Privacy Statement

Privacy Policy: is governed by the policy published at:

http://www.techmahindra.com/General/privacy_policy.aspx

Privacy Policy

Version date

Scope and application

This Privacy Statement applies to the Tech Mahindra Alumni Network site (link here) hereafter referred to as "ReMember". ReMember is administered by TechM.

INTRODUCTION

Tech Mahindra Limited (the "Company") is a multinational provider of information technology, networking, technology solutions, consulting, enterprise, Telecommunication and business support services to enable Enterprises. Protecting consumer privacy is important to the Company. The Company and its affiliated United States subsidiaries (hereinafter collectively referred to as the "Company," "we," "us" or "our") adhere to the Safe Harbor Agreement concerning the transfer of personal data from the European Union ("EU") to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (the "Principles") with respect to all such data. If there is any conflict between the policies in this privacy policy and the Principles, the Principles shall govern. The Company’s Safe Harbor certification can be found at https://safeharbor.export.gov/list.aspx. For more information about the Safe Harbor Principles, please visit the U.S. Department of Commerce’s website at http://export.gov/safeharbor/. The Company’s privacy policy ("Privacy Policy" or "Policy") outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of, and their ability to, correct that information. This Policy applies to all personal information received by the Company whether in electronic, paper or verbal format.

We self-certify compliance with

DEFINITIONS

“Personal Information” or “Information” means information that: (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual. “Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.

SAFE HARBOR PRINCIPLES

Notice

Company shall inform an individual of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which the Company discloses or may disclose that Information. Company shall provide the individual with the choice and means for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to the Company, or as soon as practicable thereafter, and in any event before the Company uses or discloses the Information for a purpose other than for which it was originally collected.

Choice

The Company will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, the Company will give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Company shall treat Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information.

Onward Transfers

Prior to disclosing Personal Information to a third party, Company shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure. Company shall ensure that any third party for which Personal Information may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is required by the Principles and agree in writing to provide an adequate level of privacy protection.

Data Security

Company shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Company has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Company cannot guarantee the security of Information on or transmitted via the Internet.

Data Integrity

Company shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, Company shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

Access

Company shall allow an individual access to their Personal Information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.

Enforcement

Company uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.

If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using (an independent resource mechanism) as a third party resolution provider.

Dispute Resolution

The Company will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information by reference to the principles contained in this Policy. For complaints that cannot be resolved between the Company and the complainant, we have agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Principles:

for disputes involving personal information received by the Company from the EEA, we have agreed to register with the United Kingdom’s Information Commissioner’s Office (https://ico.org.uk/Global/contact_us) for dispute resolution. Individuals who submit a question or concern to us who do not receive acknowledgment from us of the inquiry or who think their question or concern has not been satisfactorily addressed should then contact the UK ICO on the Internet https://ico.org.uk/Global/contact_us on the telephone at 0303 123 1113, or by mail. Inquiries by mail or fax should identify the Company as the company to which a concern or question has been submitted, and include a description of the privacy concern, the name of the individual submitting the inquiry, and whether the ICO may share the details of the inquiry with the Company. The ICO will act as a liaison to the Company to resolve these disputes.

Amendments

This Privacy Policy may be amended from time to time consistent with the requirements of the Safe Harbor. We will post any revised policy on this website (“Website”). You can check the Effective Date below to determine when the Policy was last modified. Your continued use of the Website constitutes your consent to the contents of this Policy.

Information Subject to Other Policies

The Company is committed to following the Principles for all Personal Information within the scope of the Safe Harbor Agreement. However, certain information is subject to policies of the Company that may differ in some respects from the general policies set forth in this privacy policy.

Contact Information

Questions, comments or complaints regarding the Company’s Safe Harbor Policy or data collection and processing practices can be emailed to:

Corporateombudsman@techmahindra.com

Effective Date: 10 September 2014

Collection of personal information for propagating business

From time to time, we may request Personal Information from you to get valuable feedback from your experience on our website. In addition, we may also use your personal information for other business purposes or in order to help serve you better, such as informing you of new services, products, or alliances that could help you in your business. Your posting of any such Personal Information is strictly up to you, but please understand that this is a website accessed by the public. Therefore, do NOT post any information that is confidential and/or proprietary. While you can visit our site without disclosing any Personal Information, there are web pages that require such information to complete certain functions, thus these web pages may not be available to you if you decide not to reveal the information requested. We will take reasonable steps to ensure that your Personal Information is accurate and complete.

Collecting information for on-line surveys

At times, we conduct online surveys to better understand the needs and profile of our visitors. When we conduct a survey, we will inform you about how we will use the information prior to your taking the survey. If you do not want to participate in the survey, you may refrain from contributing to it at your own discretion.

Collecting domain information; USE OF COOKIES

Our Website may use a technology known as web beacons - sometimes called single-pixel gifs - that allow this site to collect web log information. A web beacon is a graphic on a web page or in an email message designed to track pages viewed or messages opened. Web log information is gathered when you visit one of our Websites by the computer that hosts our Website (called a “webserver”). The webserver automatically recognizes some non-personal information, such as the date and time you visited our site, the pages you visited, the website you came from, the type of browser you are using (e.g., Internet Explorer), the type of operating system you are using (e.g., Windows 7), and the domain name and address of your Internet service provider (e.g., AOL). We may also include web beacons in promotional email messages in order to determine whether messages have been opened.

Our Website uses a technology called a “cookie”. A cookie is a piece of information that our webserver sends to your computer (actually to your browser file) when you access a website. Then when you come back our site will detect whether you have one of our cookies on your computer. Our cookies help provide additional functionality to the site and help us analyze site usage more accurately. For instance, our site may set a cookie on your browser that keeps you from needing to remember and then enter a password more than once during a visit to the site.

Our Website uses Internet Protocol (IP) Addresses. An IP Address is a number assigned to your computer by your Internet service provider so you can access the Internet. Generally, an IP address changes each time you connect to the Internet (it is a “dynamic” address). Note, however, that if you have a broadband connection, depending on your individual circumstance, it is possible that your IP Address that we collect, or even perhaps a cookie we use, may contain information that could be deemed identifiable. This is because with some broadband connections your IP Address doesn’t change (it is “static”) and could be associated with your personal computer. We use your IP address to report aggregate information on use and to help improve the Website.

You should be aware that this site is not intended for, or designed to attract, individuals under the age of 18. We do not collect personally identifiable information from any person we actually know is an individual under the age of 18.

Areas of this Website that collect your Information use industry standard secure socket layer encryption (SSL); however, to take advantage of this your browser must support encryption protection (found in Internet Explorer release 3.0 and above).

Disclosure to third parties

We may share your Personal Information with agents, contractors or partners of the Company in connection with services that these individuals or entities perform for, or with, the Company. These agents, contractors or partners are restricted from using this data in any way other than to provide services for the Company, or services for the collaboration in which they and the Company are engaged (for example, some of our products are developed and marketed through joint agreements with other companies). We may, for example, provide your information to agents, contractors or partners for hosting our databases, for data processing services, or so that they can mail you information that you requested. You may remove yourself from any such list or notification at any time.

The Company reserves the right to share your Personal Information to respond to duly authorized information requests of governmental authorities or where required by law. In exceptionally rare circumstances where national, state, or company security is at issue (such as with the World Trade Center terrorist act in September, 2001), The Company reserves the right to share our entire database of visitors and customers with appropriate governmental authorities.

We may also be required to disclose your Personal Information in the event of a legal investigation or any such other process where we are required to do so by applicable law or where we have to establish our legal rights or where disclosure is required to prevent or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person.

We may also provide your Information to a third party in connection with the sale, assignment, or other transfer of the business of this Website to which the information relates, in which case we will require any such buyer to agree to treat your Personal Information in accordance with this Privacy Policy.

As a convenience to our visitors, this Website currently contains links to a number of sites that we believe may offer useful information. The policies and procedures we described here do not apply to those sites. We suggest contacting those sites directly for information on their privacy, security, data collection, and distribution policies.

Agreement to data processing

The information You provide on this site as a user is used by TechM for the purpose of administering Your membership and use of the site as a member of the TechM Alumni Network. This website is located and primarily operated in India. Your personal information will be collected and used in accordance with the terms of this Privacy Statement and applicable data privacy laws.

Your privacy on ReMember

We want You to feel secure when visiting our site and are committed to maintaining Your privacy online. Please read this Privacy Statement to understand how Your personal data will be treated as You use this site. This Statement may change from time to time so please check back periodically.

ReMember is a private site available only to Alumni, former employees of TechM. Please do not give out Your username or password to anyone. If You know of an alumnus looking to get access, please ask them to register at the site. In addition, please respect the privacy of other Alumni members and do not give out personal data obtained from the site to anyone.

Please keep in mind that whenever You voluntarily disclose personal information online - in the optional fields in Your profile, through email, or in chat areas - that information is accessible to the rest of the Alumni community, and can be made public by them. TechM cannot be held responsible for any misuse of such information by others, including any unsolicited messages You may receive as a result of providing information at this site.

What information do we gather?

ReMember collects personal data when You directly give it to us, such as:

when You register. During registration and profile set-up, we require that You provide Your Name, Call Name, Date of Birth, Email, Phone Number, Location (Country and City), Professional Skills, Notable Projects( without naming any clients or customers), Current and Previous employer details, Special Interests, Blogs/websites, Date of Birth. If You were previously a user of another TechM Alumni website, additional information that You provided to that site may be automatically added to Your profile at this site. The more information You volunteer (and the more accurate it is), the better we are able to customize Your experience. However, please supply only information that is relevant for the stated purposes of this website. We may keep a record of the following types of information: `

Name, Call Name, Date of Birth, Email, Phone Number, Location (Country and City), Professional Skills, Notable Porjects, Current and Previous employer details, Special Interests, Blogs/websites, Date of Birth.

Correspondence between You and ReMember,

Information You post on ReMember, such as on the chat pages,

responses to online surveys that we use for research and quality control purposes, and

IP addresses, which are collected indirectly through our website technology and used for system administration purposes.

ReMember also shares a small amount of information about You with TechM during the registration process in order to verify that You are a TechM alumnus. This information includes Your Name, Employee ID and DOB.

How do we use Your personal data?

ReMember will use Your personal data for the following purposes:

To enable other users to search for and locate You via the directory, only in cases where You have chosen to make the information public

To research and analyse our users' demographics, interests and behaviour in an aggregated form to better understand and serve our users and improve our site and its offerings.

To contact You periodically with communications about events, publications or employment opportunities with TechM, which we feel might interest You.

To share with other internal TechM systems, specifically our internal recruiting tool, to contact You with hiring relevant information. This will only happen if You opt for an opportunity on the careers link through ReMember, this can also be avoided as per Your actions.

We may also use data for other purposes, which we would always describe to You when we collect the information.

With whom will ReMember share personal data?

As a global organization, data that TechM collects may be transferred internationally within TechM’s worldwide organization, in accordance with the privacy statement, terms of use or as otherwise communicated from time to time and in relation to the Alumni program.

ReMember does not sell or rent Your personal data. We will not disclose any of the personally data You provide to this site to third parties, except:

to our service providers, such as auditors, and contractors, including TechM, who may help develop or maintain this site,

with Your prior and informed consent, or

when required by law or a court of tribunal of competent jurisdiction, or

to third parties in the event that TechM sells or liquidates all or any part of its business or assets, or

to business partners or sponsors where this is necessary for the purposes related to the Alumni program, in which case this will be specifically described to You prior to data collection or prior to transferring the data, and You can choose not to allow the transfer by not using that particular service, or

in special cases when this is necessary in order to identify, contact or bring legal action against someone who may be violating our Terms of Service or may be causing injury to or interference with (either intentionally or unintentionally) someone else's rights or property.

What about sensitive personal data?

When You register, Your name and other details as per Your consent appears in the Alumni Directory and is visible to other registered members of the TechM Alumni community. When You complete Your profile following registration, You may choose which pieces of information are visible in the directory using the "Make it Public" feature. You may change this at any time by editing Your profile using the "Update Profile" function.

You are entitled to know what information we hold about You and to have access to that information. You can access, edit or correct the information in Your profile at any time.

Finally, You can ask us to delete or deactivate Your user account, but then You will not be able to access the site. If You choose to deactivate Your account, we will delete any residual information after a reasonable time, unless otherwise required by law. You can exercise these rights and choices by contacting us at: AlumniConnect@TechMahindra.com

Your choices and rights

We do not generally seek to collect sensitive personal data through this site. In the limited cases where we do seek to collect such data, we will do this in accordance with local data privacy law requirements. If You choose to provide us with unsolicited sensitive personal data, You consent to our using the data, subject to applicable law as described in this privacy policy. These categories may include personal identity numbers, racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union or profession or trade association, physical or mental health, biometric or genetic data, sexual life, or criminal record (including information about suspected criminal activities).

Data security

Your user account information is password-protected so that only You, TechM have access to this personal information.

Do not divulge Your password to anyone. Also remember to sign out of Your account and close Your browser window when You have finished using the site, particularly if You share a computer with someone else or are using a computer in a public place like a library or Internet cafe.

We take appropriate steps to maintain the security of personal data collected via ReMember’s site. You should understand that the open nature of the Internet is such that information and personal data may flow over networks connecting You to our systems without security measures and may be accessed and used by people other than those for whom the data is intended.

Our site may, from time to time, contain links to and from the sites of our partner networks, advertisers and affiliates. If You follow a link to any of these sites, please note that these sites have their own privacy policies and that we do not accept any responsibility or liability for these policies or sites. Please check these policies before You submit any personal data to these sites.

Enforcement, additional information and contact details

Contact TechM

If You have any further questions on this Privacy Statement or how Your personal data is used in relation to the membership services at this site, please contact TechM using the contact information provided below.

AlumniConnect@techmahindra.com

Declaration

Data collected via this exercise will be used by Tech Mahindra remember team in arrange workshops and networking session among the Company alumni. The data will be handled in accordance with the current provisions of data protection policy of Tech Mahindra Ltd. Tech Mahindra Ltd. aims in particular to maintain a degree of protection for the data collected which corresponds to US, UK, EU and other applicable law in order to avoid any illegal use of or access to the data.