Transcorp Data Privacy Policy

This privacy statement is effective as of 09.08.2023. Please note that this privacy statement will regularly be updated to reflect any changes in the way we handle your personal data or any changes in applicable laws.

Unless stated otherwise, this privacy statement applies to all of Transcorp’s externally facing applications, services, tools, websites and other data processing activities where Transcorp is acting as a data controller (or any local equivalent).

This page tells you everything you need to know about how Transcorp International Limited and its Subsidiaries ("Transcorp"; "we") protect the personal data we process and control relating to you (“your personal data”; "your data") and which rights you have in relation to the processing of your personal data.

Herein below, we give a general description of how Transcorp protects your personal data.

Does Transcorp protect your personal data?

Transcorp attaches great importance to your right to privacy and the protection of your personal data. We want you to feel secure that when you deal with Transcorp, your personal data are in good hands.

Transcorp protects your personal data in accordance with applicable laws and our data privacy policies. In addition, Transcorp maintains the appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing, loss, alteration, disclosure or access, thereto.

The following sections provide further details as to how Transcorp processes your personal data:

Which categories of personal data do we collect and how do we process such personal data?

We collect personal data of our employees, clients and website users. If the data we collect are not listed in this privacy statement, we will give individuals (when required by law) appropriate notice of which other data will be collected and how they will be used.

Below is also a chart describing the categories of personal data we collect:

In addition, for recruitment/employment purposes and to provide assessment and HR consultancy services to our clients, Transcorp may process the personal information set out in the below table.

Category of personal information	Types of personal information captured by category
Additional personal details, contact details and identifiers/demographics.	In addition to the personal details listed above, Transcorp may collect additional personal details for recruitment/employment purposes, such as national identification number, social security number, insurance information, marital/civil partnership status, domestic partners, dependents, emergency contact information, and military history; professional/personal calendar availability/scheduling information for meeting/communication purposes.
Education information and professional or employment-related information.	Transcorp may collect information about your education and professional or employment-related information, such as your employment history.
Documentation required under immigration laws.	Transcorp may collect data on citizenship, passport data, and details of residency or work permit (a physical copy and/or an electronic copy).
Financial information for payroll/benefits purposes	Your banking and other relevant financial details we need for payroll/benefits purposes.
Talent management information.	Information necessary to complete a background check, details on performance decisions and outcomes, performance feedback and warnings, e-learning/training programs, performance and development reviews (including information you provide when asking for/providing feedback, creating priorities, updating your input in relevant tools), driver’s license and car ownership information, and information used to populate biographies.
Requested recruitment information	Information requested to provide during the recruitment process, to the extent allowed by applicable law.
Recruitment information you submit	Recruitment information you submit Information that you submit in résumés / CVs, letters, writing samples, or other written materials (including photographs).
Information generated by us during recruitment or during assessments	Information generated by interviewers and recruiters related to you, based on their interactions with you or basic Internet searches where allowed under applicable law.
Recruitment information received from third parties	Information related to you provided by third-party placement firms, recruiters, or job-search websites, clients where applicable.
Audiovisual materials	Photograph, and images/audio/footage captured/recorded on CCTV or other video systems when visiting our office or captured in the course of recruitment events or video recruitment interviews or during any other virtual and live events (including recordings during virtual workshops or similar events).
Recommendations	Recommendations related information provided on your behalf by others.
Employment history and background checks	Information about your prior employment, education, and where applicable and allowed by applicable law, credit history, criminal records or other information revealed during background screenings.
Assessment information	Information generated by your participation in psychological, technical or behavioural assessments. You will receive more information about the nature of such assessments before your participation in any of them.

Except for certain information that is required by law or by Transcorp policies, your decision to provide any personal data to us is voluntary. You will therefore not be subject to adverse consequences if you do not wish to provide us with your personal data. However, please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this privacy statement, and you may not be able to use certain tools and systems which require the use of such personal data. Further any services not provided due to lack of consent and willingness to share personal data shall not be against any policy (including this policy) of the company or shall fall under the definition of deficiency in services.

If you provide us with personal data of another person (for instance, a potential employee/referral), you are responsible for ensuring that such person is made aware of the information contained in this privacy statement and that the person has given you his/her consent for sharing the information with Transcorp.

The above-mentioned categories of personal data have been obtained either directly from you or indirectly from certain third parties (for example, through our website’s technology). Such third parties include our affiliates, public authorities, public websites and social media, suppliers, clients and vendors. Except where certain information is required by law or by Transcorp policies, your decision to provide any personal data to us is voluntary.

For which purposes and on which legal basis do we use your personal data?

Transcorp uses your personal data only where required for providing services to its customers/clients/users and/or for other specific purposes under the business licenses held by Transcorp.

We rely on our legitimate purpose to use your personal data, and we are of the opinion that our legitimate interests are not overridden by your interests, rights or freedoms, given (i) the transparency we provide on the processing activity, (ii) our privacy by design approach, (iii) our regular privacy reviews and (iv) the rights you have in relation to the processing activity. If you wish to obtain further information on this, please contact Transcorp’s Grievance Officer at info@transcorpint.com

We will process your personal information for the purposes of providing various services, products, and employment opportunities on your prior consent, to the extent such consent is mandatory under applicable laws.

To the extent you are asked to click on/check “I accept”, “I agree” or similar buttons/checkboxes/functionalities in relation to a privacy statement, doing so will be considered as providing your consent to process your personal information, only where such consent is required by mandatory law.

We will not use your personal information for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest to do so.

Will we share your personal data with third parties?

We may transfer personal data to our service providers and professional advisors, public and governmental authorities, Transcorp companies/affiliates or third parties in connection with Transcorp’s operation of its business, including our partners that facilitate us in providing services, any (potential) corporate or commercial transaction and including clients if the data has been processed to provide client services. Before we do so, we shall take the necessary steps to ensure that your personal data will be given adequate protection as required by relevant data privacy laws and Transcorp’s internal policies.

For example, we may disclose personal information to third parties for other business purposes as follows:

• We share your information with third-party service providers that provide services to us, including billing, payment processing, customer service, email deployment, advertising and marketing, security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, data hosting, auditing, and data processing;
• To protect and defend the legal rights, safety, and security of Transcorp, our affiliates, users, or the public, including to protect against fraud and malicious activity; and
• For other business purposes described in this privacy statement or for any other purpose disclosed to you at the time we collect the information or pursuant to your consent.

We may also share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of a bankruptcy.

What about data security?

We maintain organizational, physical and technical security arrangements for all the personal data we hold. We have protocols, controls and relevant policies, procedures and guidance to maintain these arrangements taking into account the risks associated with the categories of personal data and the processing we undertake.

We adopt market leading security measures to protect your personal data. This includes (without being limitative):

• Transcorp adheres to the strict data security standards our partners and third-party service providers are certified by appropriate authority for data privacy and security standards.
• We have regular penetration testing performed by a third-party provider, which continues to show the strength of our technical defenses.

How long will your personal data be retained by us?

We will retain your personal data only for as long as is necessary under law. We maintain specific records management and retention policies and procedures, so that personal data are deleted after a reasonable time according to the following retention criteria:

• We retain your data as long as we have an ongoing relationship with you (in particular, if you have an account with us).
• We retain your data for as long as needed in order to comply with the applicable laws and contractual obligations.

Which rights do you have with respect to the processing of your personal data?

You are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:

• Request access to the personal data we process about you: this right entitles you to know whether we hold personal data about you and, if we do, to obtain information on and a copy of that personal data.
• Request a rectification of your personal data: this right entitles you to have your personal data be corrected if it is inaccurate or incomplete.
• Object to the processing of your personal data: this right entitles you to request that Transcorp no longer processes your personal data.
• Request the erasure of your personal data: this right entitles you to request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes.
• Request the restriction of the processing of your personal data: this right entitles you to request that Transcorp only processes your personal data in limited circumstances, including with your consent.
• Request portability of your personal data: this right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of personal data that you have provided to Transcorp, or request Transcorp to transmit such personal data to another data controller.

To the extent that the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time by contacting Transcorp. Please note that this will not affect Transcorp’s right to process personal data obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent.

If, despite our commitment and efforts to protect your personal data, you believe that your data privacy rights have been violated, we encourage and welcome individuals to come to Transcorp first to seek resolution of any complaint. You have the right at all times to register a complaint directly with the relevant supervisory authority.

Do we include (links to) websites and programs of third parties?

Our websites may include:

• Links to and from the sites of our partner networks, advertisers and affiliates.
• Certain programs (widgets and apps) of third parties. Where this is the case, note that such third parties may process your personal data collected through such programs for their own purposes.

We do not accept any responsibility or liability for such third parties’ sites or programs. Please check such third parties’ terms of use and privacy statements before using and providing any information to such third parties’ sites and programs.

Contact us

Please contact us at info@transcorpint.com if:

• You have a general question about how Transcorp protects your personal data.
• You wish to exercise your rights in relation to your personal data rights.
• You wish to make a complaint about Transcorp’s use of your data.

Updates to this Privacy Policy

We may update this Privacy Policy from time to time. Please check back from time to time for updates. Continued use of our Transcorp’s website and other platforms after any change/ amendment to this Privacy Policy shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.