Privacy Statement of Sumcircle Technologies Pvt. Ltd.

Sumcircle Technologies Pvt. Ltd., its subsidiaries, and branch operations, whether referred to as "Sumcircle," "we," "us," or "our," are committed to safeguarding your privacy and preferences. This Privacy Statement outlines our policies on the Personal Information we collect and manage in compliance with applicable data privacy laws.

Objective: We intend to provide a thorough overview of our privacy rules regarding the collection and handling of personal data from various sources by providing this statement. Although our commitment to these practices is consistent across the entire organization, this document primarily focuses on data gathered through our website www.sumcircle.com

Your collaboration with Sumcircle and the objective of Sumcircle and the objective of data processing, additional tailored privacy statements may be shared. These include more detailed descriptions aligned with your engagement with us.

This Privacy Statement outlines the types of personal data we collect, the purposes for which we process it, data recipients, your rights under applicable laws, and guidance on exercising these rights. While this Statement has global applicability, certain country- or region-specific terms may also apply.

In cases where translations of this Privacy Statement are available, the English version shall prevail in the event of discrepancies.

Personal Information That We Process and Use

Personal Information That We Process and Use

We may collect the following categories of Personal Information:

• Information related to your visit and usage of our websites, including Internet Protocol (IP) address, location data, browser type, operating system, device identifiers, and telemetry data gathered via cookies and similar technologies.
• Personal and contact details such as your name, job title, organization, email address, phone number, city/country of residence, and professional profiles like LinkedIn.
• Login credentials where applicable, such as usernames and passwords.
• Audio-visual content including photographs, videos, or webinar footage if you attend any of our events or sessions.
• Communications, queries, feedback, or correspondence submitted to us.
• Preferences and interests, including subscription details and dietary restrictions for events.
• Any other personal information relevant to your relationship with Sumcircle, as outlined in the supplementary statements.

Sources of Personal Information

Personal Information may be collected from the following sources:

• Directly from you, via forms on our website, communications, or events.
• From interactions with our sales or marketing representatives.
• From our affiliates or group entities.
• Provided by your employer if you are engaging with us professionally.
• Publicly available websites and social media platforms.
• Vendors, service providers, or business partners.
• Through cookies and tracking technologies embedded in our website (see our Cookie Policy for details).

Purpose of Using Your Personal Information

We may use your information for the following reasons:

• To improve usability, maintenance, and troubleshooting on our websites.
• To analyze user behavior for enhanced site functionality and performance.
• To create and manage login credentials where applicable.
• To recognize you after registration and personalize your experience.
• To communicate with you and respond to your queries.
• To offer customized content based on your preferences.
• For marketing, lead generation, and sales communications.
• To offer you access to our digital content, including podcasts.
• To enable your participation in events, competitions, or ideathons.
• To publish testimonials, award recognitions, or speaker profiles online.

For campaign and promotional activity, including across social media platforms.

To manage our CRM database and maintain business intelligence.

For website and business analytics and optimization.

To protect our digital infrastructure and ensure cybersecurity.

For regulatory compliance, audits, legal obligations, and protection of our legal rights.

To enhance your website experience via cookies or other technologies (refer to domain-specific cookie policies for more).

We may also use AI and machine learning technologies to improve user experience and analytics. We ensure responsible AI practices are followed during such processing.

Legal Basis for Processing

We process your Personal Information based on:

Contractual necessity – for services you engage with or employment contracts.

Legitimate interest – such as improving our services, securing data, and CRM management, provided such interests are not overridden by your rights.

Consent – especially for marketing communications or event participation. You may withdraw your consent at any time.

Legal obligation – including regulatory filings and defending legal rights.

Consequences of Not Providing Personal Information

If you choose not to provide certain mandatory Personal Information, we may be unable to fulfill your request or provide relevant services.

Data Recipients, Transfers, and Disclosures

Sumcircle does not share your Personal Information with third parties for their direct marketing purposes.

We may share Personal Information with:

Our affiliates or subsidiaries within the Sumcircle group.

Authorized service providers working with us under confidentiality agreements.

Government authorities or law enforcement as required by law.

Where applicable, cross-border data transfers are conducted with appropriate safeguards to ensure compliance with relevant privacy laws.

Sharing and Transferring Your Personal Information

Data Sharing Sumcircle Technologies Pvt. Ltd. does not share your Personal Information with third parties for their direct marketing purposes.

We may share your Personal Information with:

Sumcircle Technologies Pvt. Ltd. or its subsidiaries;

Business partners, in relation to collaborative engagements or joint offerings;

Authorized service providers, under contractual obligations to safeguard data;

Third-party agents, operating on our behalf for specific functions;

Auditors, legal entities, and government authorities, where disclosure is required by applicable law or regulation.

Facilitating International Data Transfers Your Personal Information may be transferred to countries outside your country or region of residence, either to entities within the Sumcircle group or to authorized third parties. These countries may have different data protection standards than those in your country of residence.

Our global service delivery network includes the USA, Dubai, and the UK.

Where such transfers occur, Sumcircle ensures compliance with applicable legal frameworks and implements adequate safeguards such as:

Standard contractual clauses approved by relevant authorities;

Binding corporate rules where applicable;

Appropriate data protection agreements with third-party processors.

When legally mandated, Sumcircle may also disclose Personal Information to law enforcement or regulatory bodies.

Your Rights as a Data Subject

Available Rights Subject to the data privacy laws applicable in your jurisdiction, you may have the right to:

Access your Personal Information;

Request corrections or updates (rectification);

Request deletion (right to be forgotten);

Restrict or object to processing;

Withdraw previously given consent;

Lodge a complaint with a data protection authority.

The availability and extent of these rights may vary depending on your place of residence and the legal basis of processing.

How to Exercise Your Rights

To exercise your rights, we may request verification of your identity to ensure your privacy is protected. Please contact us via support@sumcircle.com to initiate any requests or inquiries.

Managing Preferences

You can update or modify your marketing and communication preferences at any time through our Contact Preference Center.

Data Security

At Sumcircle, we maintain a robust governance model supported by sound processes and cutting-edge technology. This integrated approach helps us enforce:

Administrative controls;

Physical safeguards;

Technical and organizational measures;

All aimed at securing your Personal Information from unauthorized access, misuse, or disclosure.

Data Retention

Your Personal Information will be retained only for as long as necessary to fulfill the purposes outlined in this privacy statement, unless a longer retention period is required by legal, regulatory, or legitimate business purposes. Once your data is no longer required, it will be securely deleted or anonymized in accordance with applicable laws and our internal policies.

Escalating Concerns to Your Local Data Protection Authority

If you are not satisfied with how Sumcircle handles your Personal Information or your requests, and depending on your country of residence, you may escalate your concern to your respective Data Protection Authority.

Third-Party Links and External Portals

Sumcircle websites may include links to third-party websites, applications, or platforms. Please note:

We are not responsible for the privacy practices, policies, or content of such external websites.

Privacy practices for specific portals such as recruitment or alumni engagement will follow the privacy policy specific to those platforms.

We encourage you to read the privacy policies of any linked third-party sites you visit.

Children’s Privacy

The products, services, and content offered by Sumcircle Technologies Pvt. Ltd. are not intended for use by children.

We do not knowingly collect Personal Information from children without verifiable parental consent. If we become aware that a child has submitted personal data without such consent, we will:

Take immediate steps to delete such information from our records;

Use the data only if necessary to protect the child or others as required by law.

If you believe a child has shared Personal Information with us without parental consent, please contact us at – support@sumcircle.com

How to Contact Us

If you have any questions regarding our privacy practices or this privacy statement, or if you wish to request this privacy statement in an alternative format, please contact us at:

Contact Person: Sneha Singh.

Contact Address: 606, Rajhans Helix, 3, LBS Marg, above Vijay Sales, Sainath Nagar, Ghatkopar West, Mumbai, Maharashtra 400086

Phone: 098676 41611

Email: support@sumcircle.com

Updates to This Privacy Statement

Sumcircle Technologies may, from time to time, revise its data privacy practices and update this privacy statement to reflect those changes. Such revisions will be made available on our official website. Notwithstanding any changes, our commitment to safeguarding the privacy of our stakeholders will remain unchanged.

Privacy Statements for Other Categories of Data Subjects

Candidates (Job Applicants and Interns)

Categories of Personal Information Processed:

Name, contact information, resume, date of birth, educational qualifications and skills, prior employment details, background check data, passport details (if shortlisted), optional data (e.g., personal website, travel willingness), financial and national identification data (only where legally required).

Note: The nature of data processed may vary based on business requirements and applicable legal obligations in different jurisdictions.

Purpose of Processing:

• Evaluate suitability for employment or internships.
• Undertake recruitment procedures, including background verification by authorized vendors.
• Facilitate onboarding and comply with labor and employment laws.

Legal Basis:

• Necessity for the performance of a contract or pre-contractual steps.
• Consent, where required by applicable laws.

Data Recipients:

Authorized internal stakeholders of Sumcircle Technologies, subsidiaries or affiliates, third-party service providers including cloud service providers, background verification agencies, regulatory and law enforcement bodies, auditors (internal/external), and clients (if contractually obligated).

Employees and Alumni

Categories of Personal Information Processed:

Contact details, family details, academic and professional history, personal identification, compensation and tax-related data, benefits and claims information, performance data, IT and digital access logs, travel history, health and safety records, attendance, and leave records, background verification, and system usage monitoring data (where legally permitted).

Purpose of Processing:

• Facilitate onboarding and employment-related processes.
• Comply with applicable employment and regulatory requirements.
• Maintain alumni relations, share relevant employment records, and enable future engagement or re-employment opportunities.

Legal Basis:

Processing is conducted on the basis of:

• Contractual necessity
• Legal obligations
• Legitimate business interests
• Consent (where applicable)

Data Recipients:

Authorized personnel across relevant internal functions (HR, Finance, etc.), third-party vendors, government authorities, regulatory bodies, external/internal auditors, and clients (under contract).

Business Partners and Investors

Categories of Personal Information Processed:

Name, designation, contact details, institutional affiliation, fund or investment information, and publicly sourced data.

Purpose of Processing:

• Establish and maintain business relationships.
• Share updates and relevant communications about Sumcircle Technologies.

Legal Basis:

Processing is conducted on the basis of:

• Legitimate interests
• Consent (where mandated by applicable Data Protection laws)

Data Recipients:

Internal departments, authorized service providers, government and regulatory authorities, external auditors, and tax consultants.

Shareholders

Categories of Personal Information Processed:

Name, user ID, PAN, folio/client ID, DP ID, demat account details, contact details, address, date of birth, estimated income, residential/legal status.

Purpose of Processing:

• Administer tax deductions on dividends as required under applicable laws.

Legal Basis:

Processing is carried out in compliance with legal obligations.

Data Recipients:

Authorized personnel, statutory authorities, service providers, auditors, and tax consultants.

Please consult our Global Privacy Statement for additional insights into our privacy and data security practices.

Visitors

Categories of Personal Information Processed:

Name, contact details, organization, visit details (date, purpose), assets brought in (if any), photographs, and CCTV/video footage.

Purpose of Processing:

• Grant secure access to Sumcircle Technologies’ premises.

Legal Basis:

Processing is based on legitimate interest or consent, where applicable.

Data Recipients:

Authorized internal functions, contracted service providers, government and law enforcement authorities, and external auditors.

Visitor privacy notices are also visibly displayed at Sumcircle Technologies’ office entrances. Please refer to our Global Privacy Statement for more information.

Vendors and Service Providers

Categories of Personal Information Processed:

Vendor name, contact details, registered address, tax identification details, and primary point of contact information.

Purpose of Processing:

• Facilitate vendor onboarding
• Create purchase orders and invoices
• Conduct business communications
• Process quotations and service documentation

Legal Basis:

Processing is undertaken to fulfill contractual obligations or based on consent, as mandated by law.

Data Recipients:

Internal procurement and finance teams, service partners, tax authorities, regulatory agencies, and external auditors.