Privacy Policy
Introduction
At WAKEFLO Private Limited (WAKEFLO), WAKEFLO respects the privacy of individual/visitor and is committed to take reasonable precautions to protect information consisting of Personal information and `Sensitive Personal Data or Information’ (SPDI) (“Information”) of visitors of this WAKEFLO website and comply with all legal, regulatory and/or contractual obligations related to privacy. WAKEFLO has adopted the “Privacy by Default” principles in its approach to data privacy i.e., privacy of data and information is upheld first by default.
This policy covers the processing, storage and access to Information as required under lawful and/or contractual activities with WAKEFLO or otherwise required in the normal course of business. It describes WAKEFLO’s policies and procedures on the collection, usage and disclosure of Information provided/received by natural persons and meets the requirements established under:
- The Information Technology Act, 2000 – Section 43A.
- The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011.
- General Data Protection Regulation.
1. Scope
This policy applies to all visitors of this WAKEFLO’s website. This Privacy Statement covers our information practices, including how we collect, use, share and protect the personal information you provide to us, through our web sites that link to this Privacy Statement (collectively referred to as “WAKEFLO’s Websites”).
We may also provide social media features on our website that enable you to share WAKEFLO information with your social networks and to interact with WAKEFLO 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.
WAKEFLO’s websites are not directed at nor targeted at children. No one who has not reached the age of thirteen may use the websites unless supervised by an adult. By accessing this website, you represent and warrant that you are 13 years of age or older.
WAKEFLO will not be liable for any unsolicited information provided by you. You consent to WAKEFLO using such information as per WAKEFLO’s Privacy Statement.
2. Information covered by this Policy
This policy applies to Information collected and processed by WAKEFLO consisting of following:
2.1 Personal information is information related to a visitor, or a combination of pieces of information that could reasonably allow him to be identified. Personal information may consist of full name, personal contact numbers, organization address, official email address, gender or date of birth. While information such as date of birth in isolation may not be enough to uniquely identify the visitor, a combination of full name and date of birth may be sufficient to do so.
2.2 Sensitive personal data or information (“SPDI”) is such personal information that is collected, received, stored, transmitted or processed by WAKEFLO, consisting of:
- Password
- Any detail relating to the above personal information categories as provided to WAKEFLO for providing service; and
- Any of the information received under above personal information categories by WAKEFLO for processing, stored or processed under lawful contract or otherwise.
Please note that any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal information.
3. Purpose
WAKEFLO shall collect and use Information for legitimate business purposes in order:
- That a visitor may download product information, order products and take advantage of certain other features of WAKEFLO’s website.
- To provide information or interactive services through this website, to the visitor’s e-mail address or, where the visitor wishes it to be sent by post, to the visitor’s postal address.
- To seek the visitor’s feedback or to contact the visitor in relation to the services offered on WAKEFLO’s website.
- To process orders or applications submitted by the visitor.
- To administer or otherwise carry out WAKEFLO’s obligations in relation to any agreement that the visitor may have with WAKEFLO.
- To anticipate and resolve problems with any solutions or services supplied to the visitor.
- To create products or services that may meet the visitor’s needs.
- To process and respond to requests, improve WAKEFLO’s operations, and communicate with visitor/s about WAKEFLO’s products, services and businesses and
- To allow the visitor to subscribe to WAKEFLO’s news alerts.
4. Collection of Information
Only minimum Information required to meet the purposes mentioned in this policy shall be collected from the visitor/s. Neither WAKEFLO nor its representatives shall be responsible for the authenticity of such Information provided by the visitor/s. As normal business practice, WAKEFLO may collect Information in order to enable the secure online authentication, interaction and transaction with natural persons. This may include the installation of cookies and the collection of other session data.
5. Access, Correction of Information and withdrawal of consent
Any modifications / corrections required to the Information can be carried out on the website. In the event the visitor is unable to do so due to lack of functionality in WAKEFLO’s website and / or the visitor wants to withdraw his / her consent to provide SPDI, he / she may contact the Grievance officer, the details whereof are provided in clause 8 of this policy.
6. Retention, Processing and storage of Information:
6.1 WAKEFLO shall retain Information for only as long as necessary to meet legal or regulatory requirements or for legitimate business purposes as mentioned in this policy.
6.2 WAKEFLO has implemented required security practices and standards in line with the global standards and have a comprehensive documented information security program and policy in place, which contains managerial, technical, operational and physical security control measures that commensurate with the information assets being protected with WAKEFLO’s nature of business. It is being reviewed periodically to keep pace with business, technology and regulatory changes.
7. Disclosure of Information
7.1 WAKEFLO shall not use or disclose Information for purposes other than as mentioned in this policy, except with the consent of visitor providing such Information or as required by law. However, WAKEFLO may be legally required to disclose the Information in the following cases:
- Where the disclosure is necessary for compliance of a legal obligation.
- Where mandated under the law by government agencies to disclose such Information.
7.2 Where necessary, WAKEFLO may disclose Information to business partners or third parties during the normal course of business for the purposes mentioned in this policy. In such cases, WAKEFLO will only share Information related data when WAKEFLO is assured that:
- The Information is processed legitimately and appropriately by the business partner or third party in line with the established consent or in line with legal requirements.
- The business partner or third party has adopted a reasonable and equivalent level of security practices and procedures to ensure security of the Information shared.
8. Feedback or Concern
For feedback or concern, if any, kindly contact: info@wakeflo.com
Security Policy
WAKEFLO is a global leader in providing IT services, business solutions and outsourcing with business operations spreading across continents. WAKEFLO services multiple customers and as a part of its operations has access to business sensitive information (including personal information and IPR), impact on which could be detrimental to WAKEFLO or its customers’ business interests.
Our Security Vision is “To make WAKEFLO reliable, resilient and immune to the existing and evolving volatile environment of constant changes, accidents, attacks and failures.”
This Security Policy reiterates our commitment to protect all the information and assets that we own or are responsible for; thus, ensuring an efficient, safe and secure working environment for WAKEFLO and its customers.
WAKEFLO will deploy a convergent security model to ensure:
- Protection of information and assets against unauthorized access by deploying adequate security controls covering physical, logical and personnel security
- Compliance to legal and statutory / regulatory requirements across its global operations
- Continuity of operations in line with business requirements and obligations to its stakeholders
- Inclusion of security responsibilities of various departments / individuals to adhere to this Policy
- Adequate security awareness and competence among associates at all levels to fulfill these responsibilities
- Avenues for associates and other stakeholders to report security weaknesses, violations or disruption of services.
- A robust response framework to handle security weaknesses, violations or disruption of services
- Governance of security performance against appropriate targets and objectives, enabling continuous improvements
This Policy will be supported by Standards, Procedures and Guidelines (Security Management System) and will be made available to all stakeholders who are expected to contribute towards the effective implementation and deployment of these security norms.
The Security Management System will be periodically reviewed to ensure its continuing applicability and relevance to our operations and evolving stakeholder expectations.
This Policy will extend to WAKEFLO globally in all geographies, and will be applicable to all its associates, business associates and external parties having access and usage rights to its infrastructure, IT systems and/or Information resources. Consequences arising out of violations or contravention to any of the objectives of this Policy will be equally applicable to all associates of WAKEFLO and its wholly owned subsidiaries globally and external parties.
VIGIL MECHANISM / WHISTLE BLOWER POLICY
Preamble: – As per the provisions of Section 177 of the Companies Act, 2013 our Company has establish a vigil mechanism for the directors and employees to report genuine concerns in such manner as may be prescribed.
The Company has adopted a Code of Conduct for Directors and Senior Management Personnel (“the Code”), which lays down the principles and standards that should govern the actions of the Directors and Senior Management Personnel.
Any actual or potential violation of the Code, howsoever insignificant or perceived as such, is a matter of serious concern for the Company. Such a vigil mechanism shall provide for adequate safeguards against victimization of persons who use such mechanism and also make provision for direct access to the chairperson of the Audit Committee in appropriate or exceptional cases.
Policy Objectives:- The Vigil (Whistle Blower) Mechanism aims to provide a channel to the Directors and employees to report genuine concerns about unethical behavior, actual or suspected fraud or violation of the Codes of Conduct or policy.
The Company is committed to adhere to the highest standards of ethical, moral and legal conduct of business operations and in order to maintain these standards, the Company encourages its employees who have genuine concerns about suspected misconduct to come forward and express these concerns without fear of punishment or unfair treatment.
Scope:- The Policy is an extension of the Code of Conduct for Directors & Senior Management Personnel and covers disclosure of any unethical and improper or malpractices and events which have taken place/ suspected to take place involving:
1. Breach of the Company’s Code of Conduct
2. Breach of Business Integrity and Ethics
3. Breach of terms and conditions of employment and rules thereof
4. Intentional Financial irregularities, including fraud, or suspected fraud
5. Deliberate violation of laws/regulations
6. Gross or Willful Negligence causing substantial and specific danger to health, safety and environment
7. Manipulation of company data/records
8. Perforation of confidential/propriety information
9. Gross Wastage/misappropriation of Company funds/assets
Eligibility:- All Directors and Employees of the Company are eligible to make Protected Disclosures under the Policy in relation to matters concerning the Company.
Procedure:- All Protected Disclosures should be reported in writing by the complainant as soon as possible, not later than 30 days after the Whistle Blower becomes aware of the same and should either be typed or written in a legible handwriting in English.
The Protected Disclosure should be submitted under a covering letter signed by the complainant in a closed and secured envelope and should be super scribed as “Protected disclosure under the Whistle Blower policy” or sent through email with the subject “Protected disclosure under the Whistle Blower policy”. If the complaint is not super scribed and closed as mentioned above, the protected disclosure will be dealt with as if a normal disclosure.
All Protected Disclosures should be addressed to the Vigil Mechanism Officer.
The Contact details are as under: –
Mr. Sourabh Kagalkar
(Business Operations Manager)
In order to protect the identity of the complainant, the Vigilance Officer will not issue any acknowledgement to the complainants, and they are not advised neither to write their name / address on the envelope nor enter into any further correspondence with the Vigilance Officer.
Anonymous / Pseudonymous disclosure shall not be entertained by the Vigilance Officer. On receipt of the protected disclosure the Vigilance Officer shall detach the covering letter bearing the identity of the Whistle Blower and process only the Protected Disclosure.
Investigation:- All Protected Disclosures under this policy will be recorded and thoroughly investigated. The Vigilance Officer will carry out an investigation either himself or by involving any other Officer of the Company/ Committee constituted for the same /an outside agency before referring the matter to the Audit Committee of the Company.
The Vigilance Committee, if deems fit, may call for further information or particulars from the complainant and at its discretion, consider involving any other/additional Officer of the Company and/or Committee and/ or an outside agency for the purpose of investigation.
The investigation by itself would not be tantamount to an accusation and is to be treated as a neutral fact-finding process.
Decision And Reporting: – If an investigation leads to a conclusion that an improper or unethical act has been committed, the Chairman of the Vigilance Committee shall recommend to the Board of Directors of the Company to take such disciplinary or corrective action as it may deem fit.
Any disciplinary or corrective action initiated against the Subject as a result of the findings of an investigation pursuant to this Policy shall adhere to the applicable personnel or staff conduct and disciplinary procedures.
A complainant who makes false allegations of unethical & improper practices or about alleged wrongful conduct of the Subject to the Vigilance Officer or the vigilance Committee shall be subject to appropriate disciplinary action in accordance with the rules, procedures and policies of the Company.
Confidentiality: – The complainant, Vigilance Officer, Members of Vigilance Committee, the Subject and everybody involved in the process shall, maintain confidentiality of all matters under this Policy, discuss only to the extent or with those persons as required under this policy for completing the process of investigations and keep the papers in safe custody.
Protection: – No unfair treatment will be meted out to a Whistle Blower by virtue of his/ her having reported a Protected Disclosure under this policy. Adequate safeguards against victimization of complainants shall be provided. The Company will take steps to minimize difficulties, which the Whistle Blower may experience as a result of making the Protected Disclosure.
The identity of the Whistle Blower shall be kept confidential to the extent possible and permitted under law. Any other employee assisting in the said investigation shall also be protected to the same extent as the Whistle Blower.
Disqualifications: – While it will be ensured that genuine Whistle Blowers are accorded complete protection from any kind of unfair treatment as herein set out, any abuse of this protection will warrant disciplinary action.
Protection under this Policy would not mean protection from disciplinary action arising out of false or bogus allegations made by a Whistle Blower knowing it to be false or bogus or with a mala fide intention.
Whistle Blowers, who make any Protected Disclosures, which have been subsequently found to be mala fide, frivolous or malicious, shall be liable to be prosecuted.
Access To Chairman of The Vigilance Committee: – The Whistle Blower shall have right to access Chairman of the Audit Committee directly in exceptional cases and the Chairman of the Audit Committee is authorized to prescribe suitable directions in this regard.
Communication: – Directors and Employees shall be informed of the Policy by publishing on the website of the Company.
Retention Of Documents: – All Protected disclosures in writing or documented along with the results of Investigation relating thereto, shall be retained by the Company for a period of 5 (five) years or such other period as specified by any other law in force, whichever is more.
Amendment: – The Company reserves its right to amend or modify this Policy in whole or in part, at any time without assigning any reason whatsoever. However, no such amendment or modification will be binding on the Directors and employees unless the same is not communicated in the manner described as above.
Terms And Conditions Policy
Your consent to our Privacy Notice:
By agreeing to these terms and conditions, you agree to our (Privacy Notice link). Before accessing this website, please go through our Privacy Policy. All Personal Information provided to us will be dealt in accordance with our Privacy Policy.
Ownership of this website and its consent:
The information provided on this website is free of charge and for informational purposes only.
This website, including all of the software and code comprising or used to operate this website, and all photographs, graphic images, audio, video, HTML code, buttons, and text and other materials available on this website, (collectively “Content”) are protected under applicable intellectual property and other proprietary laws of India. All Content and intellectual property rights therein are the sole property of WAKEFLO.
Nothing contained in this site shall be construed as conferring by implication, estoppel, or otherwise, any license or right to any copyright, patent, trademark or other proprietary interest of WAKEFLO or any third party. Except as otherwise provided herein, none of this Content may be used, copied, reproduced, distributed, republished, downloaded, modified, displayed, posted or transmitted in any form or by any means, including, but not limited to, electronic, mechanical, photocopying, recording, or otherwise, without our express prior written permission, you shall (i) not modify the Content; (ii) have not right or right to retain any and all copyright and other proprietary notices contained in the Content; and (iii) not copy or post the Content on any network computer or broadcast the Content in any media.
Modifications:
WAKEFLO may, at any time, make modifications, changes and alterations to the contents of this website, including these terms and conditions, without prior notice.
Limitation of Liability:
In no event will WAKEFLO be liable for any damages, including, without limitation, indirect, incidental, special, consequential or punitive damages, whether under a contract, tort or any other theory of liability.
Trademarks:
The names and logos of WAKEFLO, all product names, all page headers, all custom graphics, all button icons, and all trademarks, service marks and logos appearing on this website, unless otherwise noted, are trademarks (whether registered or not), service marks and/or trade dress of WAKEFLO (collectively, the “Marks”).
All other trademarks, product names, company names, logos, service marks and/or trade dress mentioned, displayed, cited or otherwise indicated on this website are the property of their respective owners.
You are not authorized to display or use the Marks in any manner without our prior written permission. You are not authorized to display or use trademarks, product names, company names, logos, service marks and/or trade dress of other owners featured on this website without the prior written permission of such owners. The use or misuse of the Marks or other trademarks, product names, company names, logos, service marks and/or trade dress or any other materials contained herein, except as permitted herein, is expressly prohibited.
Link to the other sites:
WAKEFLO may establish links between this website and other websites, and you are advised to check the correctness and gentility of such third party website. WAKEFLO does not investigate, monitor or check such third party websites its accuracy and completeness etc…
Disclaimer of Warranties:
WAKEFLO provides accurate Content/information on the website, however, it makes no representation, endorsement or warranty that such Content is accurate or suitable for any particular purpose.
Waiver:
No waiver by WAKEFLO of any right under or term or provision of these terms and conditions will be deemed a waiver of any other right, term or provision of these terms and conditions at that time or a waiver of that or any other right, term or provision of these terms and conditions at any other time.
Applicable Law and Jurisdiction:
These terms and conditions are governed by and to be interpreted in accordance with laws of India and courts located at Bangalore shall have the exclusive jurisdiction to try any dispute.
Contact:
If you have a question or complaint, please contact us at info@wakeflo.com
Cookies Policy
This website uses cookies to improve the user experience and ensure that it is functioning effectively, and on occasion also to provide marketing information or advertise online, either directly or through third party vendors.
This Cookie Notice is part of WAKEFLO Private Limited’ and/or its affiliates (hereafter referred as “WAKEFLO”, or “we”) Privacy Notice. For more information about WAKEFLO, and how it protects your information, please see the Privacy Policy.
WAKEFLO may use “cookies” on its website(s). A “cookie” is a type of information that a website puts on your hard drive so that it can remember pieces of information about you when you next visit the website or a related website.
WAKEFLO uses cookies to record personal data about you when you use its website in order to facilitate your future activities.
WAKEFLO may use personal data sent in a cookie for marketing purposes and will not share this personal data with third parties for their own marketing purposes.
The cookies collect anonymous information including visitor numbers, areas most visited on our website and route to site.
How to Control Cookies?
If you prefer not to receive cookies from WAKEFLO’s website, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse cookies by turning them off in your browser, but this may impair your experience of WAKEFLO’s website.
1. Browser Controls
Most browsers will allow you to see what cookies you have and delete them on an individual basis or block cookies from particular or all websites. Be aware that any preference you have set will be lost if you delete all cookies, including your preference to opt-out from cookies as this itself requires an opt-out cookie to have been set.
2. Managing Analytics Cookies
You can opt-out of having your anonymized browsing activity within websites recorded by analytics cookies.
3. Managing Local Shared Objects or Flash Cookies
A local shared object or flash cookie is like most other browser cookies except that it can store additional types of information. These cookies cannot be controlled using the mechanisms listed above. Some parts of this website use these types of cookies to store user preferences for media player functionality and without them some video content may not play properly. These cookies can be controlled manually by visiting the website.
Social Buttons and/or External Web Services
The website contains ‘social buttons’ that enable users to share or bookmark web pages. These are buttons for third party social media sites and these sites may log information about your activities on the Internet including on this website. WAKEFLO sometimes also uses external web services on this website to display content within the web page of this website, for example to display images, show videos or run polls. As with the social buttons, WAKEFLO cannot prevent these sites, or external domains, from collecting information on your use of this embedded content. Please review the respective terms of use and privacy policies/statements/notices of these sites, or external domains to understand exactly how they use your information and to find out how to opt-out, or delete, such information.
Email Communications
WAKEFLO may also use tracking technologies to determine whether you have read, clicked on, or forwarded certain email communications which WAKEFLO sends to you, to make its communications more helpful and interesting. If you do not wish WAKEFLO to confirm whether you have opened, clicked on or forwarded its communications, you will need to unsubscribe, as it is not possible for WAKEFLO to send these emails without tracking enabled. Registered subscribers can update their communication preferences at any time by contacting WAKEFLO or can unsubscribe following the instructions in the individual email communications you receive from WAKEFLO and may modify or amend this Cookie Notice from time to time at its discretion.
Amendment to the notice/policy
We may occasionally amend this Cookie Notice to reflect company and customer feedback, and we reserve the right to make changes to this Cookie Notice at any time. The provisions contained in this Cookie Notice supersede all previous notices or policies regarding our use of cookies and similar technology on our sites. We encourage you to check frequently to see the current Cookie Notice to be informed of how WAKEFLO is committed to protecting your information and providing you with improved content on our site in order to enhance your experience.
Google reCAPTCHA Privacy Policy
Our primary goal is to provide you an experience on our website that is as secure and protected as possible. To do this, we use Google reCAPTCHA from Google Inc. (1600 Amphitheater Parkway Mountain View, CA 94043, USA). With reCAPTCHA we can determine whether you are a real person from flesh and bones, and not a robot or a spam software. By spam we mean any electronically undesirable information we receive involuntarily. Classic CAPTCHAS usually needed you to solve text or picture puzzles to check. But thanks to Google’s reCAPTCHA you usually do have to do such puzzles. Most of the times it is enough to simply tick a box and confirm you are not a bot. With the new Invisible reCAPTCHA version you don’t even have to tick a box.