EMPLOYEE PRIVACY POLICY

CONTENTS :

EMPLOYEE PRIVACY POLICY

1. ‌Background‌

   
   

   This employee privacy policy governs the collection, use, disclosure, transfer or otherwise processing of personal data or sensitive personal data by SUN Mobility Private Limited (“us, we, our”). When you are employed/retained/engaged by us (collectively “Employment”), we may collect some personal information from you. We are committed to protecting the security of your personal information and safeguarding your privacy and this employee privacy policy (“Privacy Policy”) sets out and clarifies the manner in which we collect personal information from you and use this personal information that we have collected or received about you.

   
   

   The Privacy Policy will inform you about:

   
   

   • What information we collect and why we collect it

   • How we use that information including how we share the information with third parties

   • Your rights and options

     
     

2. ‌The Information That We Collect‌

   Any personal information collected in accordance with this Privacy Policy will be collected and retained by Ability Facility Pvt. Ltd., or Ciel HR Services Pvt. Ltd., or Matrix Management Services Pvt. Ltd., or Greytip Software Pvt. Ltd., or Aarvi Encon Ltd., or Element6 Technologies Pvt. Ltd.

   
   

   The kinds of personal information collected are:

   
   

   • When you are employed/retained with us, we may collect your name, age and gender details for the purpose of maintaining personnel records;

   • We may collect your ID proof and address proof like PAN Card, we may also collect Aadhaar card related information from you pursuant to the statutory requirement applicable to us for the purpose of providing employee benefits such as for the employees' provident fund as per the Code on Social Security, 2020. We will collect this information from you at the time of your joining;

   • We may collect your home address and contact details (including your mobile telephone number) to further maintain personnel records and to facilitate communication with you;

   • We may collect your date of birth and your photograph as needed for our personnel records and to develop authentication procedures such as Employee IDs;

   • We may collect details of your educational and professional qualifications and your present employment/retainership status;

   • We may collect information necessary to provide you with benefits and for personnel administration such as leave entitlements, and bonuses;

   • We may collect information related to previous employments like appointment letter, salary slips, increment letter. In some cases, reference checks may also be conducted to authenticate employment details;

   • We may further collect information to fulfil the requirement of provident fund mapping to the employee's provident fund account; and

   • This data may be collected in the form of hardcopy and softcopy.

     
     

     The kinds of sensitive personal information collected are:

   • When you are employed or retained with us, we may require you to establish an account with us and share password related information pertaining to this account;

   • As part of our personnel records and in relation to any of your entitlements, benefits and/or privileges, we may collect your medical records and history; and

   • We may collect financial information including bank account details for the purposes of crediting renumeration to you.

3. ‌Uses of Information‌

   Personal information is collected from you only when it is necessary for one or more of the following purposes:

   
   

   • Where necessary to comply with the Company’s legal obligations;

   • Where necessary for the Company’s legitimate interests, as listed below:

     • To carry out workflow management, such as assigning, managing, and administering projects;

     • To carry out compensation related-activities;

     • To process renumeration;

     • To carry out performance management, training & development;

     • To provide you with entitlements, benefits and/or privileges, including health and medical benefits, leave entitlements, and bonuses;

     • For the purpose of talent management, career development, engagement, and teambuilding (including special events), or operations management;

     • To provide a secure and safe working environment, for example to create a security pass for identification purposes and entry into the building;

     • To protect our legitimate business interests and legal rights.

4. ‌Your Rights‌

   You have the following rights under this Privacy Policy:

   
   

   Right of Access, Modification and Deletion: You can access your personal information at any time to review any personal information that you have supplied. You may modify any personal information that has been found to be inaccurate during this review. You may also request the deletion of any sensitive personal information that you have provided to us or may withdraw consent to processing of your sensitive personal data by sending an email to the Grievance Officer mentioned below.

   Please note however that this may affect our ability to process and continue your Employment and may therefore lead us to not be able to perform our Employment contractual obligations. In some cases, if we are not allowed to process your personal data, this may result in us being required to terminate our work relationship with you.

   Security and Confidentiality: We have adopted the necessary security standard to protect the confidentiality and security of your information.

5. ‌Disclosures and Transfer‌

   All sensitive personal information that we collect is disclosed or transferred only under the following circumstances, to the entities/individuals identified below:

   
   

   • Your sensitive personal information may be disclosed or transferred for the purposes of your employment to third parties such as other entities in the SUN Mobility group of companies, and vendors and service providers that provide services to the SUN Mobility group of companies like HR services, financial and accounting support, credit control, recordkeeping, and payroll;

   • Your sensitive personal information may be disclosed and transferred to respond to law enforcement requests or where required to be provided under applicable laws, court orders, or government regulations; and

   • We may also share your personal information with other third parties subject to your prior consent.

6. ‌Amendments to this Privacy Policy‌

   
   

   We may revise the Privacy Policy from time to time. Any such changes will be posted on our employee portal and your consent will be obtained for material updates to this policy.

7. ‌Grievance Officer‌

If you have any concerns or questions in relation to this Privacy Policy, you may address them to our Grievance Officer whose name and address are as follows:

Name: Natasha Wilson

Contact information: natasha@sunmobility.com.