Privacy Notice INDIA

The company Softtek India Pvt Ltd (hereinafter "Softtek") having registered office at Shilpa Emerald, 26/1, Hosur Rd, Bengaluru, Karnataka 560068 undertakes to protect and respect the personal data you have provided to us and your privacy by adopting the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected. To this end, we inform you, through this privacy notice how we collect, use, disclose and protect your personal data in accordance with the Digital Personal Data Protection Act 2023 (DPDPA 2023) and other applicable data protection laws.

This Privacy Notice, along with the Terms of Use. and Cookies Policy, outlines how we collect, use, and protect your information.

Personal Data We Collect.

We inform you that the Personal Data that you voluntarily provide to Softtek and that may vary depending on the nature of our interaction with you, may be classified into the following categories:
- Identification data: Name, address, contact details (email address, phone number), gender, date of birth, photographs, national identification documents like Aadhaar, PAN, UAN, Passport, or any other such document.
- Professional Information: Resume/CV, job title, application form (received through various job portals), employment history, skills, educational qualifications, certifications, references, etc.
- Financial Data: Bank account details, compensation & benefits information, income tax details, and any other relevant information.
- Technical data: IP addresses, browser type, location and information about how you interact with our services or website.
- Other Data: Biometric data, Health data (Blood Group), family details, etc. (only if necessary and with explicit consent).
Purposes of processing your personal data

We only collect and process the minimum necessary personal data, and these will be collected, stored, used and, in general terms, processed by Softtek as a Data Fiduciary, for the purposes described below, in accordance with the DPDPA 2023 and other applicable data protection laws.

We process your personal data for the following purposes:
- Recruitment: To assess your qualifications and suitability for the role organization is looking for, communicate with you regarding your application status, and determine your eligibility for employment.
- Employee Onboarding: If you are successfully hired, your personal data will be used for employment-related processes such as employment offer, background verification, preparing contract, managing payroll, and administering benefits.
- Employment Records: To maintain employment records, ensure compliance with various laws in India. To manage employee performance and career development, including training programs, performance reviews, and promotions, in alignment with the company’s objectives.
- Legal Compliance: To comply with applicable laws and regulations, including tax, labor, and health and safety laws. Personal data is processed to ensure the organization meets its legal and regulatory obligations, including those arising from the DPDPA 2023.
- Employee Benefits: To administer employee benefits programs, including various insurance benefits, a daycare center (Creche), transportation, and other company-sponsored benefits.
- Access Control: Biometric data, such as fingerprints, to manage access control to restricted areas of SOFTTEK's facilities.
- For any other purpose that we may inform you about at the time of data collection.
Legal basis for processing

Under the DPDPA 2023, we rely on the following legal bases for processing your personal data:
- Consent: Where we have obtained your explicit consent to process your personal data.
- Contractual necessity: Where processing is required to perform a contract with you, or to take steps at your request prior to entering into a contract.
- Legal obligation: Where processing is necessary to comply with employment-related legal obligation.
- Legitimate interests: Where we have a legitimate business interest in processing your personal data, provided that such interests do not override your fundamental rights and freedoms.
1. 3.1 Data Sharing and Transfers
  
  Softtek may share your Personal Data with its affiliates and subsidiaries, including those located in other jurisdictions where Softtek operates or maintains data centers. Transfers may occur to our holding entity Valores Corporativos Softtek S.A. de C.V., domiciled in Mexico, for purposes of centralized information management.
  - Affiliated Companies: Your Personal Data may be transmitted to Softtek’s affiliated entities in India or abroad to support operational and administrative activities.
  - Service Providers and Partners: We may engage third party suppliers, partners, service providers, or consultants to process Personal Data on our behalf. These parties are contractually bound to maintain confidentiality, use the data only for specified purposes, and comply with applicable data protection requirements.
  All transfers are carried out in accordance with applicable data protection laws and with appropriate safeguards to ensure the security and confidentiality of your personal data.
2. 3.2 Automated Decision-Making and Profiling in Hiring Processes
  
  We do not use fully automated decision-making to select profiles in the hiring process. If fully automated decision-making or profiling is used in an individual case, we will inform you separately. If required by law, we will obtain your prior consent.
Data subject rights

As a Data Subject, you have the following rights under the DPDPA 2023 with respect to your personal data:
- Right to Access
  You have the right to request access to the personal data we hold about you. This includes information regarding the types of data, the purposes for which the data is processed, and how it is being used. Upon your request, we will provide you with a copy of the personal data we process, subject to certain limitations set out in DPDPA 2023.
- Right to Correction and Erasure
  You have the right to request the correction of any inaccurate, incomplete, or outdated personal data that we process about you. Additionally, you may request the erasure of your personal data under specific circumstances, such as when the data is no longer necessary for the purposes for which it was collected.
- Right of Grievance Redressal
  If you believe that your rights under this Act are being violated, you have the right to file a grievance with us. We are committed to addressing your concerns and resolving any issues related to the processing of your personal data.
- Right to Nominate
  You have the right to nominate a representative or a person to act on your behalf with respect to the exercise of your rights under the DPDPA 2023. This can be particularly useful if you are unable to exercise your rights personally.
- Right to withdraw consent
  You have the right to withdraw your consent at any time where we are relying on your consent to process your personal data. Withdrawal will not affect the lawfulness of processing carried out prior to your withdrawal. To exercise this right, please contact us using the details provided below.
1. 4.1 Contact for the exercise of your rights.
  
  If you wish to exercise any of your rights under DPDPA 2023, please contact our Data Protection Officer (DPO) or the authorized representative:
  
  Data Protection Officer
  - Name: Avinash N
  - Email: dpo.india@softtek.com
  - Address: Softtek India Pvt Ltd
    Shilpa Emerald, 26/1, Hosur Rd, Bengaluru, Karnataka 560068.
Data Processing for Website Provision and Log Files

When you visit our website, certain technical information is automatically collected and stored by our web servers. This may include your IP address, location, the referring website, pages visited on our site, and the date and duration of your visit.

This information is stored in system log files and used solely for:
- Diagnosing technical issues and ensuring error-free operation
- Maintaining the security and stability of our systems
- Displaying the website correctly on your device
We do not combine this technical data with other personal information, and it is not analyzed for marketing purposes. Temporary storage of anonymized IP addresses and retention of log files are essential to ensure the functionality and continuous improvement of our website.

Processing is carried out under our legitimate interest in providing a secure and reliable website, in accordance with Article 4(1)(b) of the Digital Personal Data Protection Act, 2023.
Data retention period

We will retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including legal, regulatory or contractual obligations. In accordance with the DPDPA 2023, we will periodically review the data we hold and securely delete or anonymize any personal data that is no longer needed for these purposes.
Data Security

We take appropriate technical and organizational measures to safeguard your personal data against unauthorized access, loss, alteration, or destruction. This includes the use of encryption, access controls, and secure storage protocols to protect your data.
Grievance Redress Mechanism

If you are unhappy with how we have handled your personal data or with our response to your rights, you can lodge a complaint directly with us (the DPO). We will try to resolve your complaint within a reasonable time and assist you in the process of filing a complaint.

If you are still not satisfied, and in accordance with the DPDPA 2023, you have the right to lodge a complaint with the Data Protection Board of India. To file a complaint, you can visit the official website of the Data Protection Board of India.
Contact details of the Data Protection Officer (DPO)

If you have any questions, concerns, or wish to exercise any of your rights under the DPDPA 2023, please contact our Data Protection Officer (DPO) or their authorized representative:

Data Protection Officer
Name: Avinash N
Email: dpo.india@softtek.com
Address: Softtek India Pvt Ltd
Shilpa Emerald, 26/1, Hosur Rd, Bengaluru, Karnataka 560068.
Attention to DPO

The Data Protection Officer or authorized representative will be happy to assist you with any queries or requests relating to your personal data and your rights under the DPDPA 2023.

Last modification: March 2026.