A. General Information

Who is the Data Controller? The data controller of www.hrmantra.com is HRMantra Software Private Limited, 65-70, Ground Floor, Kesar Residency, Plot CHK1, Sector 3, Charkop, Kandivali (West), Mumbai -400067, India ("HRMantra"). Where a registration form is presented on this website, the data controller may vary depending on the actual offering or the purpose of the data collection, but it is in any case displayed on the individual registration form's privacy statement. The HRMANTRA's data protection officer can be reached at it@hrmantra.com

What Personal Data does HRMANTRA collect? When you visit HRMANTRA's websites, HRMANTRA stores certain information about your browser, the operating system, and your IP address.

If you use a registration form, HRMANTRA will collect the information you provide to HRMANTRA, which consists of your first and last name, email addresses, telephone numbers, location (country, state/province, city), company name, job title/role, department and function, current relationship to HRMANTRA, and your company's industry. If you provide a credit card number or bank details to order services from HRMANTRA, then HRMANTRA will collect this information to process your payment for the requested goods or services.

Why does HRMANTRA need your Personal Data? HRMANTRA requires your Personal Data to provide you with access to this site; to deliver any ordered services; and to comply with statutory obligations, including checks required by applicable export laws.  Further information on why HRMANTRA needs your Personal Data can be found in Section B, below, if HRMANTRA's use of your Personal Data is based on a statutory permission. Further information on why HRMANTRA needs your Personal Data can be found in Section C, below, if HRMANTRA's use of your Personal Data is based on your consent.  As a general matter and although providing Personal Data is voluntary, HRMANTRA may not be able to perform or satisfy your request without it; for example, HRMANTRA might require your Personal Data to process an order you place, or to provide you with access to a web offering that you requested. In these cases, it is not possible for HRMANTRA to satisfy your request without certain Personal Data.

From What Types of Third Parties does HRMANTRA obtain Personal Data? In most cases, HRMANTRA collects Personal Data from you.  HRMANTRA might also obtain Personal Data from third parties, if the applicable national law allows HRMANTRA to do so.  HRMANTRA will treat this Personal Data according to this Privacy Policy, plus any additional restrictions imposed by the third party that provided HRMANTRA with it or the applicable national law. These third-party sources include:

• HRMANTRA and/or HRMANTRA Group's business dealings with your employer
• Third parties you directed to share your Personal Data with HRMANTRA

How long will HRMANTRA store my Personal Data? HRMANTRA will only store your Personal Data for as long as it is required:

• to make services requested available to you, including using HRMantra.com;
• for HRMANTRA to comply with its statutory obligations resulting inter alia from applicable export laws;
• until you object against such use by HRMANTRA, if HRMANTRA's use of your Personal Data is based on HRMANTRA's legitimate business interest as further stated in this Privacy Statement;
• until you revoke your consent granted in this Privacy Policy, if HRMANTRA is processing your Personal Data based on your consent; 
• by applicable mandatory law to retain your Personal Data longer or where your Personal Data is required for HRMANTRA to assert or defend against legal claims, HRMANTRA will retain your Personal Data until the end of the relevant retention period or until the claims in question have been settled.

Who are the recipients of your Personal Data and where will it be processed? Your Personal Data will be passed on to the following categories of third parties to process your Personal Data:

• companies within the HRMANTRA Group        
• Third-party service providers
• for the provision of the website or newsletter dispatch, for consulting
• services and other additional related services.

As part of a global group of companies operating internationally, HRMANTRA has affiliates (the "HRMANTRA Group") and third-party service providers outside of the European Economic Area (the "EEA") and will transfer your Personal Data to countries outside of the EEA. If these transfers are to a country for which the EU Commission has not issued an adequacy decision, HRMANTRA uses the EU standard contractual clauses to contractually require that your Personal Data receives a level of data protection consistent with the EEA. You can obtain a copy (redacted to remove commercial or irrelevant) of such standard contractual clauses by sending a request to it@hrmantra.com. You can also obtain more information from the European Commission on the international dimension of data protection here.

What are your data protection rights? You can request from HRMANTRA: access at any time to information about which Personal Data HRMANTRA processes about you and the correction or deletion of such Personal Data. Please note, however, that HRMANTRA can or will delete your Personal Data only if there is no statutory obligation or prevailing right of HRMANTRA to retain it. Kindly note further that if you request that HRMANTRA deletes your Personal Data, you will not be able to continue to use any HRMANTRA service that requires HRMANTRA's use of your Personal Data.

If HRMANTRA uses your Personal Data based on your consent or to perform a contract with you, you can further request a copy of the Personal Data that you provided to HRMANTRA.  To do so, please contact the email address below and specify the information or processing activities to which your request relates, the format in which you would like to receive this information, and whether the Personal Data should be sent to you or another recipient. HRMANTRA will carefully consider your request and discuss with you how it can best fulfil it.

Furthermore, you can request from HRMANTRA that HRMANTRA restricts your Personal Data from any further processing in any of the following events: (i) you state that the Personal Data HRMANTRA has about you is incorrect, subject to the time

HRMANTRA requires to check the accuracy of the relevant Personal Data, (ii) there is no legal basis for HRMANTRA processing your Personal Data and you demand that HRMANTRA restricts your Personal Data from further processing, (iii) HRMANTRA no longer requires your Personal Data but you state that you require HRMANTRA to retain such data in order to claim or exercise legal rights or to defend against third party claims, or (iv) in case you object to the processing of your Personal Data by HRMANTRA based on HRMANTRA's legitimate interest (as further set out below under Section C.), subject to the time required for HRMANTRA to determine whether it has a prevailing interest or legal obligation in processing your Personal Data.

For individuals within the State of California, you instead have the right: 

• to request from HRMANTRA access to your Personal Data that HRMANTRA collects, uses, discloses about you;
• to request that HRMANTRA delete Personal Data about you;
• to non-discriminatory treatment for exercise of any of your data protection rights; and
• in case of request from HRMANTRA for access to your Personal Data, for such information to be portable, if possible, in a readily usable format that allows you to transmit this information to another recipient without hindrance.

In accordance with the disclosure requirements under the CCPA, HRMANTRA is exempt from providing a notice to opt-out because it does not and will not sell your Personal Data. 

Please note, however, that HRMANTRA can or will delete your Personal Data only if there is no statutory obligation or prevailing right of HRMANTRA to retain it. Kindly note further that if you request that HRMANTRA deletes your Personal Data, you will not be able to continue to use any HRMANTRA service that requires HRMANTRA's use of your Personal Data.

How can you exercise your data protection rights? Please direct any requests to exercise your rights to it@hrmantra.com. You can also designate another person to submit requests to exercise your data protection rights to HRMANTRA. You can give authorization to such person by granting them a limited power of attorney to exercise your data protection rights on your behalf.

How will HRMANTRA verify requests to exercise data protection rights? HRMANTRA will take steps to ensure that it verifies your identity to a reasonable degree of certainty before it will process the data protection right you want to exercise.  When feasible, HRMANTRA will match Personal Data provided by you in submitting a request to exercise your rights with information already maintained by HRMANTRA. This could include matching two or more data points you provide when you submit a request with two or more data points that are already maintained by HRMANTRA.

In accordance with the verification process set forth in the California Consumer Privacy Act ("CCPA"), HRMANTRA will require a more stringent verification process for deletion requests, or for Personal Data that is considered sensitive or valuable, to minimize the harm that might be posed to you by unauthorized access or deletion of your Personal Data.   If HRMANTRA must request additional information from you outside of information that is already maintained by HRMANTRA, HRMANTRA will only use it for the purposes of verifying your identity so you can exercise your data protection rights, or for security and fraud-prevention purposes.

HRMANTRA will decline to process requests that are manifestly unfounded, excessive, fraudulent, or are not otherwise required by local law.

Right to lodge a complaint. If you take the view that HRMANTRA is not processing your Personal Data in accordance with the requirements in this Privacy Statement or under applicable EEA data protection laws, you can at any time lodge a complaint with the data protection authority of the EEA country where you live or with the data protection authority of the country or state where HRMANTRA has its registered seat.

Can I use HRMANTRA's services if I am a minor or child?

Children. HRMANTRA websites and online services are not directed to users below the age of 16 years, or equivalent minimum age in the relevant jurisdiction. If you are younger than 16, you cannot register with and use this websites or online services.

U.S. Children's Privacy. HRMANTRA does not knowingly collect the Personal Data of children under the age of 13.  If you are a parent or guardian and believe HRMANTRA collected information about a child, please contact HRMANTRA as described in this Privacy Statement.  HRMANTRA will take steps to delete the information as soon as possible.  Given that HRMANTRA websites and online services are not directed to users under 16 years of age and in accordance with the disclosure requirements of the CCPA, HRMANTRA does not sell the Personal Data of any minors under 16 years of age.

B. Processing based on a statutory permission

Processing to fulfill contractual obligations. HRMANTRA requires your Personal Data to deliver services you order under a contract HRMANTRA has with you, to establish a contract for services between you and HRMANTRA, or to send you invoices for ordered services. HRMANTRA processes Personal Data to fulfil contractual obligations pursuant to Article 6(1), lit. b GDPR. 

Processing when necessary to fulfil HRMANTRA's contractual obligation includes responding to your related inquiries, processing your feedback or providing you with support. This can also include conversation data that you may initiate or enable such as through the chat functionalities on HRMANTRA.com or other local HRMANTRA web presences, through contact forms, emails, or by telephone. In this Privacy Statement, "services" includes access to HRMANTRA's web services, offerings, contests, sweepstakes, other content, non-marketing related newsletters, white papers, tutorials, trainings and events.

Furthermore, HRMANTRA communicates on a regular basis by email with users who subscribe to its services and will also communicate by phone to resolve your or other customer complaints or to investigate suspicious transactions.  HRMANTRA will use your email address to confirm your opening of an account, to send you notice of payments, to send you information about changes to its products and services, and to send notices and other disclosures as required by law. Generally, users cannot opt out of these communications because these communications are required for the relevant business relationship and not marketing-related in nature.

For marketing-related communications such as emails and phone calls, HRMANTRA will (i) only provide you with such information after you have opted in, if legally required, and (ii) provide you the opportunity to opt out if you do not want to receive further marketing-related communications. You can also opt out of marketing-related communications at any time by updating your preferences at https://www.hrmantra.com.

Furthermore, you acknowledge that information required to track your data protection and privacy choices for processing your Personal Data, or for receipt of marketing materials (that is to say, depending on the country in which the relevant HRMANTRA Group company operates and whether you have expressly consented to or opted out of receiving marketing materials) may be exchanged among members of the HRMANTRA Group when necessary to ensure compliance.

Processing based on HRMANTRA's legitimate interest. HRMANTRA can use your Personal Data based on its legitimate interest (Article 6(1), lit. f GDPR) as follows:

• Fraud and Legal Claims. If required, HRMANTRA will use your Personal Data for the purposes of preventing or prosecuting criminal activities such as fraud and to assert or defend against legal claims.
• Questionnaires and survey. HRMANTRA could invite you to participate in questionnaires and surveys. These questionnaires and surveys will be generally designed in a way that they can be answered without any data that can be used to identify you. If you nonetheless enter such data in a questionnaire or survey, HRMANTRA will use this Personal Data to improve its products and services.
• Contract Performance. If you purchase or intend to purchase services from HRMANTRA on behalf of a corporate customer or otherwise be the nominated contact person for the business relationship between a corporate customer (a "Customer Contact") and HRMANTRA, HRMANTRA will use your Personal Data for this purpose. This includes, for the avoidance of doubt, such steps which are required for establishing the relevant business relationship. In case that an existing Customer Contact informs HRMANTRA that you are his replacement, HRMANTRA will, from the point in time of such notification, consider you to be the relevant Customer Contact for the respective customer until you object as further set out below.
• Creation of anonymized data sets. HRMANTRA will anonymize Personal Data provided under this Privacy Statement to create anonymized data sets, which will then be used to improve its and its affiliates' products and services.
• Personalized Content. If you opt-in to receive marketing communications such as and including newsletters, brochures or white papers from HRMANTRA, HRMANTRA will collect and store details of how you interact with such content to help create, develop, operate, deliver and improve our communications with you.  This information is aggregated and used to help HRMANTRA provide more useful information and to understand what is of most interest
• Recordings for quality improvement purposes. In case of telephone calls or chat sessions, HRMANTRA will record such calls or chat sessions to improve the quality of HRMANTRA's services.
• To keep you up-to-date or request feedback. Within an existing business relationship between you and HRMANTRA, HRMANTRA might inform you, where permitted in accordance with local laws, about its products or services (including webinars, seminars and events) which are similar or relate to such products and services you have already purchased or used from HRMANTRA. Furthermore, if you attend a webinar, seminar or event of HRMANTRA, download or view white papers, newsletters, videos, software free trials, or purchase products or services from HRMANTRA, HRMANTRA might contact you for feedback regarding the improvement of the relevant material, product or service.

Right to object. You can object to HRMANTRA's use of your Personal Data as set forth in this section at any time by updating your preferences at https://www.hrmantra.com. In this case, HRMANTRA will carefully review your objection and cease further use of the relevant information unless HRMANTRA has a compelling legitimate ground for continued use of the information and such ground overrides your objection, or if HRMANTRA requires the information for the establishment, exercise or defense of legal claims.

Processing under applicable national laws. If the applicable national law allows HRMANTRA to do so, HRMANTRA will use information about you, some of which is Personal Data, for the following business purposes:

• to plan and host events
• to host online forums or webinars
• for marketing purposes such as to keep you updated on HRMANTRA's latest products and services and upcoming events
• to contact you to discuss further your interest in HRMANTRA services and offerings
• to help HRMANTRA create, develop, operate, deliver and improve HRMANTRA services, products, content and advertising and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by HRMANTRA
• to provide more personalized information to you
• for loss prevention
• for account and network security purposes
• for internal purposes such as auditing, analysis, and research to improve HRMANTRA's products or services
• to verify your identity and determine appropriate services
• to assert or defend against legal claims
• detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
• debugging to identify and repair errors that impair existing intended functionality
• Undertaking internal research for technological development and demonstration
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by HRMANTRA

C. Processing based on consent

In the following cases, HRMANTRA will process your Personal Data if you granted prior consent to the specific proposed processing of your Personal Data (Article 6(1) lit. a GDPR).  If you re-open this Privacy Statement after you initially grant one or more consents, you will see the full Privacy Statement and not just information on the consents you granted.

News about HRMANTRA's Products and Services. Subject to a respective provision and your consent, HRMANTRA may use your name, email and postal address, telephone number, job title and basic information about your employer (name, address, and industry) as well as an interaction profile based on prior interactions with HRMANTRA (prior purchases, participation in webinars, seminars, or events or the use of (web) services  - further details on this topic can be found in the Cookie Statement displayed on the relevant HRMANTRA website) in order to keep you up to date on the latest product announcements, software updates, software upgrades, special offers, and other information about HRMANTRA's software and services (including marketing-related newsletters) as well as events of HRMANTRA and in order to display relevant content on HRMANTRA's websites. In connection with these marketing-related activities, HRMANTRA may provide a hashed user ID to third party operated social networks or other web offerings (such as Twitter, LinkedIn, Facebook, Instagram or Google) where this information is then matched against the social networks' data or the web offerings' own data bases in order to display to you more relevant information.

Creating user profiles. HRMANTRA offers you the option to use its web offerings including forums, blogs, and networks (such as the HRMANTRA Community) linked to this website that require you to register and create a user profile. User profiles provide the option to display personal information about you to other users, including but not limited to your name, photo, social media accounts, postal or email address, or both, telephone number, personal interests, skills, and basic information about your company.

These profiles may relate to a single web offering of HRMANTRA or, if created in the HRMANTRA Cloud Platform Identity Authentication Service, may also allow you to access other web offerings of HRMANTRA or of other entities of the HRMANTRA Group, or both (irrespective of any consent granted under the section "Forwarding your Personal Data to other HRMANTRA companies." below). It is, however, always your choice which of these additional web offerings you use and your Personal Data is only forwarded to them once you initially access them. Kindly note that without your consent for HRMANTRA to create such user profiles HRMANTRA will not be in a position to offer such services to you where your consent is a statutory requirement that HRMANTRA can provide these services to you.

Within any web offering, beyond the mere provision of access your profile is used to personalize interaction with other users (for example, by way of messaging or follow functionality) and by HRMANTRA to foster the quality of communication and collaboration through such offerings and for HRMANTRA to provide gamification elements (gamification is the process of taking something that already exists, such as a website, an enterprise application, or an online community, and integrating game mechanics into it to motivate participation, engagement, and loyalty). To the greatest extent supported by the relevant web offering, you can use the functionality of the relevant web offering to determine which information you want to share.

Special categories of Personal Data. In connection with the registration for and provision of access to an event or seminar, HRMANTRA may ask for information about your health for the purpose of identifying and being considerate of individuals who have

disabilities or special dietary requirements throughout the event. Any such use of information is based on the consent you grant hereunder. Kindly note that if you do not provide any such information about disabilities or special dietary requirements, HRMANTRA will not be able to take any respective precautions.

Event profiling. If you register for an event, seminar, or webinar of HRMANTRA, HRMANTRA may share basic participant information (your name, company, and email address) with other participants of the same event, seminar, or webinar for the purpose of communication and the exchange of ideas.

Forwarding your Personal Data to other HRMANTRA companies. HRMANTRA may transfer your Personal Data to other entities in the HRMANTRA Group. In such cases, these entities will then use the Personal Data for the same purposes and under the same conditions as outlined in this Section C. above.

Forwarding your Personal Data to other third Parties. At your request, as indicated by your consent, HRMANTRA will transfer your registration data to the companies listed on the registration page. The companies will use your registration data for the purposes of their participation in the event and are obliged to delete the data thereafter. If a company intends to use your data for any other purposes, they will contact you to explain how and for which other purposes they will use your registration data.

Revocation of a consent granted hereunder. You may at any time withdraw a consent granted hereunder by unsubscribing at https://www.hrmantra.com. In case of withdrawal, HRMANTRA will not process Personal Data subject to this consent any longer unless legally required to do so. In case HRMANTRA is required to retain your Personal Data for legal reasons your Personal Data will be restricted from further processing and only retained for the term required by law. However, any withdrawal has no effect on past processing of personal data by HRMANTRA up to the point in time of your withdrawal. Furthermore, if your use of an HRMANTRA offering requires your prior consent, HRMANTRA will not be (any longer) able to provide the relevant service (or services, if you revoke the consent for HRMANTRA to use your profile under the HRMANTRA Cloud Platform Identity Authentication Service for multiple HRMANTRA offerings), offer or event to you after your revocation.

D. Cookies and similar tools

Information gathered by cookies or similar technologies, and any use of such information, is further described in our Cookie Policy Page. You can exercise your cookie preferences as outlined in that page.

E. Additional Country-Specific Provisions

Where HRMANTRA is subject to U.S. privacy requirements, the following also applies:

Do Not Track. Your browser may allow you to set a "Do not track" preference. Unless otherwise stated, our sites do not honor "Do not track" requests. However, you may elect not to accept cookies by changing the designated settings on your web browser or, where available, by referring to our Cookie Statement. Cookies are small text files placed on your computer while visiting certain sites on the Internet used to identify your computer. Please note that if you do not accept cookies, you may not be able to use certain functions and features of our site. This site does not allow third parties to gather information about you over time and across sites. 

Where HRMANTRA is subject to Brazil regulations, the following also applies: Brazilian Law allows companies to send e-mails to potential customers conditioned to the inclusion of an opt-out mechanism and a link to a privacy statement. 

Russian specified provisions apply to citizens of the Russian Federation.

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