VENDOR PRIVACY POLICY
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INTRODUCTION
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This Vendor Privacy Policy (“Policy”) sets out how Deltatech Gaming Limited (“we”, “our” or “us”) processes any personal data we collect from you, we collect about you, or that you provide to us. We are committed to protecting your personal data and respecting your privacy. Please read this Policy carefully to understand our practices regarding your personal data and how we will treat it.
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Please note that this Policy applies in addition to all other contracts you have entered into with us.
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By providing us with the consent to process your personal data, you acknowledge that we will collect, store, use, and disclose your personal data in accordance with this Policy.
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THE DATA WE COLLECT ABOUT YOU
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We collect, use, store, transfer, or otherwise process personal data about you to fulfil purpose related to your contract with us, to the extent permissible under law. Such personal data includes:
(a)Identity Data: This includes data such as the first and last name, date of birth, title, gender, educational qualifications and background, organisation name and address, identification documents, and photographs of your employees or contractors (“Representatives”) who may get in touch with us under our commercial arrangement with you.(b)Aadhaar Data and Government Identification Documents: Please note that we may collect and process your Representatives’ Aadhaar information to verify their identity. The provision of Aadhaar information is voluntary and not mandated. Should your Representatives choose not to provide us with their Aadhaar information, we will provide them with alternate options, such as the submission of their passport information, voter’s ID, driver’s licence, or any other form of recognised national identification document.(c)Contact Data: This includes data such as your Representatives’ phone number and email address.(d)Vendor Data: This includes data such as job titles or positions of key Representatives, office location of the vendor, performance (including evaluation and feedback) and compliance records, details of training or onboarding provided to Representatives, details of grievance procedures involving Representatives, details of any business proceedings that the vendor may have been involved in, payment records, details of promotions or changes in Representatives’ status, and details of Representatives’ travel or visits to company premises.(e)Financial Data: This includes data such as your Representatives’ financial information, bank account details, bank account statements, tax residency details, tax status, details relating to declarations, nominee details, etc. -
We may also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data under law.
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HOW WE COLLECT DATA ABOUT YOU
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We use different methods, as permitted under law, to collect and process personal data about you. This includes:
(a)Information you provide us: This is the information you choose to provide in furtherance of your commercial arrangement, or when you correspond with us (for example, by email or chat). If you contact us, we will keep a record of the information shared during the correspondence.(b)Information we receive from other sources including third parties and publicly available sources: We may receive personal data about you from various publicly available sources, such as public internet pages.
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HOW WE USE YOUR PERSONAL DATA AND FOR WHAT PURPOSES
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We will only use your personal data in accordance with law. Most commonly, we will use your personal data for purposes of our commercial arrangement with you, or where we need to comply with a legal obligation.
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In general, we will not use or disclose personal data except in accordance with the following purposes or activities:
(a)To determine your eligibility to offer us your services;(b)To manage our relationship with you;(c)To administer and protect our business;(d)To send you communication related to your services;(e)To perform our obligations under our contract with you;(f)To carry out due diligence checks;(g)To detect and protect against error, fraud, and other criminal activities;(h)To optimise vendor performance metrics;
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HOW WE SHARE YOUR PERSONAL DATA
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You hereby agree and acknowledge that any and all personal data pertaining to you may be shared by us with our group companies or third parties including financial institutions, vendors, service providers, and business partners, for the purposes detailed in this Policy, in accordance with your consent where required under law.
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We may share personal data with potential buyers, transferees, or other such partners and their advisers in connection with an actual or potential transfer or merger of part or all of our business or assets, or any associated rights or interests, or to acquire a business or enter into a merger.
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You agree and acknowledge that we may share data where we are required by law, any court, government agency, or authority to disclose such personal data. Such disclosures are made in good faith and belief that it is reasonably necessary to do so for enforcing this Policy, or in order to comply with law.
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DATA SECURITY
We implement adequate security measures to protect your personal data from unauthorised access and such security measures are in compliance with the security practices and procedures as prescribed under law.
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DATA RETENTION AND DESTRUCTION
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You agree and acknowledge that your personal data will continue to be stored and retained by us for as long as necessary to fulfil our stated purpose(s) and for a reasonable period after termination of our contract with you, in compliance with law.
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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 unauthorised 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.
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Upon completion of the retention period for each category of personal data as described above, we shall delete or destroy, to the extent technically possible, personal data in our possession or control, or render the personal data into anonymised data, so that it no longer constitutes personal data, in which case we may use this information indefinitely without further notice to you.
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YOUR LEGAL RIGHTS
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Under certain circumstances and subject to law, you may have certain rights in respect of your personal data such as the right to review and correct your personal data, or revoke or deny consent.
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If you wish to exercise any of the rights set out above, please write an email to the Grievance Officer, whose details are mentioned in Section 13 of this Policy.
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Upon completion of the retention period for each category of personal data as described above, we shall delete or destroy, to the extent technically possible, personal data in our possession or control, or render the personal data into anonymised data, so that it no longer constitutes personal data, in which case we may use this information indefinitely without further notice to you.
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TRANSFER OF PERSONAL DATA
To the extent required under law, we will store your personal data in India. Where necessary, we may transfer your personal data to a third country in compliance with the law.
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BUSINESS TRANSITIONS
You agree and acknowledge that in the event we go through a business transition, such as a merger, acquisition by another organisation, or sale of all or a portion of our assets, your personal data may be among the assets transferred.
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CONFLICT
To the extent that the terms of this Policy conflict with any other contract you have entered into with us, the terms of this Policy will prevail.
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CHANGE IN PRIVACY POLICY
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We keep our Policy under regular review and may amend it from time to time, at our sole discretion.
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The terms of this Policy may change and if they do, these changes will be posted on this page and, where required by law, notified to you.
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GRIEVANCE OFFICER
You may contact us at finance@deltatech.gg with any enquiry relating to this Policy or an enquiry relating to your personal data (including reviewing or updating). You can also do so by writing to our Grievance Officer Mr Aniket Salgaonkar at aniket.salgaonkar@deltatech.gg .