Privacy Policy

This Privacy Policy outlines the privacy and data protection practices followed by Halkwinds Inc. (hereinafter referred to as “Halkwinds”), its affiliates and unaffiliated third parties with respect to information gathering, dissemination and protection.
Privacy Policy

Policy Statement

Halkwinds shall ensure that Personal Data relating to natural persons including employees (current as well as former) suppliers, and customers, are obtained and processed fairly and in accordance with the data subjects’ rights under Data Protection Laws and Regulations. Halkwinds respects the privacy and is committed to promoting the responsible use of personal information and protecting individual’s privacy rights.

Data Collection, Onward Transfer & Processing

Halkwinds may collect, store, use and disclose information about individuals which may constitute personal data (including sensitive personal data under various Government Laws e.g. Indian IT Act Privacy rules, GDPR, etc.) for lawful, explicit and legitimate purposes and for further processing of personal data consistent with those purposes.

Halkwinds shall obtain consent from the data subject wherever appropriate and required for the processing of personnel information prior to collecting, storing and processing any personal data.

Halkwinds shall not utilize an individual’s personal data beyond the scope granted without prior consent from the individual and shall take measures to ensure that this principle is observed. An individual’s personal data shall not be provided or otherwise disclosed to third parties other than Halkwinds affiliates, investigators, or law enforcement personnel when consent has been obtained from the individual in question or when disclosure is legally mandated. To the extent permitted by applicable law, Halkwinds may record and monitor electronic and voice communications to ensure compliance with the legal and regulatory obligations and internal policies and for the purposes outlined above.

Any transfer of personal data to a third party shall take place only if, all necessary controls for Data protection are applied by the third party in order to ensure that the level of protection of personal data is guaranteed.

Confidentiality & Security

Halkwinds takes prudent steps to safeguard the confidentiality and security of all personal data including taking procedural and organizational steps to protect personal data. These steps include but are not limited to entering into written agreements with all its vendors who process personal data which confirm with necessary data protection regulations.

In addition, Halkwinds strives to protect personally identifiable information that it maintains or disseminate so it is not obtained by unauthorized individuals or used in unauthorized ways, including through the use of appropriate administrative, physical, and technical safeguards. E.g. Policies and procedures, Physical and logical access controls and encryptions.

Data Subject Access, Correction & Deletion

Halkwinds recognizes the right of data subjects at reasonable intervals to seek / request a copy of the personal data held in relation to them by Halkwinds. If any personal data is found to be wrong, the individual concerned has the right to ask us to amend, update or delete it, as appropriate. In some circumstances individuals also have a right to object to the processing of their personal data as per the prevailing laws. Halkwinds shall process the personal data solely in accordance with the business purposes for which it was intended.

Privacy consent can be withdrawn easily and at any time by the data subject by informing to appropriate authority within Halkwinds or emailing us

Personal data will not be retained/stored for a period more than necessary to fulfil the purposes outlined in this privacy statement. The personal data shall be deleted from the systems after evaluating if there are any legal, statutory, contractual or legitimate purpose that expects Halkwinds to retain data.


Personal Data means any information relating to a living individual who can be identified directly or indirectly by an identifier such as:

  • Name, identification number, image, location data or an online identifier.
  • One or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of such individual.
  • Birth date, address, personal phone number, personal email address, race, nationality, ethnicity, origin, colour, religious or political beliefs or associations, age, sex, sexual orientation, marital status, family status, identifying number, code, fingerprints, blood type, inherited characteristics, health care history (including information on physical/mental disability); and educational, financial, criminal, history.
  • Photographs of employee and internal gatherings.

Lawful processing means that the activity is conducted in accordance with applicable national or international laws. Specified purpose means being clear from the outset about why we are collecting personal data and are transparent about our purposes with the individuals concerned. Accurate means that the data collected and stored are correct and their integrity is protected. Adequate, relevant and not excessive means that data should be sufficient for the intended purpose and that we should not hold more data than necessary for that purpose.

Data Protection Laws and Regulations means, in the European Union, the Data Protection Directive 95/46/EC and the national statutory legislation passed in each Member State implementing this Directive, the General Data Protection Regulation (GDPR) 2016 / 679, as well as national law that exists outside the EU in each country.

European Union means the current EU Member State countries of: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, and the United Kingdom.

Changes to the policy Halkwinds reserves the right to modify or amend this Policy at its own discretion. This policy is effective from Jan 2020. In order to check updates to this policy, please consult this page on a regular basis.