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 1. Home
 2. Online Privacy Policy


ONLINE PRIVACY POLICY

The following information is provided to you to inform you of Sodexo SVC India
Private Limited commitments in terms of Personal data protection. Pluxee India
Private Limited (Formerly known as Sodexo SVC India Private Limited) belongs to
Pluxee Group (herein after referred as “Pluxee”).

Pluxee builds strong, lasting relationships with its customers, partners and
consumers based on mutual trust: making sure that their Personal data is safe
and remains confidential is an absolute priority for Pluxee.

Pluxee is committed to comply with all applicable regulatory and legal
provisions governing the Protection of Personal data.

Pluxee enforces a very strict privacy policy to guarantee the protection of the
Personal data of those who use its websites, portals, applications, and
platforms (our “Sites”):

 * Users remain in control of their own data. The data is processed in a
   transparent, confidential, and secure manner.
 * Pluxee is committed to a continuing quest to protect its users’ Personal data
   in accordance with the Information Technology Act, 2000, The Information
   Technology (Reasonable security practices and procedures and sensitive
   personal data or information) Rules, 2011 and all the applicable laws as may
   be notified by the government from time to time.
 * Pluxee has a Global Data Protection Office dedicated to data protection,
   supported by a network of local data protection single points of contact or
   data protection officers.


PURPOSE OF THIS POLICY

Pluxee takes the protection of your personal data very seriously.

We have developed this policy to inform you of the conditions under which we
collect, process, use and protect your Personal data on our Sites and in the
context of the services provided by Pluxee India Private Limited (Formerly known
as Sodexo SVC India Private Limited) (the “Services”). This policy covers all
users, including those who use the Site and the Services without being
registered or subscribing to a specific service or account (hereinafter
collectively, the “Users”).

Please read it carefully to familiarize yourself with the categories of Personal
data that are subject to collection and processing, how we use this Personal
data and with whom we are likely to share it. This policy also describes your
rights and how you can get in touch with us to exercise these rights or to ask
us any questions you might have concerning the protection of your Personal data.

This policy may be amended, supplemented, or updated, in particular to comply
with any legal, regulatory, case law or technical developments that may arise.
However, your Personal data will always be processed in accordance with the
policy in force at the time of the data collection, unless a compulsory legal
prescription determines otherwise and must be enforced retroactively.


IDENTITY AND CONTACT DETAILS OF THE CONTROLLER

The data Controller is Pluxee India Private Limited (Formerly known as Sodexo
SVC India Private Limited) is a Private Limited Company registered under the
Companies Act, 1956 with its CIN No U74140MH2008FTC182494 and having its
registered office at B Wing, 503/ 504, Hiranandani Fulcrum, Sahar Road, Andheri
(East), Mumbai – 400 092


DEFINITIONS

“Account” The User’s dedicated personal area within the Site, which he or she
accesses when he or she registers and connects to the Site. It enables the User
to access the Services. “Controller” The Pluxee entity which, alone or jointly
with other Pluxee entities or third parties (i.e., its processor Zeta)
determines the purposes and means of the processing of personal data. “Cookies”
As defined in the Cookie Policy “Personal data” Means any information relating
to an identified natural person or one that can be directly or indirectly
identified by reference to an identification number or to one or more factors
specific to this person. “Processing” 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, organization, structuring,
storage, adaptation or alteration, retrieval, consultation, use, disclosure by
transmission, dissemination or otherwise making available, alignment or
combination, restriction, erasure or destruction. “Processor” A legal person
which processes personal data on behalf of the controller. “Site” The website of
Sodexo SVC India Pvt. Ltd available at the address www.pluxeegroup.in “us” “we”
or “our” Pluxee India Private Limited (Formerly known as Sodexo SVC India
Private Limited) (hereinafter Pluxee”), acting as controller “you” or “Users”
Any Site user/visitor.

 


COLLECTION AND SOURCE OF PERSONAL DATA

We will most likely collect your Personal data directly (in particular via the
data collection forms on our Site) or indirectly via our service providers
and/or technologies on our Site.

We undertake to obtain your consent and/or to allow you to refuse the use of
your data for certain purposes whenever necessary.

You will in any event be informed of the purposes for which your data is
collected via the various online data collection forms and via the Cookie Policy


TYPES OF PERSONAL DATA COLLECTED AND USED BY US

We may specifically collect and process the following types of personal data: 

 * the information that you provide when filling in the forms on the Site (for
   example, for subscription purposes, to participate in surveys, for marketing
   purposes, when downloading the application, etc.) the information that you
   provide for authentication purposes; 
 * the information that you provide for order fulfillment or to provide a
   service 
 * to provide issuance of pre-paid cards, activating consumer cards and approval
   of KYC 
 * the data relating to your purchases such as products, quantity, price,
   billing and delivery about you only where you volunteer and consent to this; 
 * the transaction data such as payment information and credit/debit card
   information that is transmitted directly to third parties who process your
   requests; the information provided via “posts”, comments or other content
   that you post on the website .the information from you when you use the chat
   function on our Sites. 
 * the information you provide for the purposes of managing your job application
   and, where applicable, your recruitment process (e.g.: CV, information
   relating to your education, your professional experience, awards, diplomas,
   certificates, attestations, languages spoken, salary expectations, etc.); 
 * your preferences in receiving marketing from us and our third parties and
   your communication preferences 
 * information collected through Cookies as defined in our Cookie Policy. 

Personal data identified by an asterisk in the data collection forms are
compulsory as these are necessary to fulfill any orders placed. In the absence
of this compulsory information, these transactions cannot be processed.

Please find details of the different data collected for the various purposes in
the chart (Annex 1).


PERSONAL DATA THAT WE AUTOMATICALLY COLLECT

Personal data may be collected for the following general purposes (a more
precise description of the processing of your data can be found in the Annex
1 below): 

 * Cookies
 * Account creation and management
 * Customer Relationship Management
 * Marketing Management
 * Recruitment
 * Complying with statutory requirement
 * Other legitimate purpose as may be required

In addition, please note that you have the option to click on the dedicated
icons of social networks such as Twitter, Facebook, LinkedIn, etc. that appear
on our Sites.

When you click on these icons, we may have access to the Personal data that you
have made public and accessible via your profiles on the social networks in
question. We neither create nor use any separate databases from these social
networks based on the Personal data that you have published there, and we do not
process any Personal data relating to your private life through these means.

If you do not want us to have access to your Personal data published in the
public spaces of your profile or your social accounts, then you should use the
procedures provided by the social networks in question to limit access to this
information.

These links to other websites should not be considered as navigation tracking
and we decline any responsibility concerning the Personal data protection
practices implemented by these third-party companies, each of which acts as a
separate Controller of your Personal data on their own perimeter. Once you leave
our Site or click on the logo/link to one of these social networks, it is your
responsibility to check the privacy policy applicable to that other platform.


LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA 

We process your Personal data as part of the performance and management of our
contractual relationship with you, in our legitimate interest to improve the
quality and operational excellence of the Services we offer to you or in
compliance with certain regulatory obligations depending on the purpose of
processing as identified in the chart in Annex 1.

Your Personal data may also be processed based on your prior consent in the
event that under certain circumstances, your consent would be requested (e.g
regarding health data or for certain types of Cookies).

Please find more information about the legal basis for each of our processing in
the Annex 1 below.


DISCLOSURE OF PERSONAL DATA

The security and confidentiality of your Personal data is of great importance to
us. This is why we restrict access to your Personal data only to members of our
staff only to the extent strictly necessary to process your orders or to provide
the requested Services. We ensure that persons authorized to process the
Personal data have committed themselves to confidentiality or are under an
appropriate statutory obligation of confidentiality.

We will not disclose your Personal data to any unauthorized third parties. We
may, however, share your Personal data with entities within Pluxee and with
authorized service providers (for example: technical service providers [hosting,
maintenance], consultants, etc.) whom we may call upon for the purpose of
providing our Services.

We ensure that every disclosure of your Personal data to an authorized service
provider is framed by a data processing agreement, reflecting the commitments
laid out in this policy. We do not authorize our service providers to use or
disclose your data, except to the extent necessary to deliver the Services on
our behalf or to comply with legal obligations. Furthermore, we may share your
Personal data (i) if the law or a legal procedure requires us to do so, (ii) in
response to a request by public authorities or other officials or (iii) if we
are of the opinion that transferring these data is necessary or appropriate to
prevent any physical harm or financial loss or in respect of an investigation
concerning a suspected or proven unlawful activity.


STORAGE PERIOD OF YOUR PERSONAL DATA 

We will store your Personal data only for as long as necessary to fulfill the
purposes for which it was collected and processed. This period may be extended,
if applicable, for any amount of time prescribed by any legal or regulatory
provisions that may apply. To determine the retention period of your Personal
data, we take into consideration several criteria such as: 

 * The purpose for which we hold your Personal data (e.g., when you purchase
   products on our Sites, we keep your Personal data for the duration of our
   contractual relationship); 
 * Our legal and regulatory obligations in relation to that Personal data (e.g.,
   accounting reporting obligations); 
 * Whether you are an active user of our Services, you continue to receive
   marketing communications, or you regularly browse or purchase off our Sites
   or whether you do not open our emails or visit our Sites; For instance, if
   you have agreed to receive marketing communications, we keep your Personal
   data until you: 
   * (i) unsubscribe from receiving marketing communications 
   * (ii) request we delete your Personal data, or 
   * (iii) after a period of inactivity (i.e. where you have not interacted with
     us for a period of time). This period is defined in accordance with local
     regulations and guidance. 
 * Any specific requests from you in relation to the deletion of your Personal
   data or Account. 
 * Any statutory limitation periods allowing us to manage our own rights, for
   example the defence of any legal claims in case of litigation; and 
 * Any local regulations or guidance (e.g., regarding cookies).

Please find more information about the storage period of your Personal data
in Annex 1 below


SENSITIVE PERSONAL DATA

As a general rule, we do not collect sensitive Personal data via our Sites.
“Sensitive Personal data” refers to any information concerning a person’s racial
or ethnic origins, political opinions, religious or philosophical beliefs, union
membership, health data or data relating to the sexual life or the sexual
orientation of a natural person. This definition also includes personal data
relating to criminal convictions and offenses.

In the event that it would be strictly necessary to collect such data to achieve
the purpose for which the processing is performed, we will do so in accordance
with local legal requirements for the protection of Personal data and, in
particular, with your explicit prior consent and under the conditions described
in this policy.


PERSONAL INFORMATION AND CHILDREN

Our Site is for use by adult persons who have the capacity to conclude a
contract under the legislation of the country in which they are located.

Children users under the age of [18 years or without legal capacity must obtain
consent from their legal guardians prior to submitting their Personal data to
the Site.


TRANSFER OF PERSONAL DATA 

In compliance with the Data protection regulation described above, there is no
transfer of personal data outside of India.

In case, a transfer outside of India is necessary, Pluxee will perform it in
compliance with the Data protection regulation described above and will take all
necessary measures to ensure that this data receives adequate protection.


YOUR RIGHTS

Pluxee is committed to ensure protection of your rights under applicable laws.
You will find below a table summarizing your different rights:

Right of access and rectification You can request a copy of the Personal data we
hold about you. You may also request rectification of inaccurate Personal data,
or to have incomplete Personal data completed. Right to erasure

Your right to be forgotten entitles you to request the erasure of your Personal
Data in cases where: 

 1. the data is no longer necessary for the purpose for which it was collected,
    unless required to be retained from statutory perspective;
 2. you choose to withdraw your consent; 
 3. you object to the processing of your Personal data; 
 4. your Personal data has been unlawfully processed; 
 5. there is a legal obligation to erase your Personal data;
 6. erasure is required to ensure compliance with applicable laws.

Right to restriction of Processing

You may request that processing of your Personal Data be restricted in the cases
where:

 1. you contest the accuracy of your Personal data;
 2. Pluxee no longer needs your Personal data for the purposes of the
    processing;
 3. you have objected to processing for legitimate reasons. the processing of
    your Personal data is unlawful and you prefer the restriction of their use
    instead of their deletion

Right to data portability

You can request, where applicable, the portability of your Personal data that
you have provided to Pluxee, in a structured, commonly used, and
machine-readable format you have the right to transmit this data to another
Controller without hindrance from Pluxee where: 

 * the processing of your Personal data is based on consent or on a contract;
   and 
 * the processing is carried out by automated means. 

You can also request that your Personal data be transmitted to a third party of
your choice (where technically feasible).

Right to object to Processing  You may object (i.e. exercise your right to
“opt-out”) to the processing of your Personal data particularly in relation to
profiling or to marketing communications. When we process your Personal data on
the basis of your consent, you can withdraw your consent at any time. Right not
to be subject to automated decisions You have the right not to be subject to a
decision based solely on automated processing, including profiling, which has a
legal affect upon you or significantly affects you. Right to lodge a Complaint 
You can choose to lodge a Complaint with the Data Protection Supervisory
Authority in the country of your habitual residence, place of work or place of
the alleged infringement, regardless of whether you have suffered damages. You
have also the right to lodge your Complaint before the courts where [the Pluxee
entity] has an establishment or where you have your habitual residence.

You may, at any time, exercise any of the above rights or contact us with any
data protection related queries or concerns by completing the request form and
sending it to dpo.brs.in@sodexo.com as indicated in the privacy notices and/or
the privacy policies provided to you at the time of the collection of your
Personal Data or sending it to the local Data Protection Single Point of Contact
at 022 -4321 4321; or,  by completing and submitting the dedicated request
webform.

 For more details, please consult the Local Data Protection Rights Management
Policy 


SECURITY

We implement all possible technical and organizational security measures to
ensure security and confidentiality in processing your Personal data.

To this end, we take all necessary precautions given the nature of the Personal
data and the risks related to its processing, in order to maintain data security
and in particular to prevent distortion, damage or unauthorized third-party
access (physical protection of the premises, authentication procedures with
personal, secured access via identifiers and confidential passwords, a
connection log, encryption of certain data, etc.).

In addition, if we contract with Processors for all or part of the Processing of
your Personal data, we require a contractual agreement from our service
providers to guarantee the security and confidentiality of the Personal data
that we transmit to them or that they collect on our behalf, in accordance with
the applicable regulations on the protection of Personal data.

We regularly conduct audits to verify the proper operational application of the
rules relating to the security of your Personal data.

Nevertheless, you also have a responsibility to ensure the security and
confidentiality of your Personal data so we invite you to remain vigilant,
especially when using an open system such as the Internet.


LINKS TO OTHER SITES

Occasionally, we provide links to other platforms for practical and informative
purposes. These platforms operate independently from our Sites and are not under
our control. These platforms have their own privacy policy or terms of use which
we strongly advise you to read. We do not accept any liability with regards to
the content on these platforms, for the products and services that may be
offered there or for any other use thereof.


UPDATES OF OUR ONLINE PRIVACY POLICY

We may update or amend this policy as and when needed. In this case, amendments
will only become applicable after a period of 30 business days from the date of
the amendment. Please consult this page from time to time if you want to be
informed of any possible changes.


UNSUBSCRIBING

If you have subscribed to certain services via our Site and you no longer want
to receive emails, please consult the “unsubscribe” page corresponding to the
Service you are subscribed to.


HOW TO CONTACT US

If you have any questions or comments with regard to this policy, please do not
hesitate to contact us at the following address dpo.brs.in@sodexo.com.

Last updated: 20th June 2022

Annex 1:

INFORMATION ABOUT THE PROCESSING OF YOUR PERSONAL DATA

General purpose Purpose of the Processing Personal data collected Legal basis of
the Processing Retention of the Personal data Website and application management
For more information on the processing of your Personal data in the specific
context of Cookies we invite you to consult our Cookie Policy Account creation
and Management Send an initial communication via email to invite you to register
and use our Sites and Services

Name

Email

In order to take steps at the request of the data subject prior to entering into
a contract Consent

If you are one of our customers, these communications may be sent to you for the
duration of our commercial relationship, then for ten (10) years after the end
of this relationship or of the last contact you initiated.  

If you are not yet sure whether you want to benefit from our products and
Services, and you are still in the prospecting phase, we can send you
communications on our offers and products for a period of three (3) years from
the last contact you initiated.

Register you as a user and create an account for you on our Site

Name 

Email ID 

user and Password 

KYC details 

Mobile No

Performance of a contract to which the data subject is party We will keep your
Personal data in your customer account (s) until you delete your account.
Customer Relationship Management Manage and monitor our relationships with
existing and potential customers

Name

Email

Contract and legitimate interest

We will keep your Personal data for the duration of our commercial relationship
and thereafter for a period of 10 years as required by our regulator RBI under
Payment and Settlement Systems Act, 2007, after which only the data necessary
for pre-litigation or litigation purposes will be archived until the legal
prescription is acquired.

The usual limitation period in civil and commercial matters is three (3) years.
In the event of a dispute, this data is kept for the duration of the procedure
and until the expiration of ordinary and extraordinary remedies.

Respond to your requests for information, searches, newsletter and other
content.

Name

 Email

Legitimate interest and consent We will send you our newsletter until you
unsubscribe. Access whether you are eligible for certain products and Services

Name

Email

Age

Contract Legitimate interest We will keep your Personal data for the period
necessary to carry out those checks Process and deliver your order

Name

Email 

Information on your order

Contract

We will keep your Personal data for the duration of our commercial relationship
and thereafter for a period of 10 years as required by our regulator RBI under
Payment and Settlement Systems Act, 2007,, after which only the data necessary
for pre-litigation or litigation purposes will be archived until the legal
prescription is acquired.

The usual limitation period in civil and commercial matters is Three (3) years.
In the event of a dispute, this data is kept for the duration of the procedure
and until the expiration of ordinary and extraordinary remedies.

Comply with legal obligations   Legal obligations We will keep your Personal
data for the duration of the procedure, plus the period of acquisition of legal
requirements. If there is statutory requirement, we will retain your data as may
be required to comply the laws of land. The usual limitation period in civil and
commercial matters is three (3) years from the end of the contract. Marketing
Management Conduct surveys and gather statistics

Name

Email

Legitimate interest We will keep your data for a period of three (3) years from
the last contact you initiated Manage, organize and improve of the competitions
and related promotional operations

Name

Email

Consent Consent We will keep your data for a period of three (3) years after the
end of the competition or the draw. Send commercial communications about
products and services that may be of interest to you

Name

Email

Mobile No

Consent

If you are one of our customers, these communications may be sent to you for the
duration of our commercial relationship, then for three (3) years after the end
of this relationship or of the last contact you initiated.

If you are not yet sure whether you want to benefit from our products and
services, and you are still in the prospecting phase, we can send you
communications on our offers and products for a period of three (3) years from
the last contact you initiated.

Profile your Personal data to use internally to help us understand your
motivations, values and needs   Consent Legitimate interest If you are one of
our customers, these communications may be sent to you for the duration of our
commercial relationship, then for three (3) years after the end of this
relationship or of the last contact you initiated.   If you are not yet sure
whether you want to benefit from our products and services, and you are still in
the prospecting phase, we can send you communications on our offers and products
for a period of three (3) years from the last contact you initiated. Recruitment
Assess your skills, qualifications, and suitability for the role,   In order to
take steps at the request of the data subject prior to entering into a contract
We will keep your data for a period of two (2) years after we received your job
application Carry out background and reference checks   Legitimate interest We
will keep your data for the period necessary to carry out those checks

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