Privacy Policy

Effective Date: 20th July 2022

1. INTRODUCTION

Springrole India Pvt. Limited (hereinafter referred to as “Us”“We” or “Our”) has issued this Data Protection and Privacy Policy (hereinafter “Policy”) for its product SpringVerify. This page informs you about our policies regarding the collection, use, and disclosure of Personal Information that we receive from the users of SpringVerify and related (“Platform”). Please read the entire Policy carefully, as it forms a contract between Customer or Candidate and Us depending on the context and usage of Services.

This policy will apply when you use SpringVerify and related services as a Customer or as a Candidate.

By using SpringVerify and related services and Platform you agree to the collection and use of information in accordance with this policy. If you are in any doubt regarding the applicable standards or have any comments or questions about this Policy, please contact us at the contact details provided under this Policy.

You reserve various rights and standards with respect to your data usage and processing when you use SpringVerify, and the same has been enumerated in this policy. You reserve the choice to exercise these rights. However, you understand that while exercising some of the rights under this policy, you may restrict the processing of information that is necessary to provide you the services in part or in whole.

2. APPLICABILITY

This policy applies to:
1. all the Customers who opt and pay for background verification services that are available on the SpringVerify platform.
2. all the Candidates upon whom the background verification/check is carried out.
3. all such persons who visit the SpringVerify website.

3. THE INFORMATION WE COLLECT

We require different kinds of information depending on the services requested by the Customer to carry out the background verification/check. This information will identify you as an individual and hence can be classified as (“Personal Information”). Depending on the kind of background verification requested by the Customer, we may collect the following information including:

1. Personal identifier information such as name, date of birth, phone number, email address, residential address, and applicable government-issued identification documents (such as Aadhar, PAN, Voter ID, Driving Licence, Passport, etc.). In addition, for address verification, we may also collect other government-issued documents such as (ration card, vehicle registration certificates) or documents like rental agreements, bank statements, utility bills, or any other document that proves your address.

2. Professional information such as your previous employer’s details, roles, employee records, previous salary details, benefits, and so on. To verify this information we may ask you to provide relevant documents including salary slips, experience certificates, relieving letters, appointment letter, etc. In some cases, if requested by the Customer, we will also conduct a Professional reference check on the Candidate, where the professional references provided by the candidate are contacted to confirm details regarding the professional capabilities and qualifications.

3. Education information such as details about your university, course, department, and other related information. To verify your education background we may the Candidate to produce the degree certificate, consolidated marksheet(s), or any other similar document in order to carry out and verify your educational qualification.

4. Criminal background history including any pending criminal complaints or any such related history. We may also verify Court records (both civil and criminal) to determine if there are any cases pending against the Candidate. All the information will be collected from the records provided by the Department of Justice. In cases, where requested by the Customer, we may also run a Global Database check to determine if the Candidate is directly or indirectly associated with any serious and organized crimes, and is listed in the databases of Regulatory, Compliance, Debarment, PEP, and Financial Sanctions authorities globally.

5. Credit information including your credit score and credit history from the relevant databases like CIBIL based on your PAN information.

6. Sensitive personal information depending on the kind and nature of the check requested by the Customer. However, in case the Customer requests a check that requires accessing any kind of sensitive personal information, the same will be communicated to the Candidate including the relevant information about the nature and the kind of sensitive personal that will be taken for such checks. Specific consent will be taken for the collection of such information. This information may also include medical information about the Candidate.

In addition to the above, from the Customers, we may collect the following information including:

1. Signup Information for Services:
When you sign up for our services, we may collect your (i) Name: first name and last name, (ii) Contact information including email address and telephone numbers, (iii) User names (accounts alias) and passwords according to the product specifications to allow users to login and use the product, (iv) Company/Organization name, (v) Company/Organization address.

2. Billing and Payment information:
When you subscribe to our services we would collect your billing information like Credit Card number, Debit card number, billing address, and other such information to facilitate transactions between you and us.

3. Usage Information:
To facilitate a better experience, we may also collect certain Data about the usage of our services, including (i) Time zone and date/time preferences for product usage, (ii) IT information required to provide access to systems and networks such as IP addresses, log files and login information, encryption generation keys, (iii) Information pertinent to fulfilling business transactions on a customer’s behalf, such as files uploaded by a user to a product to be processed by the application’s functionality, system-generated emails, (iv) Meta Data, such as logs, for usage information and activity logs, with identifying characteristics such as creator or author of a transaction, names of individuals who have accessed or downloaded file(s), the time file(s) were accessed or downloaded, IP addresses of users.

4. Analytics Information:
We may collect certain information from the analytics tools like Google Analytics. Furthermore, we may also analyze the data collected from the feedback shared by the candidates during their BGV process. Furthermore, our websites may collect some analytics data, when you visit the same.

5. Cookies:
Cookies are small data files that are placed on your computer or mobile device when you visit a website, mobile app, or use an online platform. Cookies are widely used by online service providers to facilitate and help to make the interaction between users and websites, mobile apps, and online platforms faster and easier, as well as to provide reporting information.SpringVerify and its Vendors may collect some cookies to make our platform faster or for analytics purposes. Collecting cookies helps us make our platform faster and identify returning business customers.

Most browsers allow you to turn off cookies or to receive a warning before a cookie is stored on your hard drive.

6. HOW DO WE COLLECT YOUR INFORMATION

1. Information that is provided to Us
SpringVerify collects information either directly when both the Customer or the Candidate directly submit to Us via our Platform, email, or any other such information required to produce a background check report. Such information may also include personal information like name, email address, or any other general information to carry out our services.

2. Third Party Information
To provide certain services and to produce relevant background check reports we may collect information from third parties with proper
authorization. Third-party sources may include both private and public records as mentioned below:

(a). Public Records: SpringVerify may collect information from public records such as government databases, Court records, global databases, law enforcement agencies, or any other publically available records. 

(b). Private Records: With proper consent from the relevant stakeholders, SpringVerify may collect private records from educational institutions, employers, healthcare providers, and credit bureaus/agencies. 

3. Automatically collected Information
When Customers, Candidates, or any other person visits our website or uses our services on our Platform, we automatically gather certain Internet or other electronic network activity information, including technical and usage information, which may or may not be associated with your user account. This information helps us improve the performance of our systems. Such automatically collected information is not shared with any third party. 

7. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We share your Personal Information with a limited number of individuals/entities as mentioned below. We never share any Personal information with any other individual/entity/party that is not mentioned below. We share your Personal Information with:

1. Employees, Contractors, and Agents of SpringVerify who require this information for performing their obligations and duties. Any Employee, Contractor, or Agent of SpringVerify who has access to such Personal Information is required to keep such information confidential and not use it for any other purpose.

2. Sub-Contractors and Vendors who are contracted by Us to prepare verification reports. We provide Candidate’s Personal Information to our selected vendors and subcontractors who may carry out part of our services for Us. We share such Personal Information with these persons/entities on a “need to know” basis and according to industry standards and applicable data protection laws.

3. We only share the final background verification report with the Customer who requested such a report and the Candidate upon whom such report was requested, except for the exceptions mentioned in clause 4 below.

4. We may share your Personal Information through the medium of the background verification report with any state police or national investigation agency or with any third party as directed by the order of a competent Court.

5. We may share a copy of the Candidate’s background verification report with the relevant stakeholders in case of litigation (threatened or actual) to defend the rights of Springrole India Pvt. Ltd.

6. Apart from the above-mentioned categories, the reports will not be shared with any other third-party without your explicit consent or when you request us to share the same in writing.

8. PURPOSES FOR WHICH WE COLLECT AND PROCESS PERSONAL INFORMATION

We only use Personal Information for the following purposes as mentioned below:

1. To provide services and prepare background verification reports: SpringVerify collects Personal Information as mentioned under Section 3 of this Policy to provide services to Customers by preparing background verification reports, providing analytics for such background verification reports, and to provide the functionality to our products. 

2. Business Operations: Some of the information that we collect such as your account information, and billing information is used to carry out our day-to-day business operations such as administering your account, billing, managing our platform, or to rectify or troubleshoot any errors or discrepancies that may arise on the Platform.

3. To meet Legal and Compliance requirements: Some of the collected information may be used by SpringVerify to (i) meet with any applicable law or regulation or any legal compliance, (ii) to assist any state police or any national investigation agency in any investigation, as required by the law or if we feel it necessary in our good faith, (iii) to protect the legal rights and legitimate interests of SpringVerify and Springrole India Pvt. Ltd., (iv) to prevent fraud and abuse of SpringVerify’s services and Platform.

4. To improve quality of systems and services: SpringVerify may use collected Personal Information to improve system functionality, through internal audits, and checks, to rectify and troubleshoot problems, and maintain and improve the security and quality of our Services.

5. To ensure Safety and Security: SpringVerify creates and maintains accounts on its Platform on basis of collected information. In order to verify the existing information, prevent unauthorized or duplication of accounts, and prevent fraud, SpringVerify may use the collected Personal Information.

9. PROCESSING OF PERSONAL INFORMATION
1. How do we Process Information

SpringVerify as a service provider and Platform is a “Processor” of data. We will only collect information as per the sole instructions of our Customers' issues to us from time to time and as agreed in our contractual agreements. This Privacy policy forms the basis of the processing of any Personal Information. SpringVerify will only process the Personal Information collected for the limited purposes mentioned in Section 6 of this Policy. The Personal Information collected by SpringVerify will not be used for any other purpose whatsoever.

We will implement technical, physical, and administrative measures against unauthorized processing of such information and against loss, destruction of, or damage to, Personal Information.

We do not own, control or direct the use of Personal Information. All the Personal Information used to prepare the background verification report belongs solely to the Candidate. We only access such information as reasonably necessary and with the consent of the Candidate, to prepare background verification reports on the request of our Customer.

2. International Transfers

There is no direct international transfer of Personal Information on the SpringVerify India platform. However, we do store some of our data on our Cloud platform of AWS United States.

3. Links to Third Party and Privacy Policy.

Our Website may contain links to other websites that may collect Personal Information. Springrole India and SpringVerify have no control or ownership of such websites and cannot guarantee the protection of your Personal Information on these websites. You are advised to read the Privacy Policy of such websites carefully and proceed carefully at your own risk.

10. YOUR RIGHTS

You are entitled to certain rights with regard to your Personal Information and data. We make it our utmost priority to inform you and safeguard your rights with regard to your Personal Information and Data. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. In case of any query, you can write to us at [email protected]

Both as a Customer and Candidate of Springverify, you have:

(a). Right to rectification: You have the right to request rectification of any personal information that we hold about you. This enables you to correct any incorrect or inaccurate Personal Information that we may possess of yours. However, considering the nature of the services that SpringVerify provides, we may ask for relevant supporting documentation before we make rectification.

(b). Right to Withdraw Consent: You have a right to withdraw your consent anytime and anywhere with regards to the collection and processing of your personal information. However, you understand that such withdrawal of consent will immediately stop SpringVerify from moving any further with background verification. As a candidate, you understand that withdrawal of your consent and its implications on your potential or actual employment is beyond the scope of Springrole India Pvt. Ltd. and you shall at no point in time hold Us responsible for the same.

(c). Right to Erasure of Personal Information: You have a right to request the erasure of any personal information that we hold about you. However, considering the nature of the services, where we act on the behalf of the Customer (who may be the prospective employer/employer of the Candidate), we will pass such a request to the Customer. If we don’t hear from the Customer within 90 days from the date of intimation about such a request, we will move ahead and delete the data from our systems. However, Springrole India reserves the right to deny any erasure request if it believes that such erasure can hamper any of its legal rights in the future.
Furthermore, both the Customer and the Candidate understand that and agree to the fact that SpringVerify has no control over the data stored in third-party sources, subcontractors, and vendors that are used to generate the background verification reports. In case, you want to remove your data from such sources, we request you to identify such sources with us and then proceed individually with such sources. We may at our sole discretion and pending obligations may help you identify such third-party holders of your Personal information. 

(d). Right to request access to Personal Information: You have the right to request access to your Personal information that we may possess. This entitles you to receive a copy of your Personal Information that we hold. You can also check if we are lawfully processing your Personal Information as per this Policy and applicable laws and as consented by You.

(e). Right to restriction on Processing of Personal Information: You have the right to object to, or obtain a restriction of, the processing of your Personal Information. You can request Us to stop the processing of any Personal Information that we possess. However, you understand that this will stop SpringVerify from carrying out and preparing the background verification report. 

(f). Right to portability: You have the right to portability which allows you to instruct us to transfer your Personal Information directly to you as per your request and instructions. You have a right to complain to the relevant authorities about our collection and processing of personal information should you find it necessary. For more information, please refer to applicable laws and regulations and contact the relevant authorities for the same.You have the right to send Us specific instructions with respect to the use of your Personal Information after your death. In the case of processing any Sensitive Personal Information for a background check, you have the right to ask for specific details and the kind of information that we may collect to move ahead with such a check.  You have a right to opt-out of any marketing communications or advertising that we send you. This allows you to stop Us from sending any marketing communications about any of our products and services.

We will not charge any fees from you for exercising your rights. However, we may charge a fee for administrative purposes if we find your request to be excessive, alternatively, we can also reject your excessive requests.

To make any requests with regards to your Data related rights, contact us at [email protected] or [email protected]. While you reserve a right to complain to relevant authorities about our Data practices, we encourage you to first contact us with any questions or concerns. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

11. OUR POLICY TOWARD CHILDREN

SpringVerify or any part of its services are not directed towards any individual who is below the age of 18. We do not knowingly collect personal information from children under the age of 18 years. In rare cases, where a Customer wants to carry out a background check on someone who is under the age of 18, then they need to obtain at their sole cost(s) and peril informed consent of the guardian of such individuals. In addition, any person below the age of 13 is not allowed to use our services under any circumstances.

If we become aware that a child under the age of 18 years without the consent of his/her Parent/Guardian or any Child under the age of 13 has provided Us with their Personal Information, then in that event We will take appropriate steps to delete such information, without undertaking any liability in that regard. If you become aware that a child has provided Us with their Personal Information, then please contact us on the details provided under the Contact Information clause incorporated under this Policy.

12. SECURITY

Our Company securely hosts your Data using AWS cloud services. Your Data is stored in the United States AWS Region. We are committed to ensuring that your information is secure. We have put in place appropriate technical, physical, and administrative procedures and protocols to safeguard and secure the information we collect in order to prevent unauthorized access, modification, or disclosure. You can request Us to provide you with a copy of such policies.

12.1. PAYMENTS

Our payments partner Razorpay is compliant with the current ISO 27001 standards and the current Payment Card Industry (PCI) Data security standards.

13. UPDATES TO THIS POLICY/NOTICE

Springrole India Pvt. Ltd. reserves the right, at its discretion, to make changes to any part of the products, platforms, or this Policy. Springrole India may change this Policy from time to time by updating this page. You should check this page from time to time to ensure that you are aware of any changes. This Policy is effective from 20th June 2022. By continuing to use the products and services, you consent to this Policy as amended from time to time.

14. COMMUNICATIONS

If you are a Customer or a Candidate availing services of SpringVerify, we may need to communicate certain necessary information to you. This information might include product information, updates, or related announcements. For instance: Information regarding maintenance of any product or our website. We assure you that we will send these announcements only when they are necessary. Such communications are not marketing communications and you may not opt out of them. The only way to Opt-out of these is by deactivating your account.

15. CONTACT INFORMATION

If you have any questions about this Policy, or wish to make a complaint about our data handling practices, you may contact: [email protected]