Pluxee India Private Limited Privacy Policy
Purpose of this Policy
The following information is provided to you to inform you of the categories of Personal Data that are subject to collection andProcessing when using websites, portals, applications, and platforms (our “Site” or “Sites”) how we (Pluxee India PrivateLimited) use this Personal Data, and with whom we are likely to share it. This policy also describes your rights and how you can get in touch with us to exercise these rights or to ask us any questions you might have concerning the protection of yourPersonal Data.
Pluxee India Private Ltd (formerly known as Sodexo SVC India Private Limited) builds strong, lasting relationships with its customers, partners, and consumers based on mutual trust, making sure that their Personal Data is safe and remains confidential is an absolute priority for Pluxee India Private Ltd.
Pluxee India Private Ltd is committed to complying with all applicable regulatory and legal provisions governing the protection of Personal Data.
Pluxee India Private Ltd enforces a very strict privacy policy to guarantee the protection of the Personal Data of those who use its Sites:
- Users remain in control of their own data. The data processed in a transparent, confidential, and secure manner.
- Pluxee India Private Limited is committed to a continuing quest to protect its users’ Personal data in accordance with the Digital Personal Data Protection Act,2023 and Information Technology Act, 2000, The Information Technology(Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 and all the applicable laws as may be notified by the government from time to time.
- Pluxee India Private Limited has a Data Protection Officer/Privacy Leader who can be contacted by email at the following email address: privacy.in@pluxeegroup.com
This policy may be amended, supplemented, or updated, in particular to comply with any legal, regulatory, case law, or technical developments that may arise. However, your Personal Data will always be processed in accordance with the policy in force at the time of the data collection, unless a compulsory legal prescription determines otherwise and must be enforced retroactively.
Identity and contact details of the Data Fiduciary
The Data Fiduciary is:
Pluxee India Private Limited 503 & 504, 5th Floor, B Wing, Hiranandani Fulcrum, Sahar Road, Andheri East, Mumbai, Maharashtra, India, 400099
Definitions
| “Data Fiduciary” | Means any person who alone or in conjunction with other persons determines the purpose and means of processing of personal data. In thisPolicy “Data Fiduciary” means Pluxee India Private Limited. |
|---|---|
| “Personal Data” | Means any information or pieces of information that could identify youeither directly (e.g., your name) or indirectly (e.g., through pseudonymized data such as a unique ID number). This means that personal data includes things like email/home addresses/mobile phone, usernames, profile pictures, personal preferences, user generated content, financial information, and welfare information. It could also include unique numerical identifiers like your computer’s IP address or your mobile device’s MAC address, as well as cookies. |
| “Processing” | Means in relation to personal data, means a wholly or partly automated operation or set of operations performed on digital personal data, and includes operations such as collection, recording, organisation, structuring, storage, adaptation, retrieval, use, alignment or combination, indexing, sharing, disclosure by transmission, dissemination or otherwise making available, restriction, erasure or destruction |
| “Processor” | Meansany person who processes personal data on behalf of a Data Fiduciary. |
| “us” “we” or “our” | Pluxee India Private Limited acting as Data Fiduciary. |
| “you” or “Users” | Any Site user/visitor or beneficiary of the Services. |
How will your Personal Data be collected? Is it mandatory thatyou or others provide your Personal Data?
We may collect your Personal Data in the ways listed below:
- Collection of your Personal Data directly from you, such as when your complete forms on our Sites; and
- Collection of your Personal Data indirectly during your navigation on the Site or via our service providers and/or technologies on our Sites.
- Collection of your Personal Data for our regulatory requirements for Know Your Customer (KYC).
We will collect your Personal Data on a mandatory basis where this is required by applicable local laws or where this isnecessary for the performance of the Services on the Site.
If we are unable to collect these mandatory Personal Data items, we will not be able to manage your access to the Site.What Personal Data does Pluxee India Private Limited hold? For which purposes and on which legal basis will yourPersonal data be collected and processed?
We may process, use, and disclose your Personal Data for certain purposes, as detailed below, connected to your use of theSite and to the services we provide.
We will collect and process your Personal Data as detailed below (without this list being exhaustive) where necessary to provide you an access to the Site, or when it is necessary for compliance with a legal obligation to which we are subject. We will also process your Personal Data for Pluxee India Private Limited’s legitimate use, except where such interests are overridden by your interests or fundamental rights and freedoms. Where certain legitimate uses do not apply as a lawful basis for theProcessing of Personal Data under the applicable Data protection laws, explicit consent will be alternatively collected as required by law.
| Data Processing activities | Purposes | Categories of Personal Data | Legal basis |
|---|---|---|---|
| Cookies |
Personalization of the Site and enhancement of the experience. A more detailed description of how and why cookies might be used on the Sites is at your disposal on our web page |
IP address Cookies Statistical data |
Consent |
| Site navigation | Compliance to legal obligations |
Identification data(name, surname, image- if you provided it) Technical data (time anddate of connection,meta data |
Consent |
| Account Creation and Management | Send an initial communication via email to invite you to register and use our Sites and Services |
Name |
Consent and Legitimate Use |
| Register you as a user and create an account for you on our Site |
Name Email ID User and Password KYC details Mobile No |
Contractual necessity | |
| Communication with Users | Collect and process requests fromUsers contacting Pluxee IndiaPrivate Ltd |
Email address Any Personal Data provided by the Users in their request |
Legitimate Use |
| Customer Relationship Management | Collect and process your data to manage customer relationships, respond to inquiries and newsletter requests, sending communication about commercial products assess eligibility for products and services, process and deliver orders, and comply with legal obligations. |
Name Email ID Age Information regarding order if any |
Legitimate Use Consent (In case of marketing, newsletter etc) |
| Marketing Management | Use your data to conduct surveys, compile statistics, manage competitions and promotions, send you relevant commercial communications, and better understand your preferences through internal profiling. These activities help us tailor our products, services, and marketing to your interests while continuously improving our offerings. |
Name Email ID Mobile number |
Consent |
| Webcast for investors | Allow investors to access the platform and enable Pluxee to compile statistics to monitor the audience and to get in touch with its investors | Identification data (name, surname, company, and position) Email address |
Legitimate Use |
| Other | Any other purpose that we may specify to you at the time of collection and described in a specific privacy policy | Determined at the time of collection and described in a specific privacy policy | Determined at the time of collection and described in a specific privacy policy |
Who will have access to your Personal Data?
Pluxee India Private Limited is part of an international group under the brand Pluxee (the “Pluxee group”). There is a possibility of transfers of your Personal Data within or outside of the Pluxee group.
- Within the Pluxee India Private Limited
The security and confidentiality of your Personal Data is of great importance to us and of the Pluxee group. This is why westrictly restrict access to your Personal Data to members of our staff and only to the extent strictly necessary to process yourPersonal Data or provide the services necessary for the Site. We ensure that the persons authorized to process the PersonalData have commited themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.
- Outside of the Pluxee India Private Limited
We will not disclose your Personal Data to any unauthorized third parties. We may, however, share your Personal Data with authorized service providers (for example, service providers for data hosting, maintenance, external consultants, etc.) whom we may call upon for the purpose listed above in compliance with the applicable data protection laws.
All third-party service providers to whom we have disclosed and transferred your Personal Data have been engaged under a binding confidentiality and data processing agreement with Pluxee India or the Pluxee Group.
If you have any questions or wish to have details on those safeguards, you can contact Pluxee India Private Limited the DataProtection Officer/Privacy Leader Pluxee India Private Limited by email at the following email address privacy.in@pluxeegroup.com
Furthermore, we may share your Personal Data (i) if the law or a legal procedure requires us to do so, (ii) in response to a request by public authorities or other officials, or (iii) if we are of the opinion that transferring this data might be necessary or appropriate to prevent any physical harm or financial loss, or in respect of an investigation concerning a suspected or proven unlawful activity.
How long will your Personal Data be held?
We will store your Personal Data only for as long as necessary to fulfill the purposes for which it was collected and processed.This period may be extended, if applicable, for any amount of time prescribed by any legal or regulatory provisions that may apply.
The specific retention periods associated to each purpose are listed in the table above.
| Categories of Personal Data | Purposes | Retention period |
|---|---|---|
|
IP address Cookies Statistical data Identification data (name, surname, image - if you provided it) Technical data (time and date of connection, meta data |
Personalization of the Site and enhancement of the experience. Compliance with legalobligation |
Maximum of 13 months (depending on the category the cookie belogs to). For more details, please refer to Cookie policy As long as necessary for processing |
|
Name Email ID user and Password KYC details Mobile No |
Send an initial communication via email to invite you to register and use our Sites and Services. Register you as a user and create an account for you on our Site |
If you are one of our customers, these communications may be sent to you for the duration of our commercial relationship, then for ten (10) years after the end of this relationship or of the last contact you initiated. If you are not yet sure whether you want to benefit from our products and Services, and you are still in the prospecting phase, we can send you communications on our offers and products for a period of three (3) years from the last contact you initiated. |
|
Email address Any Personal Data provided by the Users in their request. |
Collect and process requests from Users contacting Pluxee India Private Ltd | As long as necessary for the processing of your request |
|
Name Email ID Age Information regarding order if any |
Collect and process your data to manage customer relationships, respond to inquiries and newsletter requests, sending communication about commercial products assess eligibility for products and services, process and deliver orders, and comply with legal obligations. |
We will keep your Personal data for the duration of our commercial relationship and thereafter for a period of 10 years as required by our regulator RBI under Payment and Settlement Systems Act, 2007, after which only the data necessary for pre-litigation or litigation purposes will be archived until the legal prescription is acquired. The usual limitation period in civil and commercial matters is three (3) years. In the event of a dispute, this data is kept for the duration of the procedure and until the expiration of ordinary and extraordinary remedies. |
|
Name Email ID Mobile number |
Use your data to conduct surveys, compile statistics, manage competitions and promotions, send you relevant commercial communications, and better understand your preferences through internal profiling. These activities help us tailor our products, services, and marketing to your interests while continuously improving our offerings. |
If you are one of our customers, these communications may be sent to you for the duration of our commercial relationship, then for three (3) years after the end of this relationship or of the last contact you initiated. If you are not yet sure whether you want to benefit from our products and services, and you are still in the prospective phase, we can send you communications on our offers and products for a period of three (3) years from the last contact you initiated. |
|
Identification data (name, surname, company, and position) Email address |
Allow investors to access the platform and enable Pluxee to compile statistics to monitor the audience and to get in touch with its investors | As long as necessary for the processing of your request. |
Finally, please note that we may anonymize your Personal Data in such a way that you can no longer be identified and continueto use it for statistical purposes. Data processed for statistical purposes is no longer classified as Personal Data once it has been duly anonymized.
Sensitive Personal Data
As a general rule, we do not collect sensitive Personal Data via our Site or to provide our services. Please note that our contact forms are not intended to collect any sensitive Personal Data. You should therefore limit your input to what is strictly necessary regarding your request when sending us an email, contacting us through a contact form or by any other mean.
“Sensitive Personal data refers to any information concerning a person’s racial or ethnic origins, political opinions, religious or philosophical beliefs, union membership, health data, or data relating to the sexual life or the sexual orientation of a natural person. This definition also includes Personal Data relating to criminal convictions and offenses.
In the exceptional event that it would be strictly necessary to collect such data to achieve the purpose for which the Processing is performed or if you provide us with such data, for instance when you send us an email), we will process such data in accordance with local legal requirements for the protection of Personal Data and in particular, with your explicit prior consent and under the conditions described in this policy.
What are your rights in connection with your Personal Data and how can you exercise those rights?
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes by updating your account on the Site.
Pluxee India Private Limited is committed to ensuring protection of your privacy rights under applicable laws. You will find below a table summarizing your privacy rights under the applicable data protection law, which applies to all Personal Data processed on the Site.
| Rights | Description of your rights |
|---|---|
| Right to Access Information |
You have the right to request and obtain from us:
Please note, sharing personal data with other Data Fiduciaries authorized by law for purposes such as prevention, detection, investigation, prosecution, or punishment of offences or cyber incidents is exempt from this disclosure. |
| Right to Correction and Updation |
You have the right to request correction, completion, updating, or erasure of your personal data for which you have previously given consent, in accordance with applicable laws. Upon receiving such a request, we will:
|
| Right to erasure |
Your right to be forgotten entitles you to request the erasure of your Personal Data in cases where:
The Company needs to retain the data atleast for 10 years under Payment and Settlement Systems Act, 2007 and its Rules and Regulations including Master Directions issued by Reserve Bank of India (the Act). Hence the Right to erasure can be exercised post completion of mandatory period for which the entity needs to retain the data to ensure compliance with the Act. |
| Right to Nominate | You have the right to nominate an individual who, in the event of your death or incapacity (due to mental unsoundness or physical infirmity), may exercise your rights under the applicable data protection laws on your behalf. |
| Right to Grievance Redressal |
You have the right to access grievance redressal mechanisms provided by us regarding any concerns or complaints related to the processing of your personal data or the exercise of your rights under applicable data protection laws. We will respond to grievances within the prescribed timeframes, and you are encouraged to utilize the mechanisms mentioned below before seeking further legal recourse. |
| Right to withdraw consent | In the circumstances where you may have provided your specific consent to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. When you provide your consent, you will ordinarily be provided with the method to withdraw it. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. |
To exercise these rights, you can:
Use the online Request webform: This electronic system allows you to log in and see the progress of your request, see and send messages and review your documents securely. This system is provided by One Trust and after making the request you will be sent details about how to log on.
You can also raise queries or complaints with the Data Protection Officer/Privacy Leader of Pluxee India PrivateLimited by email at the following email address privacy.in@pluxeegroup.com.
No fee is usually required.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
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.
For more details, please consult the Data Protection Rights Management Policy.
How will your Personal Data be protected?
We implement all possible technical and organizational security measures to ensure security and confidentiality in Processing your Personal Data.
To this end, we take all necessary precautions, given the nature of the Personal Data and the risks related to its Processing, in order to maintain data security and, in particular, to prevent distortion, damage, or unauthorized third-party access (physical protection of the premises, authentication procedures with personal, secured access via identifiers and confidential passwords, a connection log, encryption of certain data, etc.)
In addition, if we contract with Processors for all or part of the Processing of your Personal Data, we require a contractual agreement from our service providers to guarantee the security and confidentiality of the Personal Data that we transmit to them or that they collect on our behalf, in accordance with the applicable regulations on the protection of Personal Data.
We regularly conduct audits to verify the proper operational application of the rules relating to the security of your Personal Data.
Nevertheless, you also have a responsibility to ensure the security and confidentiality of your Personal Data so we invite you to remain vigilant, especially when using an open system such as the Internet.
Links to other sites/platforms
Occasionally, we provide links to other platforms for practical and informative purposes. These platforms operate independently from our Sites and are not under our control. These platforms have their own privacy policies or terms of use, which we strongly advise you to read. We do not accept any liability with regards to the content on these platforms, for the products and services that may be offered there, or for any other use thereof.
Children users under the age of [18 years or without legal capacity must obtain consent from their legal guardians prior to submitting their Personal data to the Site.
How will you be notified if the uses of your Personal Data change?
We may update or amend this policy as and when needed. In this case, amendments will only become applicable after a period of days from the date of the amendment. Please consult this page from time to time if you want to be informed of any possible changes.
If you have any questions or comments with regard to this policy, please do not hesitate to contact us at the following -privacy.in@pluxeegroup.com