This Notice applies to the following NTT Communications Corporation Group companies in India:
1. Netmagic Solutions Private Limited (“NSPL”)
2. Netmagic IT Services Private Limited (“NMIT”)
The above-mentioned companies are herein collectively referred to as “Netmagic”.
This Notice applies to all individuals who access our website (“Website”), to all customers of Netmagic (“Customers”), to all vendors of Netmagic (“Vendors”), to all individuals who participate in our recruitment activities, events, or promotional events, and to all individuals and/ or stakeholders involved in any transaction with Netmagic.
‘Personal data’ in this Notice refers to any information that tells us something about you or that we can link to you. This includes your name, address, date of birth, account number, IP address or information about payments you’ve made from your bank account and such other specific and identifiable information, which otherwise is not available in public domain. By ‘processing’ we mean everything we can do with this data such as collecting it, recording, storing, adjusting, organising, using, disclosing, transferring or deleting.
PERSONAL DATA WE MAY COLLECT
When you visit our Website
The personal data that we may collect about you when you visit our website broadly fall into the following categories:
Information that you provide voluntarily
We collect personal data that you provide voluntarily through our Website, for example when completing online forms to contact us or register for events that we are organising. The information we collect about you may include some or all of the following:
- Name and job title
- Age and gender
- Company or organisation
- Contact information, including email address and telephone number(s)
- Demographic information such as postcode, preferences, and interests
- Other information relevant to client surveys or similar research
- Information pertinent to fulfilling our services to you; and
- Any other personal data that you voluntarily choose to provide to us
If we ask you to provide any other personal data not described above, the personal data that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point that you are asked to provide your personal data.
Information that we collect automatically
When you visit our Website, we may collect certain personal data automatically from your device.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification number, browser type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.
Some of this information may be collected using cookies and similar tracking technology, as explained further in our Cookie Notice.
When you engage our services (“Customer”)
When you engage us to provide you with services, we collect and use personal data which is necessary for the performance of those services or is of our legitimate interest. The majority of the personal data we collect and use to provide our services is supplied voluntarily by (or collected by us from third-party sources at the request of) our Customers.
When we engage you to provide us with services (“Vendor”)
When we engage to provide us services, we collect and use personal data which is necessary for the performance of those services and administrative tasks or is our legitimate interest.
When you participate in our recruitment services
We collect information from and about candidates in connection with available employment opportunities at Netmagic.This information may include CVs, identification documents, academic records, work history, employment, and references.
Netmagic uses your personal data to match your skills, experience, and education with the specific roles offered by the firm. This information is passed to the relevant hiring managers and persons involved in the recruitment process to decide whether to invite you for an interview. Netmagic will collect further information from you if you are invited to the interview (or equivalent) stage and onwards.
In connection with our recruitment activities, we may also collect special categories of personal data from candidates where we have an employment law obligation to do so, the information is relevant to their future working environment at Netmagic or the future provision of employment benefits, or with the individual's explicit consent.
Netmagic may collect personal data about candidates from the following sources:
- Directly from you – for example, information that you have provided when applying for a position directly through the firm's recruitment website;
- From recruitment agencies – for example, when a recruitment agency contacts us to identify you as a potential candidate;
- Through publicly available sources online – for example, where you have a professional profile posted online (e.g. on your current employer's website, or on a professional networking site like LinkedIn); and
- By reference or word of mouth – for example, through a referred from former employee/employer or from a referee you have identified.
LAWFUL BASIS FOR PROCESSING PERSONAL DATA
Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it.
However, we will normally collect personal data from you only where we need the personal data to perform a contract with you (for example, when providing our services), comply with a legal requirement or to perform a contract with you or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to process personal data about you or may need to process personal data in order to exercise, establish or defend legal claims.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal data (including any legitimate interests relied upon), please send an email to DPO@netmagicsolutions.com.
USE OF PERSONAL DATA
We generally use the information to establish and enhance our relationship with our users for the following purposes:
- Communication: We may use your information to administer and provide services you request or have expressed an interest in, to communicate with you in case of customer support, to process transactions, for sending newsletters, updates and promotional materials, for seeking your opinion and feedback and personalize and/or tailor any communications that we may send you.
- Advertising: We may use your information to carry out advertising and market research based on behavioural metrics, geo-location data, demographic data, and marketing preferences we capture. We may permit certain third party companies to help us tailor advertising based on use.
Activity Tracking: We may use your information to track your activity on our digital platforms and personalize and improve your experience. This can be used to create an individual profile for you so that we can understand and respect your preferences or for profiling purposes to enable us to personalize and/or tailor any marketing communications that you may consent to receive from us.
Optimization: We may use your information to operate, improve and maintain our site, to prevent fraud and abuse.
Information Sharing: We may use and share your information with third parties with whom we have a contractual relationship. For example, we may provide you with a link where you may share your content with another person.
Contracted services: We may collect your information for the purpose of providing contracted services to you.
Recruitment: We may collect and use personal data to help assess your skills and your suitability for the relevant job position you apply for. We may also use such data to contact you if we believe a specific job position may interest you. Such information may include your name, email address, CV, telephone number, profile photo, job history and other relevant information. Consequently, we may use your personal data in relation to the evaluation and selection of candidates including but not limited to setting up and conducting interviews and tests, evaluating and assessing the results thereto and as is otherwise needed in the recruitment processes, including the final recruitment.
DISCLOSURE OF YOUR PERSONAL DATA
We share your personal data, in the following circumstances:
- With our subsidiary undertakings and/or affiliates for the purposes of providing you with our services as described in this Privacy Notice.
- with third parties including certain service providers we have retained in connection with the services we provide, such as consultants, experts, evaluation services, couriers, or other necessary entities;
- on a confidential basis with third parties for the purposes of collecting your feedback on the firm’s service provision, to help us measure our performance and to improve and promote our services;
- with courts, law enforcement authorities, regulators, government officials or attorneys or other parties where it is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process;
- with service providers who we engage within or outside of Netmagic, domestically or abroad, e.g. shared service centres, to process personal data for any of the purposes listed above on our behalf and in accordance with our instructions only;
- if we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets to whom we assign any of our rights and obligations.
SECURITY: HOW SECURE IS YOUR PERSONAL DATA WITH US
We use appropriate technical and organisational measures to protect the personal data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data.
HOW LONG WE KEEP YOUR PERSONAL DATA
Netmagic will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.
YOUR PRIVACY RIGHTS AND WHOM TO CONTACT
We will respect your legal rights in relation to your personal data as per laws of India.
Below are the rights granted to EU residents as per GDPR and we are also committed towards protection of the same in terms of this Privacy Notice to the extent we are notified of GDPR applicability to you:
- Right to access copies of the information we hold about you at any time. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
Right to rectify your personal data if it is inaccurate or incomplete.
Right to erasure by requesting that we delete or remove your personal data from our system
Right to restrict our use of your personal data, that is, the right to "block" us from using your personal data or limit the way in which we can use it
Right to data portability by requesting that we move, copy or transfer your personal data
Right to object to our use of your personal data including where we use it for our legitimate interests
Right to withdraw consent if we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time.
All the above-mentioned rights can be exercised by contacting our Data Protection Officer (DPO) at DPO@netmagicsolutions.com.
CHANGES TO THE NOTICE
This Notice is effective as of May 25, 2018. We reserve the right to update or change this notice at any time, and we will provide you with the updated Notice when we make any substantial updates at the earliest either through email or by providing a prominent notice of the change on the website. You should check the Notice periodically.