India Personnel Privacy Notice

Information Specific to India Employees and Applicants

This India Personnel Privacy Notice (“Notice”) describes how LiveRamp India Private Limited a private company, with its principal place of business at 90/31-B, F/F, Malviya Nagar Extn., New Delhi , Delhi, India - 110017 (“LiveRamp”, “We”), collects, uses, and discloses personal data about job applicants, our individual employees (current and former employees), contractors, and their beneficiaries and emergency contacts who are residents of India in the context of our working relationship with the relevant individuals (“Personal Data”). We may update this Notice at any time. We may also provide you additional privacy notices regarding our collection, use or disclosure of data.

This Notice does not form part of any employment contract or contract to provide services. If you provide services to LiveRamp through or in connection with another company, we are not responsible for that company’s privacy practices.

This Notice does not apply to our handling of data gathered about you in your role as a consumer using LiveRamp’s websites or as a client of LiveRamp products. 

1. Types of Personal Data We Handle

We collect, store, and use various types of personal data through the application and recruitment process or during the relevant engagement or employment with us. We collect such data either directly from you or (where applicable) from another person or entity, such as an employment agency or consultancy, background check provider, or other referral sources.

The type of data we have about you depends on your role with us and may include, where applicable:

Identification and contact information and related identifiers such as full name, date and place of birth, citizenship and permanent residence, home and business addresses, telephone numbers, email addresses.

Professional or employment-related information, including:

• Recruitment, employment, or engagement information such as application forms and information included in a resume, cover letter, or otherwise provided through any application or engagement process; and copies of identification documents, such as driver’s licenses, passports, and visas; and background screening results and references.
• Career information such as job titles; work history; work dates and work locations; employment, service or engagement agreements; appraisal and performance information; information about skills, qualifications, experience, publications, speaking engagements, and preferences (e.g., mobility); absence and leave records; professional memberships; disciplinary and grievance information; and termination information.
• Financial information such as salary, payroll, pension or retirement contribution information; and bank account and tax information.
• Business travel and expense information such as travel itinerary information, corporate expenses and Company credit card usage.

Education Information such as institutions attended, degrees, certifications, training courses, publications, and transcript information.

Internet, electronic network, and device activity and device information and related identifiers such as information about your use of the LiveRamp’s network, information, and communication systems, including user IDs, passwords, IP addresses, device IDs, web logs, and audit trails of system access.

Geolocation information for device recovery if you use a LiveRamp-issued device.

Audio or visual information such as CCTV footage, as well as other information relating to the security of our premises; recorded presentations in which you participate; and photographs taken at LiveRamp functions.

Biometric information that we use for authentication and security purposes, such as imagery of the face (for ID pictures).

Classification information such as race, sex/gender, gender identity/expression, sexual orientation, marital status, military service, nationality, ethnicity, request for family care leave, and criminal history.

Health information about you, and, if applicable, your beneficiaries, such as medical conditions and other information provided in statements of health forms, disability status, health and safety incidents or accidents, sickness records, and health issues requiring adaptations to your working environment or working practices.

2. How We Use Personal Data

We collect, store, use, and disclose personal data for LiveRamp’s and its affiliates’ business purposes, which include, where applicable:

HR management and administration, including training, compensation and benefits, invoices,  leave, scheduling, career development, performance appraisals and recognition, investigating and resolving inquiries and complaints, providing references, succession planning, organizational changes, preparing analyses and reports, and communicating with our workforce about updates or relevant information about perks, benefits and discounts, and changes to LiveRamp products and services.

Performance of business operations, including providing and monitoring IT systems for any lawful purpose; maintaining accounts and internal directories, crisis management, protecting occupational health and safety; participating in due diligence activities related to the business; business succession planning and conducting internal analyses and audits.

Recruitment, including job advertising, interviewing, and selecting and hiring new staff.

Security operations, including detecting security incidents, debugging and repairing errors, and preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution; and monitoring and controlling logical and physical access to LiveRamp devices, data, premises and locations (including through use of CCTV).

Legal Compliance such as complying with anti-bribery, tax, social security and immigration obligations, and responding to and cooperating with legal or regulatory requests and investigations.

LiveRamp may collect about you: the categories of data summarized in the table below. The following table also describes how we use such categories of data.

3. Lawful basis for data processing

LiveRamp processes personal data of employees (and their beneficiaries and emergency contacts) on the following basis:

• where you have provided express consent;
• where such processing is necessary for compliance with a legal obligation to which we are subject; and
• where such processing is necessary for certain legitimate uses, in accordance with applicable law.

Additionally, LiveRamp processes personal data of job applicants and contractors (and their beneficiaries and emergency contacts) on the following basis:

• where you have provided express consent; and
• where such processing is necessary for compliance with a legal obligation to which we are subject.

4. With Whom We Disclose Personal Data

‍ We will disclose workforce personal data to the following types of entities or in the following circumstances (where applicable). 

• Internally: To people within LiveRamp (including its affiliates) to carry out the purposes described in this Notice, including to your manager, human resources, as well as personnel within LiveRamp, such as payroll, IT, legal, internal audit, compliance, and finance.
• Service Providers: Such as compensation and benefits providers, tax and other professional advisors, external auditors, technology service providers, corporate card issuers, travel management providers, travel providers, human resources suppliers, background check companies, and employment businesses (in relation to contractors or agency workers).
• For Business Operations: To provide another entity (such as a potential or existing business counterparty or customer) with a means of contacting you in the normal course of business, for example, by providing your contact details, such as your phone number and email address.
• Legal Compliance: When required to do so by law, regulation, or court order or in response to a request for assistance by the police or other law enforcement agency.
• Litigation Purposes: To seek legal advice from our external lawyers or in connection with litigation with a third party.
• Business Transaction Purposes: In connection with the sale, purchase, or merger of a business.

5. Data Security

LiveRamp takes protection of your data seriously and has implemented appropriate technical, organisational, and physical measures to prevent your personal data from being accidentally lost, altered, disclosed, or used or accessed in an unauthorised way. In addition, we limit our internal access to your personal data to our employees, agents, contractors, and other third parties who have a legitimate business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have also put in place procedures to deal with any suspected personal data breach, and we will notify you and any applicable regulator(s) of a breach where we are legally required to do so.

6. Data Retention

LiveRamp will retain information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine LiveRamp’s retention periods include: (i) the purposes for which the data was collected; (ii) the length of time business partners obligate LiveRamp to retain or delete data based on their data collection practices and privacy obligations; (iii) whether there is a legal obligation to which LiveRamp is subject; (iv) whether retention is advisable in light of LiveRamp’s legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations); and (v) whether you have requested that we delete your personal information. 

7. Exercising Rights and Choices

You have the following rights in respect to your personal data that we process:

• Right to access: Where we process personal data on the basis of your consent, you may submit a request to access:
  
  • A summary of your personal data being processed by us along with information on the processing activities undertaken by us.
  • The identities of the third-parties with whom we have shared your personal data along with a description of such personal data.
• Right to correct, complete or update: Where we process personal data on the basis of your consent, you may submit a request to correct inaccurate or misleading personal data, complete incomplete personal data and update personal data.
• Right to withdraw: Where we process personal data on the basis of your consent, you may submit a request to withdraw consent to processing of personal data.
• Right to erase: Where we process personal data on the basis of your consent, you may submit a request to erase your personal data in our possession. Upon receipt of such a request, we will erase your data as soon as reasonably practicable, unless we are required to retain your personal data for compliance with applicable law.
• Right to nominate: You may submit a request to nominate an individual who may, in the event of your death or incapacity, exercise your rights with respect to us processing your personal data.
• Right to grievance redressal: You have a readily available means of grievance redressal in respect of any act or omission in relation to our obligations under applicable law.

To exercise these rights, please refer to the ‘How to Contact Us About this Notice’ section below.

When we receive a request to exercise one of these rights, we may require you to validate your identity. 

8. Cross-border transfer of your personal data

We may transfer your personal data to our affiliates within the LiveRamp group located outside India for management purposes. We may also transfer your personal data to third-party service providers and business partners located outside India where necessary for these purposes.

When we transfer your personal data outside of India, we will comply with transfer restrictions and conditions, if any, which may apply to transfer of your personal data overseas. 

9. How to Contact Us About this Notice

If you have questions about exercising your rights with respect to your employee or applicant personal data, please contact your HRBP or recruiter. Information submitted thereto may be seen by internal employees and contractors outside of the Legal and People and Culture departments.