Privacy Policy

1.0 Introduction

Comviva Technologies Limited (hereafter referred to as “Comviva”, “we”, “our” or “us), is a global leader of mobility solutions. Our extensive portfolio of solutions spans digital financial services, customer value management, messaging and broadband solution, digital lifestyle services and managed VAS services. Our solutions are deployed by over 130 mobile service providers and financial institutions in over 95 countries and enrich the lives of over two billion people to deliver a better future.

Comviva collects information that you provide to us or that we learn about you (a “User”, “you” or ‘your”) from your use of our website(s) including, without limitation, www.comviva.com (the “Site”) as described in this Policy. We are committed to protect any personal information (as described in section 5.1 below) that you provide when you are using the Site, we collect from you when you submit your contact details to receive marketing communications from us, apply for a job at Comviva, or during or after your working relationship with us. It also applies to the information we collect in connection with available employment opportunities at Comviva and for providing details related to our mobility solutions and services on the Site.

We want our services to be safe and secure for our Users. Uniform practices for collecting, using, disclosing, storing, retaining, disposing, accessing, transferring or otherwise processing such information assists Comviva to process Personal Information fairly and appropriately, disclosing it, using it and/or transferring it only under appropriate circumstances.

This Policy tells you how we use your Personal Information collected through the Site. Please read this Policy before using the Site or submitting any Personal Information.

2.0 Purpose

The purpose of this Policy is to highlight various obligations, best practices and tools that support compliance with data privacy regulations applicable to Comviva in its role as a data controller or data processor or a joint controller and your consent for such activities.

Comviva acts as controller or its equivalent when we decide how and why personal data will be used by us. Comviva acts as a processor or its equivalent in the capacity when providing services to a client/customer, we will only use personal data in accordance with specific written instructions from our client. In such areas the client is the data controller or its equivalent for that personal data and will be responsible to data subjects for the way in which their personal data is processed. We will act as joint controller with other organisation when we jointly determine the purposes and means of processing of the data.

3.0 Applicability

This Policy is applicable to this Site and not necessarily to other Comviva sites on the World Wide Web and to all job applicants. When leaving this Site, please read the privacy policy applicable to the site you are visiting. If you do not agree with this Policy, please do not use this Site. The Policy considers the rights and obligations under the data protection laws applicable to the User / if the User is an EU resident, then as set forth in the EU General Data Protection Regulation (Regulation (EU) 2016/679, (“GDPR”).

4.0 Lawful Basis of Processing your Information your Information

Contract: To fulfill our contractual obligations to you.
Consent: We may rely on your freely given, specific, informed and unambiguous consent at the time you provided your Personal Information to us for one or more specific purposes.
Legitimate Interests: 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.
Legal Obligation: To comply with a legal obligation.

5.0 Collection and use of information

5.1 Collection of your information

Comviva collects, processes, and retains information about you when you visit the Site or apply to job with us. You may voluntarily choose to provide us with Personal Information, such as your name, email address, company information, street address, telephone number, or other Personal Information, to access protected information on the Site or so we can follow up with you after your visit.

Personal Information (PI): It is the information that relates to an identified or identifiable person such as name, an identification number, location data etc.

Thus, Personal Information (PI) only includes information relating to natural persons who:

can be identified or who are identifiable, directly from the information
who can be indirectly identified from that information in combination with other information

Personal Information may include, but is not limited to:

Contact information: Full name, physical address, Personal/corporate email address, and telephone numbers
Demographic attributes: Gender, age and date of birth, country of residence, nationality
Employment details and recruitment records: Employment records submitted by you to verify your candidature as an employee or for the future motion, Resume and application form, qualifications, references, background check information, data regarding responses to screening questions, job interview notes, assessment results and reviews on professional and social media.
Full face photos and comparable Image: For onboarding and identity
On the ‘Contact Us’ page: Comviva uses the contact information you submit to enable us to respond to a general or business inquiry made by you, or on behalf of the company that you represent.
Social media widgets: Our Sites and applications may include social media features connected with social media platform such as Facebook, Twitter, Instagram, YouTube, LinkedIn and others. Your interactions with those features are governed by the privacy policies of the companies that provide them.

5.1.1 Children

No information may be submitted to Comviva by persons under the age of 18 (16 for EU Users) (“Children”) without the consent of a parent or legal guardian, nor may children under the age of 18 make purchases or other legal acts on this Site without such consent. Further, the recruitment process is not intended for children under the age of 18 Comviva encourages all parents or guardians to instruct their children in the safe and responsible use of their Personal Information while using the Internet. Comviva will not knowingly collect or use any Personal Information collected from children for any purpose whatsoever.

5.2 How we use your Personal Information

To provide employment related and recruitment services: Employment related: We shall process your personal data for financial, accounting, payroll and compensation, rewards and re-imbursement benefits, succession and resource planning, etc., in relation to employment related services.Recruitment: Setting up a job applicant file in electronic format, managing your application, setting up interviews, conducting assessment, including arranging or reimbursing for your travel; providing accommodations; processing interview feedback; on-boarding; and conducting background checks and screening.
To gather details about prospective employees: Your information helps us to more effectively respond to your requests and queries to make the job application interface user friendly.
To send periodic emails: The email address you provide will be used to send you information and updates pertaining to employment / job openings within Comviva where we have taken explicit consent.
Website Behavioural information: We and our service provider use “cookies” and similar technologies on the Site. For more information and to manage your settings, please see the Comviva Cookie Policy.
Legal Obligation: We may disclose your personal data in response to any notification, order, inquiry, demand, request, or other communication from a law enforcement agency that requires or mandates the disclosure of such personal data, or in accordance with applicable laws.
Obtain Third Party Services: We also share Personal Information with third parties who provide services to Comviva for website management, information technology and related infrastructure provision, e-mail delivery, auditing, and other similar services. When Comviva shares Personal Information with third party service providers, we require that they use your Personal Information to contact you about a Comviva offer in support of your business needs or to conduct online surveys to understand better the Users’ needs and profiles. This is only for the purpose of providing services to us and subject to terms consistent with this Policy.
Select content, improve quality and facilitate use of the other interface channels: Comviva may use your Personal Information to help create and personalize content on our channels, facilitate your use of the channels (for example, to facilitate navigation and the login process, avoid duplicate data entry, enhance security, improve quality, track campaign and survey responsiveness and evaluate page response rates).

5.3 Sources from which we collect your Personal Information (PI)

We mostly collect information directly from you and we may receive some of your personal information from third parties such as Recruitment Agencies, Existing Data-base and Employee reference and publicly available sources, such as LinkedIn, Job Portals.

6.0 Fairness and Purpose

Comviva will collect adequate, relevant and necessary Personal Information, and will process such information fairly and lawfully for the purpose it is collected. The purpose of collection will be specified not later than at the time of data collection, or on each occasion of change of purpose.

7.0 Accuracy of information

The information held by Comviva on the Site shall be checked with you from time to time to ensure that it remains up to date. Should your personal circumstances change, you should notify us and update your details by logging in with your credentials or by writing to us at dpo@comviva.com immediately.

8.0 Distribution of Information

8.1 Information Disclosure

Comviva does not share, sell, rent, or trade Personal Information collected through its Site with third parties for their sole promotional purposes or otherwise than as outlined in this Policy. Comviva may share information with third party service providers contracted to provide services on our behalf for processing to provide your employment related services and benefits and other business purposes. These third-party service providers may only use information we provide to them as requested and instructed by Comviva.

Comviva may disclose your Personal Information as we believe to be necessary or appropriate:
- under applicable law, including laws outside your country of residence;
- to comply with legal process;
- to respond to requests from public and government authorities, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes;
- to enforce our terms and conditions; and
- to allow us to pursue available remedies or limit the damages that we may sustain.
Additionally, in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we may transfer the Personal Information we have collected to the relevant third party. A prominent Policy will appear on our Site for 30 days after any such change in ownership or control of your Personal Information.
We may share information with
(a) governmental agencies or other companies assisting us in fraud prevention or investigation. We may do so when:
- permitted or required by law; or,
- trying to protect against or prevent actual or potential fraud or unauthorized transactions; or,
- investigating fraud which has already taken place. The information is not provided to these companies for marketing purposes, and

(b) external advisors acting as processors (e.g. lawyers, accountants, auditors etc).

8.2 Cross-Border Data Transfers

When conducting business, working on Comviva projects, or implementing new processes or systems, an operation may require the transfer of Personal Information to other Comviva entities or third parties that are located outside of the Comviva operation’s country of business. While permissible data transfer mechanisms are defined by applicable law or regulation, examples include:

A data transfer agreement with the Comviva entity or third party who will access or obtain the Personal Information;
Policy to and/or approval from a country’s local data protection authority; or
Policy to and/or consent from the individual whose data is to be transferred.

9.0 Consent and Control

Consent is an individual’s choice to “opt-in” or “opt-out” of the Company’s use of Personal Information and is usually obtained by a “check box” or signature confirming the individual understands and agrees to the processing of their Personal Information. By clicking on “I agree” , you hereby consent to the following:

Collecting, using, or processing your Personal Information, including sensitive Personal Information, in certain ways or sharing the individual’s Personal Information with any third party;
Transferring your Personal Information outside of your country of residence;
Using or placing web cookies on your computer or other electronic devices.

9.1 Consent

Collecting, using, or processing your Personal Information, including sensitive Personal Information, in certain ways or sharing the individual’s Personal Information with any third party;
Transferring your Personal Information outside of your country of residence;
Using or placing web cookies on your computer or other electronic devices.

9.2 Control of your information

Comviva also provides individuals with the right to control their Personal Information, which includes the right to access, rectify, modify, erase, restrict, transmit, or object to certain uses of their information and right to ask us to provide you your Personal Information which you have provided to us in a structured, commonly used and machine-readable format.

You may request to review, correct, update, suppress, or otherwise modify any of your Personal Information that you have previously provided to us through the Site, or object to the use or processing of such Personal Information by us. You have the ability to update your information at any time. To change this information, please login and go to “update my profile”. If you have questions about your account or are having trouble accessing your account, please contact us at “dpo@comviva.com”.

In your request, please make clear what Personal Information you would like to have changed, or suppressed from our database or what limitations you would like to put on our use of your Personal Information that you have provided to us.

While the majority of questions and issues related to access can be handled quickly, complex requests may take more research and time. In such cases, issues will be addressed, or you will be contacted regarding the nature of the problem and appropriate next steps, within thirty (30) days.

10.0 Data Storage

Your Personal Information will be retained in a form which enables Comviva to identify the individual for no longer than it is necessary for the purposes for which the data was collected and used. Your Personal Information may be retained in certain files for a period of time as required by applicable law and following Comviva’s data retention policies in order to comply with such financial or legal requirements, to properly resolve disputes or to troubleshoot problems. If you wish to cancel your account or request that we no longer use your Personal Information to provide you services, contact us via the information above. We will respond to your request to access or delete your information within thirty (30) days.

Comviva shall retain your Personal information only as long as necessary for the fulfilment of the stated purposes, and shall be disposed thereafter. We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your Personal Information to provide you services, contact us via the mode mentioned in section 9.2 above. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

If your application for employment is successful and you commence employment with Comviva, your personal information may be transferred and processed consistent with Worker Privacy Notice.

If your application for employment is not successful, and depending on local laws, we will generally keep your personal data beyond the end of the application process for the purposes of:

Contacting you for future job vacancies (with explicit consent from you)
To meet recordkeeping requirements, and
For potential use in legal proceedings.

Once your data is no longer required, we will securely destroy your personal data in accordance with the Comviva Personal Data Retention Guideline.

11.0 Commitment to data security

Your Personal Information is kept secure. Only authorized employees, business partners, clients, vendors and other third-party providers (who have agreed to keep information secure and confidential) have access to it.

Comviva ensures that our suppliers employ industry standard security measures to ensure the security of information through legally binding terms and conditions. However, Users of our Site are responsible for maintaining the security of any password, user ID, or other form of authentication involved in obtaining access to password protected or secure areas of any Comviva websites. Access to and use of password protected and/or secure area of the Site is restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution.

12.0 Use of cookies

Cookies are pieces of information stored directly on the computer or mobile device that you are using. Cookies allow us to collect information such as browser type, e-mail address when you are logged-in to your e-mail from the browser you are using, time spent on the online services, pages visited, including the Site, referring URL, language preferences, and other aggregated traffic data.

We collect and store information when you visit the Site, and this may include using cookies or similar technologies to identify your browser or device. We use cookies to collect and store information when you interact with services we offer to our partners. Our analytics product helps to personalize your experience while using the online services. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the online services or to send you advertisements and marketing emails. You can configure your browser to refuse cookies, or to warn you before a cookie is placed. If you disable cookies, some parts of our Site may not function properly or at all.

13.0 Transfers outside EEA. If you are resident of the EU / EEA:

Comviva transfers Users Personal Information outside of the country where the Users are located. Some recipients of their Personal Information are located in another country for which the European Commission has not issued a decision that this country ensures an adequate level of data protection, namely India.

By way of entering into appropriate data transfer agreements based on latest Standard Contractual Clauses (released by European Commission on June 4, 2021) as referred to in Art. 46 (2)(c) EU GDPR or other adequate means, which are accessible by sending a request to dpo@comviva.com, we have established that all other recipients located outside the EEA will provide an adequate level of data protection for the Personal Information and that appropriate technical and organizational security measures are in place to protect Personal Information against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. Any onward transfer (including to our affiliates outside the EEA) is subject to appropriate onward transfer requirements as required by applicable law.

14.0 Revocation Of Consent

Your consent to your Personal Information collection and processing may be revoked subject to applicable law by notifying us via our contact page.

Please note, in case you choose to not provide us with the consent or withdraw the consent at any given point of time, we shall not be able to provide the services as detailed in section 5.2 of this Policy.

15.0 Your rights

The right of access:You have the right to obtain from us confirmation as to whether or not Personal Information concerning you is being processed, and, where that is the case, to request access to the Personal Information. The access information includes – inter alia – the purposes of the processing, the categories of Personal Information concerned, and the recipients or categories of recipients to whom the Personal Information have been or will be disclosed.

- You have the right to obtain a copy of the Personal Information undergoing processing. For additional copies requested by you, we may charge a reasonable fee based on administrative costs.

The right to rectification: You have the right to ask us to rectify any inaccurate Personal Information concerning you.

The right to erasure:You have the right to ask us to erase your Personal Information.

The right to restrict processing:You have the right to request the restriction of processing your Personal Information. In this case, the respective data will be marked and may only be processed by us for certain purposes.

The right to data portability:You have the right to ask us to provide you your Personal Information which you have provided to us in a structured, commonly used and machine-readable format. You also have the right to transmit your Personal Information to another entity without hindrance from us.

The right to object: You also have a right to object to us processing your Personal Information in certain circumstances. However, such a right to object may not exist in certain situations, for e.g. if the processing of your Personal Information is necessary to take steps prior to entering into a contract or to perform a contract already concluded or if the Personal Information is relevant to a legal dispute, then we may not stop processing your Personal Information.

In case of complaints, you also have the right to lodge a complaint with the competent supervisory authority appointed under applicable law, or if you are an EU resident, the member state of your habitual residence for the alleged breach.

16.0 Privacy Contact Information

If you have any questions regarding our Policy or if you need to update, change or remove information, you can do so by contacting us on dpo@comviva.com.

17.0 Changes

Comviva may update this Privacy Policy upon any changes in our information processing practices or to comply with applicable regulations. When updates occur, we will revise the Effective Date at the top of this Policy. You are encouraged to review the Policy whenever you visit the Site to make sure that you understand how any Personal Information you provide will be used.

18.0 DISCLAIMER

Comviva assumes no responsibility or liability for any errors or omissions in the content of this site. This website is provided “as is” and Comviva does not expressly or impliedly warrant, guarantee or make any representations concerning the use, results of use or inability to use or access the information or contents of the Website, in terms of the accuracy, reliability, completeness, functionality, performance, continuity, timeliness or otherwise, fitness for a particular purpose and/or non-infringement

This web site may be accessed from third party links over which Comviva has no control. Comviva does not make any warranties or representations of any kind as to the accuracy, currency, or completeness of any information contained in those third-party and external sites and shall have no liability for any damages or injuries of any kind arising from such content or information.