Data Privacy Policy

Last updated:

August 09, 2022

White Crow Research Private Limited (“WhiteCrow / We / Our”) respects the data provided on ‘www.whitecrow.co’ (“Website”) featuring the portals ‘talent.whitecrow.co’ (“Talent Platform”) and ‘hire.whitecrow.co’ (“Talent Marketplace”) (Talent Platform and Talent Marketplace are collectively referred to as “Portals”) by:

(i) the candidate accessing/signing-up on the portal ‘talent.whitecrow.co’ / Talent Platform, with the intent to seek job opportunities (“Individual Candidate”); or

(ii) the client and/or the designated employees of such client, subscribing to the portal ‘hire.whitecrow.co’ / Talent Marketplace with the intent to search for appropriate talents from across the internet to suit an employer’s job profile requirements (“Subscribing Client”).

(Hereinafter, the Individual Candidate and the Subscribing Client shall be collectively referred to as “Candidates / You / Your”.)

WhiteCrow / Website is committed to protecting the personal information collected about, or provided by You by using and accessing/signing-up/subscribing to the Services (defined as below).

WhiteCrow / Website also respects and is committed to make safe and responsible use of the Publicly Available Information (as defined below) collected by WhiteCrow / Website in respect of the Potential Candidate (as defined below).

To that end, We have designed the WhiteCrow’s / Website’s Data Privacy Policy along with the Addendums (this “Policy”) to guide on how WhiteCrow / Website stores, collects, manages and uses the personal information obtained from You in connection with Our Services (defined as below). The Policy also serves as a guide on how WhiteCrow / Website collects, uses and manages the Publicly Available Information of the Potential Candidate.

This Policy applies to the information submitted to and collected directly by WhiteCrow / Website through the use of the Services on the Portals by You, and to the Publicly Available Information collected by WhiteCrow / Website, through the internet, of the Potential Candidate.

It is to be noted that, the Terms and Conditions along with this Policy [including addendum(s)] the Service Level Agreement and the Subscription Form (applicable to the Subscribing Client, subscribing to the Talent Marketplace), displayed on the Website, collectively form the “Agreement”. The capitalized terms unless defined herein shall have the same meaning assigned to them under the Terms and Conditions provided on the Website.

By using, accessing / signing-up or subscribing to the Services provided on the Website / Portals, You agree to be bound by the terms of the Agreement and more specifically to the collection, use and disclosure of Your information and the information of the Potential Candidate, which is in accordance with this Policy.

WhiteCrow through the Website and the Portals, provides services pursuant to a “software-as-a-service” (i.e., “SaaS”) delivery model, primarily in the nature of a recruitment market place, under which You use the applicable software components (the “Software”) providing access to database through the Website in addition to providing SaaS services via internet: (i) on no payment basis by accessing/signing-up on the Talent Platform, in case of an Individual Candidate; or (ii) on a subscription service basis, by entering into and executing a subscription form subscribing to the Services displayed on the Talent Marketplace (“Subscription Form”), in case of the Subscribing Client. Accordingly, during the Term / Subscription Term / Renewal Term / Trial Subscription Term, as the case may be, and subject to the compliance to the provisions of the Agreement, WhiteCrow grants You a non-exclusive, non-transferable, limited, time-bounded license (non-sub licensable) to access the database through the Website and use the SaaS services and/or Services via internet. The access to the database through the Website and the SaaS services, may only be used in support of Your professional/business operations.

“The Portals’ AI engine” is a network of knowledge that stores data on jobs, skills, companies, industries, people, places and more. This enables WhiteCrow / Website to provide a platform, in the nature of the Portals, to identify the right talent / job opportunities and to maximize the scope of utilization of the Website. WhiteCrow may also provide a platform to the customers of WhiteCrow and/or ‘www.whitecrowresearch.com’ collectively known as “Customers”, to reach out to the Individual Candidate on the Talent Platform. WhiteCrow’s Services grant access to the database provided on the Portals through the Website which aids in tracking public profiles to identify and locate appropriate talent from across the internet. WhiteCrow’s sourcing involves pairing of proprietary technology with a human touch to engage and acquire talent from over 20 (twenty) channels. Website’s screening algorithms work on self-reported information, including Publicly Available Information, to identify qualified and relevant talent across the internet. Such identified qualified talent (“Potential Candidate”), after being shortlisted by the Subscribing Client is then contacted and invited to sign-up as an Individual Candidate on the Talent Platform to explore the job opportunities proposed by the Subscribing Client. Upon the Potential Candidate signing-up on the Talent Platform as an Individual Candidate, the Subscribing Client can then connect with such Potential Candidate as stipulated in the Terms. In addition to the same, the Talent Platform also aids and assists the Individual Candidate using the said portal to display their portfolios to seek appropriate and desired job opportunities. You shall select Your desired criteria and a list of options shall be available to You. To further ease the process, the Individual Candidate shall be free to filter the job opportunities and the Subscribing Client shall be free to filter the potential talents, upon gaining access to the database and use of SaaS (“Service(s) / WhiteCrow’s Services”).

WhiteCrow / Website may, from time to time, make changes to this Policy. If WhiteCrow / Website makes any material change to this Policy, WhiteCrow through the Website shall notify You of those changes by posting them on the Website and shall indicate the date of the last revision. Please note that, Your continued use of the Services after the changes pertaining to this Policy have been posted, will constitute Your acceptance of those changes.

This Policy describes the treatment of information provided, collected or retained by WhiteCrow / Website. This Policy applies to WhiteCrow’s Services displayed on the Website, but not to the website maintained by other companies or organizations to which WhiteCrow /Website may provide links. WhiteCrow / Website, therefore, is not responsible for the content or activities provided or created on such sites. Further, if You have any questions about this Policy or Our data practices, You shall not hesitate to contact Our team:

1. Privacy inquiries:	support@whitecrow.co
2. Security inquiries:	support@whitecrow.co

Information:
1. In Your Case:
2. Personal Information is information that others can use to identify, locate or contact You, including but not limited to, Your name, email address, postal address and phone numbers (collectively “Personally Identifiable Information” or “PII”). Specifically, the WhiteCrow / Website including its Portals may collect the following list of PII in connection with Your use of the Services:
  1. ‘Identity Data’ such as name of the employer entity/Subscribing Client, name of the Individual Candidate, employer entity’s website, social media profiles, username, real name, alias, postal address, unique personal identifier, online identifier, ‘Internet Protocol’ address (“IP Address”), email address, account name and if provided by You at Your discretion, the information pertaining to the (i) social security number, (ii) driver’s license number, and (iii) passport number, or other similar identifiers.
  2. ‘Personal Data’, in case of Individual Candidate, such as gender, nationality and place of residence.
  3. ‘Contact Data’ such as physical address, email address, social media address, telephone number and any other contact information You provide to WhiteCrow / Website.
  4. ‘Professional Data’, in case of Individual Candidate, such as qualification, training and certifications, professional skills and experience, language skills.
  5. ‘Employment Data’, in case of Individual Candidate, such as current/recent role, including job title, department, reporting line, responsibilities, salary, benefits and notice periods.
  6. ‘Transaction Data’, in case of Subscribing Client, such as details about payments to and from the Subscribing Client, and details regarding the subscribed Services through the portal ‘hire.whitecrow.co’.
  7. ‘Technical Data’ such as device IDs, Your login data, access dates and times, browser type and version, device information, ‘Cookies’ (defined as below), time zone setting, browser plug-in types and versions, platform and other technology on the devices You use to access the Website.
  8. ‘Profile Data’ such as Your username and password, searches made by You, preferences, user-generated content, feedback and survey responses.
  9. ‘Usage Data’ such as information about how You use the Website and the Services.
  10. Similar networking activities such as Your browsing history, search history, information on Your interaction with a website, application, or advertisement.
  11. Other information collected by WhiteCrow / Website from the Individual Candidate accessing/signing-up to the Talent Platform, including but not limited to, the Individual Candidate’s motivation and reasons for seeking new employment, career aspirations, communication preferences, details of any interviews which the Individual Candidate has attended etc.
    
    In addition to the PII listed above, the Website may also collect:
    - Generic geographic location, such as the city in which You are located;
    - Operating System; and
    - IP Address.
    The abovementioned list of the PII to be collected by WhiteCrow / Website is non-exhaustive and may or may not include other information of similar nature as may be required by WhiteCrow / Website.
3. It is made expressly clear that, the elements forming part of the compilation of the Individual Candidate’s data relating to age, ethnicity, gender etc., whether directly compiled or implied, is made with the purposes of inclusion and not to create any bias or discrimination of any nature whatsoever against the Individual Candidate. WhiteCrow proposes, recommends and anticipates that the Subscribing Client / Customers uses such data, employing the principles and fundamentals of the right to equal employment. WhiteCrow and the Website are not responsible for any consequential implications pertaining to the method and manner of use of such data by the Subscribing Client / Customers.
4. WhiteCrow / Website uses the geo-location services on the devices used to access or use the Services at any time, through Your device settings. WhiteCrow / Website collects geo-location and proximity of Your device, for which the location services will have to be enabled on Your device (e.g., GPS-based functionality on mobile devices used to access the Website) and WhiteCrow / Website may use that information to customize the interactions with location-based information and features.
5. In some cases, WhiteCrow / Website may assign an identification number to You (“ID Number”). ID Number may be linked with PII only for the purposes of providing the Services or for internal reporting purposes.
6. WhiteCrow / Website assures You that WhiteCrow / Website would never rent or sell Your PII, subject to the provisions of the CCPA Addendum. WhiteCrow /Website will solely retain its data sourced from the Services provided on the Website / Portals and not the information/data shared directly by You with WhiteCrow / Website, provided to avail the Services. Please note that, as far as the data shared by You with WhiteCrow / Website is concerned, WhiteCrow / Website will not be or act as the data owners or data controllers of such data.
7. WhiteCrow / Website may collect different types of personal and other information based on Your use of Our Services and Our business relationship with You, including contact information, billing information, equipment, performance, Website’s / Portals’ usage, viewing and other technical information about Your use of Our network, Services, Website or Portals. Such information may be collected when (i) You provide information to WhiteCrow / Website with the intent to subscribe or interact with WhiteCrow through the Website/Portals about its Services offered; (ii) collected automatically when You visit the Website or use Our Services; or (iii) WhiteCrow / Website obtains it from other sources, such as credit agencies. WhiteCrow / Website may collect/store Your calls and SMSs and content thereof, received or initiated using the Services, including but not limited to, details of the phone numbers that interact with Your account, IVR content and call recordings and information which it may automatically receive and record on its server logs from Your internet browser, including but not limited to, Your IP Address, Cookie information and details of the web pages You request. In order to sign-up/access/subscribe, as the case may be, on the Portals through the Website and use the Services, You are required to share the information for the effective performance of the Services.
8. To continue to provide You with updates to the Services, WhiteCrow / Website collects and controls information about: (i) the way You use and interact with Our Services; and (ii) Your PII shared with WhiteCrow / Website upon subscription or accessing/signing-up, as the case may be, to the Portals. Such collection and controlling of the information aids to improve Our Services and further build and recommend new services and customized features. Subject to the permissible extent stipulated under this Policy, as stated in this Section 1.1.8, WhiteCrow / Website also engages in the collection of Your PII for the purpose of Our business development exercise. WhiteCrow / Website adheres to reasonable security measures when processing Your PII for such purposes.
9. WhiteCrow’s /Website’s intension in collecting Your PII is to provide You with the best customer experience possible by communicating with You regarding Service updates, offers and promotions, delivering advertising (subject to Section 6 of this Policy) that may be of interest to You, addressing network and security issues, investigating or taking action regarding illegal activities or violations of Our terms of use or other policies, as may be laid out on the Website from time to time.
10. In Case of Potential Candidate:
11. Publicly Available Information is the information that WhiteCrow / Website has a reasonable basis to believe is lawfully made available to the general public by the Potential Candidate through widely distributed media, which includes public profiles; or information made publicly available by a person / entity to whom the Potential Candidate has disclosed the information if the Potential Candidate has not restricted the information to a specific audience (“Publicly Available Information”).
12. WhiteCrow / Website collects and uses the Publicly Available Information relating to the Potential Candidate only for its legitimate business purposes, i.e., to provide a comprehensive outlook to the Subscribing Client / Customers of the relevant talent available across the internet, in addition to the talent available on the Talent Platform, and to help them to connect with the Potential Candidate as provided in the Terms and Conditions.

Collection of Information:

WhiteCrow / Website collects Your information/PII throughout the Term / Subscription Term / Renewal Term / Trial Subscription Term, as the case may be.

Information provided by You: WhiteCrow / Website collects information that You voluntarily provide to WhiteCrow / Website during Your interaction or subscription with the Services. For example, You may choose to provide WhiteCrow / Website with information upon accessing/signing-up/subscribing to the Portals, as the case may be. In case of subscription, the Subscribing Client shall submit the Subscription Form and make payment of the subscription fees through the link provided on the Talent Marketplace.
Interacting with the Website & Portals: WhiteCrow / Website may also collect certain types of information automatically, including through the use of Cookies, web beacons and other similar tracking technologies. These tracking technologies allow WhiteCrow / Website to personalize Your experience with the Services and keep track of certain online behaviour in order to help WhiteCrow / Website determine the things that You find most interesting.

Cookies: A ‘cookie’ is a small bit of record-keeping information that sites often store on the Your computer or mobile device (“Cookie(s)”). Cookies are typically used to quickly identify Your device and to “remember” things about Your visit. For example, WhiteCrow / Website may use Cookies or a similar method to keep track of Your app session. Information contained in a Cookie may be linked to Your PII for this purpose. You can disable Cookies or set Your browser to alert You when Cookies are being sent by Your device or computer although this may affect Your ability to use many features of the Services.

WhiteCrow / Website uses Cookies to distinguish You from other users of the Website / Portals. This helps WhiteCrow / Website to provide You with a better experience when You browse the Website / Portals and also allows WhiteCrow / Website to improve.

WhiteCrow through the Website may use the following types of Cookies:

Strictly necessary cookies: These are Cookies that are required for the operation of the Website / Portals. They include, for example, Cookies that enable You to log into secure areas of the Website /Portals.
Analytical/performance Cookies: They allow WhiteCrow / Website to recognize and count the number of visitors/ Individual Candidates / Subscribing Clients and to see how visitors / You move around the Website / Portals when they / You are using it. This helps WhiteCrow to improve the way the Website / Portals works, for example, by ensuring that users / You find what they / You are looking for easily.
Functionality Cookies: These are used to recognize You when You return to the Website / Portals. This enables WhiteCrow /Website to personalize Website’s / Portal’s content for You and helps greet You by name and remember Your preferences.
Targeting Cookies: These Cookies record Your visit to the Website / Portals, the pages You have visited and the links You have followed.

You can find more information about the specific Cookies that WhiteCrow through the Website uses and the purposes for which it is used in the table below:

Name	Type	Description	Expiry By Type
Google Analytics	Analytical	This Cookie collects information about Your computer, including where available Your IP address, operating system and browser type, and geographic location. WhiteCrow/ Website uses this information for Website / Portals optimisation and to monitor Your browsing activities and navigation through the Website/Portals. This information is anonymous and would not allow WhiteCrow to identify any individual user without the assistance of a third party such as an ISP. You are able to opt out of Google Analytics by installing a browser add-in which is available at https://tools.google.com/dlpage/gaoptout. Please note that this add in is provided by Google and We offer no warranty, whether express or implied, as to its suitability or efficacy.	_ga 2 years _gid 24 hours _gat 1 minute

In addition, to analytical Cookies, WhiteCrow through the Website uses CleverTap from WizRocket Inc within Our web-portal at https://talent.whitecrow.co/. This is a third-party application which permits WhiteCrow to:

Integrate app analytics and marketing.
Track actions users are taking in the said portal to analyse how they use Our product; and
Run marketing campaigns based on the user tracking.

You may opt out of any sharing of Your PII with CleverTap by emailing us at support@whitecrow.co

WhiteCrow / Website also uses other tools like:

(i) Hotjar: https://www.hotjar.com

Individual Candidate: WhiteCrow and WhiteCrow’s and/or ‘www.whitecrowresearch.com’ customers will have access to the Individual Candidate’s data available on the Talent Platform and will collect such data of the Individual Candidate.
Third Party Sites: You by accessing/signing-up/subscribing, as the case may be, to the Services grant his/her/its irrevocable consent to WhiteCrow / Website to share Your PII with ‘www.whitecrowresearch.com’, which will operate as a ‘helpdesk’ and provide services to You, in any event You encounters issues with respect to: (i) the Services provided on the Website / Portals; or (ii) the terms of the Agreement. WhiteCrow / Website / Portals may also provide links to and share Your PII with the third party websites including but not limited to, ‘WhiteCrow’ group entities (“Sites”). The Sites can also be accessed by You, at Your discretion, to use other services provided on these Sites to aid and help in achieving Your desired outcome. The Website and the Portals may also contain links to other websites.
WhiteCrow / Website in no event is engaged in the activity of scrapping of the data from the other websites and is in compliance of any anti-scrapping policies or such similar terms of the other websites. The Services provided by WhiteCrow enables WhiteCrow / Website to grab and drop specific data for a specific instance, pertaining to an Individual Candidate or a Potential Candidate, to ease and assist the Subscribing Clients to analyze and identify potential talents and/or desired job opportunities for such talents, as the case may be, from across the internet. The grab and drop feature is provided solely to ease the capture of information for an instance identified by the Subscribing Client / Customers from a particular website and is not provided or intended to be provided for ‘bulk scrapping’ of information by the Subscribing Client/ Customers.
WhiteCrow / Website may share the Your PII with Our service providers who perform functions necessary to providing the Services on Our behalf. Examples include analyzing data and providing marketing assistance and customer service. These service providers are not authorized by WhiteCrow / Website to use or disclose PII except as needed to perform their functions or comply with legal requirements and they may not use it for any other purposes. WhiteCrow / Website does not disclose or transfer Your PII to third parties for any other purpose. However, WhiteCrow / Website does not represent that WhiteCrow / Website controls the treatment of Your PII by such third parties, as the privacy practices of third parties may differ from those described in this Policy.
Potential Candidate: WhiteCrow / Website for its legitimate business purposes identifies and collects relevant Publicly Available Information of the Potential Candidates from the internet. WhiteCrow / Website analyzes and collects the public information strictly in compliance of the applicable laws and ensures that the collected information is utilized only for the purpose of its legitimate business use.

How WhiteCrow / Website Uses Information:
WhiteCrow / Website uses Your information/PII throughout the Term / Subscription Term / Renewal Term / Trial Subscription Term, as the case may be.
1. WhiteCrow / Website shares Individual Candidate’s / Subscribing Client’s PII /data with:
  - The Talent Advocate upon the Individual Candidate or the Subscribing Client approaching through the Talent Advocate;
  - The Customers interested to approach an Individual Candidate on the Talent Platform;
  - a third party including but not limited to a managed service company, recruitment process outsourcing provider, Information Technology service provider engaged by WhiteCrow to assist in discharging it obligation under the Agreement;
  - third party service providers;
  - WhiteCrow group entities; and
  - The Customers, in case of Individual Candidate, where We have agreed to provide statistical information, market intelligence or talent mapping services to such Customers.
2. WhiteCrow / Website processes Your PII and shares this information with third parties to the extent necessary to provide You with the Services. WhiteCrow / Website cannot provide You with Services without processing Your PII. WhiteCrow / Website may also use information collected from third party software providers that You may choose to connect to WhiteCrow / Website to enable additional functionality in the platforms of the Portals.
3. When You subscribe/assess/sign-up to Our Services, WhiteCrow / Website will send You administrative or account-related information to You to keep You updated about Our Services, inform You of relevant security issues or updates or provide other transaction-related information to You. WhiteCrow / Website processes Your contact information to send You such communications. Service-related communications are not promotional in nature. You will not be able to unsubscribe from such communications, otherwise You may miss important developments relating to Your account or the Services that could affect Your use of the Services.
4. To respond to Your inquiries and provide customer service: WhiteCrow / Website processes Your PII when You contact WhiteCrow / Website, such as with questions, concerns, feedback, disputes or issues. Without Your PII, WhiteCrow / Website cannot respond to You or ensure Your continued use of the Services.
5. To enforce Our terms, agreements or policies: WhiteCrow / Website processes Your PII to actively monitor, investigate, prevent and mitigate any alleged or actual prohibited, illicit or illegal activities on Our Services; investigate, prevent, or mitigate violations of Our terms, agreements or policies; enforce Our agreements with third parties and partners; and as applicable, collect fees based on the Subscribing Client’s subscription to Our Services. WhiteCrow / Website cannot perform Our service in accordance with Our terms, agreements or policies without processing Your ‘Personal Data’ for such purposes.
6. To ensure the security of the Service: We are committed to ensuring Your safety and continued use of Our Services. To do so, WhiteCrow / Website processes Your PII to: (i) combat spam, malware, malicious activities or security risks; (ii) improve and enforce Our security measures; and (iii) to monitor and verify Your identity so that unauthorized users do not access Your account with Website / respective Portals. WhiteCrow / Website cannot ensure the security of Our Services if WhiteCrow / Website does not process Your PII for security purposes.
7. To maintain legal and regulatory compliance: Certain laws or regulations apply to Our Services that may require WhiteCrow / Website to process Your PII. For example, WhiteCrow / Website may process Your PII to fulfill Our business obligations as necessary to manage risk as required under applicable laws. Without processing Your PII for such purposes, WhiteCrow / Website cannot perform the Services in accordance with Our legal and regulatory requirements.
8. To personalize Your experience on the Service, WhiteCrow / Website provides You with third-party services, plugins and many other options to personalize Your experience on Our Service. In addition, by personalizing the Service, You get to enjoy Our Services even more because WhiteCrow / Website keeps track of Your preferences (e.g., Your language selection, Your time zone, etc.) and connect all Your favorite third-party services to Our Service. Without processing Your PII for such purposes, You may not be able to access or personalize part or all of Our Service.
9. In addition to the above, WhiteCrow / Website may use Your PII for the following purposes also:
  - Operate, manage and improve the Services.
  - Communicate with You about Your Website’s / respective Portals’ account, Your interactions with the Services or Your contacts’ interactions with the Services.
  - Protect the rights or property of WhiteCrow or third parties.
  - To provide You with alerts and other notifications/notices concerning Our Services or events or news, that may be of interest to You.
  - To improve the Website / Portals and present its contents to You.
  - For testing, research, analysis and product/Service development.
  - As necessary or appropriate to protect Your rights, property or safety, and the rights, property or safety of WhiteCrow /Website, Customers or others.
  - To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by WhiteCrow / Website is among the assets transferred.
10. Use of Publicly Available Information: WhiteCrow uses the Publicly Available Information on the internet to identify and locate the Potential Candidate suitable for the job opportunities proposed by the Subscribing Client / Customers. After identifying the Potential Candidate as a suitable talent for the job opportunity proposed by the Subscribing Client / Customers, WhiteCrow / Website displays the limited public profile(s) of the Potential Candidate to the Subscribing Client / Customers along with certain generic and descriptive information. This enables WhiteCrow / website to provide a comprehensive view of the suitable talent available across the internet, in addition to the talent available of the Talent Platform, to the Subscribing Client / Customers, and helps WhiteCrow / Website to invite the Potential Candidate shortlisted by the Subscribing Client/ Customers to the Talent Platform, in order to connect him / her with the Subscribing Client / Customers, as provided in the Terms and Conditions.
International Transfer of Collected Information:
1. To facilitate Our global operations, WhiteCrow / Website may transfer and access PII and Publicly Available Data from around the world, including from countries other than those where WhiteCrow has operations.
2. WhiteCrow / Website shall take all reasonable technical and organizational measures to protect Your data and data of the Potential Candidates.
3. If You are visiting the Website from the regions with laws governing data collection and use, please note that You are agreeing to the transfer of Your PII to India and other countries and jurisdictions. By providing Your PII, You consent to any transfer and processing in accordance with this Policy.
4. For detailed information with respect to the safeguards and disclosures on behalf of WhiteCrow, You can refer to the CCPA and GDPR Addendums to this Policy, available on the Website.
Disclosure:
1. Subject to the provisions of the CCPA Addendum, WhiteCrow / Website do not sell Your PII to anyone for any purpose and WhiteCrow / Website maintains information about You in Our business records while You remain an active user or subscriber to Our Services on the Website / Portals. WhiteCrow / Website have implemented encryption or other appropriate security controls to protect PII when stored or transmitted by WhiteCrow / Website. WhiteCrow / Website may provide PII to third parties to the extent and in the manner as stated in this Policy.
2. Please see below the disclosure focus:
  - Service Providers, Business Partners and Others: WhiteCrow / Website uses certain trusted third parties (as stated in Section 3.1, above) to help WhiteCrow / Website provide, analyze and improve the Services (including but not limited to data storage, maintenance services, database management, web analytics, security, payment processing and improvement of the Service’s features).
  - Compliance with laws and law enforcement requests and protection of WhiteCrow's rights: WhiteCrow / Website may disclose files stored in Your account and other information about You to third parties when We have a good faith belief that disclosure is reasonably necessary to: (a) comply with a law, regulation or legal requests including to meet national security or law enforcement requirements; (b) protect the safety of any person from death or serious bodily injury; (c) prevent fraud or abuse of WhiteCrow / Website or its subscribers / users (i.e., Individual Candidate and the Subscribing Client); or (d) protect WhiteCrow’s property rights.
  - Business Transfers: If We are involved in a merger, acquisition or sale of all or a portion of Our assets, Your information may be transferred as part of that transaction, but WhiteCrow through the Website will notify You (in accordance with Section 12 (Miscellaneous) of the Terms and Conditions or by posting a prominent notice on the Website) of any change in control or use of Your PII.
Consent for receiving Promotional information:
If You opt to receive marketing/promotional or informational announcements from WhiteCrow / Website, such emails will include the capability to opt-out of receiving such e-mails in the future. Marketing/promotional and informational announcements include any communications to You that are only based on advertising or promoting products and services of WhiteCrow. Transactional communications about Your account or the Services are not considered “marketing”, “promotional” or “informational” communications.
Compliance with Laws and Law Enforcement Requests:
In certain circumstances, WhiteCrow / Website may be required to disclose Your PII in response to lawful requests by public authorities, including to meet national security and law enforcement requirements. WhiteCrow / Website may disclose Your PII in response to subpoenas, court orders or legal process, or to establish or exercise Our legal rights or defend against legal claims. WhiteCrow / Website may also share such information if We believe it is necessary in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Our Services or as otherwise required by law.
Your Controls:
1. You can review and correct Your PII collected by WhiteCrow / Website. WhiteCrow / Website reserve the right to correct the information found to be inaccurate. You may verify that appropriate corrections have been made. However, it may be noted that the Website, WhiteCrow, its employees, subsidiaries, affiliates and third parties shall not be responsible for the accuracy and/or authenticity of the information supplied by You. WhiteCrow / Website hereby disclaims any and all liability arising out of or in connection with the accuracy and/or authenticity of the information.
2. WhiteCrow / Website processes and stores service data on Your behalf. WhiteCrow / Website has direct relationship neither with the Individual Candidate nor the Subscribing Client. Therefore WhiteCrow / Website is exempted from any responsibility consequential to the business relations established between the: (i) Individual Candidate and the Subscribing Client by using of the Services available on the Portals; and (ii) Individual Candidate and the Customers.
3. Consent: By using the Website / Portals and accessing/signing-up or subscribing to the Services, You consent to this Policy. In the event that You do not agree with and/or consent to the terms and conditions specifically set out herein and/or to the terms of the Agreement, please do not use or access the Website / Portals and the Services. You hereby acknowledge and agree that by mere use of the Website / Portals and the Services, You expressly consent to WhiteCrow’s /Website’s collection, receipt, storage, processing, disclosure, transfer, dealing with and handling of the customer/ Your data in accordance with this Policy throughout the Term / Subscription Term / Renewal Term / Trial Subscription Term, as the case may be. You understand that, while Your account is active to use the Website / Portals and Services, the Website, WhiteCrow, its subsidiaries, affiliates and third parties engaged by it, may retain Your PII and use it in any manner in order to comply with its contractual obligations and other obligations under applicable laws. In the event that You wish to withdraw Your consent to WhiteCrow’s /Website’s collection, receipt, storage, processing, disclosure, transfer, dealing with and handling of the information, You may contact WhiteCrow in the manner stipulated in Section 12 (Miscellaneous) of the Terms and Conditions, informing WhiteCrow of Your withdrawal of consent to its use of Your information. You hereby acknowledge and agree that, in case You withdraw Your consent to WhiteCrow’s / Website’s use and disclosure of Your PII as provided for in this Policy, such action on Your end will result in the termination of the Agreement and consequently effect in deactivation of the Individual Candidate’s account or the Subscribing Client’s subscription to the Services, restricting Your right to access the Website/ Portals and the Services, subject to Section 4.1 (Terms and Termination) of the Terms and Conditions, wherein the You will have access to the Portals through the Website for a duration of 15 (fifteen) days, solely with the intent to enable You to access and retrieve its data.
Changes to this policy:
If WhiteCrow / Website is going to use Your previously collected PII in a manner materially different from that stated in this Policy at the time of collection, such change will be notified by posting it on the Website and shall indicate the date of the last revision.
Children’s Privacy:
WhiteCrow / Website do not use the Services to knowingly solicit data from or market to children under the age of 18 (eighteen) years. WhiteCrow / Website requests that such individuals do not provide PII through the Services. If a parent or guardian becomes aware that his or her child has provided WhiteCrow / Website with information without their consent, he or she should promptly contact WhiteCrow and We will take reasonable steps to ensure that such information is deleted from WhiteCrow’s / Website’s files.
Data Security, Integrity and Retention:
1. Security: WhiteCrow / Website will protect Your PII from unauthorized access, use or disclosure. Whenever You change or access Your account information, WhiteCrow / Website offers the use of a secure server. Once Your information is in WhiteCrow’s / Website’s possession WhiteCrow / Website adheres to strict security guidelines, protecting it against unauthorized access. WhiteCrow / Website has implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. For example, WhiteCrow / Website uses firewalls, encryption technology and other automated software designed to protect against fraud and identity theft.
2. Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. All decisions which are made in the course of Our business processes involve human intervention. We do not therefore, expect to make any decisions about You using automated means.
3. WhiteCrow / Website will ensure, to the best of its ability, the security of Your Sensitive Personal Data or Information (“SPDI”) provided by You during the Term / Subscription Term / Renewal term / Trial Subscription Term, as the case may be.
4. When You download and use an app or website that requests WhiteCrow to provide the Services, WhiteCrow / Website may collect and process information locally on Your mobile or desktop device. This allows WhiteCrow / Website to identify the sensitivity level of certain device information prior to transferring it to Our servers for storage. Rather than sending sensitive device information as raw data that can be easily associated with You, WhiteCrow / Website only transfer representations of certain types of information back to WhiteCrow / Website. Our servers then associate the representations with a unique identifier assigned to You by the Website. When You subsequently interact with the Services, this process allows WhiteCrow through the Website to provide the Services without storing the sensitive information in a form that would be easily readable to unauthorized third parties.
5. The Website also protects Your privacy by seeking to minimize the amount of sensitive data that WhiteCrow / Website store on Our servers in the first place. You may also contact WhiteCrow anytime with Your questions or concerns.
6. Upon expiry or pre-determination of the Agreement, WhiteCrow / Website will: (i) retain WhiteCrow’s data sourced from the Services provided on the Website for perpetuity; and (ii) within 7 (seven) working days of the expiration or pre-determination, provide to the Subscribing Client, with a copy of the information shared directly by such Subscribing Client with WhiteCrow / Website in accordance with Section 4.5 of the Terms and Conditions.
7. You acknowledge that all information, data, text, software, documents, music, sound, photographs, graphics, videos, messages, tags, or other materials (“Content”), whether publicly posted or privately transmitted, are the sole responsibility of the person from whom such Content originated, and that You, and not WhiteCrow / Website, is entirely responsible for all Content that You upload, post, email, transmit or otherwise make available via the Services. You understand that by using the Services, You may be exposed to Content that is offensive, indecent or objectionable. Under no circumstances will the Website, WhiteCrow or its parent, holding, subsidiary or related companies, affiliates, officers, agents or employees, as the case may be, be liable in any way for any Content or any loss or damage, no matter the cause of the loss or damage, of any kind incurred as a result of the use of the Services.