Privacy Policy of Mahindra Comviva

This Privacy Policy is applicable to this Site and not necessarily to other Mahindra Comviva sites on the World Wide Web. When leaving this Site, please read the privacy policy applicable to the site you are visiting. The Privacy Policy will provide you with information on our data processing activities with respect to certain personal data you provide us or we collect including how we use such information, how we protect the security of such information and how you may change or request that we amend such information from our systems. Protecting the security and privacy of your Personal Information is important to us. If you do not agree with this Privacy Policy, please do not use this Site. The Privacy Policy considers the rights and obligations set forth in the EU General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”).

 

Personal Information

Through our Web sites, Mahindra Comviva will not collect any personally identifiable information about you (e.g. your name, address, telephone number or e-mail address etc) (“Personal Information”), unless you voluntarily choose to provide it to us (e.g. by registration, survey). Provision of the personally identifiable information by you will amount to ‘consent’ for Mahindra Comviva to store and use the personally identifiable information. If you do not want your Personal Information collected, please do not submit it on the Site.

 

Please note our Site includes hyperlinks to other websites neither owned nor managed by us. Mahindra Comviva is not associated with these third-party websites and does not review their privacy policies. We cannot guarantee the privacy of any information that may be obtained by third parties at these other websites. We strongly encourage you to review the privacy policies of any website you visit before supplying Personal Information through that website. The Personal Information provided by you to third–party website shall be governed as per the privacy policy of such third party.

 

You do not need to provide this Personal  information to us but if you don’t, we will not be able to respond to your communication. When you do provide us with Personal Information, we usually use it to respond to your inquiry, process your order or provide you access to specific account information or process your application for interviews and/or employment purposes. We use this information because we have a legitimate business interest in understanding customer/potential customer, vendor / potential vendor, employee / potential employee feedback and information and in responding to your communications in a consistent way. Also, to support our customer relationship with you:

a.) We may store and process Personal Information and share it with our worldwide affiliates as permitted under applicable data privacy law pursuant to Art.6(1)(f)GDPR for the legitimate interests  to better understand your business needs and how we can improve our products and services; or we (or a third party on our behalf) may use Personal Information to contact you about a Mahindra Comviva offer in support of your business needs or to conduct online surveys to understand better our customers’ needs and profiles.

b.) If you choose not to have your Personal Information used to support our customer relationship (especially direct-marketing or market-research),we will respect your choice. Except as described in this Privacy Policy we do not now (and do not intend to), without your consent, sell, rent or otherwise market your Personal Information to third parties.
We will keep this information for as long as you have a relationship with us or, if you do not have a relationship with us beyond this communication, for a reasonable length of time that lets us understand how people use our website.

 

Security

Mahindra Comviva takes precautions to ensure the security of your Personal Information and strives to keep it accurate. We carefully protect your Personal Information from loss, destruction, falsification, manipulation, and unauthorized access or unauthorized disclosure.

 

Non-Personal Information Collected Automatically

When you access our Site, we may automatically (i.e., not by registration) collect information that is not personally identifiable (e.g., type of Internet browser and computer operating system used; domain name of the Web site from which you came; number of visits, average time spent, pages viewed etc). Mahindra Comviva is committed to the privacy of its web site visitors. Please note that we may provide aggregate statistics about our customers, sales, traffic patterns, and related site information to reputable third parties, but these statistics will include no personally identifying information. Such information may be treated as Personal Information about the visitor in accordance with applicable local law. We use this information because we have a legitimate business interest in understanding how our website is accessed, how it is used and any problems users have with it across multiple devices. We will keep this information for a reasonable length of time that lets us understand how people use our website and any technical issues they have.

 

“Cookies” — Information Placed Automatically On Your Computer – From time to time, we may place information on your computer to allow us to identify you. This information is commonly known as “cookies”. By showing how and when our visitors use this Site, this information can help us to improve our Site on a continual basis. We will only use cookies to view information on your hard drive that was put there by a cookie from this Site. The use of cookies is an industry standard and many Web sites use them. If you do not wish to receive cookies, or want to be notified of when they are placed, you may set your web browser to do so, if your browser so permits.

 

Legal Requirements

We will also disclose Personal Information (1) in response to lawful requests by public authorities (including to meet national security or law enforcement requirements) and, where applicable, in accordance with our internal policy on access by government or regulatory authorities and (2) in our sole discretion if we believe that such disclosure is appropriate in connection with an official government or regulatory investigation or in response to a perceived significant threat to a person’s health or property.

We may also process your Personal Information if necessary in the defence of a legal claim. We will not delete Personal Information if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

All the above is done in accordance with applicable law based on Art. 6(1)(c)GDPR and to external advisors acting as controllers (e.g. lawyers, accountants, auditors etc.) based on Art. 6 (1) (f) GDPR.

 

Children

No information may be submitted to Mahindra Comviva by persons under the age of 18 without the consent of a parent or legal guardian, nor may persons under the age of 18 make purchases or other legal acts on this Site without such consent. Mahindra Comviva encourages all parents or guardians to instruct their children in the safe and responsible use of their Personal Information while using the Internet. Mahindra Comviva will not knowingly collect or use any Personal Information collected from children for any purpose whatsoever, including disclosure to third parties.

 

Protection of Personal Information

Mahindra Comviva has implemented and currently maintains an effective written information security program that includes administrative, technical, and physical safeguards and other security measures necessary to (a) ensure the security, confidentiality, and integrity of your Personal Information; (b) protect against any anticipated threats or hazards to the security, confidentiality, and integrity of your Personal Information; (c) protect against unauthorized access to, destruction, modification, disclosure or use of your Personal Information; and (d) detect and respond to security incidents involving your Personal Information. We permit persons working for us to access and use your Personal Information only to serve our legitimate business and our customers’ service needs, in accordance with this Privacy Policy.

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Transfer of Personal Information to other countries

We transfer your Personal Information outside of the country you are located. Some recipients of your Personal Information are located in another country for which the European Commission has not issued a decision that this country ensures an adequate level of data protection, namely: The U.S. or some of the locations of non-European Mahindra Group Companies

Some recipients located outside of the European Economic Area (“EEA”) are certified under the EU-U.S. Privacy Shield and others are located in countries for which the European Commission has issued adequacy decisions. In each case, the transfer is thereby recognized as providing an adequate level of data protection from a European data protection law perspective (Art. 45 GDPR).

By way of entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EU and/or 2004/915/EC) as referred to in Art. 46 (5) GDPR or other adequate means, which are accessible by sending a request to privacy@mahindracomviva.com , we have established that all other recipients located outside the EEA will provide an adequate level of data protection for the Personal Information  and that appropriate technical and organizational security measures are in place to protect Personal Information against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. Any onward transfer (including our affiliates outside the EEA) is subject to appropriate onward transfer requirements as required by applicable law.

 

 

Your rights

Under the conditions set out under applicable law (i.e., the GDPR), you have the following rights:

1. Right of access: You have the right to obtain from us confirmation as to whether or not Personal Information concerning you is being processed, and, where that is the case, to request access to the Personal Information. The access information includes – inter alia – the purposes of the processing, the categories of Personal Information concerned, and the recipients or categories of recipients to whom the Personal Information have been or will be disclosed.

You have the right to obtain a copy of the Personal Information undergoing processing. For additional copies requested by you, we may charge a reasonable fee based on administrative costs.

2.Right to ask us to rectify any inaccurate Personal Information concerning you. 3. You have the right to ask us to erase your Personal Information.

4. You have the right to request the restriction of processing your Personal Information. In this case, the respective data will be marked and may only be processed by us for certain purposes.

5 .You have the right to ask us to provide you your Personal Information which you have provided to us in a structured, commonly used and machine-readable format

6.You have the right to transmit your Personal Information to another entity without hindrance from us.

7.You also have a right to object to us processing your information in certain circumstances. However, such a right to object may not exist in certain situations, for eg. if the processing of your Personal Information is necessary to take steps prior to entering into a contract or to perform a contract already concluded or if the information is relevant to a legal dispute then we may not stop processing your information.

8.In case of complaints you also have the right to lodge a complaint with the competent supervisory authority, in particular in the Member State of your habitual residence or alleged infringement of the GDPR.

 

Changes

We reserve to right to change, modify or withdraw access to this Site, or the content of these pages at any time. We recommend you regularly review this page.

 

© Comviva Technologies Limited, India, 2018. All Rights Reserve