Caliber Privacy Policy
This Privacy Policy statement is made by the Caliber Group consisting of Caliber Technologies Private Limited, Caliber Infosolutions Inc and CALIBER TECHNOLOGIES B.V., a subsidiary of Caliber Technologies Private Limited.
Objective
Caliber is committed to protection of personal data of customers throughout the cycle of software development, implementation, and maintenance. This commitment begins with the marketing process, follows during the different phases of software development and implementation, and continues beyond the maintenance period too, if the contractual agreements require the same.
This Policy is aimed at ensuring confidentiality while handling personal data of the following entities:
- Customers and Potential customers and marketing leads engaged with the Caliber team
- Caliber website visitors and those who attempt to contact the Caliber team through emails, its marketing channels, event collaborators and partners
2. Scope of the Privacy Policy
2.1 In Scope
The Privacy Policy shall be applicable to all activities involving processing of personal data of
- Customers, potential customers, and leads during the process of sales and marketing of Caliber products and services
- Customers during the process of implementation and maintenance of Caliber products and services
- Caliber website visitors and those who attempt to contact the Caliber team through emails, its marketing channels, event collaborators and partners
2.2 Out of Scope
The design of Caliber products with respect to security and privacy is outside the scope of this policy, which is dealt with by the Caliber Data Protection and Privacy Policy.
It also does not deal with Caliber’s internal data and information assets.
3. Aspects of data collection
The different aspects of customer data collection are explained below through the concept of 5 “W” s of data collection.
3.1 Type of data collected (What data)
Caliber collects information about the Caliber Website visitors, potential customers, users of Caliber’s products and services, and others who contact Caliber through events, marketing channels, forms or email addresses published on our website or in pages linked to the same.
Operations that collect customer data include sales, marketing, project implementation and support.
3.1.1 Sales and Marketing
During the sales and marketing process, the following data is collected about the contact persons in the customer’s or potential customer organization:
3.1.1.1 At the time of Visits to Websites and Social Media Sites
Data gathered from the Caliber website and social media sites to track customer interests shall include:
- IP addresses from which the website visited
- Website page visit details
- Browser type, device details
- Behavioural data on the website such as pages opened, closed and pages clicked on
- Interactions on social media such as queries, comments, reviews, likes and dislikes
- Language preferences
- Other information that is publicly available
3.1.1.2 When Review Comments and Testimonials are Posted
3.1.2 Implementation and Support
As part of the implementation and support process, the data collected is categorized below:
- Data regarding SPOCs for implementation and support activities
- Names and contact details of SPOCs for product implementation and support
- Names of contact persons in the procurement, finance, IT, and other functions of the customer organization.
- Data for master creation of end-users of Caliber products
This activity shall be carried out with utmost care and in line with any existing NDA agreements or IT Security agreement with the customer and with the Caliber Data Protection and Privacy Policy.
3.2 Purpose for which the data is collected (Why)
3.2.1 Understanding Customer Interests
The data is collected to provide a better user experience and align the customer or prospective customer with the organization’s products, services, and marketing activities. Attitudinal data is collected in surveys and feedbacks to mainly gauge user experience, product requirements and other requirements.
The data gathered shall be analysed to provide inputs for the sales and marketing processes. The feedback received shall be used to improve communication with all customers and considered for improving the overall customer experience with Caliber products and teams. The nature of such sales and marketing activities is broadly listed below:
- Sending product brochures and responding to queries through emails
- Providing downloads on products and services
- Sending updates on changes to Privacy policy
- Conducting surveys and gathering feedback on our products and services
- Activities relating personal data in our products
3.2.2 Data collected as part of Implementation and Support Process
The information of the SPOCs of the respective end-user departments in the customer organization shall be recorded for the purpose of co-ordination during the project implementation and support process, as part of the communication and escalation matrix.
It shall also be used for communication with respect to processing purchase orders, payments, agreements, sharing information requested for the purpose of due diligence, audits, and other operational activities.
3.2.3 Provision for collection of personal data in Caliber Products
Caliber products are used by the corporate sector and the customers mainly belong to the pharma and life sciences domain. Caliber products provide the facility to store personal data of end users as part of the masters. This functionality is provided to help customers track their compliance with labour laws and provide evidence that they do not employ child labour.
3.3 At what stage is the personal data collected (When)
The data is collected during various stages of the sales and marketing process during online as well as offline activities such as
- Visiting the Caliber website
- Filling and submitting a form to download marketing material or white papers and for expressing interest in Caliber products and services
- Clicking on an advertisement put out by Caliber or its partners
- Showing interest in an event organized by Caliber
- Registering for an event organized by Caliber
- Subscribing to the Caliber newsletter
- Participating in surveys conducted by Caliber
- During implementation of Caliber products or support with respect to the same
3.4 For how long will the data be retained? (Till When)
Caliber shall retain the data as long as it engages with the customer, potential customer or lead. Information gathered from social media may be stored even if the account is deleted or closed by the user on the social media site if the engagement with the customer or potential customer continues beyond the period of account deletion or closure in the social media site.
3.5 Data storage (Where)
The data is securely stored in the backend of a contact management system with the utmost security. It is made available only to authorized users through an established approval process.
3.6 Responsibility for the Data (Who)
It is the responsibility of the person in-charge of the contact management system, or project implementation or project support, as the case may be, to ensure that the data is made available to authorized users only for the approved purposes.
Employees and independent contractors of all Caliber group entities have access to the collected data on a need-to-know basis for approved purposes and they are required to adhere to this Privacy Policy.
4. Method of Collection (How)
Caliber shall collect the data directly through email responses, survey responses and through forms filled by the customers and potential customers in various forums and events in which they participate and show interest in the Caliber products and services. Caliber website shall deploy third party cookies, wherever necessary.
Potential and existing customer engagement shall include interaction through the following:
- Social media pages
- Emails
- Paid advertisements
- Customer service channels
- Customer survey channels
4.1 Sales and marketing through Caliber partners
Caliber partners shall pass on details collected as part of the marketing process, for further analysis. Potential and existing customers may write to communications@caliberuniversal.com to get more details about the Caliber sales partners.
5. Rights of the Data Subject
5.1 Informed Consent
The data subject shall be informed that personal data shall be recorded BEFORE the collection process begins. Information shall be registered in the relevant database only after obtaining the informed consent of the data subject.
Optional information: The data subject can choose not to provide optional profile information such as a photo.
5.2 Withdrawal of Consent
The data subject shall be provided the opportunity to withdraw consent at any point of time. The data subject may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe’ function included in all such messages. The communication with respect to the customer’s projects and products shall however, continue.
The “Unsubscribe” option shall be available in every email communication. When a tool is used, it shall be ensured that the “Unsubscribe” option is available.
5.3 Right to obtain details about purpose and retention period
The data subject has the right to know the details of data collected and shall be provided this information on request. The details shall include the purpose of data collection, processing, data distribution and period of retention.
5.4 Right to rectification
Any data found to be inaccurate shall be rectified and updated based on the request received from the data subject. The information may be updated may be updated or deleted by the data subject or upon the request of the data subject. Where no specific facility for rectification has been provided to the data subject, the rectification shall be acted upon based on a request received through communications@caliberuniversal.com.
5.5 Right to erasure
A data subject may request for deletion of his or her personal data when the purpose for which it is collected, is either achieved, or no more relevant. This right shall be enforced within the permitted boundaries of any legally and contractually binding framework. Where the erasure is not possible due to such legally binding contracts or frameworks, the data subject shall be intimated that the erasure will not be possible for the reasons specified.
5.6 Right to restriction of processing
The purpose for which the data is used may be restricted by the data subject. This right shall be enforced within the permitted boundaries of any legally and contractually binding framework.
5.7 Right to object
The data subject has the right to object to the usage of the personal data if the purpose of usage of the data is not in line with the purpose for which the initial consent was provided.
5.8 Right to notification about security breaches
The data subject has the right to be informed about security breaches involving personal data. If such a breach occurs, the same shall be informed to the data subject within 24 hours of the breach coming to the notice of the Caliber team.
6. Exclusions to the Privacy Rule
DNT Signals: Our Website does not have the feature of recognizing Do Not Track signal sent by end-user browsers to avoid tracking the end user movements on the Caliber website.
Links to external websites, blogs, social media portals, chat forums, etc: The boundaries of the Privacy Policy extend to the boundaries of our website only. The links available on our website, to external sites, blogs, social media pages and chat forums are governed by the privacy policies of the respective external sites.
Legal obligations: In addition to use of personal data for the purposes informed at the time of obtaining consent, Caliber shall be legally obliged to share data with any investigation agencies or legal agencies for the purpose of compliance with applicable contracts or laws.
Social media widgets such as “Like” or “Share” or “Tweet” buttons: Our website may use social media widgets that allow our website visitors to like or share articles, product updates, event updates and so on. Such widgets collect data such as pages liked, or IP address used. Use of these widgets on our website shall be governed by the privacy laws of the respective sites.
7. Compliance with Privacy Laws
The Caliber Leadership is committed to protection of personal data and compliance with global privacy laws such as the EU GDPR. This is an ongoing effort, and the process is reviewed for continual improvement. If there is a change in the policy, Caliber shall update the same in the Caliber website. If there are any queries regarding the privacy policy, please write to us as at communications@caliberuniversal.com and the Caliber team shall be happy to address all concerns or questions.
8. Adherence to the Caliber Privacy Policy
Caliber shall endeavour to ensure adherence to this Privacy Policy. If there is a change in the policy, Caliber shall update the same in the Caliber website. If there are any queries regarding the privacy policy, please write to us as at communications@caliberuniversal.com and the Caliber team shall be happy to address all concerns or questions.
Glossary
- ‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
- ‘Lead’ means a contact engaged by the Caliber team in the sales and marketing process with the objective of introducing Caliber products and services for business development and conversion from potential customer to an actual customer
- ‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
- ‘Restriction of processing’ means the marking of stored personal data with the aim of limiting their processing in the future
- ‘Third party’ means a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorised to process personal data
- ‘Consent’ of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her
- ‘Personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed
- ‘Data subject’ means the person with respect to whom the data is collected, processed or stored. In the context of projects implemented or supported for Caliber customers, the data subjects shall include customer SPOCs
- Customer SPOCs- Single Point of Contact nominated by customers for demos, procurement, implementation, or support with respect to Caliber products.
- EU GDPR- General Data Protection Regulation which was made effective by the European Union on 25th May 2018
- NDA – Non-Disclosure Agreement. This is an agreement entered into with customers to ensure protection of data.
References
- Caliber’s Data Protection and Privacy Policy
- Informed Consent Form
- Withdrawal of Consent Form
- EU GDPR
