Additional Privacy Terms if You are Located in India

Last Updated: April 1, 2022

If you are located in India, you have certain rights with respect to your personal information. The following is a summary of those rights and additional information applicable to our collection and use of your personal information. For clarity, these Additional Privacy Terms if You are Located in India are in addition to, and not in lieu of, the information provided in our Privacy Policy.

India’s Information Technology Rules

We have adopted India’s Information Technology (Reasonable Security Practices and procedures and sensitive personal data or information) Rules, 2011 contained in the Information Technology Act, 2000 as amended by Information Technology (Amendment) Act of 2008 (the "IT Act"). These Information Technology Rules govern the way in which we collect, use, disclose, secure and dispose of personal information subject to the IT Act.

Sensitive Personal Information

Under the IT Act, sensitive information includes information about such things as an individual's sexual orientation, health condition, medical records and medical history, password information, biometric information, and financial information associated with bank accounts or other payment methods. We only use sensitive information:

  • For the primary purpose for which it was obtained;
  • For a secondary purpose that is directly related to the primary purpose;
  • With your consent; or
  • Where required or authorized by law.

Summary of Uses and Disclosures of Personal Information

The following is a summary of the categories of personal information we collect, whether we collect the information about Visitors, Employees and Contractors, and/or Client, the purposes for which we collect the information, and the categories of third parties with whom we share personal information.

This is a summary of the categories of personal information we have collected and shared in the preceding 12 months.

Category of Information Information is collected about Sources from whom information was collected Purpose Categories of Third Parties with whom we share personal information
A. Identifying Information
 
  • Visitors
  • Employees and Contractors
  • Clients
You
  • Communicate with you
  • Provide services to you
  • Personalize your experience with us
  • Provide customer service
  • Maintain and secure your account with us
  • Respond to your requests
  • Respond to law enforcement requests or as required by law
  • Vendors that provide marketing and communication services
  • Service providers
  • Government or law enforcement agencies
Employees and Contractors You Identify you, or validate or verify your identity Companies with employment or engagement opportunities
Employees and Contractors You Comply with legal requirements Government agencies
Employees and Contractors Consumer Reporting Agencies - Pre-engagement screenings

- Obtain a consumer report

Companies with engagement or employment opportunities for you
Employees and Contractors You Make payments to you Banks and other financial institutions
B. Categories of Personal Information described in India’s IT Act, Information Technology Rule 3 Protected by Law

 

Note: (some information may overlap other categories)

 

  • Visitors
  • Employees and Contractors
  • Clients
You
  • Communicate with you
  • Provide services to you
  • Personalize your experience with us
  • Provide customer service
  • Maintain and secure your account with us
  • Vendors that assist with communications
  • Service providers
Employees and Contractors Consumer Reporting Agencies Pre-engagement screenings Obtain a consumer report Companies with engagement or employment opportunities for you
Employees and Contractors You Make payments to you Banks and other financial institutions
Employees and Contractors You Provide demographic information to your Client Your Client
Employees and Contractors You Comply with legal requirements Government agencies
C.  Characteristics and similar Information Protected by Law Employees and Contractors You
  • Comply with legal requirements
  • Provide benefits to you
  • Government agencies
  • Benefit providers
D. Commercial Information
  • Visitors
  • Employees and Contractors
  • Clients
You, Cookies
  • Improve your experience on our Websites
  • Provide services to you
Service Providers
E. Biometric Information Fingerprints You As required for federal security clearance Government agencies as required
F.  Activity on our Websites
  • Visitors
  • Employees and Contractors
  • Clients
You, Cookies
  • Manage your preferences
  • Maintain and secure your account
  • Improve your experience on our Websites
  • Provide Services to you
Service providers
G. Geolocation data
  • Visitors
  • Employees and Contractors
  • Clients
You, Cookies
  • Manage your preferences
  • Improve your experience on our Websites
  • Provide Services to you
  • Improve our processes
H. Sensory Data including audio, electronic, visual, thermal, olfactory or similar information
  • Visitors
  • Employees and Contractors
  • Clients
You Telephone calls to customer support staff may be recorded for training and quality control None
Individuals who visit our offices You Audio/video monitoring of individuals who enter our offices None
I.  Professional or Employment Related Information Employees and Contractors You
  • Verify your qualifications for employment or engagement opportunities
  • Provide opportunities for you to be employed or engage with clients
  • Provide services to you
  • Companies with employment or engagement opportunities
  • Service providers
Employees and Contractors Consumer Reporting Agencies - Pre-engagement screening

- Obtain a consumer report

Companies with engagement or employment opportunities for you
J. Education Information Employees and Contractors You
  • Verify your qualifications for employment or engagement opportunities
  • Provide opportunities for you to be employed or engage with clients
  • Companies with employment or engagement opportunities
  • Service providers


Reasonable Security Practices and Procedures

Pursuant to India’s IT Act, Information Technology Rule 8, India has determined that the International Organization for Standardization (ISO) demonstrates compliance with India’s reasonable security practices and procedures.

MBO Partners received the ISO 9001:2015 certification after demonstrated ability to meet customer, statutory, and regulatory standards.  Therefore, our security practices and procedures are in full compliance with India’s laws.

Contact Details and Complaints

For any questions, concerns or complaints regarding a possible breach of your privacy by us, please contact our Data Protection Officer as follows:

  • By completing the Individual Data Request Form
  • By phone at 0011+1+703 793 6000
  • By mail to MBO Partners, Inc, Attention Data Protection Officer, 20405 Exchange Street, Suite 301, Ashburn VA 20147

We will treat each complaint confidentially. We will investigate each complaint and will contact the individual that submitted the complaint within a reasonable time period once the complaint is resolved (and in any event within any applicable time periods required by law).

Transfers of Personal Information

We may disclose your personal information to our affiliates, third party suppliers and service providers, and other third parties as described in our Privacy Policy and as authorized by India’s IT Act. Some of these entities may be located outside India, including in the United States, New Zealand, Singapore, Germany, Ireland, Australia, and the United Kingdom. We take reasonable steps to ensure that any entities located inside or outside India that receive your personal information from us ensure the same level of data protection that is adhered to by us and that such entities do not breach applicable privacy obligations.

Changes to These Additional Privacy Terms if You are Located in India

We may update these Additional Privacy Terms if You are Located in India from time to time. When we do update them, we will post a notice on our Websites, make the updated version of these Additional Privacy Terms if You are Located in India available on this page, and indicate the date it was last updated above. For clarity, any updates will apply from the date they are posted. Please check back periodically to see if these Additional Privacy Terms if You are Located in India have been updated.