Privacy Policy

AVTAR PRIVACY POLICY

Prologue

Avtar’s core mission is to ensure diversity and inclusiveness in employment opportunities. The trust placed on us by our users and customers when sharing their Personal Data is shouldered by Avtar with utmost responsibility. We at Avtar have drawn up an elaborate Privacy Policy, to which we adhere to the strictest extent, to ensure that the trust reposed is maintained and the information shared is protected. With each developing day, we continue to formulate and adopt such amends as may be required from time to time to confront new challenges on protecting your information.

Avtar’s Privacy Policy would detail the process adopted by us with regard to collection, use and disclosure of personal and non-personal data and information our users and customers share with us when using/accessing our sites, applications and/or software.  To reassure our customers and users the safety protocols we have put in place with regard to protecting data, we have drawn up this Privacy Policy and deem it fit to share the same with customers, for their comfort and as a measure of transparency.  

This policy applies to all those who visit our website/mobile application or whose information Avtar otherwise receives in connection with its services, including but not limited to contact information received by Avtar through, directly or indirectly, including but not limited to Associates, Affiliates and Partners. Avtar is and shall remain the controller of all Personal Information / Data processed pursuant to this Privacy Policy, unless otherwise provided for in writing and subject to the rights of users, as provided in this Policy document. With no specific legal framework drawn up in this regard in India, where Avtar has its primary business, this Privacy Policy is a self-regulation for the protection of Data and Information shared by users with Avtar.

The Site is made available for use only by individuals searching for employment openings, or services or information related to their personal employment or job search (“Job Seekers”). The Site may, however, also be made available to individuals and/or organizations seeking information related to hiring or human resources or seeking to make available information regarding employment openings (“Job Listings” or “Job Ads”), either on their own behalf or other’s behalf, including but not limited to agencies purchasing for multiple parties (“Employers”).

Scope

This Privacy Policy covers only data that Avtar collects through the Site/ Mobile Application, and not any other data collection or processing, including, without limitation, any third-party operators of web pages to which Avtar’s Site / Mobile Application links, and any information that we collect offline or through any websites, products, or services that do not display a direct link to this Privacy Policy. Avtar stores your Personal Data until you make a written request seeking removal of your information or until it is no longer necessary to provide our services  Avtar may also store your personal and non-personal information. Avtar may amend this Privacy Policy at any time.

 

Basis for collection of Data

Avtar collects and processes your Personal Data on the basis of different legal grounds, depending on the nature of the Personal Data being provided and the type of processing involved.

Performance of a Contract - Some of the Personal Data processed by Avtar is performed on the basis that it is necessary for the performance of our agreement with you, or in order to take steps at the request of the user prior to entering such an agreement. An example of this would be where Avtar sends a Job Seeker’s application to an Employer.

Legitimate Interest – It may be necessary for the purposes of legitimate interests pursued by Avtar or an Employer including but not limited to Avtar sharing marketing materials about our products and services, where we believe you have a reasonable expectation that we will perform a particular type of processing on your behalf, where such processing is strictly necessary for fraud detection and prevention, or where we share your Personal Data with Avtar affiliates. Avtar will only rely on such a ground where an assessment has been performed balancing the interests and rights involved and the necessity of the processing in order to provide our services, products and features to you

Compliance with a Legal Obligation - For complying with a legal obligation, where Avtar is required to retain business records for fixed periods of time in order to comply with local legal requirements.

Consent - On your consent, wherever applicable, Avtar may process your personal Information / Data.

Information Avtar may collect / have access to

Personal data / Information includes, but is not limited to, any and all information that relates to an identified or identifiable individual, including name, identification number, address, location and Non-Personal Data refers to any information that does not identify you as a specific individual. Avtar will adhere to the applicable statutory definition, if any, in determining what is and is not Personal Data for the purposes of this Privacy Policy. Where this Privacy Policy refers to “information” or “your information” this may include both Personal and Non-Personal Data.

The Data that may come to be collected from you may include

• your first name, last name, surname, age, gender, caste, email, password, address, city, country, pin code, phone number and other contact details
• educational qualifications, alumni institutions, occupation, interests, work experience, information about your past & present remuneration, organization that you are associated with, your preferences.
• Data about how and what services you interact with on the platforms, that includes your log and location info. 
• Data from you when you create an account, request information, subscribe for a service, participate in a survey, post a rating or review, post a question or answer, participate in an Avtar questionnaire / Assessment / Interactive program, upload content or otherwise actively send us data on our Site/Application.
• The name you have associated with your device, device type, information from your computer or mobile device and actions taken on the Sites, including, but not limited to, your resume, your searches, the titles of jobs you search, click on or apply to, where those jobs are located, salary interest or experience, the general salary range or experience level of the jobs you view (where indicated), the Job Listings you apply to, your amount of activity or time of most recent activity on the Sites, session activity, browser type, operating system, type of device, MAC address, IP address, and any of your other behavior on the Sites.
• Information about your communication and any information you choose to provide when using our site and to the extent permitted by law, Avtar may record and monitor your communications, verbal and written, with us to ensure compliance with our legal and regulatory obligations and our internal policies.
• Personal data belonging to any info that reveals the racial or ethnic origin, political opinions, religious/philosophical beliefs, or trade union membership, & processing of genetic data, biometric data to uniquely identify a natural person, data regarding health or sexual orientation.
• Personal data like criminal convictions, offenses, and national identification number
• You may also create an account or log in to your Avtar account using third-party websites including, but not limited to, Facebook or Google. If you do not already have an Avtar account but log in to Avtar using your Facebook or Google account, this creates an Avtar account using the same email address used in your Facebook or Google account. If you agree to provide this information to Avtar, Facebook or Google will authenticate you and redirect you to Avtar. Please note, when you log in to Avtar using your Facebook or Google account, Facebook or Google will cookie you in order to authenticate you as a Facebook or Google user.
• By accessing Avtar through your Facebook or Google account, you understand that Facebook or Google will share certain data detailed in the above paragraph for the purposes of authentication to permit you to access Avtar in a secure manner. You may stop this at any point from your Facebook or Google account. This information will be considered Avtar account information for purposes of your use of Avtar.
• Facebook or Google may also ask for your permission to share certain other details with Avtar, including but not limited to your name, profile picture, public profile information, and email address. Once you give this permission, the requested information will be shared with Avtar. This information will be used to provide services to you, including populating your Avtar profile on Avtar. The shared information will remain associated with your Avtar profile until you modify or delete it.
• If you use any automated phone screening product, Avtar will record and store your answers to an Employer’s screening questions and will forward your answers to the Employer. Where you wish to use such a product, you will agree in advance to Avtar listening to and analysing the recording in accordance with this Privacy Policy.
• Payment information (e.g., the last four digits of credit, debit, or other payment card numbers and related verification information). Please note that Avtar only has access to the last four digits of credit, debit, or other payment card numbers, and does not store full card numbers or related card security codes.
• Avtar may also collect information about third-party websites you visit through our Site/Mobile Application. This could include information about Job Listings, notes or application statuses that you submit, save, or update, or data regarding how you engage with websites or other actions you take on such websites, including URLs of websites you visit. We may also suggest information from your Avtar profile to include in applications you submit on third-party sites and see whether you make changes to these suggestions but not the changes themselves.
• Any Personal Data that Avtar may obtain from other third-party sources, including data from sponsored advertisements that we have on third party sites, will be processed by Avtar in accordance with this Privacy Policy and all applicable laws.
• For Employers, this may also include actions taken with regard to a Job Listing or to Job Seeker’s resume or application, such as pausing or closing a Job Listing, opening, viewing or responding to a resume or application, or making a decision with regard to a resume, application or Job Listing.
• When Job Seekers apply for a job recommended to them by Avtar, Avtar facilitates certain aspects of the recruitment process including, for example, negotiations between the Job Seeker and the Employer, as applicable.
• As such, we collect and process any information submitted to Avtar through this process, including but not limited to any queries a Job Seeker may have about the job or interview, information about progression through the recruitment process and information relating to salary.
• If you are an Employer, information including but not limited to Business Registration information, or a utility bill, the name and email address of an Employer representative is required. This information will be used for internal purposes only, subject to any request by law enforcement or a court order.
• Employers may be contacted to take advantage of our Avtar services, and Avtar may seek additional information about hiring needs. This allows Avtar to determine whether or not our product is suitable for an Employer’s needs.

Use of Data

 

Avtar will only use your personal data in a fair and reasonable manner, and where we have a lawful reason to do so. Our use of your personal data depends on the purpose for which you interact with us. We may process your Personal Information for the following purposes:

• Providing our services and products to you.
• If and to the extent permitted by applicable law, Avtar may use your contact information to create an account,  send you relevant search results, send your job recommendations, send you Job Alerts, send you calendar alerts, send you Invitations to Apply for a job through Avtar, send you information about the Sites, including promotional materials, to send you recommendations of suitable job seekers and any other social media communication. Avtar may use third-party partners to perform these activities on Avtar’s behalf.
• Protecting our Users and providing you with customer support;
• We use information collected from cookies and other technologies, to improve your user experience and the overall quality of our services.
• Improving our site and its content to provide better features and services.
• Conducting market research and surveys with the aim of improving our products and services.
• Share your information with third parties (including operators of third-party websites and/or social networking sites) in order to show you targeted advertisements and other content that has been customized for you.
• To optimize our services, products and features for you, we may use your previous search and browsing history and reach out to you about jobs you may be interested in.
• Use profile data to tailor your experience on the Sites and to display content according to your preferences. We may return different results for the same search query and have full discretion with respect to the Job Listings we present in response to any particular search.
• Provide information collected pursuant to this Privacy Policy, including Personal Data, to Employers that may be interested in contacting you.
• Avtar may also provide the results of any Avtar Assessments you complete to Employers.
• If you provide credit, debit or other payment card and related details to us in order to make a payment, we will use such information only for the purpose of processing the payment (e.g., the last four digits of credit card numbers and related verification information). Any credit, debit, or other payment card and related billing and payment information that you provide to us may be shared by us with companies who work on our behalf, such as payment processors and/or credit agencies, solely for the purposes of checking credit, effecting payment and servicing your account.
• For data analysis, quality control, enforcement of the Sites’ rules and other Avtar policies, content moderation, and to improve the Sites or any other Avtar product or service and preventing fraud and spam.
• To help diagnose problems with the Sites and our products and services, for preventing, detecting, investigating and taking action against crimes, potentially fraudulent or illegal activities, violations, including but not limited financial crimes, and to protect individuals from other activities that may be detrimental to you or others.
• To investigate and disclose information from or about you or your use of Avtar if we have a good faith belief that such investigation or disclosure (a) is reasonably necessary to comply with legal process (including subpoenas, search warrants, court orders) and law enforcement instructions and orders; (b) is helpful to prevent, investigate, or identify possible wrongdoing in connection with the use of the Sites; or (c) may protect our rights, reputation, property, safety, or that of the public; or (d) as necessary to meet national security requirements.
• To the extent required for identity verification, government sanctions screening and due diligence checks.
• To detect and address anomalous activity and screen content to prevent abuse such as spam or fraud
• Establishing, exercising or defending legal rights in connection with legal proceedings (including any prospective legal proceedings) and seeking professional or legal advice in relation to such legal proceedings.

Sharing your Information

Our core mission is to help Job Seekers find great jobs, and Employers find great candidates, which is a mission we share with each of our associates, affiliates and partners. In order to achieve that mission, we share certain information with our associates, affiliates and partners. Information shared by you with Avtar may be shared with an associates/affiliate/partner to provide you with services, to improve the Sites and optimize functionality on the Sites, and other purposes as described in this Policy. In particular, such sharing strengthens our ability to help Job Seekers find jobs and Employers find great candidates. The services provided to you and the functionality of the Sites could not be provided without such transfers. This sharing also allows Employers to have better insight into the performance of their Job Listings. By providing Employers with the information they need to better utilize our platform, they can provide stronger Job Listings. Avtar sends Job Seeker Personal Data to Employers Such transfers are performed in the course of the job search, application and interview process. Such Personal Data will be processed in accordance with these terms and those of the relevant Employer. When you download or install an Avtar App, you acknowledge and accept that your Personal Data may be transferred to these service providers.

Data sharing with affiliates provides customers with more personalized and improved content, performance, features and services. Such sharing is also performed to facilitate improved data analysis, testing, research, and service improvement.

Such data sharing allows Job Seekers to access an even broader database of Job Listings and Employers, and for Employers to access more Job Seekers. It also facilitates applications and the display of Job Listings from the Sites to affiliates’ websites and vice versa. Avtar and its affiliates also share Employer data to provide a better experience to those Employers.

Such data sharing allows Avtar and our affiliates to process your Personal Data for the purpose of improving user security and internal operations, troubleshooting, and detecting and preventing fraud and spam.

Employer account holders agree to comply with all their responsibilities under applicable data protection rules with respect to the collection, processing and storage of Personal Data, as well as providing adequate protection of all data subject rights provided for under all applicable data protection rules.

Avtar sends certain Employer-related information to Job Seekers. This includes publishing Job Ads, Company Pages, and salary information on the Sites and publishing Job Listings on third-party websites. Avtar may also provide information to Job Seekers about an Employer’s activity and responsiveness on the Sites in order to help Job Seekers evaluate employment opportunities. This may include the Employer representative’s name, the Employer’s city/state location, whether the Employer has taken an action with regard to the Job Seeker’s resume or application such as opening, viewing, responding to or making a decision in regard to it, whether the Employer has engaged with other Job Seekers or viewed other Job Seekers’ resumes, and whether the Employer has taken an action in regard to a Job Listing such as pausing or closing it. As an Employer, when you use the Sites you agree that Avtar may provide this information to Job Seekers.

We may use third parties to perform services in connection with our operations, to improve the Sites and our services, products, and features, to protect our users and better understand their needs, and to optimize the services and the users’ experiences. These service providers may have access to Personal Data in the course of providing these services, which may involve transfers of such Personal Data to other countries.

These third parties may provide data points including how much time you spend on specific pages, which links you choose to click, and data that helps determine user preferences. This information enables us to build and maintain our services with user feedback. These third parties may use cookies and other technologies to collect data on your behavior and devices such as the device type, browser information, and preferred language.

Avtar may transfer your Personal Data in limited situations to certain third-party vendors that assist Avtar with protecting our users and maintaining the quality of our services, products and features provided to those users.

Avtar may also share any credit, debit, or other payment card and related billing and payment information that you provide to Avtar with companies who work on Avtar’s behalf, such as payment processors and/or credit agencies, solely for the purposes of checking credit, effecting payment to Avtar and servicing your account. 

In order to provide you with certain services and support ad attribution, limited user data may be shared with certain service providers when you install, download or use an Avtar App. This may include your IP address or other unique identifier, and event data related to the installation of the Avtar App.

This may be done for a variety of purposes, including facilitating user log-in through third party accounts. It may also assist us to understand and optimize our users’ complete customer journey by helping us: (i) understand how users arrive to the Sites; (ii) better measure the performance of our ads; and (iii) understand where a user has accessed the Sites through different devices.

We may also use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable. These service providers, as represented to us, apply security measures they consider adequate for the protection of information within their system. In any event, Avtar will not be liable for any damages that may result from the misuse of any information, including Personal Data, by these third parties.

Confidentiality

Avtar shall protect the safekeeping and confidentiality of your personal data and seek to ensure compliance with the requirements of the Information Technology Act, 2000 and Rules made there under to ensure the protection and preservation of your privacy.

 

When using external service providers acting as processors, we require that they adhere to the same standards as Avtar does. Regardless of where your Personal Information is transferred or stored, we take all steps reasonably necessary to ensure that personal data is kept secure.

 

We have physical, electronic, and procedural safeguards to protect your Personal Information and by accepting the terms of this Privacy Policy, you agree that the standards and practices being implemented by us, are reasonable and sufficient for the protection of your Personal Information.

 

Third-Party links

Our site/application may make available links to other third-party websites. When you click on such links, you may leave our Sites. Your web browser may also disclose to the third-party website the URL of the Site page you clicked from, and this URL may include search terms and filters you used on the Sites. The Sites may also make available Company Pages, which may contain information provided by third-party Employers.

Avtar is not responsible for the information collection, use, disclosure or other privacy practices of any third party, including associates and affiliates of Avtar, employers, third Party social media platform, or any third party making available  the devices or operating systems for which the sites are available and any third party operating any website to which the sites contain a link.

Control and Right to Update & Rectify Your Information

Users of our Site / Application/ Software shall able to edit and update most of their Personal Data held on the Site. Users of Avtar Site/Application shall be able to edit and update most of their Personal Data held on the Site, and if you have any queries or complaints please contact us.

There are certain activities where we ask for your consent to use your Personal Data. You have the right to withdraw this consent at any time. Where you are providing location information via a mobile app, you may turn off your location services on your device at any time. For other services that rely on your consent, you can withdraw your consent via the workflow for that given service. Please note that any processing that we have carried out before the withdrawal of your consent remains lawful.

Such rights of rectification, objection, restriction, access, portability and deletion are subject to certain limitations, as provided for by applicable laws.

Closure of Account

When a customer closes an account, such customer will no longer have access to any of the data we make available under that account, including but not limited to, search history, job search preferences, saved jobs, jobs applied to, Job Alerts, resume, and any other data associated with the account. If the customer uses the same email address to set up a new account, this data from a previous account will not become available to the customer again. Closing account may result in you losing access to our products.

A closed account does not mean that all of the data is expunged from the Avtar systems. Avtar reserves the right to keep any materials in a closed account as necessary to preserve and protect its rights to the extent permitted by law or to comply with its obligations under local law, although it will not be readily available under the customer’s original account.

Employers may disable an account at any time by contacting Avtar.  Avtar shall preserve business records pertaining to that account to comply with its obligations under law, if any applicable.

Minimum Age of Users

The Sites are not for use by anyone under the age of 18. However if local laws provide for an alternative minimum age for the provision of the Sites’ services to you, then that shall apply as the applicable minimum age. if you are under the age of 18 or the age of majority in your jurisdiction, you must use the Sites under the supervision of your parent, legal guardian or responsible adult.

We adopt a range of measures to try to ensure that we do not accept individuals who do not meet the minimum age and any other applicable age requirements. If you do not satisfy these age requirements, please email us.

Acquisitions and Other Reorganizations

Information collected pursuant to this Privacy Policy may be disclosed to one or more third parties in connection with any change of ownership or control in Avtar’s business (whether by merger, sale, or otherwise), or any other reorganization or joint venture, or assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding), and any such information may be used by such third party in accordance with this Privacy Policy. Equally, information collected pursuant to this Privacy Policy, including Personal Data, may be disclosed to one or more third parties in connection with any acquisition or merger carried out by Avtar of such third parties.

Disclaimer

Avtar  is not responsible for any information or data posted on websites other than the info posted by its employees on its behalf. Avtar is only liable for its own use of the personal info received through such websites.

Avtar does not hold or store any information related to account or credit/debit card details & shall not be responsible for any loss/damage sustained by users as a result of any disclosure of any information (inadvertent or otherwise) concerning your account, credit cards, or debit cards in the path of any online transactions or payments made for any products/services offered by Avtar.

In the event of any personal information being shared by you with Avtar, which is not requested by Avtar during the registration, whether mandatorily or optionally, Avtar will not be responsible for any information security breach or disclosure related to such information.

Avtar depends on the Employer or the Employer’s agent to provide Avtar with the correct destination for all applications. In the event that the electronic destination provided to Avtar is incorrect, your application materials will not be sent to the intended recipient of the application. Avtar has no liability for such applications. If you do not wish to send your application materials in this manner, you should send them directly to the Employer.

Changes to the Privacy Policy

Any changes to this Privacy Policy will become effective on the “Last Updated” date indicated above. By using the Sites or providing information to Avtar following such changes, you will have accepted the amended Privacy Policy. If Avtar is going to use Personal Data collected through the Sites in a manner materially different from that stated at the time of collection, then Avtar will notify users via email and/or by posting a notice on its site for 30 days prior to such use or by other means as required by law.