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PRIVACY POLICY

Effective Date: 23/08/2025

Last Updated: 23/08/2025

This Privacy Policy ("Policy") explains how JTS Business Services (OPC) Pvt. Ltd. ("Company", "we", "our", or "us") collects, uses, stores, shares, and protects the personal information of Users who access or use the [seek now] ("Platform"). The Policy is in accordance with the provisions of the Digital Personal Data Protection Act, 2023 ("DPDP Act") and other applicable laws of India.

For the purposes of this Policy, the term “User(s)”, and wherever the context so requires, “You”, “Your”, and “Yourself”, shall mean any natural or legal person who accesses or uses the Platform. Where a natural person is acting on behalf of a business entity or a body corporate, such references shall be deemed to include that business entity and/or body corporate, together with its promoters, directors, officers, and authorised representatives. All references to “You” shall include both Yourself and any other person(s) for whom You are authorised, or required, to provide consent

By using the Platform, you consent to the collection and use of your personal data in accordance with this Policy. If you do not agree with any part of this Policy, you must not use the Platform.

Purpose and Scope
This Policy applies to all individuals who access or use the Platform, including employees, HR personnel, administrators, and other users authorized by organizations that have subscribed to our services. This Privacy Policy specifically applies to the personal information we collect and process when you:
1. visit, interact with, or use (or apply to use) any Company services, products, platforms, portals, or websites that link to this Privacy Policy;
2. create, access, or administer your Company account;
3. receive communications from us, or otherwise interact or communicate with us, including via email, telephone, postal mail, or through our branded social media pages;
4. complete a questionnaire, survey, promotional entry, support request, or any other information request form provided by the Company;
5. participate in any program, plan, or initiative facilitated by the Company in connection with your employer;
6. engage in a contracting, partnership, or vendor onboarding process with the Company (for example, as an employee, representative, or authorised signatory of a prospective customer, supplier, or service provider);
7. register for, attend, or take part in our marketing, training, or learning events; or
8. offer, integrate, or provide your application, content, product, or services through Company platforms or partner programs.
The Platform is designed to facilitate employee management, including but not limited to attendance tracking, leave and payroll management, employee engagement programs (including ESOP and other benefit tracking, where applicable), communication, and performance reviews. This Policy outlines how your personal data will be handled in the course of providing these services.
Types of Personal Data Collected
The personal information we collect depends on how You interact with the Platform, the services and features You use on the Platform, your choices, your location, and applicable laws. This information may be collected directly from You, automatically when You interact with the Platform, or from other authorised sources as described below.
1. Information You Provide to Us
  We collect personal information You provide directly to the Company or your employer, including when You register or create an account on the Platform, complete forms, upload documents, communicate with us, or use specific features. Depending on your role and the services you use, this may include:
  - Identification Data – Full name, employee ID, designation, department, and other identifiers assigned to You by Your employer.
  - Contact and Professional Information – Email address (preferably official), phone number, work address, company name, job title/level, and reporting manager details.
  - Employment Data – Attendance and leave records, payroll and salary details, benefits and deductions, performance evaluations, training records, and employment history.
  - Login Credentials – Username, encrypted passwords, authentication tokens, and any security credentials used to access the Platform.
  - Uploaded Images/Documents – Profile photo, identification proof, tax forms, educational certificates, resumes, or other employment-related documents.
  - Communications Information – Feedback, queries, support tickets, survey responses, or any other information You choose to share with the Company through the Platform, email, phone, or other communication channels.
  Providing certain categories of personal information may be necessary to register an account or access specific services on the Platform. If You do not provide such information when requested, the Company may be unable to deliver the requested service or feature.
2. Information We Collect Automatically
  When You use the Platform, we automatically collect certain information using standard tracking and logging technologies. This may include:
  - Usage and Interaction Data – Log-in and log-out timestamps, pages or features accessed, platform activity, and user preferences.
  - Device and Technical Data – IP address, device identifiers, browser type and version, operating system, network information, error logs, and security events.
  - Location Data – General location inferred from Your IP address, or precise location where You have granted permission through Your device settings.
  - Cookies and Tracking Technologies – Identifiers and information collected via cookies, web beacons, or similar technologies, as described in our Cookie Policy.
3. Information We Collect from Other Sources
  Depending on Your role and the nature of the services, we may also receive personal information about You from:
  - Your Employer – Information such as Your employment status, benefits, salary components, or HR-related documentation provided by Your employer or its authorised representatives to enable the Company to deliver its services.
  - Other Platform Users – For example, a manager updating Your records, or a colleague providing Your details in connection with team management or workflows.
  - Third-Party Service Providers – Information received from payroll processors, benefits administrators, background verification agencies, or identity verification partners.
  - Public and Commercial Sources – Information from professional networks (e.g., LinkedIn), public databases, or event organisers, particularly for recruitment, training, or business networking purposes.
4. Special Categories of Personal Data
  In the course of providing the services, the Company may process special categories of personal data (also referred to as “sensitive personal data” under applicable laws). This may include:
  - Health Related Information – Details relating to medical leaves, fitness-for work certifications, occupational health assessments, disability information, or participation in employer-sponsored health programs.
  - Biometric Data – Data used for identity verification or attendance tracking, such as fingerprint scans or facial recognition records.
  - Financial Information – Bank account numbers, tax identification details, provident fund numbers, and other financial identifiers used for payroll or benefits processing.
  - Government Identifiers – Aadhaar number, PAN, passport number, driver’s licence, or other official identification numbers where required by law or for employment purposes.
Legal Basis for Processing
We process such your data solely on behalf of, and under the instructions of, the respective employer(s) (or Data Fiduciary) in our capacity as a data processor, in accordance with the terms of our Data Processing Addendum with such Data Fiduciary.

The Company collects and processes Your personal information only when there is a valid legal basis for doing so, and only to the extent necessary to provide our services to you through the Platform.
1. Contractual Necessity
2. Compliance with Legal Obligations
3. Legitimate Interests of the Company
4. Legitimate Interests of Third Parties
  In certain cases, we may process personal data based on the legitimate interests of a third party, provided that such interests are not overridden by your rights and freedoms. For example, where the Company acts as a data processor for a client organisation, we may process employee or contractor data to support that client’s legitimate business purposes—such as payroll processing, attendance tracking, HR administration, or performance management—through the Platform.
5. Consent We may process Your personal data where You have provided Your explicit consent for a specific purpose. This may include:
  - participation in employee wellness programs;
  - completion of optional surveys, polls, or feedback forms;
  - inclusion in promotional or marketing activities; or
  - enabling certain HRM platform features that require access to sensitive personal data.
  - You may withdraw Your consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal.
6. In certain cases, the Company may create and use de-identified data. “De-identified data” means data that cannot reasonably be used to identify you. Where such data is maintained, the Company will not attempt to re-identify it except for the purposes of verifying that our de-identification processes meet applicable legal requirements.
Purpose of Data Processingl

Register and maintain your user account on the Platform;
Facilitate attendance, payroll, leave, and performance management;
Enable communication with HR and management teams;
Respond to support queries, complaints, or feedback;
Improve the functionality and performance of the Platform;
Provide updates on additional products and services, where applicable; and to notify You about updates, changes, or improvements to our services;
Ensure compliance with laws and employment policies;
Send promotional messages* via SMS, push notifications (web and mobile), and WhatsApp, in accordance with applicable laws and user preferences.

*You may opt out of receiving promotional or marketing communications from us at any time by adjusting your communication preferences in your account settings or by following the “unsubscribe” link provided in our emails and messages.

Data Sharing and Disclosure

With authorized personnel within your organization for employment-related functions;
With our trusted service providers or partners who assist us in delivering the Platform (under strict confidentiality agreements). We use trusted third parties for cloud hosting, payments, IT, analytics, marketing, and customer support, who may only process data for agreed purposes.
With government or regulatory authorities as mandated under law. We may also share data with advisors, banks, insurers, and payment processors to deliver and support services.
In response to legal proceedings or court orders;
To address complaints.
We may share with our affiliates or transfer data in case of a merger, acquisition, or sale of assets.

Data Storage and Retention
All personal data is securely stored using encryption and access controls.
The Company also uses secure storage services, such as Amazon Web Services (“AWS”), located in India. AWS is designed and built to meet rigorous compliance standards, providing high levels of security for all customers.
Your data will be retained only as long as necessary for the purposes stated in this Policy or as required under applicable law.
Upon termination of employment or deactivation of the user account, your data will be retained for a period mandated by law or company policy and thereafter securely deleted or anonymized. International Data Transfers
While we primarily store and process your personal data in India, certain services we use (such as email providers, cloud backups, or analytics tools) may transfer your information to servers located outside India.
In such cases, we ensure that appropriate contractual, technical, and organizational safeguards are in place to protect your data, consistent with applicable data protection laws.

Data Principal Rights
Under the DPDP Act, you have the following rights:
- Right to Access: To request a copy of your personal data held by us;
- Right to Correction: To correct any inaccurate or outdated data;
- Right to Erasure: To request deletion of data no longer necessary for the purpose for which it was collected;
- Right to Withdraw Consent: Where applicable, you may revoke consent given for data processing;
- Right to Grievance Redressal: To file a complaint against any misuse or unlawful processing.
However, these rights are not absolute. In an employment context, exercising certain rights (such as data deletion or consent withdrawal) may limit your ability to use the Platform or require authorization from your employer.

Please do note, when you submit a rights request, we will be obligated to verify your identity by confirming details such as your name and the email address linked to your account. You may appoint an authorized agent to act on your behalf, subject to verification using your existing contact information.

To exercise these rights, you may contact our Data Protection Officer:
Name: Edwin
Email: seek@seeknow.in
Address: 2nd Floor, No.3, JAY PEE Towers, East End Main Rd, Jayanagar 9th Block, Bangalore – 560 041
Phone: +91 9538770211
Working Hours: Mon – Fri 9:00 AM – 6:00 PM We will respond to your request within the timeframes prescribed by law.
We will not discriminate against you for exercising your privacy rights.

Data Security Measures

Role-based access controls;
Data encryption during transmission and storage;
Secure cloud hosting infrastructure;
Regular vulnerability testing and data breach response protocols.

Inactive Accounts and Data Deletion
If your account remains inactive for more than 180 consecutive days, we reserve the right to deactivate or delete the account along with associated data. You will receive prior notice of about 15 days and an opportunity to back up your data before deletion.

Children’s Privacy

Third-Party Links and Content

Complaints and Non-Response Consequences

Updates to the Privacy Policy

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