Privacy Policy

Website Privacy Policy

We at The Positive IT Corporation, including its subsidiaries and affiliates (collectively referred to as “The Positive IT” or “our” or “we”), are strongly committed to respect your privacy. This Website Privacy Policy describes our privacy practices regarding personal data collected through our website, which includes https://thepositiveit.com/ and any of our related websites (collectively, our “website”).

Any questions regarding our Privacy Practices should be directed to the Data Protection Officer (details provided in the Contacts section below).

Our processing activities

To find out more please go to the sections of this statement that are relevant to you.

Website Visitors (See below) | Clients | Visitors to Office | Employment Candidates

Collection and use of personal data

  1. Personal data collected automatically
  2. Our website collects certain information automatically and stores it as logs. The information collected by us is as follows:
  • Internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, device type used to access the website, browser type, operating system and other information about the usage of The Positive IT’s website, including a history of the pages you view. This is typically done to recognize your device, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics to enable us in providing better user experience to you in your future visits to this website.
  • The Positive IT’s website also uses cookies and web beacons. The Positive IT has enabled personalized advertisements based on your interests, using information made available when you interact with our website. Personalized or targeted ads are displayed based on your activities on The Positive IT and third-party websites which includes, but is not limited to visiting the website and interacting with content provided in the website. Cookies are used to enable us to learn what actions you perform in the website. These ads are displayed on external websites unaffiliated to The Positive IT. To know more about our use of cookies, please see our  Cookies Privacy Policy.
  1. Personal data collected from you
  2. We directly collect from you, the personal data in following ways:
  • By entering information in the “Contact Us” section, we collect your name, email address, country of residence, phone number, job title, company you represent and details of the inquiry to enable us to respond to a general/business inquiry made by you on behalf of your company.
  • You provide us information during registrations. In order to send you our newsletters, other news alerts that you may have subscribed to and webinars, we ask for your name, phone number, designation, email address and company you represent. Please note that we may also be collecting any information that you may have mentioned in any communication/email that you send to us after registering with us.
  • You provide us your email address when subscribing to and using the Email Preference Center. The preference center keeps track of your communication preferences (over email) and areas of interest (such as receiving newsletters and/or webinar mailers) that you may have either opted into or opted out of.
  • By entering information through registration with The Positive IT Careers, we obtain your name and email address to contact you as an Employment candidate, and consider you for job opportunities within The Positive IT.

We collect, use, and disclose the received information only to pursue our legitimate business interests in keeping you updated on our services and products, respond to your queries, establish communication with prospective clients (whom you represent) and to enhance user experience by analyzing your use of our website. We may also use information as a part of our audit processes, to enforce our agreements with you (including our website terms of use), to protect our rights, systems, property and personnel, and for such other purposes as are required or permitted by law. 

You also have the option to subscribe/opt-in to receive newsletters, new alerts and marketing content. You can opt-out of such options using our blog or click the “unsubscribe” link at the bottom of an email newsletter. You may also opt-out by contacting us directly using the contact information in the “Our contact details” section below.  We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request.  Please note that if you opt-out from receiving marketing-related emails, we may still need to send you non-marketing communications about your use of our website, or other matters.

Children’s information

Our website is not designed or directed at children. We will not intentionally collect, maintain, or distribute information about anyone under the age of 16. 

If you are a parent or guardian of a child who has provided personal data without your knowledge and consent, you may request us to remove the minor’s  information by emailing us at admin@thepositiveit.com 

Security

The Positive IT has implemented technical, physical, contractual, and organizational safeguards with a view to protecting the security of personal data from loss, damage, or unauthorized use, disclosure, alteration,  or access, having regard to the nature of the data, and the risks to which they are exposed by virtue of human action or the physical or natural environment.

Key security measures include and are not limited to the below:

  • Adopting technology and processes to limit access to your personal data to The Positive IT employees on a need to know basis, such as to respond to your inquiry or request.
  • The Positive IT adheres to ISO 27001, Certification on Information Security Management Systems, and is annually audited by the Independent auditing body, British Standards Institute (BSI) for effectiveness of controls to protect The Positive IT and Customers’ information.
  • The Positive IT undergoes regular penetration testing by independent third-party service providers.
  • The Positive IT employees are expected to adhere to The Positive IT’s Code of Conduct and Privacy policies, and any misuse of information is subject to strict disciplinary actions.

Transfers and disclosure of personal data

We are part of an international group of companies and, as such, transfer and disclose personal data concerning you to countries outside your country of residence. While such information is outside of your country, it is subject to the laws of the country in which it is located, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. 

We transfer personal data between our affiliated entities and delivery centers, as well as to third party service providers, for the purposes explained above. Please click here  to see list of our companies within our corporate group.  We require our affiliates and service providers maintain the confidentiality of your personal data and keep your personal data secure.  We also require that they only use your personal data for the limited purposes for which it is provided, and that it is retained as per the local regulatory requirements.  In some circumstances, we may permit our affiliates or service providers to retain aggregated, anonymized or statistical information that does not identify you.  We do not authorize our affiliates or service providers to disclose your personal data to unauthorized parties or to use your personal data for their direct marketing purposes.

We may disclose your personal data to give effect to transactions with you, to enforce our agreements with you (including our website terms of use), to protect our rights, systems, property and personnel, and for such other purposes as are required or permitted by law. From time to time we may consider corporate transactions such as mergers, acquisitions, reorganization, asset sale or similar. In such instances, we may transfer, disclose, or allow access to information to enable assessment and undertaking of transactions.

Your personal data is stored in databases, and on the servers of the cloud-based database management services that The Positive IT engages, located within and outside your country of residence.

The Positive IT does not provide any personal data to advertisers that display the personalized ads. Advertisers may provide us information about you (such as the sites where you have been shown ads) that we may use to provide you more relevant and useful advertising. Advertisers use technology to serve the ads that appear on our sites directly to your browser. They may use cookies to measure the effectiveness of their ads and to personalize ad content.

Retention of personal data 

We will only keep your personal data for as long as is reasonably necessary to fulfill the purposes for which it was collected, taking into consideration our need to respond to your queries or resolve problems, any other purpose outlined above or to comply with legal requirements under applicable law(s). This means that we may retain your personal data for a reasonable period after, for example, the end of the contract with the client you represent, or after your query has been addressed. After this period, your personal data will be deleted from all The Positive IT systems.

We remind you that you have a right to request to have your personal data deleted at any time. You may always choose to opt-out by writing to us at admin@thepositiveit.com.

Your rights

Subject to the requirements under applicable privacy laws, you have a right to:

  • Request access to your personal data and request details of the processing activities conducted by The Positive IT.
  • Request that your personal data be rectified if it is inaccurate or incomplete.
  • Request erasure of your personal data in certain circumstances.
  • Request restriction of the processing of your personal data by The Positive IT in certain circumstances.
  • Object to the processing of your personal data in certain circumstances.
  • Receive your personal data in a structured, commonly used and machine-readable format in certain circumstances.
  • Object to, and not to be subject to a decision based solely on, automated processing (including profiling), which produces legal effects or significantly affects you.
  • Withdraw any consent you may have provided to us at any time by contacting us. In some cases, withdrawal of your consent may mean that we will no longer be able to provide you with certain products or services or such withdrawal be subject to legal or contractual restrictions. We will inform you of the implications of your withdrawal of consent.
  • Your rights as Australia resident, you have the right under the Australia Consumer Privacy Act of 2018 (“ACPA”) to opt-out of the sale of your personal data. Whereas we do not sell any personal data in return for money, we do disclose it to third party service provider.

To exercise the rights outlined above in respect of your personal data, you may also contact our Data Protection officer admin@thepositiveit.com..

If you provide Personal data about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use and disclose his or her information as described in this data privacy statement.

External website links

This site contains links that may lead you to other sites. Be careful when accessing these links, as The Positive IT is not responsible for the privacy practices or the content of such other Websites. This Website Privacy Policy does not extend to any websites or products or services provided by third parties.

Our contact details

The Positive IT is the controller of data for the purposes of Data Privacy. If you have any concerns as to how your data is processed you can contact our Data Protection officer at admin@thepositiveit.com

Privacy statement: Clients

We at The Positive IT Corporation, including its subsidiaries and affiliates (collectively referred to as “The Positive IT” or “our” or “we”), are strongly committed to respect your privacy. The Positive IT may collect and maintain certain personal information about our clients (referred as “client” or “you” or “your”) in the context of providing services to our clients.

Collection and use of personal data

We use your personal data in order to establish a connection with you (whom you work for or represent), provide you and the client with a better client experience by analyzing your use of our website. and ensure that the marketing material we send to you reflects your personal preferences. The categories of personal data that are typically collected and processed:

  • Personal details (e.g. name, gender, country of residence);
  • Contact details (e.g. email address, contact number, postal address); and Job details (e.g. designation, job role, job title, company you represent). 

The personal data is collected or obtained from the following channels:

  • Information when you access our Website
  • By registering with The Positive IT
  • E-mail Campaigns
  • Information when you access our content on our Third Party partner Website(s)
  • Corporate Marketing and Thought Leadership Events
  • Information obtained from Third Party Business Contact Directory and Services
  • Information obtained from our Business Leaders
  • Information obtained from public sources and professional networking platforms such as LinkedIn.
  • Information received prior to/during fulfilment of contractual services

Purposes of processing your personal data

  • To contact you in order to inform you of new products, services or promotions, keep you appraised of thought leadership and marketing collateral and to better assist your needs, on occasion with your consent.
  • To invite you to The Positive IT hosted or sponsored events in your geographical region that may be of interest to you based on your role within the company and/or industry.
  • To conduct market research and to carry out marketing campaigns.
  • To carry out the services for which we have been contracted by the client you represent to deliver, and to contact you for client care related purposes including regular communication regarding project status, notifying issues/concerns, sharing project deliverables and carrying out day-to-day project activities, in order to comply with our contractual obligations.
  • To communicate with you about our service offering, for example to inform you that our services have changed or to send you critical alerts and other such notices relating to our products and/or services.
  • As part of our Sales program, our representatives may call you to inform you about our service offerings or promotions and may record their feedback and observations of such conversations to help us identify and target potential clients and business partners.
  • To conduct surveys in order receive feedback from you on the services currently provided by The Positive IT to the company you represent. We use your responses to understand our strengths and identify improvement areas to develop new and improved products, help us serve the company you represent better and improve our overall service offerings and business strategies.

You may always choose to opt-out from the marketing activities/communications referred to above by writing to us at admin@thepositiveit.com.

Security

The Positive IT has implemented technical, physical, contractual, and organizational safeguards with a view to protecting the security of personal data from loss, damage, or unauthorized use, disclosure, alteration,  or access, having regard to the nature of the data, and the risks to which they are exposed by virtue of human action or the physical or natural environment.

Transfers and disclosure of personal data with Third parties

We are part of an international group of companies and, as such, transfer and disclose personal data concerning you to countries outside your country of residence and outside the EU. While such information is outside of your country, it is subject to the laws of the country in which it is located, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.

We transfer personal data between our affiliated entities and delivery centers, as well as to third party service providers, for the purposes explained above.

We require our affiliates and service providers maintain the confidentiality of your personal data and keep your personal data secure.  We also require that they only use your personal data for the limited purposes for which it is provided, and that it be disposed of when no longer needed for those purposes.  In some circumstances, we may permit our affiliates or service providers to retain aggregated, anonymized or statistical information that does not identify you.  We do not authorize our affiliates or service providers to disclose your personal data to unauthorized parties or to use your personal data for their direct marketing purposes.

  • We may use carefully selected third parties to carry out certain activities to help us to run our business (such as cloud service providers, IT support vendors) and to carry out surveys (third party survey vendors).

Existence of Automated Profiling and Decision Making

We use automated profiling in limited circumstances relating to email campaigns.  As part of our email campaigns, we will track whenever you receive, open, click a link, or share an e-mail you receive from The Positive IT using an automated solution. The automated solution profiles the information tracked to evaluate your interest towards our service offerings or promotions. This enables us to identify and target potential clients or business partners and provide you with relevant and timely content based on your interests.

Retention of personal data

We will only keep your personal data for as long as is reasonably necessary to fulfill the purposes for which it was collected, taking into consideration our need to respond to your queries or resolve problems, any other purpose outlined above or to comply with legal requirements under applicable law(s). This means that we may retain your personal data for a reasonable period after, for example, the end of the contract with the client you represent, or after your query has been addressed. After this period, your personal data will be deleted from all The Positive IT systems.

For Further Details

For more information, such as your rights in respect of your personal data, transfer of personal data, data retention and security measures implemented by The Positive IT, please click here.

Privacy statement: Visitors

Dear Visitors,

We at The Positive IT Corporation, including its subsidiaries and affiliates (collectively referred to as “The Positive IT” or “our” or “we”), are strongly committed to respect your privacy.  The Positive IT respects you and are committed to honoring and safeguarding your privacy. This Privacy Notice describes our privacy practices regarding collection and use of your personal data when you visit our company premises.

Collection of personal data

We collect basic personal information from you in our visitors database and/ or visitor log book, which includes but is not limited to name, company name, phone number, reason of visit, date & time, photograph, etc. Video footage is also being recorded on our CCTV system installed on company premises.

Purpose for processing your personal data

We collect, use and disclose information to ensure the physical security of the people and items, security of confidential Information located in the company’s premises or accessible from the company’s premises. This is done to prevent loss, frauds, thefts, injuries, terrorism and other events of such kind in the company’s premises.

Security

The Positive IT has implemented technical, physical, contractual, and organizational safeguards with a view to protecting the security of personal data from loss, damage, or unauthorized use, disclosure, alteration,  or access, having regard to the nature of the data, and the risks to which they are exposed by virtue of human action or the physical or natural environment.

Transfers and disclosure of personal data with affiliates

We are part of an international group of companies and, as such, transfer and disclose personal data concerning you to countries outside your country of residence and outside the EU. While such information is outside of your country, it is subject to the laws of the country in which it is located, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.

Retention of personal data

We will only keep your personal data for as long as is reasonably necessary to fulfill the purposes for which it was collected, taking into consideration our need to respond to your queries or resolve problems, any other purpose outlined above or to comply with legal requirements under applicable law(s). This means that we may retain your personal data for a reasonable period after, for example, the end of the contract with the client you represent, or after your query has been addressed. After this period, your personal data will be deleted from all The Positive IT systems.

For Further Details

For more information, such as your rights in respect of your personal data, transfer of personal data, data retention and security measures implemented by The Positive IT, please click here.

Privacy statement: Employment candidates

We at The Positive IT Corporation, including its subsidiaries and affiliates (collectively referred to as “The Positive IT” or “our” or “we”), are strongly committed to respect your privacy. The Positive IT may collect and maintain certain personal information about our employment candidates (referred as “you” or “your”) as part of records of recruiting and resourcing activities.

Collection and use of personal data

We collect, use and maintain the below categories of personal data and sensitive personal data of our employment candidates. The personal data collected may include but is not limited to:

  • Identification Informationincluding name, age, date of birth, email address, home address, contact details, government-issued identification numbers, photographs, demographic information, citizenship, nationality, marital status, languages spoken, etc.
  • Educational and Professional Detailsincluding higher education, certifications, previous employment history, etc.
  • Online Information, e.g., Information provided by you on “Taleo” and “My Career” Portal such as First Name, Last Name, Email Address, Phone Number, etc.
  • Technical Information:When you access our services online, our web servers automatically create records of your visit. Please read our website privacy policy by visiting https://thepositiveit.com/privacy-policy/for more information.
  • Information collected during interviews:As part of our interview process, we may maintain information learned about you as a result of assessments or evaluations, which may include certain types of data about your personality, behavior and suitability for a particular position. Personal information captured in a video recording may include personal information such as your voice and image.
  • Information found from public sources as well as information related to reference checks, depending on the position you are applying for, and where necessary for the recruitment activities.
  • Once you have been shortlisted, we may collect additional information such as Government Identifiers, expectation of compensation and remuneration details, information relating to your family members (for benefits administration) and dependents, passport, visa and work permit (in case of expatriate), background check reports including educational and employment checks etc. where permitted by local law. We may collect your bank account details, details of the expense incurred and relevant bills to reimburse any expenses incurred by you during the interview processes.

The sensitive personal data collected may include:

  • Information relating to your Health:such as physical examination results, accident and injury reports, disability status etc.
  • Information related to racial, ethnic origin or religious beliefsto comply with local regulatory law(s).
  • Data relating to criminal convictions and offencescollected from background checks.
  • Information revealed in a video interviewsuch as racial or ethnic origin, religion or philosophical beliefs, physical or mental health or condition, job evaluations or educational records. The Positive IT does not require and asks that you do not provide such types of personal information.

Purposes of processing your personal data and the legal basis for processing

We collect, use and disclose your personal data for the purposes of The Positive IT’s recruitment or resourcing activities. This information will be collected by us directly from you when you apply (online or via email or in person), through referrals from your friends, family of professional connects who work at/ with The Positive IT and from third parties (recruitment agencies and background verification agencies), which may also include public sources such as professional networking platforms. The purpose is to comply with any legal requirements, pursue our legitimate business interests and defend our position in legal proceedings. Your personal data shall be utilized in the following ways:

  • Communicating with you, in context of recruitment activities:
    • To obtain additional information about your suitability for the role where necessary;
    • To inform you of available vacancies;
    • To provide you with information relating to your application and to fulfil your requests.
  • Managing recruitment and resourcing activities, including activities related to organizational planning. We may use your information:
    • To set up and conduct interviews and assessments;
    • To evaluate, select and recruit applicants;
    • To contact third-party referees provided by you to evaluate your previous performances.
    • In the event your profile is shortlisted, we may collect additional personal data to carry out background checks (in accordance with local law), facilitate travel for face to face interviews and to roll-out an employment offer letter.
  • Monitoring and development of our recruitment process– We may use your personal data and aggregated anonymous information to develop and improve our recruitment processes, websites and other related services.
  • Audit Compliance– We may process personal data as part of our audit processes and engage third-party auditors, to comply with applicable laws and legitimate business interests of the company.
  • Accommodation for disabilities– In certain instances, we may receive or request for information related to health such as disability status in order to make any necessary accommodations during our interview process. The Positive IT shall process such information only based on your explicit consent.
  • Prevention of fraud– We may process your personal data for the purpose of fraud prevention in pursuit of the legitimate interests of the company.
  • New employment opportunities – If you have expressed an interest in working for us in the future we may retain relevant documents collected during the recruitment process containing your personal data for future employment-related opportunities.

Security

The Positive IT has implemented technical, physical, contractual, and organizational safeguards with a view to protecting the security of personal data from loss, damage, or unauthorized use, disclosure, alteration,  or access, having regard to the nature of the data, and the risks to which they are exposed by virtue of human action or the physical or natural environment.

Transfers and disclosure of personal data with Third parties

We are part of an international group of companies and, as such, transfer and disclose personal data concerning you to countries outside your country of residence and outside the AU. While such information is outside of your country, it is subject to the laws of the country in which it is located, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.

We transfer personal data between our affiliated entities and delivery centers, as well as to third party service providers, for the purposes explained above.

  • We require our affiliates and service providers maintain the confidentiality of your personal data and keep your personal data secure.  We also require that they only use your personal data for the limited purposes for which it is provided, and that it be disposed of when no longer needed for those purposes.  In some circumstances, we may permit our affiliates or service providers to retain aggregated, anonymized or statistical information that does not identify you.  We do not authorize our affiliates or service providers to disclose your personal data to unauthorized parties or to use your personal data for their direct marketing purposes. Where required or permitted by law, personal data may be provided to others, such as regulators and law enforcement agencies.  We may use selected third parties to carry out certain activities to help us to run our business (such as cloud service providers, IT support vendors), to facilitate language tests (language assessment agencies), to carry out background checks (background verification agencies) to facilitate your travel and expense (travel and immigration vendors) and to facilitate audits (third-party auditors)
  • We share information with our internal staff and our group of companies for screening and interview purposes.

Existence of Automated Profiling and Decision Making

We do not carry out any processing activities that involve automated profiling and decision making.

Retention of personal data

We will only keep your personal data for as long as is reasonably necessary to fulfill the purposes for which it was collected, taking into consideration our need to respond to your queries or resolve problems, any other purpose outlined above or to comply with legal requirements under applicable law(s). This means that we may retain your personal data for a reasonable period after, for example, the end of the contract with the client you represent, or after your query has been addressed. After this period, your personal data will be deleted from all The Positive IT systems.

For Further Details

For more information, such as your rights in respect of your personal data, transfer of personal data, data retention and security measures implemented by The Positive IT, please click here.

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