WHAT IS THE PURPOSE OF THIS DOCUMENT

Tata Consultancy Services Limited ("TCS" or "we") is committed to protecting the privacy and security of your personal data.

This privacy notice describes how we collect and use personal data about you during and after your interaction with Board Application Portal ("Board" or the "Application") in accordance with the General Data Protection Regulation (GDPR) and applies to whosoever interacts with the Application.

TCS is a "data controller". This means that we are responsible for deciding how we hold and use personal data about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are aware of how and why we are using such information.

DATA PROTECTION PRINCIPLES

We will comply with applicable data protection laws. This means that the personal data we hold about you must be:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.

THE KIND OF INFORMATION WE HOLD ABOUT YOU

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (aka anonymous data).

• Board Application contains below modules:
• Tenant On Board(TOB)
• User Management System(UMS)
• Password Web Services(PWS)
• Meeting Management System(MMS)
• Board Web Application(Board Web App)
• Board iPad/iPhone Application
• Digital Attendance Application


• Board Application collect PI like:
• Name
• Personal Contact Number
• Mobile Number
• Email-Ids
• Photo
• Digital Signature

There is also information that is automatically collected by Board Application Portal. This information can include your IP address, domain names and access times. This information is for the operation of the service and to maintain quality of the service.

HOW IS YOUR PERSONAL DATA COLLECTED

We collect personal data about you through your interaction with the Board Application.

HOW WILL WE USE INFORMATION ABOUT YOU

The use / purpose for which any information collected by the user, may comprise all or any of the following purposes:

• Providing the services of and maintaining the Board Application
• Internal Record Keeping
• To maintain logs and Audit Trail
• To send OTP through Mobile/Email for authentication

Under the GDPR the lawful bases for this processing are performance of the contract (providing the services of Board Application), legitimate interest of TCS in maintaining and optimizing the service and keep record of its usage and legal obligation. Board Application website does not sell, rent or lease its tenant lists to third parties.

• If you fail to provide personal data
If you fail to provide certain information when requested, we may not be able to perform the service you are requesting from us, or we may be prevented from complying with our legal obligations.


• Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis, which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DATA SHARING

We do not share your data with third parties, including third-party service providers and other entities in the group except Mobile Number which is shared with third-party for sending OTP via Mobile for authentication purpose. Others are used for our internal purpose only.

Board Application web site may disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) confirm to the edicts of the law or comply with legal process served on Board Application or the site; (b) protect and defend the rights or property of Board Application; and, (c) act under exigent circumstances to protect the personal safety of users of Board Application, or the public.

• Transferring information outside the EU/EEA
We will save your personal data collect from you in INDIA outside the EU/EEA in order to perform our contract with you. There is not an adequacy decision by the European Commission with respect to INDIA. This means that the country to which we transfer your data (INDIA) is not deemed to provide an adequate level of protection for your personal data.

However, to ensure that your personal data does receive an adequate level of protection we have put in place appropriate measure/s (such as data transfer agreements based on standard contractual clauses) to ensure that your personal data is treated in a way that is consistent with and which respects the EU/EEA laws on data protection. If you require further information about this protective measure, you can request it from our DPO (see contact details below).

DATA SECURITY

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

We have put in place appropriate technical, organizational and security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

DATA RETENTION

• How long will you use my information for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Generally for the Board Application, personal data are deleted after 84 months once user is inactive. Details of retention periods for different aspects of your personal data are available in our retention policy.

In some circumstances we may anonymize your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

DATA SUBJECT RIGHTS

• Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.


• Your rights in connection with personal data
If the processing of your personal data falls under the scope of GDPR, under certain circumstances, by law you have the right to:
• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request Erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to another party.


• What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

DATA PROTECTION OFFICER

TCS has appointed internal Data Protection Officers who can be contacted for any questions or concerns about TCS' privacy policies or practices. Depending on your location, you can refer to:

Data Protection Officer for UK and Ireland	|	DPO.uki@tcs.com
Data Protection Officer for Continental Europe	|	DPO.Europe@tcs.com

DATA PROTECTION SUPERVISORY AUTHORITY

Under GDPR, you have the right to make a complaint at any time to the relevant data protection supervisory authority.

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.