1. Introduction

This Privacy Policy describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access to and use of our website www.at-people.com, the software as services provided to you, our client/customers, and the license/access granted to you in order to use our services (collectively “Services”).

This Policy applies to all individuals interacting with ATP HR Tech Pvt. Ltd., including clients, authorized users of services, website visitors, employees, vendors, and contractors. It governs the handling of personal data across all platforms, websites, mobile applications, internal systems, or interfaces developed and managed by ATP, regardless of whether the individual accesses ATP’s services independently or through a business contract with a client.

If you see an undefined term in this Privacy Policy, it has the same definition as in our Website Terms of Use (as available on the Website).

When this policy mentions “ATP,” “we,” “us,” or “our” it refers to ATP HR Tech Private Limited and any other holding/subsidiary/associate company (the Company) that is responsible for your information under this Privacy Policy.

You will also be providing your information, including personal information, to ATP when you are making a payment towards the Fee for licensing our product and/or making payment against the invoices that have been generated and raised against you and/or making any other ad-hoc payment that you may be required to make on the Website. Your private and personal information to such payment gateway shall be governed by that gateway’s own privacy policy which you may access from the payments page.

For the purposes of this Privacy Policy, the term “personal data” refers to any information that relates to an identified or identifiable natural person, whether directly or indirectly. The term “sensitive personal data or information” shall include, without limitation, any data that reveals passwords, financial details, biometric or genetic data, health-related information, or other categories of information classified as sensitive under applicable data protection laws. Any publicly available information or data disclosed under the Right to Information Act or similar laws shall not be considered sensitive.

2. Information We Collect

1. Information You Give to Us: Information that is necessary for the use of the Website and/or the Services. We ask for and collect your personal information about you, or in the case of an employee of a client company, then the details of such company (if applicable) when you use the Website and/or our Services. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested Services, including the use of the Website.
2. Account Information: When you sign up on the Website, we require certain information such as your first name, last name, and email address. To use certain features of the Website and/or our Services, we may ask you to provide additional information, which may include your address and phone number.
3. Payment Information: If and when, you give us Payment information, we use it solely to check your financial qualifications and collect payment from you. We may in the future use a third-party service provider to manage credit card processing. Whenever a service provider is on-boarded, they won’t be permitted to store, retain, or use the information you provide except for the sole purpose of payment processing on our behalf. The payment gateway may require the information as is necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations).
4. Communications with ATP: When you communicate with ATP or use the Website and/or product to communicate with us, we collect information about your communication and any information you choose to provide.
5. Information You Choose to Give Us: You may choose to provide us with additional personal information in order to obtain a better user experience when using the Website. This additional information will be processed based on your consent. In the event of information provided via the use of the product/software to utilise the Services, the same is with your consent by way of accepting the Services through a signed contract/accepted terms of service for the use/licensing of our product to you.
6. Other Information: You may otherwise choose to provide us information when you fill in a form, conduct a search, respond to surveys, post to community forums, participate in promotions, or use other features on the Website (if available and applicable).
7. Information We Automatically Collect from Your Use of the Website: When you use the Website, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Website.
8. Geo-location Information: When you use certain features of the Website, we may collect information about your approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. The Website may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
9. Usage Information: We collect information about your interactions with the Website such as the pages or content you view, your searches for a product/service that is provided by ATP, and other actions on the Website.
10. Log Data and Device Information: We automatically collect log data and device information when you access and use the Website, even if you have not created an account with ATP and/or the Website or logged in. That information includes, among other things: details about how you’ve used the Website (including if you clicked on links to third-party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Website.
11. Cookies & Tracking Technologies: We use cookies and other similar technologies. We may also allow our business partners to use these tracking technologies on the Website or engage others to track your behavior on our behalf. Some people prefer not to allow cookies, which is why most browsers give you the ability to manage cookies to suit you. Most browsers allow you to control cookies through settings, including blocking cookies entirely or setting rules on a site-by-site basis. This allows you to disallow cookies from all websites except those you trust.
    We may use tools such as Google Analytics, HubSpot, Hotjar, Facebook Pixel, LinkedIn Insight Tag, and Microsoft UET Tag to monitor and analyze user activity on the Website. By continuing to use the Website, you consent to our use of cookies and similar tracking technologies unless you choose to disable them through your browser settings. You may manage your cookie preferences at any time by adjusting your browser or device settings.
12. Information We Collect from Third Parties: ATP may collect information, including personal information, which others provide about you when they use the Website or reach the Website through a third party, or obtain information from other sources and combine that with information we collect through the Website. We do not control, supervise or are responsible for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
13. Other Sources: To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third-party service providers and/or partners, and combine it with the information we have about you. We may receive information about you and your activities on and off the Website and/or via the Product use/ through partnerships, or about your experiences and interactions from our partner ad networks.
14. The sources from which we collect personal data include direct interactions with you through our Website or product interfaces, automated technologies such as cookies, analytics tools and logging systems, and third-party partners including clients, integrations, tracking pixels, and publicly available databases. In all cases, we ensure that only relevant and limited data is collected to fulfill the specific purposes of processing described in this Policy.

3. How We Use the Information We Collect

1. For Providing and Improving Our Service: We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the Website and/or our product, create and maintain a trusted and safer environment and comply with our legal obligations and enable you to access and use the Website and/or our Services.
2. We may use the information to operate, protect, improve, and optimize the Website and/or our Services and experience, such as by performing analytics and conducting research
3. Provide customer service: Send you service or support messages, updates, security alerts, and account notifications.
4. If you provide us with your contact information, we may process this information: (a) to facilitate your referral invitations, (b) send your requests for references, (c) for fraud detection and prevention, (d) to facilitate the use of the license and/or Services purchased by you; and (e) for any purpose you authorize at the time of collection.
5. We collect your personal information on a voluntary basis. However, if you decline to provide certain personal information that is marked mandatory, you may not be able to access certain Services, or we may be unable to fully respond to your inquiry pertaining to the Services.
6. Create and Maintain a Trusted and Safer Environment.
7. Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
8. Conduct security investigations and risk assessments
9. Verify or authenticate information or identifications provided by you.
10. Conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required.
11. Comply with our legal obligations.
12. Enforce our Website terms, Product T&Cs and other policies.
13. We process this information given our legitimate interest in protecting the Website and/or our Services, to measure the adequate performance of our contract with you, and to comply with applicable laws.
14. We may use the information shared by you to send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about ATP or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google).
15. We ensure that data shared with third parties is minimal and restricted to specific purposes necessary to deliver the requested services. Personal data will not be shared or processed for any purpose other than those explicitly outlined in this policy or agreed upon with users.
16. We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications.

4. When do we use the information we collect:

1. With Your Consent: Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third-party application or website to access your registered account or when you participate in promotional and/or other activities conducted by ATP partners or third parties.
2. Compliance with Law, Responding to Legal Requests, Preventing Harm, and Protection of our Rights. ATP may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (a) to comply with our legal obligations, (b) to comply with legal process and to respond to claims asserted against ATP, (c) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (d) to enforce and administer our Website terms to use the product, or (e) to protect the rights, property or personal safety of ATP, its employees, its affiliates, directors or members of the public at large.
3. These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person’s vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Website secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage. Where appropriate, we may notify you about legal requests unless: (a) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (b) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon ATP and its Website and/or the product. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that guest about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
4. Third-Party Service Providers and Vendor Oversight: ATP may hare your personal data with trusted third-party service providers for purposes such as payment processing, customer support, analytics, and marketing. These providers are contractually obligated to adhere to our privacy and security policies and applicable data protection regulations. We maintain a robust vendor management framework that includes pre-engagement due diligence, execution of data protection agreements, and implementation of security controls. We also employ ongoing monitoring tools and conduct regular compliance reviews and audits to ensure these vendors meet our operational, legal, and data security standards.
5. Transparency in Data Sharing: We are committed to providing transparency in how and why we share your personal data with third parties. A detailed list of third-party providers and their purposes is available upon request. You may also contact us to understand how your data is processed and managed by these providers.
6. Social Media Platforms: Where permissible according to applicable law, we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Website. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. The social media platforms with which we may share your personal data are not controlled or supervised by ATP. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider.
7. Please note that you may, at any time, ask ATP to cease processing your data for these direct marketing purposes by sending an e-mail to info@at-people.com.
8. Testimonials: To the extent we share customer testimonials/comments/reviews on any of our Websites that contain personal information, we obtain any required consent(s) prior to posting the testimonial.
9. Chat: We may use a chat feature to help you with any questions or concerns. If our chat feature is offline we may still collect your name, email address, and telephone number so that we may reply to your request. Any personal data submitted via testimonials or chat support is processed solely for customer engagement, service improvement, and internal record-keeping in accordance with this Privacy Policy.

5. Other important information:

1. Analyzing your Communications: We may review, scan, or analyze your communications on the Website for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We will not review, scan, or analyze your communications to send third-party marketing messages to you, and we will not sell reviews or analyses of these communications.
2. Google Maps/Earth: Parts of the Website may use Google Maps/Earth services, including the Google Maps API(s). Use of Google Maps/Earth is subject to Google Maps/Earth Additional Terms of Use and the Google Privacy Policy.

6. Third-Party Partners & Integration:

The Website may contain links to third-party websites or services, such as third-party integrations, co-branded services, or third-party-branded services (“Third Party Partners”). ATP doesn’t own or control these Third-Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, ATP, or both. These Third Party Partners will have their own policies for the use, protection, and disclosure of personal information. We encourage you to review the privacy policies of the other websites you visit.

7. General Compliance:

ATP HR Tech Private Limited complies with applicable privacy laws and regulations to protect the personal information of all customers, clients, and users. ATP’s Services are governed by Indian laws, including the Information Technology Act (ITA) 2000, and Information Technology “Reasonable Security Practices and Procedures and Sensitive Personal Data or Information” Rules 2011. The personal data collected by ATP is used strictly for delivering services under lawful agreements with clients or organizations whose authorized users access ATP’s services. ATP ensures that data collection, usage, and management are carried out in a lawful, fair, and transparent manner in accordance with applicable regulations.

ATP adheres to the principle of limiting data collection to only what is necessary for specified purposes and ensures appropriate technical and organizational safeguards are in place to protect personal information. The information collected by ATP is used to provide its Services under lawful agreements between ATP and the organizations whose authorized users utilize the Services. All collection, usage, and management of personal data are conducted in compliance with relevant laws and regulations, ensuring the protection of user privacy. Further details about our compliance framework may be accessed [here]

8. Your rights:

1. You are responsible for your personal information accurate and up-to-date. You may request the correction of any inaccurate or incomplete information held by ATP HR Tech Pvt. Ltd. Subject to applicable law, you also have the right to access your personal information or request a copy of the data we hold about you. You may further request that we erase your data or restrict its processing, especially where it is no longer necessary for the purposes for which it was collected. Please note that certain data may be retained to fulfil our legitimate business purposes, for legal obligations, or where it has already been shared publicly (e.g., via reviews or forums).
2. Where your consent forms the legal basis for processing, you may withdraw your consent at any time by writing to us. However, withdrawal does not affect the legality of data processing that took place before your request.
   We do not sell your personal data to third-party marketers. In some cases, we may use your data for purposes based on our legitimate interest, including profiling for improving our Services. If you object to this processing, ATP will cease such use unless we can demonstrate compelling legal grounds or where it is required to establish, exercise, or defend legal claims.
3. If you wish to exercise any of your rights, please contact us at: info@at-people.com
4. Withdrawing Consent and Restriction of Processing: Where you have provided your consent to the processing of your personal information by ATP you may withdraw your consent by sending us an e-mail. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
5. We do not sell your personal information for processing by direct marketing agencies. We may however use your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing ATP will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise, or defence of legal claims.

8. Data protection and security:

1. ATP uses systems and security measures in accordance with applicable Data Protection Regulations to protect the personal information shared by users. Necessary controls are implemented to ensure your personal information remains secure and confidential.
2. We continuously implement and update administrative, technical, and physical safeguards to help protect your information against unauthorized access, loss, destruction, or alteration. These safeguards include firewalls, data encryption, and strict information access controls.
3. In the event of a data breach involving your personal information, ATP is committed to acting promptly and transparently. Affected individuals will be notified as soon as reasonably possible, along with a description of the actions taken to secure the data and mitigate risks. ATP also investigates all incidents thoroughly and implements corrective measures to prevent recurrence.
4. ATP uses industry-standard measures to protect the personal information stored in our databases. If you know or have reason to believe that your credentials shared with ATP via the website have been lost, stolen, misappropriated, or otherwise compromised—or if you suspect unauthorized use of your information, please contact us immediately at [info@at-people.com].
5. ATP processes user data strictly in accordance with contractual obligations. Data collected from end-users is limited to what is necessary to deliver ATP’s services and is accessed only by authorized personnel. This user data is governed by agreements between ATP and its clients or the organizations whose authorized users use ATP’s platforms.
6. Internal employee data, including information related to HR, system usage, and workplace analytics, is handled separately from user/customer data. This internal data is accessed only by authorized personnel and used strictly for internal operational and compliance purposes. It is protected using the same encryption, access controls, and periodic reviews as other sensitive data, and is not shared externally unless required by law.
7. ATP engages third-party vendors and partners who adhere to industry-standard data protection practices. All vendors are subject to a due diligence process before engagement and are bound by contractual obligations. ATP also employs ongoing monitoring tools and conducts periodic reviews to ensure continued compliance with these obligations and applicable data protection regulations.
8. WhatsApp Business Communication

ATP HR Tech Private Limited uses its WhatsApp Business Account (WABA) as one of the communication channels for customer and user interactions, including support, service updates, and account-related notifications.

a) Information Collected: During WhatsApp interactions, ATP may collect limited personal information such as contact details, message content, and metadata (for example, timestamps and message delivery status).

b) Purpose of Processing: This information is used solely for providing support, responding to queries, delivering service updates, or fulfilling contractual obligations with clients and users.

c) Lawful Basis: Processing is carried out based on contractual necessity, legitimate interest, or explicit consent, as applicable.

d) Data Sharing: Messages exchanged via WhatsApp are processed through Meta Platforms, Inc. (WhatsApp). ATP may share necessary information with WhatsApp and other authorized service providers solely for facilitating communication.

e) Data Security: All WhatsApp communications are end-to-end encrypted. ATP ensures secure storage, restricted access, and adherence to applicable data-protection laws, including the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000 (India), and other relevant global privacy regulations such as the GDPR and CCPA.

f) User Rights: Users may request access, correction, or deletion of their data, or opt out of WhatsApp-based communication by contacting us at [info@at-people.com].

10. Changes to this privacy policy

ATP reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Website and update the “Last Updated” date at the top of this Privacy Policy. Your continued access to or use of the Website will be subject to the revised Privacy Policy.

11. Contact Us

If you have any questions or complaints about this Privacy Policy or ATP’s information handling practices, you may email us at: [info@at-people.com]