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Privacy Policy

Version 1.1

Last updated on 2019-03-26

Introduction

Your privacy is important to us. We believe it is important for you to know how we treat the information we receive from you, on the TCS CUBO website www.tcscubo.com (the “Site”). This Privacy Policy (“Policy”) explains what personal data we, Tata Consultancy Services Limited (“TCS” or “we”), collect from you, through our interactions with you on this Site, and how we use that data. It is important that you read this Policy, together with any other privacy notice which we may provide on specific occasions when we are collecting or processing personal data about you, so that you are aware of how and why we are using such information.

TCS is a “data controller”. This means that we are responsible for deciding how we hold and use personal data about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

These privacy terms apply only to the Site and not to other website of TCS.

Data Protection Principles

We will comply with applicable data protection laws. This means that the personal data we hold about you must be:

Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.

Scope and Usage of Data

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (aka anonymous data).

We will collect and use different kind of personal information according to the various situations and interactions with you. We may process personal data to:

Ensure access to our website and online services

Our web servers or Service Providers who provide analytics and performance enhancement services collect IP address, operating system details, browsing details, device and connectivity details and language settings. This information is aggregated to measure the number of visits, average time spent on the site, pages viewed and similar information. TCS uses this information to measure the site usage, improve content and to ensure safety and security as well enhance performance of the website.

To have access to the Site's functionalities you are required to register: in these cases we will also collect your username and password (which will be stored in a safely manner), name and last name, employer and email ID; during your usage of these functionalities, we will also collect your subscriptions and your comments.

TCS uses cookies (small text files placed on your device) and similar technologies to provide our websites and to help collect data: please read here our full cookie policy. Please note that our websites may include links to websites of third parties whose privacy practices differ from those of TCS; if you provide personal data to any of those websites, your data is governed by their privacy statements.

Under the European General Data Protection Regulation ("GDPR"), the lawful bases for this processing are performance of a contractual obligation and legitimate interest.
Answer to your queries, support and contact requests

At times you may decide to connect with us for queries, requests for more information about partnerships or products or other generic support inquiries. If you do so, we will need to collect a limited amount of information about you in order to answer to your query, like personal and contact details, demographic data, qualification, profession and the content of your messages to us.

Under the GDPR the lawful bases for this processing are contractual obligation and legitimate interest.
Promote TCS brand, products, initiatives and values with marketing communications

It is TCS's strong interest to promote its brand, products, initiatives and values. We may send you marketing communication through different channels, like email, texts, phone calls or regular mail; to do so, we might use your contact details which had been previously collected in the context of an event, a query sent by you or through the navigation on our websites. We may also obtain your personal information from third parties, like business partners, data brokers, social networks, publicly available sources and marketing companies; in this cases, we will also comply with any additional restrictions imposed by the source of the data. According to the applicable legislation, we may ask for your consent before sending any marketing communication, or let you choose your preferred means. In any case, you can always opt-out from such kind of communications using the form at https://www.tcs.com/contact-us, writing to our Data Protection Officers (see section below) or by any other given tool provided from time to time.

Under the GDPR the lawful basis for this processing are legitimate interest and consent, where requested.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Sharing of data

We share personal data among TCS-controlled affiliates and subsidiaries. We also share personal data with vendors or agents working on our behalf for the purposes described in this statement. For example, companies we've hired to assist in protecting and securing our systems and services may need access to personal data to provide those functions.

We usually do not share other personal data collected from the websites with other third parties. However, this may happen if:

You request or authorize us to do so.
We need to comply with applicable law or respond to valid legal process.
We need to operate and also maintain the security of this website, including to prevent or stop an attack on our computer systems or networks;

Security of Personal Data

We have put in place measures to protect the security of your information.

Third parties will only process your personal data on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate technical, organizational and security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Where We Store and Process Personal Data

Personal data collected by TCS may be stored and processed in your region, in India, and in any other country where TCS or its affiliates, subsidiaries or service providers operate facilities. The storage location(s) are chosen in order to operate efficiently, to improve performance and to create redundancies in order to protect the data in the event of an outage or other problem. We take steps to ensure that the data we collect under this privacy statement is processed according to the provisions of this statement and the requirements of applicable law wherever the data is located.

We transfer personal data from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. Where there isn't an adequacy decision by the European Commission in respect of those countries - meaning that these are not deemed to provide an adequate level of protection for your personal data - we have put in place the appropriate measure/s to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the EU/EEA laws on data protection. These measures include Data Transfer Agreements based on the European Commission's Standard Contractual Clauses. If you require further information about these protective measures, you can request it from our Data Protection Officers (see contacts below).

Our Retention of Personal Data

TCS retains personal data for as long as necessary to provide the access to and use of the website, or for other essential purposes such as complying with our legal obligations, resolving disputes, reporting requirements and enforcing our agreement. Details of retention periods for different aspects of your personal data are available in our retention policy. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. We will retain and securely destroy your personal data in accordance with our data retention policy and applicable laws and regulations.

European Data Protection Rights - GDPR

When we process personal data about you, we do so with your consent and/or as necessary to provide the website you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests of TCS as described in this Policy.

Below, you will find additional privacy information that you may find important. TCS adheres to applicable data protection laws in the European Economic Area, which if applicable includes the following rights:

If the processing of personal data is based on your consent, you have a right to withdraw consent at any time for future processing; to withdraw your consent, please contact the DPO of your country. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
You have a right to request from us, a “data controller” as defined in the law, access to and rectification of your personal data;
You have a right to request from us that your personal data are erased, subject to certain exceptions.
You have a right to object to the processing of your personal data
You have a right to lodge a complaint with a data protection authority.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Changes to This Privacy Policy

We reserve the right to update this Policy at any time, and we will provide you with a new privacy policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data. We encourage you to periodically review this Policy to learn how TCS is protecting your information.

Data Protection Officer

TCS has appointed a Data Protection Officer (“DPO”) to oversee compliance of TCS with applicable data protection laws and with this Policy. If you have any questions about this Policy or how we handle your personal data, please contact the DPO. Depending on your location, you can refer to:

Data Protection Officer for UK and Ireland	Data Protection Officer for Continental Europe
DPO.uki@tcs.com	DPO.Europe@tcs.com

How to contact us

If you have a privacy concern, complaint or a question regarding this privacy statement, please direct it to the Chief Privacy Officer of Tata Consultancy Services at tcs.cpo@tcs.com or contact us through the form at https://www.tcs.com/contact-us.

For the purposes of the EU GDPR, the controller of your personal information is Tata Consultancy Services Limited, TCS House, 2nd Floor, Raveline Street, Fort Mumbai 400 001, India.

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