Who Are We?
We are SHRMpro pvt ltd, a modern human resources management system (HRMS) and application tracking system (ATS) solution company providing holistic on-cloud, SaaS model human resource information systems. Our software is designed to provide functional ease to the HR Teams of businesses across industries. Our product works as a support system to seamlessly manage the entire recruiting, onboarding and workforce management processes through automation with security.
Where a company decides how and why personal data is processed, then the latter is a controller according to Article 4(7) of the GDPR. Therefore, SHRMpro pvt ltd is the controller for the data regarding the website visitors, prospective clients that we contact and our existing customers.
For the purposes of this Regulation prescribed under Article 4 of GDPR
- “personal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one 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, physiological, genetic, mental, economic, cultural or social identity of that natural person;
- “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
- “restriction of processing” means the marking of stored personal data with the aim of limiting their processing in the future;
- ‘profiling’ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;
- ‘pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;
- ‘filing system’ means any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis;
- ‘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;
- ‘processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
- ‘recipient’ means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. 2However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;
- ‘third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;
- ‘consent’ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
- ‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;
- ‘genetic data’ means personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in question;
- ‘biometric data’ means personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopic data;
- ‘data concerning health’ means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;
- ‘main establishment’ means:
- as regards a controller with establishments in more than one Member State, the place of its central administration in the Union, unless the decisions on the purposes and means of the processing of personal data are taken in another establishment of the controller in the Union and the latter establishment has the power to have such decisions implemented, in which case the establishment having taken such decisions is to be considered to be the main establishment.
- as regards a processor with establishments in more than one Member State, the place of its central administration in the Union, or, if the processor has no central administration in the Union, the establishment of the processor in the Union where the main processing activities in the context of the activities of an establishment of the processor take place to the extent that the processor is subject to specific obligations under this regulation;
- ‘representative’ means a natural or legal person established in the Union who, designated by the controller or processor in writing pursuant to Article 27, represents the controller or processor with regard to their respective obligations under this Regulation;
- ‘enterprise’ means a natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in an economic activity;
- ‘group of undertakings’ means a controlling undertaking and its controlled undertakings;
- ‘binding corporate rules’ means personal data protection policies which are adhered to by a controller or processor established on the territory of a Member State for transfers or a set of transfers of personal data to a controller or processor in one or more third countries within a group of undertakings, or group of enterprises engaged in a joint economic activity;
- ‘supervisory authority’ means an independent public authority which is established by a Member State pursuant to Article 51;
- ‘supervisory authority concerned’ means a supervisory authority which is concerned by the processing of personal data because:
- the controller or processor is established on the territory of the Member State of that supervisory authority;
- data subjects residing in the Member State of that supervisory authority are substantially affected or likely to be substantially affected by the processing; or
- a complaint has been lodged with that supervisory authority;
- ‘cross-border processing’ means either:
- processing of personal data which takes place in the context of the activities of establishments in more than one Member State of a controller or processor in the Union where the controller or processor is established in more than one Member State; or
- processing of personal data which takes place in the context of the activities of a single establishment of a controller or processor in the Union but which substantially affects or is likely to substantially affect data subjects in more than one Member State.
- ‘relevant and reasoned objection’ means an objection to a draft decision as to whether there is an infringement of this Regulation, or whether envisaged action in relation to the controller or processor complies with this Regulation, which clearly demonstrates the significance of the risks posed by the draft decision as regards the fundamental rights and freedoms of data subjects and, where applicable, the free flow of personal data within the Union;
- ‘information society service’ means a service as defined in point (b) of Article 1(1) of Directive (EU) 2015/1535of the European Parliament and of the Council (¹);
- ‘international organisation’ means an organisation and its subordinate bodies governed by public international law, or any other body which is set up by, or on the basis of, an agreement between two or more countries.
This privacy statement is relevant for:
- Website visitors;
- Potential customers that we may contact; and
- Existing customers.
Personal Data We Collect
Data when you visit the website
When you visit the website, we automatically collect certain information about your device, including information about your web browser, time zone, and some of the cookies that are installed on your device. This collection of data aims at personalising your experience on the website, improve customer service, respond to queries and emails of our customers and most importantly. It is important to highlight that this information will not otherwise be aggregated in such a way that would enable us to identify any particular user of the system.
We are aware that our company is based outside of the European Economic Area (EEA) and we are offering service to data subjects that are residents in the EEA. Therefore, we are aware of the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation or GP) and we intend to comply in full with it.
We process personal data based on the consent of the data subject itself for a specific purpose to continue discussing when his/her contact details were not directly obtained from the latter, but nevertheless, there was agreement with respect to the continuation of the discussion). This will be performed in accordance with Article 6.1(a) of the GDPR.
Data which was not directly obtained from the customer/potential customer
If this is not the case, we will process the personal data based on Article 6.1(f) of the GDPR as this would be necessary for the purposes of the legitimate interests pursued by us. Hereunder, you may find a breakdown of our balancing test, which would make sure that the interests or fundamental rights and freedoms of the data subjects will not be overridden by our legitimate interests.
Therefore, in the absence of consent from the data subject we will contact, we prospect our clients on the publicly available information on LinkedIn and will always make an attempt to obtain in advance the information from the company, e.g. from the contact form or general e-mail address of the company.
Should this not be the case, we will verify and check the e-mail address via third-party prospecting services, which will guess your e-mail using publicly available information and run it through a verification tool. We have checked that legitimate interests is the most appropriate legal basis to process personal data. We understand our responsibility to protect the individual’s interests. We have conducted a legitimate interests assessment and action and also kept a record of it, in order to ensure that we can justify our decision to contact you directly via e-mail. We have checked that the processing is necessary for us in order to continue our business and gain new clients and there is no less intrusive way or another solution, which would involve disproportionate efforts and costs from us to achieve the same results. Should this not be the case, we will not be able to continue our business and find new clients as traveling to the EU to attend different events or set up meetings would involve disproportionate costs for us. We have done a balancing test and we are confident that the individual’s interests are not overridden by our legitimate interests. What is more, we will not process children’s data. We have considered safeguards to reduce the impact where possible. We have considered whether we can offer an opt-out. Each time we will contact a person via e-mail, we will immediately offer the possibility to opt-out from our communications. Consequently, we will immediately take all necessary steps to delete the data we will have in possession (name and surname, e-mail address, position in a company) with immediate effect.
Once we will obtain your contact details, we will inform you about this processing within 1 month from the date when we have obtained it.
We will not store data which is not necessary for our purposes and will not keep it for longer than it is necessary. Moreover, we will not sell/disclose this data to any other third party processors.
Where processing is based on the data subject’s consent, the controller should be able to demonstrate that the data subject has given consent to the processing operation. 2In particular in the context of a written declaration on another matter, safeguards should ensure that the data subject is aware of the fact that and the extent to which consent is given. 3In accordance with Council Directive 93/13/EEC¹ a declaration of consent pre-formulated by the controller should be provided in an intelligible and easily accessible form, using clear and plain language and it should not contain unfair terms. 4For consent to be informed, the data subject should be aware at least of the identity of the controller and the purposes of the processing for which the personal data are intended. 5Consent should not be regarded as freely given if the data subject has no genuine or free choice or is unable to refuse or withdraw consent without detriment.
In any case, we will be happy to clarify the specific legal basis that applies to the specific case of processing your personal data. As a consequence, you may contact us at the following address: email@example.com .
Sharing Your Personal Information
We will only share personal information with third parties when it is legally permitted to do so. Each time this data will be obtained, it will be via our processors (Close.io, Bitrix24, SalesQL, LeadIq, Scout, Hunter, Gsuit, Lusha, Zapier and Mailgun). When we will share personal data with others, this will only be accomplished under contractual arrangements and security mechanisms put in place intended to protect your personal information and to comply with our data protection, confidentiality and security standards.
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal information such as to check whether we are complying with applicable laws and regulations, to investigate an alleged crime, to establish, exercise or defend legal claims, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with the applicable laws or regulation.
Individuals have certain rights over their personal data and data controllers are responsible to fulfilling these rights.
These requests can be exercised free of charge and you will be informed by us as early as possible and always within one month from the date of your request. Nevertheless, where requests from data subjects are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (i) charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or (ii) refuse to act on request.
Right of Withdrawing Consent
You may always have the right to withdraw the consent where you have previously given us your consent to the processing of your information. You can always do this by sending us an e-mail at: firstname.lastname@example.org If the data/information subject’s consent is given in the context of a written declaration which also concerns other matters, the request for consent shall be presented in a manner which is clearly distinguishable from the other matters, in an intelligible and easily accessible form, using clear and plain language. 2Any part of such a declaration which constitutes an infringement of this Regulation shall not be binding on host.
The data subject shall have the right to withdraw his or her consent at any time. 2The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. 3Prior to giving consent, the data subject shall be informed thereof. 4It shall be as easy to withdraw as to give consent.
When assessing whether consent is freely given, utmost account shall be taken of whether, inter alia, the performance of a contract, including the provision of a service, is conditional on consent to the processing of personal data that is not necessary for the performance of that contract.
Right to Object the Processing of Your Information
As described above, we may also obtain your contact details where these were not directly obtained from you. Should you not agree with our processing, you have the right to object to the processing of your information when the processing is carried out on a legal basis other than consent. You can inform us at: email@example.com
Right of Access
You have the right to obtain from us confirmation as to whether or not personal data concerning you are processed, and, where that is the case, you have the right to request and get access to that personal data in accordance with applicable law. We will aim to respond to any requests for information promptly, and in any event within the legally required time limits (which is currently set for 30 days). You can do this by sending an e-mail to as at: firstname.lastname@example.org
Right of Rectification
You have the right to obtain from us the rectification of inaccurate personal data that was submitted to us and you have the right to provide additional personal data to complete any incomplete personal data. You can do this by sending us an e-mail at: email@example.com
Right to Verify the Accuracy
You have the right to verify the accuracy of your information and ask for it to be updated or corrected at: firstname.lastname@example.org
Right to Erasure
In certain cases, you have the right to obtain from us the erasure of personal data. You can do this by sending us an e-mail at: email@example.com
Right to Fill Out Complaints
You have the right to fill complaints with the applicable data protection authority in your country related to our processing of your personal information.
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us at firstname.lastname@example.org or our representative in the European Union.
Our Representative in the European Union
When a controller based outside of the European Union who provides services to residents in the European Union shall designate in writing a representative in the Union. Thus, the representative is mandated by us to be addressed in addition to or instead of us or the processor, by in particular supervisory authorities and data subjects, on all issues related to processing, for the purposes of ensuring compliance with the GDPR.
The details of our representative in the European Union are available hereunder:
When we did not obtain the contact details directly from a data subject, we will not store the data longer than necessary to fulfil the purposes we collected it for, including for purposes of satisfying any legal, accounting or reporting requirements and obligations that we are subject to.
When we will process personal data that was collected or verified via our third-party processors, we will only keep the data for a limited period of time from the moment we received it.
If there is no reply from our data subject, we will delete the data about him/her within 2 month from the date when we received it or at an earlier date in case the data subject requested so.
If we receive the consent of the data subject, we will keep the personal data for as long as it is necessary to continue the business relationship and in accordance with the necessary applicable legislation to which we are subject to. However, the personal data will not be kept longer than necessary.
We take the security of all data it holds very seriously. We have a framework of policies, procedures and trainings in place covering professional secrecy, data protection, confidentiality, security and regal review of the appropriateness of the measures it has in place to keep the data secure.
We secure information that you provide to us on computer servers in a controlled, secure environment, protected from unauthorised access, use or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorised access, use, modification and disclosure of personal data in its control and custody. However, you must be aware that no data transmission over the Internet or wireless network can be guaranteed.
Therefore, while we strive to protect your personal data, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity and privacy of any and all information and data exchanged between us cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third-party, despite our best efforts. Any part of such a declaration which constitutes an infringement of this Regulation shall not be binding.
We recognise that transparency is an ongoing responsibility so this privacy statement will be kept under regular review. We encourage you to periodically review it in order to stay informed of how we are protecting your information.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e‑mail at email@example.com
Note: As this is temporary version of above document without prejudice. As it may be amended/modified as per the rules of company and laws specified.
SHRMpro Private Limited – India Corporate Office
A-27 B, Sector 16, Noida India – 201301