BugendaiTech Private Limited (“BugendaiTech”, "Company", "We," "Us," or "Our") is committed to protecting the personal information or data and sensitive personal information or data of its users including its employees ("You," "Your") in order to ensure that their personal information and sensitive personal information (as defined below) are kept private and secure.

This Privacy Policy (“Policy”) elucidates Our privacy related standards and procedures more specifically on the collection, storage, processing, disclosure and disposal of Your personal and sensitive personal information that We collect and use through Our website, https://bugendaitech.com/ (the “Site”) as well as for the personal information/sensitive personal information that You may voluntarily supply to Us when taking part in Our webinars, lead generation campaigns or during Your employment and other forms of engagements, whether contractual or not.

BugendaiTech is dedicated to safeguarding the security and privacy of all personal information or sensitive personal information and takes abundant caution to abide by the privacy legislation within each jurisdiction in which it operates i.e. India, Europe, UK, and USA.

Although the scope of Our information processing activities is intended to be covered by this Policy globally, some jurisdictions may have greater restrictions due to legal constraints. For instance, a nation's law(s) might place restrictions on the kinds of personal information We can gather or how We can handle or transfer that data. When that occurs, We shall modify Our internal rules and procedures to comply with applicable local laws. As a responsible user, it is Your duty to stay updated with this Policy.

For the purpose of this Policy, any personally identifiable information (“Personal Information”) refers to the information that directly or indirectly identifies You such as Your first and last name, residential address, e-mail address or any other contact details. Sensitive personal information (“Sensitive Personal Information”) is also covered under the ambit of Personal Information. It includes information relating to user passwords, financial information such as bank account, credit/debit card, or other payment instrument specifics as well as medical records and history. These definitions may vary as per jurisdiction and You are advised to refer to the most appropriate meaning as per applicable laws, a gist of which is provided under Clause 3 of this Policy.

For employees: By accepting employment with BugendaiTech, You hereby expressly consent and acknowledge that You have read, agreed and understood all of the terms of this Policy as outlined herein.

2.1 Whose and what Personal Information or Sensitive Personal Information We collect?

We request the following Personal Information or Sensitive Personal Information based on how You use Our Site. This information is necessary for Us to fulfil Our obligations and adhere to the applicable law.

• A. Information of employees: As an employee of BugendaiTech, We require You to provide Your certain Personal Information or Sensitive Personal Information including but not limited to Aadhaar number, Permanent Account Number (PAN), Passport number, educational certificates/marksheets, medical history, or any other financial/general information in order to ensure Your continued employment.
  In conjunction with Your own Personal Information, You may also supply Us with information about Your related persons including Your dependants or other family members for the purpose of administering Your benefits and HR management


• B. Information of users collected through web forms:In addition to the above, We may obtain Your Personal Information through web forms if You choose to provide it. The following information is being supplied to Us for taking part in webinars and lead generation campaigns: Your first and last name, gender, e-mail address, mobile number, name of the company/organisation/institution, designation or city/country.

2.2 How is Your Personal Information or Sensitive Personal Information collected?

Commonly, We gather Personal Information or Sensitive Personal Information directly from You through Your responses from Your personal ID or through the GreytHR ESS portal (applicable for employees) or in a physical manner.

However, in some circumstances, the information We collect has been inferred about You basis the information You provide Us through the web forms or through the Contact Us option on Our Site.

You hereby agree and acknowledge that Personal Information or Sensitive Personal Information provided by You through varying forms will only be processed in accordance with the applicable local law and with Your informed, voluntary and explicit consent. By proceeding beyond this Policy, We understand that You provide Us with Your informed, voluntary and explicit consent for the same.

2.3 Why do We process Your Personal Information or Sensitive Personal Information

We process Your Personal Information or Sensitive Personal Information to provide, improve and administer Our services, communicate with You, for security and fraud prevention, and to comply with applicable law(s). We may also process Your information for other purposes with Your consent.

We process your Personal Information or Sensitive Personal Information for a variety of reasons, including but not limited to:

• Employee identification and retention:We gather Your Personal Information for the purpose of employee benefits like employee provident fund (EPF) etc., to authenticate employee identity and for the purpose of determining initial employment eligibility, including qualification verification;


• Human Resource management:We gather, store, analyse and share information for the purpose of employee recruitment, development & training, delivering and managing compensation, benefits, and incentive programmes, as well as giving Our payroll the necessary information;


• Business Management:: In order to manage Our business operations, We need to use Personal Information for matters like employee databases, maintaining Company’s assets, providing client reviews, reporting and/or distributing public data (such as annual reports, etc.), and arranging work assignments. Information may also be utilized to adhere to government rules and regulations;


• Engage in research and analysis related to the SiteWe use Your Personal Information to identify and fix errors, research and test different and new features, and analyse how visitors access use the Site;


• Personalise Your experience:We utilise Your Personal Information submitted by You, such as the software products and services You use, have used, or are exploring on the Site to customise and give suggestions to You based on the information You have supplied; and


• To improve and understand usage of the Site:We utilise Your Personal Information about your use of the Site, such as your search activity, the pages You viewed, and the date, time and the length of Your visits to better understand and optimise Site usage.

We only process Your Personal Information or Sensitive Personal Information when We believe it is necessary and We have a valid legal reason (i.e. legal basis) to do so under applicable laws, like with Your informed, voluntary and explicit consent, to comply with applicable laws, to provide You with services to enter into or fulfil Our contractual obligations, to protect Your rights, or to fulfil Our legitimate business interests.

• a. If You are located in India, this section applies to You
  If You reside in India, You will be governed by the Information Technology Act of 2000 and the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 made thereunder.
  


• b. If You are located in California, this section applies to You
  Personal information is defined by the California Consumer Privacy Act ("CCPA") as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
  
  California residents are empowered under the CCPA with the right to opt out of having their data sold to third parties, the right to request disclosure of data already collected, and the right to request deletion of data collected.
  
  Additionally, California residents have the right to be notified and the right to equal services and price (i.e. cannot be discriminated against based on their choice to exercise their rights).
  
  If You wish to exercise any of the rights set forth above, you may make a request at info@bugendaitech.com


• c. If You are located in UK, this section applies to You
  If You are from UK, You shall be governed by the principal legislation in UK namely, UK General Data Protection Regulation (UK GDPR) and the Data Protection Act, 2018.


• d. If You are located in UAE, this section applies to You
  If You are from UAE, You shall be governed by the Personal Data Protection Law, Federal Decree Law No. 45 of 2021 which consists of an integrated framework to ensure information confidentiality and preserve the privacy of individuals in the UAE.

The Company acts to safeguard Your Personal Information or Sensitive Personal Information and make sure that no unauthorized individuals have access to it by putting security measures in place.

• 4.1 The Company allows access to Personal Information or Sensitive Personal Information by the concerned sales team, marketing team and HR/admin team in order to perform their assigned tasks and duties.


• 4.2 The Company may disclose Personal Information or Sensitive Personal Information if the Company believes in good faith that it is compelled by any applicable law, rule, legal process, court order or any government authority or such disclosure is reasonably necessary to prevent fraud.


• 4.3 The Company may disclose Personal Information or Sensitive Personal Information with professional advisors for example, legal counsel/firm as may be deemed necessary in order to defend, establish or exercise their legal rights and receive legal advice on the subject matter in dispute.


• 4.4 The Company may disclose Your Personal Information with other employees or teams of the Company if You have explicitly consented to the same and the scope of sharing Your Personal Information will only be limited to legitimate purposes.


• 4.5 The Company may, during the course of Your employment undergo a merger or acquisition or establish new subsidiaries or business units across the globe. It is probable that as part of any such transaction, some or all of Your Personal Information or Sensitive Personal Information will be transferred to a different business. However, the protections and safety measures as specified in this Policy that was in effect at the time will continue to apply to Your Personal Information or Sensitive Personal Information.

Kindly take note that We shall put appropriate security measures in place to secure Your Personal Information or Sensitive Personal Information when We disclose it with any of the aforementioned recipients, as required by the applicable law

Your privacy is extremely important to Us. Personal Information or Sensitive Personal Information will not be retained longer than necessary to achieve the purposes as mentioned in this Policy as well as long as the applicable laws/local laws require. However, there may be an instance where We are required to retain the information for a longer period for legitimate business objectives or in the event of a dispute.

• 6.1 The Company employs appropriate technical and reasonable security measures to safeguard the confidentiality of the Personal Information or Sensitive Personal Information both online and offline including but not limited to implementation of access controls, use of anti-virus software, password protection and encryption


• 6.2 It is pertinent to set forth herein that only the authorized individuals/teams have the access to Your Personal Information or Sensitive Personal Information and the authorized individual(s)/team(s) also take appropriate steps to protect such shared information.


• 6.3 The Company will use commercially reasonable steps to protect Your Personal Information or Sensitive Personal Information stored or transmitted electronically from unauthorised access by third parties, including hackers. However, despite Our best efforts it is important to state that no protection of information is entirely safe and the Company cannot be held responsible for data breaches that might occur outside its reasonable scope of control. Nevertheless, in the case of a data breach, We will abide by all applicable laws and local legislation, including taking reasonable precautions to limit any harm and promptly informing You of such breaches.

• 7.1 Right to request access: Subject to the laws of Your country, You have the right to access, update, transfer, or have Your Personal Information, such as your profile and preferences, according to the laws of Your country. Additionally, You have the right to object to certain types of processing and to revoke any consent You may have given Us to use Your Personal Information by mailing Us at website@bugendaitech.com


• 7.2 Right to update/correct Your Personal Information: You can send an email to the aforementioned email address urging Us to change or update Your Personal Information or Sensitive Personal Information at any point after You have given Your consent for its processing so that We can maintain correct information in Our database. Any failure on Your part to update or correct Your Personal Information will be Your entire responsibility.


• 7.3 You can write Us an email at the aforementioned address seeking Us to erase Your Personal Information or Sensitive Personal Information. We have the right to stop providing Our services if the removal of such data interferes with such services.

We reserve the right to change this Policy at any time in response to modifications made to its services. The modification date will be updated at the top of this page so that You are aware of the changes to Our Policy. As of the amendment date, the new, updated, or amended privacy policy will be in effect. As a result, We advise You to frequently examine this Policy so that You are aware of how We are processing Your Personal Information or Sensitive Personal Information. You will be deemed to have accepted the revised Policy if You continue to use the Site.

Links to third-party websites and services may be provided by BugendaiTech. Please be advised that Our Policy no longer applies when You are furthered to a third-party website. Before providing any Personal Information or Sensitive Personal Information to such third-party websites, You should read their privacy policies. Any data loss that may occur when utilising such third-party websites or programmes is not Our responsibility. The Company hereby disclaims liability for any privacy policies, procedures, or contents of such third-party websites.

If at any time, You have any complaint or grievance with regard to the processing, storage or disclosure of Your Personal Information or Sensitive Personal Information, You may contact Our grievance redressal officer, namely Shalini Sharma at shalinisharma@bugendaitech.com .