookies: The technical information stored by session cookies lasts as long as the current web session (usually your current visit to a websites or a browser session) persists.
Analytics Cookies: These cookies track information about how a user uses the Platforms. Analytics cookies may either be first party cookies or third party cookies. These cookies allow our websites to provide you a more personalised online experience.
Whether you can opt out of cookies:With most Internet browsers, you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. Please refer to your web browser instructions or help screen to learn more about these functions. However, if you reject cookies, the functionality of our offerings may be restricted.
WHETHER WE USE ANY OTHER TRACKING TECHNOLOGIES
SOE uses certain services such as Google Analytics, a web analytics service provided by Google, Inc. ("Google"), hotjar, Zoho to understand the use of our product and continuously improve our product for our customers.
INTERNATIONAL TRANSFER OF DATA
In the process of providing access to the websites and processing your Personal Data, SOE may transfer your Personal Data to affiliated entities or other third parties across countries or jurisdictions in accordance with the transfer principles laid down in the GDPR. In this regard, you may seek information from us on firstname.lastname@example.org to be informed of the jurisdictions where your data has been used or processed.
COMMUNICATION AND GRIEVANCES
We will make all attempts to contact you only through email and ensure that your telephone number is used only for the limited purposes of providing the relevant services on the Platforms. In case you have any grievances regarding usages of your Personal Data, you can contact our Grievance Officer at email@example.com. Upon receipt of such complaint, SOE will make all the reasonable efforts to address your concerns at the earliest.
On signing up with SOE, you hereby acknowledge and confirm that:
you have read, reviewed and understood all the terms of this Policy and its implications and voluntarily agreed to provide your explicit consent for access and usages of your Personal Data for the purpose specified under this Policy;
you have been apprised of your right to withdraw your consent at all times during the subsistence of your account with SOE without detriment.
HOW CAN YOU REACH US?
You can reach out to us at firstname.lastname@example.org.