PeopleMint AI Pvt. Ltd. offers tools and platform commercialised as “HuddleUp” which provide the means to measure and increase employee commitment by giving them a voice within their organization & help in better team collaboration (the “HuddleUp Platform”). PeopleMint AI Pvt. Ltd. understands the importance of protecting Personal Information (as defined below). For this reason, PeopleMint AI Pvt. Ltd. strives to have business procedures and security safeguards in place to protect Personal Information under its control.
- Definition of Personal Information : “Personal Information” is defined as any information about an identifiable individual. This may include, for example, email addresses and contact details and any similar information provided to HuddleUp in the course of its business operations, or which HuddleUp may receive from business inquiries. Personal Information that is aggregated and/or de-identified or that cannot be associated with an identifiable individual is not considered to be Personal Information.
- Collection and Use of Personal Information through the Services : When providing the Services, HuddleUp only processes Personal Information in accordance with the Terms and applicable laws. HuddleUp generally uses Personal Information from or about its Customers and Users for the following purposes:
When possible, HuddleUp will use Personal Information in an aggregated and/or de-identified format.
- to create, establish and administer Customer’s account, to respond to Customer’s inquiries related to its account and to contact Customer about HuddleUp’s Services or account-related matters;
- to provide Services, including to provide Customer and its Users with access and use of the HuddleUp Platform and customer support;
- to manage and develop HuddleUp’s business and operations;
- to measure and analyze User behavior;
- to monitor, maintain and improve HuddleUp’s Services or features;
- to understand how Users interact with HuddleUp and ensure our services, products or features work correctly;
- to develop new services, products, features, programs and promotions;
- to meet legal and regulatory requirements and to allow HuddleUp to meet contractual requirements relating to the Services provided to Customer;
- to conduct surveys on the quality of HuddleUp’s Services or to collect feedbacks on the Services;
- to provide Customer with offers for additional services, features and products that HuddleUp believes may be of interest to Customer;
- to conduct market or benchmarking research and data analytics by tracking and analyzing current or previously collected Personal Information.
Unless required or authorized by law, HuddleUp will not use Personal Information for any other or new purpose without obtaining prior consent.
- Collection and Use of Personal Information through the Website : HuddleUp generally collects and uses Personal Information from or about its website Users as follows:
- Information Provided by Users. In many cases, HuddleUp collects Personal Information directly from Users when they visit or use the website. For instance, HuddleUp may collect the following types of information:
- Inquiries and Requests for a Trial or Service. HuddleUp may collect Users’ name, contact information, email address and any other information provided when Users make an inquiry or contact HuddleUp through the website, when Users sign up to receive HuddleUp’s newsletter or when Users submit a request or an order for an HuddleUp trial or service.
- Personalization of Website. When Users visit the website, they may, from time to time, be invited to provide information such as User’s title to help HuddleUp personalize or customize the Users experience when using the website.
- Technical Information. When Users visit the website, HuddleUp may collect, using electronic means such as cookies, technical information. This information may include information about visits to the website, including the IP address of the Users’ computer and which browser was used to view the website, the Users’ operating system, resolution of screen, location, language settings in browsers, the site the User came from, keywords searched (if arriving from a search engine), the number of page views, information entered, advertisements seen, etc. This data is used to measure and improve the effectiveness of the website or enhance the experience for Users. While most of the time this information is depersonalized, if this information relates to an identifiable individual, HuddleUp will treat this information as Personal Information. HuddleUp may also, without limitations, collect and use the following type of information when Users visit and/or interact with HuddleUp on the website:
- Google Analytics: HuddleUp uses Google Analytics which allows it to see information on User website activities including, but not limited to, page views, source and time spent on our website. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. Users may opt-out of HuddleUp’s use of Google Analytics by visiting the Google Analytics opt-out page.
- Google AdWords: HuddleUp uses Google AdWords Remarketing to advertise HuddleUp across the Internet and to advertise on third party websites (including Google) to previous visitors of the website. AdWords remarketing will display ads to Users based on what parts of the HuddleUp website they have viewed by placing a cookie on the Users’ web browser. It could mean that HuddleUp advertises to previous visitors who haven’t completed a task on the site or this could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. This cookie does not in any way identify the User or give access to the Users’ computer or mobile device. The cookie is only used to indicate to other websites that the User has visited a particular page on the website, so that they may show the User ads relating to that page. If Users do not wish to participate in Google AdWords Remarketing, they can opt out by visiting Google’s Ads Preferences Manager.
- Personal Information from Other Sources. HuddleUp may obtain from third parties additional Personal Information about a website User if such User gave permission to those third parties to share its information.
- Sharing of Personal Information : HuddleUp will not sell, rent or trade Personal Information to any third party. However, HuddleUp may share Personal Information when authorized and/or required by law or as follows:
- As Permitted or Required by Law. HuddleUp may disclose Personal Information as required by applicable law or by proper legal or governmental authority. HuddleUp may also disclose information to its accountants, auditors, agents and lawyers in connection with the enforcement or protection of its legal rights. HuddleUp may also release certain Personal Information when it has reasonable grounds to believe that such release is reasonably necessary to protect the rights, property or safety of others and itself, in accordance with or as authorized by law. In the event HuddleUp receives a governmental or other regulatory request for any Personal Information, HuddleUp will promptly notify Customer, unless it is prohibited to do so, in order that Customer shall have the option to defend such action. HuddleUp shall reasonably cooperate with Customer in such defense.
- Business Transaction. HuddleUp may disclose Personal Information to a third party in connection with a sale or transfer of business or assets, an amalgamation, reorganization or financing of parts of our business. However, in the event the transaction is completed, Personal Information will remain protected by applicable data protection laws. In the event the transaction is not completed, HuddleUp will require the other party not to use or disclose the Personal Information received in any manner whatsoever and to delete such Personal Information.
- Security of Personal Information : HuddleUp will store and process the Personal Information in a manner consistent with industry security standards, and as long as necessary for the purposes described in this Policy, unless a longer retention is required by law. HuddleUp has implemented technical, organizational and administrative systems, policies, and procedures to help ensure the security, integrity and confidentiality of Personal Information and to mitigate the risk of unauthorized access to or use of Personal Information, including: (i) appropriate administrative, technical and physical safeguards and other security measures designed to ensure the security and confidentiality of the Personal Information it manages; (ii) a security design intended to prevent any compromise of its own information systems, computer networks or data files by unauthorized Users, viruses or malicious computer programs; (iii) appropriate internal practices including, but not limited to, encryption of data in transit; using appropriate firewall and antivirus software; maintaining these countermeasures, operating systems and other applications with appropriate reasonable up-to-date virus definitions and security patches so as to avoid any adverse impact to the Personal Information that it manages; (iv) appropriate logging and alerts to monitor access controls and to assure data integrity and confidentiality; and (v) permitting only authorized Users access to systems and applications, and all persons with authorized access to Personal Information must have a genuine business need-to-know prior to access (together, “Security Program”).
- Fulfil data request, modification, and deletion : If you are an EU citizen and use our Services, then you have specific rights to your data. This relates to GDPR Chapter 3—Right of the data subject. You can request to receive your data, modify it, and/or delete it. If you want to delete or modify your data please contact your HuddleUpAdministrator first. Your Administrator will then contact us to fulfill your data request. If you cannot contact your Administrator or they will not fulfill your needs, please contact us at [email protected] If you are not an EU citizen and would like to request to modify or delete your data, please contact us, we will pass your request to your Administrator.
- Training and Supervision : HuddleUp maintains adequate training programs to ensure that its employees and any others acting on its behalf are aware of and adhere to its Security Program. HuddleUp shall exercise necessary and appropriate supervision over its relevant employees to maintain appropriate confidentiality and security of the Personal Information it manages.
- Data Incidents Involving Personal Information : HuddleUp shall promptly notify Customer of a data breach, of a loss of data or of a failure of HuddleUp’s Security Program:
(a) which has resulted or is suspected to have resulted in the loss, unauthorised access, disclosure, use or acquisition of Personal Information (including hard copy records); and
(b) which, in HuddleUp’s opinion, presents a real risk of significant harm to individuals whose Personal Information is impacted (“Data Incident”).
While the initial notice may be in a summary form, a comprehensive written notice shall be given to Customer within the legally required timeframe, where applicable. The notice shall summarize in reasonable detail the nature and scope of the Data Incident (including each data element type) and the corrective action taken or to be taken by HuddleUp. HuddleUp shall promptly take all necessary and advisable corrective actions, and shall cooperate with Customer in all reasonable efforts to mitigate the adverse effects of Data Incidents and to prevent their recurrence.
- How to Contact Us : Any questions or complaints or requests regarding this Policy or HuddleUp handling of Personal Information can be addressed by sending an email to [email protected]