Privacy Policy

1. Policy Statement
VRSM LeadMagnet is committed to protecting the privacy and confidentiality of Personal
Information about its employees, clients, business partners and other identifiable individuals.
VRSM LeadMagnet, guidelines and actions support this commitment to protecting Personal
Information. Each employee bears personal responsibility for complying with this Policy.
2. Scope
This Policy sets the minimum standard and shall guide all VRSM LeadMagnet employees
and Agents even if local law is less restrictive. Supplemental policies and practices will be
developed as needed to meet the local or global legal requirements. Supplemental policies
and practices may provide for more strict or specific privacy and protection standards than
outlined in this Policy.
3. Policy Details
3.1 VRSM LeadMagnet respects the privacy of its employees and third parties such as
customers, business partners, vendors, service providers, former employees and recognizes
the need for appropriate protection and management of Personal Information. VRSM
LeadMagnet is guided by the following principles in Processing Personal Information:
● Notice
● Choice
● Security
● Data integrity and purpose limitation
● Recourse, Enforcement and Liability
3.2 Notice. When collecting Personal Information directly from individuals, VRSM
LeadMagnet strives to provide clear and appropriate notice about the Purposes for which it
collects and uses their Personal Information
● Personal Data shall be collected for Specific explicit and legitimate purposes and not
further processed in a manner that is incompatible with those purposes.
● Data shall be kept accurate and up to date and every step need to be taken to
ensure that inaccurate data are erased or rectified
● Data shall be processed in a manner that ensures the security of the data, including
protection against unauthorized, unlawful processing and accidental loss using
appropriate technical or organizational measures.
3.3 Choice. VRSM LeadMagnet Generally, offers individuals a choice to opt-in or opt-out
from further processing and explicit consent from individuals is required when Processing
Personal Information for:
● Receiving further contents and information
● receiving further communication (email, phone, post…..etc)
3.4 Security. VRSM LeadMagnet takes reasonable and appropriate measures to protect
Personal Information from loss, misuse and unauthorized access, disclosure, alteration and
destruction, taking into due account the risks involved in the processing and the nature of the
Personal Information.
3.5 Data Integrity and Purpose Limitation. VRSM LeadMagnet will only Process Personal
Information in a way that is compatible with the purpose for which it has been collected or
subsequently authorized by the individual. VRSM LeadMagnet shall take steps to help
ensure that Personal Information is accurate, reliable, current and relevant to its intended
use.
3.6 Recourse, Enforcement and Liability. Violation of this Policy by an employee or
contractor of VRSM LeadMagnet will result in appropriate discipline up to and including
termination. Violation by an Agent, Controller or other third parties of this Policy or VRSM
LeadMagnet privacy requirements will result in the exercise of appropriate legal remedies
available at law or in equity including termination for material breach of contract.
4. Administration
4.1 Roles and Responsibilities. Responsibility for compliance with this Policy rests with the
heads of the individual functions, business units and departments together with any
individual employees collecting, using or otherwise Processing Personal Information.
Business unit, function and department heads, in coordination with the Legal Department,
are responsible for implementing further standards, guidelines and procedures that uphold
this Policy, and for assigning day-to-day responsibilities for privacy protection to specific
personnel for enforcement and monitoring.
4.2 Implementation. This Policy is meant to be implemented in conjunction with
supplementary data privacy policies specific to a region, country or department if required.
These supplementary data privacy policies will account for differences in data protection
requirements by jurisdiction or function and will specify individual roles and responsibilities.
VRSM LeadMagnet business units, functions or facilities will implement supplementary data
privacy policies as required to be in compliance with applicable laws.
4.3 Interpretation. In the event of any conflict between this Policy and any supplemental data
privacy policy, this Policy will supersede the supplemental data privacy policy to the extent
that the supplemental data privacy policy is less restrictive. Local data privacy policies may
provide for stricter data privacy and protection standards than are set forth in this Policy. In
the event local data privacy law provides for stricter data privacy and protection than this
Policy, the local data privacy law will supersede this Policy in that jurisdiction to the extent
necessary to comply with stricter local law.
5 Definitions
“Agent” means any associate that collects and/or uses Personal Information provided by
VRSM LeadMagnet to perform tasks on behalf of and under the instructions of VRSM
LeadMagnet.
“VRSM LeadMagnet” is VRSM LeadMagnet Pvt Ltd . and all of its subsidiaries and affiliates
globally.
“Controller” means a person or organization which, alone or jointly with others, determines
the purposes and means of the processing of Personal Information.
“Personal Information” is information or data about an identified or identifiable individual. It
does not include information that is anonymous, aggregated or in circumstances where the
individual is not readily identifiable.
“Policy” means this Global Data Privacy Policy, as revised.
“Processing” or “Process” means any operation or set of operations which is performed on
Personal Information or on sets of Personal Information, whether or not by automated
means, such as collection, recording, organization, structuring, storage, adaptation or
alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise
making available, alignment or combination, restriction, erasure or destruction.