Privacy Policy

1.INTRODUCTION

SpringRole Inc. and its Subsidiaries hereinafter referred as Springworks ("Us", "We", or "Our") operates https://springworks.in/ (the "Site") and has issued this Global Data Protection and Privacy Policy (“Policy”). This page informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of the Site. Please read the entire Policy carefully it forms a contract between You (“Customer”) and Us.

This Policy will apply where We are Controllers or Processors of personal data. This policy is applicable to Our Products (web platform, mobile applications, API based clients) and to Our public Site https://springworks.in/

By using the Site or any of our services that are listed below in the policy, 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 also reserve the rights and choices as to how we collect your Data and at any point in time can decline to provide any Personal Information that you want. However, when such information is necessary to provide you with any of our services, your refusal will restrict the usage of such features or services in part or in whole. The rights that you reserve, with regards to your personal information and how to exercise them have been enumerated in this policy.

2.APPLICABILITY

This Policy applies to:

• all the Customers who are (i) entities or individuals, including End-Users and Users, who have subscribed to our Service(s) and have agreed to the Terms and Conditions (ii) individuals (“Individuals”) from whom We collect data as a Controller.
• all the persons whose data we collect when they visit our website.
• all the persons who register any kind of interest in our products or provide personal information through our website, career section of our website, agents, etc.

3.THE INFORMATION WE COLLECT

We may require basic information which identifies you as an individual (“Personal Information”), in order to transact business with you, on behalf of the company you work for, as our customer. We may also collect the following information, depending on the service being used:

• 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) Job title or description, (v) Company or organization name, (vi) Company address, including country. This information may also be collected when you show interest in signing up with our business via our Website and by connecting through our Agents.
• 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.
• Usage Information:To facilitate 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,
• Service Data:While providing you with the Services, we process your Personal Information as per this policy, however due to such processing we may also perform our analytics. The Data collected through such analytics is used to determine your business needs and usage. This allows us to provide you with improved services and respond to your requests as and when they arise.
• Other systems information:We may collect some other system information such as product administration activity including adding and deactivating users or any other system or user information that may be required for compliance with any applicable law.
• Cookies and Other Usage Data:We may collect some Personal Information using Cookies. Some of this Data is collected automatically, for example, the log Data. Other data might be generated by third party Cookies which our partners may use. These Cookies and other third party tools also allow us to collect data for analytics, track your movements on our websites and administer the website. Lastly we may collect your contact information like your emails, account details etc. third parties like Social Media platforms, however this Data is only collected after you give your consent.

We do not collect sensitive personal information such as racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, or data concerning health or sexual orientation, etc. This kind of Information might be sensitive and personal to you as an individual. If we ever need to collect any sensitive personal information, we would give you a detailed notice and would only collect after you give your consent to such collection in writing.

4HOW DO WE COLLECT YOUR PERSONAL INFORMATION

Most of the Data that we collect is provided to Us by You directly. This is done when you:

• Use our websites or tools provided there to get in touch or to chat with our Agents.
• Place an order or get in a contractual agreement with Us to use our services.
• Use or visit our website via your browser’s cookies.
• Provide information in response to a marketing email or contact or any survey that we may conduct.
• Interact with a marketing campaign on a third party website or service.
• Interact with the company brand(account) on any social media website like Facebook, Twitter, etc.
• Apply for a job/work/recruitment on our website or through the career section.

In addition to the above, we may also collect some Personal Information indirectly from third parties, such as our business partners, or members of your Community. Some of your Personal information like IP addresses and usage patterns are also collected by inbuilt tools within our services.

5PURPOSES FOR WHICH WE COLLECT AND PROCESS PERSONAL INFORMATION

We will only use such Personal Information for the purposes mentioned below.

5.1Business Transactions with Customers

Our business transactions and Contractual agreements with You means that we need to process your Personal Information through our systems to provide you Our services. Thus we would process your collected personal data to provide you with our services. This is one of the major purposes for which we collect and store your Personal Information. Some of these processing may include International Data transfers. We process Personal Information through Our global IT systems, which include tools and systems that help us to administer customer accounts, orders and business transactions and share information across Our systems, and with related corporate entities We do such transfers after taking adequate measures. Such transfer may also be done based on our legitimate interests. More details regarding such transfers is provided in Clause 8.

5.2Products

You provide Personal Information to Us through our “registration” page, or by placing and processing orders, or by participating in a Community, in order to use the products which run on Our platforms, such as:

We use Personal Information that we collect to administer the products, platforms and services. More information as to why we process Personal Information is given below.

• We collect and process your Personal information to provide services to you as per our contractual agreement and related arrangements. Our product(s) provides you services and solutions by processing your Personal information.
• We collect your contact information as it enables us to provide access to customer support portals or to provide customer support services to you
• We also retain some of your Information about your visits to our websites and how you use our products. This information includes how you utilize our software for analytics purposes. This helps us to improve our products or to optimize them by making them more intuitive and user friendly. Such retention would also help us to optimize our system operations based on usage information and to enable us to develop future products and make improvements.
• We may also process your Personal Information as per applicable export control, customs and other applicable laws and regulations that are necessary to operate our systems.
• We would also process your Personal Information on the request of any Law enforcement agency or to protect other users or the general public if required. Further, we may also share your Personal Information with any law enforcement agency, if we suspect that you are using our services for any illegal or unlawful activity.
• We may also collect your usage statistics and patterns. including how you utilise our products for marketing purposes. Collecting this Data helps us to market to you specific products and solutions.

5.2.1COOKIES

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. We use cookies for advertising and analytics purposes, such as to identify returning business visitors and show them customized content, for more details, refer to the Cookies Policy.

Some of our services may have options of interacting through your social media or similar services’ accounts like(facebook, google, linkedin, twitter). These features are hosted by these third parties on websites directly, and they may enable these features to work. When you use these services you are governed by the privacy policy of these third parties. For more information as to how these third parties use Cookies, check out our Cookie Policy.

Most browsers allow you to turn off cookies or to receive a warning before a cookie is stored on your hard drive. You can find out more about Cookies and how we use cookies in our Cookie Policy.

If you do not wish us to make use of your Personal Information in this way, please email[email protected]

5.3Other legitimate business interests/purposes

We will process your Personal Information when it is necessary for our legitimate interests. This will help us to conduct our business more effectively and efficiently.
For instance we may use your Personal information to perform analytics, train, enhance, develop, support or cure any deficiency in our services. These functions help us improve our services. It also allows us to provide you with a customized and personalized service.
Based on our legitimate interest we may process your personal information to prevent any misuse of our services that is in breach of this Privacy Policy or Our Terms of usage.
It is also in our legitimate interest to fulfill our Contractual obligations with You and provide you with agreed upon services.
We may also process your Personal Information as a response to comply with laws, or to comply with any request by a law enforcement agency or a Court order as mentioned under Clause 6.3.
However these legitimate interests will not override your interests, freedoms, rights with regards to your Personal Information as a User except as per the requirements and procedures established by law.

6WHO WE SHARE YOUR PERSONAL INFORMATION WITH

6.1Within Springworks

Employees, contractors and agents of Springworks may be given access to Personal Information which we collect, but their use will be limited to the performance of their duties and the reason for processing. Our employees, contractors and agents who have access to your Personal Information are required to keep that information confidential and are not permitted to use it for any other purposes.

6.2Business Partners and Service Providers

If you enter into an agreement with us, you agree to certain Data Transfers to our Partners. When we permit a third party to access Personal Information, we will implement appropriate measures to ensure the information is used in a manner consistent with this Policy and that the security and confidentiality of the information is maintained. We will never sell, rent or disclose to unaffiliated third parties your Personal Information unless we have your permission or are required by law to do so.
We disclose the Personal Information We collect, to the following third parties:

• Business partners for the purposes of providing services, support and products to customers
• Service Providers who provide business services to us. We share personal information on a "need to know basis" and in accordance with applicable data privacy law. However, while we ensure that sharing of Data is done according to industry practices and applicable privacy laws, we encourage you to check the websites and privacy notices to keep yourself informed about how your data is processed.
• Services including social media services like Facebook, Twitter etc. for marketing purposes. These disclosures however, are done with your consent and you have options to opt out of these disclosures.

Some of the Service providers with whom we share your Personal Information with are: Stripe, Loggly, Sentry, AWS, Slack, Tawk, Mailchimp, clearbit, New Relic, Atlassian, Sugoi Labs, Atlas(Mlabs).
As the parent company Springworks provides products, support and operational services to its subsidiary SpringRole India Private Limited operating out of India.

Further, some aspects of our services and products are processed through our subsidiary. Therefore, we share your Personal Information with our Indian subsidiary SpringRole India Private Limited. This allows us to provide smooth and effective services.

6.3To third parties on Lawful Grounds

We may disclose Personal Information to third parties including Law enforcement agencies and Courts, when there are lawful grounds:

• To comply with our legal obligations, regulation or contract, or to respond to an administrative or judicial process
• In response to lawful requests by public authorities (including for national security or law enforcement purposes)
• If necessary to exercise or defend against potential, threatened or actual litigation
• In connection with the sale, assignment or other transfer of all or part of our business, or
• To exercise or to defend the legal rights of the Springworks.

7YOUR CONTROL OF YOUR PERSONAL INFORMATION

You can request correction, update and deletion of your Personal Information via e-mail sent to [email protected], and we will use reasonable efforts to contact you regarding your request. You may also withdraw consent provided to “Us”, to use your Personal information by writing us to [email protected]. To update or delete your Personal Information or correct an inaccuracy, we may ask you to verify your identity and cooperate with us in our effort.

You may exercise any other right available to you with regards to your Personal Information by contacting us at [email protected]. Your available rights with regards to your Personal Information are provided under Clause 10 of this policy.

8PROCESSING YOUR PERSONAL INFORMATION

8.1How do We Process

As the Controller of Personal Information, we will collect your Personal Information as per the conditions mentioned above. We also would process your Information only for the purposes mentioned above. We will implement technical, physical and administrative measures against unauthorized processing of such information and against loss, destruction of, or damage to, Personal Information.
Except as expressly permitted by you under this Policy, we do not own, control or direct the use of Personal Information, and only access such information as reasonably necessary to provide the Service(s) (including to respond to support requests), as otherwise authorized by you or as required by law.
Unless we explicitly agree otherwise in writing, we will not process any sensitive Personal Information on our platform.

For purposes of the GDPR and the Swiss Federal Act on Data Protection, we are the Controller of Personal Information, whereas you are “Data Subject”. As a Data Controller we will process your Personal information as per this privacy policy and the principles of GDPR.

Further, If you are an EEA or Switzerland-based customer, then We are also responsible for compliance with the applicable data protection law as We are the “Controllers”. As the controller, it shall be our responsibility to inform You about the processing, and, where required, obtain necessary consent or authorization for any Personal Information that is collected as part of the Personal Information through Your use of the Service(s). We will take all steps reasonably necessary to ensure that the Personal Information is treated securely and in accordance with this Policy. We also ensure to keep our Data practices in accordance with the GDPR principles and guidelines.

8.2International Transfer of Personal Information

As the “Controller” of Data, we may need to transfer Personal Information to countries other than the ones in which the information was originally collected. This is because our Affiliates, Related Entities and Business Partners may be based out of a different country(ies). We would only process and transfer your Personal Information to these Affiliates, Related Entities and Business Partners after informing you about such transfers and after obtaining your consent. Personal Information may be shared among related entities within Springworks as well.

As the parent company, Springworks provides products, support and operations services, and centralized corporate functions to its subsidiary - SpringRole India Pvt. Ltd.
Further, to process some of our transactions, we will transfer Personal Information to our servers in the United States. This is because our parent company in the United States, SpringRole Inc. hosts servers or utilize third party servers and applications necessary for providing you services.
In case you are a Citizen of the EU, EEA, Switzerland or the UK, all the Data transfers would match the security standards as set out under the GDPR. Further, If you are a resident of European Union, EEA, Switzerland or the United Kingdom and if your Data is transferred to any third country, which does not comply with adequate standards of privacy as specified by GDPR then such transfers would be done as per the Standard Contractual Clauses executed between the parties.
With regards to any Personal Information that is transferred to the United States, we are liable to regulatory enforcement powers of the US Federal Trade Commission.
In case you withdraw your consent for such transfers, we will stop the transfer of your Data to our subsidiary (SpringRole India Private Limited) and other business affiliates or partners. However, this may impact your User experience significantly and you may not be able to use our services partially or completely.

8.3Links to Third Party and Privacy Policy

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

9DATA RETENTION AND TIME PERIOD

• As a part of our business, we have to retain your Personal Information to provide you with our Services till the time you are Our Customer.
• After you cease to be our customer we will retain Personal information and your data for a further 12 month period. We retain this Data for our legal obligations, legitimate interests and for analytical purposes to improve our products. After the expiration of this Period we will erase your Data from our storage.

Personal Information is retained and deleted in accordance with this Privacy Policy. If you wish to request that we no longer use your Collected Data, please contact us at[email protected]. Personal Information will be retained no longer than necessary in relation to the business purposes for which such Personal Information is provided and to fulfill legal requirements.

10PRIVACY RIGHTS

You are entitled to certain rights with regards to your Personal Information. Further, If you are an individual and resident of the EEA or Switzerland, You are classified as a “Data Subject” as per the GDPR. As a resident of EEA or Switzerland, you also have certain specific rights with respect to your Personal Information as mentioned below. To ensure best practices, we afford these rights to all our Users, or to all persons to whom this policy is applicable, even if they are not a resident of European Union.

We make it our utmost priority to inform you and safeguard your rights with regards 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]

As a User:

• You can request access to your Personal Information. 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.
• You have a right to request rectification of any of your Personal Information that we hold. This enables you to correct any incorrect or inaccurate Personal Information that we may possess of yours.
• You have a right to erasure or deletion of all your Personal Information. This enables you to ask us to delete any Personal information of yours that we possess.
• If any automated processing of your Personal Information is based on your consent or a contract with you, you have a right to transfer or receive a copy of your Personal Information in a usable and portable format;
• If the processing of your Personal Information is based on your consent, you can withdraw consent at any time for future processing. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent;
• You can object to, or obtain a restriction of, the processing of your Personal Information under certain circumstances. such as when we are relying on legitimate interests to process your Personal information, or where there is any particular or unique situation which makes you object to such processing of Personal Information.
• You also have a right to request restriction for the processing of any Personal Information that we possess. This enables you to ask us to suspend the processing of any of your Personal information.
• You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.
• If we have collected and processed your Personal Information with your consent, then you have a right to withdraw your consent at any time, by writing to us.
• You have a right to Opt-out of any kind of marketing or advertising from Us. This allows you to stop Us from sending you any kind of marketing communication about our products and services.
• You have a right to data portability which allows you to instruct us to transfer your personal Data directly to you as per your request and instructions.
• For residents of France, you can send us specific instructions regarding the use of your Personal Information after your death.

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]. While you reserve a right to complain to a Data Protection Authority 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.

11CALIFORNIA-RESIDENT SPECIFIC RIGHTS

If you are resident of California and is a 'consumer' as defined under the California Consumer Privacy Act of 2018 ("CCPA") and We are a 'business' as defined under CCPA, then the following provisions applies to you:

Subject to the provisions of the CCPA, you have the right to request in the manner provided herein, for the following:

Right to request for information about the:

• Categories of Personal Information We have collected about you.
• Specific pieces of Personal Information We have collected about you.
• Categories of sources from which the Personal Information is collected.
• Business or commercial purpose for collecting Personal Information.
• Categories of third parties with whom the business shares Personal Information.

Right to request for deletion of any Personal Information collected about you by Us:

If you seek to exercise the foregoing rights to access or delete Personal Information which constitutes 'personal information' as defined in CCPA, please contact us at details provided under the Contact Information clause in this Policy. We respond to all requests we receive from you wishing to exercise your data protection rights within a reasonable timeframe in accordance with applicable data protection laws. By writing to us, you agree to receive communication from us seeking information from you in order to verify you to be the consumer from whom we have collected the Personal Information from and such other information as reasonably required to enable us to honour your request.

The details and list of the mode of collection, processing and sharing of Personal Information by Us is highlighted in the present Policy. We suggest you read it carefully and then proceed.

12OUR POLICY TOWARDS CHILDREN

The Services are not directed to individuals under the age of 18 years, as on the date of accessing/ availing the Services provided by Us. We do not knowingly collect personal information from children under the age of 18 years. Any person under the age of 18 who wants to use our services, needs to provide the consent of his Guardian at [email protected]. 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. We also encourage Parents/Guardians to monitor the internet usage of their children to ensure that they don’t access our services without your consent. 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.

13SECURITY

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 unauthorised access, modification or disclosure. We have also prepared specific protocols to deal with any kind of breach should it happen.
However, while we ensure to maintain all the safety standards and procedures, you acknowledge that the Internet is a global environment and Our products allow users to send documents and communicate with other users. We are not responsible for the data protection or privacy practices or the content of other users’ sites. When your communications leave our platforms, we cannot be responsible for the protection and privacy of any information which you provide while visiting such sites and such sites are not governed by this Policy. You should review the data protection and privacy statements applicable to such sites.

13.1Payment Systems Security

To ensure safe and secure payments, we comply with the current standards of the industry. Our payment systems are compliant with ISO 27001 standards. Further, our payment systems are also compliant with Payment Car Industry (PCI) Data security standards.

14UPDATES TO THIS POLICY/NOTICE

Springworks reserves the right, in its discretion, to make changes to any part of the products, platforms or this Policy. Springworks 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 26-Jul-2021. By continuing to use the products and services, you consent to this Policy as amended.

15OPT-OUT PROCEDURE

Springworks may send you marketing related communications from time to time. As a User you reserve a right to opt out of these marketing communications. You can opt-out of these marketing communications at any time by writing to us at [email protected].
You can also object to usage of your Personal Information for Analytics by writing to us at[email protected]

16OTHER COMMUNICATIONS

If you are a Customer of Springworks, 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.

17CONTACT INFORMATION

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

Data Protection Officer

SpringRole Inc, 1447 2nd Street Suite 200 Santa Monica, CA 90401 United States
Email: [email protected]

We will investigate any complaints received in writing and do our best to resolve them with you as soon as possible.