Objective 

The purpose of this policy is to safeguard the privacy and protect the personal information of employees, contractors, vendors, interns, associates, customers, and business partners of Integre Solutions Pvt Ltd and to ensure compliance with applicable laws and regulations (refer to Annexure A ‘Data Privacy Annexures’ document) relevant to Integre Solutions Pvt Ltd (hereafter referred to as “Integre” or “the organization”).

Scope 

This policy applies to all Integre employees, contractors, vendors, interns, associates, customers, and business partners who may receive, access, or provide personal information to the organization. It applies globally to all who handle personal data collected or processed by Integre. All Integre employees are expected to support this privacy policy when collecting, processing, or managing personal information. This policy helps to ensure the organization’s commitment to data privacy. 

All partner firms and third parties working with or for Integre, and who may have access to personal information, are required to read, understand, and comply with this policy. No third party may access personal data held by the organization without a confidentiality agreement in place.

Responsibilities 

The Data Privacy Officer (Refer Annexure 2 ‘Data Privacy Annexures’ document) is responsible for the upkeep and accuracy of this policy. Any questions regarding the implementation of the policy should be directed to the Data Privacy Officer. 

The policy will be reviewed annually or updated as necessary in line with organizational changes or based on feedback from internal or external audits.

Policy Compliance 

The Privacy Review Team (Refer Annexure 2 ‘Data Privacy Annexures’ document) will conduct annual reviews to ensure ongoing compliance. If non-compliance is identified, the Data Privacy Officer will assess the situation and propose remedial actions to the Privacy Review Team. Persistent non-compliance may result in disciplinary action, in accordance with Integre’s Disciplinary Policy.

Data Privacy Principles 

This policy outlines Integre’s commitment to generally accepted privacy principles (GAPP) for the appropriate use of personal information. The following principles guide how personal data is collected, used, and managed:

• Notice: Integre will inform data subjects about how their personal information is collected, used, and disclosed.
• Choice and Consent: Integre will offer data subjects options regarding how their personal information is collected and used, and will obtain their consent where required.
• Rights of Data Subjects: Data subjects have the right to access, modify, erase, or object to the processing of their personal data.
• Collection: Integre will collect personal information only for specified purposes and as outlined in privacy notices or contractual agreements.
• Use, Retention, and Disposal: Personal information will be used for intended purposes and retained only as long as necessary. It will be securely disposed of once its purpose is fulfilled.
• Access: Data subjects may request to access or update their personal data.
• Disclosure to Third Parties: Personal information will only be shared with third parties as specified in privacy notices or agreements, and appropriate protection measures will be ensured.
• Security: Integre will protect personal information from unauthorized access, misuse, and data breaches.
• Quality: Integre will take steps to ensure the accuracy and relevance of personal data.
• Monitoring and Enforcement: Compliance with privacy policies will be regularly monitored both internally and with third parties, and mechanisms will be established to resolve complaints or disputes.

Notice 

Notice will be provided to data subjects about how their personal information is collected and used, either online or offline. In the event of cross-border data transfers, data subjects will be informed in advance. The notice will outline the purpose of data collection, who will collect it, and the rights of the data subjects regarding its use and disclosure.

Choice and Consent 

Data subjects will be informed of their choices regarding the collection, use, and disclosure of personal information, and consent will be obtained when required. Integre will document data subject preferences and ensure compliance with their choices, including the option to withdraw consent at any time.

Collection of Personal Information 

Personal information will only be collected for legitimate business purposes, and unnecessary data collection will be avoided. Integre will ensure that data collection methods comply with its privacy standards and that third-party data collection is also compliant.

Use, Retention, and Disposal 

Personal information will only be used for purposes specified in privacy notices or contracts. When no longer needed, the data will be securely disposed of or anonymized. Regular reviews of retention periods will be conducted, and any changes will be communicated to data subjects.

Access 

Data subjects can request access to their personal information or request corrections. Integre will respond to access requests within a specified timeframe and ensure that data provided is clear and comprehensible.

Disclosure to Third Parties 

Personal information may be disclosed to third parties for legitimate business purposes, as specified in privacy notices or agreements. Third parties must sign non-disclosure agreements (NDAs) to ensure the protection of personal data.

Security 

Integre will implement information security measures to protect personal data from unauthorized access or disclosure. Incident response protocols will be established to manage any data breaches, and any breach must be reported to the Data Privacy Officer within a specified timeframe.

Quality 

Integre will ensure that personal information is accurate, relevant, and complete for the intended purposes. Regular audits will be conducted to maintain data quality.

Monitoring and Enforcement 

Integre will monitor compliance with this policy and enforce it through internal audits, complaint resolution mechanisms, and a clear dispute resolution process for both employees and third parties.

This policy ensures that Integre Solutions Pvt Ltd maintains the highest standards of data privacy and protection for all stakeholders involved.