Privacy Policy

Effective Date: 15th April 2020

This policy applies to Accute IT Solutions Pvt Ltd

Accute IT Solutions Pvt Ltd understands that user’s privacy is essential so we are committed to safeguarding the confidentiality and privacy of personal information.

This Privacy Policy describes how Accute IT Solutions Pvt Ltd protects your personal information in connection with the hosting of this website, and the data related you your interest.

Scope of this policy

This policy applies to personal information which is collected and/or used by Accute IT Solutions Pvt Ltd in its capacity as a controller as that term is defined in the Indian Personal Data Protection Bill, 2018. The contexts in which this might occur are explored under “When do we collect personal information” below. When we provide Services to clients, we sometimes handle personal information as a processor. This means that we process the information solely on the instructions of our clients, who retain control of the information. Therefore, if our use of your personal information is not covered by this policy, you may need to contact the client (and controller) on whose behalf the processing of your information is carried out.

Quick read

Accute IT Solutions Pvt Ltd collects personal information from and on behalf of its clients (e.g. about their employees and customers) to provide business advisory and other services to those clients. It also processes client personal information to manage its relationship with those clients. Further, Accute IT Solutions Pvt Ltd also collects some personal information from visitors to this website, recruitment applicants, and attendees at Accute IT Solutions Pvt Ltd events.

Accute IT Solutions Pvt Ltd uses personal information to deliver its Services to clients. For its own purposes, it also uses personal information to analyse and improve how it delivers those services, to contact representatives of its clients or prospective clients and to market to them, and to administer recruitment and events.

If Accute IT Solutions Pvt Ltd uses your personal information, you may have certain important rights which you can exercise. The rights you will be able to exercise will depend on how and why Accute IT Solutions Pvt Ltd your information.

The primary point of contact at Accute IT Solutions Pvt Ltd for questions regarding your personal information is info@accuteitsouutions.in

Who is your controller?

The Accute IT Solutions Pvt Ltd entity responsible for your personal information will be the entity that originally collected information from or about you. If you have a direct interaction with Accute IT Solutions Pvt Ltd (for example, you attend an Accute IT Solutions Pvt Ltd hosted event), the identity of your controller may be disclosed to you in connection with that interaction. If we process your personal information in the course of providing our Services to clients, your controller will be the ABS entity providing the Services (assuming those Services are provided as a controller, see above for an explanation). Please note that the contact details for all ABS entities in respect of data protection or privacy issues are the same, and are as set out below.

Your Acceptance

In respect of personal information collected over this and other Accute IT Solutions Pvt Ltd websites, your continued use of these websites constitutes your understanding of, and agreement to, the practices described in this Privacy Policy and elsewhere on the websites as well as any subsequent updates. Please see the additional information under the heading [Legal] for more information about our online terms of use and policies in general.

When do we collect personal information?

We collect information about you if:

• you use this (or any other Accute IT Solutions) website;
• you enquire about, or engage Accute IT Solutions Pvt Ltd to provide, its Services (either in a personal capacity, or as a representative for your employer or client);
• the use of your personal information is reasonably necessary to provide our Services (in these circumstances, your personal information may be disclosed to us by our client who may, for example, be your employer or service provider, or we may obtain your personal information from a range of public or subscription sources, directly from you, or from your associates or persons known to you);
• you apply for a position with Accute IT Solutions Pvt Ltd;
• you attend an Accute IT Solutions Pvt Ltd hosted or sponsored event or webinar;
• you contact us with any other enquiry, complaint or notice.

What types of personal information are collected and what do we use it for?

The following is a summary of the types of personal information we collect, and the purposes for which that information is used.

Website Users

Accute IT Solutions Pvt Ltd collects your name, address, e-mail address, telephone number and any other personally-identifiable information which you voluntarily provide as “comments” when you submit an inquiry through the “Contact Us” tool or sign-up forms or other opt-in forms. Accute IT Solutions Pvt Ltd also collects other background information about you in connection with career-related inquiries that you submit through its website.

Accute IT Solutions Pvt Ltd may also automatically collect personal information (through the use of Cookies or similar technologies, including your IP address, device identifier, browsing patterns on its websites, clickstream data, and HTP protocol elements) to ensure the effective operation of the website or in order to align the presentation of our Services more closely to your requirements (for example, processing information about your broad geographic location to serve you with a local version of this website). This tracking information is stored in an anonymous, aggregated and non-personal format, and is also used to understand and analyze trends, to administer the websites, and to learn about user behavior on the websites.

Please refer to our Cookie Policy for a more detailed overview on how Accute IT Solutions Pvt Ltd uses Cookies.

In certain instances, Accute IT Solutions Pvt Ltd may use IP addresses to help identify you when Accute IT Solutions Pvt Ltd feels, in its sole discretion, that it is necessary to enforce compliance with this Privacy Policy, to protect its services, websites, systems, information, employees, business partners, subsidiaries, affiliates, users, customers or others, or when required by law or for law enforcement purposes.

Accute It Solutions’s Former, Current and Prospective Clients

If you submit an enquiry to Accute IT Solutions Pvt Ltd about our Services (either over the website, or by emailing, telephoning or meeting with one of our colleagues), then we will process information such as your name, job title and contact information in order to respond to your enquiry.

If you attend an Accute IT Solutions Pvt Ltd event or webinar, or if you associate with an Accute IT Solutions Pvt Ltd colleague at, for example, an industry event, then Accute IT Solutions Pvt Ltd may collect basic personal information, such as contact details, which you voluntarily provide (for example, by filling in a form or handing over a business card) in order to facilitate your participation in the event, and for the management of our relationship with you as an actual or prospective client.

If you or the organisation you are associated with becomes an Accute IT Solutions Pvt Ltd client, then we may process your personal information in order to:

• carry out “Know Your Client” checks and screening prior to starting a new engagement (as well as basic contact information, this may mean processing compliance related information such as proof of your identity, information about your professional background, history of directorships and, in some circumstance, details of any criminal convictions or adverse media coverage);
• carry out background checks for the purposes of complying with anti-money laundering and terrorist financing laws;
• carry out client communication, service, billing and administration; deal with client complaints; and administer claims.
• Taking account of applicable marketing laws, we also process personal information about our clients (former, current and prospective) in order to:
• send our clients newsletters, know-how, promotional material and other marketing communications;
• invite our clients to events (and arrange and administer those events).

Performing Services for Our Clients

As discussed above, many of our Services involve the processing of personal information. In the majority of cases, personal information is provided to us in strict confidence, subject to restrictive undertakings on its use / disclosure.

Illustrative examples of the use of personal information in connection with our Services, and the legal bases we rely upon for using personal information, are set out in Annex 1 (Use of Personal Information for our Services).

Other Uses

If you apply for a position with Aero Business Solutions, we will need to collect personal information in order to consider your application, and during any interview and assessment phase.

If you enquire about, or decide to purchase stock in Aero Business Solutions, then we will collect (either from you or from your broker / investment manager) basic personal information required to register you as a stockholder.

Finally, if you contact us for any other reason, we will collect basic contact details, as well as any other personal information relevant to the reason for your enquiry, in order to resolve that enquiry.

What is our legal basis for collecting personal information?

All processing (i.e. use) of your personal information is justified by a “lawful basis” for processing. In the majority of cases, processing will be justified on the basis that:

• The processing is necessary for the performance of a contract to which you are a party, or to take steps (at your request) to enter into a contract (e.g. where you request certain Services as an individual client, or where we help advise your employer or service provider on fulfilling an obligation to you under a contract);
• the processing is necessary for us to comply with a relevant legal obligation (e.g. where we are required to collect certain information about our clients for tax or accounting purposes, or where we are required to make disclosures to courts or regulators); or
• the processing is necessary for the performance of a task carried out in the public interest (e.g. background checks for anti-money laundering and terrorist financing purposes); or
• The processing is in our legitimate interests, subject to due consideration for your interests and fundamental rights (this is the basis we rely upon for the majority of the processing of personal information in connection with the provision of our Services, and also for the purposes of most client on-boarding, administration and relationship management activities). In limited circumstances, we will use your consent as the basis for processing your personal information, for example, where we are required by applicable law to obtain your prior consent in order to send you marketing communications.
• Before collecting and/or using any special categories of data (as that term is defined in the GDPR), or criminal record data, we will establish a lawful exemption which will allow us to use that information. This exemption will typically be:
• your explicit consent;
• the establishment, exercise or defence by us or third parties of legal claims; or other uses allowed by applicable law including context specific exemptions provided for under local laws of EU Member States and other countries implementing the GDPR, such as in relation to the processing of special category data for the purposes of preventing or detecting fraud in relation to instructions from potential clients.

Disclosure of Personal Information to Third Parties

• Accute IT Solutions Pvt Ltd will not disclose your personal information to third parties other than as described in this Privacy Policy unless Accute IT Solutions Pvt Ltd has your permission or is required or permitted by law. Accute IT Solutions Pvt Ltd may share such information with its affiliates as necessary to carry out the purposes for which the information was supplied or collected. Similarly, third party contractors, consultants and/or vendors engaged by Accute IT Solutions Pvt Ltd to provide services may have access to your personal information. These third parties will be subject to their own data protection requirements providing the same or greater level of security provided by Accute IT Solutions Pvt Ltd and in most instances will also have entered into a written agreement with Accute IT Solutions Pvt Ltd which addresses the protection of your personal information.

Accute IT Solutions Pvt Ltd may also disclose your personal information for the purposes of:

• responding to requests from law enforcement agencies, regulators or courts, or to subpoenas, search warrants, or other legal requests;
• The prevention and/or detection of crime;
• establishing legal rights or to investigate or pursue legal claims; a merger, acquisition or corporate restructuring to which Accute IT Solutions Pvt Ltd is subject; preventing risk of harm to an individual.

International Hosting and Transfer of Information

• Accute IT Solutions Pvt Ltd is a global organization and may transfer certain personal information collected on its websites across geographical borders to Accute IT Solutions Pvt Ltd offices, personnel, or third parties located throughout the world. Accute IT Solutions Pvt Ltd may also store such information in a jurisdiction other than where you are based.
• Accute IT Solutions Pvt Ltd will take appropriate steps ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights. To this end:
• Where we transfer your personal information outside Accute IT Solutions Pvt Ltd to third parties who help provide us with any of the activities described in this policy, we obtain contractual commitments (such as the Standard Contractual Clauses) from them in order to protect your personal information.
• Where we receive requests for information from law enforcement, courts or regulators (who may be based overseas), we carefully validate these requests before any personal information are disclosed.
• You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.

Information Security

Accute IT Solutions Pvt Ltd has reasonable technical safeguards, security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Measures we take include placing confidentiality requirements on our staff members and service providers, limiting access to your personal information on a “need to know” basis, and providing training to appropriate Accute IT Solutions Pvt Ltd personnel. We also maintain comprehensive policies addressing data incident response protocols.

Despite Accute It Solution’s best efforts, however, security cannot be absolutely guaranteed against all threats.

Retention of your personal information

Accute IT Solutions Pvt Ltd retains your personal information for the period of time required for the purposes for which it was collected, any compatible purposes which we subsequently establish, or any new purposes to which you subsequently consent, or to comply with legal, regulatory and Accute IT Solutions Pvt Ltd policy requirements. This period of time will usually be the period of your, or the relevant client’s, relationship or contract with Accute IT Solutions Pvt Ltd plus a period reflecting the length of time for which legal claims may be made following the termination of such relationship or contract. Some information (such as call recordings, tax records and certain information required to demonstrate regulatory compliance) may need to be kept for longer. Personal information will be kept for a shorter or longer period of time if so required by law or an Accute IT Solutions Pvt Ltd policy, if the information becomes subject to a legal hold (for example, following a communication from our regulator) or if we have identified through a data protection impact assessment that a different retention period is appropriate.

Right to Access

You have the right to access personal information which Accute IT Solutions Pvt Ltd holds about you, together with certain information about how and why your personal information is processed

Right to Rectification

You have a right to request us to correct your personal information where it is inaccurate or out of date.

Right to be Forgotten (Right to Erasure)

You have the right under certain circumstances to have your personal information erased. Your information can only be erased if it is no longer necessary for the purpose for which it was collected, and we have no other legal ground for processing the information.

Right to Restrict Processing

You have the right to restrict the processing of your personal information, but only where:

• its accuracy is contested, to allow us to verify its accuracy; or
• the processing is unlawful, but you do not want it erased; or
• it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
• you have exercised the right to object, and verification of overriding grounds is pending.

Right to Data Portability

You have the right to data portability, which requires us to provide personal information to you or another controller in a commonly used, machine readable format, but only where the processing of that information is based on (i) consent; or (ii) the performance of a contract to which you are a party. Please note that Accute IT Solutions Pvt Ltd rarely relies upon consent as a legal basis, and the performance of a contract basis will only be relevant to the extent that you, as an individual, are party to a contract with Accute IT Solutions Pvt Ltd or a client, and our use of your personal information is necessary for the performance of that contract.

Right to Object to Processing

You have the right to object to the processing of your personal information at any time, but only where that processing is based on our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Marketing

Accute IT Solutions Pvt Ltd may send you information related to its services, products and events that we believe are of interest to you. This information may be sent by post or via email. If at any point you no longer prefer to receive marketing communications from Accute IT Solutions Pvt Ltd you can (i) unsubscribe from Accute IT Solutions Pvt Ltd communications sent by email using a link provided in marketing emails sent from Accute IT Solutions; or (ii) contact us to exercise your right to prevent all forms of marketing (both post and email).

Children

Accute IT Solutions’s websites are not intentionally designed for or directed at children under the age of 13. It is Accute IT Solutions’s policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services.

Links

Accute IT Solutions Pvt Ltd websites may contain links to other sites, including websites maintained by Accute IT Solutions Pvt Ltd affiliates that are governed by other privacy policies that may differ somewhat from this one. Users should review the privacy policy of each website visited before disclosing any personal information. To the extent that Accute IT Solutions Pvt Ltd provides links to third party websites, such links do not constitute an endorsement, sponsorship, or recommendation by Accute IT Solutions Pvt Ltd of the third parties, the third party websites, or the information contained on those websites, and Accute IT Solutions Pvt Ltd is not responsible or liable for your use of such third party websites. Where appropriate you should review the privacy policies of any websites or applications before submitting personal information.