Last Updated:June 24, 2020
EU-U.S. and Swiss-U.S. Privacy Shield Frameworks
VeraSafe Privacy Program
Where a privacy complaint or dispute within the scope of Atos Syntel Inc.’s Privacy Shield certification cannot be resolved through Atos Syntel Inc.’s internal processes, Atos Syntel Inc. has agreed to participate in the VeraSafe Privacy Shield Dispute Resolution Procedure. Subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe and participate in the VeraSafe Privacy Shield Dispute Resolution Procedure, please submit the required information here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/
Basis of Processing
- The need to perform our contractual obligations, or to take pre-contractual measures at your request. Where we receive your personal information as part of providing our services to you based on a contract, we require such personal information to be able to carry out the contract. Without that necessary personal information, we will not be able to provide the services to you;
- The pursuit of our legitimate interests, such as selling and providing our services to prospective and current customers;
Personal Information Collection
We may collect various categories of personal information, including:
- biographical information (such as name, education, gender, work experience, skills, and photographs/video of you);
- contact information (such as email address, mailing address, and phone number);
- unique identifiers (such as user-name, permanent account numbers (PAN), and tax deduction and collection account numbers (TAN)); and
- professional information (such as job title and position).
We may collect such personal information:
- When you call, email, or write to us;
- When you submit contact form(s) on our websites, including registering to attend an event;
- When you post comment(s) to our blog;
- When you subscribe to our email alerts and/or newsletter;
- When you request printed materials to be sent to you in hardcopy;
- In person, including when you visit an Atos|Syntel facility;
- From your colleagues, industry-peers, and similar associates; and
- From any public source, such as information made public by your employer.
Please also note that Atos|Syntel facilities are monitored, including by CCTV surveillance.
Purposes of Processing
We may use this personal information to:
- Assess the needs of your business/employer to determine suitable products and services;
- Develop and track sales leads;
- Solicit inquiries from prospects;
- Send you requested product or service information;
- Respond to customer service requests;
- Process payments;
- Arrange travel;
- Send you a newsletter or email alerts;
- Send you marketing and sales-related communications;
- Respond to your questions and concerns;
- Improve our website and marketing efforts;
- Communicate with you regarding your visit to Atos|Syntel facilities;
- Maintain a record of visitors to Atos|Syntel facilities; and
- Help ensure the security of Atos|Syntel property and information.
We will retain your personal data for as long as necessary to fulfill the purpose(s) for which it was collected or to comply with legal, regulatory or internal policy requirements.
We may make your personal information available to our service providers, as necessary, in order for them to help us with our business operations. Our service providers include those providing marketing automation software, survey software, Internet hosting services, travel booking and insurance services, financial consulting services, communications services, as well as services related to operating and securing our facilities. We may also make your personal information available to our corporate affiliates, i.e., entities within the Atos corporate group, as well as Atos|Syntel’s subsidiaries and affiliates worldwide.
We may also disclose your personal information:
- As required by law, such as to comply with a subpoena, or similar legal process;
- When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate or prevent fraud, investigate or prevent crime, or respond to a government request;
- If one of the Atos|Syntel entities is involved in a merger, acquisition, or sale of all or a portion of its assets, in which case you will be notified via email and/or a prominent notice on our main website (https://www.atos-syntel.net/) of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information; and
- To any other third party with your prior consent to do so
If we must disclose your personal information in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials or otherwise in context of any investigation into any fraud or crime (actual or suspected), we may not be able to ensure that such recipients of your personal information will maintain the privacy or security of your personal information.
Accessing, Deleting & Updating Your Personal Information
You may have a right to request access to, and the opportunity to update, correct, port, or delete your personal information. Under certain circumstances, you may have a right to restrict or object to the processing of your personal information.
To submit such requests or raise any other questions, please contact us by using the contact information provided in the “Contact Us” section below. We will respond to your request within 30 days.
Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in such emails.
Privacy of Children
Our services are not directed at, or intended for use by, children under the age of 13.
We use both session cookies and persistent cookies. A session cookie expires and is automatically deleted when you close your browser. When you return to our websites a new session cookie will be placed on your device, which will store information related to your use of our website.
A persistent cookie remains on your device for an extended period of time. These cookies stay on your device until they are deleted manually or until the web browser deletes them automatically based on the duration period specified within the cookie. Persistent cookies help our websites remember your information and settings when you visit again in the future. You can remove persistent cookies by following directions provided by your Internet browser. If you configure your Internet browser to reject cookies, you may still use our websites, but your ability to use some areas of our websites may be limited.
Web Beacons / GIFs
Third party tracking technologies on our websites may employ a software technology called clear GIFs (a.k.a. web beacons) that help us better manage content on our websites by informing us what content is effective. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of website users.
Analytics / Log Files
As is true of most websites, our websites gather certain information automatically through analytics programs such as, but not limited to Google Analytics and Hubspot, and store it in log files. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which typically does not identify individual users beyond their IP address, to analyze trends, to administer the websites, to track users’ movements around the websites and to gather aggregated demographic information about our user base as a whole.
Behavioral Targeting / Re-Targeting
The security of your personal information is important to us. Atos|Syntel has implemented and maintains technical, administrative, and physical measures that are reasonably designed to help protect personal information from unauthorized processing such as unauthorized access, disclosure, alteration, or destruction.
No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee the absolute security of your personal information.
Links to Third Party Websites
Atos|Syntel may provide links to Internet websites of other parties. Atos|Syntel is not responsible for the contents of, or any products or services offered in, those third-party websites. You should be aware when you are leaving an Atos|Syntel website and be sure to read the privacy statements of each and every website that collects your personal information. Any links provided by Atos|Syntel to any thirdparty website are provided to you as a convenience only. You should not infer that Atos|Syntel endorses or accepts responsibility for non-Atos|Syntel websites by the inclusion of any such links to those websites.
Our websites may make message boards and public forums available to its users, such as within our blog. Please understand that any information disclosed in these areas becomes public information. Except where expressly authorized by Atos|Syntel, you are prohibited from collecting data about other users on our websites.
Social Media Widgets
Our websites include social media features, such as the Facebook like button, links to our social media pages and widgets, such as the AddThis® button or interactive mini-programs that run on our websites. These features may collect your IP address, which page you are visiting on our websites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy notice of the company providing it.
Changes to This Policy
You can reach Atos|Syntel through postal mail, phone, or fax.
Attn: Atos|Syntel Legal Department
Atos Syntel Inc.
525 E. Big Beaver Road
Troy, MI 48083
You may also email your privacy concerns to email@example.com and to Mr. Sandeep Godbole at Sandeep.Godbole@atos.net. Your concerns will be addressed as soon as possible, and always within 30 days of when we receive your communication.
If your dispute or complaint concerning data transferred to Atos Syntel Inc. in reliance on the Privacy Shield can’t be resolved by us, nor through the dispute resolution program established by VeraSafe, you may have the right to require that we enter into binding arbitration with you pursuant to the Privacy Shield’s Recourse, Enforcement and Liability Principle and Annex I of the Privacy Shield.
Atos Syntel Inc. is subject to the investigatory and enforcement powers of the United States Federal Trade Commission. If you are a resident of the European Union, you may have the right to lodge a complaint with a data protection regulator in your European Union Member State.
VeraSafe has been appointed as Atos|Syntel’s representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. VeraSafe can be contacted in addition to Atos|Syntel only on matters related to the processing of personal information. To make such an inquiry, please contact VeraSafe using this contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative or via telephone at: +420 228 881 031.
Alternatively, VeraSafe can be contacted at:
VeraSafe Ireland Ltd
VeraSafe Czech Republic s.r.o.
VeraSafe Netherlands BV
Data Protection Officer
We have appointed Matthew Joseph of VeraSafe as our Data Protection Officer (DPO). While you may also contact us, our DPO can be contacted on matters related to the processing of personal information. Our DPO’s contact details are:
22 Essex Way #8203
Essex, VT 05451 USA
Phone: +1 (617) 398-7069