Data Privacy

1. Introduction

Nihilent Limited (hereafter referred as “Nihilent” or “company” or “we” or “our” or “us” or “organization”) includes all the Nihilent entities established in different regions across the globe. Nihilent respects your right to data privacy. In this Notice “You” or “Your” refers to data subject (customers, employees, website visitors or contingent workers) whose personal data is processed by Nihilent.

This privacy notice explains who we are, how we collect, share, and use personal data about you, and how you can exercise your data privacy rights. The details on what personal data will be processed and which method will be used depend significantly on the services applied for or agreed upon.

Nihilent complies with all applicable data protection laws, including, without limitation, the South Africa Protection of Personal Information Act (hereafter referred to as POPI Act), the UK Data Protection Act (hereafter referred to as UK DPA), the California Consumer Privacy Act (hereafter referred to as CCPA), and Australia Privacy Act (hereafter referred to as APA).

2. What does Nihilent do?

Nihilent is a global consulting and services company using design thinking approach to problem-solving and integrated change management. Nihilent provides a comprehensive range of process and technology-led transformation services leveraging advanced analytics, artificial intelligence, block chain, business intelligence, data science, cloud services, IoT, and machine learning. We focus these services to Banking, Financial Services, Insurance, Retail, Supply Chain & Manufacturing, Media and Entertainment, and Healthcare organizations. Nihilent has operations across Africa, Asia, Europe, Australia, the Middle East, and the USA.

This notice covers personal data of South Africa, California, Australia, and UK residents that is collected and/or shared by Nihilent. Additional information on ‘South Africa, California, UK and Australian residents’ rights required under the POPI Act, CCPA, UK DPA and APA may be found in the “Protection of Personal Information Act, South Africa”, “California Consumer Privacy Act, United States”, “Data Protection Act, UK” and “Privacy Act, Australia” sections below. References to specific terminologies used throughout this notice shall have the same meaning derived from the relevant definitions set forth by the applicable law.

Because Nihilent respects your right to privacy, it has implemented privacy practices in the provision of its services, products, and website, including in accordance with POPI Act, the Australian Privacy Principles (“APPs”), CCPA and UK DPA.

3. Protection of Personal Information Act, South Africa

3.1 Rights of Data Subjects residing in South Africa

• Right to Access: You have the right to request a copy of the personal information we hold about you. You may do this by contacting us at and specify what information you require. We will take all reasonable steps to confirm your identity before providing details of your personal information. Please note that any such access request may be subject to a payment of a legally allowable fee.

• Right to Rectification: You have the right to ask us to update and correct your personal information. You may do this by contacting us at . We will take all reasonable steps to confirm your identity before making changes to personal information we may hold about you. We shall provide you with credible evidence in support of the correction of your personal information. We shall also notify you for the action taken as a result of the request with respect to correction of your personal information. Please note that any such request may be subject to a payment of a legally allowable fee.

• Right to Erasure: You have the right to ask us to delete your personal information. You may do this by contacting us at . We will take all reasonable steps to confirm your identity before deleting your personal information we may hold about you. However, we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Right to Object: You have the right to object, on reasonable grounds to the processing of personal information or to direct marketing communications. You may do this by contacting us at . We will take all reasonable steps to confirm your identity before processing your request. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which means we can continue to process your personal information.

• Right to Restriction of Processing: You have the right to ask us to restrict the processing of personal information we may hold about you. You may do this by contacting us at . We will take all reasonable steps to confirm your identity before processing your request.

• Right not to be subject to automated decision making: You have the right not to be subject, under certain circumstances, to a decision which is based solely on the automated processing of personal information. To object to automated processing of your personal information, you may contact us at . We will take all reasonable steps to confirm your identity before processing your request. However, Nihilent does not perform automated decision making.

• Right to lodge a complaint to information officer: You have the right to lodge a complaint to Information Regulator regarding any interference with the protection of the personal information.

3.2 International transfer
We share your personal information within the group on need-to-know basis. This may involve transferring your personal information to a third party who is in a foreign country. Whenever we transfer personal information to a third party in foreign country, we ensure an adequate level of protection is offered through Binding Corporate Rules or Binding Agreement.

3.3 Consequences of not providing Personal Information
If you choose not to provide your Personal Information that is mandatory to process your request, we may not be able to provide the corresponding service.

4. California Consumer Privacy Act, United States

4.1 Right of Consumers residing in the State of California
Effective January 1, 2020, and unless otherwise stated in this notice the practices and activities detailed herein also apply to you if you were considered to be a California resident during the collection of your personal information. As a California resident, you may have:

• Right to Access: This enables you to receive a copy of the personal information we hold about you. We will be able to provide personal information/ sensitive personal information collected in the 12 months prior to the request.

• Right to Erasure: This will enable you to ask us, in certain situations, to delete or remove personal information unless our processing is specifically permitted under the CCPA.

• Right to Rectification: This will enable you to ask us to correct or update personal information we hold about you.

• Right to Limit Use and Disclosure of Sensitive Personal Information: This enables you to ask us, in certain circumstances, to provide you with the categories of personal information we disclose to third parties for sale or business purposes and to limit the use of your sensitive personal information to that use which is necessary to perform the services. Nihilent does not sell your personal information.

• Right to Data portability: This enables you to ask us, in certain circumstances, to provide you with the personal information you have provided to us in a structured, commonly used and machine-readable format or to transmit the personal information that you have provided to us to another business.

• Right to opt-out: This enables you to opt-out of the sale of your personal information by a business to other third parties. As Nihilent does not sell your personal information under any circumstances, this right does not apply to your personal information with Nihilent.

• Right to non-discrimination: This specifies that Nihilent will not discriminate against you in any way or under any circumstance for exercising your rights to your information under the CCPA.

  You may inform us that you want to exercise your rights in accordance with the “Contact Details” section below. Nihilent will verify your identity before processing any requests and you are entitled to make such request no more than twice in a 12-month period. Please also note that the CCPA contemplates certain exemptions or exceptions for certain types of transactions or other reasons contemplated by law. If you contact Nihilent regarding your personal information and an exemption or exception applies, we will inform you of that fact. California residents requesting erasure of their personal information must also review the “Considerations on Data Erasure” section below.

4.2 Time limit to respond
We try to respond to all legitimate requests within 45 days. However, the period may be extended by additional 45 days where necessary, taking into account the complexity and number of the requests. In such case we will inform you of any such extension within 45 days of receipt of this request.

4.3 Updates to Privacy Notice
Nihilent shall update this privacy notice every 12 months as per the California Consumer Privacy Act, 2018.

5. Privacy Act, Australia

5.1 Right of Individuals residing in Australia
Nihilent has adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (the Privacy Act). Nihilent abides by the APPs, which provides a scheme in relation to the collection, disclosure, use and storage of personal information.

• Request Access to your Personal Information: You may request details related to the personal information that we hold about you in accordance with the provisions of the Privacy Act. If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant, or misleading, you may send a request to Nihilent using the “Contact Details” section below.

• Request correction of your personal information: You may request amendments or corrections, if your personal information is inaccurate, irrelevant, or outdated, or incomplete.

Where lawful and practicable (i.e., if we are still able to provide the relevant service or information to you without your information), you may choose to deal with Nihilent anonymously or under a pseudonym.

5.2 International Transfer of Personal Information
Generally, your personal information is likely to be stored in your country of residence. However, some Nihilent entities and service providers are located overseas, and in some instances, your personal information may be transferred to or processed by Nihilent entities and service providers in overseas countries.

If there is an international transfer of personal information (whether by disclosing it to such parties or merely by allowing them to access it) we will take appropriate steps to ensure that it is carried out in accordance with the applicable privacy laws and the APPs. Whenever we transfer personal information to a third party in foreign country, we ensure an adequate level of protection is offered through Binding Agreement. We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information. Nihilent may obtain your consent to send your personal information to a recipient in a country that does not provide adequate level of protection for personal information. If you have any questions about the collection, use, disclosure, or storage of your personal information, please contact us using the details present in the “Contact Details” section below.

5.3 Complaints
Additionally, if you have a complaint about our privacy practices, please submit the details of your complaint using the “Contact Details” section below. Please note that your complaint must made in writing, and we will respond within a reasonable time as determined by the Privacy Act.

6. Data Protection Act, UK

6.1 Right of data subjects residing in UK
For rights of the data subjects pertaining to UK DPA, please refer to the ‘Your rights in connection with personal data’ section of the primary privacy statement on Nihilent’s website.

6.2 Restriction of Data Subject Rights
Nihilent may restrict, wholly or partly, the provision of information to the data subject (residing in UK) under Data Subject Rights in the following cases:

• To avoid obstructing an official or legal inquiry, investigation, or procedure.

• To avoid prejudicing the prevention, detection, investigation, or prosecution of criminal offences or the execution of criminal penalties.

• To protect public security.

• To protect national security.

• To protect the rights and freedoms of others.

6.3 Time limit to respond
We try to respond to all legitimate requests within 1 month. However, the period may be extended further by two months where necessary, taking into account the complexity and number of the requests. In such case we will inform you of any such extension within one month of receipt of the request.

6.4 International Transfer
We share your personal information within the group on need-to-know basis. This may involve transferring your personal data to a third party who is in a foreign country. Whenever we transfer personal data to a third party in foreign country, we ensure an adequate level of protection is offered through:

• Binding Corporate Rules or Binding Agreement.

• Adequacy decision.

• A transfer of personal data to a third country or an international organisation having appropriate safeguards.

7. Security

Nihilent utilizes appropriate technical and organizational measures to ensure that the confidentiality, integrity and availability of our systems and services protect your personal data. We take all reasonable steps to ensure that the personal data we hold is protected from misuse, interference, loss, unauthorized access, modification, or disclosure using various methods, including secure storage.

8. Considerations on Data Erasure

When processing a valid request for erasure of personal data in accordance with this privacy notice and applicable laws, Nihilent will promptly erase personal data from live systems based on the scope defined between the parties. Where data erasure applies to you, please also consider the following:

• Depending on the extent of your relationship with Nihilent, your data may be retained in Nihilent’s backup systems for a longer period of time in a format that is beyond use.

• Backup systems play a crucial role in Nihilent’s data security program and in ensuring the availability and access to data in a timely manner in the event of a physical or technical incident.

• Data erasure on certain backup systems may not be immediately possible due to existing technical controls.

• Relevant data retained in certain backup systems will not be used for any other purpose and will be secured with the appropriate technical and organizational measures based on the requirements of data protection law; and

• Relevant data retained in backup systems will be kept until such data is overwritten and completely erased based on Nihilent’s internal backup retention schedule and policies.

9. Regulatory Authority

You have the right to lodge a complaint to Regulatory Authority with respect to the processing of personal data as per POPI Act and UK DPA. If you have any questions or concerns, you may reach out to the Regulatory Authority at:

Contact details of the Information Regulator as per POPI Act:
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Email:

Contact details of the Information Commissioner as per UK DPA:
Water Lane, Wycliffe House Wilmslow – Cheshire SK9 5AF UNITED KINGDOM
Email:

10. Contact Details

If you have any questions or complaints regarding our privacy practices or this privacy statement, please contact us at:

There is no charge for lodging a complaint.

How we will deal with such a complaint: We will write to you acknowledging receipt of the complaint. After appropriate investigation, Nihilent will write to you as soon as practicable after a decision has been reached, outlining the decision and the reasons for reaching it.

Last Modified: 19 October 2023

Introduction

Nihilent Limited (hereafter referred as “Nihilent” or “company” or “we” or “our” or “us” or “organization”) includes all the Nihilent entities established in different regions across the globe. Nihilent has issued this data privacy statement to describe how we handle personal data of the applicants (hereafter referred to as “You” and “Your”) for permanent and temporary positions at Nihilent.

We respect the data privacy rights of individuals and are committed to handling personal data appropriately and in accordance with applicable laws. It is important that you read this data privacy statement carefully as it sets out how we handle your personal data when you apply for a job or other role with us and the rights you have in connection with that data collected. The term “applicants” is used in this data privacy statement to refer to anyone who applies for a job role, or who otherwise seeks to work with or for us (whether on a permanent or temporary basis).

Definitions:

‘Data Subject’ or ‘Individual’ or ‘Consumer’ – An identified or identifiable living individual natural person.

‘Personal Data’ or ‘Personal Information’ – Any information relating to a data subject who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that data subject.

‘Processing’ – Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

‘Special category of data’ or ‘Sensitive Personal Data’ or ‘Special Personal Information’ or ‘Sensitive Information’ or ‘Sensitive Personal Information’ – Special category of personal data: data that reveals your racial or ethnic origin, religious, political, or philosophical beliefs or trade union membership; genetic data; biometric data for the purposes of unique identification; or data concerning your health / sex life.

‘Contingent workers’ – Contingent workers means non-permanent workers including agents, consultants, independent contractors, sub-contractors, temporary workers, professional advisors, interns and those affiliated with third parties.

‘Controller’ or ‘Responsible Party’ or ‘Business’ or ‘APP entity’ – 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.

‘Processor’ or ‘Operator’ or ‘Service Provider’ or ‘APP entity’ – Processor means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.

‘Joint controller’ – Where two or more controllers jointly determine the purposes and means of processing, they shall be joint controllers.

‘Data Protection Officer’ or ‘Information Officer’ or ‘Privacy Officer’ – Data Protection Officer refers to an individual appointed by Nihilent for managing organizational data protection and overseeing compliance as per EU General Data Protection Regulation, UK Data Protection Act, South Africa Protection of Personal Information Act and Australia Privacy Act.

‘Third Party’ – Third Party means a natural or legal person, public authority, agency, or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

If you have any questions or concerns about our processing of your personal data, then please contact us using the contact details provided.

What does Nihilent do?

Nihilent is a global consulting and services company using design thinking approach to problem-solving and integrated change management. Nihilent provides a comprehensive range of process and technology-led transformation services leveraging advanced analytics, artificial intelligence, block chain, business intelligence, data science, cloud services, IoT, and machine learning. We focus these services to Banking, Financial Services, Insurance, Retail, Supply Chain & Manufacturing, Media and Entertainment, and Healthcare organizations. Nihilent has operations across Africa, Asia, Europe, Australia, the Middle East, and the USA.

For more information about Nihilent, please see the “About us” section on the Website at https://www.nihilent.com/about/

Data Protection Officer

Nihilent has appointed a Data Protection Officer (DPO) for you to contact if you have any questions or concerns about the Nihilent personal data policies or practices. If you have any questions or concerns about this data privacy statement or how we handle your personal data, please contact the DPO at

Nihilent’ s DPO name and contact information are as follows:
Mr. Abhay Ghate (Data Protection Officer)
Nihilent Ltd.,
4th Floor, ‘D’ Block, Nagar Road,
Weikfield It Citi Infopark,
Maharashtra, Pune – 411014.

Tel: +91(20) 3984 6100

What personal data does Nihilent collect and why?

Personal Data collected from you
The types of personal data we collect and process when you apply for a role with Nihilent includes (but is not limited to):

• Identification data and contact details – such as your name, address, email address, phone number, photograph and other contact information, gender, date of birth, nationality/ies, national identifiers (such as Aadhaar, passport, driving license number, PAN card number).

• Background information – such as academic / professional qualifications, details included in your CV / resume (which might include details of any memberships or interests constituting “special category of data”, a term which we define below), criminal records data (for verification purposes, where permissible and required in accordance with applicable law).

• Previous applications / roles – such as data relating to previous applications you have made to us. This could include data on any previous employment history with us or Group.

• Other data you voluntarily provide – throughout the process, including through assessment centers/ exercises, social interaction, meetings, and interviews.

Generally, during the recruitment process, we intent not to collect or process any special category of personal data: data that reveals your racial or ethnic origin, religious, political, or philosophical beliefs or trade union membership; genetic data; biometric data for the purposes of unique identification; or data concerning your health / sex life unless required by applicable laws or where necessary to comply with applicable laws.

However, in certain circumstances, we may need to collect or request on a voluntary disclosure basis, special category of personal data for legitimate purposes: for example, data about your racial / ethnic origin, gender and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws and for government and regulatory reporting obligations, where applicable. Another example where we might request voluntary disclosure of special category of data is about your physical or mental condition and data collected during your health check-up so that we can consider how we might accommodate you during the recruitment process and / or subsequent job role if we do recruit you.

You may provide, on a voluntary basis, other special category of personal data during the recruitment process, for example your CV may state that your interests include activities involving a particular religious group or a group which espouses particular political of philosophical views.

We may collect your Special Category of Personal Data in certain cases after obtaining your consent, wherever necessary.

Personal data collected from other sources

• References provided by referees.

• Other background data provided or confirmed by academic institutions and training or certification providers.

• Criminal records data obtained through criminal records checks. (We will not carry out such checks without your explicit consent unless required for any legitimate purpose or lawful processing).

• Data provided by recruitment or executive search agencies.

• Pre-employment health checkup performed only for Indian applicants/employees where data is provided by diagnostic centres/pathological labs and

• Data collected from social networks and social media platforms.

Personal Data that we collect automatically
Our cookie statement and data privacy statement are available on the website and will inform you about how we collect certain personal data automatically from your device when you visit our website.

We collect and process the personal data for:
We collect and process the personal data for recruitment purposes, in particular, to determine your qualifications for employment and to reach a hiring decision. This includes assessing your skills, qualifications, and background for a particular role, verifying your data, carrying our reference checks or background checks (where required) and generally to manage the hiring process and communicate with you about it.

If you are accepted for a role at Nihilent, the data collected and processed during the recruitment process will form part of your ongoing staff member record and will be processed in accordance with our data privacy statement.

If you are not successful, we may still keep your personal data to allow us to consider you for other suitable openings within Nihilent or other Group companies in the future unless you request that we delete your personal data. We will hold onto such data until we destroy it which is securely in accordance with our local data retention practice.

Change of Purpose

We will only use your personal data for the purposes for which it was collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the contact details provided.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.

Legal basis for processing personal data

Our legal basis for processing your personal data as part of the recruitment process is:

• our legitimate interests (which are not overridden by your data protection interests or fundamental rights and freedoms, particularly taking into consideration the safeguards that we put in place).

• to comply with applicable immigration and / or employment laws and regulations and legal obligations.

• to take steps prior to entering into an employment contract with you, where you are considered for employment.

• where processing is required for your vital interest or of another data subject.

• in circumstances where we have made the data public or tasks carried out in public interest.

• where we have your consent to do so. Where we have requested your consent to process your personal data, you have the right to withdraw your consent.

If we request you to provide personal data to comply with any legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data).

Who does Nihilent share my personal data with?

We allow access to your personal data only to those who require such access to perform their tasks and duties, and to contingent workers who have a legitimate purpose for accessing it. Whenever we allow a contingent worker to access personal data, we will implement appropriate measures to ensure the data is used in a manner consistent with this data privacy statement and ensure that the confidentiality, availability and integrity of the data is maintained.

a) Transfers to other group companies
We may share your personal data with other Group companies as part of our recruitment processes. Where we do share personal data with other Group companies this will include sending your personal data outside your country of residence.

b) Transfers to contingent workers
We may make certain personal data available to contingent workers who provide services relating to the recruitment process to us:

• recruitment or executive search agencies involved in your recruitment.

• background checking or other screening providers (with your consent) and relevant local criminal records checking agencies.

• shared services and recruitment platform providers, IT developers and support providers.

• contingent workers who provide support and advice including in relation to legal, insurance, health and safety, security and/ reporting issues.

We may also disclose your personal data to contingent workers on other lawful grounds, including:

• Where we have your consent to do so. Where we have requested your consent to process your personal data, you have the right to withdraw your consent.

• To comply with legal obligations, including where necessary to abide by applicable laws, regulations, or contractual obligations, or to respond to a court order, administrative or judiciary processes, including, but not limited to, a subpoena, government audit or search warrant.

• In response to lawful requests by public authorities or government agencies (including for tax, immigration, health, and safety, national security, or law enforcement purposes).

• Where necessary to protect your vital interests or of another data subject

• As necessary to establish, exercise or defend against potential, threatened or actual legal claims or litigations.

• In connection with the sale, assignment or other transfer of all or part of our business.

c) Transfers to third countries and international organisations
Your personal data may be transferred to, and processed in, countries other than the country in which you reside, or your data was collected. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Our group companies, contingent workers may operate around the world. This means that when we collect your personal data, we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal data will remain protected in accordance with this data privacy statement. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal data between our group companies, which require all group companies to protect personal data they process from the EEA in accordance with European Union data protection law

We have implemented similar appropriate safeguards with our contingent workers and further details can be provided upon request.

A list of third countries and international organization to whom personal data may be shared can be made available upon request to DPO.

How does Nihilent keep my personal data secure?

We use appropriate technical and organizational measures to protect the personal data that we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data

Sensitive data like, Passwords are protected for data in transit by data encryption. In addition to encryption, we have implemented robust network security controls to help protect data in transit. Network security solutions like firewalls and / or network access control to secure the networks used to transmit data against malware attacks or intrusions.

We use secure means to communicate with you where appropriate, such as ‘https’ and other security and encryption protocols.

If you have any concerns about the security of your own personal computers and mobile devices, we suggest you read the advice of ‘Get Safe Online’, which can be accessed here.

How long does Nihilent keep my personal data?

We retain personal data we process where we have legitimate interest, performance of the contract, vital interest of data subject or of another natural person, performance of a task carried out in the public interest or in the exercise of official authority vested or for the purposes of satisfying any legal, accounting, or other regulatory reporting requirements or with your consent.

When any of the above requirement cease to exist, we will either delete or if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible. Personal data will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this data privacy statement or as otherwise required by applicable laws.

Automated Decision Making

Automated decisions are decisions concerning you which are made automatically on the basis of a computer determination (using software algorithms), without human intervention. We do not use automated decision making.

What are your data protection rights?

Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes by keeping your details up to date on our website.

Your rights in connection with personal data
Under certain circumstances, by law you have the right to:

• Request access: To your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request rectification: Of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. We may need to verify the accuracy of any new data you provide to us.

• Request erasure: Of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing: Of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which means we can continue to process your personal data.

• Request the restriction of processing:Of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • if you want us to establish the data’s accuracy.

  • where our use of the data is unlawful but you do not want us to erase it.

  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

• Request for portability: Of your personal data to another party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Right to withdraw consent at any time: Where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

• Right to lodge a complaint with a Supervisory authority: In case you consider that the processing of your personal data infringes any of your rights or provisions related to the laws and regulations in scope.

Fees for excessive or unreasonable requests
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Time limit to respond
We try to respond to all legitimate requests within 30-45 days. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

We may also contact you to ask you for further information in relation to your request to speed up our response

If you wish to exercise any of the rights set out above, please contact us at

Changes to this data privacy statement

We may update this data privacy statement from time to time in response to emerging legal, technical, contractual, regulatory, or business developments. When we update our data privacy statement, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material data privacy statement changes if and where this is required by applicable laws.

You can see when this data privacy statement was last updated by checking the “Last Modified” date displayed at the end of this data privacy statement.

For additional requirements pertaining to Privacy Act, Australia, Protection of Personal Information Act, South Africa, Data Protection Act, UK, and California Consumer Privacy Act, US refer to our Privacy Statement-Annexure.

Last Modified: 19 October 2023