Mindtickle Privacy Policy
Last Updated: November 16, 2023
MindTickle, Inc. and MindTickle Interactive Media Pvt. Ltd. (collectively referred to as “Mindtickle” or “we”, “us” or “our”) are committed to ensuring that your privacy is protected and want you to understand how we collect, use, and disclose your information. This Privacy Policy outlines the manner in which Mindtickle gathers, utilizes, transfers, safeguards, stores, maintains, or otherwise manages the Personal Information of individuals (“You”) collected through our marketing website located at mindtickle.com, including linked sub-domains (the “Website” or “the “Site”) or shared with us through other sales /marketing channels and business partners. It also describes the rights accessible to you as a data subject under applicable data protection laws and the procedures governing our response to such requests.
By using our Site or sharing Personal Information with us, you accept and agree to the practices described in this Privacy Policy. We highly recommend you regularly review this Privacy Policy to stay informed about any updates or modifications we may make.
You can request a copy of this Privacy Policy by contacting us at [email protected].
1. Types of Personal Information
1.1. Personal Information
This refers to any information related to an identified or identifiable natural person. This information may include name, business email address, job title, phone number, etc. (collectively “Personal Information”).
If you submit any Personal Information relating to other people to us, such as their names and email addresses, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
1.2 Network and Device Information
As is true of most websites, we automatically gather certain information, such as IP addresses.
1.3. Navigational Information
We may also gather navigational information about you, which may include but is not limited to the number of visits, pages visited, average time spent, number of clicks, pages referred from the landing page, etc.
2. Categories of Personal Information
The following table details the categories of Personal Information that we collect and have collected over the past 12 months from you, either directly or through other sources. For each category of Personal Information, we have also set out the source for collection and the categories of third parties with whom we share the Personal Information.
| Category of Personal Information | Examples of Personal Information Collected | Source | Third Parties With Whom We Share Data For Business Purposes |
| Identifiers | | - Information that you have provided on the website forms, chatbot, and surveys
- Your contact information shared by lead generation services and partners
- Offline forms that you have submitted in events, exhibitions, and conferences
- Business/contact card that you have shared
- Information provided by browsers and devices
- Website interaction information provided by technology partners integrated into the website
| We may share the collected information with the following categories of third parties: - Website hosting provider
- Customer relationship management provider
- Email address verification and validation provider
- Cookie consent management provider
- Interactive product walkthrough provider
- Meeting scheduler
- Cloud phone communication provider
- Workshop enrollment form provider
- Marketing event co-sponsors
- Corporate gift delivery partner
|
| Professional or employment-related information | |
| Geolocation information | |
| Internet, device, or other electronic network activity information | |
| Analytics data | - User identifier captured in session cookies
- Website interaction information such as number of visits, pages visited, average time spent, number of clicks, pages referred from the landing page, etc.
|
3. Sources of Personal Information
We may collect Personal Information directly when you interact with our Website or through other sales/marketing channels. We may also collect Navigational Information about your visit to understand your preferences and interest in our services. Mindtickle provides notice in clear and conspicuous language at the time of the collection of Personal Information to help you provide informed consent.
We collect Personal Information about you through the below-mentioned sources:
3.1 Website Forms, Chatbot, and Surveys
If you wish to explore our services, express interest in receiving more information, or require support online, you may be asked to furnish Personal Information using online forms and chatbots available on our Website. This includes instances such as requesting a free trial or demo, registering for a webinar, contacting us, subscribing to our email newsletter, and downloading content like thought leadership papers, technical resource papers, case studies, etc.
We may also collect Personal Information through the surveys sent for the purpose of analyzing the experience of our product and services.
3.2 Lead Generation Services and Partners
We may receive your Personal Information from a third party whom we have engaged for data enrichment and lead generation. This includes, but is not limited to, providers of lead data and data enrichment tools that capture and share data regarding visitors to our website or people exploring our services, all within the bounds of legal permissions.
3.3 Events, Exhibitions, and Conferences
As a part of our sales initiative, Mindtickle may organize, co-sponsor, or participate in events, conferences, or exhibitions. We may collect Personal Information during such events from our co-sponsors or directly from you when you fill out an offline form or share your business card with us.
3.4 Technology Partners
As with most online services, our Website uses cookies to streamline your navigation and enable key site functions. We also employ third-party cookies for website analysis, preferences, and personalized content/advertising, but only with your consent. To know more about the cookies used by these third parties, please refer to our Cookie Policy.
You have the choice to either enable or disable the use of the optional cookies using the preferences provided in the cookie banner on our Website. If you decide to disable specific cookies, a new cookie will usually be created to remember your preference. This information will be communicated to our Website during your subsequent visits, ensuring that the cookies you opted out of are not employed.
3.5 Social Media Features
Our Website includes social media widgets that allow you to share the content on social media sites. e.g., Facebook, LinkedIn, X, etc. These features may collect your IP address and which page you are visiting on our Website and may set a cookie to enable the feature to function properly. The functionality provided by these social media widgets is managed by third parties, and your interaction with these features will be governed by the privacy policy of respective social media sites; examples below -
4. Use of Personal Information
We may primarily use the collected Personal Information to run marketing and advertising campaigns to sell our services to you.
We use Personal Information for the following purposes, including:
- sharing requested technical resource papers, recorded webinars, interactive product walkthroughs, etc.
- enabling you to participate in webinars, events, seminars, workshops, etc.
- onboarding you on the Mindtickle platform sandbox instance to explore features and functionality
- sending relevant marketing communication and product surveys
- personalizing your experience and improving the overall quality of our website
- identifying visitor engagement trends for determining the effectiveness of our promotional campaigns
- responding to queries and feedback raised through our website contact page or otherwise
- fulfilling and responding to data subject requests
- capturing and managing the cookie consent on the website
- sending alerts regarding the subscribed events, such as sub-processor notification
- delivering corporate gifts relating to participation and contribution to promotional events
- enriching and generating business development and sales leads
- validating and verifying contact email addresses for fraud detection and spam prevention
- contacting and scheduling meetings for business development conversation
- as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
5. Sharing of Personal Information
Your Personal Information may be shared with third parties as permitted under data protection laws and this Privacy Policy.
5.1 Third Parties
We may enlist the services of third parties to assist us in our business operation and associated Website. These third parties provide services such as website hosting, fraud prevention, web analytics, improving marketing campaigns, enhancing social and advertising networks, scheduling meetings with you, providing interactive product walkthroughs, corporate gift delivery, cookie consent management, customer relationship management, lead data enrichment, etc.
To provide these activities, these third parties require access to data that may contain your Personal Information. These third parties are provided minimum required access to data on a need-to-know basis only to perform activities required to provide requested services.
We engage these third parties after performing required due diligence and privacy reviews. Additionally, we sign appropriate confidentiality, non-disclosure, and data protection agreements with these third parties to ensure the security and privacy of your Personal Information.
5.2 Business Partners
Mindtickle might collaborate with third parties to promote and distribute its services. We may disclose the Personal Information that you provide when registering for the event to the co-sponsors of events to allow them to contact you regarding products, programs, services, and promotions that they believe may be of interest to you.
Mindtickle chooses to partner with reputable third parties that respect your information, and your Personal Information will be processed by these business partners as per their respective privacy policies. If you would like to opt-out from sharing your Personal Information with these business partners, please contact us at [email protected].
5.3 Business Transfers
If Mindtickle is a party to a merger or acquisition by another company, or its assets are entirely or partially acquired, Users’ Personal Information may be among the assets transferred. Mindtickle may disclose Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). In this event, you will be notified via email or a prominent notice on our website of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
5.4 Compelled Disclosure
We may be required to disclose Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. We reserve the right to use or disclose your Personal Information if required by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
We have not received any request for disclosure of Personal Information from the government or law enforcement agencies in the past 12 months. For more details, please refer to our Transparency Report.
6. Retention of Personal Information
We may retain collected Personal Information as long as we consider it potentially useful for fulfilling the purposes outlined in this Privacy Policy or as needed to comply with our legal obligations to resolve disputes unless we are required to delete this information by law or court order. Further, we periodically review, clean up, and retain only the Personal Information that aligns with the business purpose for which the information was initially collected.
Please note that we may need to retain certain information provided as part of a data subject request for compliance recordkeeping purposes or to have proof and evidence concerning our relationship should any legal issues arise.
7. Transfer of Personal Information
By disclosing your Personal Information to us, you consent to the transfer of your Personal Information to countries outside of your country of residence, which may have different data protection laws than those of your country or the country in which you were located when you initially provided the Personal Information.
7.1 Data Transfer Mechanism
Your Personal Information may be stored and processed in any country where our service providers have data storage facilities. When we do, we will ensure that an adequate level of protection is provided for the Personal Information by using one or more of the following approaches:
- Similar data protection laws - We may transfer Personal Information to countries that have privacy laws that have been recognized by the country from which the Personal Information is transferred as providing similar protections.
- Contractual safeguards - We may enter into written agreements, such as standard contractual clauses, with recipients that require them to provide the same level of protection for their Personal Information.
- Approved transfer mechanism - We may rely on other transfer mechanisms approved by authorities in the country from which the Personal Information is transferred.
7.2 EU-U.S. Data Privacy Framework with UK Extension, and Swiss-U.S. Data Privacy Framework
Mindtickle complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.
We have certified to the U.S. Department of Commerce that we adhere to:
- the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF
- the United Kingdom (and Gibraltar) under the UK Extension to the EU-U.S. DPF
- the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.
If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
Mindtickle is responsible for the processing of personal data it receives, under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF and subsequently transfers to a third party acting as an agent on its behalf. We comply with the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles for all onward transfers of personal data from the EU, UK, and Switzerland, including the onward transfer liability provisions.
The Federal Trade Commission has jurisdiction over Mindtickle’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
8. Security of Personal Information
We use and ensure our service providers implement a variety of technical and organizational security measures to protect your Personal Information from unauthorized access, use, alteration, disclosure, or destruction. While we are taking efforts to protect your Personal Information, it's important to note that, like any service, this may not ensure absolute immunity from potential issues such as wrongdoings, malfunctions, or misuse.
If you have a reason to believe that your information with us is no longer secure or the security of your account has been compromised, please notify us at [email protected].
9. Your Rights as a Data Subject
Your Personal Information comes with certain rights, per applicable data protection laws, including the EU or UK General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), the Colorado Privacy Act (CPA), the Connecticut Personal Data Privacy and Online Monitoring Act (CTDPA), the Utah Consumer Privacy Act (UCPA), the Virginia Consumer Data Protection Act (VCDPA), the Nevada Privacy of Information Collected on the Internet from Consumers Act (NPICICA), the Brazilian General Data Protection Law (LGPD), the Swiss Data Protection Act (FADP), the Personal Information Protection Law of the People’s Republic of China (PIPL), the Digital Personal Data Protection Act (DPDPA) or the Canada Personal Information Protection and Electronic Documents Act (PIPEDA). Please find more information about your rights below.
- Access - You can request details about the Personal Information we hold about you.
- Rectification - You can request correction or provide supplement data if you think your Personal Information is incorrect or incomplete.
- Erasure - You can request the erasure of your Personal Information from our systems.
- Withdrawal of Consent - If we process your Personal Information based on your consent (as indicated at the time of collection), you can request withdrawal of your consent.
- Data Portability - You can request a copy of your Personal Information in an industry-standard format. Additionally, you can ask us to transmit the data to another organization where technically feasible.
- Restrict Processing - You can ask us to restrict further processing of your Personal Information.
- Object to Processing - You can object to the continued use or disclosure of your Personal Information for specific purposes.
- Right to Opt-Out of Sale - You can request to opt out of the sale of Personal Information we hold about you.
If you seek more information about these rights or wish to submit a request, kindly contact us at [email protected] or fill out the Individual Rights Request Form.
10. Exercising Data Subject Rights
If you are an individual whose Personal Information has been shared and stored in our systems, please feel free to contact us at [email protected].
10.1 Request Verification
We will verify your request using the information associated with your account, including the email address. In some cases, government identification may be required.
10.2 Timeline
We strive to complete data subject requests within 30 days. We will notify you if we require an additional time of up to 60 days to complete the request.
10.3 Exceptions to the Rights of Individuals
Mindtickle reserves the right to charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking action requested in cases where it has sufficient reasons to believe that the requests from an individual are unfounded and excessive. Further, there may be situations where we cannot fully comply with your request, such as in cases where it is frivolous, highly impractical, jeopardizes the rights of others, or is not legally required. However, even in such circumstances, we will respond to inform you of our decision.
10.4 Avoidance of Discriminatory Practices
Mindtickle acknowledges that it does not involve any practice that can be discriminatory against individuals who have exercised their rights available under data protection laws.
11. Other Important Terms
11.1 We Never Sell Personal Information
Under the California Consumers Privacy Act (CCPA) / California Privacy Rights Act (CPRA), Sale is defined as “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information by the business to another business or a third party” in exchange for “monetary” or “other valuable consideration.”
We use the information received for the declared business purpose only and are not involved in any process or activity that can be termed as a “Sale” under CCPA/CPRA. We acknowledge that we have not sold Personal Information received through our Website in the preceding 12 months.
11.2 Sensitive Information
“Sensitive Personal Information” or “Special Categories of Personal Information” means Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or concerns health or a natural person’s sex life or sexual orientation, or is used for processing of genetic data, biometric data or precise geolocation data for the purpose of uniquely identifying a natural person.
We do not require access to your Sensitive Personal Information or Special Categories of Personal Information, and you should not share such information with us.
11.3 Information About Children
Our Website is not intended for or targeted at children (as per the age defined under relevant laws. e.g., 18 years, 16 years, 13 years, etc.), and we do not knowingly or intentionally collect information about children. If you believe that we have collected Personal Information about a child, please contact us at [email protected] so that we can delete the Personal Information.
11.4 Your Consent
By using our Website, you consent to our collection and use of your Personal Information as described in this Privacy Policy. Additionally, we may store and process your Personal Information in various facilities throughout the globe, including in data centers operated and maintained by our Service Providers. If you are a resident in a jurisdiction where the transfer of your Personal Information to another jurisdiction requires your consent, then it is hereby understood that you provide us your consent to such transfer.
11.5 Automated Decision-Making
We do not use Personal Information provided to us to perform automated decision-making.
11.6 Unsubscribing From Our Communications
You may unsubscribe from our marketing communication by clicking on the “unsubscribe” link located at the bottom of our emails or by sending us an email at [email protected].
11.7 Changes to this Privacy Policy
We annually review this Privacy Policy and may update it from time to time to reflect our ongoing commitments. The “Last Updated” legend at the top of this page indicates when this Privacy Policy was last revised. Your continued use of our Website will be subject to the terms of the then Privacy Policy.
12. Questions, Concerns, or Complaints
If you have any questions about this Privacy Policy or our processing of the Personal Information you provide us, please write to us using the below information:
MindTickle, Inc.
Attn: Data Privacy Officer
535 Mission St, 14th Floor, San Francisco
California 94105, United States of America
or
MindTickle Interactive Media Pvt. Ltd.
Attn: Data Privacy Officer or Grievance Officer
4th Floor, Solitaire World, Baner,
Pune, Maharashtra 411045, India
You can reach out to us at [email protected].
13. Dispute Resolution Authority
If you have an unresolved privacy or data use concern, not received timely acknowledgment of your DPF Principles-related complaint from us or we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint (free of charge) with TRUSTe, an alternative dispute resolution provider based in the United States.
For complaints regarding EU-U.S. DPF, the UK Extension to the EU-U.S DPF, and Swiss-U.S. DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.
Platform Privacy Policy
Last Updated: November 1, 2023
MindTickle, Inc. and MindTickle Interactive Media Pvt. Ltd. (collectively referred to as “Mindtickle” or “we,” “us” or “our”) are committed to ensuring that your privacy is protected and want you to understand how we process your information. This Privacy Policy outlines how Mindtickle gathers, utilizes, transfers, safeguards, stores, maintains or otherwise manages Personal Information across web applications, mobile applications, and other services offered as a part of our subscription services (the “Services”). It also describes the rights accessible to you as a data subject under applicable data protection laws and the procedures governing our response to such requests. The use of information collected through our service shall be limited to providing the service for which the Customer has engaged Mindtickle.
In this Privacy Policy, “You” or a “User” or “End-Users” refers to individuals who have been authorized to use the Services subscribed by their respective organizations (“Customer”). Using the Services, you accept and agree to the practices described in this Privacy Policy. We highly recommend you regularly review this Privacy Policy to stay informed about any updates or modifications we may make.
You can request a copy of this Privacy Policy by contacting us at
[email protected].
1. Types of Personal Information
1.1 Personal Information
This refers to any information about an identifiable natural person. We may receive this information from our Customers or directly from you when such information is provided or generated through the use of the Services. This information may include name, business email address, job title, reporting hierarchy, audio/video recording, etc. (collectively “Personal Information”).
If you submit any Personal Information relating to other people to us, such as their names and email addresses, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
1.2 Network and Device Information
As is true of most web-based services, we automatically gather certain information such as IP address, operating system, browser version, device type, device identifier, etc.
1.3 Navigational Information
We gather navigational information about User visits and sessions that include but are not limited to referring pages, clickstream data, date/time stamp, etc.
2. Categories of Personal Information
The following table details the categories of Personal Information that we collect and have collected over the past 12 months from our Customers and their End-Users. For each category of Personal Information, we have also set out the source for collection and the categories of third parties with whom we share the Personal Information.
| Category of Personal Information |
Examples of Personal Information Collected |
Source |
Third Parties With Whom We Share Data For Business Purposes |
| Identifiers |
- Name
- Business email ID
- Any additional identifiers captured by Customers
|
- Information provided as input on the learning site, admin site, or mobile application
- Files uploaded on the learning site, admin site, or mobile application
- Video/audio recorded on the learning site, admin site or mobile application
- Information provided through Application Programme Interface (APIs)
- Participant information received through calendar or web conferencing tool
- Information retrieved through CRM systems
- Video/audio recording received through dialers or web conferencing tool
- User details synchronized through human resource management systems or identity providers
- Information provided by browsers and devices
- Navigational / session information provided by Mindtickle sub-processors integrated on the learning site, admin site, and mobile application
|
Mindtickle shares information with sub-processors to provide services to its Customers in compliance with this privacy policy and contractual agreements with the Customers.
The list of subprocessors currently engaged by Mindtickle can be found at https://www.mindtickle.com/subprocessors
In accordance with our Vendor Security Policy, Mindtickle performs mandatory due diligence of all sub-processors through information security, privacy, and legal reviews.
Mindtickle signs a Data Processing Agreement (DPA) and standard contractual clauses with all of its sub-processors and imposes data protection obligations for protecting Customer Personal Information with similar security standards as committed by Mindtickle to the Customers. These data processing agreements are aligned with the global data protection laws such as GDPR, CCPA, CPRA, UK DPA, etc. |
| Professional or employment-related information |
This is optional, and typically, Customers capture the following information -
- Job title
- Reporting manager
- Reporting hierarchy
- Business unit
|
| Audio, electronic, visual, or similar information |
- Learning or sales content containing personal information
- Training videos
- Training audio
- Training feedback or comments
- Audio call recording
- Video conference meeting recording
- Sales pitch video recording
- Sales pitch audio recording
|
| Customer records information |
This is optional, and typically Customers capture the following information from their Customer Relationship Management (CRM) system, calendar integration, or video conferencing tool integration -
- Customer contact name
- Customer contact email ID
- Prospect contact name
- Prospect contact email ID
- Meeting participant name
- Meeting participant email ID
|
| Internet, device or other electronic network activity information |
- IP address
- Device ID
- User agent string that may reveal your device version, operating system and browser version
|
| Analytics data |
- User identifier captured in session cookies
- User session containing navigational information
|
3. Sources of Personal Information
Mindtickle does not have a direct contractual relationship with the Users whose Personal Information is collected or received while providing Services to the Customers. Our Services are aimed at businesses and are not offered to individual consumers directly. The purposes and means of processing such Personal Information are determined by our Customers, who are the data controllers or similar terms defined in respective data protection laws. We are responsible for processing the collected information as per the instructions provided to us by our Customers through contractual agreements.
We collect Personal Information about you through the below-mentioned sources:
3.1 Use of Services
To fulfill their business needs, Customers may directly provide or require you to submit some Personal Information to Services, including but not limited to name, business email address, job title, reporting manager, audio/video recording, etc.
3.2 Integrations
We may receive your Personal Information through the Services integrations configured by our Customers. These integrations may include Customer systems such as Identity Providers (IdP), Human Resource Management Systems (HRMS), Customer Relationship Management (CRM), calendars, video conferencing, dialers, etc.
3.3 Call Recording
Customers subscribed to our Call AI Services control call recording options and may record your calls. You can make use of Customer-provided options to enable or disable call recording. Customers are required to seek their legal team’s guidance on their call recording policy and decide/configure options to capture call participant consent.
3.4 Network and Devices
We automatically collect information shared by networks, devices, and browsers, such as IP address, operating system, browser version, device model/type, device identifier, etc.
3.5 Third-Party Cookies
We may engage third parties (such as Mixpanel, FullStory, Zipy, etc.) to track User activity and gather usage data from mobile devices, cookies, or browser local storage. To know more about the cookies used by these third parties, please refer to our
Cookie Policy.
These third parties are bound by their privacy policy, as listed below, and may provide options to opt out of collecting usage data. e.g.
https://www.fullstory.com/optout.
Alternatively, Customers can request us to opt-out of collecting optional usage data.
4. Use of Personal Information
Our Customers typically use Mindtickle Services to build training, enablement, coaching, assets/deals management, and capability-building programs used by their employees, business affiliates & customers.
We use Personal Information to provide our Services as per instructions mentioned in the Contractual Agreement signed with our Customers. Our Customer Agreements prohibit us from using this Personal Information, except as necessary to provide and improve the Services and for general business purposes, as permitted by this Privacy Policy and as required by law.
We may use the Personal Information for providing Services, including
- Performing User registration, activation, and authentication activities
- Displaying User details in the User profile, reporting hierarchy, User analytics, coaching reviews, content metadata, feedback, and comments
- Displaying audio/video submissions and call recordings
- Sharing assets on behalf of User through their email address
- Processing and responding to API (REST, GraphQL, Open Data Protocol, etc.) and integration data exchange requests
- Providing User analytics information through integrated data warehouse e.g., Snowflake
- Providing insights, forecasts, risks and opportunities into Customer sales processes and revenue pipeline
- Logging and monitoring of User session activity for issue debugging and product improvement
- Tracking of reported service issues and enhancement requests
- Sending chat and email communication for support, issue debugging, account and relationship management, etc.
- Sending email communication related to service notifications/reminders, release notes, announcements, service incidents, scheduled maintenance, legal/privacy communication, subscribed webinars, product surveys, etc.
- Tracking User engagement and feedback in Customer relationship management system
- Gathering feedback on product onboarding and orientation process
Additionally, we may use the Personal Information for
- Supporting Customers in their business objectives, including providing data and analysis related to their usage of Services
- Fulfilling any other Customer requests within the scope of Services in the Customer Agreement
- Sending marketing communications relating to our business or of third parties which we think may be of interest to you (Applicable as per the Customer Agreement representing End-User)
- Participating in contests and other promotional events (Applicable as per the Customer Agreement representing the End-User)
- Our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving, or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities.
- As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
5. Sharing of Personal Information
Your Personal Information may be shared with third parties or authorities as permitted or required by the contractual agreement signed with our Customers, data protection laws, and this Privacy Policy.
5.1 Third Parties
We may engage third parties for performing activities as required to provide Services to our Customers. These third parties enable us to build capabilities related to technology infrastructure, product features, system integration, technical support, etc. To provide these activities, these third parties require access to data that may contain your Personal Information. These third parties are provided minimum required access to data on a need-to-know basis only to perform activities required to provide Services.
We engage these third parties after performing required due diligence,
security evaluation, privacy review, and as per contractual agreements signed with our Customers. Additionally, we sign appropriate confidentiality, non-disclosure, and data protection agreements with these third parties to ensure the security and privacy of your Personal Information.
To know more about the third parties engaged by us, please refer to our
sub-processor repository.
5.2 Business Transfers
If Mindtickle is a party to a merger or acquisition by another company, or its assets are entirely or partially acquired, Users’ Personal Information may be among the assets transferred. Mindtickle may disclose Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). In this event, our Customers will be notified via email or a prominent notice on our website of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
5.3 Compelled Disclosure
We may be required to disclose Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. We reserve the right to use or disclose your Personal Information if required by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
We have not received any request for disclosure of Personal Information from the government or law enforcement agencies in the past 12 months. For more details, please refer to our
Transparency Report.
6. Retention of Personal Information
Your Personal Information will be retained only for the duration required to provide Services to our Customers, to fulfill our obligations towards you as outlined in this Privacy Policy, as required by law, or for dispute resolution.
Your Personal Information is retained throughout the duration of an active contract with the Customers. Upon the end of or on termination of the contract signed with the Customer, your Personal Information will be retained, returned to the Customer, or deleted as per the terms agreed in the Customer contract.
Please note that we may need to retain certain information provided as part of a data subject request for compliance recordkeeping purposes or to have proof and evidence concerning our relationship should any legal issues arise following your discontinuance of use.
7. Transfer of Personal Information
By using our Services or disclosing Personal Information to us, you consent to the transfer of your Personal Information to countries outside of your country of residence, which may have different data protection laws than those of your country or the country in which you were located when you initially provided the Personal Information.
7.1 Data Transfer Mechanism
Unless otherwise agreed to in a separate Customer agreement, your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers. When we do, we will ensure that an adequate level of protection is provided for the Personal Information by using one or more of the following approaches:
- Similar data protection laws - We may transfer Personal Information to countries that have privacy laws that have been recognized by the country from which the Personal Information is transferred as providing similar protections.
- Contractual safeguards - We may enter into written agreements, such as standard contractual clauses, with recipients that require them to provide the same level of protection for their Personal Information.
- Approved transfer mechanism - We may rely on other transfer mechanisms approved by authorities in the country from which the Personal Information is transferred.
7.2 EU-U.S. Data Privacy Framework with UK Extension, and Swiss-U.S. Data Privacy Framework
Mindtickle complies with the
EU-U.S. Data Privacy Framework (EU-U.S. DPF), the
UK Extension to the EU-U.S. DPF, and the
Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.
We have certified to the U.S. Department of Commerce that we adhere to:
- the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF
- the United Kingdom (and Gibraltar) under the UK Extension to the EU-U.S. DPF
- the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.
If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit
https://www.dataprivacyframework.gov/.
Mindtickle is responsible for the processing of personal data it receives, under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF and subsequently transfers to a third party acting as an agent on its behalf. We comply with the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles for all onward transfers of personal data from the EU, UK, and Switzerland, including the onward transfer liability provisions.
The Federal Trade Commission has jurisdiction over Mindtickle’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
8. Security of Personal Information
We use a variety of
technical and organizational security measures to protect your Personal Information from unauthorized access, use, alteration, disclosure, or destruction. While we are taking efforts to protect your Personal Information, it's important to note that, like any service, this may not ensure absolute immunity from potential issues such as wrongdoings, malfunctions, or misuse.
If you have a reason to believe that your information with us is no longer secure or the security of your account has been compromised, please notify us at
[email protected].
9. Your Rights as a Data Subject
Your Personal Information comes with certain rights, per applicable data protection laws, including the EU or UK General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), the Colorado Privacy Act (CPA), the Connecticut Personal Data Privacy and Online Monitoring Act (CTDPA), the Utah Consumer Privacy Act (UCPA), the Virginia Consumer Data Protection Act (VCDPA), the Nevada Privacy of Information Collected on the Internet from Consumers Act (NPICICA), the Brazilian General Data Protection Law (LGPD), the Swiss Data Protection Act (FADP), the Personal Information Protection Law of the People’s Republic of China (PIPL), the Digital Personal Data Protection Act (DPDPA) or the Canada Personal Information Protection and Electronic Documents Act (PIPEDA). Our Services generally have the option to access or rectify your Personal Information directly or through your organization’s administrator of the Services. Please find below more information about your rights as a data subject.
- Access - You can request details about the Personal Information we hold about you.
- Rectification - You can request correction or provide supplement data if you think your Personal Information is incorrect or incomplete.
- Erasure - You can request the erasure of your Personal Information from our systems.
- Withdrawal of Consent - If we process your Personal Information based on your consent (as indicated at the time of collection), you can request withdrawal of your consent.
- Data Portability - You can request a copy of your Personal Information in an industry-standard format. Additionally, you can ask us to transmit the data to another organization where technically feasible.
- Restrict Processing - You can ask us to restrict further processing of your Personal Information.
- Object to Processing - You can object to the continued use or disclosure of your Personal Information for specific purposes.
- Right to Opt-Out of Sale - You can request to opt out of the sale of Personal Information we hold about you.
If you seek more information about these rights or wish to submit a request, kindly reach out to us at
[email protected] or fill out the
Individual Rights Request Form.
10. Exercising Data Subject Rights
If you are an individual whose Personal Information who has shared Personal Information is stored in our systems, please feel free to reach out to us at
[email protected].
10.1 Request Verification
We will verify your request using the information associated with your account, including the email address. In some cases, government identification may be required.
We will forward verified requests to your organization and act as per their instructions. Consumers can also designate an authorized agent to help them fulfill data subject requests.
10.2 Timeline
We strive to complete data subject requests within 30 days. We will notify you if we require an additional time of up to 60 days to complete the request.
10.3 Exceptions to the Rights of Individuals
Mindtickle reserves the right to charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking action requested in cases where it has sufficient reasons to believe that the requests from an individual are unfounded and excessive. Further, there may be situations where we cannot fully comply with your request, such as in cases where it is frivolous, highly impractical, jeopardizes the rights of others, or is not legally required. However, even in such circumstances, we will respond to inform you of our decision.
10.4 Avoidance of Discriminatory Practices
Mindtickle acknowledges that it does not involve any practice that can be discriminatory against individuals who have exercised their rights available under data protection laws.
11. Other Important Terms
11.1 We Never Sell Personal Information
Under the California Consumers Privacy Act (CCPA) / California Privacy Rights Act (CPRA), Sale is defined as “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information by the business to another business or a third party” in exchange for “monetary” or “other valuable consideration.”
We use the information received from the Users themselves for the declared business purpose only and are not involved in any process or activity that can be termed as a “Sale” under CCPA/CPRA. We acknowledge that we have not sold Personal Information received through our Services in the preceding 12 months.
11.2 Sensitive Information
“Sensitive Personal Information” or “Special Categories of Personal Information” means Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or concerns health or a natural person’s sex life or sexual orientation, or is used for processing of genetic data, biometric data or precise geolocation data for the purpose of uniquely identifying a natural person.
In order to provide our Website, we do not require access to your Sensitive Personal Information or Special Categories of Personal Information, and you should not share such information with us.
11.3 Information About Children
Our Website is not intended for or targeted at children (as per the age defined under relevant laws. e.g., 18 years, 16 years, 13 years, etc.), and we do not knowingly or intentionally collect information about children. If you believe that we have collected Personal Information about a child, please contact us at
[email protected] so that we can delete the Personal Information.
11.4 Your Consent
By using our Services, you consent to our collection and use of your Personal Information as described in this Privacy Policy. Additionally, we may store and process your Personal Information in various facilities throughout the globe, including in data centers operated and maintained by cloud-based service providers. If you are a resident in a jurisdiction where the transfer of your Personal Information to another jurisdiction requires your consent, then it is hereby understood that you provide us your consent to such transfer.
11.5 Automated Decision-Making
We do not encourage the use of information provided or generated by our Services to perform automated decision-making.
11.6 Unsubscribing From Our Communications
You may unsubscribe from our marketing communication by clicking on the “unsubscribe” link located at the bottom of our emails or by sending us an email at
[email protected]. You cannot opt out of receiving transactional emails and notifications related to the Services subscribed through our Customers. You may reach out to your organization to configure the email and notification preferences in the Services.
11.7 Changes to this Privacy Policy
We annually review this Privacy Policy and may update it from time to time to reflect our ongoing commitments. If we make any material change to our existing privacy commitments, we will send a notification as per the communication details provided in the contractual agreement signed with our Customers. The “Last Updated” legend at the top of this page indicates when this Privacy Policy was last revised. Your continued use of our Services will be subject to the terms of the then Privacy Policy.
12. Questions, Concerns, or Complaints
If you have any questions about this Privacy Policy or our processing of the Personal Information you provide us, please write to us using the below information:
MindTickle, Inc.
Attn: Data Privacy Officer
535 Mission St, 14th Floor, San Francisco
California 94105, United States of America
or
MindTickle Interactive Media Pvt. Ltd.
Attn: Data Privacy Officer or Grievance Officer
4th Floor, Solitaire World, Baner,
Pune, Maharashtra 411045, India
You can reach out to us at
[email protected].
13. Dispute Resolution Authority
If you have an unresolved privacy or data use concern, not received timely acknowledgment of your DPF Principles-related complaint from us or we have not addressed your DPF Principles-related complaint to your satisfaction, please visit
https://feedback-form.truste.com/watchdog/request for more information or to file a complaint (free of charge) with TRUSTe, an alternative dispute resolution provider based in the United States.
For complaints regarding EU-U.S. DPF, the UK Extension to the EU-U.S DPF, and Swiss-U.S. DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website:
https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.
Job Applicants Privacy Policy
Last Updated: November 1, 2023
MindTickle, Inc. and MindTickle Interactive Media Pvt. Ltd. (collectively referred to as “Mindtickle,” “us,” “we,” or “our”) respect your privacy and are committed to protecting your Personal Information. This Privacy Policy outlines the manner in which Mindtickle gathers, utilizes, transfers, safeguards, stores, maintains, or otherwise manages the Personal Information of individuals (“You”) collected from your job application, résumé, curriculum vitae or via other sources throughout the recruitment process. It also describes the rights accessible to you as a data subject under applicable data protection laws and the procedures governing our response to such requests.
By choosing to apply for a job at Mindtickle and appearing for the hiring process, you accept and agree to the practices described in this Privacy Notice. We highly recommend you regularly review this Privacy Policy to stay informed about any updates or modifications we may make.
You can request a copy of this Privacy Policy by contacting us at [email protected].
1. Personal Information
Personal Information refers to any information related to an identified or identifiable natural person. This information may include name, phone number, email ID, address, etc.
If you submit any Personal Information relating to other people to us, such as their names and email addresses, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
2. Categories of Personal Information
The following table details the categories of Personal Information that we collect and have collected over the past 12 months from you, either directly or through other sources. For each category of Personal Information, we have also set out the source for collection and the categories of third parties with whom we share the Personal Information.
| Category of Personal Information | Examples of Personal Information Collected | Source | Third Parties With Whom We Share Data For Business Purposes |
| Identifiers | | - Information shared with Mindtickle over an email (e.g., [email protected])
- Information submitted through third-party job portals such as Lever, LinkedIn, Naukari, etc.
- Information shared by our sourcing partners and recruiting agencies
- Information shared by colleges and universities during campus hiring
- Information of candidates referred by Mindtickle employees
- Video or audio conversation during the screening and interview process
- Social media profiles voluntarily shared as part of job application
- Information generated by competency assessment tool based on responses submitted by candidates
| We may share the collected information with the following categories of third parties: - Recruitment process management provider
- Knowledge competency and assessment tool
- New hire joining kit delivery partner
- Human resource management system
- Background verification service provider
|
| Professional, employment-related, or educational information | - Job title
- Company name
- Employment history
- Professional certifications
- Professional references
- Educational qualification
|
| Geolocation information | |
| Audio, electronic, visual, and similar information | - Profile picture
- Interview audio and video recordings
|
| Financial information | - Current and desired salary
- Terms relating to compensation and benefits packages
|
| Information we collect or generate during the recruitment process | - Interview notes
- Assessment scores
- Correspondence data
|
3. Sources of Personal Information
We may collect Personal Information directly from you or through other sources. The information we gather is required to facilitate recruitment and ensure compliance with our legal responsibilities.
Mindtickle provides notice in clear and conspicuous language at the time of collecting Personal Information to help you provide informed consent.
We collect Personal Information about you through the below-mentioned sources:
3.1 Job Applicaton, Résumé or Curriculum Vitae
We may collect your Personal Information, which is a part of the job application, résumé, and curriculum vitae that we receive directly from you or through other sources such as third-party job portals, our sourcing partners and recruiting agencies, referrals by employees or colleges and universities during campus hiring.
3.2 Interview Process
We may collect Personal Information about you during the application review and interview process. This may include information obtained when you appear for interviews over the phone or through video conference tools.
3.3 Competency Assessment Tool
As a part of our recruitment process, we may ask you to appear for assessments, for which we may utilize third-party tools. We do not perform automated decision-making based on assessment-generated or any other information.
3.4 Social Media Profiles
Mindtickle may also capture additional professional Personal Information from your social media profiles, such as LinkedIn, GitHub, Twitter, etc., that you may voluntarily provide as a part of the job application.
4. Use of Personal Information
Mindtickle uses the collected Personal Information for the recruitment process and other purposes listed below:
- assessing your suitability for the job position
- creating and maintaining your profile in our internal systems
- reaching out to discuss the role, respond to inquiries, and communicate with you about your application
- contacting you with future communications and updates about other suitable opportunities at Mindtickle
- requesting feedback for enhancing our application and recruitment procedures
- verifying the information shared as a part of the job application and conducting background/reference checks
- as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
5. Sharing of Personal Information
Your Personal Information may be shared with third parties as permitted under data protection laws and this Privacy Policy.
5.1 Recruitment process management provider
Mindtickle uses and may disclose Personal Information with recruitment process management providers to review your job application and complete the recruitment process.
5.2 Knowledge competency and assessment tool
During the recruitment process, we may use a third-party assessment tool. To provide you access to the third-party assessment platform, we may be required to share your Personal Information with the third party.
5.3 New hire joining kit delivery partner
Prior to the date of joining, Mindtickle may share your Personal Information with third parties for the delivery of the new hire joining kit.
5.4 Human Resource Management System
As per country-specific requirements, we may ask you to share your Personal Information on our human resource management system. We would require this information to create your profile and capture the data necessary for handling post-joining activities.
5.5 Background Verification Service Provider
Mindtickle may share your Personal Information with background verification service providers for the purposes of the verification/background checks.
5.6 Business Transfers
If Mindtickle is a party to a merger or acquisition by another company, or its assets are entirely or partially acquired, Users’ Personal Information may be among the assets transferred. Mindtickle may disclose Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). In this event, you will be notified via email or a prominent notice on our website of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
5.7 Compelled Disclosure
We may be required to disclose Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. We reserve the right to use or disclose your Personal Information if required by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
We have not received any request for disclosure of Personal Information from the government or law enforcement agencies in the past 12 months. For more details, please refer to our Transparency Report.
6. Retention of Personal Information
We may retain collected Personal Information for a period of fulfilling the purposes outlined in this Privacy Policy or as needed to comply with our legal obligations to resolve disputes unless we are required to delete this information by law or court order.
For clarity, if your initial job application is unsuccessful, we may keep your Personal Information on record for two years from the last application date. The Personal information will only be retained with your permission. This will enable us to reach out to you regarding other potentially fitting opportunities in the future.
Please note that we may need to retain certain information provided as part of a data subject request for compliance recordkeeping purposes or to have proof and evidence concerning our relationship should any legal issues arise.
7. Transfer of Personal Information
By disclosing your Personal Information to us, you consent to the transfer of your Personal Information to countries outside of your country of residence, which may have different data protection laws than those of your country or the country in which you were located when you initially provided the Personal Information.
7.1 Data Transfer Mechanism
Your Personal Information may be stored and processed in any country where our service providers have data storage facilities. When we do, we will ensure that an adequate level of protection is provided for the Personal Information by using one or more of the following approaches:
- Similar data protection laws - We may transfer Personal Information to countries that have privacy laws that have been recognized by the country from which the Personal Information is transferred as providing similar protections.
- Contractual safeguards - We may enter into written agreements, such as standard contractual clauses, with recipients that require them to provide the same level of protection for their Personal Information.
- Approved transfer mechanism - We may rely on other transfer mechanisms approved by authorities in the country from which the Personal Information is transferred.
7.2 EU-U.S. Data Privacy Framework with UK Extension, and Swiss-U.S. Data Privacy Framework
Mindtickle complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.
We have certified to the U.S. Department of Commerce that we adhere to:
- the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF
- the United Kingdom (and Gibraltar) under the UK Extension to the EU-U.S. DPF
- the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.
If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
Mindtickle is responsible for the processing of personal data it receives, under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF and subsequently transfers to a third party acting as an agent on its behalf. We comply with the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles for all onward transfers of personal data from the EU, UK, and Switzerland, including the onward transfer liability provisions.
The Federal Trade Commission has jurisdiction over Mindtickle’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
8. Security of Personal Information
We use and ensure our service providers implement a variety of technical and organizational security measures to protect your Personal Information from unauthorized access, use, alteration, disclosure, or destruction. While we are taking efforts to protect your Personal Information, it's important to note that, like any service, this may not ensure absolute immunity from potential issues such as wrongdoings, malfunctions, or misuse.
If you have a reason to believe that your information with us is no longer secure or the security of your account has been compromised, please notify us at [email protected].
9. Your Rights as a Data Subject
Your Personal Information comes with certain rights, per applicable data protection laws, including the EU or UK General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), the Colorado Privacy Act (CPA), the Connecticut Personal Data Privacy and Online Monitoring Act (CTDPA), the Utah Consumer Privacy Act (UCPA), the Virginia Consumer Data Protection Act (VCDPA), the Nevada Privacy of Information Collected on the Internet from Consumers Act (NPICICA), the Brazilian General Data Protection Law (LGPD), the Swiss Data Protection Act (FADP), the Personal Information Protection Law of the People’s Republic of China (PIPL), the Digital Personal Data Protection Act (DPDPA) or the Canada Personal Information Protection and Electronic Documents Act (PIPEDA). Please find more information about your rights below.
- Access - You can request details about the Personal Information we hold about you.
- Rectification - You can request correction or provide supplement data if you think your Personal Information is incorrect or incomplete.
- Erasure - You can request the erasure of your Personal Information from our systems.
- Withdrawal of Consent - If we process your Personal Information based on your consent (as indicated at the time of collection), you can request withdrawal of your consent.
- Data Portability - You can request a copy of your Personal Information in an industry-standard format. Additionally, you can ask us to transmit the data to another organization where technically feasible.
- Restrict Processing - You can ask us to restrict further processing of your Personal Information.
- Object to Processing - You can object to the continued use or disclosure of your Personal Information for specific purposes.
- Right to Opt-Out of Sale - You can request to opt out of the sale of Personal Information we hold about you.
If you seek more information about these rights or wish to submit a request, kindly contact us at [email protected] or fill out the Individual Rights Request Form.
10. Exercising Data Subject Rights
If you are an individual whose Personal Information has been shared and stored in our systems, please feel free to contact us at [email protected].
10.1 Request Verification
We will verify your request using the information associated with your account, including the email address. In some cases, government identification may be required.
10.2 Timeline
We strive to complete data subject requests within 30 days. We will notify you if we require an additional time of up to 60 days to complete the request.
10.3 Exceptions to the Rights of Individuals
Mindtickle reserves the right to charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking action requested in cases where it has sufficient reasons to believe that the requests from an individual are unfounded and excessive. Further, there may be situations where we cannot fully comply with your request, such as in cases where it is frivolous, highly impractical, jeopardizes the rights of others, or is not legally required. However, even in such circumstances, we will respond to inform you of our decision.
10.4 Avoidance of Discriminatory Practices
Mindtickle acknowledges that it does not involve any practice that can be discriminatory against individuals who have exercised their rights available under data protection laws.
11. Other Important Terms
11.1 We Never Sell Personal Information
Under the California Consumers Privacy Act (CCPA) / California Privacy Rights Act (CPRA), Sale is defined as “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information by the business to another business or a third party” in exchange for “monetary” or “other valuable consideration.”
We use the information received for the declared business purpose only and are not involved in any process or activity that can be termed as a “Sale” under CCPA/CPRA. We acknowledge that we have not sold Personal Information received through our Website in the preceding 12 months.
11.2 Sensitive Information
“Sensitive Personal Information” or “Special Categories of Personal Information” means Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or concerns health or a natural person’s sex life or sexual orientation, or is used for processing of genetic data, biometric data or precise geolocation data for the purpose of uniquely identifying a natural person.
We do not require you to submit any Sensitive Personal Information as part of your job application, and you should not share such information with us.
11.3 Information About Children
We strictly prohibit the employment of children (as per the age defined under relevant laws. e.g., 18 years, 16 years, 13 years, etc.), and we do not knowingly or intentionally collect information about children. If you believe that we have collected Personal Information about a child, please contact us at [email protected] so that we can delete the Personal Information.
11.4 Your Consent
By applying for a position at Mindtickle and continuing interest in the recruitment process, you consent to our collection and use of your Personal Information as described in this Privacy Policy. Additionally, we may store and process your Personal Information in various facilities throughout the globe, including in data centers operated and maintained by our Service Providers. If you are a resident in a jurisdiction where the transfer of your Personal Information to another jurisdiction requires your consent, then it is hereby understood that you provide us your consent to such transfer.
11.5 Automated Decision-Making
We do not use Personal Information provided to us to perform automated decision-making.
11.6 Changes to this Privacy Policy
We annually review this Privacy Policy and may update it from time to time to reflect our ongoing commitments. The “Last Updated” legend at the top of this page indicates when this Privacy Policy was last revised. Your continued interest in applying for a job and continuing the screening process will be subject to the terms of the then Privacy Policy.
12. Questions, Concerns, or Complaints
If you have any questions about this Privacy Policy or our processing of the Personal Information you provide us, please write to us using the below information:
MindTickle, Inc.
Attn: Data Privacy Officer
535 Mission St, 14th Floor, San Francisco
California 94105, United States of America
or
MindTickle Interactive Media Pvt. Ltd.
Attn: Data Privacy Officer or Grievance Officer
4th Floor, Solitaire World, Baner,
Pune, Maharashtra 411045, India
You can reach out to us at [email protected].
13. Dispute Resolution Authority
If you have an unresolved privacy or data use concern, not received timely acknowledgment of your DPF Principles-related complaint from us or we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint (free of charge) with TRUSTe, an alternative dispute resolution provider based in the United States.
For complaints regarding EU-U.S. DPF, the UK Extension to the EU-U.S DPF, and Swiss-U.S. DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.
