Privacy Notice

WHAT IS THE PURPOSE OF THIS DOCUMENT

TCS (“TCS” or “we”) is committed to protecting the privacy and security of your personal data.

This privacy notice describes how we collect and use personal data about you during and after the Contest in accordance with the applicable data privacy regulation(s).

TCS is a “Data Controller” for the scope and context set in this document. This means that we are responsible for deciding and notifying you about how we hold and use personal data about you

This notice is meant for individuals who participate in the Contest.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are aware of how and why we are using such information

DATA PROTECTION PRINCIPLES

We comply with all applicable data protection laws. This means that the personal data we hold about you is:

1. Used lawfully, fairly and in a transparent way.

2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

3. Accurate and kept up to date with best of our knowledge and informed by/to you.

4. Kept only as long as necessary for the purposes we have told you about

5. Kept securely

THE KIND OF INFORMATION WE HOLD ABOUT YOU

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (aka anonymous data).

We will collect, store, and use the following categories of personal data about you:

• Email address
• Participant's name
• Image, photographs
• Audio-visual footage
• Location
• Biographical details
• Universally Unique Identifier
• IP Address

We do not process any “special categories“ of more sensitive personal data

HOW IS YOUR PERSONAL DATA COLLECTED

We collect personal data about Participants through their Site interactions for e.g. through Registration workflows and other Contest related activites

HOW WE WILL USE INFORMATION ABOUT YOU

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

1. Where we need to perform the contract we have entered into with you.

2. Where we need to comply with a legal obligation

3. 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.

We may also use your personal data in the following situations, which are likely to be rare:

1. Where we need to protect your interests (or someone else's interests).

2. Where it is needed in the public interest or for official purposes.

Situations in which we will use your personal data

We need all the categories of information in the list above primarily to allow us to administer and manage the Contest in which you have chosen to participate and to enable us to comply with legal obligations. In some cases we may use your personal data to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal data are listed below

• To process Participant's registration and manage Participant's participation in the Contest.

• For Contest administration and prize/award/reward distribution

• To create and maintain Participants' profiles in TCS' system database for internal records and other necessary reference

• To understand and study the profile of the Participants for further competitions

• To generate publicity materials for TCS events and programs

• To attribute Participants as the inventors/authors of the invention/work that was created for the purposes of the Challenges, and/or

• To administer the assignment and protection of the rights in the Submission

• To contact participant by email and for any other purpose reasonably related to the aforesaid (collectively, the “Purposes”).

If you fail to provide personal data

If you fail to provide certain information when requested, we shall not be able to serve the purpose(s) for which we process your personal data, or we may be prevented from complying with our legal obligations also

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Do we need your consent?

By participating in the Contest, you consent to TCS' collection, use, processing, and disclosure of your personal data for the purposes mentioned herein. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need its, so that you can carefully consider whether you wish to consent.

AUTOMATED DECISION-MAKING

Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

1. Where it is necessary to administer and manage the Contest and appropriate measures are in place to safeguard your rights

2. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal data, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you. We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

DATA SHARING

We may need to share your personal data with regulators or to otherwise comply with the law. We may transfer your personal data outside your country. If we do so, you can expect a similar degree of protection in respect of your personal data

Why might you share my personal data with third parties?

We will share your personal data with third parties where required by law, where it is necessary to administer the relationship with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal data?

“Third parties ” includes third-party service providers (including contractors and designated agents) and other entities within our group

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal data in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

When might you share my personal data with other entities in the group?

We will share your personal data with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganization or group restructuring exercise, for system maintenance support and hosting of data.

What about other regulatory and/or government authorities?

We may disclose your personal data with regulatory and/or government authorities when asked and in order to comply with the applicable law(s).

Transferring information outside the country

We may transfer the personal data we collect about you to India in order to perform our contract and/or serve the purpose(s) we notify to you. Some geography/countries, where we transfer your personal data might not have appropriate (or adequate) privacy regulation and requirements, but TCS, as a global company, ensures that our global privacy policy is complied across globe.

In order to ensure that your personal data does receive at-par level of protection, we have put in place the relevant contracts and agreements which ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the - country specific laws on data protection. We undertake all those measures required to comply with cross-border personal data transfers, before transferring any of your personal data overseas.

DATA SECURITY

We have put in place measures to protect the security of your information.

Third parties will only process your personal data on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate technical, organizational and security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

DATA RETENTION

How long will you use my information for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

The retention period for the data we collected and generated about you is 6 Months after the purpose we collected it for is complete/over. This retention period is for complying with applicable legal obligation, and while storing/processing it we ensure that we keep it secure and limit its usage only for the legal obligation compliance purposes.

In some circumstances we may anonymize your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer associated with the company, we will retain and securely destroy your personal data in accordance with our data retention policy and applicable laws and regulations

DATA SUBJECT RIGHTS

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

• Request access to your personal data (commonly known as a “data subject access request ”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Object to processing processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to another party.

If you want to exercise a data subject right please contact us at details mentioned in below section.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

RIGHT TO WITHDRAW CONSENT

You have the right to withdraw your consent at any time. To withdraw your consent, please contact TCS at cvgroupmail@tcscomprod.onmicrosoft.com. Withdrawal of Participant’s consent will lead to automatic removal of the Participant from the Contest and forfeiture of prizes/awards/rewards, if any, won by the Participant. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

DATA PROTECTION OFFICE

We have dedicated data protection office and have appointed data protection officers (DPO) to oversee compliance of TCS with applicable data protection laws and with this privacy notice. If you have any questions about this privacy notice or how we handle your personal data, please contact the respective DPO at details mentioned in below section as per your location:

• Data Protection Officer for UK and Ireland: DPO.UKI@tcs.com
• Data Protection Officer for Continental Europe: DPO.europe@tcs.com
• Data Protection Officer for the United States: US.Privacy@tcs.com
• Data Protection Officer for Canada: Canada.Privacy@tcs.com
• Data Protection Officer for LATAM: DPO.LATAM@tcs.com
• Data Protection officer for Brazil: DPO.Brasil@tcs.com
• Data Protection officer for APAC: DPO.APAC@tcs.com
• Data Protection officer for MEA: Mea.privacy@tcs.com
• Data Protection Officer for TCS Technology Solutions(TTS): DCE.TTSDPO@tcs.com

DATA PROTECTION SUPERVISORY AUTHORITY (DPA)

You have the right to make a complaint at any time to the applicable DPA for relevant jurisdiction.

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.