Commitment to Principles
Neeyamo recognizes that the EEA has established strict regulations regarding handling EEA Personal Data of the EEA and/or UK residents, including requirements to provide adequate protection for such Personal Data transferred outside of the EEA and/or UK. To provide the required protection of the Personal Data about corporate customers, clients, suppliers, and business partners in the EEA and/or UK, received in the USA, Neeyamo has elected to self-certify to the EU-US Privacy Shield Framework administered by the US Department of Commerce (“Privacy Shield”).
For purposes of enforcing compliance with the Privacy Shield, Neeyamo is subject to the jurisdiction and enforcement authority of the US Federal Trade Commission.
Types of personal data collected
Neeyamo, being in the HR industry, collects sensitive and personal data required to process all activities such as Background Verification, Payroll, HR-related services, and technologies, where there is a legal basis and/or the legitimate reason, with your required consents, both directly and indirectly.
We collect such personal data as a Data processor to provide our services to our customers. When Neeyamo handles data for our Client, we may be a data controller or data processor, depending on the specifics of our contract. In such case, Neeyamo makes sure that the obligations of the Standard Contractual Clauses are being adhered to when the EEA data is further transferred for processing.
The Personal data transferred concerns the following categories of data:
- Contact information such as Full Name, Home Address, Email Address, Date of Birth, and Financial information
- Documentation: Education/ Employment documents and Identity proofs.
- Payroll data, such as banking data necessary to make payments to the data subject, compensation information, data on leave, paycheck details (including the following: total gross salary, employees wage tax (withheld by the employer), employees compulsory social security deduction, employees compulsory retirement deduction, employees compulsory unemployment deduction, employees additional medical care deduction, other compulsory or additional employees deductions, employees voluntary retirement deduction, employees voluntary medical care deduction, other employees voluntary deductions, total employee deductions, total net salary, expenses refund and advances, banking details, and third party payments (where acting as an employer surrogate when the employee is on leave for long-term sickness, accident at work or other reason).
Special categories of data (if required and as applicable)
- Bank account information
- Where applicable, religious affiliation and information required deducting sick payments (if required for payroll and tax processing); Passport, Social security numbers, details of disabilities, if any.
- Other special categories of personal data contained in payroll information (if any)
- Activities, interactions, preferences, transactional information, and other computer and connection information (such as IP address) relating to the use of our websites and our services
- Log files, information collected by cookies and similar technologies about the pages viewed, links clicked, and other actions taken when accessing our website.
We collect and process customer personal information directly and indirectly.
- to provide service(s) agreed through commercial contracts,
- managing customer accounts within our applications,
- to verify customer identity or to perform any other authentication that we need to provide service(s),
- to maintain customer personal profile,
- to provide the services that the customer has requested, including processing transactions,
- to tailor/customize our website or other services we provide to customers as per customer requirements.
- to enable third parties to perform services or functions on our behalf, for example, where this is necessary to process a transaction or provide services.
- to comply with applicable laws and regulations.
Neeyamo notifies Data Subjects about its data practices regarding Personal Data received by Neeyamo in the US from EEA (including Liechtenstein, Norway, and Iceland) and/or the UK. Neeyamo will not use or disclose Personal Data transferred from an EEA Member State and/or UK to the United States for any purpose that has not previously been disclosed to the data subjects unless:
- The data subjects have received a notice and an opportunity to exercise choice, as described below, concerning such use or disclosure; or
- Applicable law permits the use or disclosure without requiring that Neeyamo first comply with the Notice and Choice Principles.
Neeyamo currently does not allow personal data to be shared with a non-agent third party or used for other reasons than it was provided for. If this practice should change in the future, we will notify individuals beforehand and provide an opt-out choice. Neeyamo maintains reasonable procedures to help and ensure that EEA and/or UK Personal Data is reliable for its intended use, accurate, complete, and current.
Use and disclosure of personal data and accountability for onward transfer
Neeyamo limits the access to Personal Data to its employees, subcontractors, and third parties with a specific business reason for accessing such Personal Data. Neeyamo has partnerships and alliances leveraging expertise and knowledge of various countries’ local labor laws, union rules, and collective labor agreements.
We have a triangulated framework for compliance that comprises three different sources providing us with updates for all the countries on the changing legislative requirements
- A central team of dedicated compliance experts to oversee and manage all compliance-related activities
- Partnership with leading global audit firms to warranty 100% compliance and to stay abreast in various aspects of compliance management
- Foot-on-the-ground presence in each and every jurisdiction through a network of carefully shortlisted in-country partners to guarantee local compliance
Neeyamo shall disclose the personal information to our sub-contractors, who would be engaged to provide part of the services on our behalf to our customer or are part of the supply chain in rendering service to customers by handling a portion of the process, in accordance with contractual agreements with customer and applicable laws & regulations.
We will provide an individual opt-out choice or opt-in for sensitive data before we share your data with third parties other than our agents or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to firstname.lastname@example.org
Note that Neeyamo may be required to share EEA and/or UK-based personal data in response to lawful requests by public authorities, including to meet national security and/or law enforcement requirements.
Neeyamo’s accountability for personal data received in the United States under the Privacy Shield and subsequently transferred to a third party is described in the Privacy Shield Principles. In particular, Neeyamo remains responsible and liable under the Privacy Shield Principles if third-party that engages in processing the personal data on its behalf does so in a manner inconsistent with the Principles unless Neeyamo proves that it is not for a party to the event(s)-giving rise to the damage.
Neeyamo may be required to release personal data of EU and/or UK individuals in response to legal requests by lawful authorities, including to meet law enforcement and national security requirements.
Neeyamo is committed to safeguarding the Personal Data that it receives from the EEA and/or UK from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
Neeyamo implemented Technical and Organizational security measures to safeguard Personal Data. For example, facility security is designed to prevent unauthorized access to Neeyamo computers. Electronic security measures, including, for example, network access controls, passwords, and access logging, protect from hacking and other unauthorized access.
And, considering the technology threats and ransomware attacks, Neeyamo has implemented a cyber-security framework and controls to safeguard Personal data.
Data integrity and purpose limitation
Neeyamo will use personal data only for the purposes for which it is collected or subsequently authorized by the customer. Neeyamo will take reasonable steps to ensure that personal data is relevant to its intended use. Neeyamo depends on you to update and correct your personal data to the extent necessary for the purposes for which it is collected and subsequently authorized by you.
Neeyamo recognizes the right of EU and UK individuals to access their data. Upon request, Neeyamo will provide you with access to the personal information that we hold about you. You may also request to correct, amend, or delete incorrect information or request the erasure of the personal information we hold about you if it is being or has been processed in violation of the Privacy Shield Principles. An individual who wishes to exercise this right should direct their query to email@example.com or via post at Neeyamo Data Privacy office to the Attention of DPO, Neeyamo Enterprise Solutions Private Limited, Lvl-1, IT-05 Blueridge SEZ, Hinjewadi Phase-1, Pune-411057, Maharashtra, India. Upon such request to remove or correct the Personal data, we will respond within a reasonable timeframe or as required by law.
Neeyamo may require identity verification before providing access to Personal Data. Please note that in cases where Neeyamo is acting as a data processor on behalf of a customer, we may have to forward your request to that entity, which remains the data controller for your information.
Recourse, enforcement and liability
In compliance with the Privacy Shield Principles, Neeyamo commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. Data subjects from EEA and/or UK with Privacy Shield inquiries or complaints should first contact Neeyamo by email at firstname.lastname@example.org or via post at: to the Attention of DPO, Neeyamo Enterprise Solutions Private Limited, Lvl-1, IT-05 Blueridge SEZ, Hinjewadi Phase-1, Pune-411057, Maharashtra, India.
Neeyamo has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit: https://bbbprograms.org/programs/all-programs/bbb-eu-privacy-shield-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.
For Human Resources Data
If your complaint involves human resources data transferred to the United States from the EEA and/or UK in the context of the employment relationship. Neeyamo does not address it satisfactorily. Neeyamo commits to cooperate with the panel established by the EU data protection authorities (DPA Panel) or the United Kingdom Information Commissioner’s Office (ICO), as applicable and to comply with the advice given by that authority. Contact the state or national data protection or labor authority in the appropriate jurisdiction to pursue an unresolved human resources complaint. Complaints related to human resources data should not be addressed to the BBB EU PRIVACY SHIELD.
Contact details for the EU data protection authorities can be found at https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
UK individuals can also file a complaint with the ICO at https://ico.org.uk/make-a-complaint/eu-us-privacy-shield/
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
Changes to this Policy
We reserve the right to amend this Policy from time to time consistent with the Privacy Shield’s requirements.
Last updated on: February 10, 2023