Introduction
We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, share, and protect your personal information in compliance with applicable data protection laws including California Consumer Privacy Act (CCPA/CPRA), General Data Protection Regulation (GDPR), India’s Data Protection Act 2023 and Digital Personal Data Protection Act (DPDP) 2023, China’s Personal Information Protection Law (PIPL), Brazil’s Lei Geral de Proteção de Dados (LGPD), Japan’s Act on the Protection of Personal Information (APPI), and other global regulations.
Definitions:
For clarity, this Privacy Policy uses key terms as defined below:
- Personal Data: Any information relating to an identified or identifiable individual, including but not limited to name, contact details, IP address, or other identifiers.
- Sensitive Personal Data: Personal Data related to health, biometric data, racial or ethnic origin, political opinions, religious beliefs, or other categories requiring higher protection.
- Protected Health Information (PHI): Individually identifiable health information held or transmitted by a covered entity or business associate as defined under HIPAA, including medical records and payment information.
- Data Subject: The individual to whom the personal data relates.
- Processing: Any operation performed on personal data such as collection, storage, use, disclosure, or deletion.
- Data Fiduciary: The entity or person responsible for deciding the purpose and means of processing personal data (as per DPDP Act 2023).
Information We Collect
HTC collects your Personal Data explicitly when you voluntarily provide your data with your consent (e.g., when you subscribe to any of our services, request information from us, apply for a job, accept an offer for employment or contracted services, or enrol in benefits).
We also collect certain categories of your Personal Data implicitly (using automatic tracking technologies) when you visit our website (e.g., Cookies, IP Address, Geolocation etc.). The information we collect using these technologies includes IP address, browser type and language, access time, and referring website.
We may also obtain Information about you from third parties who have a legal basis to provide us with your information. We may use information about you which we receive from a third party in accordance with the terms we establish with that third party
Use of Your Information
HTC collects and uses your Personal Data when required for specific purposes. Your data is used for:
- Legal and regulatory compliance
- Marketing and customer identification
- Data analytics
- Customer support and service management
- Conducting risk assessments and fraud prevention
- Enhancing user experience and product/service development
- Employment and contractor management
- Legal claims and dispute resolution
- Internal audit and business continuity
li>Records management and historical documentation
Legal Basis for Processing
Processing is based on your consent, contractual necessity, legal obligations, vital interests, or legitimate interests balanced with your privacy rights, as mandated by applicable laws.
DPDP Act 2023 Specific Provisions
- We act as Data Fiduciaries responsible for protecting your digital personal data with security safeguards
- Consent is sought for all personal data processing activities and can be withdrawn anytime
- Personal data is erased when no longer needed or upon consent withdrawal
- Data breaches, if any, will be notified promptly to affected individuals and regulatory authorities
- Special protections are in place for children including obtaining parental consent and prohibiting harmful data practices
- You can nominate a representative to exercise your data rights in case of death/incapacity
- Cross-border data transfers comply strictly with government notifications and safeguards
Sharing Your Personal Data with Third Parties
We may share your Personal Data with third parties who provide data processing services on our behalf. These providers are contractually obligated to use the data only for the agreed purposes and to protect it in accordance with applicable laws and
International Transfers of Your Personal Data
HTC Global Services and its group companies are collectively referred to as “HTC” in this privacy notice. HTC is an international organization with a presence in the USA, India, and other locations listed on this website. HTC store or process personal information, including data related to employees, contractors, vendors, applicants, and marketing lists within our corporate infrastructure across these locations, with appropriate safeguards in place to protect the data.
Our public websites may be hosted in India. As a result, website cookies and IP addresses from visitors around the world may be captured and transferred to servers located in India. HTC abides by all applicable legal and contractual obligations governing the international transfer of personal data.
Your Rights Under GDPR, DPDP Act, And Other Relevant Data Privacy Laws
You have certain rights regarding your personal data under the General Data Protection Regulation (GDPR), the Digital Personal Data Protection Act (DPDP), and other applicable data protection laws. These rights may include:
- The right to access and obtain a copy of your personal data
- The right to correct or update inaccurate or incomplete data
- The right to request deletion or erasure of your personal data
- The right to restrict or object to certain types of data processing
- The right to data portability, allowing you to move your data to another service provider
- The right to withdraw consent for data processing where such processing is based on your consent
- The right to nominate a representative to exercise your data rights on your behalf (applicable under DPDP)
- The right to be informed about and object to automated decision-making and profiling
- The right to limit the use of sensitive personal data
- The right to data breach notification
- The right to lodge complaints with relevant data protection authorities
Please note that exercising some of these rights may affect our ability to provide you with certain services. For any questions or to exercise your rights, please contact us using the information provided in the Privacy Contact section of this document.
California and USA State Privacy Rights
Californian consumers have additional rights including:
- Know what personal data is collected and how it is used
- Delete personal data with exceptions
- Opt-out of sale or sharing of personal data
- Transparent disclosures regarding automated decision-making
The content linked click here under the ‘US State Consumer Privacy Law Comparison Chart’ will be reviewed and updated at least quarterly.
Cookies and Tracking Technologies
Our website uses cookies and similar technologies to improve your experience. Your consent preferences can be managed as per applicable laws.
Data Retention and Security
HTC retains your data as long as required by relevant laws and regulations, and our business requirements are relevant to the reason you provided your data to us. HTC deletes and purges data periodically based upon our Data Retention and Removal policy.
Children’s Privacy
Services are not intended for children under 18 (or applicable age). Under DPDP, COPPA( Under 13) and other regulations, parental consent is mandatory before collecting children’s data.
Collecting/Sharing Sensitive Personal Data
HTC only collects Sensitive Personal Data with the consent of the individual. Furthermore, Sensitive Personal Data is only collected if it is required by law or regulation or when necessary to provide the individual with a benefit that the individual has requested. HTC takes reasonable and appropriate measures to restrict access to any Sensitive Personal Data collected to only those employees, contractors or vendors whose jobs or responsibilities require such access.
HIPAA compliance
In accordance with the Health Insurance Portability and Accountability Act (HIPAA), our organization ensures compliance with applicable privacy and security regulations. We are responsible for developing, implementing, and overseeing privacy policies and procedures to protect electronic Protected Health Information (ePHI).”
Updates and Contact
3270 West Big Beaver Rd. Troy, MI 48084
Tel: 248.530.2525
Email: privacy@htcinc.com
