QualiZeal and entities in India and USA (collectively referred to as ‘QualiZeal’) are committed to the confidentiality, privacy, security and protection of Personal Information (as defined below) collected from/ disclosed by/ shared by Data Subjects (as defined below) including its employees (at all levels and grades, whether regular, fixed-term contract or
temporary), contractors, vendors, associates, consultants, customers and business partners of QualiZeal.
This Privacy Policy (hereinafter referred to as ‘Policy’) broadly outlines the security practices and procedures adopted
by QualiZeal for collection, receipt, possession, storage, dealing, handling, processing and protection of Personal Data
(as defined below) and Sensitive Personal Data (as defined below) (‘Personal Data’ and ‘Sensitive Personal Data’ are
hereinafter collectively referred to as ‘Personal Information) of the Data Subjects, in compliance with applicable laws
and regulations.
This Policy is applicable to (i) all Data Subjects who provide, disclose, and share Personal Information to/ with
QualiZeal, (ii) Data Processors (as defined below) working with or for QualiZeal, and who have or may have access to
or receive Personal Information from QualiZeal and who have access to Personal Information collected or processed
by QualiZeal; and (iii) Employees of QualiZeal who have access to Personal Information collected or processed by or
on behalf of QualiZeal.
The Data Subjects, the Employees of QualiZeal and the Data Processors are expected to read, understand and comply
with the Policy.
This Policy applies to all information that QualiZeal collects, uses, process, stores, shares and dispose your personally
identifiable information from the access made to websites, products & services.
QualiZeal obligations in connection with data protection presently emanate from:
For the purpose of Privacy Policy:
The Data Protection Officer of QualiZeal is responsible for overseeing the compliance with this Policy. In accordance
with the Act, the Data Protection Officer is designated as the Grievance Officer to redress the grievances of the Data
Subjects, within the regulatory/prescribed timelines. If a Data Subject has any questions about this Policy or concerns
about how QualiZeal manages his/her Personal Information or if a Data Subject becomes aware of any breach of
Personal Information, he/she may contact/notify the Data Protection Officer.
QualiZeal is committed to privacy. The information QualiZeal has about customers and users is protected and secure
and QualiZeal works diligently to ensure that preferences regarding the use of your information are honored.
This Policy explains the types of personal information QualiZeal collect and use, store, protect and disclose that
information.
QualiZeal build a privacy that works for everyone. Protecting our users’ privacy and security is a responsibility that
comes with creating products and services that are made available for all. QualiZeal look to these principles to guide
our products, our processes, our people in keeping our users’ data private, safe, secure and are committed to
continually improve the level of protection it requires.
As a rule, QualiZeal will collect Personal Information from the Data Subjects for specific, explicit, contractual, regulatory
and legitimate purposes as required and in accordance with Applicable Laws, Rules and Regulations.
QualiZeal may also gather the Data Subjects’ Personal Information from third parties in accordance with Applicable
Laws, Rules and Regulations. For instance, if the Data Subject is a potential candidate for employment with QualiZeal,
QualiZeal may have received the Data Subject’s Personal Information from third parties such as recruiters or external
websites. QualiZeal shall apply the terms of this Policy to any Personal Information received from a third party.
QualiZeal is not responsible for third parties’ dissemination of a Data Subject’s Personal Information.
QualiZeal may combine the Personal Information a Data Subject provides with other information so as to provide and
improve its services.
QualiZeal shall use and process the Data Subject’s Personal Information for a lawful purpose to meet the
needs/performance of its business/legal obligations, in accordance with Applicable Laws, Rules and Regulations. Such
processing of Data Subject’s Personal Information will be adequate, relevant and limited to what is necessary and
compatible in relation to the purposes for which it is collected.
QualiZeal will not share information with any third party outside its organization, other than as necessary to fulfill any
statutory or contractual requirements.
By using QualiZeal’ services and/or otherwise interacting with QualiZeal, the Data Subject consents to QualiZeal
collecting, processing and disclosing Personal Information in accordance with this Policy. The Data Subject will, for the
services rendered by QualiZeal, share/provide/disclose to QualiZeal only such Personal Information that is sought by
QualiZeal pursuant to Applicable Laws, Rules and Regulations.
QualiZeal may share the Personal Information of the Data Subjects with third parties, in a variety of ways, including, as
the following:
Service Providers acting on behalf of QualiZeal: QualiZeal may share Personal Information about its Data Subjects
with service providers or agents in order to have them perform on QualiZeal’ behalf any of the activities QualiZeal is
permitted to conduct under this Policy, Applicable Laws, Rules and Regulations and other applicable contractual terms.
This includes things like designing or operating features, helping QualiZeal research and test feature improvements,
identifying offers or personalized recommendations, performing analytics and marketing its services. These third parties
are acting on behalf of QualiZeal so while they may have access to Personal Information they are required to follow
QualiZeal’ instructions and meet the standards explained in this Policy when handling information about a Data Subject
that QualiZeal provide them.
As Part of a Corporate Change: QualiZeal may disclose and transfer information about Data Subjects to a third party
as part of, or in preparation for, capital raising, change of control, restructuring, corporate change, or sale or transfer of
assets. For instance, QualiZeal may allow a potential acquirer or merger partner to review its databases, although it
would restrict their use and disclosure of this data during the diligence phase.
For Legal Reasons: QualiZeal reserves the right to transfer or disclose information about Data Subjects to third parties
for certain legal purposes as required by law enforcement, government officials, or other third parties pursuant to a
court order, or other legal process or when it believes, in its sole discretion, that the disclosure of Personal Information
is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of
legal agreements or organizational policies; to enforce its terms and conditions, to protect the security or integrity of its
services;
With Data Subject’s Consent: There may also be other limited contexts in which QualiZeal shares specific types of
Personal Information with the express consent of Data Subjects.
QualiZeal would like to clarify that it does not sell/share the Personal Information of Data Subjects to/with third parties
without an explicit contract.
Given that QualiZeal is an organization having an international presence as well as the digital nature of Personal
Information, there may be a likelihood of the Personal Information collected by QualiZeal from the Data Subjects being
transferred to and stored at, a destination outside India or USA, subject to such laws as maybe applicable from time to
time, including for the purposes of processing. By submitting Personal Information, the Data Subject agrees to this kind
of storing, processing and transferring of the Personal information. However, the Data Subject will appreciate that
QualiZeal is inclined towards the safety of its Personal Information and therefore, it takes all reasonable steps to ensure
that such Personal information is treated securely and in accordance with this Policy and Applicable Law, Rules and
Regulations. Moreover, it is clarified that whenever QualiZeal shares data, it relies on lawful measures to transfer such
data.
QualiZeal may combine a Data Subject’s Personal Information with those of other users of its services and share or
provide this trend information in aggregated and anonymized form with third parties, such as prospective investors,
affiliates, partners and advertisers. This will only be anonymized data, and will never be capable of personally identifying
an individual, and, will only be shared in accordance with Applicable Laws, Rules and Regulations. For example,
QualiZeal may anonymize a Data Subject’s Personal Information and use it in aggregated form in order to report on
industry, marketing and employment trends.
QualiZeal shall protect the Personal Information received from the Data Subjects with the same degree of care, but no
less than a reasonable degree of care, to prevent the unauthorized use, dissemination or publication of the information
as it protects its own confidential information of a like nature. QualiZeal shall maintain physical, technical and procedural
safeguards that are appropriate to protect the Data Subjects’ Personal Information from loss, unauthorized access,
copying, use, modification or disclosure. QualiZeal has appropriate policies and technical and organizational measures
in place to safeguard and protect the Data Subjects’ Personal Information against unlawful or unauthorized access,
accidental loss or destruction, damage, unlawful or unauthorized use and disclosure. QualiZeal will also take all
reasonable precautions to ensure that its staff and employees who have access to Personal Information about the Data
Subjects have received adequate training.
QualiZeal endeavors to retain the Personal Information only for as long as it is necessary to fulfill the purpose for which
the same was collected. The Personal Information will be kept in a manner which permits identification for as long as it
is necessary for the purposes for which the relevant Personal Information is processed and as required by the
Applicable Laws, Rules and Regulations. QualiZeal has the right to retain the Personal Information for legal and
regulatory purpose and/or as per applicable data protection laws.
Personal Information may be stored for longer periods where the Personal Information is being processed for archiving
purposes in the public interest, scientific or historical research purposes or statistical purposes or other purposes
permitted under Applicable Laws, Rules and Regulations subject to implementation of the appropriate technical and
organizational measures.
A Data Subject is entitled to request details of his/her Personal Information that QualiZeal holds. If a Data Subject wants
to review, modify, verify, correct, restrict, seek deletion, seek erasure of any of the Personal Information, the Data
Subject may contact the Data Protection Officer using the contact details provided herein. If any Personal Information
happens to change during the course of employment/contract period/business arrangement, the Data Subject is
requested to keep QualiZeal informed of the same.
QualiZeal does its best to ensure that the Personal Information it holds and uses is accurate. QualiZeal relies on the
Data Subjects to disclose to it all relevant information and to inform of any changes thereto.
QualiZeal takes appropriate steps to maintain the security of Personal Information collected from Data Subjects. If a
security breach occurs, QualiZeal will promptly take steps to address the breach. If a security breach causes an
unauthorized intrusion in the QualiZeal system that materially affects a Data Subject, QualiZeal will endeavor to notify
the concerned Data Subject as soon as possible and where necessary or required by Applicable Laws, Rules and
Regulations, report the actions taken in response to any breach.
In such an event however, QualiZeal assumes no responsibility of whatsoever nature, for making good the losses and
damages that a Data Subject may incur.
This Policy is subject to modifications as per changes in Applicable Laws, Rules and Regulations changes within
QualiZeal’s operating environment or on recommendations of the internal/external auditors. QualiZeal reserves the
right to modify this Policy at any time, without notice to Data Subject/(s).
The Data Protection Officer will review the compliance of this Policy and the processes thereunder on an annual basis
to ensure continuous monitoring through the implementation of compliance measurements and review processes in
accordance with the Applicable Laws, Rules and Regulations. If there are any material changes in the way QualiZeal
treats a Data Subject’s Personal Information, QualiZeal will place a prominent notice on its websites before the change
goes into effect.
QualiZeal will regularly review the Policy and may make changes, as maybe required, to this Policy from time-to-time.
