1. INTRODUCTION

This Privacy Policy (“Policy”) sets out the manner in which m-Pledge Consulting Private Limited and its affiliates (together “m-Pledge”, “Company”, “we”, “us” or “our”) collects, receives, stores, uses, processes, discloses, transfers, retains and otherwise handles personal data through our website currently available at www.m-pledge.com, including all related webpages, landing pages and microsites (“Website”), contact us, submit an enquiry, apply for a position, or otherwise interact with our services.

m-Pledge is a Salesforce consulting and digital transformation company providing Salesforce consulting, implementation, AI, data management, analytics, automation, managed services and related technology solutions. m-Pledge operates internationally, with a presence in India and the United States.

The Website is operated by m-Pledge Consulting Private Limited, a company incorporated under the laws of India, having its registered office at Prestige DotCom, #16/2, Residency Road, Bangalore – 560 025, India. All of our employees are located in India. Where you deal with our affiliate, namely m-Pledge Consulting, Inc, a corporation organized under the laws of the State of Delaware, United States, that affiliate may also act as a controller of your personal data in respect of that relationship, and this Privacy Policy will apply to its processing.

Please read this Policy carefully. By accessing or using the Website, applying for any employment or internship opportunity, engaging with us as a representative of a current or prospective client, partner or vendor, or otherwise interacting with m-Pledge, you acknowledge and accept that you have read and understood this Privacy Policy. Your continued use of the Website even after we update this Privacy Policy shall be construed as your acknowledgement and acceptance of this Policy, to the extent permitted by Applicable Law. This Privacy Policy has been prepared in compliance with the data privacy laws that apply to our operations.

2. DEFINITIONS

For the purposes of this Policy,

“Applicable Law” means all applicable laws, regulations, rules, notifications, guidelines and legally binding directions relating to privacy, data protection, information security, employment and digital services in India and relevant jurisdictions, each to the extent applicable and in force.

“Data Fiduciary” means any person who alone or in conjunction with others determines the purpose and means of processing Personal Data, including m-Pledge where acting in such capacity.

“Data Principal” means the individual to whom the Personal Data relates and includes any equivalent concept such as “data subject” under Applicable Law.

“Personal Data” means any data about an individual who is identifiable by or in relation to such data and includes any equivalent expression such as “personal information” under Applicable Law.

“Processing” means any operation or set of operations performed on Personal Data, whether or not by automated means, including collection, recording, storage, organization, structuring, adaptation, retrieval, consultation, use, disclosure, dissemination, transfer, alignment, restriction, erasure or destruction.

“Sensitive Personal Data” means any personal data that is designated as sensitive under Applicable Law, and may include passwords, financial information such as bank account or payment card details, health information, biometric information, or government-issued identification numbers, where applicable.

“User” or “you” means any person who accesses or uses the Website, or services, including website visitors, candidates, client representatives, partners, vendors and other individuals interacting with us.

3. SCOPE AND APPLICABILITY

This Policy applies to all Personal Data collection, storage, use, disclosure, transfer, retention, processing and other handling by m-Pledge in connection with the Website, and related services, including Personal Data of website visitors, candidates, client representatives, partners, vendors, consultants and any other natural person whose Personal Data is processed by us in connection with the Website and the services. This Policy applies regardless of whether such Personal Data is collected online, offline, directly from you, automatically through technical means, or from third parties lawfully entitled to share such information with us. This Policy does not apply to third-party websites, platforms or services not controlled by m-Pledge, nor does it apply to clients, partners, vendors or other third parties who receive Personal Data from m-Pledge and process such data independently under their own privacy notices and applicable legal obligations.

4. ROLE OF M-PLEDGE IN DATA PROCESSING

Depending on the nature of the engagement and the processing activity concerned, m-Pledge may act either as an independent Data Fiduciary / controller, determining the purpose and means of Processing, or as a processor / service provider, acting on behalf of a client, partner or other organization in accordance with contractual arrangements. In general, where a User browses the Website, submits a contact request, requests information about our services, communicates directly with m-Pledge, or creates a user relationship directly with m-Pledge, the Company ordinarily acts as an independent Data Fiduciary / controller in respect of such Processing. In certain client engagements, implementation, managed services or technology support workflows, m-Pledge may process Personal Data on behalf of a client or business partner.

In some cases, m-Pledge may process different categories of data in different capacities within the same service relationship. Where m-Pledge engages third-party processors or service providers, it shall do so under valid written contractual arrangements that include appropriate data protection obligations, in accordance with Applicable Law.

5. CATEGORIES OF PERSONAL DATA COLLECTED

Depending on how you interact with our Website and us, we may collect the following categories of personal data. We only request personal data that is reasonably necessary for the relevant purpose. Where any personal data is marked as mandatory, we may not be able to respond to your enquiry or process your application if you do not provide it.

5.1 Personal Data You Provide Directly

You may voluntarily provide personal data to us when you:

• Submit an enquiry through the Contact Us section of our Website;
• Request information about our services;
• Contact us by email, telephone or other communication channels;
• Submit your resume or application for employment or an internship, including through the application form linked from our Careers page;
• Subscribe to or request insights, updates or other information from us;
• Participate in surveys, webinars, events or other activities hosted or sponsored by us; or
• Engage with us as a representative of a current or prospective client, partner or vendor.

5.2 Personal Data may include:

• Full name;
• Email address;
• Telephone or mobile number;
• Company or organization name;
• Job title or professional information;
• Location;
• Information contained in your enquiry or communication;
• Resume / CV and employment-related information; and
• Any other information you voluntarily provide.

If you provide us with Personal Data of another individual, you confirm that you are authorized to do so and that you have informed that individual of this Privacy Policy.

5.3 Sensitive Personal Data

Please do not provide us with sensitive personal data or information (such as passwords, financial information such as bank account or payment card details, health information, biometric information, or government-issued identification numbers) through the Website, unless we specifically request it. Where we require such information, we will collect it only with your prior written consent and in accordance with Applicable Data Protection Laws. Where required by Applicable Law, m-Pledge shall obtain written consent prior to collecting or processing Sensitive Personal Data and shall use such data only for the specific lawful purpose for which it was collected. Sensitive Personal Data shall not be shared with third parties except with the Data Principal’s prior consent or as required by law.

5.4 Personal Data Collected Automatically

When you visit our Website certain technical information may be collected automatically, depending on the technologies enabled on the Website. This may include:

• IP address;
• Browser type and version;
• Device type;
• Operating system;
• Approximate geographic location derived from IP address;
• Pages visited;
• Date and time of visits;
• Referring website or URL;
• Website interaction and usage information; and
• Technical information relating to website performance and security.

This Personal Data may be collected through cookies, analytics technologies, server logs and similar technologies.

5.5 Careers and Recruitment Information

If you apply for a position through our Website or otherwise submit your resume to us, we may collect Personal Data including name and contact details, resume / CV, educational qualifications, employment history, skills and professional experience, and information voluntarily provided during the recruitment process. We use this Personal Data to assess applications, communicate with candidates, conduct recruitment activities and meet applicable legal and regulatory requirements. We may retain candidate Personal Data for a reasonable period after a recruitment process has concluded where permitted by applicable law, including for consideration for future opportunities.

6. MANNER OF COLLECTION

We may collect Personal Data:

• Directly from you when you browse the Website, submit a form, communicate with us, apply for a position or internship opportunities, participate in surveys, webinars, events or other activities, or otherwise interact with the Services;
• Automatically through cookies, log files, analytics tools, scripts, pixels, software development kits and similar technologies when you access or interact with the Website or services; and
• From third parties, including clients, partners, vendors, references, verification agencies, service providers, publicly available sources and your authorized representatives, to the extent lawfully permitted.

You represent that any data provided by you is accurate, current and complete, and that where you provide Personal Data relating to another individual, you are duly authorized to do so and that such provision is in compliance with Applicable Law.

7. PURPOSES OF PROCESSING

m-Pledge may process Personal Data for the following purposes:

• Responding to enquiries and requests;
• Providing information about m-Pledge and its capabilities;
• Understanding your business requirements and scheduling consultations or discussions;
• Operating, maintaining and securing the Website and services;
• Providing and improving our Website, and services;
• Managing business relationships with clients, partners and vendors;
• Processing employment applications and evaluating candidates for employment or internship opportunities;
• Verifying identity, qualifications, eligibility, employment history and supporting documents;
• Sending service communications, notifications and updates;
• Monitoring and analyzing website usage, analytics and performance;
• Maintaining website security and preventing fraudulent or unauthorized activity;
• Detecting, preventing and investigating fraud, misuse, unlawful conduct, security incidents and policy violations;
• Complying with applicable legal, regulatory, judicial, governmental, tax or law enforcement obligations;
• Establishing, exercising or defending legal claims; and
• Conducting audits, internal administration and business reporting.

We will not use your personal information for purposes that are incompatible with the purpose for which it was collected unless permitted or required by applicable law.

Where Applicable Law requires a notice to be given before or at the time of collecting Personal Data, such notice shall describe: (i) the Personal Data sought to be collected and the purpose of Processing; (ii) the manner in which you may exercise your rights as a Data Principal; (iii) the manner in which you may withdraw consent; and (iv) the manner in which you may raise a grievance, including before the Data Protection Board where applicable.

8. LAWFUL BASIS OF PROCESSING

Where Applicable Law requires a valid ground for Processing, m-Pledge shall process Personal Data only on one or more of the following lawful bases:

• Your consent, where you have provided free, specific, informed, unconditional and unambiguous consent for the specified purpose, and voluntarily provided your Personal Data to m-Pledge;
• Performance of a contract or steps taken at your request before entering into a contract;
• Our legitimate business interests, including recruitment and employment-related purposes, such as candidate sourcing, evaluation, screening, verification, onboarding and related HR activities, to the extent permitted as a legitimate use under Applicable Law;
• Compliance with legal obligations, including court orders, regulatory directions, audit requirements, tax obligations and lawful governmental requests;
• Protection of vital interests, including medical emergency, disaster management or protection of vital interests, where applicable; and
• Establishment, exercise or defense of legal claims, and prevention, detection or investigation of fraud, misuse or security incidents, to the extent permitted by Applicable Law.

Where Processing is based on your consent, such consent may be withdrawn at any time by contacting us at connect@m-pledge.com. Withdrawal of consent may affect m-Pledge’s ability to provide certain services or continue to support your candidature, account or business relationship.

9. COOKIES AND SIMILAR TECHNOLOGIES

Our Website may use cookies and similar technologies to improve functionality, understand how visitors use the Website, maintain security and analyze website performance. These may be categorized as:

• Strictly necessary cookies, required for the operation of the Website or services, including login authentication and session management, and which cannot be disabled without affecting core functionality;
• Functional cookies, used to remember your preferences, settings and user choices to improve usability;
• Analytics cookies, used to understand how users interact with the Website and services, to measure traffic and to improve performance; and
• Marketing and communication cookies, used, where lawfully permissible, to measure the effectiveness of communications, campaigns or outreach.

You can manage or disable cookies through your browser settings, device controls, or any cookie preference tool made available by us. Please note that disabling certain cookies may affect the functionality of parts of the Website or services. Where required by Applicable Law, non-essential cookies and similar tracking technologies shall be used only with your prior consent.

Where third-party cookies or analytics tools are used, processing may also be subject to the privacy practices of the relevant third-party providers. We encourage users to review the privacy practices of relevant third-party providers. Where cookies collect Sensitive Personal Data or any data requiring written consent under the Applicable Law, appropriate written consent shall be obtained before such collection. m-Pledge may publish a separate Cookie Notice or cookie preference mechanism on the Website to provide additional details, including identification of specific third-party tools deployed.

10. ANALYTICS AND THIRD-PARTY TECHNOLOGIES

We may use third-party services to help us understand Website traffic, measure performance, maintain security or improve our digital presence. Such third-party providers may process technical information such as IP addresses, device information, browser information and website interaction data. Where third-party analytics, advertising, embedded content or other technologies are used, their processing may also be governed by their respective privacy policies.

11. DISCLOSURE AND SHARING OF PERSONAL DATA

We do not sell or rent your personal information for money. m-Pledge may share Personal Data on a need-to-know basis and subject to appropriate controls with the following categories of recipients:

• Website hosting and infrastructure providers;
• IT and technology service providers;
• Cloud hosting, analytics, CRM and communication platform vendors;
• Communication and email service providers;
• Recruitment and applicant management service providers;
• Professional advisers, consultants, auditors, legal advisers or insurers;
• Government authorities, regulators, courts, tribunals or law enforcement agencies where required or permitted by law;
• Business partners or service providers where necessary to provide requested services;
• Group entities and affiliates; and
• Other service providers engaged by us for legitimate business purposes under adequate contractual obligations, including data processing agreements where required.

Third parties processing information on our behalf are expected to process Personal Data only for authorized purposes and to maintain appropriate safeguards. Personal Data may also be disclosed to courts, tribunals, regulators, government departments, statutory authorities and law enforcement bodies where required by Applicable Law or where reasonably necessary to protect rights, safety, property or legal interests.

We may also disclose Personal Data in connection with any merger, acquisition, restructuring, financing, investment, sale of assets or transfer of business, subject to appropriate confidentiality obligations. m-Pledge does not sell Personal Data for monetary consideration. However, certain uses of cookies or analytics technologies may constitute regulated data sharing under the laws of certain jurisdictions.

12. CROSS-BORDER TRANSFER OF PERSONAL DATA

As m-Pledge operates internationally, with a presence in India and the United States, your personal information may be processed, stored in, or accessed from jurisdictions outside India, including jurisdictions where clients, partners, service providers or other stakeholders are located. Such transfers may be necessary for international service delivery, cloud infrastructure management, technical support, analytics or related service purposes.

Where Personal Data is transferred internationally, we will take reasonable steps to ensure that such transfers are carried out in accordance with applicable data protection laws and that appropriate safeguards are implemented where required, including consent, an adequate level of protection, contractual safeguards and data processing agreements, confidentiality obligations, access controls and data minimization, vendor due diligence and technical security measures, and internal governance measures. By using the Services in connection with international operations, you acknowledge that such cross-border processing may be necessary for service delivery and related compliance requirements.

13. DATA RETENTION

We retain Personal Data only for as long as reasonably necessary for the purposes described in this Privacy Policy, or for such longer period as may be required or permitted under Applicable Law, contractual obligations, dispute preservation requirements, internal legal hold requirements or legitimate business needs, including to:

• Respond to enquiries;
• Maintain business and contractual relationships;
• Process employment and internship applications;
• Fulfil legitimate business requirements;
• Comply with legal, accounting, tax, regulatory and reporting obligations;
• Resolve disputes; and
• Enforce agreements and protect our legal rights.

Retention periods may vary depending on the type of information and the purpose for which it was collected. Where required by Applicable Law or our internal retention practices, m-Pledge may provide advance notice to users before deletion of inactive accounts or data. At the expiry of the applicable retention period, Personal Data shall be securely deleted, anonymized, de-identified or otherwise disposed of in accordance with our internal controls and Applicable Law. When personal information is no longer required, we will take reasonable steps to securely delete, anonymize, or otherwise dispose of it, subject to applicable legal requirements.

14. DATA SECURITY

We take reasonable administrative, technical and organizational measures to protect Personal Data against unauthorized access, disclosure, misuse, loss, destruction, accidental alteration or unlawful Processing. Such safeguards may include role-based access restrictions and credential controls, secure transmission practices and encryption where appropriate, cloud and infrastructure security measures, monitoring, logging and anomaly detection, vendor due diligence and contractual confidentiality obligations, internal data protection policies, and incident management and response processes.

However, no method of transmission over the Internet or electronic storage is completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee absolute security. You should also take reasonable steps to protect your login credentials and devices.

15. DATA BREACH NOTIFICATION

In the event m-Pledge becomes aware of a personal data breach, security incident or unauthorized Processing that may compromise the confidentiality, integrity or availability of Personal Data, m-Pledge shall:

• Investigate and contain the incident as expeditiously as practicable;
• Assess the nature, scope and extent of the affected Personal Data;
• Notify affected Data Principals without undue delay, where required by Applicable Law, providing particulars of the breach, its likely consequences, remedial measures taken and the contact details of the responsible officer; and
• Notify the competent authority in accordance with and as prescribed under Applicable Law.

m-Pledge shall maintain breach response procedures, investigation records and remediation documentation in accordance with Applicable Law.

16. RIGHTS OF DATA PRINCIPALS / USERS

Subject to Applicable Law, you may have certain rights concerning your personal information. These may include the right to:

• Access personal information we hold about you and obtain a summary of processing activities, purposes and categories of data shared with third parties;
• Request correction of inaccurate or incomplete personal information;
• Request deletion or erasure of personal information in certain circumstances, where Processing is no longer necessary or lawful, subject to legal exceptions;
• Request restriction of processing;
• Object to certain processing activities;
• Withdraw consent, where processing is based on consent, with effect from the point of withdrawal;
• Request portability of certain personal information;
• Nominate another person to exercise rights on your behalf, where permitted under law;
• Opt out of marketing communications at any time; and
• Raise a grievance with a competent authority.

These rights are subject to applicable legal limitations and exceptions. m-Pledge may require reasonable documentation or information to verify the identity of the requester before acting upon any such request. To exercise any applicable privacy right, please contact us using the details provided in Contact Us section below. Where Applicable Law prescribes timelines for responding to requests, m-Pledge shall endeavor to comply with such timelines.

17. GRIEVANCE REDRESSAL MECHANISM

Any User who has a concern, complaint or grievance relating to the collection, use, disclosure, correction, deletion, security or other Processing of Personal Data may contact m-Pledge’s designated Grievance Officer using the details set out below:

• Grievance Officer Name: Haider Parvez
• Designation: Head of Business Ops & Excellence,
• Email: connect@m-pledge.com,
• Postal Address: Prestige DotCom, #16/2, Residency Road, Bangalore – 560 025, India

Grievances will be addressed in accordance with applicable legal timelines.

18. MARKETING COMMUNICATIONS

If we send you marketing or promotional communications, you may request to stop receiving such communications at any time. You may contact us or use the unsubscribe mechanism included in the relevant communication, where available, or update your account or communication preferences on the Website.

Please note that even if you opt out of marketing communications, we may still send you non-promotional communications where necessary, such as communications relating to an enquiry, service, transaction, security matter or legal obligation.

19. THIRD-PARTY WEBSITES AND SERVICES

Our Website may contain links to third-party websites, platforms, applications, plug-ins or services. These third-party websites are not controlled by m-Pledge, and this Privacy Policy does not apply to their privacy practices. We encourage you to review the privacy policy and applicable terms of any third-party website or service you visit before sharing any Personal Data.

20. AUTOMATED TOOLS AND DECISION SUPPORT

m-Pledge may use automated, rule-based, algorithmic or AI-assisted tools to support data management, analytics, automation, workflow management, communications, fraud detection, document processing and service enhancement as part of its Salesforce consulting, implementation and managed services. Such tools are intended to improve efficiency, consistency and user experience and may operate in conjunction with human review, operational checks or decision support processes.

21. CHILDREN’S PRIVACY

Our Website and services are intended primarily for businesses and professional users. The Services are not intended for children, and m-Pledge does not knowingly collect or process Personal Data of children in violation of Applicable Law. For the purposes of this Policy, “child” means any individual below the age of 18 years. Users registering for or using the Services must be at least 18 years of age unless use is otherwise permitted under Applicable Law with any required authorization or consent. You represent that you are above 18 years of age.

We do not knowingly collect personal information from children, where prohibited by applicable law. If you believe that a child has provided personal information to us without appropriate consent, please contact us so that we can take appropriate action. Where m-Pledge becomes aware that Personal Data of a child has been collected without lawful authorization, m-Pledge shall take reasonable steps to delete or otherwise handle such data in accordance with Applicable Law. Where required by Applicable Law, verifiable parental or guardian consent shall be obtained before any permitted Processing of a child’s Personal Data.

22. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our business, technology, services, law, regulatory guidance, business practices, technologies or service offerings. When we make changes, we will update the “Effective Date” and “Last Updated” date at the top of this Privacy Policy and the updated version shall be posted on the Website with a revised date. We encourage you to periodically review this page to remain informed about how we handle personal information. Your continued use of the Website and services after the revised Policy has been posted shall constitute acknowledgement of the updated Policy, to the extent permitted by Applicable Law.

23. CONTACT US

If you have questions, concerns or requests relating to this Privacy Policy or our handling of personal information, please contact us:

• m-Pledge Consulting Private Limited
• Email: connect@m-pledge.com
• Address: Prestige DotCom, #16/2, Residency Road, Bangalore – 560 025, India

All privacy and grievance-related requests may also be addressed to the designated Grievance Officer at the contact details provided in Section 17 (Grievance Redressal Mechanism) above. We will make reasonable efforts to respond to privacy-related requests within the period required by applicable law.