Your privacy is important to us. URI Technologies Limited and its group companies hereinafter referred as ‘URI Technologies,’ is committed to respect your privacy while using our website. This URI Technologies Data Privacy Policy (“Policy”) defines the requirements to ensure compliance with the applicable data privacy laws and regulations applicable to URI Technologies’s collection, use, and transmission of Personal Data and Sensitive Personal Data for information collected by us about you.

Protecting the privacy rights of data subjects and safeguarding their Personal Data is now being treated as a basic right of an individual and a legal requirement in many parts of world.

URI Technologies, being a global organization, respects the privacy of data subjects and is committed to complying with the applicable data privacy laws.

1. Policy Statement

This Policy is designed to explain and set out URI Technologies’s procedures and policies when processing Personal Data and Sensitive Personal Data (the meaning of which are set out below) by the organization. This Policy defines the requirements to ensure compliance with the Data Privacy Laws applicable to URI Technologies’s collection, use, and transmission of Personal Data and Sensitive Personal Data.

2. Scope

The scope of this Policy applies to URI Technologies, its affiliates, business partners, employees, and Third Parties providing services to URI Technologies (together “URI Technologies”, “we” or “us”). It covers Processing (including but not limited to collection, storage, usage, transmission and destruction) of Personal Data and Sensitive Personal Data of URI Technologies’s current and previous employees, prospective candidates, current, prospective and previous customers, current and previous partners/vendors, website visitors, sub-contractors and visitors, (together “you”/ “your”) by URI Technologies during the course of its business activities.

URI Technologies acts as a Data Controller with respect to any Personal Data or Sensitive Personal Data it holds about you. URI Technologies is responsible for ensuring that it uses your Personal Data in compliance with the Data Privacy Laws.

This Policy sets out the basis on which any Personal Data, Personal Information and Sensitive Personal Data about you that you provide to us, that we create, or that we obtain about you from other sources, will be processed by us.

3.

Your Personal Data may be stored and processed by us in the following ways and for the following lawful purposes:

  • Where you have applied for a role with us, to review and process your job application with us and (only where legally permissible and where strictly necessary to assess your suitability for the relevant role) to conduct background screening checks on you (when permitted or required by the applicable law);

  • To carry out activities relating to your employment contract with us (including, but not limited to, processing your salary, administering benefits, managing and providing training relevant to your role and managing your performance);

  • To provide our products and services to you;

  • To comply with any legal and regulatory obligations that we have to discharge;

  • To establish, exercise or defend our legal rights or for the purpose of legal proceedings;

  • Where you are an employee or visitor to our premises, to record and monitor your use of our premises and/or information technology systems in order to maintain its security and protect them against fraud or unauthorised entry;

  • Use it for our legitimate business interests, such as operating our website, managing the efficient management and operation of our business, conducting marketing activities designed to improve the products and services we offer to you, and administering the security of our business (“Legitimate Business Interests”); and improve the products and services we offer to you, and administering the security of

  • Use it to prevent and respond to actual or potential fraud or illegal activities.

  • Internal Research: We may Process Personal Information for internal research for technological development and demonstration

  • Transactional: We may transfer Personal Information as an asset through a merger, acquisition, bankruptcy or other transaction in which a Third Party assumes control of the business in whole or in part. In such event, the Third Party cannot materially alter how it uses or shares the acquired Personal Information subject to certain exceptions.

We are entitled to Process your Personal Data, Personal Information or Sensitive Personal Data in these ways because of the following reasons:

  1. Performance of Contract: We may process your Personal Data, Personal Information or Sensitive Personal Data, where necessary to enter into a contract with you or to perform our obligations under a contract with you. E.g processing of personal data for employment purposes (such as processing your salary, administering benefits) or providing services to our customers which are necessary to execute the contract. If you do not provide Personal Data for processing under this legal basis, we may not be able to perform as per the respective contract.

  2. Consent: Where permitted under applicable local laws, we may (but usually do not) process your Personal Data, Personal Information or Sensitive Personal Data based on your prior consent. In such cases, you have the right to withdraw your consent at any time by contacting the details below provided in this Privacy Policy. In certain limited circumstances, even after withdrawal of Data Subject consent, we may be entitled to continue processing your Personal Data where we have a lawful reason to do so and as communicated to you.

  3. Legitimate Interests: We may process your Personal Data, Personal Information where it is necessary for our Legitimate Business Interests as a company, including to manage, which are outlined above

  4. Legal Obligations: We may process your Personal Data, Personal Information where it is necessary in order to comply with applicable legal and/or regulatory obligations, establish, exercise or defend our legal rights or for the purpose of legal proceedings and to prevent and respond to actual or potential fraud or illegal activities.

  5. Other “Public Interest” Grounds: We may process your Personal Data, Personal Information (or where relevant, your Sensitive Personal Data) on other public interest grounds where it is subject to regulatory requirements where Processing is necessary by us for the performance of a task mandated by governmental authorities, regulatory authorities or any other law enforcing authorities in the public interest.

Data Elements / Categories Purpose of Collection Lawful Basis
URI Technologies Customer’s data/Customer’s customer data that is shared with URI Technologies to be processed in the role of a Processor / Sub-processor Providing services to fulfil the contractual obligations with URI Technologies’s customers in the role of a Processor. This data will not be shared/processed for any other purpose other than what is stated in the contract between URI Technologies and its Customers Performance of the contract or business purpose
Partner/Vendor Personal Data or Personal Information Receiving Services from Vendor/ Partner: to receive products and services from you; Performance of the contract or business purpose
Prospective Candidates Employment Opportunities: Where you have applied for a role with us, to review and process your job application with us and (only where legally permissible and where strictly necessary to assess your suitability for the relevant role) to conduct background screening checks on you (when permitted or required by the applicable law); Legitimate interest of URI Technologies or business purpose
Employee Data Employment related activities: To carry out activities relating to your employment contract with us; Performance of contract, compliance with laws and legitimate interest or business purpose
Visitor information Security Purposes: Where you are a visitor to our premises, to record and monitor your use of our premises and/or IT systems in order to maintain their security and protect them against fraud or unauthorised entry Legitimate interest or business purpose
Marketing Data, Website Data, initiatives, survey and Events Marketing purposes: To engage in marketing and business development activities in relation to our products and services. This may include email and SMS marketing, other marketing communications as well as organising events. Use it for our legitimate business interests, such as operating our website, managing the efficient management and operation of our business, conducting marketing activities designed to improve the products and services we offer to you, and administering the security of our business Consent, Legitimate Interest or business purpose
Website Cookies Marketing purposes: Where you use functionality or visit our website including, subject to acquiring your prior consent where legally necessary, the use of cookies on our website (see our Cookie Policy for more information) Consent, Legitimate Interest

4.Processing Sensitive Personal Data

We may, where legally permissible, process your Sensitive Personal Data on the following lawful bases:

  • Explicit Consent is obtained from you where required under applicable local laws or in specific circumstances, where you are physically or legally incapable of giving consent, but the processing is necessary to protect your vital interest for example, where emergency medical care is needed

  • Without explicit consent when such Processing is specifically authorised or mandated by applicable local Data Privacy Laws including but not limited to circumstances where URI Technologies is permitted to process Sensitive Personal Data.

5.Personal Data of Individuals below 18 years

We may process Personal Data or Sensitive Personal Data of any individuals below the age of 18 years only for travel and immigration purposes. If we are required to process Personal Data or Sensitive Personal Data of such individuals, then we shall do so by taking explicit written consent from their legal guardians. If it comes to your knowledge that we have unintentionally collected or received Personal Data or Sensitive Personal Information about an individual below the age of 18 years directly from them, then immediately notify Us in the contact details provided in this Policy and we will accordingly delete such information.

Note: If you are below the age of 18 years, then we do not want you to provide any of your Personal Data in our website.

6.How we will be using your Personal Data/ Personal Information for Direct Marketing

For direct marketing, we will be using your Personal Data/ Personal Information in the following ways (to the extent in compliance with applicable local laws).

  1. Manage and maintain our relationship with you, including responding to an inquiry, question or comment made by you.

  2. To engage in marketing and business development activities in relation to improve URI Technologies’ products and services.

  3. Improve the products and services we offer to you, and administering the security of our business.

  4. To conduct analysis and market research to improve this website

  5. Inform you about our service offerings by communicating through email, SMS, phone and any other similar communications means

  6. Respond to any legal process or as required by law in response to any court order, subpoena or a law enforcement agency, defending us in case of legal disputes or to take action against any illegal activity and to address any potential threat to the physical safety of a person

  7. California residents who provide Personal Information are entitled to request information about themselves that we shared with Third Parties for their own direct marketing purposes (if applicable), including the categories of information and the names and addresses of those businesses. We do not currently share the Personal Information of California residents with Third Parties for their own direct marketing purposes

7.Events and Initiatives

We organize and participate in events and initiatives. In such cases this Policy applies to participants and speakers together with any other supplementary information that is provided in relation with each event. In the event we appoint any Third Parties to conduct or organize such events and initiatives, your Personal Data or Personal Information shall be shared to such Third Parties under contractual obligations with such Third Parties in compliance with applicable Data Privacy Laws. The processing of Personal Data/ Personal Information by such Third Parties shall however be governed by the respective parties’ privacy policies and the contractual obligations entered with us.

8.Retention and Disposal of Personal Data or Personal Information

How long we continues to hold your Personal Data/ Personal Information will vary depending principally on:

  • Purposes identified in this Policy for using the Personal Data/ Personal Information/ Sensitive Personal Information – we will need to keep the information for as long as is necessary for the relevant purpose; and

  • Legal obligations – laws or regulation may set a minimum period for which we will have to keep your Personal Data/ Personal Information/ Sensitive Personal Information

  • Disposal of Personal Data/ Personal Information/ Sensitive Personal Information shall be handled with utmost care and shall be governed in accordance with reasonable data security practices as detailed by its internal policies governing data disposal.

  • Personal Data/ Personal Information/ Sensitive Personal Data shall only be Processed for the period necessary for the purposes for which it was originally collected as per the URI Technologies Retention Policy.

9.Security of Personal Data/ Personal Information/ Sensitive Personal Data

In order to comply with our data security obligations under applicable Data Privacy Laws, we has adopted the following physical, technical and organizational security measures to ensure the security of your Personal Data/ Personal Information and Sensitive Personal Data:

  • That includes the prevention of their alteration, damage, loss, unauthorized processing or access, having regard to the nature of the data and the risks to which they are exposed by virtue of human action or the physical or natural environment.

  • We shall comply with the security safeguards as per our contractual and statutory requirements in consultation with its internal I.T department.

  • The Office of Data Privacy and Chief Information Security Officer shall assess the security measures implemented to safeguard Personal Data, Personal Information and Sensitive Personal Data on a regular basis and update the same, where required

  • All employees and contractors shall be imparted with mandatory Privacy training (e.g., Training on Embedding Privacy in Software Development etc.). Further confidentiality agreements and Non-Disclosure Agreements shall be signed by all employees and contractors on or before their joining date with URI Technologies.

  • We have implemented the following safeguards to ensure the data We collects, stores, processes and shares is secure:

    • Physical Security Controls

      • Facility Perimeter, HD access reader, Data Centre, Video surveillance

    • IT Infrastructure Controls

      • Encryption, DLP, Data masking, controlled Portable ports, Access Control, Unauthorized software check, Data destruction, System Hygiene measures, Monitoring, User Access Management, Patch Management, Vulnerability Management

We have implemented an incident and breach management procedure to ensure that exceptions in data privacy compliance are promptly reported to the Office of the Data Privacy.

10.Privacy by Design

  • We have established a process to proactively embed privacy at the initial planning/design stages and throughout the complete development process of new processes/ services/ technologies and/or platforms that involve Processing of Personal Data.

  • Considerations have been made for technical and organizational measures to enhance privacy (e.g. pseudonymization, anonymization, data minimization, data aggregation etc.).In addition, we shall take appropriate technical and organizational measures to ensure that Personal Data collected or Processed is adequate, relevant and limited to what is necessary in relation to the purposes for which they are Processed.

  • With respect to the Personal Information of California residents and in addition to the above, we will use measures to enhance the privacy of your Personal Information through the use of measures to “aggregate consumer information” or to “deidentify” such Personal Information as those terms are defined by the CCPA.

11.Your Rights

You have certain rights relating to your Personal Data/ Sensitive Personal Data provided for under applicable Data Protection Laws.

  • The right to request access to your Personal Data/ Sensitive Personal Data and the processing activities on the Personal Data/ Sensitive Personal Data and, where applicable, receive a copy of your Personal Data/ Sensitive Personal Data. Please note that there may be circumstances in which we are entitled to refuse requests for access or to receive copies of your Personal Data/ Sensitive Personal Data.

  • Request that your Personal Data/ Sensitive Personal Data is corrected if it is inaccurate or incomplete.

  • Request erasure of your Personal Data/ Sensitive Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it.

  • Request that the processing of your Personal Data/ Sensitive Personal Data is restricted in certain circumstances.

  • Object to processing of your Personal Data/ Sensitive Personal Data in certain circumstances. Again, there may be circumstances where you object to our processing of your Personal Data/ Sensitive Personal Data but we are legally entitled to refuse that request.

  • Receive your Personal Data/ Sensitive Personal Data provided to us as a Data Controller in a structured, commonly used and machine-readable format in certain circumstances and/or request that we transmit that Personal Data/ Sensitive Personal Data to a Third Party where that is technically feasible. Please note that this right only applies to Personal Data/ Sensitive Personal Data which you have actually provided to us.

  • Lodge a complaint with an applicable data protection supervisory authority, if you think that any of your data protection rights have been infringed by us. We can, via the contact details provided in this Policy, tell you which data protection supervisory authority is relevant to the processing of your Personal Data/ Sensitive Personal Data.

  • If the Processing of your Personal Data/Sensitive Personal Data is based on (explicit) consent, you can withdraw your consent at any time by contacting us. Please bear in mind that in certain circumstances it may be lawful for us to continue processing your Personal Data/ Sensitive Personal Data without your consent if we have another legal basis (other than consent) for doing so.

  • Right to have onsite access of your Personal Data (for Mexico only).

  • Right to raise a request to cancel processing of your Personal Data (for Mexico only).

12.Disclosure to Third Parties

  • We may disclose some of your Personal Data/ Personal Information/ Sensitive Personal Data to affiliates within our corporate group companies under the following circumstances:

    • Personnel administration, employee work and business management purposes.

    • To provide service that is legally bound by a valid contract.

    • To provide service that is legally bound by a valid contract.

    • To identify and contact the Data Subject.

    • To ensure compliance to local laws and regulations.

    • Security Management

    • Events and Initiatives

  • We may also share Personal Data/ Personal Information/ Sensitive Personal Data outside of its corporate group where we relies on Third Parties to assist in its processing activities. This may include:

    • Third Party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your Personal Data/ Personal Information/ Sensitive Personal Data for the purposes described in this Policy. This may include, but is not limited to, information technology and communication services providers.

    • Third Parties relevant to the products and services that we provide. This may include, but is not limited to, hardware or software manufacturers, other professional services providers, regulators, authorities and other governmental institutions.

    • To the extent required by law, regulation or court order, for example if we are under a duty to disclose your Personal Data/ Personal Information/ Sensitive Personal Data in order to comply with any legal obligation.

    • You may reach out to the contact details provided in this Policy, if you would like to know the name of the Third Parties to whom we have shared your Personal Data.

  • With respect to disclosing Personal Data/ Personal Information/ Sensitive Personal Data to Third Parties, such written contracts with Third Parties will include restrictions prohibiting the Third Party from retaining, using or disclosing Personal Data/ Personal Information/ Sensitive Personal Data for any purpose except performing the services specified in the contract or as otherwise permitted by applicable Data Privacy Laws.

  • Where it discloses your Personal Data/ Personal Information/ Sensitive Personal Data to Third Parties URI Technologies will seek to use a Data Processors or Subprocessors that are capable of providing sufficient security measures in accordance with applicable Data Privacy Laws and shall put in place contractual mechanisms to ensure that the relevant Data Processor or Subprocessor takes reasonable steps to ensure compliance with those measures.

  • URI Technologies does not sell any Personal Data/ Personal Information/ Sensitive Personal Data under any circumstances.

13.Quality of Personal Data/ Personal Information and Sensitive Personal Information

  • We shall ensure to implement reasonable Processes to monitor the quality of the Personal Data/ Personal Information and Sensitive Personal Data we store/ process.

  • Each business unit & support function within our organisation shall take steps to assure that Processed Personal Data/ Personal Information and Sensitive Personal Data is complete and accurate.

  • We shall implement a process to ensure that our employees can review, update and confirm on the accuracy and completeness of their Personal Data/ Personal Information and Sensitive Personal Data Processed by us.

14.Complaints and Grievances

Any complaints or grievances received about our use of Personal Data, Personal Information or Sensitive Personal Data should be promptly directed to the our Data Privacy Officer.

Complaints related to Personal Data, Personal Information, Sensitive Personal Data protection and any communications regarding enforcement of your privacy rights should be directed to the Data Privacy Officer at the following contact details:

info@uritechnologies.com