Effective Date 15/02/2022
PRIVACY POLICY
I. Purpose and Scope
1. Global Root Inc (“us”, “we”, or “our”) is engaged in the business of providing clients with specific personnel (“Personnel”) identified as per qualifications set by the clients and further employ such Personnel on behalf of the clients (“Employer on Record (EOR)/Recruitment Services”) and such identified Personnel will provide services as per the user’s requirement (“Service”) for the visitor or a registered user to utilise the platform available at Global Root Inc’s website https://www.gloroots.com/ (“Website”) (such user to be referred to as “you” or “your”), based on the explicit consent obtained.
2. Our Privacy Policy governs your visit to https://www.gloroots.com/, and explains how we collect, safeguard and disclose information that results from your use of our Service.
3. We use your data to provide and improve Service. By using our Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions. Our Terms and Conditions (“Terms”) govern all use of our Service and together with the Privacy Policy constitutes your agreement with us (“Agreement”).
II. Definitions
1. “Cookies” are small files stored on your device (computer or mobile device).
2. “Data Controller” means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.
3. “Data Processors” means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various service providers in order to process your data more effectively.
4. “Data Subject” is any living individual who is the subject of Personal Data.
5. “Data Protection Laws” means any law, regulation or directives or requirements of any regulatory body which relates to the protection of individuals with regard to the processing of Personal Data, including but not limited to Information Technology Act, 2000 (as amended by the Information Technology Amendment Act, 2008) read with the Information Technology [Reasonable Security Practices and Procedures and Sensitive Personal Data or Information] Rules, 2011 (SPDI Rules) within Indian jurisdiction, the General Data Protection Regulation within EU jurisdiction, the California Consumer Privacy Act.
6. “Personal Data” 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.
7. “Sensitive Personal Data” means such personal data, which may, reveal, be related to, or constitute (i) financial data; (ii) health data; (iii) official identifier; (iv) sex life; (v) sexual orientation; (vi) biometric data; (vii) genetic data; (viii) transgender status; (ix) intersex status; (x) caste or tribe; (xi) religious or political belief or affiliation; or (xii) any other data categorized as sensitive personal data under Data Protection Laws.
8. Usage Data is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).
III. Information Collection and Use and
We collect several different types of information for various purposes to provide and improve our Service to you.
IV. Types of Data Collected
1. Personal Data
1.1 While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, Country, State, Province, ZIP/Postal code, City
- Cookies and Usage Data
1.2 We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link.
2. Usage Data
2.1 We may also collect information that your browser sends whenever you visit our Service or when you access Service by or through any device (“Usage Data”).
2.2 This Usage Data may include information such as your computer’s internet protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
2.3 When you access Service with a device, this Usage Data may include information such as the type of device you use, your device unique ID, the IP address of your device, your device operating system, the type of Internet browser you use, unique device identifiers and other diagnostic data.
3. Tracking Cookies Data
3.1 Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.
3.2 The Website uses temporary cookies to store certain data (that is not sensitive personal data or information) that is used by Global Root Inc and its service providers for the technical administration of the Website, research and development, and for User administration. These cookies are intended to be automatically cleared or deleted when the User quits the browser application. All Users are, however, encouraged to use the “clear cookies” functionality of their browsers to ensure such clearing / deletion, since it is impossible for Global Root Inc to guarantee, predict or provide for the behaviour of every User’s equipment. However, if you do not accept cookies, you may not be able to use some portions of our Service.
4. While using our Service, we may also collect the following information: sex, age, date of birth, place of birth, passport details, citizenship, registration at place of residence and actual address, telephone number (work, mobile), details of documents on education, qualification, professional training, employment agreements, NDA agreements, information on bonuses and compensation, information on marital status, family members, social security (or other taxpayer identification) number, office location and other data.
5. We do not knowingly collect personal data from children.
V. Use of Data
1. Global Root Inc uses the collected data for various purposes:
- to provide and maintain our Service;
- to notify you about changes to our Service;
- to allow you to participate in interactive features of our Service when you choose to do so;
- to provide customer support;
- to gather analysis or valuable information so that we can improve our Service;
- to monitor the usage of our Service;
- to detect, prevent and address technical issues;
- to fulfil any other purpose for which you provide it;
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc and with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchase or enquired about unless you have opted not to receive such information;
- In any other way we may describe when you provide the information and for any other purpose with your explicit consent.
2. Analytics
We may use third-party Service Providers to monitor and analyze the use of our Service.
3. Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
VI. Retention of Data
1. We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
2. We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
VII. Transfer of Data
1. Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
2. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. Accordingly, a condition of each User’s use of and access to the Website and to the other services provided by us to employers and candidates is their acceptance of the Terms, which also involves acceptance of the terms of this Privacy Policy. Any User that does not agree with any provisions of the same is required to leave the Website immediately.
3. We will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.
VIII. Disclosure of Data
We may disclose personal information that we collect, or you provide:
1. Business Transaction. If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.
2. Other cases. We may disclose your information in the following situations including but not limited to:
- to our subsidiaries and affiliates;
- to contractors, service providers, and other third parties we use to support our business;
- to fulfill the purpose for which you provide it;
- for the purpose of including your company’s logo on our website;
- for any other purpose disclosed by us when you provide the information;
- with your consent in any other cases;
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.
2.1 We implemented standard security policies, rules and technical measures to protect the personal data that we have under its control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss.
2.2 We will not disclose any personal information or data to governmental institutions or authorities unless such disclosure is requisitioned under any applicable law within India or in any other applicable jurisdiction.
3. Service Providers
3.1 We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.
3.2 We may use third-party Service Providers to automate the development process of our Service.
3.3 These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
IX. Data Security and related measures
1. The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
2. The Website may enable Users to communicate with other Users or to post information to be accessed by others, whereupon other Users may collect such data. Global Root Inc hereby expressly disclaims any liability for any misuse of such information that is made available by visitors in such a manner.
3. Visitors on the Website
3.1 No sensitive personal data or information is automatically collected by us from any visitors who are casually browsing (“Visitors”) the Website, who are merely perusing the site.
3.2 Nevertheless, certain provisions of this Privacy Policy are applicable to even such Visitors, and such Visitors are also required to read and understand the privacy statements set out herein, failing which they are required to leave the Website immediately.
3.3 If you, as a Visitor, have inadvertently browsed any other pages of this Website prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is obtained, stored or used, merely quitting this browser application should ordinarily clear all temporary cookies installed by us. However, all visitors are encouraged to use the “clear cookies” functionality of their browsers to ensure such clearing / deletion, as we cannot guarantee, predict or provide for the behaviour of the equipment of all the Visitors of the Website.
3.4 You are not a Visitor if you have willingly submitted any personal data or information to us through any means, including email or any of processes as provided on the Website. All such visitors will be deemed to be, and will be treated as, users for the purposes of this Privacy Policy, and in which case, all the statements in this Privacy Policy apply to such persons.
3.5 Inadvertent submission of Personal Data
- If you have inadvertently submitted any such information to us prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is collected, stored or used, then you may send an email to <<>>, requesting for edition or deletion of such information submitted by you on the Website.
- All such requests will be acted only upon receipt of such written request to us.
3.6 Editing of Personal Data
- We allow every user to challenge the data that we holds about such user and every user may have the data erased, rectified, amended, or completed, per their wishes.
- All of our employees and data processors, who have access to, and are associated with the processing of sensitive personal data or information, are obliged to respect the confidentiality of every user’s sensitive personal data and information.
X. Your Data Protection Rights under General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA) and other jurisdictions
1. GDPR
1.1 Governance of processing EU User data
We process information of Users in the EU in accordance with European laws and regulations such as the General Data Protection Regulation (GDPR). The GDPR governs how we may process your information, and the rights that EU Users have in relation to your information. This means that we will collect and use your information only where:
- We need such information to provide you the Service and fulfil our obligations to you under our Terms. This includes the functionalities of the Website and/or Services;
- The collection and use of your information is justified because of a legitimate interest such as for research and development or marketing the Services (but only where our legitimate interest isn’t overridden by your interest in protecting your information);
- We have obtained your consent for using your information in a certain way;
- The collection and use of your information is necessary for compliance with our legal obligations;
1.2 Withdrawal of consent
You may withdraw your consent for using your information at any time. Depending on the situation you can either withdraw your consent by writing to <<>>. Where we are using your information because of a legitimate interest to do so, you have the right to object to that use. However, if you do so, you may not be able to continue using the functionalities of the Website and/or the Services.
1.3 Cross Border Transfer of Information
In the event we transfer information of Users in the EU to a Service Provider located outside the EU and/or is not subject to an adequacy decision by the EU Commission, we will ensure that:
- we obtain your prior consent for such transfer; and
- such Service Providers have appropriate safeguards for your information by way of entering into a binding agreement that provides for the same.
2. CCPA
2.1 Governance of Personal Data as per CCPA. According to CCPA we agree to the following:
- users can visit our site anonymously.
- our Privacy Policy link includes the word “Privacy” and can easily be found on the home page of our website.
- users will be notified of any privacy policy changes on our Privacy Policy page.
- users are able to change their personal information by emailing us at <<>>.
2.2 Data Protection rights as per CCPA.
- To the extent that the CCPA applies, you acknowledge that we are a business and that we are engaged as the service provider to you.
- In accordance with the CCPA, Supplier shall:
- neither sell Personal Data nor collect, retain, disclose or use Personal Data for any purpose other than providing the Services;
- implement and maintain appropriate measures to comply with a Consumer request to opt-out, access or erase Personal Data and
- ensure that any Service Provider that it engages to provide the Services complies with this Privacy Policy, the Terms and all applicable data protection law.
2.3 Our Policy on “Do Not Track” Signals:
- We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
- You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
3. Rights in respect of your information
3.1 The laws of some countries grant particular rights in respect of personal information. If you are a User in such jurisdictions, you may have the right to:
- Request a copy of your Personal Data;
- Request that we correct inaccuracies relating to your Personal Data;
- Request that your Personal Data be deleted or that we restrict access to it;
- Request a structured electronic version of your Personal Data; and
- Object to our use of your Personal Data;
XI. Changes to This Privacy Policy
1. We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
2. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.
3. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy is effective when they are posted on this page.
XII. Contact Us
1. If you have any questions about this Privacy Policy, please contact us by email at accounts@gloroots.com
2. Upon request, which any visitor can indicate by sending an email to accounts@gloroots.com, we will provide every User with a readable copy of the personal data which it keeps about such User, although we may require proof of identity prior to such request.
3. In some circumstances we may not be able to comply with a request that you make in respect of your Personal Data. For example, we may not be able to provide a copy of your personal information where it infringes on the rights of another User. We may also be required to retain certain Personal Data that you ask us to delete for various reasons, such as where there is a legal requirement to do so. If we are unable to resolve your request, or if you are concerned about a potential violation, you may be entitled to report the issue or make a complaint to the data protection authority in your jurisdiction.
4. We will address any discrepancies and grievances of all Users with respect to processing of information in a time bound manner. For this purpose, we have designated Nitai Agarwal as the Grievance Officer, who will redress the grievances of the Users expeditiously but within one month's from the date of receipt of grievance, and who can be reached by:
- Sending a letter marked to the attention of Nitai Agarwal to
- Sending an email to accounts@gloroots.com.