For the purposes of this Privacy Policy, any information (such as name, email id, company name, phone number, IP address etc.) provided by you or collected by us, as a result of your use / access of the Website, that can identify you as a person shall be referred to as “Personal Information”.

Residents of the European Union (“EU”) should note that this Privacy Policy has been updated in accordance with the requirements of the EU General Data Protection Regulation (the “GDPR”). As per the provisions of the GDPR we shall be considered the Controllers of the Personal information collected as a result of your use / access of the Website.

For Non-EU residents, by continuing to use or access the Website, you agree to this Privacy Policy. If you do not agree to this Privacy Policy, you may not use or access the Website.

To get in touch with us through the through the ‘contact us’ link on the Website, you would need to provide us with Personal Information such as your name, and e-mail address.

Accuracy of information. Please make sure that any Personal Information you share with us is accurate and upto date information. If you are sharing any Personal Information on behalf of a third person, you should ensure that you are authorized to do so.

We use the Personal Information for the following purposes:

1. to provide you information about our Offerings and / or our periodic newsletters;
2. if we do engage in a business relationship, we may use the Personal Information to provide you the agreed products/ services and to assist you in the event you need any additional support;
3. for creation or development of business intelligence or data analytics in relation to our Website and/ or the Offerings provided by us;
4. to assess queries, requirements, and process requests for products and services;
5. for client communication, billing and administration;
6. to improve usability of the Website and for Website maintenance;
7. to process job applications (if you apply for a position with our organization);
8. to prevent fraud and abuse;
9. to enhance the security of the Website;
10. to ensure that content from the Website is presented in the most effective manner for you and for your computer;
11. to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
12. to maintain leads;
13. to run marketing or promotional campaigns;
14. to create brand awareness;
15. to improve the Offerings;
16. to provide you information that we may believe may be of your interest;
17. for internal record keeping; and
18. to comply with our legal or statutory obligations.

Legal Basis (for EU residents): We will not process your Personal Information without a lawful basis to do so. We will process your Personal Information only on the legal bases of consent [as provided in Art. 6 (1) (a) of the GDPR], contract [as provided in Art. 6 (1) (b) of the GDPR], or on the basis of our legitimate interests [as provided in Art. 6 (1) (f) of the GDPR], provided that such interests are not overridden by your privacy rights and interests.

We do not sell, rent, share, distribute, lease or otherwise provide your Personal Information to third parties, without your prior consent. Keeping this in mind, we may disclose your Personal Information in the following cases:

• Affiliates: We may provide your Personal Information to our affiliates to enable them to respond to your queries.

• Merger or Acquisition:  We may transfer your Personal Information if we are acquired by another entity, or if we merge with another company or transfer a part of our business, including the Website, to a third party. Any such third party or resultant entity that receives your Personal Information shall have the right to continue to use your Personal Information in line with the purposes set out herein.

• Legal and Regulatory Authorities:  We may disclose your Personal Information in order to comply with our legal obligations/ court orders/ requests by Govt. authorities.

We have a worldwide presence through our regional sales or delivery centers. The Personal Information we collect (of EU residents) might be processed outside the EU at a secure center. We collect and transfer Personal Information outside the EU in accordance with the provisions of the GDPR. If you have questions, please contact us as at complianceofficer@harbingergroup.com.

1. 7.1

   We endeavour to only collect only such Personal Information that is necessary for the purposes indicated here, and to retain such data for no longer than is necessary for such purposes. The length of time Personal Information is retained, and criteria for determining that time, are dependent on the nature of the Personal Information and the purpose for which it was provided/ collected.

2. 7.2

   Subject to this section, we will try to delete your Personal Information upon reasonable written request for the same. Please note, however, that there might be latency in deleting Personal Information from our servers and backed-up versions might exist even after deletion. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact complianceofficer@harbingergroup.com.

We store your Personal Information in India. Although we provide appropriate firewalls and protections, we cannot warrant the security of any Personal Information transmitted as these systems are not hack proof. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible, and we assume no liability or responsibility for it. You are required to be careful to avoid “phishing” scams, where someone may send you an e-mail that looks like it is from us asking for your Personal Information.

You have the right to access your Personal Information in our possession, right to have us rectify or modify any such Personal Information, right to have us erase/delete your Personal Information, right to restrict us from processing such Personal Information, right to object to our use of your Personal Information. If you would like to exercise ANY of these rights, please contact complianceofficer@harbingergroup.com.

Our Website is meant for adults. We do not knowingly collect information from or about children under the age of 18. If you are a parent or guardian and think we have information about your child, please contact complianceofficer@harbingergroup.com.

Our Website may contain links to other websites/applications of your interest. Unless the third-party websites/ applications are owned by members of the Harbinger Group, we do not have any control over them and you will be accessing them at your own risk. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites/applications. You should exercise caution and look at the privacy policy applicable to such websites/applications.

To the extent permissible under the law, we shall not be liable for any direct, indirect, incidental, special, consequential or exemplary damages, including but not limited to, damages for loss of profits, goodwill, data, information, or other intangible losses (even if we have been advised of the possibility of such damages), arising out of this Privacy Policy.

This Privacy Policy shall be construed and governed by the laws of India without regard to principles of conflict of laws. Any dispute arising, between you and us shall be submitted to the arbitration to be conducted in Pune, India in English language, in accordance with the provisions of Arbitration and Conciliation Act of 1996, by a sole arbitrator (appointed by us), and the award made in pursuance thereof shall be binding. Subject to the arbitration provisions, you agree that the courts in Pune, India shall have an exclusive jurisdiction over such disputes.

For any EU residents, this Privacy Policy shall be governed by the provisions of the GDPR.

We may update this Privacy Policy from time to time. We shall provide you with an email notification indicating any material changes in the Privacy Policy. Additionally, you are encouraged to check this Privacy Policy on a regular basis to be aware of the changes made to it.

This Privacy Policy was last modified in November 2018.

If you have any questions or concerns or grievances regarding this Privacy Policy, you can email us at our grievance email-address complianceofficer@harbingergroup.com.