Privacy Notice

Zensar Privacy Notice

This Privacy Notice is effective as of January 1, 2020.

Preamble

Zensar Technologies Ltd., and its affiliated entities around the world (collectively “Zensar”, “we”, or “us”), is committed to protecting the privacy of your personal information. This Privacy Notice details certain policies implemented throughout our company governing Zensar’s use of personal information about:

  • visitors to our Internet website (the “Site”) located at the URL: www.Zensar.com and/or to any of our affiliate/subsidiary Company’s websites (“Site)”;

  • visitors and users of the following applications: Zensar, ZenEdge, and ZenCSR, other Zensar applications (collectively, the “Applications”); and

  • employees, contractors and customers of our clients who use our services and/or products (collectively, services and products are: “Service” or “Services”).

Collectively, the Site, Applications, and Services shall be referred to as the Websites. Where the Privacy Notice differs depending on whether you are using the Site, Applications or the Services, those distinctions will be noted in this Privacy Notice.

This notice does not apply to information collected or obtained by any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Websites.

By accessing, browsing, or otherwise using the Websites, you acknowledge and consent to our collection and use of information as set forth in this Privacy Notice. PLEASE READ THIS PRIVACY NOTICE CAREFULLY. YOUR USE OF THE WEBSITES CONSTITUTES YOUR CONSENT TO THIS PRIVACY NOTICE. DO NOT USE THE WEBSITES IF YOU ARE UNWILLING OR UNABLE TO CONSENT TO THIS PRIVACY NOTICE.

Information Collection

When using the Websites, you may choose to provide Zensar with certain information, including personal information. "Personal information" is any information that can be used to identify an individual, and may include name, address, email address, phone number, login information (account number, password), marketing preferences, or social media account information. We may also collect information automatically from you regarding your use of our Websites, without any active submission of information from you.

Through the Site:

You can generally visit the Site without revealing any personal information about yourself. However, in certain sections of the Site, we may invite you to contact us for information or questions, inquire about a job or apply for a job, or to obtain content we provide for informational and marketing purposes. In such situations, you may disclose to us your name, phone number, email address, title, company name, and certain employment-related information.

We may track and store information such as the total number of visitors to our Site, the number of visitors to each page of our Site, your IP address, your browser type, the number of external web site (defined below) pages you have visited, and other browsing or computer data. For more information, see the description below on Cookies.

Through the Applications:

When using the Applications, we may track and store information such as device properties including, but not limited to, unique or other device identifiers; device operating system and firmware; IP address (i.e., a number that is automatically assigned to your device or computer used to access the Applications, and allows us to identify your device or computer) and Internet service provider; mobile phone carrier; geographical data such as country or region; and other similar data.

Through the Services:

When our clients use our Services, our clients may provide us with information about you, including personal information such as your name, address, email, phone number and IP address.

Use of Information

In general, we do not and will not share your personally identifiable information except as set forth in this Privacy Notice. We do not sell, transfer, and/or share your personally identifiable information with third parties for their own marketing purposes.

We use the information we collect from you when you browse and/or use our Websites in the following manner:

Categories of Personal Information

Use of Information

Identification information, application usage data (e.g., features/pages accessed by a member), location data (GPS).

To operate and improve the Websites and associated services.

 

Identification information, application usage data (e.g., features/pages accessed by a member), location data (GPS).

To understand and analyze information related to the number and type of visitors that browse and use the Websites.

 

Identification information, application usage data (e.g., features/pages accessed by a member), location data (GPS).

 

To verify you and your authority to use the Websites.

Name, phone number, mailing address, email address.

To provide you with information, products, or services that you request from us, or that may be of interest to you.

 

Name, phone number, mailing address, email address.

To provide Services to Clients, under the Client’s direction and instruction.

 

Name, phone number, mailing address, email address.

To respond to your comments, inquiries and questions and provide customer services.

 

Name, phone number, mailing address, email address.

To permit you to participate in social sharing, including commenting on our blog or on our social media platforms such as LinkedIn, Instagram, and Facebook.

 

Name, phone number, mailing address, email address.

To send administrative information to you, for example, information regarding the Websites and changes to our terms, conditions, and policies. Because this information may be important to your use of the Websites, you may not opt-out of receiving these communications.

 

Name, mailing address, email address, phone number, demographic information

To permit you to register for a webinar and/or event and for us to communicate with you regarding that webinar/event.

 

Name, mailing address, email address, phone number, demographic information

To link or combine with other personal information we get from third-parties, to help understand your needs and provide you with better information on the Websites.

 

Name, mailing address, email address, phone number, demographic information, employment-related information

 

To permit you to submit an employment application with us and for us to consider your eligibility for employment.

Name, mailing address, email address, phone number, demographic information

 

To fulfill any other purpose for which you provide it or for which you have given us consent to use it.


How We Use Automatically Collected Information:

The information we collect automatically is statistical data and generally does not contain personal information. However, we may maintain it or associate it with personal information we collect in other ways or receive from third parties. We will use this automatically-collected information to improve our Websites and to deliver a better and more personalized service, including to:

  • Estimate our audience size and usage patterns;

  • Store information about your preferences, allowing us to customize our Sites according to your individual interests;

  • Speed up your searches; and

  • Recognize you when you return to our Sites.

Cookies

In order to enhance your experience on our Websites, we use "cookies". Cookies are small text files that we place in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personal information unless you choose to provide this information to us by, for example, registering at our Websites. Once you choose to provide a web page with personal information, this information may be linked to the data stored in the cookie. A cookie is like a unique identity card. It is unique to your computer and can only be read by the server that gave it to you.

We use cookies to understand site usage and to improve the content and offerings on our Websites. For example, we may use cookies to personalize your experience on our web pages (e.g. to recognize you by name when you return to our Websites). We also may use cookies to offer you services.

Cookies save you time as they help us to remember who you are. Cookies help us to be more efficient. We can learn about what content is important to you and what is not. If you are concerned about cookies, you can turn them off in your browser.

We want to be completely transparent about the cookies we use and to make their control as easy as possible for you. When you first enter our Websites, you will be asked to accept or reject cookies via the Cookie Notice. If, after your initial visit to the Site, you decide to change your cookie selection, you can do so by visiting the Cookie Notice, available at https://www.zensar.com/cookie-policy. As outlined in the Cookie Notice, certain cookies are necessary for the functioning of the Websites and cannot be rejected.

Further, if you want to delete any cookies that are already on your computer, please refer to www.allaboutcookies.org, which contains information related to deleting and controlling cookies. Further, the following links explain how to block cookies in your browser:

Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site.

Disclosure and Onward Transfer of Information

We will not rent or sell your personal information to any company or organization. Nor will Your Personal Information be licensed or disclosed to unaffiliated third-parties, except in connection with the sale, transfer, merger, consolidation or other transaction involving all or part of our company or as may be permitted under applicable law.

We may provide your personal information to our subsidiaries and affiliates. We may provide your personal information to vendors and service agencies that we may engage to assist us in providing the Websites and/or our Services to our clients, or to assist us in verifying your eligibility for employment with Zensar. Such third parties will be restricted from further distributing your personal information and must enter into a written confidentiality agreement with us.

In addition to the above, we may be required to disclose your information to (i) comply with laws or to respond to lawful requests and legal process (including to respond to requests from public or government authorities, including public or government authorities outside your country of residence), (ii) to investigate, prevent, or take action regarding illegal or suspected illegal activities, (iii) to protect the rights and property of Zensar, and others to enforce our agreements, and this Privacy Notice and the Terms of Use, including to protect the security or integrity of the Websites or our information systems, (iv) in an emergency to protect person or property, (v) as may be needed on a confidential basis to support a corporate transaction (including a merger, acquisition, divestiture, financing, or sale of assets or lines of business), or (vi) on an aggregated basis for any purpose in which your specific personal information is blinded, masked or otherwise not identifiable. We may also exchange information with third parties for fraud protection and credit risk reduction.

Links to Third Party Sites

The Websites may provide links to other web sites or resources over which Zensar does not have control (“External Web Sites”). Such links do not constitute an endorsement by Zensar of those External Web Sites. You acknowledge that Zensar is providing these links to you only as a convenience, and further agree that Zensar is not responsible for the content of such External Web Sites. Your use of External Web Sites is subject to the terms of use and privacy policies located on the External Web Sites.

Limiting the Use of Personal Information Collected Through the Site and Services

You may be permitted to limit our use of personal information collected through our Websites by following the instructions at the bottom of each email we send you, or by contacting us at dpo@zensar.com. If your personal information is provided to us through a third-party or client, you can limit our use of certain of that personal information by managing your account at the respective client with whom you interact.

Geographic Location of Data Storage and Processing

The Websites collect information and process and store that information in a variety of geographic locations, including the United States, Europe and India. If you are visiting the Websites, you should be aware that you may transfer personally identifiable information about yourself to another country and/or region, and that the data protection laws of that country and/or region may not be as comprehensive as those in your own country. By visiting the Websites and submitting any personally identifiable information you consent to the transfer of such personally identifiable information to the United States and India.

Additional information for international visitors can be found below.

Reviewing, Correcting and Deleting Personal Information Collected Through the Site

Zensar provides you with the ability to request to review, correct, and delete your personal information that we have received if it is inaccurate or you wish us to delete it in certain circumstances. As necessary, Zensar will retain a copy in its files of all personal information, even if corrected, to resolve disputes.

Zensar retains personal information you submit through our Websites as required under applicable regulatory, tax, insurance or other legal requirements in the places in which it operates. Zensar thereafter deletes or anonymizes such information in accordance with applicable laws.

You have the ability to request to review or delete the foregoing information, by contacting Zensar at:

Data Protection Officer

C/o Legal Department
Zensar Technologies, Inc. 
2 Research Way, First Floor
Princeton, NJ  08540 USA

Email: dpo@zensar.com

Special Information for California Residents

The California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws provides California residents (i.e., consumers) with specific rights regarding personal information. This section of the Privacy Notice describes those CCPA rights and how to exercise those rights. This section does not apply to publicly available information.

Access to Specific Information and Data Portability Rights

California residents have the right to request that Zensar disclose certain information to you about Zensar’s collection and use of your personal information over the past twelve (12) months. Once Zensar receives and confirms a verifiable consumer request from you, Zensar will disclose to you, to the extent permitted by law:

  • The categories of personal information Zensar collected about you.

  • The categories of sources for your personal information Zensar collected about you.

  • Zensar’s business or commercial purpose for collecting your personal information.

  • The categories of third parties with whom Zensar shares your personal information.

  • If we disclosed your personal information for a business purpose, the personal information categories that each category of recipient obtained.

You shall have the right to request that the information described above be provided to you in a portable and readily useable format, to the extent technically feasible (“data portability”).

Zensar does not sell your personal information.

Deletion Request Rights

You have the right to request that Zensar delete certain of your personal information that Zensar collected from and/or related to you and retained, subject to certain exceptions.

To the extent that Zensar can delete your personal information, once Zensar receives and confirms your verifiable consumer request, Zensar will delete (and direct our service providers to delete) your personal information, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which we collected your personal information, provide a good or service that you requested, or take actions reasonably anticipated within the context of our ongoing business relationship with you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Debug products to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  • Comply with a legal obligation.

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Your Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Zensar by either:

  • Contacting us at dpo@zensar.com; or

  • Calling Zensar, at +91-20-66074000; or

  • Calling Zensar, at +1 866 665 3757 (toll free)

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows Zensar to reasonably verify you are the person about whom Zensar collected personal information or an authorized representative.

  • Describe your request with sufficient detail that allows Zensar to properly understand, evaluate, and respond to it.

Zensar cannot respond to your request or provide you with your personal information if Zensar cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. Any disclosures provided pursuant to the CCPA will only cover the 12-month period preceding the receipt of the verifiable consumer request.

Zensar will respond to a verifiable consumer request within 45 days of its receipt, or notify you that Zensar requires more time to respond and the reason for the extended response time. Zensar will deliver its written response by mail or electronically, at your option.

To the extent that your verifiable consumer request is excessive, repetitive, or manifestly unfounded, Zensar may charge a reasonable fee to respond to such request.

Zensar will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, Zensar will not:

  • Deny you goods or services.

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  • Provide you a different level or quality of goods or services.

  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Special Information for EU Users

The processing of personal data of users in the European Union (“EU”) is subject to the EU General Data Protection Regulation (“GDPR”). This section provides information as relates to EU users' rights, and Zensar's responsibilities, under this regulation.

1. EU User Rights

If you are a Zensar user in the EU, you have the following rights with respect to Zensar's handling of your personal information. To exercise these rights, please see below.

Users outside the EU may also request explanation, correction, deletion or copies of their personal data, as described above in this Privacy Notice.

Explanation and copies of your data

  • You have the right to request an explanation of the personal information that Zensar has about you and how Zensar uses that information.

  • You also have the right to receive a copy of the personal information that Zensar collects about you if collected on the basis of consent or because Zensar requires the information to provide the services that you request.

Correction

  • If Zensar has personal information about you that you believe is inaccurate, you have the right to request correction of your personal information. Please see below for more information on correcting, or requesting correction of, your information.

Deletion

  • You may request deletion of your personal information at any time. We may retain certain information about you as required by law and for legitimate business purposes permitted by law. Please see the “Reviewing, Correcting and Deleting Personal Information Collected Through the Site” section above for more information regarding Zensar's retention and deletion practices.

Objections and complaints

  • Users in the EU have the right to object to Zensar's processing of personal information, including for marketing purposes based on profiling and/or automated decision making. Zensar may continue to process your information notwithstanding the objection to the extent permitted under GDPR.

  • Users in the EU also have the right to file a complaint relating to Zensar's handling of your personal information with the UK Commissioner’s Office (ICO), the UK Data Protection Authority. Their contact information is as follows:

Information Commissioner’s Office

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113

You may also submit questions, comments or complaints to Zensar's Data Protection Officer, at dpo@zensar.com.

2. Grounds for Processing

The GDPR requires that companies processing the personal information of EU users do so on the basis of specific legal grounds. As described below, Zensar processes the information of EU users based on one or more of the grounds specified under the GDPR:

  • The processing is necessary for Zensar's legitimate interests

  • Zensar collects and uses personal information to the extent necessary for its legitimate interests. This includes collecting and using information:

    • To understand how people use our products and services.

    • To perform background checks necessary to verify employment eligibility.

    • To provide customer support.

    • To optimize our service and develop new services.

    • For research and analytical purposes.

    • For direct marketing purposes. This includes, for example, analysing data to identify trends and tailor marketing messages to user needs.

  • The processing is necessary to fulfill Zensar's legal obligations

  • Zensar may process your personal information when we have a legal obligation to do so, for example, if we’re responding to a legal process or an enforceable governmental request.

  • Zensar may collect and use your personal information on the basis of your consent. You may revoke your consent at any time. If you revoke your consent, you will not be able to use any service or feature that requires collection or use of the information we collected or used on the basis of consent.

3. Exercising Your Data Rights

To exercise the data rights described above, please submit a request to Zensar by contacting us at dpo@zensar.com.

Only you or a person authorized to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child.

Zensar cannot respond to your request or provide you with your personal information if Zensar cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a data rights request does not require you to create an account with us. We will only use personal information provided in a data request to verify the requestor's identity or authority to make the request.

Zensar will respond to a request within 30 days of its receipt, or notify you that Zensar requires more time to respond and the reason for the extended response time. Zensar will deliver its written response by mail or electronically.

Special Information for Citizens of South Africa

The processing of personal information of users in South Africa (“SA”) is subject to the Protection of Personal Information Act (“POPIA”). POPIA is intended to promote the right to privacy in South Africa’s Constitution, while at the same time protecting the flow of information and advancing the right of access to and protection of information. This section provides information as relates to South African users' rights, and Zensar's responsibilities, under the Act.

For detailed information about your rights under POPIA, please follow this link to read Zensar’s Promotion of Access to Information Act (“PAIA”) Manual, which provides more information about your rights and how you can exercise them.

POPIA establishes eight conditions for the collection and processing of your personal information. Those conditions are:

  • Accountability: This condition makes it a requirement for all responsible parties to comply with the other seven conditions for processing. Zensar’s Information Officer ensures accountability by promoting compliance with the Act within Zensar, handling information requests from citizens, co-operating with the Information Regulator if there is an investigation or query and taking such other measures as may be prescribed by applicable laws.

  • Limitations on processing: This condition is aimed at ensuring that processing of personal information is as limited as possible, with reference to the purpose for which it is processed. It requires that processing must be done in a lawful and reasonable manner, which does not unreasonably infringe on your privacy. Also, the extent of the personal information that is processed must be limited to such information as is relevant, adequate and not excessive in relation to the reason for processing the information. Personal information may be processed if necessary in order to provide a service to a data subject, or if they consent to its processing. The data subject may withdraw this consent, but it may then become impossible to provide them with services. Lastly, as far as reasonably possible, personal information must be collected directly from the data subject to whom it pertains and not from third parties, although this is subject to other applicable laws, which may require verification with third parties.

  • Reasons for processing: This condition relates to the purpose for which personal information is being processed. Zensar processes your personal information in accordance with this notice as described above.

  • Quality of information: Zensar is required to take “reasonably practicable” steps to ensure that the information it processes is complete, accurate, not misleading and updated where necessary, with reference to the purpose for which the information is being processed.

  • Notices and communication: This condition relates to Zensar’s communication and notifications to you, which helps you to understand what your information is being used for and how to exercise your rights in respect of your information.

  • Security: Zensar is required to take “appropriate, reasonable technical and organizational measures” to prevent loss, damage, unauthorized destruction and unauthorized access to or processing of personal information.

  • Participation: This condition relates to your rights to access personal information about you and to request corrections, deletion or destruction thereof.

Your Rights

In terms of Sections 23 and 24 of POPI, you have the following rights:

Access and Explanation

  • You have the right to request an explanation of the personal information that Zensar has about you and how Zensar uses that information.

  • You also have the right to receive a copy of the personal information that Zensar collects about you if collected on the basis of consent or because Zensar requires the information to provide the services that you request.

Correction

  • If Zensar has personal information about you that you believe is inaccurate, you have the right to request correction of your personal information. Please see below for more information on correcting, or requesting correction of, your information.

Deletion

  • You may request deletion of your personal information at any time. We may retain certain information about you as required by law and for legitimate business purposes permitted by law. Please see the “Reviewing, Correcting and Deleting Personal Information Collected Through the Site” section above for more information regarding Zensar's retention and deletion practices.
     

Objections and Complaints

  • Users in South Africa have the right to object to Zensar's processing of personal information, including for marketing purposes based on profiling and/or automated decision making. Zensar may continue to process your information notwithstanding the objection to the extent permitted under POPIA.

  • Users in the South Africa also have the right to file a complaint relating to Zensar's handling of your personal information with the Information Regulator. Their contact information is as follows:

Information Regulator

33 Hoofd Street
Forum III, 3rd Floor Braampark
Braamfontein, Johannesburg
inforeg@justice.gov.za

Exercising Your Rights

To exercise any of your rights, or to make any inquiries regarding your personal information, please follow the procedure described in Section 9 of Zensar’s PAIA Manual, available at Zensar-PAIA-Manual

Commitment to meet compliance 

Zensar is a responsible organization and it is our commitment to meet all applicable data protection and privacy laws of countries where we operate in. We meet our commitment by implementing appropriate security and privacy controls within our business processes, IT operations and at locations either operated by us or by 3rd party vendors on our behalf.

Security

We employ procedural and technological measures that are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction. Zensar uses Transport Layer Security, firewalls, password protection and takes other physical and logical security measures and places internal restrictions on who within Zensar may access your data to help prevent unauthorized access to your personally identifiable information. Our security is annually audited by a third party, under the ISO27001:2013 standard, SSAE18 SOC2 and SOC3 and additionally to comply with the PCI-DSS version 3.2 for specific client Services.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for keeping that password confidential. We ask you not to share your password with anyone. You also acknowledge that your account is personal to you and agree not to provide any other person with access to these Websites or portions of it using your user name, password or other security information. You agree to notify us immediately of any unauthorized access to or use of your user name or password or any other breach of security.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, as described above, we cannot guarantee the security of your personal information transmitted to our Websites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites.

Data storage 

As a security best practice and to meet various geographic regions’ local data protection regulations where we operate our business, Zensar does not store either its customer or any third parties data within its IT environment, unless it is explicitly agreed upon and necessary contractual documents are signed to perform such activities or prior consent is obtained from data subjects.  

Privacy breach handling and disciplinary actions thereon 

Any violations leading to breach of privacy of individuals will be appropriately investigated, primary cause of the breach is identified, and mitigation measures are quickly implemented. These measures may include fixing of gaps by updating hardware or software within the IT systems holding personal data, securing communication channels traversing data and/or initiating disciplinary actions against the employees or persons processing personal data in an unauthorized manner causing the breach or security incident and retraining such persons on data security measures.

Children’s Privacy

Zensar recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. The Site is not intended for children under the age of 13. Zensar does not target the Site to children under 13. Zensar does not knowingly collect personal information from children under the age of 13.

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

Data Protection Officer

Zensar Technologies Ltd.
Zensar Knowledge Park
Kharadi, Plot #4, MIDC, Off Nagar Road
Pune 411 014, India
Email: dpo@zensar.com

Privacy Notice Updates

Due to the Internet’s rapidly evolving nature, Zensar may need to update this Privacy Notice from time to time. As such, we reserve the right to amend this Privacy Notice at our discretion and at any time.

Zensar will post a notice of the change and the updated Privacy Notice on our Site located at. We may also send registered visitors of the Site e-mail notifications notifying such visitors of any changes to the Privacy Notice.

If any change is unacceptable to you, you have the right to cease using these Websites. If you do not cease using these Websites, you will be deemed to have accepted Zensar’s then current Privacy Notice.

Contacting Us

If you have any questions regarding this Privacy Notice please contact us via e-mail at: dpo@zensar.com.