1. Who are we?
is generally a legal organization or person that determines the purposes for which, and the manner in which, personal data are or will be processed.
is any person or organization who processes personal data on behalf of the data controller
As Ugam being in the business of Data Analytics it provides services to its customers or clients which are generally the Data Controllers. Ugam may receive personal information in the due course for processing, as part of the services offered. Whereby, Ugam shall be considered a Data Processor for its clients. Likewise, there could be business scenario where Ugam handles your personal data as a Data Controller.
4. What personal data do we collect and how will we use your personal data?
Personal Data is information that identifies you or can be used to identify or contact you. Such personal data may include your name, address, email address, telephone number, and billing information.
We may collect and process the following personal data about you:
If you are a California resident, the following applies to you:
- Information provided by you: When you visit our website or access our resources, we collect basic information such as first name, last name, company, job title, work email and comments provided by you in our website form or through content download form. We also collect this information when you choose to contact us through our website and enable us to respond to a general/business inquiry made by you.
- Information provided by Clients: We receive personal data provided by our clients such as name, company name, position, contact information, financial information for payment and personal data relating to the clients or other third parties which they provide to us for the purpose of receiving our services.
- Information provided during surveys: We may collect and process any information provided by you as part of the survey or research study conducted by Ugam, or on behalf of Ugam. In most such cases, we collect information on behalf of our clients as part of research studies where Ugam is a data processor. We also record the responses and feedback provided by you as part of these studies.
- Information such as Internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, other information about the usage of Ugam’s website, including a history of the pages you visited. 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 these pages and other statistics to enable us in providing better user experience to you in your future visits to our website.
- Information provided under careers page: When you apply for a job role in Ugam through careers page, we collect information such as name, email address, contact details, academic and professional qualifications, education, CV/Resume, and city/location. We use this information to enable us to contact or respond you for the employment purposes.
- Information from third parties and integration partners: We collect your personal information from third parties where, for example, you give permission to those third parties to share your information with us, where such information is publicly available online. We may also collect information from third party recruitment agencies and universities.
- We also collect information provided by you when you unsubscribe or choose to opt-out by writing to us at email@example.com using your email address. We ensure all the data is completely deleted once the data subject chooses to opt-out or unsubscribe.
- We may also process sensitive personal data about you for our business purposes with regards to surveys or research studies conducted by Ugam or on behalf of Ugam. We will ensure that we do not process any sensitive information without informing you prior of the survey.
- In some circumstances, we may take photographs of individuals at seminars or events we run, sponsor or are otherwise involved in, which may be posted on our social media platforms. By agreeing to be a part of the seminar or social event, Ugam would request you to provide your consent to post the photographs on our social media platforms.
In the past 12 months, we have or may have collected the following information about you. Please note that the following list represents categories of personal data across all California residents whose personal data we may have collected or received and does not necessarily represent information we have collected specifically about you:
A real name, name of country, online identifier, Internet Protocol address, email address, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, telephone number, employment, employment history,
C. Protected classification characteristics under California or federal law.
Age (as range and not exact age), race, national origin, religion or creed, marital status, , sex (gender), sexual orientation.
D. Commercial information.
Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.
This category is not applicable.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application.
G. Geolocation data.
This category is not applicable.
H. Sensory data.
This category is not applicable.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
This category is not applicable.
K. Inferences drawn from other personal information.
This category is not applicable.
Please also note that the definition of “personal information” under CCPA is subject to certain exceptions as set forth therein and does not include information that is publicly available or has been aggregated or deidentified in accordance with CCPA.
We disclose your personal information for a business purpose to the following categories of third parties:
- Our affiliates.
- Service providers.
- Market research agencies.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with services we provide to you.
4.1. Marketing Communications
We may collect and use personal information about individuals to send marketing and promotional communications that we may believe will be of interest to them. These communications may be sent in various ways, including by email or other electronic means.
4.2. General cases
Other general cases where we may collect personal data include the collection in relation to subscriptions to our promotional activities, events organised by Ugam where you may be a participant, during acquisitions and mergers, for communicating with you when you reach out to us over email, for communicating with you if you are a potential business prospect for Ugam etc. The personal data collected in these scenarios will belong to the categories of personal data mentioned in the sections above, and the collection would be on the basis of one of the following lawful bases only:
- Where we need to perform a contract that we will be entering into with you
- Where we need to comply with a legal obligation
- Where it is necessary for our legitimate interests
- Where we need to protect your vital interests (or someone else's vital interests)
- Where we have obtained your explicit consent through our website
- Where it is required for the public interest (or for official purposes)
You are not required to provide the personal data that we have requested. However, if you choose not to do so, in many cases we will not be able to provide you with our resources on the website, our services or respond to requests you may have.
5. How do we keep your personal data secure?
We take reasonable steps to ensure your personal data is protected from misuse and loss and from unauthorised access, modification or disclosure, and other risks to which it may be exposed by virtue of human action or the physical or natural environment. To this effect, we adopt physical, technical, and organisational measures to ensure the security of personal data.
We take steps such as the following to protect your personal data:
- Prevent unauthorised persons from gaining access to data processing and storage systems in which personal data are processed
- Prevent persons entitled to use data processing systems from accessing personal data beyond their needs and authorisations
- Ensure that in the case where processing is carried out by another entity on our behalf, the data is processed only in accordance with the data processing addendums and the agreed contractual obligations
- Ensure that personal data is not retained longer than necessary
5.1. For Minors
Our Site is not intended for use by minors under the age of sixteen (16) years. Ugam does not knowingly collect, disclose, or sell the personal data of minors under 16 years of age. If you are under 16 years old, please do not provide any personal data even if prompted to do so. If you believe that you have inadvertently provided personal data, please ask your parent(s) or legal guardian(s) to notify us and we will delete your personal data.
6. How do we share and disclose your personal data?
Information shared within Ugam and Ugam’s parent and legal entity:
We may from time to time disclose your personal data within our group of companies. All of the categories of personal information under CCPA may be shared (and have been shared within the last 12 months) within our group of companies.
Information shared with our third-party service providers:
We use a number of third parties to perform business functions on our behalf, such as sending our newsletters and hosting our online services and customer relationship management. We will disclose personal data to these vendors and service providers to enable them to provide their services. In cases where Processing is carried out by a Data Processor or Data Sub Processor, the data shall be processed only in accordance with the instructions of security requirements of Ugam.
All of the categories of personal information under CCPA (see Your California Rights) may be shared (and have been shared within the last 12 months) with our third-party service providers.
Information shared due to corporate mergers or restructuring:
We may disclose personal data with any successor to all or part of our business. For example, if part of our business is sold, we may give our customer list as part of that transaction. All of the categories of personal information under CCPA (see Your California Rights) may be shared with any successor for this purpose.
Information shared with other parties as required by law or to prevent or investigate illegal activities:
Where required or permitted by law, personal data may be provided to others, such as regulator and law enforcement agencies, for example in response to a court order, or in response to a law enforcement agency’s request, or where we believe it is necessary to investigate, prevent or take action regarding illegal activities or to protect Ugam, our websites, customers, employees, and business partners from fraud or other malicious activity, and as otherwise required by law. All of the categories of personal information under CCPA (see Your California Rights) may be used by us or shared with other parties for these purposes.
We may use and share personal data as otherwise disclosed to you from time to time when collecting your personal information or as otherwise permitted by law. All of the categories of personal information under CCPA (see Your California Rights) may be used by us or shared with other parties for these purposes.
We do not sell or rent any personal data about you to any third party and have not done so within the past 12 months.
7. Do we use your personal data for any other purpose?
We will only use personal data for the purposes described above or as otherwise disclosed at the time we request such data from you. Should your personal data
has originally been collected for, we will provide you with information on that other purpose, and any additional relevant information.
8. How long do we store your personal data?
Our policy is to retain personal data only for as long as it is needed for the business purpose defined. Note that retention periods vary in different jurisdictions and are set in accordance with local regulatory and professional retention requirements.
In order to meet our professional and legal requirements, to establish, exercise or defend our legal rights, and for archiving and historical purposes we need to retain information for significant periods of time.
9. Do we process your personal data for automated individual decision-making?
We do not use your personal data to make decisions with legal or similar effects for you, based on only the automated processing of your personal data. In case we perform automated individual decision-making in the future, we will inform you of the same and your rights regarding the opting-out of such processing.
10. External Website Links
By accessing third party websites through our site, you are consenting to the terms and privacy policies of those websites. We do not accept any responsibility or liability for their privacy practices or the content of such Websites.
11. What rights do you have?
You have the following rights with respect to your personal data.
- Right to Access and Data Portability
You have the right to request from us information on the personal data about you we process at any time.
This also enables you to receive a copy of the personal data we hold about you.
If you are a California resident, you may have the right to request that we disclose to you information about our collection and use of your personal data in the preceding 12 months, including:
a. the categories and specific pieces of personal data we collect;
b. the categories of sources from which we collect or sell personal data;
c. the business or commercial purpose for which we collect personal data;
d. the categories of third parties with whom we share personal data; and
e. the categories of personal data disclosed for a business purpose or sold to third parties and the categories of third parties to whom such personal data was sold or disclosed.
- Right to Rectification of Incorrect Data
If data about you is inaccurate, you have the right to obtain from us the rectification of such data without undue delay.
- Right to Erasure
a. You have the right to request from us the erasure of your personal data. In particular, you may ask us to erase personal data, if
b. it is no longer necessary in relation to the purposes for which it was collected or otherwise processed
c. the personal data has been unlawfully processed
d. you object to the processing, and there are no overriding legitimate grounds for the processing
e. the personal data has to be erased for compliance, with a legal obligation in Union or Member State law to which we are subject; or
f. you withdraw your consent on which the processing is based, and there is no other legal ground for processing.
If you are a California resident, you may request that we delete certain personal data that we have collected about you. The foregoing is subject to our right to maintain your personal data for specific purposes permitted under CCPA. If we are unable to comply with any such request, we will notify you.
- Right to Restriction of Processing
You have the right to obtain from us restriction of processing, where one of the following applies:
a. The accuracy of the personal data is contested by you, processing will be restricted for a period, enabling us to verify the accuracy of the personal data
b. the processing is unlawful, and you oppose the erasure of the personal data and request the restriction of its use instead
c. we no longer need the personal data for the purposes of the processing but are required by you to keep it for the establishment, exercise or defense of legal claims;
d. you have objected to processing, and the verification whether our legitimate interests override yours is pending.
- Right to Object
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you. We will no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing serves the purpose of establishing, exercising or defending legal claims.
- Right to Withdraw Consent
You have the right to withdraw your consent for the processing of personal data where explicit consent has been sought. In the limited circumstances where you may have provided your consent to the collection, processing, and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you are a California resident, you have the following rights under certain circumstances:
- Do not track
Ugam does not track its website visitors over time and across third party websites to provide targeted advertising. Third parties that have content embedded on Ugam’s websites such as a social feature may set cookies on a user’s browser and/or obtain information about the fact that a web browser visited a specific Ugam website from a certain IP address. Third parties cannot collect any other personally identifiable information from Ugam’s websites unless you provide it to them directly.
As part of processing your request, we require you to provide certain personal data about you in order to verify your identity in accordance with the GDPR and CCPA requirements. This information includes your first and last name, email address, physical address, telephone number, and description of relationship to Ugam, but may also include additional information based on the nature of your request and your relationship with us.
Additionally, in accordance with your rights under the CCPA, you may designate an authorized agent to make a request on your behalf. In order to comply with your request, we will require the personal data referenced above to be used for identity verification purposes, as well as the name, email address, and telephone number of your authorized agent.
Please note that in a period of last 12 months the access request made by you for your personal data should be limited to 3 to 4 requests.
12. What is the process for reporting a privacy-related breach or exercising my rights or sending complaints / grievances / questions?
You can, at any time, exercise your right to access your information, request a copy of personal information we hold about you, unsubscribe or request to withdraw consent, right to rectification, erasure, to be forgotten, to restrict data processing and to object data processing. You can communicate any of the above requests to us by writing to
You may use any of the following methods to exercise your rights or register any grievance / complaint related to our processing of your personal data or linked to our processing in accordance to applicable data protection principles, our policies, and procedures:
Your request will be responded within 72 hours and completed within max 30 days
It should be noted that situations may arise where providing the information requested by you would disclose personal data about another individual. In such cases, data may be redacted or withheld as may be necessary or appropriate to protect that person’s rights.
- Write an email to our Data Privacy Team at firstname.lastname@example.org.
- Call on our local US number +1-6462-543-500 extension 1433 between 11 a.m. to 7 p.m. (IST) Monday to Friday, except public holidays;
You also have the right to complain to the data protection authority in your country or refer the matter to a court of competent jurisdiction.