Effective Date: May 13, 2025
Indecomm Holdings, Inc. d/b/a Indecomm Global Services (‘Indecomm’ or ‘the Company’ or ‘we’) believes that the responsible use of personal information collected on its Web site is critical to its business objectives and reputation. As part of our commitment to privacy, we have adopted this Data Privacy Policy (‘Policy’). The extent and type of information we receive from you on our Web site depends on the information provided to us. The purpose of this Policy is to ensure that all individuals whose Personally Identifiable Information (“PII”) is collected by Indecomm are well informed about how and why Indecomm collects Personally Identifiable Information and what rights are available to them under the international, federal, and state laws as described in more detail below.
This Privacy Policy applies to all business units, processes, and systems in all countries in which Indecomm conducts business and has dealings or other business relationships.
This Policy applies to all business units, processes, and systems in all countries in which Indecomm conducts business and has dealings or other business relationships. This Policy applies to all employees, directors, contractors, consultants, advisors, or service providers that may collect, process, or have access to Personally Identifiable Information (“PII”) of individual data subjects. It is the duty of all the above to be familiar with this Policy and ensure compliance with all Privacy laws.
Indecomm respects individual privacy and values the confidence of its clients, customers, employees, job applicants, business partners, and vendors. Indecomm collects, uses, and discloses PII in a manner consistent with the laws of the countries and states in which it does business. Indecomm also adheres to the most recent industry standards to protect data and is committed to upholding the highest ethical standards in its business practices as it relates to data security and the duty it has to its clients and their consumers.
Indecomm has implemented industry standard security safeguards designed to protect the PII that you may provide to Indecomm’s clients, vendors, or directly to Indecomm. Indecomm monitors its system(s) for possible vulnerabilities and attacks, consistent with industry standards.
Your privacy is important to us. Indecomm believes it is important for you to know how Indecomm treats the PII in the course of offering services to its clients and for its employees. This Privacy Policy explains what Personal Data Indecomm may collect from its clients, vendors and employees, through Indecomm’s interactions with you on Indecomm’s Website, or by offering its services to clients, and for its employees and how Indecomm uses that data.
IF YOU DO NOT AGREE WITH THE TERMS IN THIS PRIVACY POLICY, DO NOT USE THE SERVICES AND WEBSITES. CONTINUED USE OF THE SERVICES AND WEBSITES CONSTITUTES YOUR KNOWINGLY, WILLINGLY AND FREELY GIVING, SPECIFIC AND INFORMED CONSENT AND AGREEMENT TO YOUR PERSONAL DATA BEING PROCESSED PURSUANT TO THIS POLICY.
“Affiliate Company(ies)” means any person or entity, any other person or entity controlled by or under common control with such entity, where “Control” with regard to an entity, means the ownership, either directly or indirectly, of more than fifty percent (50%) or more ownership interest or by stock ownership of such entity are under common ownership and/or “Control”.
“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.”
“Data Subject” means an identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, demographic, economic, or identifier that provides for the identity of that natural person.
“Joint Controller” means two or more controllers jointly determining the purposes and means of processing Personal Data.
“Personal Data” and “Personally Identifiable Information” means any information relating to an individual that can be used to identify that individual either on its own or in combination with other non-public information and/or data.
“Pixels” means small, graphic images on web pages, web-based documents, or in email messages that allow us or third parties to monitor who is visiting our Sites (or other third-party sites) or if an email has been read.
“Processor” means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
“Respondent” means individuals who provide responses to sample, sample panel or survey questions.
“Special Categories of Data” means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
“We”, “our”, and “us” in this Privacy Policy refer to Indecomm and any legally empaneled sub-processor or contractor delivering the services and products herein who are required to adhere to the protection and confidentiality of personal data and PII.
“You” means the individual or entity to whom any given Personal Data and/or PII which may be covered by this Privacy Policy refers.
This Website is not intended for children under the age of 18. If you are under 18 years old, please do not provide information of any kind whatsoever on the Sites. If you are the parent of a child under 18 and believe your child has provided us with personal information, please contact us via Section XI below and we will remove that information.
Any Personal Identifiable Information we collect is used only to respond to your inquiry, process an order or allow you to access specific account information, and is not shared with third parties or for any marketing purposes. This can include but is not limited to email, name, address, phone numbers.
We do not seek to collect or otherwise process your sensitive Personal Identifiable Information for any other purpose other than what is legitimate, and we do so in accordance with applicable law.
We do not collect or otherwise process Personal Identifiable Information about race, religion, sexual orientation, health, or any other information that is deemed to be sensitive in the ordinary course of business with the exception of employees and job applicants and employees if said information was provided of their own free will. By applying for a position with Indecomm you are providing express written consent to be contacted by email, phone and or text message. Indecomm does not share your information with any third parties or affiliates for marketing purposes.
PII collected either electronically or physically, including but not limited to through the performance of third-party services to Indecomm clients, customers and vendors, emails, cold calls, resumes, social media networking sites, subscription to databases and prospective candidate search engines, etc.
Policy Statement and – What Personal Data is Collected and How it is Used
Indecomm shall protect its customers, employees and job applicants’ information/data deemed as ‘Personal’ and/or ‘Private’.
‘Customers’ records shall not be sold, traded, or disclosed to any third party except as may be required by law.
Any information that is provided to us in the course of interacting with our project staff or support departments shall be held in strict confidence. This includes information (including, but not limited to email addresses, phone numbers, postal addresses, bank account details, credit card numbers and medical history), as well as any data that is supplied to us in the course of business engagement.
You can visit most of our sites without registering or actively submitting Personal Data to us. If you do not register, general technical user data such as your device’s Internet Protocol (IP) address, operating system and browser type, and the date and time of your visit, may be automatically collected through the use of “cookies”.
Indecomm will only use your personal information when the law allows us to do so. Although in limited circumstances we may use your information because you have specifically consented to it, we generally rely on the following legal bases to use your information such as:
We will only use your personal information for the purposes for which it was collected 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 information for an unrelated purpose, we will notify you, our client, or our vendor and we will explain the legal basis which allows us to do so.
Indecomm may also retain the aggregate data (not linked to PII) in order to improve its services and for legitimate business purposes. We may combine and synchronize information that your device transmits, information that you actively submit and information that we obtain from third party sources (including suppliers of market research samples and data marketing platforms that may direct you to our sites to answer demographic questions about yourself in preparation for your completion of surveys, and web publishers, advertisers, data brokers and online service providers that may have obtained information from you or your devices via cookies, Pixels, and other tracking technologies). The lawful purpose is in order for Indecomm to perform under its contractual obligations and through third party consent of those business entities to ensure that all PII is protected under industry standards.
Indecomm uses the data collected for two main purposes, described in detail below to operate its business including the official website and to send communications, including promotional communications.
Communications: We use data collected to communicate with you and personalize our communications with you. Additionally, you can sign up for email subscriptions and choose whether you wish to receive promotional communications from Indecomm by email, SMS, post and telephone or other means of communication.
We may process your PII to contact you via email, telephone, SMS or other methods of communication to provide you with information regarding the services and/or products you authorized our client to provide on your behalf and as Indecomm being their third-party in providing those services or products you sought and authorized. For employees, Indecomm . may send information to you regarding our offerings that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.
When Indecomm processes Personal Data about you, we do so with your consent and/or as necessary to provide the website you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our clients/customers, or fulfill other legitimate interests of Indecomm as described in this Privacy Policy.
Below, you will find additional private information that you may find important. Indecomm adheres to applicable data protection laws through the GDPR in the European Union, which if applicable, includes the following rights:
If the processing of Personal Data is based on your consent, you have a right to withdraw consent at any time for future processing;
While the DPDPA was published in August 2023, its provisions are yet to be effective through enforcement as the requirements are yet to be published. Publication of the DPDPA requirements is anticipated in 2024 the following is what Indecomm adheres to at this time under the initial DPDPA:
Digital Personal data is (i) personal data in digital format and (ii) personal data which is collected in a physical format and later digitized. The Central Government of India will subsequently issue rules which will elaborate on the implementation aspects of the DPDPA. The rules will provide further clarity on notice requirements; functions of the consent manager; procedure for data breach notifications; parental consent for children’s data; grievance; exemptions for processing of personal data; redressal procedures etc. Updates will be added to this Privacy Policy as the same become available.
Indecomm is a “financial institution” under GLBA and as such is required to protect “Nonpublic Personal Information” that Indecomm collects from its clients, customers, and vendors. Since Indecomm provides third party support services and financial products to business in the United States it is required to adhere to the requirements of GLBA. Under the GLBA, only an institution that is “significantly engaged” in financial activities is considered a financial institution. You need to take into account all the facts and circumstances of your financial activities to determine if you are “significantly engaged” in such activities.
GLBA protects a consumer’s “nonpublic personal information” (NPI). NPI is any “personally identifiable financial information” that a financial institution collects about an individual in connection with providing a financial product or service unless that information is otherwise “publicly available.”
We take reasonable steps to ensure that PII or Non-Public Information (“NPI”) we receive, process, or maintain is accurate, complete, and reliable for its intended use. Indecomm relies on the accuracy of the information provided directly to us but accepts responsibility for the management and confidentiality of the PII collected.
In general, we keep PII only as long as we need it to provide you and our clients with the services you requested. We may also process data on behalf of third parties who have engaged us. We keep PII and NPI processed on behalf of third parties for as long as needed to provide services to third party in question. However, we reserve the right to retain PII and NPI for any period required by law or to comply with our legal obligations, resolve disputes, and enforce our agreements.
Indecomm takes every reasonable step to ensure that your PII and NPI that we process is limited to the purposes set out in this policy or as required to provide you services or access to the services.
When Indecomm does share your Personal Information with third party service providers and/or sub-processors, Indecomm will:
If you are visiting this website from a country other than the country in which our servers are located, your communications with us will result in the transfer of information across international boundaries. By visiting this website and communicating electronically with us, you consent to such cross-border transfers.
Indecomm is committed to protecting the security of your Personal Data. We use a variety of security technologies and procedures to help protect your Personal Data from unauthorized access, use or disclosure.
Indecomm uses reasonable security measures in an effort to prevent loss, misuse, and alteration of information under our control. However, we cannot guarantee the security of information on or transmitted via the Internet. We rely on various security procedures and systems to ensure the secure storage and transmission of data, including encryption and authentication technology licensed from third parties, to effect secure transmission of confidential information. Additionally, we have absolutely no control over the security of other sites you might visit, interact with, or do business with.
If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. Indecomm may post a notice on the Indecomm Site if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach (or to withdraw your consent from receiving electronic notice) you should notify us.
Our Websites may contain links to external websites, and areas where you can provide information to third parties. These are provided for your convenience only, and we do not have control over the content or privacy and security practices and policies of such third parties or third-party sites. Any Personal Information you provide in such areas, and on such linked pages is provided directly to that third party and is subject to that third party’s privacy policy. Please learn about the privacy and security practices and policies of external websites and third parties before providing them with Personal
You can choose to opt-out whenever your Personal Information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individuals.
If you consent to receive SMS text messages from Indecomm, you agree to receive account notifications, service updates, and customer support-related messages from us. Message frequency may vary based on your interaction with our services or the services you requested and authorized Indecomm to perform on behalf of its clients. You may:
We reserve the right to modify this Privacy Policy at any time. If we decide to change our Privacy Policy, we will prominently post those changes here and any other place we deem appropriate, so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make any material changes, we will notify you by means of a notice on this site prior to the change becoming effective. We will use information in accordance with the privacy policy under which the information was collected.
We use a self-assessment approach to address compliance with this Privacy Policy, verifying periodically that the policy is accurate, comprehensive, and addresses the privacy requirements applicable to the markets we serve. Periodically, our operations and business practices are reviewed for compliance with corporate policies and procedures governing the confidentiality of information.