Thanks for entrusting TurboHire.co with data and your pertinent personal information. Handling your data is a serious responsibility, and we want you to know how we go about doing that.Effective date | 12th March 2019 Last date Modified | 17th June 2020
Thanks for entrusting TurboHire.co with data and your pertinent personal information. Handling your data is a serious responsibility, and we want you to know how we go about doing that. TurboHire Technologies PVT LTD (TurboHire.co) is registered in India as a Private limited company with number U72200TG2019PTC131204.
We are TurboHire Technologies Private Limited, a provider of talent selection services based in India. All references in this policy to “TurboHire.co”, “our”, “us” or “we” refer to TurboHire Technologies Private Limited, or our suppliers which provide services to us, as appropriate.
- Section 43A of the Information Technology Act, 2000; - Rule 4 of the Information Technology (Reasonable Security Practices and - Procedures and Sensitive Personal Data or Information) Rules, 2011; and - Rule 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.
1. HOW WE HANDLE YOUR DATA
1.1 Information We Collect
Information from website browsers
What do we collect?
If you are browsing the Website, we collect the same basic information that many other websites collect. We use common internet technologies, such web server logs. This is information we collect from everybody who visits our Website, whether they have an account or not.
The information we collect about all visitors to our Website includes the visitor’s browser type, language preference, referring site, and the date and time of each visitor request. We also collect potentially personally-identifying information like Internet Protocol (IP) addresses.
Why do we collect this?
This is done improve the visitor experience and provide better content and service to our current as well as prospective customers based on their geography and potential usage of our product and services.
Information from users uploading files
What do we collect?
If you login, upload file(s) or source candidate files using our Services, we collect your email address, contact information, location, along with details of the filename or file URL.
Why do we collect this?
We collect this information in order to provide our talent selection services to you – without this information we are not able to upload files, analyze them and provide you with talent selection service.
Information from users with accounts
What do we collect?
If you create an account with us on our Website, we require some basic information at the time of account creation. You will create your own password, and we will ask you for your full name and a valid email address. We will also collect your billing details, including credit/debit card information (card name, number, expiry and CVV), a billing address and for some customers a valid GST/ VAT number. You have the option to either save or delete information relating to your credit/debit card information (card name, number, expiry and CVV) on the Website or Service.
Why do we collect this?
People who contact us with enquires
What do we collect?
If you contact us with a sales or support enquiry, we will collect the information provided when you correspond with us, such as your name, your address, your email address and your telephone number.
Why do we collect this?
We will collect, use and store the kinds of information as set out in this Section 1.1 (“Personal Information”) to deal with any enquiries or issues you have about our Services, including any questions you may have about how we collect, store and use your Personal Information, or any requests made by you for a copy of the information we hold about you.
1.2 Information We Do Not Collect
We do not intentionally collect or store special categories of personal data, such as date of birth, genetic data, health information, or religious information. Although TurboHire.co does not request or intentionally collect any special categories of personal data, we realize that you might store this kind of information in your account, via the files that you upload.
If you ask us to upload or store any files containing special categories of personal data on our servers, located in India, we will only do so on your instructions as a data processor and service provider and in accordance with our Terms of Service with you. You are the controller of this data and you must ensure that you have a legal basis to share this data with us.
1.3 How We Use Your Information and our Legal Basis for doing so
We use the information, including Personal Information, you provide to us in a number of ways and we have set out our legal basis for processing your information below:
To provide, update, maintain and improve the Services we offer to you
This is the most common usage of your information. We use your Personal Information to provide various talent selection Services to you, in accordance with our Terms of Service. In particular, we will use your data to: set-up an account; upload the files that you provide us with, to convert them to more user friendly format and fulfill and improve task of talent selection and improve usability of Service; and to send you links to access and view our service output to the email address you provide us with.
Our use of your Personal Information in this way is necessary to perform our obligations to provide the Services to you, under our Terms of Service.
To communicate with you by responding to your requests, comments, Support enquiries and sales enquiries
If you contact our support team we may use the information that you provide to us in order to help us respond to your enquiry. Our use of your Personal Information in this way is necessary to perform our customer service obligations to you, under our Terms of Service. If we do not have a contract with you, we may process your Personal Information for these purposes where it is in our legitimate interests to do so for customer services purposes.
For billing, account management and other administrative matters
TurboHire.co may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments. Our use of your Personal Information in this way is necessary to perform our obligations to you under our Terms of Service. However, your information, including Personal Information is accessible to only few authorized personnel within TurboHire and they will only do so to contact you on any of these matters.
As required by applicable law, legal process or regulation
We may use your information, including Personal Information, to comply with court orders and similar legal or regulatory obligations which apply to us. This may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so.
To investigate and help prevent abuse or security issues
We may use information such as your IP address to help us prevent abuse of the Services we provide and investigate any potential unauthorized use of those Services or other security breaches. In these circumstances, we believe we have a legitimate interest in handling your data.
If we rely on our (or another person’s) legitimate interests for using your Personal Information, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the Personal Information. You can ask us for information on this balancing test by using the contact details at section 5.7.
We also collect and use data which is aggregated or anonymised for certain business purposes, such as creating aggregate statistics or reporting. However, no single individual will be identifiable from the anonymised details we collect for these purposes.
Information we may have access to
Apart from your Personal Information, we do not collect any other information. However, where you upload your resumes, CVs or any other documents in relation to a job posting or interview on the Services, we may have access to the information contained in such resume, CVs or other documents. You hereby agree and consent to our access to such information. You are entitled to delete any such information at your sole discretion.
1.4 Information collected inside TurboHire from Google.
Turbohire requires Google authorization to get access to user emails, these emails are scanned to find a valid attachment i.e is a potential resume, once the process is completed Turbohire only keeps the attachment and the email id of the email account used for scanning through email’s, whose permission is granted by the user.
Turbohire does not change any information of the Google account used, nor sends any mail from the authorized Google account. Nor does Turbohire add or amend the folder or label structure of Gmail. The data obtained from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
What are cookies?
Cookies are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. They allow a website to recognize a particular device or browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire. For further information on deleting, disabling, blocking and controlling cookies please visit http://www.allaboutcookies.org
We use Google Analytics as a third party tracking service, but don’t use it to track you individually. We use Google Analytics to collect information about how our Website performs and how our users, in general, navigate through and use TurboHire.co to help us evaluate our users’ use of TurboHire.co; compile statistical reports on activity; and improve our content and Website performance.
We look to protect your privacy by anonymizing your IP address prior to sending it to Google Analytics and we only gather certain basic information, such as your browser type, referring and exit pages, time stamp, and similar data about your use of TurboHire.co. We do not link this information to any of your Personal Information.
We do not allow any third party social media websites (such as Facebook or Twitter) to track you across our Services – all of the social media buttons served through our Services are configured to explicitly disallow tracking from third parties whilst using our Services.
2. HOW WE SHARE DATA
2.1 Sharing Your Information
We do not share, sell, rent or trade your email address with any third parties for any commercial purposes.
We will share your Personal Information with the following third party vendors:
- Microsoft Azure Services and Amazon Web Services who provides server hosting and content distribution networks (CDN’s) services; - Godaddy Inc who provides domain name services; - SendGrid Inc who provides us email sending services; - Razorpay who provides payment processing services; and - Google Suite and Hubspot, who provide customer relationship management and customer service tools.
When we transfer your data to our vendors, we remain responsible for it. We try to ensure that any third parties with whom we share your Personal Information are limited (by law and by contract) in their ability to use your Personal Information for any purpose other than to provide services for us.
We may share Personal Information where it is in our legitimate interests to do so to run, grow and develop our business if we are involved in a merger, sale, or acquisition. If any such change of ownership happens, we will ensure it is under terms that preserve the confidentiality of Personal Information, and we will notify you on our Website or by email before any transfer of your Personal Information.
2.2 Third Party Advertising
We do not host any third party advertising at TurboHire.co. Therefore, whether you access our Service outside or inside of European Economic Area (“EEA”), none of personal or user data is shared with any third party advertising.
2.3 Legal Disclosures
TurboHire.co may disclose personally-identifying information or other information we collect about you in response to a valid subpoena, court order, warrant, or similar government order, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or those of third parties or the public at large. This may include exchanging Personal Information with other organisations for the purposes of fraud protection and credit risk reduction.
We will also disclose your Personal Information to third parties in order to enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity.
3. HOW DO WE MANAGE DATA
TurboHire.co takes the security of data very seriously, and we work hard to protect any information you provide to us from loss, misuse, and unauthorized access or disclosure. We take all reasonable precautions to safeguard the confidentiality of your Personal Information, including through use of appropriate organisational and technical measures. These measures take into account the sensitivity of the data we collect, process and store, and the current state of technology.
Given the nature of communications and information processing technology, TurboHire.co cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, but we do our utmost to protect it. Once we have received your Personal Information, we will use strict procedures and security features to prevent unauthorised access to it.
As a minimum we take the following measures to secure your data:
- Physical Security – TurboHire.co infrastructure is only hosted in data centres which meet rigorous security standards. Physical access is strictly controlled both at the perimeter and at building ingress points by professional security staff utilising video surveillance, intrusion detection systems, and other electronic means.
- Data Transfer Integrity – All traffic to and from TurboHire.co servers is secured by transport level security (TLS) sent over a Secure Socket Layer (SSL), and secured using an AES 256-bit SSL certificate. This ensures that data sent between your systems and ours is encrypted using military grade encryption.
- Password Encryption – TurboHire.co user account passwords are stored in our database after being salted and hashed using the encryption algorithms. - Firewalls – TurboHire.co enforces network level control for access to infrastructure by using multiple different firewall technologies to ensure that different components of its systems are logically isolated from one another.
- Operational Access Controls – TurboHire.co employees require access to production services for operational reasons. We employ multiple authentication mechanisms to ensure that production systems are accessed only by authorized members of staff and are protected from unauthorized access.
- Software Updates – TurboHire.co regularly applies software patches to production infrastructure in order to ensure a strong security posture to known software vulnerabilities.
- Bug Bounty Program – TurboHire.co operates an informal “bug bounty” program that encourages security researchers to perform limited and authorized testing of the integrity of TurboHire.co systems.
3.2 Data Retention and Deletion
If you have an account with TurboHire.co
We will retain your Personal Information for as long as your account is active or as needed to provide you with Services that you request. Once your account is deactivated we will permanently remove any files associated with your account in accordance with our Terms of Service).
We may, in Our sole discretion, continue to store data / information such as email and contact information, billing and invoice information, payment, late payment or non-payment information or such related information of the Customer for record keeping, audit, fraud and reporting purposes in accordance with applicable laws. For example, we don’t automatically delete inactive user accounts, so unless you ask us to permanently delete your account we will retain some account information to enable you to return and use our Services more easily in future.
If you do not have an account with TurboHire.co
We will store any files you upload or source using the service for trying the Service, and their converted format on our systems for no longer than 180 days following upload. After this time they will be permanently removed from our storage systems.
We will retain Personal Information such as your IP address, email address, contact information and browser details for no longer than 180 days. After this time we permanently delete your browser data and anonymise your IP address and email address so that we can no longer personally identify you.
3.3 International Data Transfers
TurboHire.co may transfer your personal data to countries other than the one in which you live, including to our hosting servers with reputed suppliers located in the United States and Asia.
- in the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further https://www.privacyshield.gov/welcome); or
- in the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them. Further details on the steps we take to protect your Personal Information, in these cases is available from us on request by contacting us by email at support@TurboHire.co at any time.
4. YOUR RIGHTS
If you have a user account for the Services you may review and edit any personal data you have supplied to us in your user profile. If you do not have a user account, or if you have questions about your account information or other personal data please contact us by email at email@example.com.
Individuals located in certain countries, including the European Economic Area and Switzerland, have certain statutory rights in relation to their personal data. While some of these rights apply generally, certain rights apply only in certain limited circumstances. We describe these rights below.
Please note that we may ask you to verify your identity before taking further action on your request. Additionally your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we are permitted by law or have compelling legitimate interests to keep.
4.1 Right to be Informed
You have the right to be provided with information about the data we hold, our data processing activities and whether we transfer personal data outside of the EEA, along with the methods we use to safeguard such data.
4.2 Right to Access
In some jurisdictions, applicable law may entitle you to request copies of your Personal Information held by us
4.3 Right to Rectification
You have the right to ask us to correct inaccurate, out of date or incomplete Personal Information concerning you (and which you cannot update yourself within the Services).
4.4 Right to Erasure
We generally retain any Personal Information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the Services to you, you can request that we erase your Personal Information and (if you have one) close your user account. Please note that if you request the erasure of your Personal Information:
- We may retain some of your Personal Information as necessary for our legitimate business interests and for identification purposes, and in the interest of prevention of fraud, impersonation, etc..
- We may retain and use your Personal Information to the extent necessary to comply with our legal obligations.
- Because we maintain the TurboHire.co Services to protect from accidental or malicious data loss and destruction, residual copies of your Personal Information may not be removed from our backup systems for a limited period of time.
4.5 Right to Object / Restrict Processing
In some jurisdictions, applicable law may entitle you to request TurboHire.co not to process your Personal Information for certain specific purposes where such processing is based on our (or another party’s) legitimate interests. If you object to such processing TurboHire.co will no longer process your Personal Information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
4.6 Right to Data Portability
You may be entitled to request copies of Personal Information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible). This right only applies where we use your Personal Information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.
5. OTHER IMPORTANT INFORMATION
5.1 Data Processing Addendum
To the extent that we act as a data processor on your behalf in connection with the performance of our Services, we will enter into a separate “Data Processing Addendum” with you. You can find out more information on this Data Processing Addendum by emailing us at firstname.lastname@example.org.
5.2 Age Limitations
Persons who are competent of contracting within the meaning of the Indian Contract Act, 1872 shall be eligible to access, use or register on the Website and avail the Services. In the event that, as a minor you wish to use the Website and / or Services, such use shall be made available to you upon the review of these Terms by your legal guardian or parent(s) and upon them consenting to be bound by the Terms. Further, in the event that it is discovered that You are below the age of 18 (eighteen) years and the Terms have not been consented to by your legal guardian or parent(s), or if the details provided by you are false or inaccurate, TurboHire shall not have the responsibility and shall not be held liable if the aforesaid eligibility criteria is not satisfied by you.
5.4 Third Party Links And Third Party Integration
The Website / Services may host links to third party websites and services (“Third Party Links”). We have no control over such Third Party Links, which are provided by persons or companies other than us. We are not responsible for any collection or disclosure of your data / information or Personal Information by such companies or persons on such Third Party Links thereof.
Certain other features and integrations, including but not limited to infrastructure services, communication integrations, user visibility and assessment services, background verification services (“Third Party Integrations”) are available to You through third party platforms and forums where applications are developed for their integration with the Service(s). These Third Party Integrations are governed by their own terms and privacy policies and You agree that We are not responsible for Your use of these Third Party Integrations where You choose to enable these Third Party Integrations and integrate them into Our Service(s). By enabling the Third Party Integrations, You understand and agree that We do not provide any warranties in any manner whatsoever for Third Party Integrations and We are not liable for any damage or loss caused or alleged to be caused by or in connection with Your enablement, access or use of any such Third Party Integrations, or Your reliance on the privacy practices, data security processes or any other policies and processes of such Third Party Integrations. You understand that We are not responsible for providing technical support for such Third Party Integrations and that We are not responsible for the data hosting and data transfer practices followed by providers of such Third Party Integrations. To this extent, You shall address any comments, queries, complaints or feedback about such Third Party Integrations to the respective developers or publishers as specified on such other platforms or forums.
You agree and acknowledge that Third Party Links and Third Party Integrations have their own privacy policies governing the collection, storage, transfer, retention and / or disclosure of your information and that you access or use such Third Party Links and Third Party Integrations at your own risk.
5.6 Governing Law
5.7 Contacting TurboHire.co
TurboHire.co Ltd Data Protection Representative at
DLabs, Block A, Road no 6, ISB Rd, Gachibowli, Hyderabad, Telangana, India 500032