1. OBJECTIVE, SCOPE AND APPLICABILITY

Punditry Tech Labs Private Limited  (hereinafter referred to as the “Company”, “We”, “Us”, “Our”) respects an individual’s privacy and is committed to protecting the same. This document (“ Policy”) describes how We collect, use, disclose and transfer Personal Data (as defined below), through Our website and applications, current and which may be used by the Company in future including through punditry.co and online services (collectively, the “Platform”) of the individuals who browse, or access the Platform or provide information on or through the Platform, or whose information the Company otherwise collects, receives or processes in connection with its services (“Services”) (hereinafter, collectively referred to as “Users“, “You”, “Your”) and ensure its compliance with applicable laws and regulations. We are committed to respecting Your online privacy and recognize the need for appropriate protection and management of any Personal Data You share with Us.

This Policy is an electronic record in terms of: (i) Information Technology Act, 2000 (“IT Act”); (ii) the rules framed there under as applicable; and (iii) the amended provisions pertaining to electronic records in various statutes as amended by the IT Act. This electronic record is generated by a computer system and does not require any physical or digital signatures.

This Policy is published in accordance with the provisions of the IT Act and the rules made thereunder that require publishing the rules and regulations, privacy policy and terms of use for access or usage of our Platform.

The Platform is owned, registered and operated by Punditry Tech Labs Private Limited, a private limited company, incorporated under the provisions of the Companies Act, 2013 and having its registered office at WeWork Latitude, 9th floor, RMZ Latitude Commercial, Bellary Road, Hebbal, Bangalore, Karnataka 560024.

Any Third Parties working with or for the Company, and who have or may have access to the Personal Data, will be expected to have read, understand and comply with this Policy.

By accessing and / or using our Platform, the Services and providing the information as explained in this Policy, You understand that We will collect and use Your Personal Data as described in this Policy and You expressly consent to the terms of this Policy. We encourage You to read this Policy regarding the collection, use, and disclosure of Your Personal Data. If You are not comfortable with any of the terms or policies described in this Policy, You may choose to discontinue usage of the Platform and the Services.

The Company may act as data processor or as a separate data controller depending on the Service being provided and the amount of control the Company has over the purpose(s) and means of the data processing.

We reserve the right to make changes to this Policy at any time. Any such modifications shall become effective immediately upon posting to the Platform and your continued use of the Platform constitutes your consent to such modifications. If you object to any changes, you may deactivate your User Account. You agree to periodically review the current version of the Policy as posted on the Platform.

If You are a job applicant for employment with Our clients (“Applicant”) You understand that the Company provides a suite of talent acquisition products, to:

• Help our clients find their next hires: when You apply, Our client (the recruiter or hiring manager) can consider You for any job opportunities they have and can use any talent acquisition or productivity tools to track, manage and make a decision.

If You or Your organization is Our client and have a separate agreement with Us, that agreement may have privacy terms that also apply to the Personal Data You provide to Us under that agreement. You are requested to review the terms of that agreement as well.

Our clients or any other third party may either collect Your Personal Data and transfer the same to Us or require Us or any third party, to collect such Personal Data on behalf of them. The Personal Data provided to the Company by Our clients is collected by those clients under their own privacy policies. This Policy does not apply to practices that the Company does not own and accordingly, in such case, the Company will only process the Personal Data provided by or collected on behalf of such clients and will only act for and on behalf of such clients. To such an extent, the Company will qualify as a processor.

If You are a current or former employee or applicant for employment with the Company, We will act as a “controller” for the purpose of GDPR and this Policy describes the Personal Data that We may collect from or about You, and how We use and to whom We disclose that Personal Data. We collect the types of Personal Data that We require in order to manage our relationship with You, from the point at which You make an application to work with Us (e.g. in your application) and throughout Your employment with Us (e.g., through on-boarding, using our systems, and signing up for benefits).

Notwithstanding anything contained herein, if You breach the terms of the Policy, the Company reserves the right to take any legal or other action against you, including but not limited to, denying or revoking access to the Platform and the Services and referral to the appropriate authorities.

For the purpose of this Policy, the following terms used herein shall have the meaning ascribed to it below:

• Personal Data: It refers any information about an individual which can be used to distinguish or trace an individual’s identity or any other information which indirectly in combination with certain other information can be used to identify an individual. Examples included but not limited to name, email address, curriculum vitae, . Personal Data includes the information 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.
• Third Party: All external parties such as suppliers, clients, customers, advisers, contractors, interns, summer trainees, vendors, etc. who have access to the Company’s information assets or information systems.

2 PURPOSE OF COLLECTING AND KINDS OF PERSONAL DATA COLLECTED

2.1 The use and the collection of the Personal Data by the Company is dependent upon how the User interacts and/or avails the Services of the Company.

We collect certain information pertaining to You and/or Your usage of the Platform or our Services, to provide better services and offerings. We collect the following categories of Personal Data in the following ways:

• name, age, gender, email address, password, country, city, contact number, current status of job search, company/organization that You are associated with, company/organization(s) that You’ve been associated with in the past, Your educational background (degrees, diplomas or certifications) and other information related to Your professional career when You sign up for alerts on the Platform;
• information that one would usually include in a resume, including name, contact details including e-mail address and contact number, work experience, educational qualifications, data relating to Your current and past remuneration or salary, a copy of Your resume, etc. when You register on the Platform;
• information about Your current salary, Your expected salary and Your preferred job location(s);
• information about the Services that You use and how You use them, including log information and location information, when You are a user of the Services through the Platform;
• We may collect Your information such as name, age, contact details, preferences, etc. through surveys and forms, when You choose to participate in these surveys etc.;
• when You communicate with or use the Platform to communicate with other Users (such as partners), We collect information about Your communication and any information You choose to provide;
• Job search behaviour and preferences, and a record of the searches that You make on our sites;
• Your educational details as You sign up with us;
• Other details that You may submit to Us or that may be included in the information provided to Us by clients or Third Parties;
• Technical information about Your use of our Platform;
• when You visit the Platform, We use cookies to automatically collect, store and use technical information about Your system and interaction with Our Platform;
• when You use a device to access the Platform, the Company may collect technical or other related information from the device as well as the device location;
• to the extent permitted by law, the Company may record and monitor Your communications with Us to ensure compliance with our legal and regulatory obligations and our internal policies. This may include the recording of telephone conversations;
• publicly available data about You from Third Party sites and sources, including profiles created by You on other websites, or other information you have publicly shared for the purpose of advertising or informing others about Your background;
• If You choose to sign in with Your social media account to access the Platform, or otherwise connect Your social media account with the services of the Platform, You consent to Our collection, storage, and use, in accordance with this Policy, of the information that You make available to Us through the social media interface. Please see Your social media provider’s privacy policy and help centre for more information about how they share information when You choose to connect Your account.

2.2 We shall use Your Personal Data in a fair and reasonable manner, and where We have a lawful reason to do so. Our use of Your Personal Data depends on the purpose for which You interact with us. We may process Your Personal Data for the following purposes:

• Creating Your account and send You job alerts or other promotional materials;
• give You relevant search results and job recommendations;
• facilitate communication as part of the job search, application and interview process;
• make Your resume / profile available to Third-Parties which shall be informed to You;
• as applicable, match You with job-listings;
• facilitate payment, in connection with chargeable Services;
• carry out automated processing in order to provide many of Our Services;
• enhance and optimize Our Services and security for employees and employers by data sharing with our affiliated entities and websites;
• providing our Services and products to You including to send You job alerts, calendar alerts, relevant search results, recommended jobs and/or candidates (as the case may be), and other social media communication facilities;
• Protecting our Users and providing You with customer support;
• We use information collected from cookies and other technologies, to improve Your experience and the overall quality of our Services (for more information please refer to paragraph on cookies below). When showing You tailored ads, We will not associate an identifier from cookies or similar technologies with sensitive categories, such as those based on race, religion, sexual orientation or health.
• Improving the Platform and its content to provide better features and Services.
• Conducting market research and surveys with the aim of improving Our products and Services.
• Sending You information about Our products and Services for marketing purposes and promotions;
• Meet any applicable law, regulation, legal process or enforceable governmental request.
• Internal employment requirements

 

2.3 We may also collect and/or generate anonymized and aggregated information from Your use of the Platform. The anonymized or aggregated information is not Personal Data since We are not able to re-identify You using any means available to Us from that anonymized or aggregated information. The anonymized and aggregated information is used for a variety of functions, including to help Us identify and remediate any bugs, and to improve the performance of Our Platform. The Company may use such information in a number of ways, including internal analysis, analytics and research. We may share this information with Third Parties for Our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying You.

• AdditionalUses and Disclosures of Non-Personal Data:

In addition to the other uses and disclosures of information set forth in this Policy, and notwithstanding anything in this Policy to the contrary, We may use and disclose, for any purpose, any non-personal data, except where We are required to do otherwise under applicable law. If We combine any non-personal data with personal data, then We will only use and disclose such combined information for the purposes described above while it is so combined.

Retention of Data: Notwithstanding the provisions of this Policy, if the Customer has provided us with Personal Data on a voluntary basis, the same shall be retained as required under applicable law

2.6 Limitations of Use:

• Your Personal Data will not be used in the following cases: Where details provided to Us are incorrect or inaccurate. It is your sole responsibility to ensure that Your Personal Data is up-to-date and accurate in all respects.
• Where minimum age of Users is under the age of 18 (eighteen).  If You are under the age of eighteen or the age of majority in Your jurisdiction, You must use Our Platform under the supervision of Your parent, legal guardian or responsible adult.

 

• The Platform is not intended for persons under the age of 18 (eighteen). If you are aware whether your child/legal ward has provided us with personal information without your consent, please contact us at the email address provided below. If we become aware that a person under the age of 18 (eighteen) has provided us with personal information, we shall take appropriate action to remove such information and suspend/terminate the relevant account

 

3. WHO IS THIS PERSONAL DATA SHARED WITH

 

We share Personal Data with certain Third Parties, such as suppliers, clients and advisers that perform certain services on Our behalf or that receive Services from Us. Sometimes sharing Your Personal Data with these Third Parties is necessary for them to perform their services or for Us to provide our Services to them.

We will only share Your Personal Data with Third Parties for the purposes identified above in accordance with the Policy, or with Your consent. We will obtain assurances from each Third Party with whom We share Your Personal Data for purposes of maintaining our relationship with You (e.g., benefits providers) that it will safeguard Your Personal Data consistently with this Policy and will notify the Company if it makes a determination it can no longer meet this obligation. If We have knowledge that a Third Party is using or disclosing the Personal Data in a manner contrary to this Policy, We will take steps to prevent or stop the use or disclosure.

Your Personal Data may be also disclosed or transferred to a third party in the event of any proposed or actual reorganization, sale, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of our Company or of any Company assets (including should the Company become insolvent, enter into receivership or any similar event occur). Should such an event take place, We will direct the transferee to use the Personal Data in a manner that is consistent with this Policy.

We may also disclose Your Personal Data to third parties if necessary, to comply with legal obligations, for example to cooperate with regulatory authorities, law enforcement bodies, or courts.

4. HOW WE STORE DATA

We may store Your personal data using Our own secure on-site servers or other internally hosted technology. Your Personal Data may also be stored by Third Parties, via cloud services or other technology, with whom the Company has contracted, to support the Company’s business operations.

These Third Parties do not use or have access to Your Personal Data other than for cloud storage and retrieval, and the Company requires such parties to employ at least the same level of security that We use to protect Your Personal Data.

5. HOW LONG DO WE STORE YOUR PERSONAL DATA

We store Your Personal Data until it is no longer necessary to provide our Services, or until You ask Us to delete Your Personal Data. We may also be required to retain certain information in order to comply with applicable laws. If You wish to delete Your Personal Data, You should submit a delete request to hello@PUNDITRY.co However, if You are a job applicant, please log-in to Your account and make a formal request to delete Your Personal Data.

6. TRANSFER OF PERSONAL DATA ACROSS BORDERS

The Company has affiliates all over the world and has  globalclients,. As a result, Your data may be transferred to the affiliates for the purposes identified above. Any such transfer shall take place only in accordance with and as permitted by the laws of India. Regardless, in all events, We shall apply the provisions of this Policy to Your Personal Data wherever it is located.

7. CUSTOMER COMMENTS AND CONTENT

If You post any comments or content on Our Platform, You should be aware that any information You choose to provide there may be read, collected, or used by the third parties. We are not responsible for the information You choose to submit, and We cannot guarantee that third parties have not made copies of or will not use such information in any way. We may display links to web sites that are owned or operated by third parties on Our Platform. Please understand that these websites are independent from the Company, and the Company has no control over the content on that website, even if the Company provides information or Services to the owner of that website. The Company is not making any representations about, endorsing, or accepting any responsibility for the content or the use of such website. Further, We are not responsible or liable for any damage or loss related to the use of any Third-Party website. You should always read the terms and conditions and the privacy policy of a Third-Party website before accessing or using it.

8. SECURITY

We use reasonable security measures to help protect against the unauthorised access, loss, misuse and alteration of the Personal Data under our control. No method of transmission over the internet, or method of electronic storage, is completely secure, however. In addition, please note that emails, messages sent via Your web browser, and other similar means of communication with other Users, are not encrypted. Therefore, while We strive to protect Your information, We cannot guarantee its security.

Please also be aware that We may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable; these service providers have informed Us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, We will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including Personal Data, by these companies.

9. AUTOMATED PROCESSING

Our clients may opt in to use features that assist them in the recruitment process through automated means. For You as a candidate, it means that Your application is processed and analyzed to identify relevant aspects from Your work history such as previous positions and employers, education history, demonstrated skills, and duration of work. These aspects are then compared against the job published by Our client to indicate how Your application corresponds with the requirements outlined in the job listing.

These findings help Our client highlight existing information in Your application. The automated capabilities are used to facilitate the recruitment process; however, any conclusive hiring decisions are ultimately at the client’s discretion.

10. EXERCISING RIGHTS WITH RESPECT TO PERSONAL DATA

As a User, You may avail Yourself of the rights explained below. Please note, We may attempt to verify Your identity through the email address or telephone number associated with Your use of our Platform prior to fulfilling any such request and reserve the right to deny a request where We are unable to satisfactorily complete this process. If You authorize someone to make a request on Your behalf, We may also deny Your request if We are unable to verify with You that the individual making the request is authorized to act on Your behalf.

In cases where We are data processors, We will forward any requests, inquiries or claims concerning these processing activities to the respective data controller for further assessment and necessary action.

10.1 The Right to Rectify Your Personal Data

The Users are able to edit and update most of their Personal Data held by Us on the Platform, and if You have any queries or complaints, We encourage You to contact Us at dpo@PUNDITRY.com.

Alternatively, if You do not wish to do this You may make a formal request to have Us rectify any inaccurate Personal Data on Your behalf by sending an email to hello@punditry.co from the email address associated with Your account.

10.2 Opting Out of Marketing Messages and Withdrawing Consent

If You no longer want to receive marketing materials from Us based upon Your Personal Data, You may opt-out by following the procedures specified below:

If You wish to opt out of a particular marketing email, You may do so by clicking “unsubscribe” (or an equivalent action) where applicable. Please note that this will only opt You out of that particular marketing message.

In addition, You may opt out of all marketing messages by sending an email to hello@punditry.co We will comply with Your request as soon as reasonably practicable, and in accordance with applicable laws.

Finally, please note that We may still send other messages to You, such as administrative and transactional messages.

10.3 Some Limitations

Such rights of rectification, objection, restriction, access, portability and deletion are subject to certain limitations, as provided for by applicable laws. Individual requests will be completed within the time allotted by relevant regulations, which starts to run from the point of the Company confirming Your request. Where permitted, please note there may be a charge for subsequent requests from the same individual, which will be determined by the Company and only imposed to the extent permitted by applicable law.

11. COOKIES INFORMATION:

We may send one or more cookies or other anonymous identifiers to Your device through the Platform to collect and store information when You visit the Platform.

We may use both session cookies, which expire once You close Your web browser, and persistent cookies, which stay on Your computer until You delete them and other technologies to help Us collect data and to enhance Your experience with the Platform. Cookies are small text files a website can use to recognize a repeat visitor to the website. We may use cookies for various purposes, including to:

• authenticate Users;
• personalize Your experience;
• analyze which portions of the Platform are visited or used most frequently; and
• measure and optimize advertising and promotional effectiveness.

If You do not want Us to deploy cookies in Your browser, You can opt out by setting Your browser to reject cookies or to notify You when a website tries to put a cookie in Your browser software. If You choose to disable cookies in Your browser, You can still use the Platform, although Your ability to use some of the features may be affected.

12. THIRD-PARTY ANALYTICS

When processing Your data, We may use third-party analytics services to evaluate Your use of the Platform, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Platform and mobile and internet usage. These third parties may have access to Your data, use cookies and other technologies to help analyze and provide Us the information and, in some cases, connect such information with other data held by Us, or third party, environments. You consent to the processing of information about You by these analytics providers in the manner and for the purposes set out in this Policy.

13. ADVERTISEMENT INFORMATION

The Company or third-party advertisers or their advertising servers may also place or recognize unique cookies on devices or use other electronic tools in order to help display advertisements that the Customers see on the Platform. Information about visits to, and activity on, the Platform, an IP address, the number of times an advertisement has been viewed and other such usage information is used, alone or in combination with other information, to display on the device screen advertisements that may be of particular interest to You. We may use web beacons, provided by third-party advertising companies, to help manage and optimize our online advertising and product performance. The web beacons enable Us to recognize a browser’s cookie when a browser visits the website, and to learn which banner ads bring users to the website. The use and collection of the information by these third-party service providers, and third-party advertisers and their advertising servers is not covered by this Policy.

14. RESPONSIBILITIES

Notwithstanding anything stated herein above, We currently keep Your Personal Data in a very secure manner and restrict who has access to it. We need Your Personal Data to be able to provide Services to You and to give You access to our Platform and You give Us your Personal Data at the time your register for Our Platform, download Our mobile app and/or use or buy Our products and Services.

15. PRIVACY CONCERNS AND GRIEVANCES

If You have any grievances as to the usage of any of Your Personal Information or any other privacy concerns, you can contact the Grievance Officer whose details are provided hereunder:

Name: Ananda Gokhle
E-mail Address: Ananda.g@punditry.co
Phone Number: +91897162800

16. GOVERNING LAW AND JURISDICTION

This Privacy Policy shall be governed by and constructed in accordance with the applicable laws of India without reference to conflict of laws principles. The courts in Mumbai, India shall have the exclusive jurisdiction to determine any disputes arising in relation to, or under this Privacy Policy