This policy is applicable to ValueFirst Digital Media Private Limited and all its subsidiaries and/or branch offices in India.
- “Act” shall mean the Information Technology Act, 2000 and Rules thereunder as amended from time to time.
- “Information” shall mean and include Personal Information and Sensitive Personal Data and Information as may be collected by ValueFirst.
- “Personal Information (PI)” shall have the same meaning as under Rule 2 (i) of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 as amended from time to time. For ease of reference Rule 2 (i) of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 is re-produced under Appendix 1.
- “Rules” shall mean the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 as amended from time to time.
- “Registered User” shall mean such user whose registration is accepted by ValueFirst.
- “Sensitive Personal Data and Information (SPDI)” shall mean and include information under Rule 3 of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 as amended from time to time. For ease of reference Rule 3 of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 is re-produced under Schedule 1.
All words and expressions used and not defined in this document but defined in the Act or the Rules shall have the meanings respectively assigned to them in the Act or the Rules.
Collection of Information:
You may use ValueFirst’s website to access Information, learn about its products and services, read publications and check career opportunities etc. without providing any PI/SPDI. ValueFirst may collect and process PI/ SPDI provided by you in the following forms:
- Should you opt to access such services of ValueFirst, which are available only to Registered Users, Information is required to be provided by you at registration such as your name, date of birth, address, email ID, gender and phone number and transaction details like mobile number, email, message text.
- Information that you provide directly to ValueFirst via email or electronic communication.
- Information that you provide to ValueFirst over telephone. ValueFirst may make and keep a record of such information shared by you.
- Information that you provide to ValueFirst in physical form whether sent through post or courier or handed over to a ValueFirst representative in person.
- PI/SPDI collected by ValueFirst from its employees, suppliers, clients, prospects or onsite consultants or by lead generation for the purpose of employment, availing their services etc.
You will at all times have the option of not providing ValueFirst with PI/SPDI that ValueFirst seeks to collect. Even after you have provided ValueFirst with any PI/SPDI, you will have the option to access, modify, rectify or withdraw the consent given earlier by contacting ValueFirst at firstname.lastname@example.org or contact us on www.vfirst.com. In such cases, ValueFirst will have the right to not provide or discontinue the provision of any service that is linked with such PI/SPDI.
Use of Information Collected:
Any information, if collected will be used in connection with the relevant purpose as communicated by ValueFirst to you via verbal or written method of any sort. The provider of information availing any Services from ValueFirst shall be deemed to have consented to ValueFirst for the use of such information as under this policy. Employees, suppliers, clients, prospects or consultants of ValueFirst shall be duly advised about the purpose for which any Information is being collected at the time of such collection.
Sharing of Information:
Where PI/SPDI is required to be shared, arising out of any contractual obligation, ValueFirst shall part with such PI/SPDI only in accordance with your consent for the same. To the extent necessary to provide you the requested Services or to the extent required under applicable law, we may provide your PI/SPDI to the following Third Parties without notice to you:
- Employees or Consultants (including auditors, authorized vendors) on a 'need to know' basis under a Non-Disclosure Agreement;
- Governmental authorities, in such manner as permitted or required by applicable law; and
- Legal proceedings: In the event, ValueFirst is required to respond to subpoenas, court orders or other legal process, your PI/SPDI may be disclosed pursuant to such subpoena, court order or legal process, which may be without notice to you.
Security of Information:
ValueFirst strives to ensure the security, integrity and privacy of your PI/SPDI and adequacy of protection of your Information against unauthorized access, alteration, disclosure or destruction. Stringent security measures (physical, electronic and managerial) are in place to protect against the loss, misuse, and alteration of the PI/SPDI under our control. ValueFirst’s servers are accessible only to authorized personnel and your Information is shared with employees and authorized personnel strictly on a 'need to know' basis. ValueFirst periodically assesses, audits and updates its information security protocols and policies to achieve the highest standards on a continuous and ongoing basis. You may review the Information you have provided to ValueFirst at any time. On your request, ValueFirst will ensure that any PI/SPDI notified to be inaccurate or deficient, shall be corrected or amended. However, ValueFirst shall not be responsible for the authenticity of the PI/ SPDI.
Employees/Relevant Individuals Obligations & Consequences of Violations:
Every ValueFirst Employee/Relevant Individual, who deals with or comes into contact with Personal Data regardless of its origin, shall have a responsibility to comply with the applicable law concerning data privacy and specific privacy practices. The Employee/Relevant Individual should seek advice in the event of any ambiguity while dealing with Personal Data or in understanding this Policy. The Employee/Relevant Individual shall be diligent and extend caution while dealing with Personal Data of others, in the course of performance of his/her duties and shall also, at all times:
- Prevent any un-authorized person from having access to any computer systems processing Personal Data, and especially:
- un-authorized reading, copying, alteration, deletion or removal of data
- un-authorized data input, disclosure, uploading, transmission/transfer of Personal Data
- Abide by ValueFirst internal logical and physical security policies and procedures.
- Ensure that authorized users of a data-processing system can access only the Personal Data to which their access right refers.
- Keep a record of which personal data have been communicated, when and to whom.
- Not provide any Personal Data to any third party without first consulting with his/her Manager or the Human Resources Department.
- Ensure that Personal Data processed on behalf of a third party (client) can be processed only in the manner prescribed by such third party.
- Ensure that, during communication of Personal Data and transfer of storage media, the data cannot be read, copied or erased without authorization.
- Immediately, on becoming aware report and notify any vulnerabilities and privacy related breach/security breaches (including potential risks).
- Attend trainings on security and data privacy
Failure to comply with the Policy and applicable laws may have serious consequences and can expose both ValueFirst and the Employee/Relevant Individual to damages, criminal fines and penalties. It is important to note that any non-compliance with this Policy is taken very seriously by ValueFirst and may lead to initiation of appropriate disciplinary actions including but not limited to Employee dismissal or Relevant Individual termination.
Retention and Revocation of Information:
It is ValueFirst’s policy to retain certain Personal Data of the relevant individuals when they cease to be employed/ engaged by ValueFirst. This Personal Data may be required for ValueFirst’s legal and business purposes, including any residual activities relating to the employment/engagement, including for example, provision of references, processing of applications for re-employment/re-engagement, matters relating to retirement benefits (if applicable) and allowing ValueFirst to fulfil any of its contractual or statutory obligations.
Once ValueFirst no longer requires the Personal Data, it is destroyed appropriately and securely or anonymized in accordance with the law. Services transactional data is retained for three years.
Inquiries/Notification of Changes for Employees
You may contact ValueFirst at email@example.com.
Vish Bajaj (firstname.lastname@example.org)
- Rule 2 (i)
“Personal information" means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.
- Rule 3
Sensitive personal data or information of a person means such personal information which consists of information relating to:-
- financial information such as Bank account or credit card or debit card or other payment instrument details ;
- physical, physiological and mental health condition;
- sexual orientation;
- medical records and history;
- Biometric information;
- any detail relating to the above clauses as provided to body corporate for providing service; and
- any of the information received under above clauses by body corporate for processing, stored or processed under lawful contract or otherwise:
provided that, any information that is freely available or accessible in public domain or furnished
under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information for the purposes of these rules.