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Privacy Policy
A. GENERAL
This Privacy Policy applies to all current and former users accessing or using Our Website, whether for the purposes of our Services or otherwise engaging with us through email or other means (collectively, “You” or “Your”). By accessing or using Our Website or by otherwise giving Us Your information, You confirm that You have the capacity to enter into a legally binding contract and have read, understood and agreed to the practices and policies outlined in this Privacy Policy. You hereby consent to Our collection, use, sharing, and disclosure of Your information as described in this Privacy Policy. We may modify, add or delete from this Privacy Policy from time to time, and Your continued access to, or use of the Website, will be deemed to be an acceptance of the said changes. If You do not agree with this Privacy Policy at any time, in part or as a whole, do not access/use the Website or services provided through the Website, or provide Us with any of Your Information. If You are accessing or using the Website from any location outside India, You will be solely liable for compliance with any local laws, as may be applicable.
B. INFORMATION WE MAY COLLECT FROM YOU
We may collect Your following Personal Information either directly from you or from any third party:
  • INFORMATION REQUEST - When you are requesting materials or information from HOSPL, we may collect your name, job title, address, email address, phone number, IP address, company name, country/state of residence, photocopy of your ID and other Personal Information, as well as professional interests and the reasons why you are requesting HOSPL services.
  • CLIENT LOGIN - When you use the client log-in portal for background verification, you will be sent to our webpage where we will collect login information such as account, username and/or password in order to access your account and perform the requested services.
  • BACKGROUND VERIFICATION SERVICES - When your prospective or current employer requests a background check, HOSPL may collect your personal information, that you provide by filling in authorization forms (online or in physical format), through our clients, including your full name, employee ID, employee title, joining data, last working date, date of birth, annual compensation, passport number, Aadhar number, PAN number, Driving License, email address, telephone number, and any personal information contained within any scanned or photographed documentation you provide to Us.
  • JOB APPLICANTS - When you apply for employment with HOSPL we will collect your name, email address, country of residence, physical address, cell phone number and any other personal information you include in your resume.
  • BILLING INFORMATION - If you purchase our services you may need to provide HOSPL with payment and billing information, such as your billing address, Goods & Service Tax Identification Number.
  • BLOG, INSIGHTS, NEWSLETTERS - When you subscribe to our communications, we will collect your email address.
  • INDIRECT INFORMATION - When you visit our Website, we may collect and store general Internet data, such as your domain name, browser type, device, date and time of access, which of our web pages you visited, the referring Uniform Resource Locator (URL). This information may be collected to assist us in making improvements to our Website and to administer our Website. HOSPL may employ third party companies and individuals to facilitate these services (e.g., maintenance, analysis, audit, development). These third parties have limited access to your personal information and only to perform these services or tasks on our behalf.
C. PURPOSES FOR WHICH YOUR PERSONAL INFORMATION IS COLLECTED AND USED BY HOSPL
We use your information for a number of legitimate interests, including to provide and improve our services, administer our relationship with you and our business, for marketing and in order to exercise our rights and responsibilities. More detailed information about these legitimate interests is set out below:
  • FOR PROVIDING OUR SERVICES - HOSPL acts as a processor when processing personal information on behalf of our controller clients who request background checks for employment screening or vetting purposes. The legal basis for this use of your personal information is that processing is necessary for the performance of our contract with our Client. We may also analyse your personal information in conjunction with the results of Our searches, and report to Our clients on the accuracy and authenticity of the personal information you have provided.
  • FOR CONDUCTING SEARCHES ON PUBLICLY AVAILABLE AND PRIVATE DATABASES - We may cross reference and match the personal information you provide to Us (your name and work history) to other personal information held about you, in accordance with applicable law. The legal basis for this use of your personal information is that processing is necessary for performance of Our contractual obligation.
  • FOR ADMINISTERING THE RELATIONSHIP WITH OUR CURRENT AND PROSPECTIVE CLIENTS - We process personal information to administer our relationship with our current and prospective clients. This routinely includes: contacting you to discuss matters for which you have engaged us or those for which you may engage us to handle on your behalf. This also includes due diligence, fraud prevention, processing payments, accounting, auditing, billing and collection, and support services.
  • FOR COMPLIANCE WITH LEGAL OBLIGATIONS - We also process your personal information in order to comply with our legal and regulatory obligations. We also process personal information to establish, exercise and defend our legal rights and any legal proceedings which may arise; and to prevent, detect and respond to actual or potential fraud or other illegal activities.
  • FOR MARKETING PURPOSES - HOSPL also may process personal information to send you information about new developments or HOSPL activities in the form of newsletters, event invitations, alerts, blog postings, or other similar communications. Depending upon the nature of the communication, these messages may be sent to you with your consent or pursuant to our legitimate interests. If you do not wish to receive such communications, you can opt-out of receiving future messages by email by opting out using the link in the message or by contacting the Point of Contact provided in this policy.
D. DISCLOSURE OF YOUR PERSONAL INFORMATION
To facilitate the purposes set out above, we may transfer, disclose, grant access to or share your personal information with:
  • Professional advisers including lawyers, bankers, auditors and insurers;
  • Regulators and other authorities who require reporting of processing activities in certain circumstances;
  • In the event that we are involved in merger, acquisition, reorganization or sale of assets, in which case your information may be sold or transferred as part of that transaction. This Privacy Policy will apply to your information as transferred to the new entity;
  • Third-party companies who help Us provide and improve our services such as:
    • to assist with our verification process where we may not be able to do it ourselves (only used in extreme circumstances);
    • to help Us understand and improve the use of our Services, such as Google Analytics; and
    • to Companies providing cloud-based hosting, storage and processing service to Us such as Google, Inc (Global), Microsoft Azure and Amazon Web Services.
  • We share your personal information with such third-party service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use your personal information only for specified purposes and in accordance with our instructions.
  • We may disclose your information, including personal information, if legally required to do so, pursuant to an order from a governmental entity or in good faith. We will disclose the Information to:
    • Conform to legal requirements or comply with legal process;
    • Protect Our rights or property;
    • Prevent a crime or protect national security; or
    • Protect the personal safety of users or the public.
E. CHANGES TO YOUR INFORMATION
  • HOSPL has enabled appropriate security procedures to secure the Information obtained, stored, processed, and used by HOSPL during the course of its business, and has been certified in relation to the same, including, without limitation, under the International Standard ISO 27001.
  • HOSPL has reasonable security policies and procedures in place to protect Information from unauthorised loss, misuse, alteration, or destruction. Despite HOSPL’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your Information is limited to those who have a need to know. Those individuals who have access to the Information are required to maintain the confidentiality of such Information.
F. DATA RETENTION
HOSPL retains personal information as needed to provide you services, respond to inquiries, consider your employment application, partner with you, or as required by contractual, statutory or other legal obligations.
G. THIRD PARTY LINKS
  • Our Website may contain links to third party websites and services. We have no control over such third party services, which are provided by persons or companies other than Us. We are not responsible for any collection or disclosure of Your information by such companies or persons thereof.
  • Further, We are not liable for any loss or damage which may be incurred by You as a result of the collection and/or disclosure of Your information via third party services. We shall not be liable for any disputes arising from or in connection with such transactions between You and the aforementioned third parties.
  • Such third party websites, and external applications or resources, accessible via the Website may have their own privacy policies governing the collection, storage, transfer, retention and/or disclosure of Your information that You may be subject to. We recommend that You exercise reasonable diligence before committing to any transaction or exchange of information, including but not limited to reviewing the third party website or application’s privacy policy.
H. This Privacy Policy (“Privacy Policy”) is published in compliance with inter alia:
  • Section 43A of the Information Technology Act, 2000 (“IT Act”);
  • Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”); and
  • Rule 3(1)(a) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.
In the event of a change in the law applicable to data protection in India, You hereby expressly consent to Our continued use, storage, collection and disclosure of Your information including personal information to the fullest extent permitted under such applicable law. We may reach out to You for obtaining additional consents and approvals as required under the amended law and You will be required to comply with such requests. Should You choose to not provide Us with such additional consents and approvals, We may have to discontinue your access to the Website.
I. GRIEVANCE OFFICER AND CONTACT INFORMATION
In accordance with the IT Act and rules made there under, the name and

contact details of the Grievance Officer are provided below:

Mr. Piyush Peshwani

You may write to him at the following address:

Handy Online Solutions Private Limited,

Plot No. 34, Institutional Area, Sector 44,

Gurugram, Haryana - 122 003

Or

Email him at partner@elockr.io
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Contact
Address
Handy Online Solutions Private Limited,
Plot No. 34, Institutional Area, Sector 44,
Gurugram, Haryana - 122 003
Phone
08047094800