PRIVACY POLICY

LAST REVISION: 2023

I. Who are we?

WECP Private Limited, a company, having its registered office at 2628, Sector-1, 27th Main Road, HSR Layout, Bangalore – India 560102. At WeCP, data privacy is superior to any other matter, and when it comes to our users’ data, we’re committed to providing transparency about how we collect data, how we use data, and how we protect them. This Privacy Policy is published to let you know the information we collect about you on our websites (the “Websites”), including from individual users who register to use the WeCP Assessment Platform and customers who use the WeCP Assessment Platform. This Privacy Policy describes WeCP’s privacy practices in relation to the use of the Websites and the related applications and services offered by WeCP (collectively, the “Services”), as well as individuals’ choices regarding use, access, and correction of personal information. In this Privacy Policy, the terms “WeCP,” “WeCP Assessment Platform,” “We,” and “Us” refer to WeCP Private Limited, a Private Limited doing business as WeCP.

II. Types of Data Collected

WeCP collects, processes, and retains information about you when you visit the Websites or use the Services. You may choose to provide WeCP with information, such as:

• Contact information such as your name, email address, and phone number;
• Captured live images through the web camera enabled tests;
• Customized employment information such as your HR/employee ID, length of time that you have worked in your employer organization, job title, work location, department, employment start date, and next pay date;
• Technical information, such as your Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, screen resolution, flash version, time zone setting, browser plug-in types and versions, operating system, platform, and traffic data, cookies data, weblogs, and other communication data, and details of the resources that you access, which we collect from you when you access the Platform; and
• Any other information that you agree to provide to us.

Certain data elements requested of you by the Websites are “mandatory” or “required,” and failure to provide this Data may make it impossible for WeCP to provide its Services to you. In cases where requested data elements are not mandatory or required, you may choose not to provide the requested data without any consequences to the availability or the functioning of the Services. WeCP may observe your activities, interactions, preferences, and other computer and connection information (such as IP address and geographic location) relating to your use of the Websites and Services. WeCP may also use log files, cookies, and similar technologies to collect information about the pages you view, links you click on, and other actions you may take when accessing the Websites and Services. For more information about our use of these technologies, please see the Cookies section below. We may collect and store this information and combine this information with other personal information you may have provided.

III. WeCP Assessment Platform Service Data

WeCP customers may upload data to the WeCP Assessment Platform. WeCP will not share or distribute any such customer data except as provided in the contractual agreement between WeCP and customer for the provision of the WeCP Assessment Platform Service, or as may be required by law. If a WeCP customer is located within the European Economic Area, the customer is the Controller with respect to the WeCP Assessment Platform data, and WeCP is a Processor.

IV. Use of Collected Data

• Contact information such as your name, email address, and phone number;
• Respond to your inquiries or fulfill your requests;
• Diagnose Website and Service technical problems;
• Send you administrative information such as notices related to the Services or policy changes;
• Understand how the Websites and Services are being used to enhance and optimize them;
• Personalize your experience on the Websites;
• Prevent, detect, mitigate, and investigate fraudulent or illegal activity; and
• As described to you at the point of collection of the information.

V. Processing the Data

The information collected by WeCP is stored and processed by WeCP’s sub-processor, Amazon Web Services (“AWS”), leveraging AWS data centers located within the Asia Pacific (Mumbai) region. Processing of the information collected about you is only undertaken for the purposes described in this Privacy Policy.

VI. Data Processing Details

Analytics The third-party services described in this section enable WeCP to monitor and analyze Website and Service traffic.

• MixPanel (MixPanel Inc.) MixPanel is an analytics service provided by Mixpanel Inc. Information collected: Cookies and Usage data. Place of processing: US – Privacy Policy – Opt Out
• Google Analytics (Google Inc.) – Google Analytics is a web analysis service provided by Google Inc. Google utilizes the information collected to track and examine the use of the Websites and Services to prepare reports that may be used for the optimization of the Websites and Services. Information collected: Cookies and Usage data. Place of processing: US – Privacy Policy – Opt Out

Displaying Content from External Platforms The third-party service described in this section enables WeCP to display content to you on the Websites that are hosted on an external third party platform. This type of service may collect web traffic data to optimize the content’s delivery on the Websites.

VII. Sending Data Outside the EEA

We are an India based company with staff located in India, and therefore, your personal data will be processed outside the European Economic Area (“ EEA”). If we transfer personal data outside the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA and may be required to take specific additional measures to safeguard the relevant personal data. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to the Data Protection Laws (see the full list here). Therefore no additional safeguards are required to export personal data to these jurisdictions. In countries which have not had these approvals, we will establish legal grounds justifying such transfer, such as European Commission-approved model contractual clauses, or other legal grounds permitted by applicable legal requirements.

You can contact us on the contact details below to find out more about safeguards we have in place for any transfers of your personal data outside of the EEA or if you would like to see a copy of the specific safeguards applied to the export of your personal data.

VIII. User Signup and Authentication for the WeCP Assessment Platform

The third-party services described in this section enable the Websites and Services to register, identify, and authenticate you to access dedicated Services.

AWS Cognito Authentication (Amazon Web Services, Inc) – Information collected: authentication data as specified in the AWS Cognito privacy policy. Place of processing: India – Privacy NoticePolicy

IX. Disclosure of Your Data

We do not sell, lease, rent, or give away the information collected about You without your permission. We only disclose your information, as described below. If we disclose your information, we require those we share it with to comply with adequate privacy and confidentiality requirements and security standards.

• Service Providers Processing Data on Our Behalf: We may use contractors and service providers to process the information collected about you on our behalf for the purposes described in this Privacy Policy. We contractually require service providers to keep information secure and confidential. We do not allow our data processors to disclose your information to others without our authorization or to use it for their own purposes. However, if you have an independent relationship with these service providers, their privacy statements will apply.
• Law Enforcement: In certain instances, it may be necessary for WeCP to disclose the information that we’ve collected about you to government officials or otherwise as required by applicable law. No personal data will be disclosed to any law enforcement agency or governmental agency except in response to:
• A subpoena, warrant, or other process issued by a court of competent jurisdiction;
• A legal process having the same consequence as a court-issued request for information, in that if WeCP were to refuse to provide such information, it would be in breach of local law, and it or its officers, executives, or employees would be subject to liability for failing to honor such legal process; or
• Where such disclosure is necessary for WeCP to enforce its legal rights pursuant to the laws of the jurisdiction from which such information was gathered.

X. Cookies and Similar Technologies

A cookie is a commonly used automated data collection tool. Cookies are small text files placed on your computer or device by websites that you visit or HTML-formatted emails you open to make websites work or work more efficiently. We may use cookies, web beacons, pixel tags, or other similar technologies on the Websites to, among other things:

• Authenticate you as a WeCP Assessment Platform user;
• Collect statistics regarding your usage of the Websites;
• Tailor information presented to you based on your usage of the Websites;
• Help provide additional functionality to the Websites; and
• Analyze the use of our Services.

You may refuse to accept cookies by activating the appropriate setting on your browser. If a cookie blocking setting is selected on your browser, you may be unable to access certain parts of our Website or receive certain Services.

XI. Do-Not-Track

There are different ways you can prevent tracking of your online activity. One of them is setting a preference in your browser that alerts websites you visit that you do not want them to collect certain information about you. This is referred to as a Do-Not-Track (“DNT”) signal. Please note that our Websites may not recognize or take action in response to DNT signals from your browser.

XII. Managing Your Data

Managing Your Data We retain the information that we collect about you for as long as your WeCP account is active or as needed to provide you Services. We also retain and use the information collected about you as necessary to comply with our legal obligations, resolve disputes, prevent and detect fraud, and enforce our agreements. We store the information collected about you for as long as is necessary for the purpose for which we collect it.

XIII. Your Rights With Respect to Your Data

Data protection laws in the European Economic Area (EEA) and some other countries provide individuals certain rights in relation to their information held by WeCP. If the processing of your data is subject to the EU General Data Protection Regulation (GDPR), you are entitled to the rights listed hereinafter. You may contact us using the contact details below to exercise any of these rights. We will respond to any request received from you within one week from the date of the request.

Details of Rights

• A right to access personal data held by us about you.
• A right to require us to rectify any inaccurate personal data held by us about you.
• A right to restrict our processing of personal data held by us about you: this right will only apply where (for example): you dispute the accuracy of the personal data held by us or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but you require the data for the purposes of dealing with legal claims.
• A right to require us to erase personal data held by us about you: this right will only apply where (for example): we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent (if we are using your personal data based on your consent); or where you object to the way we process your personal data (in line with Right 6 below).
• A right to receive personal data, which you have provided to us, in a structured, commonly used, and machine-readable format. You also have the right to require us to transfer this personal data to another organization, at your request.
• A right to object to our processing of your personal data (including to send marketing materials to you).
• A right to withdraw your consent, where we rely on it to use your personal data (for example, to provide you with marketing information about our services or products). If you withdraw your consent, we may not be able to provide certain products or services to you.

If you choose to exercise one of the above rights, we may request specific information from you to help us confirm your identity and that you are entitled to make a request for the exercise of the said right. The request from WeCP is to ensure that personal data is not disclosed to any person who has no right to access or receive it. These rights are subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege) and may not all be available in the country in which you are based.

XIV. Accessing, Updating, Correcting, or Deleting Your Data

You can view and update much of the information collected about you through your WeCP account. If you wish to cancel your account or request that we no longer use your information to provide you Services, contact us via the information below. We will respond to your request to access or delete your information within 15 days. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

WeCP Private Limited; Attn: Data Privacy; #2628 27th Main Rd, Sector 1; HSR Layout, Bangalore, Karnataka 560102; Republic of India.

Via email: admin@wecreateproblems.com with “Data Privacy” in the subject line

XV. Changes to this Privacy Policy

WeCP reserves the right to revise or modify this Privacy Policy. We will post a prominent notice on the Websites prior to the change becoming effective in such an event.