The Chief Technology Officer and Information Security Team.
As stated in the Company Information Security Program Charter, the Company will follow a risk management approach to developing and implementing Information Security policies, standards, guidelines, and procedures. The Information Security Program is designed to protect information assets by developing Information Security policies to identify, classify, and define the acceptable use of company information assets.
The types of personal data include names, addresses, phone numbers, birthdates, social security numbers, tax identification numbers, national insurance numbers and financial account numbers.
The Policy applies to all employees, contractors, consultants and vendors who access, use or control company resources.
The Company adheres to legal, regulatory and customer privacy requirements.
The Company collects personally identifiable information when voluntarily submitted by our online and onsite visitors. The information provided is used to fulfil specific requests unless given permission to use it in another manner.
ln connection with the services we provide, the Company may collect the following types of information:
Personally Identifiable Information. Names, addresses, email addresses, phone numbers, birthdates, Aadhaar, tax identification, financial account, national insurance numbers, and company information.
Cookies. When a visitor views Company websites, a cookie is sent out to the viewer’s computer that will identify the visitor’s browser. These cookies enable the website to recognize the visitor’s computer the next time the visitor views the Company website. These cookies will be used exclusively to collect information concerning the use of the website. Cookies contain no personally identifiable data, so the visitor’s personally identifiable information is not collected or retained.
User Communications. When a visitor sends an email or other communication to the Company, these communications may be retained in order to process inquiries, respond to requests, and improve overall services.
Affiliated Websites. Personal information that a visitor may provide to websites affiliated with the Company may be sent to the Company in order to deliver services to the Company or other entities affiliated which the Company provides. The Company processes such information in accordance with the Policy.
The Company reserves the right to collect and process personal information in the course of providing services to our clients without the knowledge of individuals involved. Where the Company collects personal information from individuals within the Indian region, upon request, the Company will inform them about the types of person information collected from them, the purposes for which it was collected, and uses of the information, and the types of non-agent third parties to which the Company discloses that information.
The Company may share information with governmental agencies or other companies assisting in fraud prevention or investigation. The Company may do so when: Permitted or required by law
Trying to protect against or prevent actual or potential fraud or unauthorized transactions
Investigating fraud which has already taken place
This information, however, is not provided to these companies for marketing purposes.
Permitted transfers of information, either to third parties or within the Company, include the transfer of information within the India region and shall not be moved out of one jurisdiction to another.
The Company takes reasonable steps to protect personally identifiable information. To prevent unauthorized access or disclosure of personally identifiable information, maintain data accuracy, and support the appropriate use and confidentiality of personally identifiable information, either for its own purposes or on behalf of our clients, the Company has put in place appropriate physical, technical, and managerial procedures to safeguard and secure the personally identifiable information and data the Company possesses.
The Company collects and maintains personally identifiable information in a manner that is compatible with the purpose for which it was collected and maintained, or as subsequently authorized by an individual or client. To the extent necessary for such purposes, the Company takes reasonable steps to confirm that personal information is accurate and complete with regard to its intended use.
Whenever the Company is processing personal data, it will take reasonable steps to keep personal data accurate and up-to-date for the purposes for which they were collected. It will provide data subjects with the ability to exercise the following rights under the conditions and within the limits set forth in the law. If you wish to contact us regarding the use of your personal data or want to object in whole or in part to the processing of your personal data, please contact us. If you have provided consent, you may withdraw consent. You may also request, subject to confidentiality obligations,to:
Access your personal data as processed by the Company
Ask for correction or erasure of your personal data
Request portability, where applicable, of your personal data, i.e., that the personal data you have provided to the Company, are returned to you or transferred to the person of your choice, in a structured, commonly used and machine-readable format.
Information obtained from or relating to clients or former clients is further subject to the terms of any privacy notice provided to the client, any contract or other agreement with the client, and application enforcement laws.
The Company will cooperate with the appropriate regulatory authorities, including local data protection regulatory authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between the Company and an individual.
5. Policy Compliance
6. Policy Enforcement and Compliance
Compliance with the policy is mandatory and Spocto department managers shall ensure continuous compliance monitoring within their department. Compliance with the statements of the policy is a matter of periodic review.
Any breach of the policy may constitute a security violation and gives Spocto the right to conduct disciplinary and / or legal action, up to and including termination of employment or business relationship.
7. Document Management
Technological advances and changes in the business requirements will necessitate periodic revisions to documents. Therefore, this document may be updated to reflect changes or define new or improved requirements as and when required and in compliance with the Information Security Program Charter.
Any change will require the approval of the Information Security Steering Committee (ISSC).
The preservation of confidentiality, integrity and availability of information; in addition, other properties, such as authenticity, accountability, non- repudiation, and reliability can also be involved.
A plan of action to guide decisions and actions. The term may apply to government, private sector organizations and groups, and individuals. The policy process includes the identification of different alternatives, such as programs or spending priorities, and choosing among them on the basis of the impact they will have.
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