Privacy Policy

1. Introduction

This policy (“Privacy Notice”) is applicable to FirstConnectt (hereinafter “FirstConnectt”, “we” or “us”) and its offices in India.

FirstConnectt is the Data Fiduciary of your personal data as described in this Privacy Notice, unless otherwise specified.

At FirstConnectt, we prioritize your privacy and the protection of your personal data. We want you to feel confident that your personal data is well-protected when you interact with FirstConnectt.

2. Objective

This Privacy Notice is designed to inform you about how FirstConnectt collects, defines, and uses your personal data (PII) when you interact with our websites, social media platforms, or utilize our services. It aims to provide clarity on:

• The types of information we collect from you.
• The sources of your information, including instances where data is collected indirectly.
• The purposes for which we collect your information.
• How your information is collected, stored, used, and processed.
• Your rights concerning your personal data.

FirstConnectt is dedicated to safeguarding your personal data and respecting your privacy. This notice provides comprehensive details on how we handle your personal data (PII) in accordance with regulations such as the GDPR and the DPDPA.

3. Scope

This Privacy Notice outlines how we handle your personal data (PII) in compliance with the GDPR, the DPDPA, the IT Act 2000 and the SPDI Rules 2011 of India. It applies to any personal information collected directly from you or from third parties in various contexts, including:

• Visiting our public websites and online services, including social media platforms;
• Sending or receiving communications with us via email, phone, or text;
• Using our products and services (for example, as an employee of our customer with access to our offerings) where we act as a data controller. Please note that processing personal data is essential for accessing certain products or services;
• Participating in our events, webinars, training sessions, campaigns, or contests, or visiting our offices;
• Accessing, using, or downloading our content (such as newsletters, whitepapers, and reports);
• Providing information over the phone, which we may record and retain.

Our websites and services are intended for use by individuals in their business or professional capacities and are not aimed at children under 18. We do not knowingly collect or market personal data online from children under 18. If you are a parent or guardian and believe your child has provided us with personal data without your consent, please contact us as detailed below so we can delete their information from our systems.

For any concerns or inquiries about this Privacy Notice, or if you wish to exercise your rights regarding your personal data, please contact us at the address provided below.

4. Basic Terms

Personal Data / Personally Identifiable Information (PII) / Personal Information

Any information relating to an identified or identifiable natural person (“data subject / PII Principal”); 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 one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

Law / Act

The Digital Personal Data Protection Act, 2023 (DPDPA), the General Data Protection Regulation (GDPR), the Information Technology Act, 2000, the SPDI Rules 2011, and additional legislation that confers powers or obligations upon us.

Information

Personal Information and Sensitive Personal Data and Information as may be collected by FirstConnectt.

Data Subject / PII Principal / Data Principal

The individual whose personal information is being collected, held, or processed.

IP Address

An Internet Protocol address is a logical numeric address assigned to a computer, printer, switch, router, or any other device that is part of a TCP/IP-based network.

Data / PII Controller / Data Fiduciary

A person, company, or other body that determines the purpose and means of personal data processing (alone, or jointly with another person, company, or body).

Machine Readable Format

Data in a structured format that can be easily processed by a computer, for example a word document, a PDF document, or an excel sheet.

Data / PII Processor

A natural or legal person, public authority, agency, or other body that processes personal data on behalf of the data fiduciary.

5. Abbreviations

DPO

Data Protection Officer

TCP/IP

Transmission Control Protocol / Internet Protocol

PII

Personally Identifiable Information

6. Roles & Responsibilities

• Data Fiduciary detail: FirstConnectt, 418, 4th Floor, Palm Spring, New Link Rd, Malad West, Mumbai, Maharashtra 400064, India.
• Data Protection Officer (DPO) contact details: We are committed to protecting and safeguarding your personal data, and our nominated representative can be reached at dpo@firstconnectt.com.

7. What Personal Data Do We Process?

Depending on how you interact with us, we may collect various types of information about you. This can include business contact details such as your name, job title, company, email address, country, designation, industry, product interests, or telephone number. We also gather the content of your communications with us, details about how you use our website and services, your feedback, your interests in our products and services, and any publicly available information relevant from a business perspective. Additionally, we may collect information about your computer and your visits to and usage of our site, such as your Internet Protocol (IP) address, your operating system, browser type, and data gathered through cookies.

We collect information about you, your use of our services, your interactions with us, and the devices you use to access our services (such as computers, mobile devices, and tablets). This information may include, but is not limited to:

• Activities on our website, such as types of pages viewed, time spent on pages, and search queries;
• Advertising identifiers, such as cookie IDs found in browsers;
• Information collected via cookies and other technologies.

To enhance the user experience on our website, we may use cookies or similar electronic tools to collect information, assigning each visitor a unique, random User Identification (“User ID”) to understand individual interests based on the identified computer. Unless you voluntarily identify yourself (for example, through registration), we will not know who you are, even if we assign a cookie to your computer. The only personal information a cookie can hold is information you provide; a cookie cannot read data from your hard drive. For more details, please refer to our Cookie Policy.

8. Purposes and Lawfulness of Processing

We use the personal data we collect from you for various business purposes, based on different legal grounds for processing. Below is a summary of how, and on which legal bases, we use your personal data. We may use personal data to:

1. 1Respond to your inquiries and fulfil your requests, such as sending you newsletters or marketing materials.
2. 2Send you administrative information, including updates about our services, changes to our terms and conditions, and policy updates.
3. 3Facilitate social sharing functionality.
4. 4Enhance and improve the services we offer.
5. 5Provide a more personalized service experience.
6. 6Fulfil our contractual obligations related to your personal data.

Additionally, we may process personal data as we deem necessary or appropriate to:

1. 1Comply with applicable laws, including laws outside your state or country of residence.
2. 2Adhere to legal processes and prevent, detect, or suppress abuse, fraud, or criminal activities.
3. 3Respond to requests from public and governmental authorities, including authorities outside your state or country of residence.
4. 4Enforce our terms and conditions.
5. 5Protect our operations, assets, or interests, or those of our affiliates.
6. 6Safeguard the rights, privacy, safety, or property of our affiliates, you, or others.
7. 7Pursue available remedies or limit potential damages.

Consent: We may process your personal data based on your consent. This means we will obtain your consent before processing your personal data for specific purposes.

9. Retention and Storage

We will retain your personal data for as long as necessary to fulfil the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law.

After the retention period, your data will be deleted, destroyed, or archived according to our data destruction protocols, which comply with applicable laws, industry best practices, regional sectoral guidelines, and contractual requirements.

If complete deletion of personal data from our systems is not possible, we will implement appropriate measures to secure the information and prevent any further use.

10. Your Rights

You have certain rights regarding your personal data under applicable data protection laws (for example, India’s DPDPA 2023 and the General Data Protection Regulation) or based on your use of our offerings. These rights include:

Access

You can request confirmation of whether we are processing your personal data, details about such processing, and a copy of your personal data.

Erasure

You can ask us to erase your personal data if certain conditions are met. We are not required to comply where processing is necessary for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims.

Objection

You can object in writing to any processing of your personal data that is done on the basis of our legitimate interests, if you believe your fundamental rights and freedoms outweigh those interests. You can also object to the processing of your personal data for direct marketing purposes, including profiling related to such marketing, and we will then cease that processing.

Portability

You can ask us to provide your personal data in a structured, commonly used, machine-readable format, or to have it ported directly to another data controller, where our processing is based on your consent and carried out by automated means.

Rectification

You can ask us to update or correct certain information; we may verify the accuracy of the data before rectifying it.

Restriction

You can ask us to restrict (keep but not use) your personal data in specific circumstances, such as where its accuracy is contested, the processing is unlawful but you do not want it erased, or you have exercised the right to object and verification of overriding grounds is pending.

Withdrawal of Consent

You can withdraw your consent where processing is based on consent you previously provided. Your withdrawal will not affect the lawfulness of processing carried out before the withdrawal takes effect. If you have questions about how to withdraw a consent, please contact the Data Protection Officer at dpo@firstconnectt.com.

Right to Nominate

A Data Principal has the right to nominate, in the manner prescribed, another individual who shall, in the event of the death or incapacity of the Data Principal, exercise the rights of the Data Principal in accordance with the Digital Personal Data Protection Act, 2023.

Right of Grievance Redressal

In accordance with the Digital Personal Data Protection Act, 2023 and the Information Technology Act, 2000 read with the SPDI Rules, 2011, if you face any grievance with respect to this Privacy Notice, you may contact the Data Protection Officer at dpo@firstconnectt.com. The DPO will address any discrepancies and grievances with respect to the processing of information within the timelines prescribed under applicable law.

Exercise of Rights

To exercise your rights, please write to dpo@firstconnectt.com. We do not discriminate based on whether you choose to exercise your rights and will not, on that basis, deny you our offerings, charge you different rates, or provide a different level or quality of offerings. In order to properly process a request, we may need to verify your identity before taking any request-related actions.

11. Security of Personal Data

All information you provide to us is secured using strict procedures and security measures designed to prevent unauthorized access, breaches, or leaks. We implement a variety of technical, organizational, and physical safeguards to protect your personal data from unauthorized or unlawful access, loss, disclosure, or alteration. Our controls, policies, and procedures are aligned with industry best practices and recognized information security standards to help protect personal data throughout its lifecycle.

However, no system can be entirely secure. If you have any concerns about the security of your personal information, or believe that the information we hold about you is no longer secure, please contact us immediately using the contact details provided in this Privacy Notice.

12. Disclosure

We may disclose your information to any of our employees, officers, insurers, professional advisers, agents, partners, suppliers, or subcontractors insofar as reasonably necessary for the purposes set out in this Privacy Notice and for the purpose of providing services to you.

We may disclose your personal data to any member of our group, which means our subsidiaries, our holding company, and its subsidiaries.

• We may disclose your personal data to third parties if we are under a duty to disclose or share it in order to comply with any legal obligation, to enforce or apply our terms of use and other agreements, or to protect the rights, property, or safety of FirstConnectt, our customers, or others.
• We may disclose data to third-party service providers who provide services such as website hosting and webinars. Information provided to such service providers is subject to confidentiality obligations and is intended to be used solely for the permitted purposes.
• We may disclose data to identify you to anyone to whom you send messages through our services. You may also choose to disclose your personal data on chat, social media, blogs, and other services to which you can post information; please note that any information you post through such services may become public.
• We may disclose data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

13. Cross-Border Data Transfer

The data that we collect or are provided with may be transferred to and stored at a destination outside the base location. It may also be processed by staff operating outside the base location who work for us or for one of our related companies and affiliates.

We will ensure that any transfer of your personal data to a location abroad takes place in accordance with the transfer mechanisms mandated by applicable laws.

14. Changes to This Privacy Policy

We may update this Privacy Notice periodically. If we make significant changes, we will revise the “Last updated” date at the top of this page. Additionally, we may notify you of these changes by posting a notice on our website or, where required by law, by providing you with direct notice before the updates take effect.

15. Questions and Queries

Questions, comments, and requests regarding this Privacy Notice are welcomed and should be addressed to dpo@firstconnectt.com. You may also write to us at: FirstConnectt, 418, 4th Floor, Palm Spring, New Link Rd, Malad West, Mumbai, Maharashtra 400064, India.