Effective Date of Current Policy: October 26, 2018
3. TRANSPARENCY/NOTICE—TYPES of Personal Information We Collect and How We Use It
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Xebia and the requirements of applicable law. Some of the ways that Xebia may collect Personal Information include:
You may provide Personal Information directly to Xebia through interacting with the Services, participating in surveys, during events such as sweepstakes, and requesting Services, or information.
As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
We endeavour to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
3.1 Types of Personal Information We Collect
Xebia collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, guests, and employees (collectively “Individuals”).
3.2 How Xebia Uses Your Information
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
Administrative Purposes. Xebia may use Personal Information about you for its administrative purposes, including to:
You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 6 below.
3.3 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout
Our uses of such Technologies fall into the following general categories:
If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
3.4 Third-Party Websites, Social Media Platforms, and Software Development Kits
The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Xebia does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
Xebia’s Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
3.5 Third-Party Payment Processing
From time to time, we may sell Virtual Items or Merchandise through our Services. When you make purchases through the Services, we process your payments through a Third-Party application (“App Stores”) and Social Networking Sites (“SNS”) such as Facebook. The Third-Party application may collect certain financial information from you to process a payment on behalf of Xebia, including your name, email address, address and other billing information.
4 Human Resources Data
Xebia collects Personal Information from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals.
We acquire, hold, use and Process Human Resources Data for a variety of business purposes including:
5 Onward Transfer—Xebia May Disclose Your Information
5.1 Information We Share
In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
5.2 Data Transfers
All Personal Information collected via or by Xebia may be stored anywhere in the world, including but not limited to, the India, United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Xebia, you consent to the storage of your Personal Information in these locations.
6 Opt-Out (RIGHT TO RESTRICT PROCESSING)
You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Xebia’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt-out to further Processing by contacting us using website. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
6.2 Email and Telephone Communications
We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
6.3 Mobile devices
Xebia may occasionally send you to push notifications through our mobile applications and other notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Xebia may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
6.4 Human Resources Data
With regard to Personal Information that Xebia receives in connection with the employment relationship, Xebia will use such Personal Information only for employment-related purposes as more fully described above. If Xebia intends to use this Personal Information for any other purpose, Xebia will notify the Individual and provide an opportunity to opt-out of such uses.
6.5 “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honour DNT signals or similar mechanisms transmitted by web browsers.
6.6 Cookies and Interest-Based Advertising
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at Click Here, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here.
7. Rights of Access, Rectification, Erasure, and Restriction
Although Xebia makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Xebia is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Xebia determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Xebia will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
8. Data Retention
9. Security of Your Information
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
10. International Users
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the India, and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
11. Children’s Privacy
The Services are not directed to children under 13 (and in certain jurisdictions under the age of 16) years of age, and Xebia does not knowingly collect Personally Identifiable Information from children under 13 (and in certain jurisdictions under the age of 16) years of age. If you are under the age of 18, you must have your parent’s permission to access the Services. Xebia urges parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when online. If you learn that your child has provided us with Personal Information without your consent, you may alert us at our website. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information and terminate the child’s Account.
12. Redress/Compliance and Accountability
The following capitalized terms shall have the meanings herein as set forth below.
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