Last Updated On: April 24, 2024
This Privacy Notice for California Consumers supplements the information contained in the general Digital Risk privacy notice. We are subject to the California Consumer Privacy Act (CCPA)/ California Privacy Rights Act (CPRA) when we collect and use Personal Information about you and are responsible as a business or service provider for such Personal Information.
Keeping your Personal Information secure is our priority. Consistent with our responsibilities under CCPA/ CPRA, we maintain appropriate safeguards and security measures to protect your Personal Information.
1. Information we collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). We have collected the following categories of Personal Information from consumers within the last twelve (12) months:
| Sr. No. | Category | Examples | Collected | Source of PII | Shared with Third Party |
|---|---|---|---|---|---|
| 1 | Online Identifiers | Identifiers such as a mobile device identifier; cookies, beacons, and similar technology, internet protocol address, and other similar identifiers. | YES | Website Visit | Yes |
| 2 | Personal Identifiers | Name, Address, Date of Birth, Age, Primary and Secondary contact numbers, Postal code, Country, email address, and other similar identifiers. | YES | • Application Tracking System • Fraud Detection/Candidate Identification Check • Interview Assessment Platforms • External Interview Platforms • Website contact us form |
Yes |
| 3 | Biometric information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | YES | Interview Proctoring Tool | Yes |
| 4 | Protected classification characteristics under California or federal law. | Age, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | YES | Application Tracking System | No |
| 5 | Additional Data Subject to Cal. Civ. Code § 1798.80 | Signature, state identification card number, education information, or medical information. | YES | Application Tracking System | No |
| 6 | Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, intelligence, abilities, and aptitudes. | NO | NA | NA |
| 7 | Commercial Information | Commercial information, including records of private property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies, financial transaction information. | NO | NA | NA |
| 8 | Online Activity | Information regarding your interaction with websites, applications, session related information. | YES | Website Analytics, like page view, visits, avg session, bounce rate etc through Adobe Analytics. | NA |
| 9 | Geolocation Data | Physical location or movements | NO | NA | NA |
| 10 | Employment Information | Professional or employment-related information. (E.g., Resume, Education details, Cover letters etc.) | YES | Candidate Application Form – Application Tracking System | No |
We do not collect Personal Information of children or minors who are at least 13 years of age and less than 16 years of age. If you are a child or minor, please refrain from or not provide any data/details about you to us unless under the authorized supervision and/or guidance of your parents or legal guardians. If you are a child or a minor and has mistakenly provided your Personal Data to us, then contact us through any of the below mode that is listed under ‘Contact Information’ section.
2. Personal information does not include:
• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
a. Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.
b. Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
3. Purpose
The personal information we collect for the purpose of and that may be used to:
• Provide information and services as requested by you.
• Assess queries, requirements, and process requests for products and services.
• Perform client communication, service, billing, and administration.
• Conduct data analysis.
• Execute monitoring.
• Share it with affiliated entities/subsidiaries/branch offices for legitimate business purposes.
• Share it with statutory authorities, government institutions or other bodies for compliance with legal requirements.
• Market products and services based on legitimate business interest under the applicable law or
• Conduct processing necessary to fulfill other contractual obligations for the individual.
• To conduct background verifications for employee onboarding.
• Job Application processing.
• Address Data Subject Rights Requests.
4. Rights of Consumers under CCPA
The CCPA/ CPRA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA/ CPRA rights.
Request access - You or your authorized agents have the right to check whether we hold or use your Personal Data and request access to such data.
Request correction – You or your authorized agents have the right to correct your Personal Data if you find that the data, we hold about you is inaccurate.
Request deletion – You or your authorized agents have the right in certain situations to ask us to erase or delete your Personal Information unless it is specifically permitted under CCPA/ CPRA.
Right to Non-Discrimination: You have the right not to be discriminated against by Digital Risk for having exercised your rights under the applicable laws.
We cannot respond to your request or provide you with Personal Information if we cannot verify you or your authorized agent’s identity or authority to make the request and confirm the Personal Information that relates to you. We strive to respond to a verifiable consumer request within 10 to 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you want to submit a request to exercise any of your above rights please fill in the online form listed at: Information Request Form (office.com) or reach out to privacy@mphasis.com
5. We Do Not Sell your Personal Information
We do not sell your Personal Information that we collect for direct marketing purposes or for any commercial purpose, and in the last twelve (12) months, we have not sold any Personal Information.
6. We Retain your Personal Information
We retain each category of your Personal Information, including sensitive Personal Information for which the Personal Information was collected not longer than is reasonably necessary for the purpose for which such Personal Information was disclosed.
7. Contact Information
If you have any questions about the ways in which we collect and use your Personal Information or if you wish to exercise your rights, please do not hesitate to contact us at:
Name of the Data Protection Officer: Richa Gupta
Email: privacy@mphasis.com
For more information about our privacy practices, please review our privacy notice: Digital Risk - Privacy (mphasis.com)
