Pershing India Privacy Policy

Pershing India Operational Services Private Limited (“Pershing India”) is committed to respecting the privacy of every person who shares information with Pershing India. Your privacy is important to us and we strive to take reasonable care and protect the information we receive from you.

This Privacy Policy is applicable to employees, customers and any another persons who discloses Personal Information (defined below) to Pershing India such as vendors, suppliers, distributors, licensors, licensees, agents, representatives, sub-contractors or advisors of Pershing India.

The purpose of this Privacy Policy, as amended from time to time, is to give you an understanding on how we intend to collect, store, transfer and use information you provide to us.

By using and/or accessing Pershing India’s products and services and/or providing any products or services to Pershing India and/or executing an employment or any other agreement with Pershing India and/or executing a consent letter provided by Pershing India, you have consented / hereby consent to the collection, storage, disclosure, processing and transfer of your Personal Information that you provide to us for the purposes as set out in this Privacy Policy.

The Privacy Policy may be subject to further changes. Your continued use of Pershing India’s products and services or provision of products or services to Pershing India and/or your continued engagement with Pershing India will signify your consent to such further changes.

You are providing your Personal Information out of your free will. You have the option not to provide us your Personal Information sought to be collected if you do not agree with this Privacy Policy or even otherwise. Further, you have an option to withdraw your consent given earlier, provided such withdrawal of consent is intimated to us in writing. If you opt not to provide us Personal Information or withdraw consent previously provided at any point in time, we may not be able to fulfill the Intended Purposes (as defined below) and accordingly we may be required to terminate our association with you or restrict you from using our products/ services (where applicable).

What information does Pershing India collect?

We collect various kinds of personal and sensitive information from you that may be capable of identifying you or that may be termed as sensitive or personal (collectively, “Personal Information”). From amongst the various kinds of Personal Information that we may collect, the following items of Personal Information are considered to be Sensitive Personal Data or Information as such term is defined under the Information Technology Act, 2000 (“SPDI”):

  • Your password;
  • financial information such as details of bank accounts, credit cards, debit cards or other payment instruments;
  • Your physical, physiological and mental health condition;
  • Your sexual orientation;
  • Your medical records and history; or
  • Your biometric information.
  • Your IP addresses, location, system details;
  • Data gathered from Pershing’s employees’ emails, instant messages, telephone calls and other electronic communications as well as internet access.

This Privacy Policy may accord different treatment to SPDI keeping in mind its sensitive nature.

Usage of Personal Information

We may collect, store, disclose, process and transfer your Personal Information for various purposes including but not limited to the following (“Intended Purposes”):

  • To enable the functioning of Pershing India’s business including providing services and/ or engage in/ carry out the activities/ transactions that would enable and assist in providing you our services and services of our channel partners;
  • To operate and improve our services;
  • To provide effective customer service;
  • In connection with a variety of purposes relating to your employment or engagement by Pershing India, including, but not limited to, background checks, practice licensing and certification (including any continuing education or certification requirements), immigration, visa and work permits, recruitment, remuneration, entitlements, benefits, incentives, leave, payroll, pensions, severance, retirement, accounts and expenses, auditing, performance management, appraisals, promotion, surveys, compliance with company policies, Code of Conduct and internal regulations, sickness, fitness for work, workplace injuries, health and safety, attendance, workers’ compensation issues, career development, relocation, assignments, employee transfers, secondments, travel, insurance, business mergers, business acquisitions, business transfers, due diligence, legal, judicial, governmental and regulatory compliance, tax administration and compliance, union membership, representation, consultation and negotiations, contact for work purposes and for emergencies, Pershing India events, mentoring, counseling, complaints, employee relations, misconduct, monitoring, investigations, security, discovery, collection of evidence, document retention requirements, overseas affiliates’ compliance with foreign laws and cooperation with overseas regulators, disciplinary action, termination and post-termination matters, outplacement services, employment certification, employment references, and other purposes related to or connected with the above;
  • To transfer information about you if we are acquired by or merged with another company;
  • To administer or otherwise carry out our obligations in relation to any agreement you have with us;
  • To respond to subpoenas, court orders, or legal process, to establish or exercise our legal rights or defend against legal claims or to make disclosure to regulatory agencies as may be required; and
  • To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of the website or as otherwise required by law.

You consent that the collection, storage, disclosure, processing and transfer of any Personal Information or any other information as disclosed under this Privacy Policy shall not cause any loss or wrongful gain to you if the same is used for the Intended Purposes.

Sharing and transfer of Personal Information

We may need to share your Personal Information with our group companies within and outside India and/or business associates within and outside India in connection with the Intended Purposes set out above.

You authorize us to exchange, disclose, transfer, share, part with all Personal Information and/or any information provided by you, within India, to any other countries across the world.

Security

The security of your Personal Information is important to us. We have adopted reasonable security practices and procedure, to ensure that the Personal Information collected is secure. You agree that such measures are secure and adequate. We restrict access to your Personal Information to our and our affiliates’ employees, agents, third party business associates who need to know such Personal Information in relation to the Intended Purposes as specified above in this Privacy Policy. When we share or transfer your SPDI in accordance with this Privacy Policy, we will undertake reasonable efforts to ensure that the transferee maintains or adopts security practices and procedures which are at least as stringent as the security practices and procedures we follow. While we will endeavor to take all reasonable and appropriate steps to keep secure any information which we hold about you and prevent unauthorized access, you acknowledge that such steps are never 100% secure and that we cannot provide any absolute assurance regarding the security of your Personal Information. To the fullest extent permissible by applicable law, we disclaim any liability in relation to any breach of security or unintended loss or disclosure of information in relation to your Personal Information.

Access

If you need to access, update or correct your SPDI, you may contact us at the following email address, PrivacyOffice@pershing.co.in

Grievance

We have nominated Anbalagan Rathinam as the Grievance Officer of Pershing India who you may approach if you have any grievance with respect to the processing and use of your SPDI. You may contact this officer at the following email address, PrivacyOffice@pershing.co.in

Data Retention

It is Pershing India’s policy to retain Personal Data of both current and former employees and contractors only for as long as Pershing India believes it to be necessary for the Intended Purposes for which the data was collected, subject to any legal requirements for the data to be retained for longer periods of time.

Compliance with laws

You are not allowed to utilize the products/ services of Pershing India or engage with Pershing India if any of the terms of this Privacy Policy are not in accordance with the laws applicable to you.

Updated on March 26, 2014