Privacy Notice

 

Privacy Notice

1. Introduction

This Privacy Notice articulates the privacy and data protection principles followed by Hughes Systique Private Limited (hereinafter referred to as “Hughes Systique”) and its entities (also referred to as “we”, “us”, or “our”) around the world with regards to the safeguarding personal information of its data subjects (“you”, “your”, “user”, “subscriber”) i.e. customers (including products, outsourcing and other services clients), partners, employees (current or former employees, trainees), job applicants, contractors, prospects and vendors and current or former members of the Board of Directors, whose personal information are processed by Hughes Systique ("Data Controller").

This Privacy Notice explains the use and protection of personal information collected by Hughes Systique. It applies to any personal information you provide to Hughes Systique and, subject to local law, any personal information we collect from other sources (viz. email, tradeshows, social media etc.).

2. Scope of the Privacy Notice

This Privacy Notice covers our information privacy practices, including how we collect, store, use, protect and use personal information you provide to us, through our web site(s) that link to this Privacy Notice (collectively referred to as “Hughes Systique’s Web sites”) or other sources.

3. Our Details

“Hsc.com” is a property of Hughes Systique Private Limited, having its corporate office at D-24, Infocity II, Sector 33, Gurgaon – 122010, India. Hughes Systique is a software solutions and services company that has been instrumental in steering the digital transformation journey of its clients from the forefront. To learn or understand more about our solutions and services, you may read 'About Us' to know more about Hughes Systique.

4. Personal information collected by Hughes Systique

Personal information (PI) - means any information relating to an identified or identifiable living person (‘data subject’ here in referred as “you/ your”). In particular using a common 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 or any other piece of information as per applicable laws and regulations. Following are the categories of data subjects from whom we may collect personal information.

  • Individuals who have subscribed to our services or enquired to us to obtain information about our products and services offerings.
  • Individuals who have visited the website.
  • Our existing and former customers and their employees or representatives, which may include clients of our existing and former customers;
  • Our existing and former employees including agents, individual contractors or temporary workers and details of family members, guardians or associates/ referees  of employees, former employees or applicants;
  • Candidates who have applied for jobs/ employment;
  • Existing and former third party contractors, vendors, brokers, agents, consultants and suppliers and their individual employees;

4.1. Information collected when you visit our websites or via emails

In some instances, Hughes Systique automatically collects personal information pertaining to you when you visit our websites. The details of the same are as follows:

Server Log Information

We may process “Log information” that includes data about your use of our website and services. The log data may include, but not limited to your IP Address, geographical location, device details, browser type and version, operating system, referral source, length of your visit, page views and website navigation paths, as well as timestamps, frequency and pattern of your service use. Such information will allow us to improve the effectiveness and accessibility of Hughes Systique websites for your benefit and ease. Also, the sever log information is collected and stored to meet our legal obligation to implement appropriate technical and organizational measures to ensure security of personal information processed.

By using Hughes Systique’s websites, associated microsites and mobile applications, you agree to the processing of your information as explained in this Privacy Notice.

Cookies and similar technologies

A cookie is a small amount of data generated by a website and saved by your web browser. Its purpose is to remember information about you that shall allow us to improve your experience. Just like most of the professional websites we use functional and analytical cookies to gain insight on useful information such as counting website visitors and their user behaviour, targeted advertising, user preferences and for ease of authentication (e.g. auto profile login) purposes that will allow us to improve our services or products offerings, enhance user experience and ease of accessibility to the website users.

We also use web beacons or tracking pixels in our emails and web pages which help us to monitor whether you have opened any newsletters we may have sent to you. A web beacon is one of various techniques used on web pages or email, to unobtrusively (usually invisibly) allow checking that a user has accessed some content. Common uses are email tracking and page tagging for web analytics. We use this information to deliver you a personalized service by ensuring that we send you information that we believe you will find interesting based on the content we know you have engaged with previously.

For further information on how we use cookies and web beacons, please see our Cookie policy.

You may choose to reject certain or all cookies we use on our website by modifying your browser settings but doing so may prevent you from taking full advantage of the website as it may disable some or all of its features.

4.2. Information collected from mobile devices

If you access our websites on your mobile device, we may collect your personal information such as your First Name, Last Name, E-mail Address, Job Title, Organization Name, Country, City, Phone Number, IP address and Device details. When you provide us your mobile phone number, you consent to the use of your mobile phone number for the purposes identified in this Privacy Notice. If you choose to refrain from receiving any text notifications from us on your mobile, we will not be using your mobile number for such purposes unless required to meet legal requirements or legitimate business purposes. We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.

4.3. Information collected directly when you contact or enquire us

Personal information we process is mostly provided to us directly by you for one of the following reasons:

  • When you make an enquiry to us about our solution and service offerings.
  • When you make an information request to us.
  • When you subscribe to our marketing mailers and e-newsletter.
  • When you have applied for a job with us.
  • When you exchange information (i.e. business cards) with us at tradeshows or events for business purposes

We may collect personal information such as your First Name, Last Name, E-mail Address, Job Title, Organization Name, Country, City and Phone Number when you fill forms, create user account/ profile or raise a query through our websites, or send emails, call us or write to us.

You may choose to give us personal information such as your name and address or e-mail identification address (‘ID’) that may be needed, for example, to correspond with you, for you to download our white papers, to provide you with subscription information, marketing newsletters and mailers or for conducting business. We will endeavour to protect the accuracy and integrity of your personally identifiable information.

For job applications, you may provide us with personal information such as Name, address, email address, contact number and additional information as a part of CVs or resume such as qualifications, skills, experience and employment history and any other necessary information. However, this information shall only be collected upon obtaining an explicit consent from you.

Hughes Systique will not be liable for any unsolicited information provided by you. You consent to Hughes Systique using such information as per Hughes Systique’s Privacy Notice.

4.4. Information collected from indirectly or from third parties

We also receive personal information indirectly, in the following scenarios:

When you engage with us through social media websites or through features on Hughes Systique websites that integrate with social media sites. When you engage with us through social media sites, you may allow us to have access to certain information from your social media profile based upon your privacy preference settings on such platform.

  • An employee of ours gives your contact details as an emergency contact for creation of ID card emergency information or gives your contact details for pre-employment referral checks.
  • Information provided by our customer or client for the purpose of performance of the contract which you may be subject to.
  • Referral CVs or resumes provided by our employees (Employee Referral Program) or by third party recruitment agencies.

As a part of our sales and marketing outreach, in certain circumstances where we need to verify the information we hold about you or obtain missing information we require to provide you with a service, we might collect your information from publicly accessible sources such as online customer databases, social media, business directories, media publications, and official company websites (may be your own) and any affiliates. Doing so will enable us to understand your business, its requirements in relation to our product and services, and to provide or recommend tailored products/ services to you as per your business needs. We will have a legitimate interest in obtaining information about you from public and private sources. This would include targeted B2B sales and marketing communications.

Hughes Systique shall not be responsible for the authenticity of the personal information supplied to it by its service providers, whose duty it is to ensure that the information provided by it or its employees is authentic.

5. How we use your information?

The personal information we collect may be used to/ for, but not limited to:

  • provide information and services as requested by you
  • assess queries, requirements, and process requests for products and services
  • perform client communication, service, billing and administration
  • data storage and administration
  • assess queries, requirements, and process requests for products and services
  • analysis of trends and statistical data
  • assess web site performance and usage analysis
  • maintain leads
  • run marketing or promotional campaigns
  • create brand awareness
  • provide better services and generate demand
  • market products and services based on legitimate business interest under the applicable law
  • conducting market research and surveys with the aim of improving our products and services
  • conduct processing necessary to fulfil other contractual obligations
  • recruitment purposes
  • employee administration
  • maintenance and development of our website
  • preventing, detecting, investigating and prosecuting crimes (including but not limited to fraud and other financial crimes) in any jurisdiction, identity verification, government sanctions screening and due diligence checks
  • improve your user experience and the overall quality of our services

With your consent, we may also use your personal information for additional purposes. Instances where sensitive personal information is collected will warrant explicit consent. Unless it is necessary for our legitimate business purposes, should you choose not to provide any personal information during certain activity, you will nevertheless be able to continue with such activity wherever possible.

5.1 Use of Automated decision-making and profiling

Profiling

We use profiling on our website to personalize your experience. However, automated decision-making is not performed and such processing shall not have any legal or similarly significant effects on you.

Web Analytics

Our web analytics service, “Google Analytics” collects and uses information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on). However, the data available to us is in an aggregated and anonymised form where it is not possible for us to personally identify you. You can opt out of Google Analytics by installing the browser plugin here: Google Analytics Opt-out Browser Add-on

Our products/ services dealing with automated profiling

Our range of product and services (Wi-Fi Analytics, OTT QOE) provided to our customers, include automated profiling and behavioural analysis of individuals who may be subject to such processing upon usage of such services where Hughes Systique may act a Data Controller independently. The analytics involves automated processing where collection and analysis of personal data is performed to gain insights into behaviours and characteristics of the data subjects that shall allow our clients to understand their customers (data subjects) better and offer better/personalized services, understand the effectiveness of their product or services, analysing trends based on usage, provide enhanced customer support and improve overall customer experience. However, it is ensured that such kind of analytics only include data in an aggregated form where Hughes Systique shall not involve any personally identifiable information that may be linked or associated to you and does not have a legal or similar effects on you. We use appropriate administrative, organizational, technical, and physical safeguards to protect the personal information we collect and process about you.

In case if you have questions about or need further information concerning the legal basis on which we collect and use your personal information or if you are subject to such processing and want to exercise your data subject rights, please contact us using the contact details provided under the “Your Rights as a Data Subject” section below.

6. Disclosure/ Transfers to Third Parties

Hughes Systique may share personal information about you with affiliates, partners, service providers, group entities and non-affiliated companies (a) to provide products or services you’ve requested; (b) when we have your permission: or (c) under the following circumstances:

  • We may share information with affiliated entities/subsidiaries/branch offices for legitimate business purposes.
  • We may provide the information to trusted entities or third parties who work on behalf of or with Hughes Systique under strict confidentiality and data protection agreements. These entities may use your personal information to help Hughes Systique communicate with you about offers from Hughes Systique and for other legitimate business purposes. However, these companies do not have any independent right to further share or disseminate this information;
  • We may share information with statutory authorities, government institutions or other bodies where required for compliance with legal requirements.
  • We may use the information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;
  • We may share information where we believe it is necessary to investigate, prevent, or take action against any illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.
  • We may share information where we believe it is necessary to protect or enforce Hughes Systique’s rights, usage terms, intellectual or physical property or for safety of Hughes Systique or associated parties.
  • We may share information about you if Hughes Systique is acquired by or merged with another company.

Hughes Systique may share your personal information with your consent, or where the disclosure is necessary for compliance of a legal obligation or where required by government agencies mandated under law to procure such disclosure. It shall also take steps to ensure that the information transferred to a third party is not further disclosed by it except where permissible under law.

Please keep in mind that when you provide information to us on a third-party site or platform (for example, via our applications where you may login with third party social media account shall be covered by this privacy notice, and the information collected by the third-party site or platform shall be subject to the third-party site or platform’s privacy practices.

7. International Transfer of Personal Information

Hughes Systique has a global presence As a result, the data that we may collect from you may be transferred to, stored at, and processed in any of our locations which may be inside or outside the European Economic Area (“EEA”) or the country in which you are a resident.  A Transfer of personal information has a broad meaning and occurs when information is communicated, moved, accessed or otherwise sent to another country. Hughes Systique may transfer certain personal information across geographical borders to our entities or third party service providers in other countries working on our behalf in accordance with applicable law.  These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). However, Hughes Systique has put in place adequate measures to protect data which is transferred internationally, including appropriate security measures to safeguard the transfer of your personal data. Hughes Systique ensures the “same level of data protection” as per applicable data protection laws and regulations when it transfers your personal information to any other body corporate or a person in any country.

By submitting your personal data, you agree to this transfer, storing or processing.

8. How long do we retain your personal information?

We will retain your personal information for as long as necessary to provide the services you have requested, or for other essential purpose such as performance of a contract, legal, regulatory, statuary obligations and enforcing our policies. At expiry of such periods, your personal information will be deleted or archived to comply with legal/ contractual retention obligations or in accordance with applicable statuary retention periods.

9. Links to other websites

Hughes Systique may provide links to third-party websites for your convenience and information. If you access those links through the Hughes Systique website, you will leave the Hughes Systique website. We do not endorse or make any representations about third-party websites. The personal information you choose to provide to or that is collected by these third parties, including any social media websites featured on our website, is not covered by the Hughes Systique’s Privacy Notice. We encourage you to review the privacy statement or policy of any website before submitting your personal information.

We may also provide social media features on our website that enable you to share Hughes Systique’s information with your social networks and to interact with Hughes Systique on various social media sites. Your use of these features may result in the collection or sharing of information about you, depending on the feature. We encourage you to review the privacy policies and settings on the social media sites with which you interact to make sure you understand how the information provided by you could be used or shared by those sites.

10. Security and Compliance with Laws

Hughes Systique has implemented a host of physical, technical and administrative security measures to protect personal information from loss, misuse, alteration or destruction. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data.

Hughes Systique discloses information to third parties only for legitimate purposes such as our service providers and agents who are bound to maintain the confidentiality of personal information and may not use the information for any unauthorized purpose. Hughes Systique will ensure through formally executed contracts that the service providers are committed to “same level of data protection” as applicable data protection laws and regulations.

11. Your Rights as a Data Subject

We respect your right to be informed, access, correct, request deletion or request restriction, portability, objection, and rights in relation to automated decision making and profiling, in our usage of your personal information as required by applicable law. We also take steps to ensure that the personal information we collect is accurate and up to date.

Verification of identity where you exercise rights related to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so. These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information. If it is not possible to identity you from existing information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.    

Responding to your requests

Hughes Systique shall provide information on action taken on a request pertaining to the rights above without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. Hughes Systique shall inform the data subject of any such extension within one month of receipt of the request, together with the reasons for delay.

Following are data subject rights as applicable under GDPR:

11.1 Access and Rectification of your personal information

When you use the services on our Website or applications (or any of its sub sites), we make reasonable efforts to provide you, as and when requested by you, with access to your personal information and shall further ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible. We ask individual users to identify themselves and the information requested to be accessed or corrected before processing such requests. We may decline to process requests that are unreasonably repetitive or systematic, requiring disproportionate technical effort, jeopardizing the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case, where we provide information access and rectification we perform this service free of charge, except if doing so would require a disproportionate effort.

If you have created a profile or account on one of our websites, you can update your contact information after you log into your account.

11.2 Right to Rectification

You have the right for inaccurate or incomplete data we hold to be updated. You shall have the right to obtain from Hughes Systique without undue delay the rectification of inaccurate personal information concerning you.

11.3 Data Portability

You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and have the right to transmit to another controller, wherever feasible

11.4 Data Erasure

For us to provide services to you, we may retain certain personal information regarding you. The information will be retained in accordance with the retention policy pertaining to that information. If you no longer want us to use your information, then you can request that we erase your personal information. Please note that if you request for the erasure of your personal information, we may retain certain personal information as necessary for our legitimate business interests, such as fraud detection and prevention, enhancing safety and to the extent necessary to comply with our legal obligations. For example, we may keep your information for tax, legal reporting and auditing obligations.

11.5 Right to withdraw consent and Restriction of processing

For withdrawing your consent at any time during the tenure of our services with you. We shall review your request and may ask you to verify your identity. Post verification we will withdraw the consent for which request was made by you and stop any further processing of your personal information.

11.6 Right to Opt-out or Object to the Processing

Hughes Systique respects your privacy considerations and hence provides an option to you, to not provide the data or information sought to be collected.

Further, you can also withdraw your consent which was earlier given to Hughes Systique, and the same must be communicated to Hughes Systique via email.

Profile

If you have created a profile or account on one of our websites, you can delete your contact information after you log into your account.

Sales and Marketing Communications

If you request electronic communications, such as sales and marketing mailers and e-newsletter, you will be able to unsubscribe at any time by following the instructions included in the communication or be writing an email to us.

Mobile Devices

If you previously chose to receive push notifications on your mobile device from us but no longer wish to receive them, you can manage your preferences either through your device or the application settings. If you no longer wish to have any information collected by the mobile application, you may uninstall the application by using the uninstall process available on your mobile device

11.7. Right to lodge complain to Supervisory Authorities

You have the right to complaint about the data processing activities carried out by Hughes Systique before the competent data protection supervisory authorities.

11.8. Right to object being subject to a decision based solely on automated processing, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

This does not apply if:

  • it is necessary for entering into, or the drawing up of, a contract between us
  • it is authorised by Union or Member State law to which the Data Controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or
  • it is based on your explicit consent

To achieve the paragraph above, we have to implement suitable measures to safeguard your rights and freedom and legitimate interest, at least the right to offer a human intervention from our side to present your own point of view, and to challenge a decision.

12. Children’s Information

Hughes Systique’s websites are not directed at nor targeted at children. No one who has not reached the age of sixteen may use the websites unless supervised by their parent or legal guardian.

The minimum age for these purposes shall be 16, however if local laws require that you must be older in order for Hughes Systique to lawfully provide the services in the website/ mobile application to you then that older age shall apply as the applicable minimum age. In all jurisdictions outside the European Union, if you are under the age of 18 or the age of majority in your jurisdiction, you must use our services under the supervision of your parent, legal guardian or responsible adult.

By accessing this website, you represent and warrant that you are 16 years of age or older. 

13. Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

Hughes Systique does not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us unless required for which you have explicitly provided your consent to do so.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us for processing that sensitive personal information. In this case, you should contact our Data Protection Officer (DPO) at communication channels mentioned below.

14. Data Protection Office (DPOffice) and Data Protection Officer (DPO)

Hughes Systique has set up a Data Protection Office (DPOffice) and appointed a Data Protection Officer (DPO) for you to contact if you have any concerns or queries about Hughes Systique’s Privacy Notice and practices or information regarding handling your personal information.

Contact Information

If you have any questions or comments regarding this Privacy Notice or processing of your personal information, or you wish to exercise your rights, or you have any complaints regarding processing of your personal information, you may contact us through below-mentioned communication channels.

Address: 

Hughes Systique Pvt. Ltd.

D-24, Infocity II,

Sector 33, Gurgaon – 122001,

India

Contact Number: +91.124.4178999 (Mon – Fri between 8:00 AM to 5:00 PM IST)

Email: DPOffice@hsc.com or info@hsc.com

 15. Effective Date

This Privacy Notice is effective from 12 October, 2018 and it supersedes all existing polices on the subject matter.

16. Changes to Privacy Notice

Please note that this Privacy Notice may be subject to change from time to time. The revised Privacy Notice will accordingly be published on this page.  We will not reduce your rights under this Privacy Notice without your explicit consent. You are responsible for periodically visiting our Site and this Policy to check for any changes.

17. Disclaimer

Hughes Systique shall not be liable for any loss or damage sustained by reason of any disclosure (inadvertent or otherwise) of any information concerning the user's account nor for any error, omission or inaccuracy with respect to any information so disclosed and used whether in pursuance of a legal process or otherwise.

Any other personal information (including sensitive personal information) shared by you which is not asked by Hughes Systique during registration, either mandatorily or optionally; accounts to wilful and intentional furnishing; and Hughes Systique will not be liable for breach of such information.