1. WHAT DATA DO WE COLLECT?

We collect information directly from you and in some instances from your employer.

When you (or your employer) sign up to the Platform you may provide certain personal data including:

• contact information such as your name, email address, and phone number;

• captured live images through the web camera enabled tests;

• any personal data regarding another individual that you provide in the course of using the services;

• employment information such as your HR/employee ID, length of time that you have worked in your employer organisation, job title, work location, department, employment start date and next pay date;

• details of your correspondence with us;

• technical information, such as your Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, screen resolution, flash version, time zone setting, browser plug-in types and versions, operating system, platform and traffic data, cookies data, web logs and other communication data, and details of the resources that you access, which we collect from you when you access the Platform; and

• any other information you provide to us.

2. HOW DO WE USE THE DATA WE COLLECT?

The personal data we collect enables us to provide you and your employer with access to the Platform and its features and enable you to interact with the Platform.

In particular, we use your personal data to:

• enable you to access and use the Platform, including to verify your identity when signing up to the Platform and verifying your account;

• verify your identity when subsequently logging in and using the Platform;

• to prevent you from navigating away from the test window while an assessment is ongoing;

• contact you when necessary (including about changes to our service) and respond to your requests and enquiries;

• provide technical assistance or allow any third party authorised by us to do so;

• manage troubleshooting problems, detect and protect against error;

• market products and services to you, including ours, those of our affiliates, and those of other third parties, provided that, where required, we have obtained your consent to do so;

• fulfil legal and regulatory requirements;

• detect and prevent fraud, suspicious activities, and other illegal activities;

• analyse and improve products and services, collect feedback, enhance the Platform, and evaluate the effectiveness of our marketing activities and overall services;

• perform statistical analyses on users of the Platform and track your use of the Platform; and

• on an aggregated and anonymised basis, share the data and statistical analyses with our clients.

3. DISCLOSURE OF YOUR INFORMATION

We may share your personal data to assist with managing and running the Platform and undertaking the activities set out in section 2 above, or to provide other products or services or support as requested by you or your employer. In particular, we may share this information with:

• your current or potential employer in order to assess your suitability for a job;

• other Mettl clients who are hosting a hackathon when you have registered your interest in participating in future hackathons;

• our affiliates to enable them to provide services to you and, where we have the requisite consent, to contact you regarding additional products and services that may be of interest to you;

• third parties who handle your personal data on our behalf in order to provide the Platform, including Amazon Web Services, who support the Platform, and who may access your personal data on our behalf in order to make the Platform available and in connection with providing enhanced functionality;

• law enforcement agencies, regulatory authorities and other public bodies such as courts in order to comply with our legal or regulatory obligations; and

4. USING YOUR INFORMATION IN ACCORDANCE WITH DATA PROTECTION LAW

Data Protection Law requires that we meet certain conditions before we are allowed to use your personal data in the manner described in this privacy notice. To use your personal data, we will rely on one of the following conditions, depending on the activities we are carrying out:

5. HOW LONG WE KEEP YOUR INFORMATION FOR

Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose.

We usually keep your information for as long as required to:

• to respond to any questions or complaints;

• to show that we treated you fairly;

• to demonstrate compliance with our regulatory obligations; and/or

• to maintain records according to rules that apply to us.

6. SENDING DATA OUTSIDE OF THE EEA

We are an India based company with staff located in India, and therefore, your personal data will be processed outside the European Economic Area (“EEA”).

If we do transfer personal data outside of the EEA we will make sure that it is protected in the same way as if it was being used in the EEA and may be required to take specific additional measures to safeguard the relevant personal data. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to the Data Protection Laws (see the full list here) and therefore no additional safeguards are required to export personal data to these jurisdictions. In countries which have not had these approvals, we will establish legal grounds justifying such transfer, such as European Commission-approved model contractual clauses, or other legal grounds permitted by applicable legal requirements.

You can contact us as set out in section 10 below to find out more about safeguards we have in place for any transfers of your personal data outside of the EEA or if you would like to see a copy of the specific safeguards applied to the export of your personal data.

7. WHAT STEPS DO WE TAKE TO PROTECT YOUR INFORMATION?

All information you provide to us is stored on our or our subcontractors’ secure servers and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone and may suspend or terminate your access to the Platform if you do so.

We restrict access to your personal data to those employees of ours, our affiliates, and third party service providers who reasonably need it to provide products or services. We have implemented commercially reasonable physical, electronic, procedural, administrative, and technical safeguards in a way that complies with the security requirements of data protection laws to protect your personal data, located in the countries where we are based from unauthorised access. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of these systems, nor can we guarantee that information supplied by you or on your behalf cannot be intercepted while being transmitted over the Internet.

8. WHAT RIGHTS AND OBLIGATIONS DO YOU HAVE WITH RESPECT TO YOUR DATA?

You have a number of rights under data protection laws in relation to the way we process your personal data. These are set out below. You may contact us using the details in section 11 below to exercise any of these rights. We will respond to any request received from you within one month from the date of the request.

9. CHANGES TO THIS PRIVACY NOTICE

We may change the content of the Platform and how we use cookies and consequently this privacy notice and our cookies notice and any other document to which they refer are subject to change at any time. If we make material updates to this privacy notice, we will update the date it was last changed and will clearly indicate this via a banner on the Platform and via email. Any changes we make to this privacy notice become effective immediately when we post the revised privacy notice on the Platform. We recommend that you review this privacy notice regularly for changes.

This privacy notice was last updated on 5 October 2020.