Last Updated: January 10, 2023
A reference to “Majesco,” “we,” “us” or the “Company” is a reference to Majesco and its relevant affiliates involved in the collection, use, sharing, or other processing of Personal Data.
- Responsible Entity
- Processing Activities
- What Types of Personal Information Do We Collect?
- How Do We Use Personal Information?
- How Do We Share Personal Information?
- How Do We Respond to ‘Do Not Track’ Signals?
- How Do We Protect Your Information?
- Your Privacy Choices
- U.S. State Disclosures
- EEA, Swiss, and UK Disclosures
- How to Exercise Your Rights
- Your Rights Relating to Customer Data
- Marketing Communications
- California Consumer Privacy Act (CCPA) Employee and Applicant Privacy Notice
- International Transfers of Data
- Children’s Privacy
- How Long Do We Keep Your Personal Data?
- Change of Control
- Policy Changes
- Contact Information
1. Responsible Entity
2. Processing Activities Covered
- Visit our branded social media pages;
- Attend our conferences or other events;
- Receive communications from us, including emails, phone calls, texts or fax;
- Use our software products and services as an authorized user where we act as a controller of your Personal Data; and,
- Apply for employment opportunities with us.
Our websites and services may contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any data to these websites.
3. What Types of Personal Information Do We Collect?
Information You Give Us. We collect a variety of information that you provide directly to us, including information submitted on our website forms and login pages. You may also provide more general information, such as information about your industry, business or profession, and your credit card type. By providing this information, you have informed us that you have an interest in the research, insights, and/or other information we have on the market, or that you are interested in hearing from us. We may collect the following categories of information from you:
- Contact information, such as name, email, phone number, country, job title, and role, when you subscribe to our newsletters, register for our webinars and conferences, request information from our website, or request other services from us;
- Commercial information, such as records of products or services purchased from us;
- Financial information, such as credit card information, when you purchase services online;
- Internet or other electronic network activity information, such as information regarding your usage and interaction with our online platform services; and/or,
- Professional, employment, or education information, such as your resume and CV, if you apply to work with us.
Information We Automatically Collect. Majesco may use server log analysis tools to gather and analyze information regarding use of the websites and the visitor’s experience, such as (for example and not limitation) the number of hits received, the website’s most/least visited pages, how our visitors use the website, the website’s most/least used functions, errors experienced by users, processes completed or abandoned by users, and browsers and platforms used to connect to the website. The following are examples of information about your visit that is, or may be, collected for this purpose: IP address, physical location, type of browser and/or operating system, internet service provider (ISP) and/or mobile phone carrier, the date and time you visited the website, websites you visited before and after the Majesco websites, the pages you visited and the order in which you navigated the websites, the action you performed or tried to perform (e.g., perform a search, enter information, publish information or generate a report), and codes that correspond to the status of your action (e.g., successful request, data not found, etc.).
The above information belongs to Majesco and Majesco and certain of its suppliers may use it to improve the content, layout and/or operation of the websites, and to serve you content we believe most relevant to you. We may release this information in the aggregate, for example, by sharing it with our partners or authorized service providers, or by publishing a report on the usage of the Websites. This information is not used in a form that would enable direct identification of any of our visitors.
Information We Collect From Third Parties. From time to time, we may obtain information about you from third-party sources, such as public databases, corporate directories, public profiles on social media platforms, and information derived from these sources from third-party data providers.
4. How Do We Use and Share Personal Information?
Majesco uses your personal information as follows:
- Promoting the security of our websites and services: We process your Personal Data by tracking use of our websites and services, creating aggregated non-personal data, verifying accounts and activity, investigating suspicious activity, and enforcing our terms and policies to the extent it is necessary for promoting the safety and security of the services, systems and applications;
- Managing user registrations: If you have registered for an account with us, we process your Personal Data by managing your user account for the purpose of performing our contract with you according to applicable terms of service;
- Handling contact and user support requests: If you fill out a web form or request user support, or if you contact us by other means including via a phone call, we process your Personal Data to perform our contract with you and to the extent it is necessary for fulfilling your requests and communicating with you;
- Event registration: If you have registered for an event with us, we process your Personal Data for the purposes of event registration and event management;
- Managing payments: If you have provided financial information to us, we process your Personal Data to verify that information and to collect payments to the extent that doing so is necessary to complete a transaction and perform our contract with you;
- Developing and improving our websites and services: We process your Personal Data to analyze trends and to track your usage of and interactions with our websites and services to the extent it is necessary for developing and improving our websites and services and providing our users with more relevant content and service offerings;
- Assessing and improving user experience: We process device and usage data, which in some cases may be associated with your Personal Data, to analyze trends and assess and improve the overall user experience to the extent it is necessary for developing and improving the service offering;
- Identifying customer opportunities: We process your Personal Data to assess new potential customer opportunities to ensure that we are meeting the demands of our customers and their users’ experiences;
- Recording phone calls: We may record phone calls for training, quality assurance, and administration purposes. If required under applicable law, we will obtain your prior consent or give you the option to object to a call being recorded;
- Sending marketing communications: We will process your Personal Data or device and usage data, which in some cases may be associated with your Personal Data, to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, white papers) about us and our affiliates and partners, including information about our products or promotions (please see the “Your rights relating to your Personal Data” section below, to learn how you can control the processing of your Personal Data by Majesco for marketing purposes); and,
- Complying with legal obligations: We process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws, to protect against misuse or abuse of our websites, protect personal property or safety, pursue remedies available to us, and limit our damages, comply with judicial proceedings, court orders or legal processes, respond to lawful requests, or for auditing purposes.
If we need to collect and process Personal Data by law, or under a contract we have entered into with you, and you fail to provide the required Personal Data when requested, we may not be able to perform our contract with you.
5. How Do We Share Personal Information?
Third Party Links and Websites. Our website may contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any data to these websites.
Professional Advisers. In individual instances, we may share your Personal Data with professional advisers acting as service providers, processors, or joint controllers, including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services.
Third Parties Involved in a Corporate Transaction. We may share your Personal Data if we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by a third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Data to an unaffiliated third party.
Aggregate Data. We may share such anonymous or de-identified usage data on an aggregate basis in the normal course of operating our business; for example, we may share information publicly to show trends about the general use of our services.
Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your personal information in order to comply with any legal obligation, to enforce or apply our terms and conditions and other agreements, to protect our rights, property, or safety, or the protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
6. How Do We Respond to ‘Do Not Track’ Signals?
DNT is a privacy preference you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For all the details, including how to turn on Do Not Track, visit www.donottrack.us. We recognize and respond to browser-initiated DNT signals.
7. How Do We Protect Your Information?
Majesco uses reasonable security procedures and technical and organizational measures to protect your personal information. We adhere to the International Organization for Standardization (ISO) 27001. We restrict access to personal information to Majesco affiliates, employees, contractors, business partners and agents who need to know that information to operate, develop or improve our services. These individuals are bound by confidentiality obligations.
However, no website, application, or transmission can guarantee security. Thus, while we have established and maintain what we believe to be reasonable procedures to protect the confidentiality, security, and integrity of personal information obtained through the websites, we cannot ensure or warrant the security of any information you transmit to us.
8. Your Privacy Choices
- Access your Personal Data held by us;
- Know more about how we process your Personal Data;
- Erase or delete your Personal Data, to the extent permitted by applicable data protection laws;
- Correct inaccurate Personal Data we maintain about you;
- Restrict our processing of your Personal Data, to the extent permitted by law;
- Object to our processing of your Personal Data. Where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
- Opt-out of certain disclosures of your Personal Data to third parties;
- Limit the use and disclosure of your sensitive Personal Data; and,
- Not be discriminated against for exercising your rights described above.
You may have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:
- U.S. State Disclosures
We have listed the privacy rights for several U.S. state jurisdictions below, but we understand you may have additional rights in your jurisdiction. You may contact us directly at any time about exercising your data protection rights. We will consider your request in accordance with applicable laws.Certain state laws require that we detail the categories of Personal Data that we disclose for certain “business purposes,” such as to service providers that assist us with securing our services or marketing our products.
We disclose the following categories of Personal Data for our business purposes:
- Personal information under California Civil Code section 1798.80;
- Commercial information;
- Internet activity information;
- Visual information;
- Professional or employment-related information; and
- Inferences drawn from any of the above information categories.
Sensitive Categories of Personal Data:
- Account log-in information; and
- Financial account information.
Several jurisdictions grant state residents certain rights, including the right to access specific types of Personal Data, the right to learn how we process Personal Data, the right to correct inaccurate Personal Data, the right to know whether and how we disclose or sell Personal Data, the right to opt out of any sale of Personal Data, the right to request deletion of Personal Data in certain circumstances, the right to limit the use of your sensitive Personal Data, and the right not to be denied goods or services for exercising these rights.
Third Party Marketing. California law further permits you to request information regarding the disclosure of your personal information to third parties for the third parties’ direct marketing purposes. We do not disclose your personal information to third parties for the third parties’ direct marketing purposes.
Limit the Use of My Sensitive Personal Information. We do not use or disclose sensitive personal information for any purpose other than providing our goods and services to you, or as otherwise permitted under applicable law.
Authorized Agents. If you are an authorized agent wishing to exercise rights on behalf of a state resident, please contact us using the information in the “Contact us” section below and provide us with a copy of the consumer’s written authorization designating you as their agent. We may need to verify your identity and place of residence before completing your rights request.
- EEA, Swiss, and U.K. Disclosures
Our legal bases for collecting and using your Personal Data include:
- The performance of your contract or to enter into the contract and to take action on your requests. For example, the processing of your account registration, providing our services and products to you, providing customer service to you.
- Our legitimate business interests. For example, fraud prevention, maintaining the security of our network and services, direct marketing to you, and maintaining, analyzing, and improving our products and services.
- Compliance with a mandatory legal obligation. For example, maintaining administrative records which are subject to mandatory retention periods. We may also collect your Personal Data to record your requests to exercise your rights and to verify your identity for such requests.
- Consent you provide where we do not rely on another legal basis. Consent may be withdrawn at any time.
In some countries, and in particular if you are located in the EEA, you may have the right to:
- Access your personal information;
- Correct inaccurate personal information;
- Request erasure of your personal information without undue delay;
- Request the restricted processing of your personal information;
- Request portability of the personal information that you have given us; and,
- To object to the processing of your personal information.
To exercise any of these rights, please contact us as set forth in the “Contact Us” section below and specify which privacy right(s) you wish to exercise. We may need to verify your identity in order to honor your request. If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority. We would, however, appreciate the opportunity to first address your concerns and would welcome you directing an inquiry first to us per the “Contact us” section below. You may also contact our Data Protection Officer (“DPO”) at any time at Tom.Murray@Majesco.com
- How to Exercise Your Rights
To exercise your rights, please contact us by using the information in the “Contact us” section below. Your personal data may be processed in responding to these rights. We will respond to all legitimate requests in a timely manner and in accordance with applicable laws, and will contact you if we need additional information from you in order to honor your request or verify your identity.
- Your Rights Relating to Customer Data
- Marketing Communications
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all of these communications from us by following the unsubscribe instructions provided in any email we send, or you can contact us using the contact details provided in the “Contact Us” section below. You will still continue to receive service-related messages concerning products and services you have purchased (unless we have indicated otherwise).
9. California Consumer Privacy Act (CCPA) Employee and Applicant Privacy Notice
This Privacy Notice for California Employees (the “Notice”) applies solely to all job applicants, employees, owners, directors, officers, and contractors (collectively referred to in this Notice as “employees”) who reside in the State of California (“you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice.
We are committed to protecting the privacy and security of the information we collect and to being transparent about the purposes for which we use your information. This Notice sets forth our policies and practices for handling the information we collect and use in the employment context.
- Categories of Personal Information We Collect
When a person applies to join our team or over the course of a person’s employment, we may collect the following categories of personal information. We collect and use this information only as permitted or required by, and in compliance with, law.
- Contact Information, including name, alias and other names, email address, telephone or mobile phone number, address, Social Security Number, driver’s license number or state ID card number, passport number, and other unique personal identifiers associated with you or other beneficiaries such as your spouse or child;
- Sign-In and Device Information, including username and password, account name or number, and other online or device identifiers, Internet or other electronic network activity information such as browsing and search history and information regarding interactions with websites and applications, our systems, and networks;
- Educational, Professional, and Employment-Related Information, including employment, employment and education history, professional licenses, marital or domestic partner status, date of birth, age, gender, classifications protected under state or federal Equal Employment Opportunity laws (such as race or national origin), medical condition or information, and health insurance information and policy number;
- Location Information, including office address and service location (such as city, state, and/or country)
- Financial Information, including bank account, billing address, and information about your income and account balances.
- Categories of Sensitive Personal Information We Collect
In addition, where relevant to the recruitment and employment process, including where necessary to accommodate any disability needs, achieve diversity initiatives, or to comply with some regulatory requirements, we may also have the need to process sensitive personal information. This may include:
- social security, driver’s license, state identification card, or passport number;
- account log-In, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
- precise geolocation;
- racial or ethnic origin, religious or philosophical beliefs, or union membership;
- the contents of mall, email and text messages;
- genetic data;
- biometric information for the purpose of uniquely identifying a consumer;
- health information;
- sex life or sexual orientation information.
- Purposes for Which Personal Information Is Used
We process your personal information for the following business purposes:
- Determining your eligibility for a position with the company, including processing your application, assessing your fit with us or for a specific role, conducting interviews, carrying out background and reference checks in accordance with law, and keeping records related to our hiring process;
- Managing compensation, benefits, and employment-related expenses, including payroll processing, managing salaries and expenses, managing corporate credit cards and expense reimbursements, as well as administering equity, compensation, bonus, and insurance programs;
- Managing professional development, performance, and conduct, including responding to complaints of misconduct, managing conflicts of interest, conducting performance appraisals, supporting career development, and managing whistleblower programs;
- Protecting the company against illegal activity and other misconduct, including by detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
- Undertaking activities to verify and maintain the quality, safety, and performance of our products and services, including product and service testing, research, and development;
- Complying with our legal obligations, including those related to tax and anti-discrimination laws; and
- Other routine business purposes.
- How We Share Your Information
We disclose personal information for purposes set out in this Notice, as explicitly consented to by you or as legally justified. We do not sell your personal information. We may disclose personal information to:
- Our parent company or other affiliates;
- Vendors or service providers who perform services on our behalf, such as payroll processing, pension services, or workforce analytics services;
- Any recipient, if required to comply with the law or protect us or our employees;
- Any recipient, when reasonably necessary, such as in the event of a life-threatening emergency;
- A newly formed or acquiring organization if we are involved in a merger, sale or a transfer of some or all of its business;
- Any recipient, as permitted by law.
- Your Privacy Rights
You have the following privacy rights:
- The right to know what personal information is being collected about you.
- The right to know whether your personal information is sold or disclosed and to whom.
- The right to say no to the sale of personal information or to limit use or disclosure of sensitive personal information to that which is necessary.
- The right to access your personal information twice in a 12-month period.
- The right to correct your personal information.
- The right, in certain circumstances, to delete the information you have provided to us, when the information is no longer necessary for the purpose it was collected or is unlawfully processed. You may also request erasure when you withdraw consent or object to the processing of your information. Even if the request is approved, we may retain your personal information to comply with our legal obligations.
- The right to be free from discrimination or retaliation, if you exercise your privacy rights.
- We may need to verify your identity to process your privacy requests, and we will notify you if we are unable to process your requests due to our legal obligations. To exercise your privacy rights, please contact us at Privacy@Majesco.com.
- Retention of Personal Information
We retain your personal information for as long as it is necessary or relevant for the practices described in this Notice. We also keep information as otherwise required or permitted by law.
- Contact Information & Updates
We may update this Notice from time to time, in which case the revised Notice will be posted to our intranet or provided to you in writing, by email, or mail. If you have any questions or comments about this Notice and the ways in which Company collects and uses your information as described above, please do not hesitate to contact us through the HR Department at Privacy@Majesco.com
10. International Transfers of Data
Any data that you provide to us may be accessed, shared or processed by our offices, located in India, the United States, and abroad, and service providers located in India, the United States, and abroad, if such data transfer is necessary for the specific purpose for which you submitted your data (such as the provision of goods or services under a written contract) and the recipient ensures the same level of data protection that is adhered to by Majesco. This may entail a transfer of your personal information across international borders, including, but not limited to, transfers from within the European Economic Area (the “EEA”) to India or the United States. The data protections standards may differ and be lower than the standards enforced in your jurisdiction. We maintain appropriate safeguards as required by applicable law for any personal information transferred internationally, and as required by applicable law, will seek your consent prior to such transfers.
11. Children’s Privacy
This website is not directed at individuals under the age of 16. We do not knowingly collect personal information from children under 16. If you become aware that a child has provided us with personal information, please contact us using the contact information below. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information.
12. How Long Do We Keep Your Personal Data?
We may retain your Personal Data for a period of time consistent with the original purpose of collection (see the “Purposes for which we process Personal Data” section above) or as long as required to fulfill our legal obligations. We determine the appropriate retention period for Personal Data on the basis of the amount, nature, and sensitivity of the Personal Data being processed, the potential risk of harm from unauthorized use or disclosure of the Personal Data, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).
After expiry of the applicable retention periods, your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of or access to such data.
For more information on data retention periods, please contact us by using the information in the “Contact us” section, below.
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14. Change of Control
Personal information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other change in control. If Majesco sells, merges or transfers any part of the business, part of the sale may include your personal information.
15. Policy Changes
16. Contact Information
Morristown, NJ 07960
For EEA residents:
Tom Murray, Data Protection Officer
Unit 5A Sandyford Business Centre
Sandyford, Dublin 18, D18 X383