AptusDataLabs Technologies Private Limited (“Company”, “Aptus Data Labs”, “”) is engaged in the business of building software products and solutions and provide consulting and technical services on Big Data & Advanced Analytics (“Services”) to clients all over the world (“Clients”). Personal information is collected by the Clients and provided as input data for the Company in order to provide the Services. Given the nature of the Company’s business, the Company does not collect Personal Information (as defined below).

While this Privacy Policy (“Policy”) applies to all Personal Information in the Company’s custody, it is specifically intended to comply with the Safe Harbour Principles, thereby enabling Clients to transmit Personal Information to the Company.

For the purposes of this Policy, “Personal Information” means data about an identified or identifiable individual received by the Company from any Client and recorded in any form and includes Sensitive Information. “Sensitive Information” shall mean Personal Information specifying personal, medical or health conditions, including but not limited to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual.


In the nature of its business, the Company does not collect information from any person. However, the Company may, for the purpose of rendering Services, receive Personal / Professional/ Business Information (“INFORMATION”) collected by Clients all over the globe. The Company does not disclose such information to any third party except to subsidiaries and only under obligations of confidentiality. The Company enters into Non-Disclosure Agreements (NDA) with all of its employees who may deal with such Information in the course of rendering Services. For any inquiries and complaints related to this Policy, the Company’s officer identified in the Enforcement clause below may be contacted.

As stated earlier in this Policy, the Company does not collect Information from any person. The Company reasonably presumes that the Clients who transmit Information to the Company have obtained appropriate consents, including affirmative consents in respect of Sensitive Information, from those to whom the Information belongs or relates to.

Onward Transfers:
The Company may, in order to perform the Services for Clients, transmit the Information onward to its subsidiaries. The Company shall have entered into contractual arrangements requiring them to provide the same privacy protection as incorporated in the Safe Harbour Principles read with this Policy. If any person has any inquiries in this regard or any complaints as regards onward transfer by the Company, or chooses not to have his or her Information so transmitted onward, the person may contact the Company officer / contact mentioned below.

If any person requests access to his or her Information held by the Company, including for the purpose of correct, amend, or delete that information where it is inaccurate, the Company shall provide such access within a reasonable time after informing the relevant Client of such request. Alternately, the Company shall request the relevant Client to provide access to the Information directly to the requester. This obligation shall not apply if in a given instance, the burden or expense of providing access would be disproportionate to the risks to the requester’s privacy in the case in question, or where the rights of persons other than the requester would be violated.

The Company shall take all reasonable precautions to protect Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Data Integrity:
Information received by the Company shall be relevant for the purposes for which it is to be used. The Company shall not process such Information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the Client and/or individual. The Company shall take reasonable steps to ensure that the reliability of the Information for its intended use, or its accuracy, completeness and currency, are not affected.

For any inquiries and complaints, please email at [email protected]. All inquiries and complaints shall be looked into promptly and without charging any fee to the inquirer / complainant. Since the Company merely receives Information from Clients and does not collect the Information itself, the Company shall keep informed and cooperate with the Client from whom the Information related to the inquiry / complaint was received. The Company shall also cooperate with the Data Protection authorities of the European Union in the investigation and resolution of complaints in relation to the treatment of Information under this Policy. The Company will comply with any advice given by such authorities in relation to any complaint.

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