Privacy Policy

  1. Introduction.

NeuralWaves Systems Private Limited (“the Company“, “We“, “Us” or “Our“) is committed to protecting your Personal Data (defined below). This Privacy Policy sets out the policies and procedures through which We collect, use, disclose, transfer, and store your Personal Data. Please read this software as a service (“Privacy Policy”) carefully before using this software, namely LEGO SAPIEN created, developed by NEURALWAVES [“licensor” or “Provider” or “the Company“].

We will only collect and use your Personal Data in accordance with the Information Technology Act, 2000 (“IT Act”) read with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”), or the Digital Personal Data Protection Act, 2023 (as and when different provisions come into force from time to time) as amended or updated from time to time (and any other such laws that may be enacted in India related to the governance of personal data from time to time) as well as this Privacy Policy and such other term(s) in the agreement(s) that You may contract with Us or have contracted with Us.

This Privacy Policy sets out the types of Data (defined below) including Personal Data that we collect from you through the Website (defined below), as well as the manner in which We collect, use, disclose, transfer to third parties, store and protect your Personal Data. This Privacy Policy also identifies the rights and options available to You with respect to your Personal Data and the manner in which You may reach out to Us should You have any concerns or queries regarding this Privacy Policy.

We are committed to protecting your Personal Data through Reasonable Security Practices and Procedures (defined below) in accordance with Applicable Laws (defined below). Should You choose to not provide Us with the requested Personal Data, We may be unable to offer You the Services (defined below).

You are advised to carefully read the Privacy Policy before using the Website / Services or any other platform, application or channels for communicating with Us or sharing any Data including Personal Data with Us. We shall not be liable / responsible for any breach of privacy owing to your negligence. Please note that the Website and other digital platforms may contain links to third party applications / digital platforms which are provided for your convenience. We are only responsible for the privacy practices and security of the Website. We recommend that You check the privacy and security policies and procedures of each and every other application / digital platform that You visit.

All capitalized terms not defined in the Privacy Policy shall have the meanings ascribed to them in the Terms and Conditions of the Website, which can be accessed here.

 

2. Definitions.

Capitalised terms not defined in the Terms shall mean as follows:

      • ‘Account’ means a unique account created for You to access our Service or parts of the Service.
      • ‘Affiliate’ means an entity that controls, is controlled by or is under common control with a party, where ‘control’ means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority. Affiliates for the purpose of this Privacy Policy include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
      • ‘Applicable Laws’ mean all provisions of laws, statutes, ordinances, rules, regulations, permits, certificates, judgments, decisions, decrees or orders of any governmental authority applicable to a natural person and includes the Information Technology Act 2000, Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011, and the Digital Personal Data Protection Act 2023 (as and when different provisions come into force from time to time), as amended from time to time.
      • ‘Data’ means and includes a representation of information, knowledge, facts, concepts or instructions which are being prepared or have been prepared in a formalized manner, uploaded to or stored on the Platform by the Customer and is intended to be processed, is being processed or has been processed in a computer system or computer network, and may be in any form (including computer printouts, magnetic or optical storage media, punched cards, punched tapes) or stored internally in the memory of the computer.
      • ‘Company’ (referred to as either “the Company“, “We“, “Us” or “Our” in this Privacy Policy) means NeuralWaves Systems Private Limited, Pune, India.
      • ‘Cookies’ mean small files that are placed on your Device containing the details of your browsing history on the Website among its many uses, which allows a website or application to remember your actions or preferences for a certain period of time.
      • ‘Country’ means Maharashtra, India.
      • ‘Device’ means any device that can access the Service such as a computer, a cellphone or a digital tablet.
      • ‘Personal Data’ means any information that relates directly or indirectly to an identified or identifiable individual/Candidate who gives Interview on Platform.
      • ‘Reasonable Security Practices and Procedures’ means security practices and procedures designed to protect such information from unauthorized access, damage, use, modification, disclosure or impairment, as may be specified in an agreement between the parties or as may be specified in any law for the time being in force and in the absence of such agreement or any law, such reasonable security practices and procedures, as may be prescribed by the Central Government in consultation with such professional bodies or associations as it may deem fit.
      • ‘Service’ means the Website owned and operated by the Company.
      • ‘Service Provider’ means any natural or legal person who processes Data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used.
      • ‘Usage Data’ means the Data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
      • ‘Website’ means LegoSapien, accessible from https://neuralwavesystems.com OR <https://legosapien.com/>.
      • ‘You’ means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. All references to ‘You’ shall include yourself and any other persons You are authorised to and required to provide consent for.

3. Collecting and using your Personal Data.

3.1 Types of Data collected.

3.1.1 Personal Data.

While using Our Service, We may ask You to provide Us with certain Personal Data that can be used to contact or identify You. Personal Data may include, but is not limited to:

(i) Personal information such as your email address, first name and last name, phone number, date of birth, nationality;

                • Candidates (Potential candidates or employees taking the assessment) Photos and Videos from proctored tests:  for candidates taking proctored tests, periodic webcam snapshots are taken which usually contain a photo of your face.
                • Technical information:  including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

(ii) Device information such as device hardware information, device model and software version, App version, mobile country code and network code, device operating system versions, phone number and your device setting in accessing the Website;

(iii) Usage Data (as detailed further below);

(iv) Any other Personal Data not mentioned herein that You provide to Us or collected by Us in the course of your dealing with Us and/or where we require You to provide other Personal Data depending on the nature of Our business and its circumstances, the nature of your transaction and so forth; and

(v) Where You are a company, We may collect Personal Data of your employees. For the avoidance of doubt, You shall obtain the consent of the employees before providing Us with employees’ Personal Data.

3.1.2 Usage Data.

(i) Usage Data is collected automatically when using the Service.

(ii) Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

(iii) When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

(iv) We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

(v) A processor processes personal information on behalf of a controller based on the controller’s instructions. When NEURALWAVES processes your Customer Account Data, the NEURALWAVES entity with whom you are contracting is acting as a controller. When we process the information on your behalf (employee and candidate data), you are the controller and NEURALWAVES is the processor.

(vi)We use Customer Account Data to further our legitimate interests to: 

                • Understand who our customers and potential customers are and their interests in NEURALWAVES product and services,
                • Fulfil our contractual obligations to the Customer
                • Manage our relationship with you and other customers,
                • Carry out core business operations such as accounting, filing taxes, and fulfilling regulatory obligations and
                • Help detect, prevent, or investigate security incidents, fraud and other abuse and/or misuse of our products and services.

 

4. Tracking technologies and Cookies.

4.1 We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

        • Cookies or browser Cookies. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
        • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
        • Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your Device when You go offline, while Session Cookies are deleted as soon as You close your web browser. You can learn more about Cookies on [TermsFeedwebsite](https://www.termsfeed.com/blog/cookies/#What_Are_Cookies).

4.2 We use both Session and Persistent Cookies for the purposes set out below:

        • Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with Services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the Services that You have asked for cannot be provided, and We only use these Cookies to provide You with those Services.

        • Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of Cookies on the Website.

        • Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow Us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

4.3 For more information about the Cookies We use and your choices regarding Cookies, please visit our Cookies Policy.

 

5. Use of your Personal Data.

5.1 The Company may use Personal Data for the following purposes:

        • To provide and maintain our Service, including to monitor the usage of our Service.
        • To manage your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
        • For the performance of a contract, which includes the development, compliance and undertaking of the purchase contract for the products, items or Services You have purchased or of any other contract with Us through the Service.
        • To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
        • To provide You with news, special offers and general information about other goods, services and events which We offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information.
        • To manage Your requests: To attend and manage Your requests to Us.
        • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
        • For other purposes: We may use Your information for other purposes, such  as data analysis, identifying usage trends, determining the effectiveness of Our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
        • We may share your Personal Data in the following situations:

(i) For business transfers: We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

(ii) With Our group entities and Affiliates: We may share Your Personal Data with Our group entities and Affiliates, in which case We will require such group entities and Affiliates to honor this Privacy Policy.

(iii) With business partners: We may share Your Personal Data with Our business partners to offer You certain products, services or promotions.

(iv) With your consent: We may disclose your Data for any other purpose with your prior consent.

5.2 Retention of your Personal Data.

        • The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.
        • The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this Data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this Data for longer time periods.

5.3 Transfer of your Personal Data.

        • Your Data, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this Data may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
        • Your consent to this Privacy Policy followed by your submission of such Data represents your agreement to such transfer(s) of your Data (including Personal Data).
        • The Company will take all steps reasonably necessary to ensure that your Data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your Data including Personal Data.
        • The Company shall undertake all Reasonable Security Practices and Procedures prescribed under Applicable Laws to ensure that the confidentiality of your information (including your Personal Data) is maintained by third parties to whom it discloses such information.
        • The Company may be required to disclose your Personal Data to statutory authorities or other persons in connection with any legal process that may be initiated by such authorities in accordance with Applicable Laws, or for any risk mitigations purposes undertaken by us. However, this does not include selling or otherwise disclosing your Personal Data for commercial purposes in violation of this Privacy Policy and Applicable Laws.

5.4 Delete your Personal Data.

        • You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.
        • Our Service may give You the ability to delete certain Data about You from within the Service.
        • You may update, amend, or delete Your Personal Data at any time by signing in to your account, if you have one, and visiting the account settings section that allows You to manage Your Personal Data . You may also contact Us to request access to, correct, or delete any Personal Data that You have provided to Us.
        • Please note, however, that We may need to retain certain Personal Data when We have a legal obligation or lawful basis to do so.

5.5 Disclosure of your Personal Data.

        • Business Transactions

If the Company is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different privacy policy.

        • Law enforcement

Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

        • Other legal requirements

The Company may disclose your Personal Data in the good faith belief that such action is necessary to:

(i) Comply with a legal obligation;

(ii) Protect and defend the rights or property of the Company;

(iii) Prevent or investigate possible wrongdoing in connection with the Service;

(iv) Protect the personal safety of users of the Service or the public; or

(v) Protect against legal liability.

6. Consent for collection and usage of Personal Data.

      • The Company only collects Data (including Personal Data) from You in accordance with the explicit consents obtained from You and after informing You about the consequences of refusing to provide Data or withdrawing consent for the identified purpose.
      • The Company maintains an auditable record of such consents granted, modified or withdrawn.
      • All Data provided by You (including Personal Data) is purely voluntary.
      • You may also withdraw or modify your consent to collect / provide / share / process the Data (including your Personal Data) by communicating to the email ID given below in writing. However, in such instance, (i) You may not be able to access some or all of the features or pages of Website; (ii) You may not be able to avail some or all of Our Services; or (iii) if You have already availed Our Services, such Services may be withdrawn, curtailed or cancelled as per the terms thereof upon such withdrawal or modification of consent.
      • In some cases, it is essential for the Data (including Personal Data) to be collected / retained / stored / processed / shared either regulatorily, or as a matter of policy or for any of the purposes above and You are requested not to avail the Services if You do not wish to provide such Data or provide consent to collect / share / process the same. For any queries in this regard, You may contact the email IDs mentioned at the end of this Privacy Policy.
      • The Company ensures that an appropriate data privacy commitment is provided to You and your express consent for seeking, collecting, storing, utilizing and sharing Personal Data is obtained at the time of or before collecting Personal Data including any sensitive Personal Data either by the terms of this Privacy Policy or otherwise through the Website.
      • All Data collected is stored in secure databases protected via a variety of access controls and is treated as confidential information by the Company. You should be careful with usage of your username and password by maintaining confidentiality and ensure that You do not knowingly or accidentally share, provide and facilitate unauthorized use of the same.
      • We may also obtain your Data from independent third parties, as governed by their respective privacy policies, including our Service Providers.

7. Storage of Personal Data.

      • The Personal Data collected from You is stored at Our backend servers and cloud servers situated in India and other jurisdictions.
      • We shall only collect the above-mentioned information on a need basis strictly for the purpose of providing You the Services.
      • Where required by Applicable Law, We may store your Data including Personal Data after the identified purpose for which your Data has been collected is fulfilled.

8. Security of Your Personal Data.

The security of your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect your Personal Data, We cannot guarantee its absolute security.

9. Children’s privacy.

      • Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18.
      • If You are a parent or guardian and You are aware that your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.
      • If We need to rely on consent as a legal basis for processing your Personal Data and your country requires consent from a parent, We may require your parent’s consent before We collect and use that Personal Data.

10. Links to other websites.

      • Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.
      • We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

11. Changes to this Privacy Policy.

      • We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
      • We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.
      • You are advised to review this Privacy Policy periodically for any changes.
      • Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us 

If you have any questions about this Privacy Policy, You can contact us by visiting this page on Our Website: [https://neuralwavesystems.com/PrivacyPolicy](https://neuralwavesystems.com/Privacy Policy)

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