Privacy policy
INTRODUCTION
This Privacy Policy (“Policy”) sets out the principles and practices adopted by Passing Gifts Private Limited (“Company”, “we”, “our”, or “us”) regarding the collection, use, processing, storage, and protection of Personally Identifiable Information (“PII”), which refers to any data that can directly or indirectly identify an individual, either alone or when combined with other information, including but not limited to your name, email address, location data, etc. This definition includes, but is not limited to, identifiers such as names, contact details, identification numbers, biometric data, and other personal attributes, as recognized under the Digital Personal Data Protection Act, 2023 (“DPDP Act”). We are committed to safeguarding the privacy rights of all individuals whose PII we handle.
SCOPE AND APPLICABILITY
This Policy applies to all PII collected or processed by the Company across its business operations, including information related to applicants, employees, contractors, interns, agents, project partners, former employees, and visitors (collectively referred to as “Data Principals”).
ACCOUNTABILITY
The Company is responsible for ensuring compliance with this Policy and applicable laws, including the DPDP Act. The Human Resources Department or any officer designated by it oversees the implementation and adherence to this Policy and data protection obligations.
LIMITING COLLECTION
We collect only such PII as is reasonably necessary for legitimate and lawful purposes, using fair and transparent means consistent with the DPDP Act. Such purposes include but are not limited to collecting and storing information to provide, improve, and administer our services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
CONSENT
We obtain free, specific, informed, unconditional, and unambiguous consent in writing from Data Principals before collecting, storing, or processing their PII, except where otherwise permitted by law. Consent shall be taken prior to collecting any information of the Data Principal and will be valid only if it involves a clear affirmative action explicitly agreeing to the processing for specified purposes. For instance, when a Data Principal visits our website, we will seek consent in the form of a tick-box prior to collecting any PII of such Data Principal.
TRANSPARENCY AND NOTICE
Every request for consent will be accompanied by a clear notice specifying the PII to be collected, the purposes of collection and processing, the Data Principal’s right to withdraw consent at any time, details of the grievance redressal officer, and instructions for filing complaints with the Data Protection Board of India.
LIMITING USE, DISCLOSURE, AND RETENTION
PII will be used strictly for the purposes for which it was collected, unless the Data Principal provides written consent for other uses. Disclosure to third parties will occur only with consent or as required by law. PII will be retained only as long as necessary and securely disposed of thereafter.
ACCURACY
We will maintain PII in an accurate, complete, and up-to-date form required for the purposes for which it was collected. Data Principals may request correction, updating, or deletion of their PII, and such requests will be addressed promptly in accordance with the DPDP Act.
SAFEGUARDS
Any PII collected, stored, and/or processed by us is safeguarded against unauthorized access, alteration, or disclosure, in accordance with the standards prescribed under the DPDP Act using appropriate organizational and technical security measures, including but not limited to encryption, Multi-Factor Authentication (MFA), password protections, and physical security controls. Employees handling PII are trained on their data protection responsibilities.
OPENNESS AND INDIVIDUAL ACCESS
Data Principals may request information of where their PII is stored, access such PII, and seek correction or deletion, subject to legal restrictions. The Company maintains transparency about its data management and protection practices.
RIGHTS OF DATA PRINCIPALS
Data Principals have the following enforceable rights, supported by robust internal procedures:
(a) Right of access information pertaining to their PII, including a summary of their PII and identities of any Data Processor appointed by the Company.
(b) Right to rectification, deletion, or restriction of data processing.
(c) Right to object to processing for legitimate purposes or profiling.
(d) Right to withdraw consent anytime.
(e) Right to nominate any other individual to exercise these rights in case of the Data Principal’s death/incapacity.
(f) Right to seek remedy and/or complaint redressal.
Data Principals may exercise any of their aforementioned rights by contacting the Human Resources Department at the contact details provided hereinbelow.
GRIEVANCE REDRESSAL
To address any concerns or complaints relating to the handling of your PII, the following Grievance Redressal Officer has been appointed:
Grievance Redressal Officer: Ms Kavita Nathan, Director of Finance
Contact No.: +91-12043 33019
Email Id: contactus@heiferindia.com
Please feel free to reach out to the Grievance Redressal Officer for timely resolution of your data privacy-related grievances. A response to your complaint will be provided within 30 days from the date of its submission.
CONTACT INFORMATION
For any inquiries, requests relating to Data Principal’s rights, or other privacy-related communications, please contact our designated personnel at:
(a) Human Resources Department: Ms Ankita Chowdhary
(b) Email: contactus@heiferindia.com
(c) Phone: +91-12043 33019
We are committed to responding to your concerns promptly and ensuring the protection of your personal data.