Last Updated May, 2018
Click on the links below to jump to each section:
- INFORMATION WE COLLECT
- HOW WE USE INFORMATION
- INFORMATION WE SHARE
- YOUR CONTROL OVER INFORMATION
- HOW WE PROTECT INFORMATION
- QUESTIONS OR COMPLAINTS
- INFORMATION WE COLLECT
Once you visit our Website or use Monjin Services, you are no longer anonymous to us because we collect certain information personally identifiable to you. We collect information about you when you register or sign up for a new account, when you use our services or when you visit the sites and/or links provided on our Website. When you register, we ask for information that is personally identifiable to you, such as your name, location, phone number, e-mail address, industry, skills and work experience. Also, we may collect a video recording, which includes your image, voice, the background of your interview location, and other information not otherwise publicly available. All this information is referred to in this Policy as “Personal Information.”
Your Personal Information may also be made available to us by the subscribing employer who has invited you for a Video Interview. Your Video Interview shall be scheduled through an online scheduling calendar and you shall be required to login into your account at the scheduled time. Once an online video conference session is established with the designated interviewer, the recording shall start and you shall be shown a message to that effect on your screen. The recording shall continue throughout the session till the interviewer stops the recording. Please note that your bodily image and voice, as well as your surroundings, including but not limited to the background of the place of interview or any movements thereto may be recorded as part of the Video Interview. The recording at your side will continue even if the interviewer drops off temporarily due to lack of internet connectivity during the interview.
Certain information is collected automatically, such as Internet Protocol (IP) address, cookies, location, browser type, access time, error log, etc. IP addresses and cookies are received automatically from your Internet browser and recorded into our server logs. This information is collected for all Users, irrespective of registration status with us.
As part of our commitment to providing the best possible service to our Users, we record all telephone calls answered in our contact centers. We store these recordings securely for the period prescribed under applicable regulations, such as Directive 95/46/EC for EU, EU General Data Protection Regulation (Regulation (EU) 2016/679), Information Technology Act and Rules for India, and Privacy Shield principles for the US. We may destroy recordings after the prescribed period.
Please note that we do not knowingly collect Personal Information from users under the age of 18. By using our Website, you hereby expressly confirm that you are at least 18 years of age and legally eligible to enter into a binding contract and share Personal Information.
- HOW WE USE INFORMATION
Monjin uses Personal Information to operate or improve our Website or Monjin Services, to outsource certain services to strategic partners, to complete a transaction that has been requested, to develop aggregate information, to process to store data, to host the Website, to market our services, to comply with audits, to perform web analysis and/or as otherwise disclosed to you.
Our Website uses information like IP address, cookies, location, browser type, access time, etc., to maintain the quality of our services and to provide general statistics about website visitors. Depending on the business model and privacy setting chosen by you, our Website will evaluate the information, including your Video Interview, and make it visible to a subscribing employer or all subscribing employers, end clients, agencies or interviewers applicable to the business model. Whereas we strive to increase the efficiency of our website, we do not give any warranty or guarantee that our privacy setting will work as intended every time.
Video Interview files may be published, distributed, used, reproduced, modified, translated or displayed in any manner or medium by Monjin or our clients as part of the delivery of the services we provide. Monjin has sole discretion to post, remove or delete any matter, and may block or terminate the access of any person to Video Interview files maintained or stored by Monjin. For this purpose, you grant Monjin a non-exclusive, irrevocable, world-wide, royalty-free right to use the Personal Information you shared with Monjin.
We use recorded telephone calls and emails for the following purposes:
- for staff training purposes, to help us improve the quality of our services and ensure information we provide is consistent and accurate;
- for reporting on the types and numbers of questions we receive, so we can find ways to simplify our services, and
- to ensure we have an accurate record of calls, which may be needed to support any transactions or in case of a dispute.
- INFORMATION WE SHARE
Monjin generally provides Personal Information to third parties where:
- we have your consent;
- the disclosure is necessary to complete a transaction requested;
- we have obtained information from a third party (presuming that you have previously provided such consent to any such third party from whom Monjin obtains such information);
- we are required or permitted to do so by law;
The essential nature of Monjin Services requires sharing of Personal Information submitted by Users seeking employment with other users offering the prospect of employment. Personal Information may be disclosed to subscribing customers, agents, service providers or interview panels to fulfil our obligation to other Users of Monjin Services. In such cases, Personal Information will only be shared where we have consent to do so. Monjin may disclose your Personal Information including the Video Interviews to subscribing customers according to the service model through which you have registered and privacy settings chosen by you in your account for a specific period of time. In some cases, Users of Monjin Services may be able to download your Video Interview and other Personal Information and store them on their computers and servers. Other Users may be able to use shared links to distribute your Personal Information to third parties outside our control.
If another company in the Monjin group or our third-party contractors are located in or have business activities in a country outside the EU/EEA, your Personal Information may be transferred to such countries. In such cases we ensure that the transfer is made if the recipient can guarantee an adequate level of protection for the processing of your Personal Information, or by having implemented appropriate safeguards such as the EU Standard Contractual Clauses that have been approved by the European Commission which are available on its website.
- Third-Party Contractors
We may employ or engage certain trusted third party contractors (“Third-Party Contractors”) to perform functions and provide various services on our behalf. Specifically, Monjin uses Third-Party Contractors to establish video conferences, record video conferences, host its platform and associated data on a protected cloud infrastructure, and to send email or text messages. Monjin may also store Personal Information a remote server managed by a Third-Party Contractor who ensures the same level of data protection required under Directive 95/46/EC for EU, EU General Data Protection Regulation (Regulation (EU) 2016/679), Privacy Shield principles for US, Information Technology Act, 2000 for India, and other applicable laws and regulations.
Third-Party Contractors may get access to Personal Information while discharging their respective services. Monjin will share Personal Information with these Third-Party Contractors only to the extent necessary to perform the functions or provide the services for which they are engaged. Generally, Monjin will obtain contractual commitments from Third-Party Contractors to maintain the privacy and security of Personal Information shared with them. Third-Party Contractors will ensure that Personal Information disclosed to them is used solely to provide the applicable services to Monjin and shall not be further disclosed to any other party. Monjin may change its Third-Party Contractors from time to time as per the business demands without notice to Users.
- Business Transfers
- Legal Compliance
Monjin may disclose any information about you and/or content created by you to government or law enforcement officials as we, in our sole discretion, believe necessary or appropriate to:
comply with an order from a court of competent jurisdiction, regulatory agency, and/or other governmental authority;
respond to claims, court orders, or other legal process
enforce the terms of this and other Monjin agreements as well as to protect the property and rights of Monjin, its Strategic Partners or other third parties;
protect, in Monjin’s sole discretion, the public or any person from harm;
investigate, prevent, stop, or take other action regarding any action perceived to be fraudulent, illegal, unethical, or legally actionable in Monjin’s sole discretion; and/or
generally comply with the law.
Monjin disclaims any duty, obligation or liability to provide you with prior or subsequent notice of disclosure of your data to government or law enforcement officials as above.
- External Links
We may offer links to third party websites on our website. These third party sites have their own independent and separate privacy policies. Therefore, we are not liable for the contents or activities on those sites or how they use or disclose your personal information.
- YOUR CONTROL OVER INFORMATION
a. Access, rectification, restriction, erasure, objection and portability
You are entitled to receive information about your Personal Information that is being processed, regardless of how it was collected. This can include information on the origin of the Personal Information, the recipients or categories of recipients to whom the Personal Information have been disclosed and the purpose of storage. Furthermore, to the extent required by law, you are entitled to have your Personal Data rectified or erased or their processing restricted, or to a right to data portability with respect to your Personal Information. You also have the right to withdraw your consent to processing of your Personal Information at any time. If you would like to receive such information or make such requests as described, you must send us a written request with your name and address and sent to email@example.com.
Whenever you use Monjin Services, we aim to provide you with access to your Personal Information. If that information is incorrect, we strive to provide you ways to quickly update or delete the information, unless we need to preserve it for legitimate business or legal purposes and in accordance with applicable law. When updating your Personal Information or making requests as described above, we may ask you to verify your identity before we act on your request.
Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort. We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete Personal Information from our Website, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems immediately (but no later than is permitted by applicable law).
If you are not satisfied with our response or believe that we are not processing your Personal Information in accordance with the law, you may contact or lodge a complaint with the relevant competent supervisory authority or seek other remedies under applicable law.
- HOW WE PROTECT INFORMATION
Our Website secures the Personal Information provided by you on computer servers in a controlled and protected environment to prevent loss, misuse, unauthorized access, disclosure, alteration and destruction of the information. It is necessary that users keep their personal Information including, but not limited to, email address and password confidential and must not share it with anyone to prevent unauthorized use or access of their Personal Information. We will not sell, trade or lease collected information without your consent, except in the circumstances as described elsewhere in this document.
Monjin follows standards and guidelines common to the information security industry to prevent unauthorized access to the Personal Information. But at the same time Monjin cannot make any warranties regarding the same. Some of the security practices we have deployed include the following.
The data is encrypted during transit using the prescribed SSL protocol and is also encrypted while at rest using transparent data encryption provided by Windows Azure.
Our Video Interview files are stored in an encrypted storage and are protected using time limited shared access signature provided by Windows Azure to protect private blob storage.
We obtain security assurances or certifications from the third parties that we use in providing services to our customers.
Access to your data is restricted on a ‘need to know’ basis and controlled through role based access control mechanism.
Our Website is periodically assessed by third party service providers for security vulnerabilities and we perform periodic penetration testing.
We have deployed security tools to identify unauthorized access attempts and any potential cyberattacks.
We conduct periodic security audits of or information security processes.
While Monjin takes all possible precautions to avoid misuse of Personal Information shared by you on the Monjin platform and the Website, you understand and acknowledge that there may be risks involved. These include, but are not limited to, the risk of physical or other harm from dealing with strangers, foreign nationals, underage persons, or people acting under false pretenses. You assume all risks associated with dealing with other users with whom you come in contact through the Website.
By accessing our Website, you agree and understand that Monjin is an online platform that enables Video Interviews and as an “Intermediary” within the meaning ascribed to it under the provisions of the Information Technology Act, 2000 of India.
Monjin implements reasonable security practices in the storage of Personal Information. The length of time Monjin retains Personal Information will vary depending on the nature of the services for which the information has been collected. Although this period may extend beyond the end of your relationship with Monjin, it will be retained for so long as necessary for Monjin to respond to any issues arising from your relationship.
When Monjin no longer needs Personal Information, we will destroy, delete, erase or convert it to an anonymous form without any notice to Users. Monjin may delete information including, but not limited to, stored messages, interviews, videos, audio, other content, and records of User accounts without any prior notice to Users. Monjin recommends that you back up on your own computer any critical and important information prior to allowing your Monjin Services to terminate or expire. Should your account be terminated, Monjin may immediately and permanently delete all stored messages, interviews, videos, audio, other content, and records of your account without any prior notice.
- QUESTIONS OR COMPLAINTS
India: Mr. Aniruddha Fansalkar, who can be reached at firstname.lastname@example.org
United States: Mr. Avadhoot Deshpande, who can be reached at email@example.com
European Union: Mr. Ola Persson, who can be reached at firstname.lastname@example.org
Complaints will be handled according to a set of defined procedures. When we receive written complaints, we will reply to them within 45 days. Where we cannot resolve a complaint involving our use or transfer of Personal Information with our Users directly, we will work with the appropriate regulatory authorities.