Privacy Policy
SCOPE
KEY DEFINITIONS
“Consent” means freely given, specific, informed, and unambiguous indication of the Data Subject’s wishes via a statement or by a clear affirmative action, signifying agreement to the Processing of Data.
“Data” means Personal Data, Sensitive Personal Data, Digitized Personal Data and any other data or information covered under the Regulation.
“Data Subject” means an identified or identifiable natural person or wherever applicable legal guardian or parents of Data Subject to whom the Data relates.
“Data Controller” means a person or organization who (either alone, or jointly, or in common) determines the purposes for which and the way any Data is to be Processed. For the purposes of this Policy, references to Data Controller shall mean references to Plugwork, its branch offices, subsidiaries, and its affiliates, where relevant.
“Data Processor” means a person or organization who Processes the Data on behalf of and under the instruction of the Data Controller.
“Policy” means this Privacy Statement and Cookie Policy.
“Process”, “Processes”, “Processed”, or “Processing” refers to any operation or set of operations which is performed on Data or on sets of 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.
“Profiling” means any form of automated processing of Data to evaluate certain personal aspects relating to a natural person, including but not limited to work performance, health, reliability, etc.
“Sell,” “selling,” “sale,” or “sold” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Data Subjects Data by the business to another business or a Third Party for monetary or other valuable consideration.
“Sensitive Personal Data” refers to such Data being defined as any information revealing an identified or identifiable natural person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and the processing of genetic information, biometric information for the purpose of uniquely identifying a natural person, Data concerning health, or information concerning an individual’s sex life or sexual orientation, and data relating to offenses, or criminal convictions, and includes information as may be prescribed under the Regulations. With respect to California residents, in addition to the preceding, the term also includes national origin or ancestry, sexual orientation, sex (including, gen-der, gender identity, and gender expression), pregnancy, childbirth and medical conditions related to same, age, physical or mental disability, veteran status, genetic information and citizenship.
“Regulations” means all applicable privacy laws and Regulations applicable in countries where Plugwork operates, as may be in force from time to time.
“Services” refers to services offered by Plugwork.
“Third-Party” means any person other than the Data Subject, the Data Controller, or any Data Processor or other person authorized to process Data for the Data Controller.
CORE PRIVACY PRINCIPLES
This Policy address the core data privacy principles to emphasize our commitment to Privacy:
- Lawfulness, Fairness, and Transparency – collect Data that is required for lawful purpose
- Limitations on Purposes of Collection, Processing, and Storage – clear purpose for which Data will be used
- Data Minimization and Accuracy – collect only that is necessary
- Data Security and confidentiality – secure and limit access to Data
- Data Storage Limits – consider the purpose when determining archiving
- Accountability – be responsible for Data collected
COLLECTION AND USE OF PERSONAL INFORMATION
WHAT INFORMATION DO WE COLLECT?
Plugwork may collect Data about You if you choose to provide it through any means including access and use of Plugwork’s websites, social media, physical and electronic/online documents, forms, etc.
The category of Data collected and processed will differ based on Your interaction with Plugwork and the purpose for which the Data is shared with Plugwork.
Plugwork Process three broad categories of Data:
Information Provided Directly By You – Data provided by customer/clients, business partners , vendors, prospective candidates, employees , website visitors’ information, collected via any and all modes and will include names, email, employment details, demographics, audio-visual information, video /audio recordings, including Your comments, feedback, correspondence etc.
Information Received from Third Parties – Data provided by potential employees, and other sources like recruitment agencies, referral program, LinkedIn profiles/URLs (or similar professional Data set). Additionally, Plugwork may collect certain Data points based on the categories of Data Subject and their relationship with Plugwork , other customer/ business partner and vendor referral.
Information Collected Automatically – In some instances, Plugwork and its service providers use Cookies, web beacons and other technologies to automatically collect certain types of information when You visit us online, as well as through emails exchanged. Plugwork may also collect IP addresses, login credentials, such as username and passwords, when You register for any Services. The collection of this information allows Plugwork to customize Your online experience, improve the performance, usability, and effectiveness of Plugwork’s online presence, and to measure the effectiveness of Plugwork marketing activities.
Cookie – A Cookie is a small data file containing a string of characters that is sent to Your computer when You visit a website. When You visit the website again, the Cookie allows that site to recognize Your browser and device. The length of time a Cookie will stay on Your computer or mobile device depends on whether it is a “persistent” or “session” Cookie. Session Cookies will only stay on Your device until You stop browsing. Persistent Cookies stay on Your computer or mobile device until they expire or are deleted.
In some instances, Plugwork and its service providers use Cookies, web beacons and other technologies to automatically collect certain types of information when You visit Plugwork online, as well as through emails that You may exchange with Plugwork.
The collection of this information allows us to customize Your online experience, improve the performance, usability, and effectiveness of Plugwork’s online presence, and to measure the effectiveness of our marketing activities.
Strictly Necessary Cookies – Some cookies are essential for You to be able to experience the full functionality of our site. These cookies are necessary for the website to function and cannot be switched off in our systems. Please note that without these cookies, our web site may not be displayed optimally, and some functions are no longer technically available. These cookies also enable services You have specifically asked for. For example, when you subscribe to one of our Internet Products, we use session cookies to signal that You are logged in so that You are able to use subscriber features of the website, and persistent cookies to provide automatic login.
Performance Cookies – These cookies collect anonymous information about how You use the website. Plugwork uses performance cookies for web analytics, which allow Plugwork to statistically monitor how people are using our website, to help us improve our online offerings as well as to test different design ideas for particular pages. Plugwork may work with independent measurement and research companies to perform these services for Plugwork, so some of these cookies may be set by a third-party company. You have a right to allow these cookies to be placed on Your browser. If You do not allow these cookies Plugwork will not know when You have visited Plugwork site and will not be able to monitor its performance.
Functionality Cookies – These cookies allow Plugwork website to remember choices You make to improve Your experience (such as Your unit of measurement preferences) and to provide enhanced, more personal features (such as information about Your browser and whether You have configured your website tools), and to improve response speed and efficiency by storing certainly frequently accessed information. You have a right to allow these cookies to be placed on Your browser. If you do not allow these cookies we will not know when You have visited our site and will not be able to provide You enhanced functionality and personalisation such as allowing the website to remember the choices, You make. On some pages of Plugwork site, third parties may also set their own anonymous cookies, for the purposes of tracking the success of their application or customizing the application for You. Plugwork cannot access these cookies, nor can third parties access the data in our cookies.
Advertising And Targeting Cookies – Subject to Your consent, Plugwork may use cookies to track the effectiveness of advertising purchased on third party sites, and to support our affiliate program by letting our affiliate sites know that a visitor to one of their sites later purchased a product or service on our site. Plugwork will process Data for the purpose of providing targeted advertisement to You on other websites based on Your visit to our websites and to monitor Your preferences on our website. Plugwork will also determine how effective its advertising efforts to You have been. You may provide your consent to ‘Targeting cookies’ via the cookie banner that will allow Plugwork to receive Your Data.
Plugwork also use cookies to assist in targeted advertising. Plugwork website’s advertisements may be displayed or served by a third party, and many of the advertisements You see on Plugwork website are generated by third parties.
Some Plugwork third-party advertisers use their own anonymous cookies to track how many people have seen a particular ad, or to track how many people have seen it more than once. The companies that generate these cookies have their own privacy policies, and Plugwork has no access to these cookies. These third-party ad cookies may be used by those third parties to anonymously target advertising to You on other websites, based on Your visit to our website.
Plugwork also set anonymous cookies on certain other sites that Plugwork advertises on. If You receive one of those cookies, Plugwork may then use it to identify You as having visited that site if You later visit Plugwork site and will serve targeted advertising based on this information.
Remarketing And Targeting Technologies – When You visit Plugwork web pages and consent to tracking cookies, Plugwork may recognize Your browser or terminal device (e.g., a so-called browser fingerprint), evaluate Your IP address, store, or read recognition features on Your terminal device (e.g., cookies) or gain access to individual tracking pixels. For this purpose, Plugwork would like to process the following Data categories:
- Visitor IP address;
- Visitor X-Forwarded For;
- Timestamp;
- Referrer;
- Page URL;
- Cookie ID
Plugwork can also use these individual features to recognize Your terminal device on Plugwork websites. Using this tracking technology, Plugwork may display advertisements on third-party websites to You based on the pages You visited on Plugwork website.
Important: Kindly note that Your consent provided through the selection of tracking cookies is voluntary. If You want to revoke Your consent at any time or update cookie configurations, You can adapt Your settings by re-opening the cookie banner.
IP Addresses – An IP address is a number assigned to Your computer whenever You access the internet. It allows computers and servers to recognize and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.
Consent to Use Cookies – Note that Your Consent provided for the selection of tracking Cookies is voluntary. However, if You reject cookies, certain products, offerings, features, or resources of our website (including certain Internet Products) may not work properly and You may experience some loss of convenience. You can withdraw Your Consent to the use of Cookies in the future and adjust Your cookie settings on Plugwork Cookie banner at any time.
To turn off targeting by advertisers, networks, or providers of analytics, You may use the opt-out by accessing the third-party links provided above.
In addition, You can also choose to customise your choices regarding cookies You want to accept. You may configure Your browser to accept all cookies or to alert You every time a cookie is offered by a website’s server. Most browsers automatically accept cookies. You can set Your browser option so that You will not receive cookies and You can also delete existing cookies from Your browser. Please be aware that some parts of the site will not function properly if you have disabled cookies.
The links below set out information about how to change Your browser settings for some of the most used web browsers:
- Google Chrome
- Mozilla Firefox
- Microsoft Internet Explorer
- Apple Safari
Some browsers, such as Chrome and Firefox, allow You to change Your settings to browse in ‘incognito’ mode, limiting the amount of data placed on Your system/ device and automatically deleting any persistent Cookies placed on Your system/ device when you finish Your browsing session.
To clear Cookies that have previously been placed on Your browser, You should select the option to clear Your browsing history and ensure that the option to delete or clear Cookies is included when You do so.
Use of Cookies – Cookies may be placed on Your computer or internet-enabled device whenever You visit us online. This allows the site to remember Your computer or device and serves several purposes.
On some of Plugwork web sites, a notification banner will appear requiring Your Consent to collect Cookies. If You do not provide Consent, Your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of Cookie referred to as “user-input” Cookies may still be required for necessary functionality. Such Cookies will not be blocked through this notification banner. Your selection will be saved in a cookie and valid for 90 days (about 3 months). If You wish to revoke Your selection, You may do so by clearing Your browser’s Cookies.
Although most browsers automatically accept Cookies, You can choose whether to accept Cookies via Your browser’s settings (often found in Your browser’s Tools or Preferences menu). You may also delete Cookies from Your device at any time. However, please be aware that if You do not accept Cookies, You may not be able to fully experience some of our web sites’ features.
Further information about managing cookies can be found in Your browser’s help file or through sites such as www.allaboutcookies.org
Other third-party tools and widgets may be used on Plugwork’s individual web pages to provide additional functionality. Use of these tools or widgets may place a Cookie on Your device to make its service easier to use and ensure Your interaction is displayed on Plugwork web pages properly.
Cookies themselves do not tell us Your email address or otherwise identify You personally. In Plugwork’s analytical reports, Plugwork may obtain other identifiers including IP addresses, but this is to identify the number of unique visitors to Plugwork web sites and geographic origin of visitor trends, and not to identify individual visitors.
By navigating on Plugwork web sites or entering Your login details to access areas reserved for registered users, You agree that Plugwork can place these Cookies on Your computer or internet-enabled device.
Google Analytics – Plugwork uses Google Analytics. More information about how Google Analytics used by Plugwork can be found here: http://www.google.com/analytics/learn/privacy.html
To provide website visitors with more choice on how their Data is collected by Google Analytics, Google has developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services.
Web Beacons – A web beacon is a small image file on a web page that can be used to collect certain information from Your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of Cookies previously set by the same server.
Plugwork or its service providers may use web beacons to track the effectiveness of third-party web sites that provide Plugwork with recruiting or marketing services or to gather aggregate visitor statistics and manage Cookies.
You have the option to render some web beacons unusable by rejecting their associated Cookies. The web beacon may still record an anonymous visit from Your IP address, but cookie information will not be recorded.
In some of Plugwork newsletters and other communications, Plugwork may monitor recipient actions such as email open rates through embedded links within the messages. Plugwork collects this information to gauge user interest and to enhance future user experiences.
Location-Based Tools – Plugwork may collect and use the geographical location of Your computer or mobile device. This location Data is collected for the purpose of providing You with information regarding Services which we believe may be of interest to You based on Your geographic location, and to improve our location-based Services.
Social Media Widgets and Applications – Plugwork web sites may include functionality to enable sharing via third-party social media applications, such as the Facebook Like button and Twitter widget. These social media applications may collect and use information regarding Your use of Plugwork web sites. Any Data that You provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. Plugwork does not have control over, or responsibility for, those companies or their use of Your information.
In addition, Plugwork web sites may host blogs, forums, and other applications or services (collectively “social media features”). The purpose of social media features is to facilitate the sharing of knowledge and content. Any Data that You provide on any Plugwork social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom Plugwork may have limited or no control.
The provider of the social media platform uses web tracking methods. Web tracking may also take place independently of whether You are logged in or registered on the social media platform. Unfortunately, Plugwork cannot influence or restrict the web tracking methods of the social media platform.
Please be aware that the platform provider may use Your profile and behavioral data to evaluate, among other things, Your habits, personal relationships, and preferences. Plugwork has no influence on the processing of Your Data by the platform provider.
Please refer to the privacy policies of the platform provider for more information on the purpose and scope of Data collection and Data analysis undertaken by the social network as well as Your options to modify settings and how to protect Your privacy.
Other sources of Data Plugwork may collect include Data shared with Plugwork (its employees, Data shared while visiting any Plugwork premise) public websites, social media, cookies & tracking technologies, events, workshops, seminars etc.
LAWFUL GROUNDS FOR PROCESSING DATA
Plugwork collects only the Data necessary to fulfil Your request. Where additional, optional information is sought, You will be notified of this at the point of collection. The applicable Regulations provide for certain justifiable grounds for collection and Processing of Data, commonly referred to as legal basis of Processing.
Plugwork we will use this information in the manner outlined in this Policy. Your Data is not used for other purposes, unless Plugwork obtains Your Consent, or unless otherwise required or permitted by law or professional standards.
We use the Data for the following purpose:
- To provide the Services and related support, process transactions, manage Your user account and respond to Your requests.
- To the extent permitted by applicable law, and for certain legitimate interests, including cloud service providers, business partners, vendors, consultants, government bodies including statutory, regulatory authorities, law enforcement agencies (where applicable), auditors (internal/ external), clients based on contractual obligations or legitimate business purposes.
- To meet our corporate and social responsibility obligations.
- To conduct and to analyze Plugwork’s marketing activity.
- To exercise Plugwork’s fundamental right to conduct business and right to property in jurisdictions where applicable.
- In the event that Plugwork sell or buy any business, assets, or shares in part or whole, to disclose Your personal details to such relevant third parties involved on a need-to-know basis.
- To ensure that Plugwork can comply and fulfil its legal and regulatory obligations including those regarding Your account, for example, the verification of the accuracy of any information You give us.
- To investigate, and assist with the investigation of, suspected unlawful, fraudulent, or other improper activity connected with the Services (including, where appropriate, dealing with requests from regulatory bodies for the sharing of information).
- To establish, exercise or defend Plugwork’s legal rights or for the purpose of legal proceedings.
- To utilise for assessing or finalizing potential employment or engagement with Plugwork.
- To carry out activities relating to Your employment contract with Plugwork (including, but not limited to, processing your salary, administering statutory and other benefits, managing Your performance and career prospects and growth with Plugwork).
- To carry out internal research for technological development and demonstration.
- For marketing and advertising, including sending You updates and information about new products and services, upcoming events or other promotions or news, including by email or push notification, as permitted by law.
- Useability, troubleshooting, site maintenance, track website visits (which part visited frequently).
Performance of Contract: This is when the Processing of Your Data is necessary to perform Plugwork’s obligations under a contract; e.g., Processing Data for employment purposes (such as processing your salary, administering benefits) or providing Services to Plugwork customers which are necessary to perform the contract.
Consent: In some cases, Plugwork will ask You for specific permission to process some of Your Data and Plugwork will only Process Your Data in this way if You agree to Plugwork doing so. You may withdraw Your Consent at any time by contacting Plugwork on the details mentioned under ‘CONTACT OUR DATA PROTECTION OFFICER’.
Legitimate Interests: Plugwork may Process Your Data where it is necessary for legitimate business interests.
Legal Obligations: Plugwork may Process Your Data where it is necessary to comply with applicable legal and/or Regulations , establish, exercise, or defend Plugwork’s legal rights or for the purpose of legal proceedings and to prevent and respond to actual or potential fraud or illegal activities.
Vital interest: Plugwork may Process Your Data to protect Your vital interests or that of another natural person.
Other “Public Interest” Grounds: Plugwork may Process Your Data on other public interest grounds where it is subject to regulatory requirements where Processing is necessary for the performance of a task mandated by governmental authorities, regulatory authorities or any other law enforcing authorities in the public interest.
WHAT INFORMATION DO WE COLLECT?
Plugwork may, where legally permissible, process your Sensitive Personal Data on the following lawful bases:
- Explicit consent;
- Legal Obligations;
- Protect Your vital interests or of another natural person where the person is physically or legally incapable of giving consent;
- Legitimate Interests;
- Data manifestly made public by the Data Subject;
- Establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity;
- Public interest or health;
- Preventive or occupational medicine; and/or
- Archiving purposes in the public interest, scientific or historical research purposes or statistical purposes.
Change Of Purpose: Plugwork Processes Your Data when it is necessary for the purposes of a legitimate interest pursued by Plugwork or based on Your Consent, wherever applicable. If Plugwork needs to use Your Data for an unrelated purpose, Plugwork will notify You and Plugwork will explain the legal basis which allows Plugwork to do so. Please note that Plugwork may Process Your Data without Your knowledge or Consent, in compliance with the Regulations or permitted by law.
If You choose not to provide Your Data that is mandatory to process Your request, Plugwork may not be able to provide the corresponding Service.
SHARING AND TRANSFER OF PERSONAL INFORMATION
Plugwork may share Data with its subsidiaries; affiliates, business partners; service providers, vendors; authorized third-party agents; or contractors.
TRANSFER WITHIN PLUGWORK
Plugwork shares Data with its subsidiaries, affiliates, and other members of the Plugwork entities , existing anywhere in the world including but not limited to those in Australia, Canada, Colombia, Jamaica, Philippines, UK, and USA. Affiliates and subsidiaries of Plugwork may provide services to Plugwork and You, for example hosting and supporting IT applications, client engagement services and otherwise as required to continue to run Plugwork’s business.
Plugwork will ensure that Data is protected and transferred consistent with applicable Regulations. This can be done in several diverse ways, for instance:
- The country to which Plugwork sends the Data may be approved by the European Commission as a jurisdiction offering an “adequate” level of Data Privacy Laws;
- Where applicable, Plugwork has implemented additional (technical, contractual (inter-company transfer agreements and standard contractual clauses) and/or organizational measures to secure the transfer of Data;
- The recipient organisation has signed a contract based on approved “model contractual clauses” obliging them to protect the Data.
- Any transfer of Data will be compliant with applicable Regulations.
In the event of any high-risk processing activity, DPIA / PIA will be conducted before the beginning of such processing. This helps in screening of potential widespread or serious impact on individuals.
TRANSFERS TO THIRD PARTIES
Plugwork does not share Data with third parties, except as necessary for legitimate professional and business needs, to carry out Your requests, and/or as required or permitted by applicable law or professional standards.
Plugwork will not transfer the Data to any third parties for their own direct marketing use.
DISCLOSURE OF DATA
In compliance with applicable laws, access to Your Data is restricted to only necessary persons/entities on a strictly need-to-know basis.
We may disclose some of Your Data with the following recipients:
- Any company within the Plugwork and its related group;
- Internal departments, including with Your reporting manager, managers in the business areas, IT team, Admin Team, or any other team;
- Third parties with whom we have a contractual relationship, including clients, payroll vendor, law firms, etc.
- In the event that Plugwork sells or buys any business, assets, or shares Plugwork may disclose Your Data to such relevant third parties involved, to meet its contractual and legal obligations.
- Disclosure to any supervisory authority as required by applicable laws.
With respect to disclosing Data to Third Parties, written contracts with Third Parties will include restrictions prohibiting the Third-Party from retaining, using, or disclosing Data for any purpose except performing the services specified in the contract or as otherwise permitted by applicable laws.
Plugwork will seek to use Data Processors or Sub-Processors that can provide sufficient security measures in accordance with applicable Regulations and shall put in place contractual mechanisms to ensure that the relevant Data Processor or Sub-Processor takes reasonable steps to ensure compliance with those measures.
CHOICES
In general, You are not required to submit any Data to Plugwork, but Plugwork may require You to provide certain Data for You to receive additional information about Plugwork Services and events. Plugwork may also ask for Your permission or Consent for certain uses of Your Data, and You can agree to or decline those uses. If You opt-in for Services or communications, such as an e-newsletter, You will be able to unsubscribe at any time by following the instructions included in each communication. If You decide to unsubscribe from a service or communication, Plugwork will try to remove Your information promptly, although Plugwork may require additional information before we can process your request.
DATA SUBJECT RIGHTS
In accordance with the applicable law and Regulations, Data Subjects have rights that include the following:
- The right to be informed
- The right to access the Data
- The right to rectification of any Data that is inaccurate or incomplete
- The right to erasure of Data (also known as ‘the right to be forgotten’)
- The right to object/ opt-out to the Processing of Data
- The right to Data portability
- Rights in relation to automated decision making and profiling
- The right to restrict the Processing of Data
- The right to be indemnified for damages due to inaccurate Data
Plugwork will handle all Your requests in accordance with applicable laws and Regulations. Please note that there may be circumstances in which Plugwork is legally entitled to refuse some of these requests. You will not have to pay a fee to access Your Data (or to exercise any of the other rights). However, Plugwork may charge a reasonable fee if Your request for access is clearly unfounded or excessive. Alternatively, Plugwork may refuse to comply with the request in such circumstances.
For exercising Your rights, Plugwork may need to request certain information for ascertaining Your identity and confirming that You are entitled to exercise the same. You may raise a request by contacting Plugwork on the details mentioned under ‘CONTACT OUR DATA PROTECTION OFFICER
PERSONAL DATA OF INDIVIDUALS BELOW 13 YEARS
If we are required to process Data of individuals under 13, we shall do so by getting explicit written Consent from their parents/legal guardians.
Note: If you are below the age of 13 years, then we do not want you to provide any of Your Data.
DATA SECURITY
DATA RETENTION
Plugwork make reasonable efforts to retain Data only for so long
- it is necessary to comply with an individual’s request,
- it’s necessary to comply with legal, regulatory, internal business or policy requirements, or
- information is deleted by Plugwork or at request of Data Subject
- Data will be retained until necessary to fulfill the purposes outlined in this notice unless a longer retention period is required or permitted by applicable law.
The period for which Data is retained will depend on the specific nature and circumstances under which the information was collected; however, subject to requirements of i)-iii) above. The deletion of Data shall be handled with utmost care and shall be governed in accordance with reasonable security practices as detailed by Plugwork’s internal policies.