Applicant/Employee Privacy Notice

Scope and Overview

This Privacy Notice describes how Juniper Square, Inc. and its subsidiaries, affiliates, and related entities (collectively, "Juniper Square," "we," "us," or “our”) collect and process personal data regarding all job applicants and employees of Juniper Square.  The “controller” of your personal data (or comparable role as recognized under applicable law, such as “fiduciary”) will be the entity with which you have applied for a job or are employed by, but your data may be shared with other Juniper Square entities in accordance with this Privacy Notice. 

This Privacy Notice describes the categories of personal data that we collect, how we use your personal data, how we secure your personal data, when we may disclose your personal data to third parties, and when we may transfer your personal data outside of your home jurisdiction. This Privacy Notice also describes your rights regarding the personal data that we hold about you including how you can access, correct, and request erasure of your personal data.

We will only process your personal data in accordance with this Privacy Notice unless otherwise required by applicable law. We take steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.

For the purposes of this Privacy Notice, personal data means any information about an identifiable individual. To the extent permitted by applicable law, personal data excludes anonymous data that is not associated with a particular individual.

The personal data [listed in this notice/identified below with an (*)] is mandatory in connection with our recruiting activities and employment relationships. Failure to provide or allow us to process mandatory personal data may affect our ability to accomplish the purposes stated in this Privacy Notice. 

This Privacy Notice is accompanied by Schedules for specific jurisdictions.  If you are based in one of these jurisdictions, then this Privacy Notice should be read and interpreted in accordance with that Schedule. 

For Job Applicants

Collection and Use of Personal Data

Juniper Square may collect personal data directly from you, as a job applicant, or may receive personal data from third parties, for example, in connection with a background, employment, or reference check, subject to your consent where required by applicable law. Juniper Square may also collect personal data from recruitment consultants/agencies and from publicly available online resources. 

We only process your personal data where applicable law permits or requires it in connection with carrying out our application and recruitment process, to take steps necessary to enter into an employment contract with you, where the processing is necessary to comply with a legal obligation that applies to us, for our legitimate interests or the legitimate interests of third parties (where recognized under applicable law), or with your consent if applicable law requires consent.  Examples of our legitimate interests include: 

• To ensure we engage appropriate staff and monitor the effectiveness of our recruitment process. 
• To prevent fraud.
• To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution.

In addition to using your personal data for the position for which you have applied, we may retain and use your personal data to inform you about and consider you for other positions that may be appropriate for you with your consent. If you want us to consider you for other positions, you may reach out to your recruitment contact, and we will retain your personal data for that purpose. You may ask us to delete your personal data at any time (for more information on your rights, see below). 

We will only process your personal data for the purposes we collected it for or for “compatible” or “consistent” purposes (as interpreted in accordance with applicable law). If we need to process your personal data for another purpose, we will provide notice to you and, if required by law, seek your consent. We may process your personal data without your knowledge or consent only where permitted or required by applicable law.

Categories of Personal Data and Processing Purposes 

The information below identifies: 

• What personal data we process about you;
• Our processing purposes; and 
• The lawful basis for processing your personal data.

1. Contact Information

• Name.*
• Address.*
• Email address.*
• Phone number.*

2. Personal Information

• Date of birth.* (only collected in background check process)
• Gender.* (only collected in background check process)
• Marital or relationship status.* (only collected in onboarding process)
• Personal information contained in your CV, cover letter, or application form.*

3. Identity and Background Information

• Details of education, academic and professional qualifications, and results.*
• Career history, experience, and skills.*
• Passport or other identification information.
• Residency, right to work, or other visa information (where unrelated to your race or ethnicity).*
• CV and professional profile.*
• Application form.*
• Evaluative notes and decisions from phone screenings and interviews.*
• Salary preferences, willingness to relocate, job preferences, and other information relating to compensation and benefits.*
• Details regarding a referring party.*
• Information obtained about you from previous employers, education providers, or referring parties, for example in references provided to us.

4. Financial Information* (only collected in onboarding process)

• Bank account details.
• Salary, compensation, and other remuneration information.
• Any specific and relevant government identification numbers.

5. Employment Administration Information*

• Terms and conditions of employment.
• Your working preferences.
• Your preferences in relation to our use of your personal data.

6. Travel and Expenses Information

• Visa, passport, and insurance details.
• Flight and accommodation booking information.
• Travel itinerary information.
• Driving License or other relevant government documents* [as part of the post-offer onboarding process].

7. Security and Access Control Data

• Personal data, including image, captured or recorded by electronic card access systems, CCTV, and other security control systems.

Collection and Use of Special Categories of Personal Data

The following special categories of personal data are considered sensitive under the laws of several jurisdictions and may receive special protection.  In addition to identifying a lawful basis, we must also identify an additional “special category basis” for processing such personal data. We may collect and process the following special categories of personal data when you voluntarily provide them, or if we receive them from a third party: (i) with your consent; (ii) when relevant for a particular position to carry out our obligations under employment law; or (iii) as applicable law otherwise permits:

• Racial or ethnic origin (optional but where provided, processed as necessary under Equal Employment Opportunity Laws).
• Physical or mental health condition or disability status to determine appropriate workplace accommodations and evaluate fitness for a particular position.
• Data concerning sexual orientation or gender identity (optional but where provided, processed as necessary under Equal Employment Opportunity Laws).

We may process the following categories of special category personal data in the recruitment process for the following reasons: 

1. Racial or Ethnic Origin 

• Racial or ethnic origin, including nationality and visa information.

2. Data Concerning Health

• Health data from pre-employment medical assessment (if necessary).

We may also collect and process personal data relating to criminal convictions and offences and/or information about your financial circumstances, where relevant for the role. This information is obtained from pre-employment checks and is only processed where permitted under, and in accordance with, applicable law.  We implement appropriate safeguards in relation to such personal data.

For Employees

Collection and Use of Personal Data

In addition to the above processing, in order to carry out our activities and obligations as an employer, we will collect, store, and process additional categories of information from successful applicants who become employees. 

We only process your personal data where applicable law permits or requires it, including where the processing is necessary for the performance of our employment contract with you, where the processing is necessary to comply with a legal obligation that applies to us as your employer, for our legitimate interests or the legitimate interests of third parties (where recognized under applicable law), to protect your vital interests, or with your consent if applicable law requires consent. Examples of our legitimate interests are set out in more detail below. 

The majority of the personal data that we process will be collected directly from you or generated in the course of your employment. In limited circumstances third parties may provide your personal data to us, such as former employers, listed references, official bodies (such as regulators or criminal record bureaus), and/or other sources.

We will only process your personal data for the purposes we collected it for or for “compatible” or “consistent” purposes (as interpreted in accordance with applicable law). If we need to process your personal data for another purpose, we will provide notice to you and, if required by law, seek your consent. We may process your personal data without your knowledge or consent where permitted or required by applicable law.

Categories of Personal Data and Processing Purposes

The information below identifies: 

• What personal data we process about you;
• Our processing purposes; and 
• The lawful basis for processing your personal data.

1. Personal and Identity Information

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.*
• Government identification numbers such as social insurance or other national insurance number, driver's license number, or other identification card number.*
• Date of birth.*
• Gender.*
• Photograph.*

2. Benefit and Expenses Information

• Bank account details and payroll information.*
• Wage and benefit information. *
• Compensation history .
• Expenses submitted.
• Insurance enrollment information.* (not for countries where we have Employers of Record to manage payroll and benefits) 
• Marital* and dependent status (only when needed to administer benefits such as health insurance or pension benefits).
• Beneficiary (when needed to administer benefits) and emergency contact information.*

3. Employment Administration Information 

• Start date and job title.*
• Location of employment.*
• Education and training.*
• Performance information. (not during onboarding)
• Employment records (including professional memberships, references, work history, and proof of work eligibility).*
• Other personal details included in a CV, resume, application form, or cover letter or that you otherwise voluntarily provide to us.*
• Your use of company IT systems. 

4. Security and Access Control Data

• Personal data, including image, captured or recorded by electronic card access systems, CCTV, and other security control systems.

It is not possible to list all processing activities that will be undertaken in the employment context in a Privacy Notice.  For more information about the specific lawful basis relied upon for any particular processing that we are undertaking, please contact privacy@junipersquare.com. 

Collection and Use of Special Categories of Personal Data

The following special categories of personal data are considered sensitive under the laws of your jurisdiction and may receive special protection. In addition to identifying a lawful basis, we must also identify an additional “special category basis” for processing such personal data:

• Racial or ethnic origin.
• Biometric data. (only as necessary for unlocking devices under security purposes)
• Data concerning health.
• Data concerning sexual orientation or gender identity. (not in employment systems, optional for Employee Resource Groups)

Data relating to criminal convictions and offences may also receive special protection under the laws of your jurisdiction (i.e. we may be prohibited from refusing to discriminate where the criminal conviction is unrelated to your employment or prospective position – for more information, please contact us).

We may collect and process the following special categories of personal data when you voluntarily provide them: (i) with your consent; (ii) to carry out our obligations under employment law; or (iii) or as applicable law otherwise permits:

• Trade union membership information for the purpose of paying trade union premiums.
• Physical or mental health information or disability status to comply with health and safety obligations in the workplace, to make appropriate workplace accommodations, as part of sickness absence monitoring, and to administer benefits.
• Race or ethnic origin, religious affiliation, health information, sexual orientation, and/or gender identity to ensure meaningful equal opportunity monitoring and reporting.

We will always treat special categories of personal data as confidential, and we will only share such data internally where there is a specific and legitimate purpose for sharing the data. As set out below, we have implemented appropriate physical, technical, and organizational security measures designed to secure your personal data against accidental loss and unauthorized access, use, alteration, or disclosure.

We will only retain special categories of personal data for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. For more information about specific retention periods, please see our retention policy. 

Applicable To All Parties

Data Sharing

We will only disclose your personal data to third parties where permitted or required by law, or to third-party service providers who require such information to assist us with administering the employment relationship with you, including third-party service providers who provide services to us or on our behalf. Third-party service providers may include, but are not limited to, payroll processors, benefits administration providers, data storage, or hosting providers. These third-party service providers may be located outside of your home jurisdiction. 

We require all our third-party service providers, by written contract, to implement appropriate security measures to protect your personal data. We do not permit our third-party service providers who process your personal data on our behalf to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes in accordance with our instructions.

We may also disclose your personal data for the following purposes, where permitted or required by applicable law:

• To other members of our group of companies (including affiliates and subsidiaries outside of your home jurisdiction) for the purposes set out in this Privacy Notice and as necessary to perform our employment contract with you and in our legitimate interest of administering our global workforce.
• As part of our regular reporting activities to other members of our group of companies.
• To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal data to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal data necessary for the specific purpose and circumstances.  We may also disclose your personal data in circumstances where we are not legally obligated to, but it is in our legitimate interest to do so (i.e. in cooperating with an investigation) – before doing so, we will balance your rights and freedoms against our legitimate interest. 
• To protect the rights and property of Juniper Square.
• During emergency situations or where necessary to protect the safety of persons.
• Where the personal data is publicly available (as permitted by applicable law).
• If a business transfer or change in ownership occurs and the disclosure is necessary to progress or complete the transaction (i.e. for due diligence). In these circumstances, we will limit data sharing to what is absolutely necessary, and we will anonymize the data where possible. Where it is not possible to anonymize the data, we may be required by applicable law to notify you of the disclosure.  Further, if the business of Juniper Square is sold or otherwise restructured, your personal data may be one of the assets that is transferred.
• For additional purposes (with your consent where such consent is required by law).

Cross-Border Data Transfers

Where permitted by applicable law, we may transfer the personal data we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country for the purposes set out in this Privacy Notice. Your information may be subject to the local laws of the jurisdiction to which it is transferred, and it may be accessible to local governments, tribunals, law enforcement and regulatory agencies (if permitted under applicable law).

In order to protect and safeguard any international data transfers between Juniper Square entities, affiliates, and sub-processors, we will utilize model clauses (such as the European Union’s Standard Contractual Clauses (EU SCCs) as approved by the European Commission in (EU 2021/914) where appropriate. Regardless of where you are from, we will ensure that all international data transfers involving personal information are adequately safeguarded as required by applicable law. 

Data Security

We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal data against accidental loss and unauthorized access, use, alteration, or disclosure. These measures include, but are not limited to the following: security policies, security controls testing, access controls, change controls, business continuity measures, data security measures, encryption and key management, administrative controls, vulnerability testing, and routine security patches. In addition, we limit access to personal data to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.

Data Retention

Except as otherwise permitted or required by applicable law, we will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for personal data, we consider applicable legal requirements, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes we process your personal data for, and whether we can achieve those purposes through other means. We specify the retention periods for your personal data in our data retention policy, a copy of which is available to employees.  Once you are no longer an employee of the company, we will retain and securely destroy your personal data in accordance with our document retention policy and applicable laws and regulations.

Under some circumstances we may anonymize your personal data so that it can no longer be associated with you. We reserve the right to use such anonymous data for any purpose without further notice to you or your consent. 

Rights of Access, Correction, Erasure, and Objection

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your employment, or the recruitment process. By law you may have the right to request to access, correct, and erase the personal data that we hold about you, or object to the processing of your personal data under certain circumstances. You may also have the right to request that we transfer your personal data to another party. If you want to review, verify, correct, or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact us by using the Privacy Request Center.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal data that we hold about you, or we may have destroyed, erased, or anonymized your personal data in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal data, we will inform you of the reasons why, subject to any restrictions under applicable law.

Right to Withdraw Consent

Where you have provided your consent to the collection, processing, and/or transfer of your personal data, you have the right to withdraw your consent. If you decide to withdraw your consent, we will stop processing your personal data for that purpose unless we identify an alternative legal basis. To withdraw your consent visit  the Privacy Request Center. 

Data Protection Officer

Our Luxembourg subsidiary, Juniper Square Luxembourg S.à r.l., has appointed a Data Protection Officer to oversee compliance with this Privacy Notice and other Privacy issues in Luxembourg. If you are an EU/EEA resident and have any questions about this Privacy Notice or how we handle your Personal Information, or would like to file a complaint, please contact the Data Protection Officer at: DPO@junipersquare.com. 

Complaints 

You may also have the right to make a complaint with the data protection authority in your jurisdiction by contacting the data protection authority.

Changes to This Privacy Notice

We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any updates. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent only where required or permitted by applicable law or regulation.

Contact Us

If you have any questions about our processing of your personal data or would like to make an access or other request, please contact us through  the Privacy Request CenterIf you are unsatisfied with our response to any issues that you raise, you may have the right to make a complaint with the data protection authority in your jurisdiction by contacting the data protection authority.

We have appointed Juniper Square Luxembourg S.à r.l. as our EU representative to help ensure our compliance with applicable law. Please direct any questions relating to our processing of your personal data to our EU representative at: DPO@junipersquare.com.

Use of Artificial Intelligence in Recruitment and Employment Decisions

Overview

Juniper Square uses artificial intelligence (“AI”) tools and systems at various stages of our recruitment and employment processes. This section describes how we use AI in connection with your personal data, the safeguards we apply, and the rights available to you.

For the purposes of this section, “AI” includes: generative AI tools accessible through Juniper Square’s internal systems (including AI-assisted drafting and summarization tools); automated screening, scoring, or matching features in our applicant tracking system or other HR software; video interview assessment tools; and any other automated system that generates recommendations, summaries, scores, or other outputs based on your personal data.

How We Use AI

We may use AI tools to assist with certain activities including but not limited to the following: 

For job applicants:

• Drafting and refining job descriptions, structured interview question sets, and candidate outreach communications.
• Summarizing interview notes and evaluator observations prepared by Juniper Square personnel.
• Identifying themes or patterns across application materials to support (but not replace) human review.
• Processing system-generated screening scores or candidate match recommendations produced by our applicant tracking system.
• Administering AI-assisted skills assessments and reviewing AI-generated flags from proctored assessment sessions, where used in connection with a specific role. 

For employees:

• Drafting performance review language and development goals based on notes and input provided by managers.
• Identifying themes across feedback materials and self-assessments to support (but not replace) human-led performance discussions.
• Summarizing documents relevant to compensation benchmarking or internal promotion committee discussions.
• Supporting HR administrative tasks such as drafting template communications and internal HR documentation.

Human Decision-Making

All decisions that affect your application, employment, compensation, performance evaluation, or employment status are made by a human being. AI tools do not play a significant role in evaluating your application. AI tools are used only to assist Juniper Square personnel in carrying out their responsibilities not to make, finalize, or as a substitute for human judgment.

AI-generated outputs (including scores, summaries, rankings, or recommendations) are reviewed, and where appropriate adjusted or disregarded, by a Juniper Square employee before they are used in connection with any decision that affects you. You will not be subject to a decision solely on the basis of automated processing of your personal data, unless and except where such processing is necessary for entering into or performing a contract with you, is permitted by applicable law with appropriate safeguards in place, or is based on your explicit consent.

Sensitive Personal Data

We do not use special categories of personal data,  including data relating to racial or ethnic origin, health or disability status, religious beliefs, biometric characteristics, behavioral assessment results, or neural data as inputs to any AI system, prompt, or automated tool, except as specifically described elsewhere in this Privacy Notice, where required by applicable law, or with your explicit consent. Where sensitive personal data is inadvertently submitted to an AI tool, we will take steps to delete and remediate such data 

Notification of AI Use

Where Juniper Square uses an AI tool that evaluates or generates output about you in connection with a hiring, performance, or employment decision, we will take reasonable steps to inform you of that use, including through this Privacy Notice. Where required by applicable law, we will provide you with specific notice at or before the time of that use.

AI-Proctored Skill Assessments

For certain roles, Juniper Square may use an AI-assisted proctoring tool during skills assessments administered as part of the application process. Where we do so, the tool may collect keystroke dynamics, mouse movement patterns, screen activity, browser activity logs, and, where a webcam component is enabled, video footage recorded during your assessment session. This data is used solely to verify the integrity of the assessment. It is not used to infer your emotional state, personality, or any characteristics unrelated to the specific skills being assessed.

Any anomaly or flag generated by the proctoring tool will be reviewed by a Juniper Square employee before it is used in connection with any hiring decision. You will not be disqualified solely on the basis of an AI-generated flag.

We do not collect biometric identifiers or biometric information directly.  Where we leverage third-party applications for interview proctoring tools or meeting note-takers, the third-party will not create a unique voiceprint without your explicit consent. 

If you have a disability or other condition that may affect your ability to complete an assessment under standard proctored conditions, please contact us before the assessment is administered. We will work with you to arrange an appropriate accommodation, which may include an alternative assessment format that does not involve AI proctoring.

Your Rights in Connection with AI-Assisted Processing

In addition to your general rights described in the “Rights of Access, Correction, Erasure, and Objection” section of this Privacy Notice, you have the following rights where applicable law recognizes them:

Right to an explanation. If you believe that an AI tool contributed to a decision that significantly affected your application outcome, employment status, compensation, or performance evaluation, you have the right to request a meaningful explanation of how that AI was used and the basis for any output it generated. This right applies where AI materially contributed to the outcome, regardless of whether the final decision was made by a human. This right is recognized under EU AI Act Article 86 and applicable California law.

Right to human review. You have the right to request that a named Juniper Square employee independently review a decision that you believe was materially influenced by AI, without reliance on the AI’s output. We will inform you of the outcome of that review. This right is recognized under EU AI Act Articles 14 and 26.

Right to object. To the extent that any AI-assisted processing constitutes profiling or automated decision-making subject to applicable data protection law (including Article 22 of the EU General Data Protection Regulation), you have the right to object to such processing. We will assess your objection and respond in accordance with applicable law.

Right to withdraw consent. Where our use of AI in connection with your personal data is based on your consent, you may withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out prior to withdrawal.

To exercise any of the rights described in this section, please contact us through the Privacy Request Center.

Processing Purposes and Lawful Basis

The table below sets out the specific processing activities carried out using AI tools, the purposes for which we process your personal data in connection with such activities, and the lawful basis for that processing.

Data Retention

Any automatically generated system logs of AI systems used in connection with your application or employment, under our control, will be retained for at least six months, or a longer  period if appropriate to the intended purpose of the AI system used. Retention periods may be longer where required by applicable law. All records are subject to our general data retention and security policies.

Questions About Our Use of AI

If you have any questions about how we use AI in connection with your personal data, or wish to exercise any of the rights described in this section, please contact us through the Privacy Request Center or by emailing privacy@junipersquare.com. If you are an EU/EEA resident, you may also contact our Data Protection Officer at DPO@junipersquare.com.

Schedule A – Canada 

This Schedule A applies to applicants and employees in Canada and serves to amend and supplement the relevant parts of the Privacy Notice as referred to in this Schedule A.  In the event that any provisions of this Schedule A conflict with the provisions of the Privacy Notice, the terms of this Schedule A shall prevail.

Personal Data Collected 

We will never process your Canadian social insurance number for any purpose other than as specifically contemplated in statute (namely, tax administration).  In particular, you will not be asked to provide such number in order to verify your identity. 

Lawful Bases for Processing 

The processing of personal data under applicable data protection law in Canada is largely done on the basis of “consent” which, unlike applicable data protection law in other jurisdictions, can be “implied consent”.  Implied consent applies where data subjects are informed as to how their data will be used and for what purposes (i.e. in this Privacy Notice) and they do not object to such use. 

Where you are based in Canada, we will therefore process your personal data on the basis of your consent (or an exception to consent – as outlined below), which may include your implied consent. This will replace the references to lawful bases for processing discussed in this Privacy Notice. 

Express Consent and Sensitive Personal Data

Express consent is only required for more sensitive categories of personal data and for specific processing purposes. “Sensitive” personal data is not defined by reference to specific categories under applicable data protection law in Canada and is instead determined contextually on a case-by-case basis. 

In addition to those processing activities that refer to Explicit Consent under the “Collection and Use of Special Categories of Personal Data” section above, we will only undertake background checks after obtaining your express consent. 

Exemptions for Employment Relationship

We may also rely on exceptions to consent requirements (both implied and express), where such exceptions permit the collection, use and disclosure of personal data without consent where necessary to establish, administer or terminate an employment relationship.  For example, we will only process your residency, right to work, or other visa information where it is required to establish the employment relationship.

Your Data Subject Rights 

Individuals employed in British Columbia have the right to access and correct their personal data and/or withdraw their consent for processing.  Individuals in other parts of Canada may also have the right to erase their personal data, object to its processing, or request it is transferred to a third party (“portability”). For more information, or to exercise any of your rights, please contact us  through the Privacy Request Center

Schedule B – India 

This Schedule B applies to applicants and employees in India and serves to amend and supplement the relevant parts of the Privacy Notice as referred to in this Schedule B.  In the event that any provisions of this Schedule B conflict with the provisions of the Privacy Notice, the terms of this Schedule B shall prevail.

Grievance Officer 

Please note that Dan Rothenberg (privacy@junipersquare.com) has been appointed as the “Grievance Officer” under applicable data protection law in India. Grievances will be responded to within one month (unless an exemption applies).  

Local Language Version 

If you would like to receive a copy of this Privacy Notice in another language, please contact the Grievance Officer.  In the event of any discrepancy or conflict between the English version of the Privacy Notice and versions of the Privacy Notice in other languages, the English version will prevail.

Lawful Bases for Processing 

The processing of personal data under applicable data protection law in India is largely done on the basis of “consent” which, unlike applicable data protection law in other jurisdictions, can be obtained where data subjects are informed as to how their data will be used and for what purposes (e.g., in this Privacy Notice). 

Where you are based in India, we will therefore process your personal data for the specific processing purposes listed in this Privacy Notice on the basis of your consent (as indicated by your provision of the personal data to us) or an exception to consent – as outlined below. This will replace the references to lawful bases for processing discussed in this Privacy Notice. 

Exemptions in Certain Circumstances

For some processing, we do not need consent as the processing is undertaken for employment purposes as permitted under applicable data protection law. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

Data Subject Rights

In addition to your rights to access, correct, update and erase your information described above, Indian data subjects have the right to nominate any other individual to exercise your rights, in the event of death or incapacity.