WHAT IS THE PURPOSE OF THIS DOCUMENT

Tata Consultancy Services Limited ("TCS") is committed to protecting the privacy and security of your personal data.

This privacy notice describes how we collect and use personal data about you during and after registering and participating in Global CodeVita event in accordance with the General Data Protection Regulation (GDPR).

TCS is a "data controller". This means that we are responsible for deciding how we hold and use personal data about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to Students aged from 17 to 30 registering and participating in Global CodeVita event.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are aware of how and why we are using such information.

DATA PROTECTION PRINCIPLES

We will comply with applicable data protection laws. This means that the personal data we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only as long as necessary for the purposes we have told you about.
  6. Kept securely.
THE KIND OF INFORMATION WE HOLD ABOUT YOU

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (aka anonymous data).

There are "special categories" of more sensitive personal data, which require a higher level of protection.

We will collect, store, and use the following categories of personal data about you like:

DATA PROTECTION PRINCIPLES

We will comply with applicable data protection laws. This means that the personal data we hold about you must be:

  • Name
  • Institute name along with country
  • Contact details like phone number(s) and email ID(s)
  • Authentication data like email ID and Password (secret code).
HOW IS YOUR PERSONAL DATA COLLECTED

We collect personal data about Global Students through our website directly from you.

HOW WE WILL USE INFORMATION ABOUT YOU

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  1. Where we need to perform the contract we have entered into with you, allowing you to participate to the contest.
  2. Where we need to comply with a legal obligation.
  3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal data in the following situations, which are likely to be rare:

  1. Where we need to protect your interests (or someone else’s interests).
  2. Where it is needed in the public interest or for official purposes.

Situations in which we will use your personal data

The situations in which we will process your personal data are listed below.

  • To allow you to participate in the CodeVita contest, receive fundamental communications and other required activities.
  • We also collect your contact phone number(s) and email id(s) to share with you regular updates on CodeVita which usually are informative and promotional.
  • We may also use these details to provide you with more effective customer service, for enhancing CodeVita and any related services, and to make it easier to use by eliminating the need for you to repeatedly enter the same information or by customizing CodeVita to your particular preference or interests.

TCS may use your personal details to provide you with important information and critical updates about:

  • CodeVita products or services that you have used, are using and could possibly use in future.
  • CodeVita contests and competitions of the past, current and forthcoming.
  • CodeVita channel information of the past, current and future.
  • Various CodeVita offerings of the past, current and future.

Some of the above grounds for processing will overlap and there may be several grounds, which justify our use of your personal data.

In the context of EU GDPR, the "lawful" basis of processing your personal data are "processing is necessary for the performance of the contract", "processing is necessary for the purposes of the legitimate interests" pursued by TCS and, in case you gave it, your consent.

If you fail to provide personal data

If you fail to provide certain information when requested, we may not be able to perform/comply with our commitments such as providing regular updates.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

HOW WE USE PARTICULARLY SENSITIVE PERSONAL DATA

Our obligations as a Data Controller

Except as otherwise described in this statement, personal details you provide for CodeVita purpose will not be shared outside of TCS and its controlled subsidiaries and affiliates without your permission. Please be aware that this privacy statement and any choices you make regarding CodeVita will not necessarily apply to personal details you may have provided to TCS in the context of other, separately operated, TCS products or services. Also, please note that for updating or editing the personal details, you need to send an email to campuscommune @tcs.com

Do we need your consent?

We do not need your consent if we use special categories of your personal data in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

DATA SHARING

We may have to share your data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal data outside the EU/EEA. If we do, you can expect a similar degree of protection in respect of your personal data.

Why might you share my personal data with third parties?

We will share your personal data with third parties where required by law, where it is necessary to administer the working relationship with you (as Student) or where we have another legitimate interest in doing so. TCS may enter into a contract with other companies and / or entities to provide limited services on our behalf, such as conducting CodeVita and delivering prizes, answering customer questions etc. TCS will provide those companies and / or entities only the personal details they need to enable them to deliver the services. These companies and / or entities are required to maintain the confidentiality of the information as per the standards laid down in the contract and are prohibited from using the personal details provided by you for any other purpose other than that which is required to perform the services under the contract.

Your personal information will be stored on infrastructures by our external provider Amazon AWS (USA) and TCS servers.

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal data in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

When might you share my personal data with other entities in the group?

We will share your personal data with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganization or group restructuring exercise, for system maintenance support and hosting of data.

What about other third parties?

We may share your personal data with other third parties. We may also need to share your personal data with a regulator or to otherwise comply with the law.

Transferring information outside the EU/EEA

We will transfer the personal data we collect about you to India and USA in order to perform our contract with you. There is not an adequacy decision by the European Commission in respect of that country. This means that the country to which we transfer your data are not deemed to provide an adequate level of protection for your personal data. However, to ensure that your personal data does receive an adequate level of protection we have put in place appropriate measure/s (such as data transfer agreements based on standard contracual clauses and Privacy Shield) to ensure that your personal data is treated consistently across countries.

DATA SECURITY

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal data on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate technical, organizational and security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

DATA RETENTION

How long will you use my information for?

We will securely retain your personal data for maximum of 5 seasons (i.e. 5 years) to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In some circumstances we may anonymize your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. Post the retention period as mentioned above, we will securely and permanently destroy your personal data from our system.

DATA SUBJECT RIGHTS

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Your rights in connection with personal data

Under certain circumstances, by EU GDPR you have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
  • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal data to another party.

If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact campuscommune@tcs.com in writing or our Data Protection Officer (see contact details below).

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

DATA PROTECTION OFFICER

We have appointed data protection officers (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal data, please contact the DPO as per your location:

Data Protection Officer for UK and Ireland:DPO.uki@tcs.com

Data Protection Officer for Continental Europe:DPO.Europe@tcs.com

From non-EU and non-UK-Ireland geographies, if you have a privacy concern, complaint or a question regarding this privacy statement, please direct it to the Chief Privacy Officer of Tata Consultancy Services at cpo.tcs@tcs.com

DATA PROTECTION SUPERVISORY AUTHORITY

Under EU GDPR, you have the right to make a complaint at any time to the relevant data protection supervisory authority.

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.