Privacy Statement

This privacy statement (“Privacy Statement”) articulates the privacy and data protection principles followed by PDS Limited (hereinafter referred to as “PDS”) and its entities around the world with regards to the personal data (“Personal Data”) of its customers, partners, employees (current or former employees), trainees, applicants, contractors, consultants, prospects and vendors/service providers, current or former members of the Board of Directors, visitors on PDS’s premises/offices and all other individuals who have shared their Personal Data with PDS or whose Personal Data is processed by PDS (also referred to as “you”, “your”). This Privacy Statement explains the use and protection of Personal Data collected and processed by PDS. It applies to any Personal Data you provide to PDS and, subject to local laws, any Personal Data we collect from other sources. Throughout this Privacy Statement, “PDS” refers to PDS Limited, including its affiliates and subsidiaries (also referred to as “we”, “us”, or “our”). PDS has created this Privacy Statement to demonstrate our firm commitment to privacy. We understand you trust us with your Personal Data, hence this website has security measures in place to protect the loss, misuse, and alteration of such data provided. PDS is committed to providing privacy to our visitors. This Privacy Statement is to bring before you the Personal Data that we collect, why we collect it and what we do with it; further ensuring that PDS is compliant with the General Data Protection Regulation (GDPR) and Digital Personal Data Protection Act, 2023 (DPDPA) standards, as may be applicable. Our Privacy Statement is subject to change at any time without notice. To make sure you are aware of any changes, please review this Privacy Statement periodically.

1.Scope of this Privacy Statement

This Privacy Statement covers our information practices, including how we collect, use, share, process and protect the Personal Data you provide to us, through our websites that link to this Privacy Statement (collectively referred to as “PDS’s Website(s)/our Website(s)/Website(s)”) or through other means as provided in this Privacy Statement. PDS may provide links to third-party websites for your convenience and information. If you access those links through the PDS Website, you will leave the PDS Website. PDS does not control those sites or their privacy practices, which may differ from PDS’s practices. We do not endorse or make any representations about third-party websites. The Personal Data you choose to provide to, or that is collected by, these third parties, including any social media websites featured on our Website, is not covered by the PDS’s Privacy Statement. We encourage you to review the Privacy Statement or the statement of any website before submitting your Personal Data. We may also provide social media features on our Website that enable you to share PDS information with your social networks and to interact with PDS on various social media sites. Your use of these features may result in the collection or sharing of Personal Data about you, depending on the feature. We encourage you to review the policies and settings on the social media sites with which you interact to make sure you understand how the Personal Data provided by you could be used or shared by those sites.

2.Types of Personal Data Collected

Below is a list of the categories of Personal Data which PDS may collect and process from different stakeholder groups:

A. Employees, prospective candidates/applicants, trainees and consultants

A1.Personal/Demographic Information: Identification/demographic data such as name, photograph, contact details, emergency contact details, date of birth, nationality and gender;

A2.Professional Information: Resume/CV and information such as prior work experience and educational qualifications;

A3.Financial Information: Bank account details;

A4.Identity documents: Permanent Account Number (“PAN”), passport, or other government-issued identification document;

A5.Leave: Information and documentation relating to any absences from work;

A6.Monitoring: CCTV footage, door access, desk and meeting room bookings and locker usage, time of entry/exit;

A7.IT: Passwords, access rights and usage data, records of email and internet usage;

A8.Health: Disability status and medical certificates, outcomes of medical tests;

A9.References: References and background verification data; and

A10.Correspondence: Correspondence and other communications with us.

B. Contractors, partners, customers, vendors, service providers, visitors on PDS’s premises/offices

B1.Personal/Demographic Information:: Name, email address, telephone/mobile number, country, photograph, emergency contact details, date of birth, nationality and gender;

B2.Financial Information: Bank account details;

B3.Tax Information: Goods and Services tax identification number and PAN;

B4.Contractual and Transactional Information: Records of contracts, purchase orders, or other transaction history;

B5.Premises:CCTV footage and visitor registration logs;

B6.Correspondence: Correspondence and other communications with us; and

B7.IT: Digital identification viz. Internet Service Provider (ISP), Internet Protocol (IP) address, browser type, OS, device details, Metadata viz., location, cookies, time spent on pages, the information being surfed, and access timing details.

3.Collection of Personal Data

PDS may collect Personal Data in the following manner, as applicable:

Employees, prospective candidates/applicants, trainees and consultants

A1.Job applications or resumes submitted via the Website, job portals, referrals, or recruitment agencies or when you agree to receive job alerts;

A2. Interviews, assessments, and/or other selection processes (including background verification and reference checks);

A3. Employee onboarding forms and documentation, including identity and tax-related submissions;

A4.

Internal systems and tools used during the course of employment (e.g. HRMS, time tracking, payroll, internal communications);

A5. During training and development programs and performance appraisals;

A6.Surveys, forms, or when you decide to communicate such data to us (i.e., when you fill in forms displayed on the Website) or indirectly, where such Personal Data is provided to us by your electronic communication terminal equipment or your Internet browser;

A7.CCTV or security systems, if entering PDS premises/offices; and

A8. Information imported by you from third-party applications, Websites or linked services.

Contractors, partners, customers, vendors, service providers, visitors on PDS premises/offices

B1. Contractual documentation, onboarding forms, or proposals shared during the initiation of a business relationship;

B2.Email communications, calls, or meetings conducted during the course of business;

B3. Due diligence processes, including background checks;

B4.Event registrations, or contact forms submitted at conferences, vendor fairs, or networking events;

B5.Visitor management systems, or CCTV recordings when visiting PDS offices/premises;

B6.Public sources such as websites or professional platforms;

B7.When you decide to communicate such data to us (i.e., when you fill in forms displayed on the Website) or indirectly, where such Personal Data is provided to us by your electronic communication terminal equipment or your Internet browser; and

B8.When you voluntarily choose to provide us with information, such as when you write to us through PDS’s Websites.

4.Use and Processing of Personal Data

PDS may use and process Personal Data in the following manner, as applicable:

A. Employees, prospective candidates/applicants, trainees and consultants

A1.Sending you job alerts, information about careers at PDS and relevant search results;

A2.For employers/recruiters from PDS to contact you;

A3.To verify your identity and eligibility for job roles or services offered;

A4.For onboarding, background checks, and reference verification;

A5.To prevent, detect, and investigate any illegal activities, or activities which may violate our policies or are otherwise found to be illegal;

A6.To process payroll, benefits, reimbursements, and/or other financial transactions;

A7.For performance management, training, development, and internal mobility opportunities;

A8.To administer leaves, travel, and expense claims;

A9.To respond to queries, grievances, and/or disciplinary actions;

A10.To support workplace health and safety programs;

A11.To conduct employee engagement activities;

A12.To issue and manage access credentials or authorizations for facilities, systems, or networks;

A13.To comply with legal obligations, regulatory requirements, and enforce our legal rights; and

A14.Where Personal Data has been voluntarily provided by you, for the specified purpose for which such Personal Data is voluntarily provided.

B.Contractors, partners, customers, vendors, service providers, visitors on PDS premises/offices

B1.To provide you with customer service support;

B2.To enhance and improve the features and services provided on the Website;

B3.Conducting surveys with the aim of improving and promoting our services;

B4.To administer contractual relationships;

B5.To comply with legal obligations, regulatory requirements, and enforce our legal rights;

B6.To prevent, detect, and investigate any illegal activities, or activities which may violate our policies or are otherwise found to be illegal;

B7.To process payments, reimbursements, and/or other financial transactions;

B8.For due diligence, vendor assessments, and/or KYC processes prior to onboarding;

B9.To manage visitor entries and appointments when you visit PDS premises or offices;

B10.To issue and manage access credentials or authorizations for facilities, systems, or networks;

B11.To communicate with you in the course of fulfilling business obligations and/or service delivery; and

B12.Where Personal Data has been voluntarily provided by you, for the specified purpose for which such Personal Data is voluntarily provided.

B13.We ensure that the Personal Data processed is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.

5. Legal Basis for Processing Your Personal Data

(For individuals in the UK, EU, India, or other relevant jurisdictions)

The legal basis for processing your Personal Data will depend on the specific context in which your Personal Data is collected. Where applicable, we process your Personal Data based on one or more of the following legal grounds:

5.1.Your Consent: Where you have given us clear and affirmative consent to process your Personal Data for a specific purpose (e.g., sending job alerts). When requesting consent, we will clearly explain the purpose of the processing and provide you with the ability to opt-in or withdraw consent at any time.

5.2.Performance of a Contract: Where the processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract (e.g., responding to a service inquiry).

5.3.Compliance with Legal Obligations: Where the processing is necessary for us to comply with a legal or regulatory obligation (e.g., tax compliance, data protection laws).

5.4.Legitimate Interests: Where the processing is necessary for our legitimate interests or those of a third party, and your fundamental rights do not override those interests (e.g., for improving our services, preventing fraud, network and information security).

5.5.Legitimate Uses: Where the processing of your Personal Data is for certain legitimate uses as provided under applicable data protection laws (e.g., for a specific purpose for which you voluntarily provide your Personal Data and in respect of which you have not indicated to us that you do not consent to the use of your Personal Data).

6. Sharing and Disclosure of your Personal Data

We may share and disclose your Personal Data to others (as stated herein below) where it is lawful to do so in order to:

(i)Provide information and services as requested by you;

(ii)Assess queries, requirements, and process requests for products and services;

(iii)Perform client communication, service, and administration;

(iv)Conduct data analysis;

(v)Assess Website performance and usage analysis;

(vi)Run marketing or promotional campaigns;

(vii)Create brand awareness;

(viii)Provide better services and generate demand; and

(ix)Market products and services based on legitimate business interests under the applicable laws.

7. To whom your Personal Data may be shared and disclosed

We may share and disclose your Personal Data for the above purposes with other parties, including:

(i)Other group companies, subsidiaries, joint ventures, affiliates and any sub-contractors, agents or service providers who work for us or provide services to us or to group companies (including their employees, sub-contractors, service providers, directors and officers);

(ii)Law enforcement authorities, government authorities, courts, dispute resolution bodies, statutory and regulatory bodies/authorities, auditors and any party appointed or requested by regulators to carry out investigations or audits of our activities;

(iii)Investigating agencies and entities or persons, to whom or before whom it is mandatory to share and disclose your Personal Data as per the applicable laws, courts, judicial and quasi-judicial authorities and tribunals, arbitrators and arbitration tribunals; and

(iv)Anybody else that we have been instructed to share and disclose your Personal Data with by you.

8. Data Protection and Confidentiality

8.1.PDS has implemented reasonable and adequate physical, technical and administrative security measures to protect your Personal Data from loss, misuse, alteration or destruction.

8.2.PDS shares and discloses your Personal Data to third parties as mentioned above, who are bound to maintain the confidentiality of your Personal Data and may not use such data for any unauthorized purpose. PDS will ensure, through formally executed contracts, that the service providers are committed to the same level of data protection as applicable data protection laws and regulations.

8.3.PDS will take reasonable steps to ensure that all dealings in your Personal Data shall:
- 8.3.1.Be processed fairly and lawfully;
- 8.3.2.Be obtained only with your consent or other legal basis as permitted under applicable data protection laws;
- 8.3.3.Be collected only when:
  - 8.3.3.1.The data is collected for a lawful purpose connected with a function or activity of PDS; and
  - 8.3.3.2.The collection of sensitive personal data or information (if categorised by applicable data protection laws) is considered necessary for that purpose.
- 8.3.4.Be kept secure against unauthorized or unlawful processing and against accidental loss, destruction or damage, as per the prescribed standards to protect the quality and integrity of your Personal Data.

9. Your Rights and Choices

9.1.You have certain rights as mentioned below, subject to applicable data protection laws:
- 9.1.1.Right to Access: Subject to certain conditions, and where we have relied on your consent to process your Personal Data, or where you have voluntarily provided your Personal Data for a specified purpose, you have the right to obtain information from us as below, as well as such information as may be further prescribed under applicable laws:
  - (i)Summary of Personal Data and processing activities: You have the right to receive a summary of your Personal Data that is being processed by us, along with details regarding the processing activities undertaken by us with respect to such Personal Data; and
  - (ii)Identities of other entities: You have the right to know the identities of all other entities with whom your Personal Data has been shared and disclosed by us. This includes a description of your Personal Data shared with these entities.
- 9.1.2.Right to Correction, Completion and Updation: Subject to certain conditions, and where we have relied on your consent to process your Personal Data, or where you have voluntarily provided your Personal Data for a specified purpose, you have the right to correct, complete, and update your Personal Data. This includes the right to:
  - (i)Correct any inaccurate or misleading Personal Data;
  - (ii)Complete the incomplete Personal Data; and
  - (iii)Update your Personal Data.
- 9.1.3.Right to Erasure (“Right to be Forgotten”): Subject to certain conditions, and where we have relied on your consent to process your Personal Data, or where you have voluntarily provided your Personal Data for a specified purpose, you have the right to request deletion/erasure of your Personal Data under certain circumstances.
- 9.1.4.Right to Nominate an individual for exercising rights: You have the right to nominate any other person to exercise the rights mentioned above in case of your death or incapacity.
- 9.1.5.Right to Withdraw Consent: Where we have relied on your consent to process your Personal Data, you have the right to withdraw your consent at any time. Withdrawal shall not affect the lawfulness of processing based on consent before its withdrawal. You may update or revoke your consent preferences through the consent banner available on our Website. You may also unsubscribe from marketing communications through the unsubscribe option available in such communications.
- 9.1.6.Right to Restrict Processing: You have the right to request limitation of the processing of your Personal Data under certain conditions.
- 9.1.7.Right to Object to Processing: You have the right to object to processing where we rely on legitimate interests as the legal basis.
- 9.1.8.Right to Data Portability: You have the right to request transfer of your Personal Data to another organisation, or directly to you, under certain conditions.
- 9.1.9.Right of Grievance Redressal (“Right to Lodge a Complaint”): You have the right to raise grievances regarding the processing of your Personal Data. We will try responding to all grievances or rights requests within three (3) days and notify you of any delay as per applicable law.

9.2.To exercise any of the data subject rights, please contact our Data Protection Officer (DPO) at mohit.sharma@pdsltd.com.

9.3.To raise any complaint about the processing of your Personal Data, you can contact our Grievance Officer at privacy@pdsltd.com.

9.4.If you are not satisfied with how we have resolved your complaints or requests, you may lodge a complaint with the appropriate Data Protection Board (DPB), Supervisory Authority (SA) or another competent National Authority in your jurisdiction.

9.5.We may need to verify your identity before fulfilling your request. We may decline to process requests that are frivolous, unreasonably repetitive, or burdensome, as permitted under applicable law.

10. Retention of Personal Data

10.1.We will retain your Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, unless we are required to retain your Personal Data to comply with our legal/statutory obligations and/or resolve disputes. The retention period may vary depending on the type of data and its purpose, as per applicable data protection laws.

10.2.Personal Data collected from job applicants through the Careers Page may be retained for future recruitment purposes. Where your Personal Data is collected via job referrals, it is processed solely for recruitment purposes. The individual making the referral represents and warrants that they have obtained all necessary and valid consent from the referred individuals, as required under applicable law. PDS does not independently verify such consent and is not responsible for obtaining it.

10.3.For data collected through such referrals, we will obtain the explicit consent of the referred individual via our portal before processing their Personal Data for recruitment purposes. You may revoke this consent at any time by emailing us at privacy@pdsltd.com. PDS will only process referral data for recruitment purposes and ensure that such processing complies with applicable data protection laws.

10.4.Upon expiration of the specified purposes and retention period, your Personal Data will be securely deleted or archived in accordance with legal and statutory requirements.

10.5.We will notify you at least forty-eight (48) hours before deleting your Personal Data. Your Personal Data will be erased upon expiry of such period unless you initiate contact with us for the performance of the specified purpose or otherwise exercise your rights in relation to your Personal Data. You may contact us at privacy@pdsltd.com, subject to applicable law.

11. Usage of Cookies

11.1.Cookies are small text files that are placed on your computer or mobile phone when you visit a website. They are widely used in order to make websites work or to work more efficiently. These cookies help our Website to recognize your device and remember information about your visit (e.g., your preferred language, font size and other preferences).

11.2.We use cookies on our Websites to personalize content and ads, to analyse our traffic and performance, to provide social media features and for the functioning of the Website. You are always free to decline our cookies if your browser permits, although in that case, you may not be able to use certain features on the Website. For detailed information on the types of cookies we use, their purpose, and how you can manage your preferences, please see our dedicated Cookie Policy.

11.3.Additionally, you may encounter “cookies” or other similar devices on certain pages of the Website that are placed by third parties. We do not control the use of cookies by third parties.

12. International Transfer of Personal Data

12.1.PDS may transfer your Personal Data across geographical borders to PDS entities or service providers working on our behalf in other countries with different data protection laws that may not be on par with those of the origin country. A transfer of Personal Data occurs when data is communicated, moved, accessed or otherwise sent to another country.

12.2.In cases where your Personal Data would need to be transferred outside of a country where PDS operates, towards other jurisdictions, specific requirements may apply for such transfer to be allowed.

12.3.For instance, data protection laws of the European Economic Area (“EEA”) and of Switzerland authorize the transfer of Personal Data:

12.3.1.to countries which have been recognized by the European Commission as offering an adequate level of protection for Personal Data.

12.3.2.if appropriate measures in compliance with the European Union data protection legal requirements are in place in order to ensure the protection and confidentiality of Personal Data in countries that do not offer an adequate level of protection.

12.4.This is the case where the recipient PDS entity or third party concludes with the exporting relevant entity of PDS an agreement based on the European Union standard contractual clauses, to ensure the protection of Personal Data.

12.5.PDS may also transfer Personal Data to a third party located outside the EEA or Switzerland without having to implement the above measures where one of the following conditions is met:

A.You have given your consent to PDS for the transfer of your Personal Data.

B.PDS needs to carry out the transfer of Personal Data to perform or conclude a contract with you, where the transfer of your Personal Data is necessary:

(i).to protect your vital interests (i.e., in case of a life-or-death situation);

(ii).to allow PDS to establish, exercise or defend a legal claim; or

(iii).for reasons of public interest.

C.The transfer covers Personal Data publicly available (for instance, from a public register).

12.6.PDS may also transfer Personal Data outside India except for countries or territories which are expressly prohibited, as per applicable data protection laws.

13. Third-Party Websites

Our Site may contain links to third-party websites or services that are not owned or controlled by PDS Limited. We are not responsible for the privacy practices, content, or compliance of those third-party sites. We encourage you to review the privacy policies of any third-party websites you visit

14. Children’s Privacy

Our Website is not directed to, nor intended for use by individuals who are considered minors under applicable data protection laws. We do not knowingly collect Personal Data from minors. If you are a minor in your jurisdiction, please do not submit any Personal Data on the Website. If we learn we have collected or received Personal Data from a minor without valid parental or guardian consent, we will take appropriate steps to delete such Personal Data in accordance with applicable legal requirements.

15. Authenticity

PDS shall not be responsible for the authenticity of the Personal Data supplied to it by its service providers, whose duty it is to ensure that Personal Data provided by it or its employees is authentic.

16. Intellectual Property Rights

16.1.All Intellectual Property Rights on this Website and the Website Content belong to PDS. You have no right to use any of our (or our licensors’) trade names, trademarks, service marks, logos, copyrights, domain names or any other Intellectual Property Rights.

16.2.You may not distribute, modify, transmit, copy or use any Website Content in any manner for public or commercial purposes without prior written consent from PDS.

16.3.The products, technology or processes described on this Website may be the subject of other Intellectual Property Rights owned by PDS or by other third parties. No license is granted to you in respect of those Intellectual Property Rights.

16.4.Without prejudice to the rest of this Clause, all marks which are identified with the symbol ® or ™ are trade or service marks belonging to and used by PDS. Use of such marks is prohibited without the prior written consent of PDS.

16.5.For the purposes of this Privacy Statement, “Intellectual Property Rights” shall mean any copyright, trademarks, service marks, logos, trade names, corporate names, Internet domain names, patents, registered designs, database rights, rights in designs, topography, know-how, trade secrets or any similar right or proprietary right, whether registered or not, and all applications or rights to apply for the same, whether presently existing or created in the future, anywhere in the world, and all benefits, privileges, or rights to sue, recover damages and obtain relief for any past, current or future infringement, misappropriation or violation of any of the foregoing rights.

17. Effective Date

This Privacy Statement is effective from the date first stated hereinabove and supersedes all existing privacy statements on the subject matter.

18. Severability

If any of the terms of this Privacy Statement are found to be invalid, illegal or unenforceable by any court or tribunal of competent jurisdiction, it will be severed, and the remaining terms will continue in full force and effect as if this Privacy Statement had been made without the invalid, illegal or unenforceable terms. Each clause and sub-clause herein shall be treated as a separate and independent provision, and the unenforceability of any one clause shall not impair the enforceability of any of the other clauses.

19. Changes to this Statement

We may update this Statement from time to time on our sole discretion to reflect changes in our practices or for other operational,legal, or regulatory reasons without any notice orliability to you. Without prejudice to the foregoing, the latest version of this Statement shall be posted on this Website. If you continue to use this Website after the amended version has been ,you agree to be bound by such amendments to this PrivacyStatement. We encourage you to review this Privacy Statement periodically.

20. Contact Us

If you have any questions or comments regarding this Privacy Statement or the processing of your Personal Data, please contact us by writing to the Data Protection Officer at mohit.sharma@pdsltd.com.

PDS Limited

Unit No.971, Solitaire Corporate Park,

Andheri – Ghatkopar Link Road, Andheri (East),

Mumbai – 400093

Maharashtra (India)

Email: privacy@pdsltd.com

21. Do Not Sell My Personal Data

If you are a resident of the United States, certain state privacy laws may grant you the right to opt out of the sale or sharing of your Personal Data. To exercise this right, please refer to the “Do Not Sell or Share My Personal Data” banner on the Website and submit your opt-out choice.

PDS Limited

Unit No.971, Solitaire Corporate Park,

Andheri – Ghatkopar Link Road, Andheri (East),

Mumbai – 400093

Maharashtra (India)

privacy@pdsltd.com