This Privacy Policy is adopted by Nea Life Private Limited (“NLPL/Us/Our/We/Company”), the owner and operator of https://nealife.in/ (“Website”) and you (“you/your/user/viewer/corporate client/candidate”), a user of the Website. The Company is committed to respecting your online privacy and recognizes the need for appropriate protection and management of any personally identifiable information you share with us. This Privacy Policy describes how the Company collects, uses, discloses and transfers to third persons the Personal Information of users through its Website and applications, including Assess i.e., its web portal or through its mobile applications and online services (collectively, referred to as the “Platform“).

Applicability:-
This Privacy Policy applies to those who visit the Platform, or whose information NLPL otherwise receives in connection with its services (such as contact information of Candidates/ Clients) (hereinafter collectively referred to as “Users“).

Interpretation:-
This Privacy Policy shall be read in conjugation with the Terms of Use/ TOU, provided at TOU and all capitalised terms not defined herein, shall be construed to have the same meaning as that under the TOU. By visiting and/or using our Website, you agree to the provisions of this Privacy Policy.

Personal Information:-

“Personal Information” means any information relating to an identified or identifiable natural person including common identifiers such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person and any other information that is so categorized by applicable laws.

Grounds of collecting Personal Information:-

1. Consent: By accessing and using the Platform, You provide your specific and express consent to process your Personal Information in a manner provided in this Policy.
2. Compliance with applicable laws: In addition to the purposes/uses specified in this Policy, your Personal Information may be processed by NLPL, to the extent that such processing is necessary to allow NLPL to comply with a legal obligation. An example of this would be if NLPL is required to disclose your Personal Information to respond to a court order or if NLPL is required to retain specific records for a fixed period to comply with requirements under any applicable law, or if so required by the Clients, pursuant to a recruitment procedure (as applicable).

Information we collect:-
We collect information, including Personal Information (“Information”), as mentioned herein-below, based upon your interaction with us through the Platform:

• Information you post: We collect Information you post in a public space or on a third-party social media site/ platform that you may choose to register with us, or to authenticate your profile.
• Information posted while registering/ signing up: We collect Information, including full name, education board, class, age, location, stream, experience, organization, email address, password, country, city, contact number when you sign up on the Platform.
• Information shared while taking assessments on the Platform: We collect Information that you submit while taking assessments on the Platform, pursuant to a recruitment procedure, or otherwise.
• Other Information: If you use our Platform, we may collect Information about your IP address, browser and duration of usage of our Platform. We might also collect the type of mobile device you are using, and the version of the operating system of your computer or device. We make no attempt to link these addresses with the identity of individuals visiting our Platform, unless an attempt to damage the Platform, or the reputation of NLPL and/ or its officers/ directors/ affiliates, is suspected.
• We do not knowingly solicit, collect, or share information from any individuals under the age of 18 (“Minor”). Any information provided by a Minor shall be deemed to have been provided by the guardian of the Minor and subject to parental consent/supervision.

We collect Information in different ways:-

• We collect Information directly from you:

1. 1. We collect Information directly from you when you register on the Platform and other details shared by you on the Platform.
   2. We also collect Information if you post a comment on our Platform or contact us through phone or email, for communication purposes.
   3. We collect Information when you voluntarily choose to link your social media profiles with us, for registering on the Platform.
   4. We collect Information when you undertake assessments, or review the assessments as part recruitment procedure, on the Platform (as may be applicable).

• We collect Information from you passively:

1. 1. We use tracking tools like browser cookies and web beacons for collecting Information about your usage of our Platform.
   2. When you visit the Platform, we use cookies to automatically collect, store and use technical information about your system and IP address, device and device location, and interaction with our Platform;
   3. When you use a device to access the Platform, we may collect technical or other related information from the device as well as the device location.
   4. The cookies you consent to, are also used to collect your Personal Information, for the purpose of recruitment opportunities, and we will not share your details with any advertiser or advertising concern.
   5. We use cookies to compile anonymous, aggregated statistics that allow us to understand how the Users use our Platform and to help us improve the interface, content, assessments tools, etc.

Cookie management on the Website:-
A “Cookie”, or HTTP/ Internet Cookie, is a small text file that is built specifically for Internet web browsers to track, personalize, and save information about each user’s session (i.e., time spent on a website) and may be used, for example, to collect information about website activity. Some cookies and other technologies may serve to recall Personal Information previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. There are many ways to manage your cookies:

• You can refuse your consent; or
• You can disable NLPL or third-party cookies by use of your browser’s cookie settings.

Most internet browsers are initially set up to automatically accept cookies. If you do not want our Platform to store cookies on your device, you can change your browser settings in order to receive a notification before certain cookies are stored. You can also adjust your settings so that your browser refuses most of our cookies and only accepts certain and/ or necessary cookies. You can also withdraw your consent to cookies by deleting the cookies that have already been stored. However, disabling cookies might impact your experience while on the Platform, like restricting the use or facilities, or unique User-experience that you may avail through the same.

Use of your Personal Information:

• We use Information to contact you: We might use the Information you provide for communicating with you, including without limitation for the purpose of or in connection with an assessment, alert and/or the development of the Website for better user experience.
• We use Information to respond to your requests or questions: We might use your Information to communicate with you, with respect to your queries and/ or requests and providing customer support.
• Providing services on the Platform: We might use the Information you provide for providing our services including to send you alerts related to career, mental health, wellbeing and work opportunities which we find suitable on the basis of your use of the NEA Life Platform (as the case maybe), and other allied services.
• Advertisements: We might use your Information to inform you of updates to our services, security alerts, and other support and administrative messages of the Company. We may also use the Information to communicate with you about products, services, offers, promotions, and events, and provide other news and information we think will be of interest to you.
• Shortlisting profile: We use the Information provided by you on the Platform, to shortlist your profile for work opportunities or alerts related to career, mental health and well-being, based upon the assessments undertaken by you on the Platform.
• Assessments: We use the Information to update the AI platform to analyse your profile and also to provide you with the results of assessments conducted on the AI platform.
• Improvement of our Services: We may use the Information to monitor and analyze trends, usage, and activities in connection with the services we provide.
• Preventing fraud: We may collect and use the Information shared by you for preventing, detecting, investigating and taking action against crimes (including but not limited to fraud and other financial crimes), any other illegal activities, suspected fraud, or violations of NLPL’s Terms of Use in any jurisdiction.

Period of storing Information:-
NLPL will retain your Information no longer than it is required for the purposes for which the Information may lawfully be used or is otherwise required under any law in force. In some cases such Information must be kept for considerable periods of time, including, without limitation, until the resolution of disputes, if any, and/or pursuant to a recruitment procedure, and the like. Retention periods of such Information shall be determined for each Information that is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused Information at the earliest reasonable opportunity. We design our services in a manner in which we will hold your Information only till and as required.

Sharing of Information with Third-Parties:-
We restrict access to your Personal Information to employees/ Clients (if and as applicable) who we believe reasonably need to know such Personal Information, in furtherance of or in relation with the services through our Platform, as applicable from case to case.

NLPL does not disclose, transfer or share your Personal Information with others, except for:

1. its internal business and/or administrative purposes and/or general corporate operations may share the information with its holding, subsidiary and associate companies;
2. provision of services aimed at helping and supporting you in securing the appropriate alerts related to career, mental health, wellbeing and work opportunities which we find suitable on the basis of your use of the Platform, or selecting the appropriate Candidate (as the case may be);
3. Potential recruiters amongst Clients, if we determine that your profile and assessments undertaken matches with a particular work opportunity available with such recruiters. By registering on the Platform and consenting to the terms of this Privacy Policy, you agree that NLPL may contact you with respect to such work opportunities;
4. Third parties including enforcement, regulatory and judicial authorities, if we determine that disclosure of your Personal Information is required to a) respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims; or b) investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of NLPL’s Terms of Use or as otherwise required by law;
5. In the event of a merger, acquisition, financing, or sale of assets or any other situation involving the transfer of some or all of NLP’s business assets we may disclose Personal Information to those involved in the negotiation or transfer.
6. Third party service providers and marketing partners that NLPL engages in connection with its services on the Platform. NLPL shall take reasonable steps to ensure that these third-party service providers are obligated to protect your Personal Information (to the exception of regulatory authorities) and are also subject to appropriate confidentiality / non-disclosure obligations.

Financial Information:
NLPL does not collect any account related information or any credit / debit card details that you may input while registering a corporate account on the Platform (if and when applicable). However, payment gateways are linked to the Platform wherein Clients may avail of while registering on the Platform. For the sake of easy accessibility and convenience of the Users, the Platform facilitates the saving of details of credit/ debit card or any other payment options available, for future transactions. NLPL shall not be liable for any loss or damage sustained by Users as a result of any disclosure (inadvertent or otherwise) of any information concerning the User’s account, credit cards or debit cards in the course of any online transactions or payments made for any services offered through the Platform and that the same shall be governed by the privacy policy and terms of the applicable payment gateway used by the User. In case any Personal Information is shared by you with NLPL, which is not requested by NLPL during registration, (whether mandatorily or optionally), NLPL will not be liable for any information security breach or disclosure in relation to such information.

Securing Information Collected:-
We value the integrity and security of your Information and that of your family members (if provided to us) and therefore, we have designed the Platform and our services with a dedicated team and resources to oversee the safekeeping and confidentiality of your Personal Information. We undertake best efforts and industry practices to protect and secure your Information, irrespective of where such Information is transferred or stored. At NLPL, we have the physical, electronic, and procedural safeguards in compliance with the laws prevalent in India to protect your Personal Information. Your access to the Platform shall signify your agreement with our standards and practices being commensurate with the applicable laws, including without limitation the Information Technology Act, 2000 and Rules made thereunder.

However, we hope you agree and understand that, like every technology-based platform, the Platform may be subjected to technical errors/ breaches that is not under NLPL’s control. If you have any concerns that your account or Personal Information shared on the Platform has been put at risk or breached, please get in touch with the Grievance Officer appointed under this Privacy Policy to support us in resolving the same.

GOVERNING LAW:-
We are based in India and the information we collect is governed by Indian Laws. By accessing or using the Platform or otherwise providing Information to us, you consent to the processing, transfer, and storage of information in and to India and other countries, where you may not have the same rights as you do under local law.

GRIEVANCE OFFICER:-

1. In accordance with Information Technology Act, 2000, and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, the name and contact details of the Grievance Officer appointed by the Company are provided below:

Grievance Officer,
3rd Floor, Demach House,
Law College Rd, Pune,
Maharashtra – 411004
Phone: +91 7788992270
Email: info@nealife.in

2. You also have certain rights with respect to the Personal Information provided by you. You may request NLPL to remove/update/rectify/edit/complete/port/restrict from processing your data. You may send your requests/ grievances (if any) to the above stated Grievance Officer and your requests will be processed and/ or grievances shall be resolved by NLPL within one month of receiving the requests, unless communicated otherwise.

YOUR RIGHTS:-
You are in control of your Personal Information. You have the right to: a) rectify, update or correct your Personal Information; b) obtain confirmation on whether or not your Personal Information is being or shall be processed; c) access your Personal Information or exercise your right to data portability; or d) exercise your right to restrict the continuing disclosure of your Personal Information to any third party; e) request us for a copy of your Personal Information; f) delete your Personal Information or to request that we only use it for certain purposes, or ask us to completely stop using the same.

UPDATES TO THIS POLICY:-
This Privacy Policy may be updated from time to time. We will notify you of any material changes to the same, if and as required by law. We will also post an updated copy of the same on our Website. Please check our Website periodically, for updates.

Disclaimer: This Privacy Policy has been published in accordance with the provisions of Rule 3 (1) of the Information Technology (Intermediaries guidelines) Rules, 2011, Rule 4(1) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and other applicable laws.