Neeyamo Inc. recognizes that the EU has established strict protections regarding the handling of EU Personal Data, including requirements to provide adequate protection for EU Personal Data transferred outside of the EU. To provide adequate protection for certain EU Personal Data about corporate customers, clients, suppliers, and business partners received in the US, Neeyamo.Inc 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.Inc is subject to the investigatory and enforcement authority of the US Federal Trade Commission.
Neeyamo being in the HR industry collects a lot of sensitive and personal data required to process all activities related to the lines of businesses. Client’s/ Employees / Staff in the countries within scope-including full-time, part-time, Consultants and contractors.
The personal data transferred concern 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 data subject, compensation information, data on leave, paycheck details (including the following: total gross salary, employee’s wage tax (withheld by the employer), employee’s compulsory social security deduction, employee’s compulsory retirement deduction, employee’s compulsory unemployment deduction, employee’s additional medical care deduction, other compulsory or additional employee’s deductions, employee’s voluntary retirement deduction, employee’s voluntary medical care deduction, other employee’s 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)
- Bank account information;
- Where applicable, religious affiliation and information required to deduct sick payments (if required for payroll and related tax processing); Passport, Social security numbers, details of disabilities, if any.
- Other special categories of personal data contained in payroll information (if any).
Neeyamo Inc. notifies Data Subjects about its data practices regarding Personal Data received by Neeyamo Inc. in the US from EEA (including Liechtenstein, Norway and Iceland). Neeyamo Inc. will not use or disclose Personal Data transferred from an EU Member State to the United States for any purpose that has not previously been disclosed to the data subjects unless: (a) the data subjects has received notice and an opportunity to exercise choice, as described below, with respect to such use or disclosure; or (b) applicable law permits the use or disclosure without requiring that Neeyamo Inc. first comply with the Notice and Choice Principles.
Neeyamo Inc. currently does not allow personal data to be either shared with third party non-agents or used for reasons other than that for which it was provided. If this practice should change in the future we will notify individuals beforehand and provide opt-out choice. Neeyamo.Inc maintains reasonable procedures to help ensure that EU Personal Data is reliable for its intended use, accurate, complete, and current.
Use and Disclosure of Personal Data and Accountability for Onward Transfer:
Neeyamo Inc. limits access to Personal Data to employees, subcontractors, and third-party agents that have a specific business reason for accessing such Personal Data. Neeyamo has partnerships and alliances in leveraging expertise and knowledge of countries’ local labor laws, labor union rules and collective labor agreements.
We have a triangulated framework for compliance that comprises of 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 last mile
Neeyamo shall disclose the personal information to the third parties like Process Service providers and Compliance Service providers in accordance with applicable laws and regulations. Personal data may also be disclosed in the event of a sale, merger, reorganization, liquidation or similar event.
Note that we also may be required to share EEA personal data in response to lawful requests by public authorities including to meet national security and/or law enforcement requirements.
Neeyamo Inc. is liable for onward transfers to third party agents. Before transferring personal data to a third party agent, Neeyamo Inc. will obtain assurances that it will safeguard the data subjects ‘Personal Data in a manner consistent with the policy. Where Neeyamo Inc. learns that an agent is using or disclosing Personal Data in manner contrary to this policy, Neeyamo Inc. will take responsible steps to prevent such use or disclosure.
Neeyamo Inc. is committed to safeguarding the Personal Data that it received from the EU. Neeyamo Inc. possession from loss, misuse, unauthorized access, disclosure, alteration and destruction.
Neeyamo Inc. utilizes security technologies, procedures and organizational measures to help safeguard Personal Data. For example, facility security is designed to prevent unauthorized access to Neeyamo Inc. computers. Electronic security measures including, for example, network access controls, passwords and access logging provide protection from hacking and other unauthorized access.
Data Integrity & Purpose Limitation:
Neeyamo Inc. will use personal data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. Neeyamo Inc. will take reasonable steps to ensure that personal data is relevant to its intended use, accurate, complete, and current. Neeyamo Inc. depends on you to update and correct your personal data to the extent necessary for the purposes for which it was collected and subsequently authorized by you.
Neeyamo acknowledges the right of EEA individuals to access their personal data to inspect, amend, correct, or erase it. Upon reasonable request, Neeyamo Inc. will grant data subjects reasonable access to their Personal Data and will permit them to correct, amend or delete Personal Data that is inaccurate or incomplete. Data subjects who wish to review or update their Personal Data can do so by contacting Neeyamo Inc. Data Privacy office at 14317 La Rinconada Dr, Los Gatos, CA 95032. Neeyamo Inc. may require verification of identity before providing access to Personal Data.
Recourse, Enforcement and Liability:
In compliance with the EU-US Privacy Shield Principles, Neeyamo Inc. commits to resolve complaints concerning its processing of Personal Data in accordance with the Privacy Shield Principles. European Union individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Neeyamo at:
If Neeyamo.Inc maintains your Personal Data in one of the Services within the scope of our Privacy Shield certification, you may direct any inquiries or complaints concerning our Privacy Shield compliance to email@example.com
Neeyamo has further committed to refer unresolved Privacy Shield complaints to BBB EU Privacy Shield, an alternative dispute resolution provider located in the United Sates. If you do not receive timely acknowledgement of your complaint from us, or if we have not resolved your complaint, please contact or visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information or to file a complaint. The services of BBB EU Privacy Shield are provided at no cost to you.
Finally as a last resort and under limited circumstances, EU individuals with residuals may invoke a binding arbitration option before a Privacy Shield Panel. For more information on this option please see Annex 1 of the Privacy Shield at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
Human Resources Data within the Context of the HR Relationship:
Neeyamo commits to cooperate with the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to complaints on human resources data of Neeyamo employees transferred from the EEA in the context of the employment relationship.
Changes To This Policy
We reserve the right to amend this Policy from time to time consistent with the Privacy Shield’s requirements.
Effective Date: February 19, 2018