I. INTRODUCTION
iComply Lifescience Solutions Private Limited (the “Company”), a company duly incorporated under the Companies Act 2013, owns and operates the website “www.icomplyqualityplatform.com”, its mobile-friendly website and the mobile application (hereinafter individually and collectively referred to as the “Channel”). The Company operates in the IT and IT enabled services sector and provides strategic consulting, business process service and technology solutions (the “Services”) world-wide through these Channels.
For the purpose of this Privacy Policy (the “Policy”), the use of terms like “we”, “us” and “ours” refers to the Company and the terms “you” and “your” refers to the User (defined below).
At iComply, we want you to know that your privacy is important to us and in order to protect the Personal Data (defined below) of any person who accesses the Channels(the “User”) (a) to obtain information about the Services provided by the Company, or (b) to inquire about the Services, we hereby provide this notice explaining our privacy practices for protecting your Personal Data.
The procedure for handling and securing the User’s information shall be governed in accordance with the terms and conditions of this Policy. We hereby request the User(s) to note the Policy is in accordance with the IT Act 2000, Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011, EU General Data Protection Regulation 2016/679, and all applicable legislation relating to privacy or data protection in other jurisdictions (individually and collectively referred to as the “Regulations”).
The Users are hereby notified that by accessing and using the Channels, you acknowledge that you are well aware of this Policy, have read and understood the terms provided herein and agree to be bound by it. However, if you disagree with these terms, kindly exit the Channel immediately. Your continued access of the Channel shall be considered as an acceptance of the Policy.
II. DEFINITIONS
a) “PERSONAL DATA” shall mean and refer to the information that identifies a specific User, who can be identified, directly or indirectly, in particular by reference, such as name, identification number. location data or to one or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that User. When the User engages in certain activities on the Channels, such as registration on the Channel for the purpose of applying for a job vacancy, subscription to a newsletter, filling out the survey forms or any other forms as available on the Channels, using live chat, creating, maintaining and updating an account or submitting a proposal for availing the Services, posting content as a review, or while enquiring about the Services, we may ask you to provide certain information about yourself. It is optional for you to engage in such activity. If you elect to engage yourself in the activities/services on the Channels, we may ask you to provide us with certain personal information about yourself, such as your first and last name, gender, date of birth, age, profession, pay scale, email address, postal address, amongst other information. Further, in case you intend to avail the Services, we may ask you to provide us with your debit or credit card number, expiration date and authentication codes or banking or wallet related information for the payment purposes. The Personal Data shall also include your user id/log –in and passwords for accessing the Channel. If you choose to not provide your information for a particular activity/service, you will not be permitted to engage in that activity/service.
b) “NON-PERSONAL DATA” shall mean and refer to any other personal information that may be collected by us while your visit to the Channels and includes information about your device, IP address, operating system and browser type for system administration. The Users are advised to note that this is statistical data about the User’s browsing actions and patterns and does not identify any individual. We use such information for the improvement of the Services we offer through the Channels.
c) “COOKIES” refers to other information related to the usage of our Channel by using a cookie file which is stored on your browser or on the hard drive of your device. Cookies contain information that is transferred to your computer’s hard drive, which helps us to improve our site and deliver a better and more personalized experience of the Channel to the Users. Some of the cookies we use are essential for the site to operate. Your continued usage and access of the Channel denotes your consent to our usage of cookies.
III. TERMS AND CONDITIONS
This Policy applies to any User, either a person or any legal entity, who accesses the Channels to gain information about the Services provided by the Company or intends to avail the same. This Policy governs the access, collection, usage, handling, storage and disclosure of such Personal Data in accordance with the terms as given below:
- Collection of Information:
i We may collect the ‘Data’ (including Personal Data and Non-Personal Data) when you access the Channel to gain information regarding the Services provided by the Company, or avail or intend the avail the same. We record your Data in physical and electronic form, and our usage of such data is done in accordance with the Regulations.
ii We may collect your Data when you indulge in activities on the Channel, including but not limited to, create a profile on the Channels, enquire about the Services, avail the Services, use the live chat option, submit content for a review; fill out a form for a survey for other forms as published by the Company on the Channel. When entering the information on the Channels, as appropriate, you may be asked:
a. To enter your name, gender, email address, mailing address, phone number, age, or other details as required to contact you with respect to your appointment with the Company, to respond to your queries, managing our relationships with you, etc.
b. The details regarding the debit or credit card information, expiry date, authentication codes, banking, UPI Id, wallet details or any other information required for the purpose of availing the Services on the Channels.
iii It is optional for you to avail the Services provided by the Company. If you elect to avail the Services through the Channels, we may ask you to provide us with certain Personal Data. If you choose to not provide your information, you may not be permitted to engage in an activity on the Channel or avail the Services and your access to the Channel may become restricted.
iv The User may also from time to time request to update, amend or correct the Personal Data writing to us at info@icomplylifesciences.com, in accordance with Section 6 (c) of this Policy.
v Further, while using the Channel, we may also collect certain Non-Personal Data such as device ID, device make/model, IP address, browser type, operating system, page views, website navigation, timing and frequency of use of the Channels, User preferences etc. for, analytics and research purposes, in order to improve the quality and efficiency of our Channels, and the quality of Services.
vi If you choose not to provide, or object to our processing of the information we collect, we may not be able to process your instructions or continue to provide information to you about our Services. - Usage of Data:
i We process information about you and/or your business to enable us to provide our Services to you and to meet our legal or regulatory obligations.
ii We may use the User’s Data for several purposes including, but not limited to,
a) Registering on the Channel
b) Sending the verification code or OTPs while creating a User profile on the Channels and for confirmation of their transaction.
c) Expeditious Transactions
d) To contact the User for sending them details regarding their appointments and required Services.
e) For sending reminders regarding their appointment.
f) To stay in touch with potential customers after they raise their queries through live chat, emails or phone.
g) To contact the third parties for business purposes
h) To assess and consider a candidate with regards to a current or future job application
i) To improve customer service and experience
j) To send periodic emails regarding the Company, its Services and other related updates
k) To follow up with the Users regarding their queries on the Services
l) For administering contests, promotions, surveys or any other engagement activity.
m) To understand the needs and preferences of the User
n) To protect the User’s profile from any unauthorized access as the messages for every access from an unauthorized device are sent on the registered number as provided by the User.
iii The information collected from the reviews posted by the Users is used by the Company for the purpose of providing the Services to the Users, improving the quality of Services provided by the Company through the feedback and reviews provided by the Users on the Channels and enhancing the User experience.
iv The Personal Data, surveys and reviews submitted by the Users on the Channels helps the Company to identify the User preferences, and accordingly, develop additional services to suit the Users.
v For the purpose of providing the required Services to our Users, we may share your Data with third parties under a confidentiality agreement which inter alia provides that such third parties shall not further disclose the Information to any person, until and unless such disclosure is required for statutory or legal purposes.
vi Further, we may use third-party service providers to monitor and use our website or application to track and report website traffic. The web analytics service provider engaged from time to time may use the collected data to contextualize and personalize the adds of its own advertising network. The privacy and security of your data by these third-party service providers are governed by their respective privacy policy. - Duration of retention of Data
i Your Data shall be retained only for so long as reasonably necessary for the purpose set out in this Policy in accordance with the applicable law, including for the purpose of satisfying any legal, regulatory, accounting or reporting requirements.
ii You may withdraw your consent to submit any or all Personal Data or decline to provide any permissions on the Channels. In case, you choose to do so then your access to the Channels may be limited, and we might not be able to provide the Services to you. You may withdraw your consent by sending an email to us on info@icomplylifesciences.com. - Protection of Data
i Your Data resides on a secure server that only selected personnel of the Company to have access to. Every such personnel is bound by the confidentiality obligations of the Company and accordingly, we use a range of measures to ensure we keep your Data secure, accurate and up to date, by incorporating measures like:
a. educating and training our staff to ensure they are aware of our privacy obligations when handling your Data;
b. administrative and technical controls to restrict access on a ‘need to know’ basis;
c. technological security measures, including firewalls, encryption and anti-virus software.
ii We have implemented and maintain technical, administrative and physical measures that are reasonably designed according to the industry standards in order to protect from unauthorized processing of data, which includes unauthorized access, disclosure, alteration or destruction of the User’s Data.
iii The Channels are scanned on a regular basis for any vulnerabilities in order to make your use as safe as possible
iv Further, the Company shall adopt such other measures as provided under the prevailing laws to protect the Data.
v Under certain circumstances, the Company may be required to disclose your Data by the law enforcement agencies, statutory or government authorities, and the User understands that such disclosure is mandatory; however, the Company shall endeavour to take steps for minimum disclosure.
vi We strongly recommend you do not share your login Id and password (“credentials”) with anyone under any circumstances. Any personnel of the Company would never contact you to provide your credentials; hence you are advised to not entertain such faux calls or messages.
vii Please note that no method of transmission over the Internet or of electronic storage is 100% secure, hence we take no responsibility for any unauthorized disclosure of your Personal Data. - Links and Third Parties
The Channel may contain links to other websites controlled by third parties independent of us and our control whether directly or indirectly. We do not take any responsibility for the privacy practices of such third parties or the contents of their websites or mobile applications. We encourage you to read the privacy statements of such websites before providing any of your personal information to them. We do not take responsibility for the opinions of third parties expressed on or through our Sites. - Your Rights
i As the owner of the Data, you have various rights with respect to your Personal Data, provided as follows:
a. The Right to be Informed
We are obliged to provide you with clear and transparent information about our data processing activities, if such information is required by you (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from where it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences)
b. The Right of access
• You have a right to access your information which provides that you may ask for a copy of your personal information from us and we shall be under the obligation to provide you with the same within the timeframes as provided under the applicable laws.
• If there are exceptional circumstances which prohibit us to provide the information, we will notify you regarding the same, along with the reason for such refusal.
c. The Right of Rectification
When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected. You can amend the information by writing to us at info@icomplylifesciences.com.
d. The Right to Erasure (or the ‘right to be forgotten’)
Where no overriding legal basis or legitimate reason continues to exist for processing the Personal Data, you may request us to delete the Personal Data. We will take all reasonable steps to ensure erasure.
e. The Right to Restrict Processing
You may ask us to stop processing your Personal Data. We will still hold the data, but will not process it any further. This right is an alternative to the right to erasure.
f. The Right to Data Portability
You may request your Personal Data be transferred to another controller or processor, provided in a commonly used and machine-readable format.
g. The Right to Object
You have the right to object to our processing of your data.
ii Please note that you may raise a request for exercising any of the rights as mentioned under this Section by writing to us at info@icomplylifesciences.com.
iii Further, in order to abide by your requests, we will have to identify your identity, post satisfaction of the same we shall process your request within the timelines as per the applicable laws. Further, we reserve the right to deny your request as per the applicable law and shall notify you regarding the same. - Liability and Warranty
i Although we have implemented and employed the necessary internet security methods and technology to secure the information and data transmitted to us, the security of the data transmitted over the internet cannot be absolutely guaranteed; thereby we cannot ensure or warrant the security of any information that you transmit to us. Accordingly, the Users share their Personal Data with us entirely at their own risk. In light of the above, the Company declares as follows:
a. We shall not be held liable for any loss or injury caused to you, as a result, voluntary disclosure of the Personal Data by the User to a third party.
b. Further, notwithstanding anything contained in this Policy, we disclaim all the warranty for any loss, damage or misuse of the Data.
c. We disclaim all the warranty and takes no responsibility and liability for the privacy practices and security of Data collected by the third party website linked to our channel and services that are outside our control. - Data Tracking
Cookies will be used to customize and enhance your experience with the Channels, as they save the User’s time by helping to identify the identity. Cookies also allow the Company to collect Non-Personal Data, for example, the pages you visited and what links you click on. Use of such Non-Personal Data helps us to create a more user-friendly experience for all the Users. Most browsers automatically accept cookies, but you may modify your browser settings to decline cookies, however, declining such settings may make some parts of the Channel inaccessible. - Eligibility
i The User’s access to the Channels shall be blocked in case the User is below 18 years of age. In case we become aware of any User, below 18 years of age, the Company shall take immediate steps to block the access of that User.
ii Please take into consideration that we do not knowingly collect data relating to children, below the age of 18 years. - Disclaimer
We do not collect the Personal Data of any individual except when such an individual voluntarily shares information and data on our Channel. Upon such voluntary disclosure of information and data, we may further verify and collate the information and data from information available in public domain (as permitted by law) in order to prevent cases of identity theft, fraud etc. We may receive your information and data through third-party websites if you are connected to us through those websites and services. - Conditions of Use and Revision of Policy
i This Policy should be at all times read along with the terms and conditions of use issued by the Company on the Channel.
ii The Policy may be updated from time to time at the sole discretion of the Company or on due to changes in the prevailing laws. Unless otherwise specified, such revisions shall take effect from the day and date they are posted on the Channels. You are advised to consult this Policy regularly for any changes, and your continued access and use of the Channel shall be deemed as an acceptance to the changes in the Policy. - Contact Us
The Users are requested to note that in case they face any trouble regarding the Services or wish to report a security breach or have an issue that you are unable to resolve or otherwise require any other assistance with respect to the Channel or this Policy, you may contact our Data Protection Officer at
E-mail: info@icomplylifesciences.com