NIIT MTS EU/US Data Privacy Framework Policy Version 1.2 - Aug 11, 2023


INTRODUCTION

NIIT MTS (“NIIT MTS”, “we”, “us” and “our”) respects individual privacy, and values the confidence of its customers, their stakeholders, employees, business partners and others who may use our services. Not only do we strive to collect, use, and dispose personal information in a manner consistent with the laws of the countries in which we do business, but we also aim to uphold the highest ethical standards in our business practices. This Policy (the "Policy") sets forth the privacy principles that NIIT MTS follows with respect to transfers of personal information between the member states of the European Union, including participating countries in the European Economic Area (collectively, "the EU"), the United Kingdom, and Switzerland, and United States.

DATA PRIVACY FRAMEWORK PRINCIPLES

The United States uses a sectoral approach that relies on a mix of legislation, regulation, and self-regulation. Given those differences and to provide organizations in the United States with a reliable mechanism for personal data transfers to the United States from the European Union, the United Kingdome and Switzerland, while ensuring those data subjects continue to benefit from effective safeguards and protection as required by European legislation with respect to the processing of their personal data when they have been transferred to non-EU countries, the Department of Commerce has issued the Data Privacy Framework Program.

NIIT MTS complies with the EU-US Data Privacy Framework, (EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF) as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries, the United Kingdome (including Gibraltar) and Switzerland. NIIT MTS has certified that it adheres to the Data Privacy Framework Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the DPF Principles, the DPF Principles shall govern. To learn more about the Data Privacy Framework program, and to view our certification page, please visit https://www.dataprivacyframework.gov/

SCOPE

The Policy applies to all personal information received by NIIT MTS in the United States from the EU, the United Kingdome (including Gibraltar) and Switzerland in any format including electronic, paper or verbal.

DEFINITIONS

For purposes of this Policy, the following definitions shall apply:

"NIIT MTS" means NIIT MTS USA Inc, its successors, subsidiaries, divisions, and groups in the United States.

"Personal information" means any information or set of information that identifies or could be used by or on behalf of NIIT MTS to identify an individual. Personal information does not include information that is encoded or anonymized or publicly available information that has not been combined with non-public personal information.

"Sensitive personal information" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, NIIT MTS will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

PRIVACY PRINCIPLES

NIIT MTS uses personal information, such as Name, Email ID, Contact Number, and other relevant information for training administration, and to associate learning progress records to an individual.

Personal information that is transferred to NIIT MTS in the US from the EU falls under one of the following two situations:

NIIT MTS collects personal information of individuals in the EU, the UK, and Switzerland on behalf of its customers. NIIT MTS will not disclose or share this information with anyone other than NIIT MTSí customer and our service providers unless required to do so by law.

NIIT MTSí internal assessment team will monitor the adherence on a regular basis.

NIIT MTS complies to the following privacy principles, modeled after the EU-U.S. DATA PRIVACY FRAMEWORK.

DISPUTE RESOLUTION

In compliance with the EU-U.S Data Privacy Framework (EU-U.S DPF), the UK Extension to the EU-U.S DPF, and the Swiss-U.S Data Privacy Framework (Swiss-U.S DPF) Principles, NIIT Learning Systems Limited (NLSL) commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the EU-U.S DPF, the UK extension to the EU-U.S DPF, and the Swiss-U.S Data Privacy Framework Principles. European Union, United Kingdom, and Swiss individuals with inquiries or complaints should first contact NIIT MTS at:

Chief Privacy Officer,
NIIT USA Inc
3 Ravinia Drive NE, Suite 1930
Atlanta, GA 30346
+1 770-450-6777

Email ID: Privacy@niitmts.com

NIIT MTS has further committed to refer unresolved privacy complaints under the Data Privacy Framework program to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. 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/dpf-consumers/ProcessForConsumers, for more information and to file a complaint. This service is provided free of charge to you.

If your DPF 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 https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2

CONTACT INFORMATION

Inquiries, complaints, Questions or comments regarding this Policy should be submitted to NIIT MTS by post or e-mail as follows:

Chief Privacy Officer,
NIIT USA Inc
3 Ravinia Drive NE, Suite 1930
Dunwoody, GA 30346
+1 770-450-6777

Email ID: Privacy@niitmts.com