Privacy Policy

Introduction

As a globally integrated company, Luckwell Solutions business processes increasingly go beyond the borders of one country. This globalization demands not only the availability of communication and information systems across Luckwell Solutions, but also the world-wide processing, sharing and use of multiple types of information including information about an individual whose identity is apparent (either directly and indirectly), or can be reasonably be ascertained from the information available or likely to be available (Personal Information).

This Policy letter sets forth the general principles which underlie Luckwell Solutions specific practices for collecting, using, disclosing, storing, retaining, disposing, accessing, transferring or otherwise processing Personal Information.

Applicability

This Policy applies to all Luckwell Solutions personnel, operating units, and wholly owned subsidiaries worldwide and (as transferred and agreed) with suppliers/business partners who must act consistently with the principles contained in the policy. Country and industry-specific laws and regulations shall take precedence over this policy, to the extent applicable. 

Privacy Policy Statement

Luckwell Solutions remains committed to protecting the privacy and confidentiality of Personal Information of its Employees (including prospects and contractors), Clients, Client Customers, Business Partners and other identifiable individuals that it may receive, use, access, process, transfer or store as part of its business. Uniform practices for collecting, using, disclosing, storing, retaining, disposing, accessing, transferring or otherwise processing such information assists Luckwell Solutions to process Personal Information fairly and appropriately.

Luckwell Solutions may collect personal information from various persons as part of the services it may render to them, or in the course of its business. Based on the information being collected and nature of services or requirement, Luckwell Solutions will apply suitable mechanisms to ensure that Luckwell Solutions has a lawful basis for receiving, accessing, using, processing, transferring, storing and/or disposing such personal information.

General Privacy Principles

1. Accountability

Luckwell Solutions understands its accountability and responsibility for any Personal Information that it may receive, use, process, store as part of its business.  Accordingly, it will:

I. have appropriate corporate instructions, guidelines and other measures to be able to demonstrate that Personal Information is used/ stored / processed / retained / disposed / transferred in compliance with applicable law and other applicable guidelines;

II. designate an individual or individuals who are accountable for the organization’s compliance with the Privacy principles; and

III. ensure the availability of required policies, procedures and contacts for management of personal information; these being reviewed at a minimum annually or as and when there is a change warranted.

2. Disclosure and Data Sharing

Luckwell Solutions will make Personal Information available inside or outside Luckwell Solutions under appropriate circumstances for business purpose only or as authorized by law.

This may require Luckwell Solutions to transfer personal information to countries other than Luckwell Solutions operation’s country of business (including transfer to other entities or third parties).

Luckwell Solutions will implement privacy principles for the use / processing/ transfer / storing/ disposal of personal information as may be prescribed under applicable laws.

3. Security

Luckwell Solutions will implement reasonable technical and organizational measures to safeguard Personal Information and instruct third parties processing Personal Information on behalf of Luckwell Solutions to process and manage it in a manner which is consistent with Luckwell Solutions standards (for Luckwell Solutions owned information) or Luckwell Solutions Client standards (for Client information), as may be applicable.

4. Access

Upon request, Luckwell Solutions will, within a reasonable time, manner, and in a readily intelligible form provide individuals appropriate access to Personal Information retained by Luckwell Solutions. Luckwell Solutions has the right to deny the request; however, the reasons of denial will be provided. Luckwell Solutions will erase, rectify, complete, or amend the data pursuant to a justified request.

5. Retention and Disposal

Luckwell Solutions will retain Personal information in a form that permits identification for no longer than as necessary for the fulfillment of the stated purpose, and should be disposed thereafter.

6. Transparency

Luckwell Solutions will be transparent, and make readily available to individuals, specific information related to management of Personal Information.