1 Privacy Statement INDEX
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1 INDEX 1 Privacy Statement Mphasis is committed to protecting the personal information of its customers, employees, suppliers, contractors and business associates. Personal information includes data related to a person who can be identified or located by that data. In order to create an environment of trust and to comply with applicable local law, Mphasis has established privacy policies and data protection procedures in processes and services that involve collection, processing, storage or transmission of any personal information. As part of this fundamental obligation, Mphasis is committed to protecting personal information that has been collected through its website(s). Our intent is to collect personal information that is provided voluntarily by you, so that we can offer you information and/ or services with requested by you. Please read this Online Privacy Statement ("Online Privacy Statement" or "Privacy Statement") to learn more about how we collect, use, share, transfer and protect the personal information that we have received. Management Commitment Mphasis demonstrates commitment to maintain data privacy by establishing ownership and accountability with senior management for supervision, communication, implementation and operations of Data Privacy Policies and Procedures. Mphasis management shall also take reasonable efforts to protect the personal information of its past, present or prospective employees, customers, suppliers, contractors and/ or business associates. Notice Mphasis provides notice to the individual(s) regarding intent of the personal information collected and used. Mphasis shall not collect personal information from any provider or person unless consented to and/ or is required and permitted under a lawful contract. Mphasis does not sell, rent or lease personal information received from any provider or person unless permitted through a lawful contract. Choice and Consent INTERNAL 1
2 Mphasis presents individual(s) with choices regarding the use of personal information obtained from our website. In general, an individual may be required to submit personal information in certain system(s), application(s) and websites of Mphasis in order process or communicate key employment related services or events. Permission for certain uses of personal information may be requested with an option or choice to agree or decline those uses. Collection, use and retention of personal information By registering and/ or submitting personal information on Mphasis system, application or website, you agree to the use of this information in accordance with the Privacy Statement. Personal information shall not be used for other purposes, unless an explicit permission has been received, or unless otherwise required or permitted by law or professional standards. For example, if you raise a travel request, Mphasis will use the personal information to respond and process the request. Mphasis only collects "sensitive" personal information when the individuals voluntarily provides this information or where such information is required or permitted to be collected by law or professional standards. Sensitive information includes personal information regarding a person s race, ethnicity, political beliefs, trade union membership, religious or similar beliefs, physical or mental health, sexual life or criminal record. Individual(s) should use their discretion when providing sensitive information to Mphasis. If you have any questions about whether the provision of sensitive information to Mphasis is, or may be, necessary or appropriate for particular purposes, please contact Mphasis at Privacy@mphasis.com. Automatic collection of personal information In some instances, Mphasis automatically collects certain types of information through the website or exchanges. Automated technologies may include the use of web server logs to collect IP addresses, "cookies", and web beacons. The collection of this information will allow Mphasis to understand and improve performance, usability and effectiveness of Mphasis website(s) and to measure effectiveness of our marketing activities. IP addresses INTERNAL 2
3 An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognize and communicate with one another. IP addresses may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct website trend and performance analysis. Cookies A "cookie is a small piece of text that a website places in the cookie file of your browser and that allows the site to remember who you are. Cookies cannot be used to run programs or deliver viruses to your computer. Mphasis only uses cookies in accordance with applicable laws. Cookies by themselves do not provide address or otherwise identify an individual browsing through the website. The choice of deciding whether to accept or refuse cookies will be the responsibility of the individual. The browser can be set to reject cookies or notify presence of cookies. Note: Mphasis website may not function at desired efficiency levels or fully experience some of the website features if the cookie is disabled or refused. Web beacons A web beacon is a small image file on a web page that can be used to collect certain information from an individual s computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. Mphasis only uses web beacons in accordance with applicable laws. Mphasis or its service providers may use web beacons to track the effectiveness of third party web sites that provide Mphasis with recruitment or marketing services or to gather aggregate visitor statistics and manage cookies. An individual have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded. INTERNAL 3
4 In some of our newsletters and other communications, we may confirm a recipient s address through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences. Quality Mphasis endeavors to maintain accurate, complete and relevant personal information for the purposes identified in the notice. Access If an individual has submitted personal information to Mphasis, under any circumstances, the individual has the right to access the data to correct any inaccuracies. An individual can also make a request to update or remove information by contacting Privacy@mphasis.com. Mphasis shall make all reasonable and practical efforts to comply with the request, so long as it is consistent with applicable law and professional standards. Security for privacy Mphasis has Information Security related policies and procedures in place. This will be applied to protect personal information from unauthorized loss, misuse, alteration, destruction, disclosure or unauthorized access. Despite, Mphasis efforts, security cannot be absolutely guaranteed against all threats. To the best of Mphasis ability, access to personal information shall be limited to those on need to know basis. Those individuals who have access to the data are required to maintain the confidentiality of such information. Mphasis also makes reasonable efforts to retain personal information only for so long as the information is necessary to comply with an individual s request or until that person asks that the information be deleted. Where necessary or appropriate, Mphasis shall consider implementing additional measures for particular types of personal information that needs to be handled with additional care, to respect local laws or regulations. Disclosure to third parties and onward transfer Mphasis does not share personal information with unaffiliated third parties, except as necessary for legitimate professional and business needs, to carry out requests, and/ or as required or permitted by law or professional standards. In some instances, Mphasis may also share personal information with various outside companies or service providers or vendors working on behalf of Mphasis. INTERNAL 4
5 In addition, Mphasis may transfer certain personal information across geographical borders to other Mphasis entities/ subsidiaries or outside companies working on behalf of Mphasis. Mphasis may also store personal information in a jurisdiction other than where the individual is based. By providing personal information on Mphasis website, visitors and individuals are consenting to this transfer and/ or storage of their data across borders. Mphasis may also disclose personal information in connection with the sale, assignment, or other transfer of the business of the site to which the data relates, in order to respond to requests of government or law enforcement agencies or where this is required by applicable laws, court orders, or government regulations. These disclosures may also be needed for data privacy or security audits and/ or to investigate or respond to a complaint or security threat. Mphasis does not sell personal information to any third parties. Also, Mphasis will not transfer the personal information you provide to any third parties for their own direct marketing use. 1. Where a third party processes personal information on behalf of Mphasis, Mphasis ensures that the third party is under an obligation: a. Not to process or transfer the personal information except pursuant to instructions from Mphasis (which shall take the form of a written agreement); and b. Mphasis takes appropriate measures to protect the personal information to an extent substantially similar to the protections provided by Mphasis. 2. Personal information is shared with third parties only under a lawful contractual and/ or service agreement in line with the data provider s consent. 3. Personal information transfer to a third party is performed only for the purposes identified in the notice and with the implicit or explicit consent of the individual. 4. Personal information transfer to a third party shall be performed only after ensuring the third party has implemented all the required security and privacy controls which are equal to or greater than that at Mphasis. 5. Personal information shall not be transferred to another country unless the transferor has assurance that an adequate level of protection is in place for personal information as required, considering applicable laws and regulations. Children Mphasis understands the importance of protecting children's privacy, especially in an online environment. In particular, Mphasis websites are not INTERNAL 5
6 intentionally designed for or directed at children under the age of 13. It is our policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services. Links to other sites Please be aware that Mphasis websites may contain links to other sites, including sites maintained by other Mphasis entities/ subsidiaries that are not governed by this Privacy Statement but by other privacy statements that may differ. We encourage users to review the privacy policy of each website visited before disclosing any personal information. Changes to this policy Mphasis may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the updated date at the top of this page. We encourage you to periodically review this Privacy Statement to be informed about how Mphasis is protecting your information. Monitoring and enforcement Mphasis continuously monitors the regulatory environment in the countries of it operations in order to be compliant with the requirements of the law. Any changes and updates to the regulation or law are reflected in Mphasis Data Privacy Policy. Mphasis has established procedures to address privacy-related incidents, complaints and disputes. Mphasis has also appointed Data Privacy Officer (DPO) to ensure that policies and principles comply with relevant privacy and data protection laws and regulations. In case of privacy-related concerns, complaints, disputes or questions about our administration of personally information, please contact the Data Privacy Officer (DPO) at You may also use this address to communicate any concerns you may have regarding compliance with our Online Privacy Statement. INTERNAL 6
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