1. Introduction

StackRoute Learning, Division of NIIT Limited and its affiliates (hereafter referred to as “STACKROUTE”) are committed to protect your Personal Information. Uniform practices for collecting, using, disclosing, storing, retaining, disposing, accessing, transferring or otherwise processing such information assists StackRoute in processing Personal Information fairly and appropriately, disclosing it and/or transferring it only under appropriate circumstances. This privacy policy relates to our use of any Personal Information StackRoute collects from you. This Policy tells you how STACKROUTE uses your Personal Information collected through this website. Please read this Policy before submitting any Personal Information. Please Note: The privacy practices set forth in this Policy are for Personal information collected on this website only.

2. Definitions

'Personal Information' means the personally identifiable information provided by you in relation to or in connection with your employment or prospective employment with STACKROUTE. 'System' means the computer network or computer system or computer resource of STACKROUTE which receives your Personal Information. 'Website' means the portal / interface of system which receives your Personal Information.

3. Purpose

The purpose of this Policy is to highlight various obligations, best practices and processes that support compliance with data privacy regulations applicable to STACKROUTE in its role as both data controller as well as processor of Personal Information.

4. Applicability

This policy applies to all STACKROUTE personnel, operating units, and wholly owned subsidiaries worldwide.

5. Collection and use of information

STACKROUTE collects, processes, and retains Personal Information when you access and interact with the website. It also maintains the Personal Information in the System which relates to your employment. You may choose to provide STACKROUTE with information, such as your name, email address, company information, street address, telephone number, or other information, to access protected information on the System or so STACKROUTE can connect up with you after your visit. Personal Information may include, but is not limited to:

• I. Your name, physical address, email addresses, and telephone numbers
• II. Behavioral or demographic attributes, when tied to personal identifiers
• III. Previous Employment Details
• IV. Financial and bank account details
• V. Employment records
• VI. Company Profile
• VII. Background checks

Any of the information that STACKROUTE collects from you may be used in one of the following ways: To provide employment related services: STACKROUTE shall process your Personal Information for financial, accounting, payroll and compensation, rewards and reimbursement benefits, succession and resource planning in relation to employment related services.

• A. To gather details about employees application use: Your Personal Information helps STACKROUTE to more effectively respond to your requests and queries to make the application interface user friendly.
• B. To process transactions: STACKROUTE may use Personal Information along with banking information to process your transactions for salary and expense reimbursement transactions.
• C. To send periodic emails: The email address you provide will be used to send you information and updates pertaining to employment transactions within STACKROUTE.
• D. Select Content, Improve Quality and Facilitate Use of the other interface: STACKROUTE may use your Personal Information to help create and personalize content on our website, facilitate your use of the website for example, to facilitate navigation and the login process for internal sites, avoid duplicate data entry, enhance security, improve quality, track campaign and survey responsiveness and evaluate page response rates.
• E. Obtain third party services: As part of the hiring process, STACKROUTE shares relevant information completed by you to obtain a background check and provide you with the compensation and benefits offered.
• F. For Compliance: Your Personal Information may be used to comply with the respective statutory mandates of the government or law enforcement agencies or any other competent authorities, which may be applicable in relation to your employment with STACKROUTE.

6. Fairness and Purpose

STACKROUTE will collect adequate, relevant and necessary Personal Information, and will process the same fairly and lawfully for the purpose it is collected. The purpose of collection will be specified not later than at the time of data collection or on each occasion of change of purpose.

7. Accuracy of information

The information held by STACKROUTE on the System shall be checked with you from time to time to ensure that it remains up-to-date. Should there be any change in your Personal Information, you should notify STACKROUTE and update your details on the website immediately.

8. Distribution of Information

• A. STACKROUTE does not share, sell, rent, or trade Personal Information collected through its System with third parties for their sole promotional purposes or as otherwise outlined in this Privacy Policy. STACKROUTE may share information with third party service providers contracted to provide services on its behalf for processing to provide your employment outsource related services and benefits and other business purposes. These third-party service providers may only use information STACKROUTE provides to them as requested and instructed by STACKROUTE.
• B. STACKROUTE may disclose your Personal Information as it may believe to be necessary or appropriate:
• I. under applicable law, including laws outside your country of residence;
• II. to comply with legal process;
• III. to respond to requests from public and government authorities, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes;
• IV. to enforce our terms and conditions; and
• V. to allow it to pursue available remedies or limit the damages that it may sustain.
• C. Additionally, in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), STACKROUTE may transfer the personal information STACKROUTE may have collected to the relevant third party.
• D. If STACKROUTE goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personal information collected through our website may be among the assets transferred. A prominent notice will appear on our website(s) for 30 days after any such change in ownership or control of your personal information.
• E. STACKROUTE may share information with governmental agencies or other companies assisting it in fraud prevention or investigation. It may do so when:
• I. permitted or required by law; or,
• II. trying to protect against or prevent actual or potential fraud or unauthorized transactions; or,
• III. Investigating fraud which has already taken place. The information is not provided to these companies for marketing purposes.

• I. a data transfer agreement with the party who will access or obtain the personal information;
• II. Notice to and/or approval from a country's local data protection authority; or
• III. Notice to and/or consent from the individual whose data is to be transferred.

9. Consent and Control

• I. collecting, using, or processing your personal information, including sensitive personal information, in certain ways or sharing the individual's personal information with any third party;
• II. transferring your Personal Information outside of your country of residence
• III. using or placing web cookies on your computer or other electronic devices.

• A. STACKROUTE also provides you with the right to control their personal information, which includes the right to access, modify, erase, restrict, transmit, or object to certain uses of their information.
• B. You may request to review, correct, update, suppress, or otherwise modify any of your personal information that you have previously provided to STACKROUTE through this website, or object to the use or processing of such Personal Information by STACKROUTE. You have the ability to update your personal profile at any time. If you have questions about your account or are having trouble accessing your account, you can request help by contacting Human Resources or the IT department. If you have privacy concerns regarding access to or the correction of your personal information, please contact STACKROUTE Privacy office, contact information mentioned at Section 14 hereunder.
• C. In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information that you have provided to STACKROUTE suppressed from our database or otherwise let STACKROUTE know what limitations you would like to put on our use of your Personal Information that you have provided to STACKROUTE.
• D. While the majority of questions and issues related to access can be handled quickly, complex requests may take more effort and time. In such cases, issues will be addressed, or you will be contacted regarding the nature of the problem and appropriate next steps, within thirty days.

10. Data Storage

Your personal information is stored in the System. STACKROUTE also provides information on your behalf to external vendors for benefits administration.

11. Commitment to Data Security

• A. Your personally identifiable information is kept secure. Only authorized employees, and other third-party providers (who have agreed to keep information secure and confidential) have access to this information.
• B. STACKROUTE ensures that our supplier employs industry standard security measures to ensure the security of information through legally binding terms and conditions. However, users of our website are responsible for maintaining the security of any password, user ID, or other form of authentication involved in obtaining access to secure areas of the website. Access to and use of password protected and/or secure areas of the website are restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution.
• C. Use of cookies - STACKROUTE uses various technologies to collect and store information when you visit the website and this may include using cookies or similar technologies to identify your browser or device. STACKROUTE also uses these technologies to collect and store information when you interact with services STACKROUTE offers. You can configure your browser to refuse cookies or to warn you before a cookie is placed. If you disable cookies, some parts of our websites may not function properly or not work at all.
• D. EU – U.S. Privacy Shield Statement - STACKROUTE complies with to the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. STACKROUTE has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the policy with higher degree of restrictions shall prevail.

12. Retention and Disposal

We keep your Personally Identifiable Information for no longer than necessary for the purposes for which the Personally Identifiable Information is processed. The length of time we retain Personally Identifiable Information for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

13. Your Consent

• A. Please refer to end of this policy for providing your consent. Your consent to personal data collection and processing may be revoked by notifying STACKROUTE (See section Privacy Contact Information).
• B. Please note, in case you choose to not provide STACKROUTE with the consent or withdraw the consent at any given point of time, STACKROUTE shall not be able to provide the services as detailed in section 5.2 of this policy.

14. Privacy Contact Information

If you have any questions regarding our Privacy Statement or if you need to update, change or remove information, you can do so by contacting human Resources. If you wish to report any policy violations or have any escalation related to handling of personal data, you may contact Privacy Office at STACKROUTE by addressing email to: PrivacyOffice@niit.com.