Privacy Policy

SWAAYAM

INTRODUCTION
Vwyre Technology Labs Pvt. Ltd. AND its technology product Swaayam (hereinafter collectively referred to as “the Company” or “Swaayam”) respect your privacy and is committed to protecting it through this Privacy Policy under the “Data Protection Rules” notified under the Information Technology Act, 2000 (“IT Act”) by Union of India.

This Privacy Policy governs your access to and use of the swaayam.co (hereinafter referred to as the “Website”), including any content, functionality and services offered on or through the Website whether as a guest or a registered user.

When accessing the Website, the Company will learn certain information about you, both automatically and through voluntary actions, you may take, during your visit to the Website. This policy applies to information the Company collect on the Website and in email, text, or other electronic messages whatsoever between you and the Website.

Please read the Privacy Policy carefully before you start to use the Website. By using the Website or by clicking to accept or agree to the Terms of Use when this option is made available to you, you accept and agree to be bound and abide by the Privacy Policy. If you do not want to agree to the Privacy Policy, you must not access or use the Website.

User Under the Age of Adolescents as per The Child Labour (Prevention and Regulation) Amendment Act Our Website is not intended for users under legal age provided by The Child Labour (Prevention and Regulation) Amendment Act. No one under said age may provide any information to or on the Website. We do not knowingly collect personal information from users under said age. If you are under said age, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your photograph, video, name, address, telephone number, email address, or any screen name or user name you may use.

If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at connect@swaayam.co

This  Privacy Policy describes the privacy and security practices that Swaayam, its subsidiaries and affiliates (We or us) employ when collecting, using and handling (processing) personal information about you in connection with our online and offline services. It also explains the choices you have in relation to these processing activities.

Personal information means all information that relates to an identified individual, legal entity or to an identifiable individual, legal entity. For example, your photograph, video, name, address, email address, educational and employment background, CV/resume, job qualifications, and information alike. Personal information is also referred to as information about you.

This Privacy Policy was last changed on October 5, 2021. However, the Privacy Policy may change over time to comply with legal requirements or to meet our changing business needs. The most up-to-date version of the Privacy Policy can be found on this website. In case there is an important change that we want to highlight to you, we will also inform you in another appropriate way (for example, via a pop-up on our website).

SCOPE

This Privacy Policy applies to the processing of personal information by Swaayam of:

• visitors and users of the various websites operated under control of Swaayam, including our websites on Swaayam.co, computer or mobile software applications and our social media pages that link to this Privacy Policy (collectively referred to as the sites);
• attendees of Swaayam events, such as Swaayam sponsored events;
• customers and prospective customers and their representatives;
• subscribers to Swaayam publications and newsletters;
• visitors to Swaayam physical facilities;
• engagement through Whatsapp or any other social media chat-bot; and
• suppliers and business partners and their representatives.

The Privacy Policy does not apply to the following activities:

• Personal information collected about you by Swaayam customers. Swaayam customers are responsible for their own personal information collection and processing practices, including when customers use Swaayam products or services to process their personal information. To find out more about our customers’ use of personal information about you, you are encouraged to review the relevant privacy policy of the company/employer who collected your information from you. Please consult that company directly if you have any further questions about its use of information about you.
• Personal information you provide on third party sites not controlled by Swaayam. When interacting with our websites, you also have the ability to link or connect with non- Swaayam websites, services, social networks, applications or other features. Enabling these features will lead to other parties than Swaayam processing information about you. Swaayam does not have any control over the features of other parties. We encourage you to review the privacy policies of these parties before using these features.

RESPONSIBLITY FOR YOUR PERSONAL INFORMATION
Swaayam and its affiliated entities are responsible for processing your personal information described in this Privacy Policy.

CATEGORIES AND SPECIFIC PIECES OF PERSONAL INFORMATION DO WE PROCESS
Swaayam can process information about you collected directly from you both offline and online, including when you create a Swaayam account to access Swaayam products and services or attend a Swaayam-sponsored event. Information about you may also be provided to Swaayam by selected third-party sources, such as data aggregators who may not have a direct relationship with you or by third parties who collect information about you on behalf of Swaayam such as when you download a Swaayam whitepaper/newsletter.

Specific pieces of information about you that Swaayam may collect and process depending on your interaction with Swaayam, includes for e.g., but not limited to:

• name and physical address, email addresses, and telephone numbers;
• demographic attributes, when tied to personal information that identifies you;
• photographs that identify you and testimonials;
• videos that identify you and testimonials
• transactional data, including products and services ordered, financial details and payment methods;
• company data such as the name, size and location of the company you work for and your role within the company as well as publicly available company information and activity associated with company data;
• data from surveys conducted by Swaayam or by third parties on behalf of Swaayam and publicly available information, such as social media posts;
• call recording and chat transcript data from Sales and customer support calls and live chat sessions or interviews;
• unique IDs such as your mobile device identifier or cookie ID on your browser;
• IP address and information that may be derived from IP address, such as geographic location;
• information about a device you use, such as browser, device type, operating system, the presence or use of “apps”, screen resolution, and the preferred language;
• certain location or geolocation information you provide directly or through automated means, if you choose to enable location based services from your device or Swaayam application/SAAS; and
• behavioral data of the internet connected computer or device you use when interacting with the sites, such as advertisements clicked or viewed, sites and content areas, date and time of activities or the web search used to locate and navigate to a site.

Certain online information about you or device information may originate from the use of cookies and similar technologies (for example, pixel tags and device identifiers) on our sites or sites of third parties.

Please note that Swaayam does not control the content that you may post to any Communities forums or social networks; in some cases, such content may be publicly available on the Internet. You should carefully consider whether you wish to submit personal information to these forums or social networks and whether you wish to make your profile available to other users, and you should tailor any content you may submit accordingly.

USE OF YOUR PERSONAL INFORMATION
We may use personal information for the following business purposes:

• to communicate and respond to your requests and inquiries to Swaayam;
• to create and administer a Swaayam single sign-up account (also referred to as an ‘Swaayam Account’) and to deliver functionality on our sites/application and for their technical and functional management;
• to engage in transactions with customers, suppliers and business partners and to process orders for Swaayam products and services;
• to analyze, develop, improve and optimize the use, function and performance of our sites and products and services;
• to manage the security and operation of our sites, facilities, and networks and systems; and
• to comply with applicable laws and regulations and to operate our business.

We may use personal information for the following commercial purposes:

• to administer subscriptions of Swaayam publications and newsletters;
• to market our products and services or related products and services, and to tailor our marketing and sales activities to your or your company’s interests; and
• to provide select business-to-business services to Swaayam customers using publicly available information about companies which may include personal information such as the name of a company’s CEO that is publicly available.
• We rely on our legitimate interest in processing contact and related information about you in order to communicate adequately with you and to respond to your requests.
• In order to engage in transactions with customers, suppliers and business partners, and to process purchases and downloads of our products and services, we need to process information about you as necessary to enter into or perform a contract with you.
• We process personal information for marketing and sales activities (including events) based on your consent where so indicated on our sites at the time your personal information was collected, or further to our legitimate interest to keep you updated on developments around our products and services which may be of interest to you.
• We rely on our legitimate interest to analyze, develop, improve and optimize our sites, facilities, products and services, and to maintain the security of our sites, networks and systems.
• In order to comply with applicable laws and regulations, such as to comply with any legal process, or to process an opt-out request.

PERIOD FOR RETAIING PERSONAL INFORMATION

Swaayam maintains personal information for the following retention periods:

• Information about you we collect to engage in transactions with our customers, suppliers and business partners, and to process purchases of our products and services, will be retained for the duration of the transaction or services period, or longer as necessary for record retention and legal compliance purposes.
• If you have registered for a Swaayam account to access Swaayam sites or have agreed to receive Swaayam marketing materials, your account information will be retained for as long as you maintain an active account. Your account and account information will be deleted if you do not log in for a period of time as per regulation. Swaayam retains records of that deletion for 90 days.
• If you opened a Swaayam account, your account information will be retained for as long as you maintain an active account. After service termination, minimal account information will be held for records retention purposes. Please note the Swaayam Privacy team cannot delete, correct, or access service account data or terminate your contracted Swaayam product or service account. Please refer to the Swaayam Contact US page for resources and contact information to administer service account data.
• If you have registered for our newsletters and blogs, including Swaayam magazine, your subscription data will be retained for as long as you are subscribed to our distribution lists. Swaayam retains records of that deletion for 30 days.
• Contact information such as your email address or phone number collected online on our sites or offline from our interactions with you at Swaayam events and conferences, and used for direct marketing and sales activities will be retained for as long as we have an active (customer) relationship with you. We treat you as an active contact if (i) you have interacted with Swaayam or updated your contact details and preferences in the past 12 months; and (ii) you have not made a deletion request.
• If you have reached out to us via Swaayam Sales chat-bot, we will delete all chat transcripts 90 days after the chat has concluded.
• If you have reached out to us via our customer support service and you have not opted out of call recording, we will delete call recordings 60 days after the call has concluded unless otherwise specified during the call.
• If you have visited a Swaayam facility, the personal information needed to allow you to enter the facility will be held for one year after your last visit for records retention purposes.
• Personal information needed to retain your opt-out preferences is retained for 20 years (or longer as necessary to comply with applicable law under Data Protection Rules).

SHARING YOUR PERSONAL INFORMATION
Sharing within Swaayam
As a global organization, information about you may be shared globally throughout Swaayam’s worldwide organization. Swaayam employees are authorized to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their job functions.

Sharing with third parties
We may share personal information with the following third parties for a business purpose:

• Third-party service providers (for example, payment-gateway, credit card processing services, order fulfilment, analytics, event/campaign management, website management, information technology and related infrastructure provision, customer service, e-mail delivery, auditing, and other similar service providers) in order for those service providers to perform business functions on behalf of Swaayam;
• Relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);
• As required by law, such as to comply with any legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.
• When third parties are given access to personal information, we will take appropriate contractual, technical and organizational measures designed to ensure that personal information is processed only to the extent that such processing is necessary, consistent with this Privacy Policy, and in accordance with applicable law.

SECURITY OF PERSONAL INFORMATION
Swaayam has implemented appropriate technical, physical and organizational measures designed to protect personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access, as well as all other forms of unlawful processing.

TECHNOLOGY AND COOKIES WE USE ON OUR SITES
Cookies and similar technologies are used by Swaayam and our advertising technology partners to recognize you and/or your device(s) on, off and across different services and devices for the purposes.

• When do we use cookies and similar technologies?

Cookies are small text files that contain a string of characters and uniquely identify a browser on a device connected to the Internet. We place cookies in your browser when you visit Swaayam sites and non- Swaayam sites that host our plugins or tags. Depending on your jurisdiction, you may be presented with different consent options, including the option to reject all non-essential cookies, prior to Swaayam placing cookies on your browser.

We use cookies and other technologies on all our sites to ensure the best possible and secure experience on our sites and to provide you with tailored information on products and services. Swaayam also uses cookies or similar technologies on its sites to collect online information such as your mobile device ID, IP address, and other information about your device, as well as behavioural data of your device usage on our sites (e.g. pages viewed, links clicked, documents downloaded).

• How can I manage my cookie preferences?

If you are a visitor or our sites, you can use a cookie preferences tool to opt-out of cookies that are not required to enable core site functionality, such as advertising and functional cookies.

You can also access the opt-out checkbox to opt-out of interest-based advertising by Swaayam and other participating advertising technology companies serving interest-related ads to you on behalf of Swaayam.

If you do not want to receive cookies, you can also change your browser settings on your computer or other device you are using to access our services. Most browsers also provide functionality that lets you review and delete cookies, including Swaayam cookies.

PRIVACY RIGHTS
You have multiple privacy rights under Data Privacy Act, India and subject to various other applicable law, in respect of the information we process about you:

• Opt-out of our use or sharing of your personal information
  You may withdraw consent you have previously provided for the processing of information about you, including for email marketing by Swaayam.
• Delete personal information
  You can ask us to erase or delete all or some of the information about you.
• Change or correct personal information
  You can edit some of the information about you. You can also ask us to change, update or fix information about you in certain cases, particularly if it is inaccurate.

If you are authorized to make an access or deletion request on behalf of a data subject, please reach out to us via the inquiry form and indicate with evidence that you are an authorized agent. We will provide you with instructions on how to submit a request as an authorized agent on behalf of a data subject.

In the event you have previously created an account for a certain Swaayam portal, you can access and manage your personal information stored in these portals (i) by clicking the links and following the corresponding instructions, and (ii) taking the actions within each portal with regards to your personal information, such as updating your contact details, deleting certain entries or records. Please note that these actions are available to the extent permitted by each portal’s functionality.

If your inquiry relates to your company’s service account or support of Swaayam products or services, please note the Swaayam Privacy team cannot delete, correct, or access service account data or terminate your contracted Swaayam product or service account. Please go to the Contact Us at  Swaayam page for resources and contact information to administer service account data.

SENSITIVE INFORMATION
Swaayam does not request or require and asks that you do not send us any sensitive personal information, such as details concerning the racial or ethnic origin, religion or philosophical beliefs, health, sexual orientation, or political affiliation in connection with your job application and our recruiting efforts. To the extent information you do provide to us contains sensitive information, for example, details of your racial or ethnic origin, political opinions or beliefs, religious beliefs, membership in a trade union or political party, physical or mental health or condition, sexual orientation, commission or alleged commission of an offence or related proceedings, job evaluations or educational records, you explicitly authorize Swaayam to process this personal information as described in this Privacy Policy. The processing by Swaayam of your voice recordings or image, or behaviour, personality or other psychometric information is subject to the Privacy Policy terms.

Additionally, if you have a disability and would like Swaayam to consider any accommodation, you may provide that information during the sign-up process.

YOUR RESPONSIBILITIES
You are responsible for the personal information that you provide or make available to Swaayam, and you must ensure it is relevant, truthful, accurate and not misleading in any way. You must ensure that the information provided does not contain material that is obscene, defamatory, or infringing on any rights of any third party; does not contain malicious code; and is not otherwise legally actionable. Further, if you provide any personal information concerning any other person, such as individuals you provide as references, you are responsible for providing any notices and obtaining any consents necessary for Swaayam to collect and use that information as described in this Privacy Policy.

You explicitly undertake NOT to upload any video/graphic content which is inappropriate legally, morally, ethically. Swaayam reserves rights to take appropriate actions as deemed fit to remove such content without due notice.

DISPUTE RESOLUTION
If you have any complaints regarding our compliance with this Privacy Policy, please contact us first @ connect@swaayam.co or at our Corporate headquarter located at: Villa 1B, The Grove, Tekkan Estates, Dr. Ambedkar Nagar Road, Whitefield Bangalore 560066. We will investigate and attempt to resolve complaints and disputes regarding the use and disclosure of personal information in accordance with this Privacy Policy and in accordance with applicable law. Under certain conditions, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.