Last updated: May 25, 2021

We at Sugun Thomas Foundation and our affiliated companies worldwide are a global professional services firm focused on recruitment services for providing end to end Human Resource Management to organizations and helps them address their critical talent needs for our clients.

We respect you and are committed to honoring and protecting your privacy. This document describes our privacy policies and practices regarding collection and use of your personal data when we process it in the context of you accessing our websites and mobile applications and sets out your privacy rights. If you have any questions or concerns about this privacy policy or your personal data, please contact us at contact@sugunthomasfoundation.org

This policy is applicable to:

• Our job candidates and recipients of our career services;
• Our associates, who are people we source or place on assignment with one of our clients, or individuals to whom we provide outplacement or career transition services;
• Users of our websites and applications;
• Our employees and associated third parties, as applicable; and
• Representatives of our business partners, clients and vendors.

This policy describes the types of personal data or personal information we collect, how we use the information, how we process and protect the information we collect, for how long we store it, with whom we share it, to whom we transfer it and the rights that individuals can exercise regarding our use of their personal data. We also describe how you can contact us about our privacy practices and to exercise your rights. In general, our privacy practices conform to local law and regulation, including where applicable the provisions of the European Union’s General Data Protection Regulation (GDPR).

Accordingly, our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements; and you can view specific local terms by visiting our local websites.

Information We Collect

We, Sugun Thomas Foundation, may at times collect your personal data in one of the following ways:

• Through our sites, applications and social media channels; at our events; through phone and fax; through job applications; in connection with in-person recruitment; or in connection with our interactions with clients and vendors, we may collect the following types of personal data:
  • Your name, and email address, country of residence, company you represent, industry and details of the inquiry on the page titled Contact Us, you enable us to respond to a general/ business inquiry made by you or on behalf of your company that you represent. If you wish to be contacted by telephone, we may also collect your work phone number;
  • User name or passwords when you register on our sites;
  • Information you provide about friends or other people you would like us to contact. (The Controller assumes that the other person previously gave an authorization for such communication);
• In addition, if you are an associate or job candidate, you apply for a position or create an account to apply for a position, we may collect the following types of personal data (as permitted under local law):
  • employment and education history;
  • language proficiencies and other work-related skills;
  • National identifier or other government-issued identification number like PAN, Aadhaar number, Passport or any other photo id or address proof;
  • date of birth;
  • gender;
  • bank account information;
  • citizenship and work authorization status;
  • benefits information;
  • tax-related information;
  • information provided by references; and
  • Information contained in your resume or C.V., information you provide regarding your career interests, and other information about your qualifications for employment
• For associates and/ or job candidates, we collect the above personal data for the following services:
  • Providing you with job opportunities and work;
  • Providing HR services to you, including administration of benefit programs, payroll, performance management and disciplinary investigations or actions;
  • Providing additional services to you, such as training, career counselling and career transition services;
  • Assessing your suitability as a job candidate and your associate qualifications for positions; and
• We use cookies, IP addresses and web beacons to collect data on how you use our websites. This may include for example information on which Sugun Thomas Foundation websites you have visited, how long you stayed on them, which items you clicked on and your IP-address.
  • A “cookie” is a file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser.
  • A “web beacon” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and is used to transmit information collected through cookies back to a web server. Through these automated collection methods, we may obtain “clickstream data,” which is a log of the links and other content on which a visitor clicks while browsing a website. To know more about our use of cookies, please see our Cookies Privacy Policy;
• As you click through our sites, a record of the action may be collected and stored. We link certain data elements we have collected through automated means, such as your browser information, with other information we have obtained about you to let us know, for example, whether you have opened an email we sent to you. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Your browser will allow you to block cookies, however, you may not be able to use all of the features of our Sites without cookies;
• Providers of third-party apps, tools, widgets and plug-ins on our sites, such as social media sharing tools, also may use automated means to collect information regarding your interactions with these features. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers. Subject to applicable law, Sugun Thomas Foundation is not responsible for these providers’ information practices. To the extent required by applicable law, we will obtain your consent before collecting information using cookies or similar automated means;
• On our sites, we may collect information about your online activities to provide you with advertising about products and services tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our ads are served;
• Our sites are not designed to respond to “do not track” signals from browsers. Information collected through third-party plug-ins and widgets on the Sites (such as information relating to your use of a social media sharing tool) is collected directly by the providers of the plug-ins and widgets. This information is subject to the privacy policies of the providers of the plug-ins and widgets, and Sugun Thomas Foundation is not responsible for those providers’ information practices.
• For your convenience and information, our sites may provide links to third-party sites, apps and services that may be operated by companies not affiliated with Sugun Thomas Foundation. These companies may have their own privacy notices or policies, which we strongly suggest you review. We are not responsible for the privacy practices of any non-associated sites, apps or services
• E-mail Communications: If you are a recipient of our marketing communications, we will track whenever you receive, open, click a link, or share an e-mail you receive from Sugun Thomas Foundation.
• Information from Other Sources: We might receive information about you from other sources to ensure the accuracy and completeness of your profile.

Sugun Thomas Foundation shall only process the received information pursuant to pursue our legitimate business interests for example screening CV’s of prospective candidates, establishing communication with prospective clients (whom you represent), establishing and receiving services from job providers.

You also have the option to subscribe/ opt-in to receive newsletters, thought leadership content and/or marketing collateral. You can always opt-out of such options by writing to , Sugun Thomas Foundation shall adhere to your preferences.

How We Use the Information We Collect

We collect and uses the data gathered for the following purposes (as permitted under local law):

• Providing workforce solutions and connecting people to work;
• Creating and managing online accounts;
• Processing payments;
• Managing our business partner, client and vendor relationships;
• Where permitted under law and consistent with this privacy policy, to send promotional materials, alerts regarding available positions and other communications;
• Where permitted under law, for communicating about, and administering participation in, special events, promotions, programs, offers, surveys, contests and market research;
• Responding to individuals’ inquiries and claims;
• Operating, evaluating and improving our business (including developing, enhancing, analyzing and improving our services;
• Managing our communications; performing data analytics; and performing accounting, auditing and other internal functions);
• Protecting against, identifying and seeking to prevent fraud and other unlawful activity, claims and other liabilities; and
• Complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies.

You may see certain Sugun Thomas Foundation ads on other websites because we engage third-party advertising networks. Through such advertising networks, we can target our messaging to users through demographic, interest-based, behavioral and contextual means. Through the ad networks, we can track your online activities over time by collecting information through automated means, including through the use of third-party cookies, web server logs, pixels and web beacons. The networks use this information to show you advertisements that may be tailored to your individual interests and previous activity. The information our advertising networks may collect on our behalf includes data about your visits to websites that serve Sugun Thomas Foundation advertisements, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Sites and on third-party websites that participate in these ad networks. This process also helps us track the effectiveness of our marketing efforts. To learn how to opt out of this ad network interest-based advertising (If any), please visit aboutads.info/choices/. To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising

Our Legitimate Interest for Processing Personal Data

Sugun Thomas Foundation shall process personal data for certain legitimate business purposes, which includes some of all of the following:

• Where the process enables us to perform, enhance, modify, personalize or otherwise improve our services/ communications for the benefits of our clients, candidates, associates and employees;
• To identify & prevent fraud;
• To enhance security of our network and information systems;
• To Better understand how people interact with our websites;
• To provide postal communications to you which we think will be of interest to you;

Whenever we process data for these purposes we will ensure that we keep your rights in high regard and take account of these rights.

How We Process and Protect Personal Information

We process the personal data we collect, also by automated means, for the purposes defined above and for a specific period of time, which complies with our internal data retention policy, in order to ensure that the personal data are not kept longer than necessary. We maintain administrative, technical and physical safeguards designed to protect the personal data you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. In order to ensure adequate security and confidentiality of the personal data, we may apply the following security measures as appropriate:

• Restriction of access to your personal data to Sugun Thomas Foundation employees strictly on a need to know basis, such as to respond to your inquiry or request;
• Implementation of appropriate physical, electronic, administrative, technical and procedural safeguards that comply with all applicable laws and regulations to protect your personal data from unauthorized or inappropriate access, alteration, disclosure and destruction. It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when you are done using a shared computer;
• Sugun Thomas Foundation employees who misuse personal data are subject to strict disciplinary action, as it is a violation of the Integrity Policy of Sugun Thomas Foundation
• Encryption of personal data in transit;
• Hardened network infrastructure; and
• Network monitoring solutions.

Who we may share your personal data with (the recipients or categories of recipients of the personal data)

We do not disclose personal data that we collect about you, except as described in this Privacy policy or in separate notices provided in connection with particular activities. We may share personal data with our vendors who perform services on our behalf based on our instructions, with whom we have individual contractual relationships. We do not authorize these vendors to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. We also may share your personal data (i) with our subsidiaries and affiliates; (ii) if you are a job candidate, with clients who may have job opportunities available or interest in placing our job candidates; and (iii) with others with whom we work, such as job placement consultants and subcontractors, to find you a job.

In addition, we may disclose personal data about you

• If we are required to do so by law or legal process;
• To law enforcement authorities or other government officials based on a lawful disclosure request; and
• When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.

We also reserve the right to transfer personal data we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation). From time to time, we may consider corporate transactions such as a merger, acquisition, reorganization, asset sale, or similar. In these instances, we may transfer or allow access to information to enable the assessment and undertaking of that transaction. If we buy or sell any business or assets, personal data may be transferred to third parties involved in the transaction.

International and group company transfers of personal data

We are part of an international group of companies and, as such, transfer personal data concerning you to countries outside the European Union (EU). We transfer personal data between our group companies and data centers for the purposes described above. We may also transfer personal data to our third party suppliers outside of the EU as described above. Your personal data may be stored in databases located outside of the EU including in India. The database is controlled by our administrative staff located outside of the EU including in India and can be accessed electronically.

We also may transfer the personal data we collect about you to countries outside of the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the personal data. When we transfer your information to other countries, we will protect that data as described in this Privacy policy and such transfers will be in compliance with applicable law. The countries to which we may transfer the personal data we collect about you may be:

• Within the European Union;
• Outside the European Union: When we transfer personal data from within the European Union to countries or international organizations that are based outside the European Union the transfer takes place on the basis of:-
  • An adequacy decision by the European Commission; or
  • In the absence of an adequacy decision, other legally permitted grounds:
  • a legally binding and enforceable instrument between public authorities or bodies;
  • Standard data protection clauses (formerly called the Model Clauses) promulgated by the Commission.

Where we transfer personal data outside of EU, we either transfer personal data to countries that provide an adequate level of protection (as determined by the European Commission) or we have appropriate safeguards in place. Appropriate safeguards to cover these transfers are in the form of standard contractual/data protection clauses adopted by the European Commission. Please (Link) to know more about standard contractual/data protection clauses.

Where we transfer personal data between our group companies we have covered these transfers by entering into standard contractual clauses adopted by the European Commission.

Your rights

You may have certain rights relating to your personal data provided for under applicable law. These are the right to: Request access to your personal data and request details of the processing activities conducted by Sugun Thomas Foundation.

• Request that your personal data is rectified if it is inaccurate or incomplete;
• Request erasure of your personal data in certain circumstances;
• Request restriction of the processing of your personal data in certain circumstances;
• Object to the processing of your personal data in certain circumstances;
• Receive your personal data provided to us as a controller in a structured, commonly used and machine-readable format in certain circumstances;
• Lodge a complaint with a supervisory authority;
• Object to, and not to be subject to a decision based solely on, automated processing (including profiling), which produces legal effects or significantly affects you;
• Withdraw your consent provided at any time by contacting us;
• Right of access to your personal data in order to verify that his or her personal data is processed in accordance with law.

If you require more information about the processing of your personal data, please refer to the How to Contact Us section below.

Changes to our privacy policy

This privacy policy was last updated in December 2018 and we will notify you of changes we may make to this privacy policy where required, however we would recommend that you look back at this notice from time to time to check for any updates.

Contact

If you have any concerns as to how your data is processed or you want to execute your rights, you can contact us at contact@sugunthomasfoundation.org