Who are we?
We are Sphinx Worldbiz Limited, an India-based IT Outsourcing Company providing Software Development, Product Development services such as customized applications, mobility, e-Commerce portals, ERP solutions, software migration, systems integration and a host of other IT service requirements across verticals to its global clientele. We offer a complete range of managed services and backend support with the end-to-end in-house developed products for our customers making our association with them a complete delight.
With our indigenous enterprise products – SHRMpro and SCRMpro; we bring core expertise in developing turnkey projects to cater to clients from a range of industries in both Indian and international markets. At core, we are an employee driven and vision focused organization with exceptional records for Offshore Development Centre utility backed by ambitious technologies. Because we believe in collective progress, our company culture is all-inclusive where the primary requirement is to possess limitless passion to develop products on modern technologies and don a never-say-never attitude, hence transforming our customers into happy clients.
Where a company decides how and why personal data is processed, then the latter is a controller according to Article 4(7) of the GDPR. Therefore, Sphinx Worldbiz Limited is the controller for the data regarding the website visitors, prospective clients that we contact and our existing customers.
This privacy statement is relevant for:
- Website visitors;
- Potential customers that we may contact; and
- Existing customers.
Personal data we collect
Data when you visit the website
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, time zone, and some of the cookies that are installed on your device. This collection of data aims at personalising your experience on the Site, improve customer service, respond to queries and emails of our customers and most importantly. It is important to highlight that this information will not otherwise be aggregated in such a way that would enable us to identify any particular user of the system.
More information about this type of data you can find here
We are aware that our company is based outside of the European Economic Area (EEA) and we are offering goods and service to data subjects that are residents in the EEA. Therefore, we are aware of the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation or GP) and we intend to comply in full with it.
We process personal data based on the consent of the data subject itself for a specific purpose to continue discussing when his/her contact details were not directly obtained from the latter, but nevertheless, there was agreement with respect to the continuation of the discussion). This will be performed in accordance with Article 6.1(a) of the GDPR.
Data which was not directly obtained from the customer / potential customer
If this is not the case, we will process the personal data based on Article 6.1(f) of the GDPR as this would be necessary for the purposes of the legitimate interests pursued by us. Hereunder, you may find a breakdown of our balancing test, which would make sure that the interests or fundamental rights and freedoms of the data subjects will not be overridden by our legitimate interests.
Therefore, in the absence of consent from the data subject we will contact, we prospect our clients on the publicly available information on LinkedIn and will always make an attempt to obtain in advance the information from the company, e.g. from the contact form or general e-mail address of the company.
Should this not be the case, we will verify and check the e-mail address via third-party prospecting services, which will guess your e-mail using publicly available information and run it through a verification tool. We have checked that legitimate interests is the most appropriate legal basis to process personal data. We understand our responsibility to protect the individual’s interests. We have conducted a legitimate interests assessment and action and also kept a record of it, in order to ensure that we can justify our decision to contact you directly via e-mail. We have checked that the processing is necessary for us in order to continue our business and gain new clients and there is no less intrusive way or another solution, which would involve disproportionate efforts and costs from us to achieve the same results. Should this not be the case, we will not be able to continue our business and find new clients as traveling to the EU to attend different events or set up meetings would involve disproportionate costs for us. We have done a balancing test and we are confident that the individual’s interests are not overridden by our legitimate interests. What is more, we will not process children’s data. We have considered safeguards to reduce the impact where possible. We have considered whether we can offer an opt out. Each time we will contact a person via e-mail, we will immediately offer the possibility to opt-out from our communications. Consequently, we will immediately take all necessary steps to delete the data we will have in possession (name and surname, e-mail address, position in a company) with immediate effect.
Once we will obtain your contact details, we will inform you about this processing within 1 month from the date when we have obtained it.
We will not store data which is not necessary for our purposes and will not keep it for longer than it is necessary. Moreover, we will not sell / disclose this data to any other third party processors.
In any case, we will be happy to clarify the specific legal basis that applies to the specific case of processing your personal data. As a consequence, you may contact us at the following address: firstname.lastname@example.org .
Sharing your personal information
We will only share personal information with third parties when it is legally permitted to do so. Each time this data will be obtained, it will be via our processors (Close.io, Bitrix24, SalesQL, LeadIq, Scout, Hunter, Gsuit, Lusha, Zapier and Mailgun). When we will share personal data with others, this will only be accomplished under contractual arrangements and security mechanisms put in place intended to protect your personal information and to comply with our data protection, confidentiality and security standards.
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal information such as to check whether we are complying with applicable laws and regulations, to investigate an alleged crime, to establish, exercise or defend legal claims, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with the applicable laws or regulation.
Individuals have certain rights over their personal data and data controllers are responsible to fulfilling these rights.
These requests can be exercised free of charge and you will be informed by us as early as possible and always within one month from the date of your request. Nevertheless, where requests from data subjects are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (i) charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or (ii) refuse to act on request.
Right of withdrawing consent
You may always have the right to withdraw the consent where you have previously given us your consent to the processing of your information. You can always do this by sending us an e-mail at: email@example.com
Right to object the processing of your information
As described above, we may also obtain your contact details where these were not directly obtained from you. Should you not agree with our processing, you have the right to object to the processing of your information when the processing is carried out on a legal basis other than consent. You can inform us at: firstname.lastname@example.org
Right of access
You have the right to obtain from us confirmation as to whether or not personal data concerning you are processed, and, where that is the case, you have the right to request and get access to that personal data in accordance with applicable law. We will aim to respond to any requests for information promptly, and in any event within the legally required time limits (which is currently set for 30 days). You can do this by sending an e-mail to as at: email@example.com
Right of rectification
You have the right to obtain from us the rectification of inaccurate personal data that was submitted to us and you have the right to provide additional personal data to complete any incomplete personal data. You can do this by sending us an e-mail at: firstname.lastname@example.org
Right to verify the accuracy
You have the right to verify the accuracy of your information and ask for it to be updated or corrected at: email@example.com
Right to erasure
In certain cases, you have the right to obtain from us the erasure of personal data. You can do this by sending us an e-mail at: firstname.lastname@example.org
Right to fill out complaints
You have the right to fill complaints with the applicable data protection authority in your country related to our processing of your personal information.
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us at email@example.com or our representative in the European Union.
Our representative in the European Union
When a controller based outside of the European Union who provides services to residents in the European Union shall designate in writing a representative in the Union. Thus, the representative is mandated by us to be addressed in addition to or instead of us or the processor, by in particular supervisory authorities and data subjects, on all issues related to processing, for the purposes of ensuring compliance with the GDPR.
The details of our representative in the European Union are available hereunder:
When we did not obtain the contact details directly from a data subject, we will not store the data longer than necessary to fulfil the purposes we collected it for, including for purposes of satisfying any legal, accounting or reporting requirements and obligations that we are subject to.
When we will process personal data that was collected or verified via our third-party processors, we will only keep the data for a limited period of time from the moment we received it.
If there is no reply from our data subject, we will delete the data about him/her within 2 month from the date when we received it or at an earlier date in case the data subject requested so.
If we receive the consent of the data subject, we will keep the personal data for as long as it is necessary to continue the business relationship and in accordance with the necessary applicable legislation to which we are subject to. However, the personal data will not be kept longer than necessary.
We take the security of all data it holds very seriously. We have a framework of policies, procedures and trainings in place covering professional secrecy, data protection, confidentiality, security and regal review of the appropriateness of the measures it has in place to keep the data secure.
We secure information that you provide to us on computer servers in a controlled, secure environment, protected from unauthorised access, use or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorised access, use, modification and disclosure of personal data in its control and custody. However, you must be aware that no data transmission over the Internet or wireless network can be guaranteed.
Therefore, while we strive to protect your personal data, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity and privacy of any and all information and data exchanged between us cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third-party, despite our best efforts.
We recognise that transparency is an ongoing responsibility so this privacy statement will be kept under regular review.
We encourage you to periodically review it in order to stay informed of how we are protecting your information.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e‑mail at firstname.lastname@example.org
Sphinx Worldbiz Ltd
A-27 B, Sector 16, Noida India – 201301
Tel.: +91-120-4736400, +91-120-4736499