Privacy Policy

Data Security and Privacy Policy
 

Overview

Team Versatiles’ intention behind publishing this Data Security and Privacy Policy is to ensure that we are compliant to the privacy and data security requirements. Herein, Team Versatiles would like to provide detailed information regarding the data we collect, process and the controls we have implemented to safeguard the information provided to us by Data Subjects.

Objective

The purpose of this policy is to outline the practices that we adhere to with respect to:

  • Data Security and Privacy Regulations defined in. European Union General Data Protection Regulation (EU GDPR), Malaysia Personal Data Protection Act and any other such data privacy regulations

  • Statutory and Regulatory requirements such as HIPAA(Health Insurance Portability and Accountability Act)

  • Data Security, Confidentiality and Privacy requirements specified as part of Master Services Agreement (MSA), Statement of work (SOW) etc. by customers

  • Intellectual Property Rights of Data Subjects and customers

Terms & Definitions

MSA

MSA Master Service Agreements

SOW

Statement of Work

HIPAA

Health Insurance Portability and Accountability Act

Personally Identifiable Information (PII)

Any data that could potentially identify a specific individual. Any information that can be used to distinguish one person from another and can be used for de-anonymizing anonymous data can be considered PII.

Protected Health Information (PHI)

Any information about health status, provision of health care, or payment for health care that is created or collected and can be linked to a specific individual

Processing of PHI / PII

Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction

EU GDPR

European Union General Data Protection regulation

Data Controller

Any natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law

Data Processor

Means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller

Data Subject

Any natural or legal person providing its PII

Policy Description

Many countries have introduced legislations placing controls on collection, processing, and transmission of PII.
We ensure to perform our services abiding by such laws and ensuring data security, privacy, and confidentiality

What data/
information
we collect

Policy Description

  • Prospective customers may provide their information while contacting us through our website for business opportunities
  • We collect name, company details, email id (professional email id), and phone number

  • Access to such PII is provided only on need-to-know basis and is restricted to those individuals, affiliates or subcontractors who are subjected to Team Versatiles’ strict confidentiality obligations and disciplinary policies

  • Adequate controls are implemented to safeguard the PII which includes physical, technical and administrative controls

  • Team Versatiles is a leading business technology and consulting services firm catering to over 180 customers through 25 offices globally. Our services span Digital Enablement and Product Development for leading organizations across sectors. We would like to connect to organizations such as yours to explore partnership opportunities.
  • We receive information including name, email id, phone number, role, organization associated with from professional service providers such as LinkedIn premium service, marketing databases, prospective customer websites, references from our existing clients

  • We assume that the data subjects have provided consent to such professional service providers to share the PII with Team Versatiles

Customers Information

  • To provide effective services to our customers we collect PII which includes name, professional email id, phone number and company address
  • We are provided with the information during the contract phase by the respective customer in order to perform services effectively (billing, invoicing, program management etc.)
  • Team Versatiles assumes that the customer organization has already obtained consent from the data subject and would exclude Team Versatiles from any additional consent to be acquired

Prospective Employess

  • In the process of recruitment and talent management, Team Versatiles’ HR may receive PII from job posting sites / portals, LinkedIn etc.
  • Team Versatiles receives name, email ID, mobile number, address and other information provided by data subject in the respective job portals
  • Team Versatiles assumes that the job posting portals has already obtained consent from the data subjects to share such information and would exclude Team Versatiles from any of the obligations related to additional consent management

Data Processing

Prospective Customers

In order to establish this connection, we would like to reach out to prospective customers with technological / digital propositions and solutions relevant to their business, invitations for our sales reach events, white papers, publications, industry newsletters and any relevant technology related content

Customers Information

PII collected through the job portals for recruitment and talent acquisition will be processed to reach out to prospective employees for job openings and careers at Team Versatiles

Data Storage

Prospective Customers

  • PII provided by the prospect in the website or gathered through marketing database would be stored on a well-established CRM tool
  • Appropriate technical controls including but not limited to access control mechanism, encryption, data anonymization are in place to safe guard the confidentiality, integrity and availability of the information

Customers Information

  • PII provided by the prospective employees in the website or job portals would be stored on a well-established HRIS Tool
  • Appropriate technical controls including but not limited to access control mechanism, encryption, data anonymization are in place to safe guard the confidentiality, integrity and availability of the information

Data Disposal

  • PII / PHI data of data subjects will not be kept longer than necessary. Such requirements would be identified during data collection process based on regulatory or legal requirements prevailing in that period
  • PII / PHI Data will be securely disposed once it is no longer in use.

Data Disclosure

  • Team Versatiles ensures that PII / PHI data is not disclosed to the unauthorized users without proper consent
  • Any such request for access to the data from third parties including law enforcement and government agencies would be notified to Data Subject where applicable
  • Disciplinary actions would be initiated as per the disciplinary policy defined for any unauthorised disclosure of PII / PHI

Data Subject Rights

Right of Access, Modify

  • Prospective Clients and Employees
  • Data subjects at all times can reach out to Team Versatiles through “email id: EUGDPR@Team Versatiles.com ” for access to the personal data to review, modify and correct any inaccuracies

  • For Customer provided information, we request Customer to inform Team Versatiles in case the data subject has withdrawn the consent so Team Versatiles can take actions on such PII as appropriate

Right to consent/opt-out consent

  • Prospective Clients
  • In case of data obtained through Premium services, Team Versatiles will reach out to all such prospective clients with an email to obtain their consent providing a link to this policy

  • In case the data subject would like to opt out they can reply to the email or weblink option provided. In case, we do not receive the information within one week it would be deemed that consent is provided

  • Team Versatiles would maintain name, LinkedIn ID, or marketing database ID of opted out data subjects in do-not-contact(DNC) list to ensure that no future contacts are made by our sales team

  • Prospective Employees
  • Team Versatiles will reach out to all such prospective employees with an email to obtain their consent providing a link to this policy

  • In case the data subject would like to opt out they can reply to the email or weblink option provided. In case, we do not receive the information within one week it would be deemed that consent is provided

  • Team Versatiles would maintain name, LinkedIn ID, job portal ID of opted out data subjects in do-not-contact(DNC) list to ensure that no future contacts are made by our HR team

  • Right to Erase
  • Data subjects at all times can reach out to Team Versatiles through “email id: EUGDPR@Team Versatiles.com” to erase a part of data or complete data

  • For Customer provided information, we request customer to inform Team Versatiles in case the data subject has made such request

Breach Notification

  • Team Versatiles would intimate the data subjects, customers on any instance of data breach which could potentially impact the privacy of data subject
  • Such notifications where ever feasible would be within 72 hours or as per the contracts established
  • Team Versatiles would further take all reasonable steps to curb such instance from repeating and take all corrective measure to minimize the impact of such data breach

Data Controller
and
Contracting Parties

In case the data subject resides in the countries that are part of the European Union (EU), European Economic Area (EEA) Team Versatiles UK Limited would be the data controller

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