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PRIVACY POLICY

TERMS USED IN THIS POLICYLast Updated February 16, 2022

In this Data Privacy and Protection Policy:

  • “GDPR” means the EU General Data Protection Regulation.
  • “Personal Data” means any information relating to an identified or identifiable natural person.
  • “Policy” means this Data Privacy & Protection Policy.
  • “Service” refers to a service that HBG provides, for a fee or gratis. You are using our Service when you actively sign up or sign in to get access to any Service provided by us.
  • “controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
  • “processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
  • “We”, “Us”, “Our”, and “HBG” refer to HBG KNOWLEDGE SERVICES PRIVATE LIMITED.
  • “Website” refers to HBG (https://www.hbgknowledge.com/) website. You are using our “website” when you are visiting our website.
  • “You” refers to you, as a user or subscriber of the services provided by us.
OUR COMMITMENT TOWARDS PROTECTING THE PERSONAL INFORMATION

Your privacy is important to us. We will use your personal information only in the manner set out in this Policy. We act in accordance with the applicable data protection laws, including GDPR. We are committed to safeguarding the privacy of our website visitors, clients, prospects, and research participants. This Policy sets out how we deal with your personal information.Our commitment towards protecting your personal information includes the following obligations:

  • We promise to protect your privacy and treat the information you give us as confidential.
  • The information you provide to us will be used by us only for the purpose for which it was sought.
  • We will not release your personal information to any third party without your consent.
  • We will never try to sell you anything and we will never sell your personal data to anyone.
  • Your decision to provide or not to provide any information will be respected without question.
STATUS - WHETHER CONTROLLER OR PROCESSOR

We act as both Processor and Controller. In most cases, where we process data on Personal Data on behalf and on instructions of a Client, we act as Data Processors. However, certain times, post seeking consent from Respondents we retain their Personal Data for future usage and make them a part of HBG’s panel, in such situations post we also act as Data Controllers.

WHAT DATA DO WE COLLECT ABOUT YOU, AND FOR WHAT PURPOSE?
  • We may process data about your use of our website and services (“Usage Data”) - The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of your visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your Service use. The source of the usage data is our analytics tracking system. In addition, we may use third-party analytics tracking services such as Google Analytics and Facebook Pixel. This usage data may be processed for the purposes of analyzing the use of the Website and Services in order to improve our performance metrics, and for communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely monitoring and improving our Website and Services.

  • We may process your data that is provided to us during the course of our surveys (“Response Data”) - The response data may include your name, company name, contact number,job title,professional experience, resume/CV, age, area of residence, email address, your responses to the questions that we may ask you. The source of the response data is you. The response data may be processed for the purposes of providing our services, ensuring the integrity of our operations and processes, maintaining backups of our databases, and for communicating with you. The legal basis for this processing is your consent.

  • We may process your information included in your personal profile on our website (“Profile Data”) - The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services and for communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our Website and Services.

  • We may process your personal data that are provided in the course of the use of our Services (“Service Data”) - The service data may include your name, address, telephone number, email address. The source of the service data is you or your employer. The service data may be processed for the purposes of providing our Services, ensuring the security of our Website and Services, maintaining back-ups of our databases, and for communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our Website and business. In some cases, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

  • We may process information that you post for publication on our Website or through our Services (“Publication Data”) - The publication data may be processed for the purposes of enabling such publication and administering our Website and Services. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our Website and business. In some cases, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

  • We may process information contained in any enquiry you submit to us regarding goods and/or services (“Enquiry Data”) - The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you and for and for communicating with you. The legal basis for this processing is your consent.

  • We may process information relating to our customer relationships, including customer contact information(“Customer Relationship Data”) - The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications, promoting our products and services to customers, and for communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our Website and business. In some cases, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

  • We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“Transaction Data”) - The transaction data may include your contact details, your banking details, your credit card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services, keeping proper records of those transactions, and for communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our business. In some cases, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

  • We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“Notification Data”) - The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters, and for communicating with you. The legal basis for this processing is your consent.

  • We may process information that you provide to us for the purpose of sending the promised honorarium to you (if any) (monetary incentives and gift vouchers) – The correspondence data may include your name, email address, physical address, bank details, PayPal account details or other payment details selected by you as the mode of receiving the honorarium. We may have to share this information on third party application to process your honorarium. The legal basis of this processing in your consent and our legitimate interest of keeping our promise of providing you with the honorarium offered.

  • We may process information contained in or relating to any communication that you send to us (“Correspondence Data”) - The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record keeping. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our Website and business and communications with our business counterparts.

In addition to the specific purposes for which we may process your personal data set out in this Section, we may process any of your personal data identified in this Policy where necessary for:
  • The establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

  • The purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

  • Compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

WHOM DO WE SHARE YOUR DATA WITH?
  • We may disclose your personal data to any of our employees, officers, and agents as long as such disclosure is reasonably necessary for the purposes, and on the legal bases, set out in this Policy.

  • We may disclose your personal data to any member of our group of companies (this means our ultimate holding company and all its subsidiaries and joint venture partners) as long as such disclosure is reasonably necessary for the purposes, and on the legal bases, set out in this Policy.

  • We may disclose your personal data collected as part of research surveys with our clients as long as such disclosures is reasonable necessary for the purpose and on the legal bases, set out in this policy.

  • We may disclose your personal data to our insurers and professional advisers as long as such disclosure is reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

  • We may disclose your personal data to our suppliers or subcontractors as long as such disclosure is reasonably necessary for providing Services to you.

  • Financial transactions relating to our Website and Services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

  • We may disclose your personal data to third party suppliers of goods and services for the purpose of enabling them to contact you so that they can offer, market and sell to you the relevant goods and/or services.

  • In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

We will not sell, share, rent or otherwise intentionally transfer your name, address, telephone number or e-mail address to market research companies, direct marketing companies or anyone else. The only exceptions when we may disclose your personal information to third parties are as follows:
  • You request us to share, or consent to us sharing, your data with the third parties for a specified purpose.

  • We provide your responses to a third party who is contractually bound to keep the information confidential and use it only for research or statistical purposes.

  • In the rare, but possible circumstance that the information is subject to disclosure pursuant to judicial or other government subpoenas, warrants, orders or for similar legal or regulatory requirements.

HOW LONG DO WE RETAIN YOUR DATA?

Your personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will retain your personal data as follows:

RETENTION PERIOD AS A PROCESSOR:

As a processor when the legal purpose is based on a contract or a DPA, then we follow customer instruction for data retention.

RETENTION PERIOD AS A CONTROLLER
  • Usage Data – It will be retained for a minimum period of one week following the date of your visit, and for a maximum period of ten years following the date of your visit.

  • Response Data – It will be retained for a minimum period of one month following the submission of your response, and for a maximum period of ten years following the submission of your response.

  • Profile Data – It will be retained for a minimum period of one day following the date of deletion of your profile on our Website, and for a maximum period of ten years following such deletion.

  • Service Data – It will be retained for a minimum period of one month following the fulfillment of the Service, and for a maximum period of ten years following the last date on which any obligation in respect of such Service concludes.

  • Publication Data – It will be retained for a minimum period of one week following the publication of such data, and for a maximum period of ten years following the date on which such data is removed from such publication.

  • Enquiry Data – It will be retained for a minimum period of one day following the date of the enquiry, and for a maximum period of ten years following the date of the enquiry.

  • Customer Relationship Data – It will be retained for a minimum period of one month following the conclusion of the said relationship, and for a maximum period of ten years following the conclusion of the said relationship.

  • Transaction Data – It will be retained for a minimum period of one week following the date of the transaction, and for a maximum period of ten years following the date of the transaction.

  • Notification Data – It will be retained for a minimum period of one day following the date of unsubscribing from our newsletters, and for a maximum period of ten years following the date of request for such unsubscribing.

  • Correspondence Data – It will be retained for a minimum period of one day following the date of the communication, and for a maximum period of twenty years following the date of the communication.

In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

Sr. No. Category of Data Factors on which Retention Period will be based
1 Usage Data Parameters of usage being analyzed
2 Response Data “Terms of Service” under which the response is solicited
3 Profile Data Nature of utilization of profile
4 Service Data Nature of Service; covenants of Service contract
5 Publication Data Means of publication; citation of publication in other works
6 Enquiry Data Means of enquiry; nature of Service enquired for
7 Customer Relationship Data Nature of relationship; covenants of Service contract
8 Transaction Data Nature of transaction; covenants of Service contract
9 Notification Data Terms of opt-in
10 Correspondence Data Nature of correspondence; requirements of law

Notwithstanding the foregoing provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

TRANSFER OF DATA
  • Your information, including Personal Data, is transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

  • If you are located outside India and choose to provide information to us, please note that we transfer the data, including Personal Data, to India and USA and process it there.

  • Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

HBG will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information

WHAT ARE YOUR RIGHTS REGARDING YOUR DATA WITH US?
This Section summarizes the rights that you have under data protection law. Please note that some of the rights available to you are convoluted and may not be represented in detail in this Policy. We advise you to peruse the relevant laws for a complete understanding your rights. Your principal rights concerning your Personal Data under GDPR are as below:
  • Right to Access – You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data.Subject to the condition that the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can request your personal data with us, by emailing us on privacy@hbgknowledge.com

  • Right to Rectification – You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

  • Right to Erasure – In certain circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data provided to us is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

  • Right to Restrict – In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you do not desire erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

  • Right to Object – You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

  • Right to Data Portability – To the extent that the legal basis for our processing of your personal data is: (a) consent; or (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

  • Right to Complain – If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

  • Right to Withdraw Consent – To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may exercise any of your rights in relation to your personal data by a written notice to us on privacy@hbgknowledge.com In order for us to comply with your request, your notice must clearly state the right that you wish to exercise and identify your information in respect of which you wish to exercise such right. Please note that as a security measure, we may require you to verify your identity before accepting any request concerning your Personal Data.

WHY DO WE USE COOKIES?

We use first and third party cookies for several reasons. Some cookies are required for technical reasons in order for our websites to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our website. This is described in more detail below.

HOW WE USE COOKIES

We use cookies for the following purposes:

  1. Essential Cookies: These cookies are necessary for the operation of our website. They enable you to move around the website and use its features.

  2. Analytics Cookies: We use analytics cookies to analyze how users interact with our website, which helps us improve our website’s performance and content.

  3. Functionality Cookies: These cookies allow our website to remember choices you make (Such as language preferences) and provide enhanced features.

  4. Third-party Cookies: we may also use third-party cookies to track website usage and for advertising purposes.

We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

HOW TO REMOVE OR LIMIT HBG Unite’S RESEARCH USE OF COOKIES

You have a full control over the use of Cookies. By changing the Internet browser settings, you can deactivate or restrict the transmission of Cookies.

Through browser preferences, it is also possible to delete Cookies installed in the past, including the Cookies that may have saved the initial consent for the installation of Cookies by this website.

Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses:

  1. Chrome: https://support.google.com/chrome/answer/95647?hl=en

  2. Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

  3. Opera: http://www.opera.com/help/tutorials/security/cookies/

  4. Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windowsinternet-explorer-delete-manage-cookies

  5. Safari: https://support.apple.com/kb/PH21411

  6. Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy

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