Privacy Statement

Last Updated on 6 September 2024

B S R & Co. LLP is a limited liability partnership, registered with The Institute of Chartered Accountants of India (ICAI). The terms “Firm”, “we”, “our”, “us, and “BSR” in this privacy statement ("Privacy Statement") refer to the B S R & Co. LLP This website is operated by BSR and it is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, Firm is committed to the appropriate protection and use of personal information (sometimes referred to as “personal data”, "personally identifiable information" or "PII") collected online.

This privacy statement ("Privacy Statement") explains what personal information the Firm collects online, how it collects and uses such personal information and describes the rights you have with respect to your personal information.

How do we collect personal data?

Directly: We obtain personal data directly from individuals in a variety of ways, including obtaining personal data from individuals who provide us with their business card(s), our online forms, subscribe to our newsletters, register for webinars, attend meetings or events we host, visit our offices or for recruitment purposes. We may also obtain personal data directly for example, when we are establishing a business relationship, performing professional services through a contract, or through our hosted software applications.

Indirectly: We obtain personal data indirectly about individuals from a variety of sources, including recruitment agencies, our clients, and other parties including former employers, credit reference agencies and third-party vendors.

Public sources- Personal data may be obtained from news articles, sanctions list, crime prevention agencies and internet searches.

Social and professional networking sites- If you register or login to our websites using social media (e.g., LinkedIn, Google, or X (erstwhile Twitter) to authenticate your identity and connect your social media login information with us, we will collect information or content needed for the registration or login that you permitted your social media provider to share with us. That information may include your name and email address and depending on your privacy settings, additional details about you, so please review the privacy controls on the applicable social media websites to set how much information you want to be shared with us.

Business clients- Our business clients may engage us to perform professional services which involves sharing personal data they control as part of that engagement. Our services may also include processing personal data under our clients’ control on our hosted software applications, which may be governed by different privacy terms, policies and notices.

I. What categories of personal data do we collect?

We may obtain the following categories of personal data about individuals through direct interactions with us, or from information provided through client engagements, from applicants, our suppliers and through other situations including those described in this Privacy Statement.

Contact details (e.g., name, company name, job title, work and mobile /telephone numbers, work and personal email and postal address).
Professional details (e.g., job and career history, educational background and professional memberships).
CCTV at our sites may collect images of visitors. Our policy is to automatically overwrite CCTV footage within 30 days.
Personal identification documents that may reveal race, religion or ethnic origin, possibly biometric data of individuals, beneficial owners of corporate entities, or applicants.
Adverse information about potential or existing clients/ third parties and applicants that may reveal criminal convictions or offences information.
Personal Information provided to us by our clients in the course of a professional engagement.
Diversity and equal opportunity information voluntarily shared by applicants as part of recruitment processes.
Health data where the processing is necessary to assess, monitor and control the spread of infectious diseases and to provide a safe environment for our employees, clients and suppliers.

II. Children data

Our sites are not intentionally designed for or directed at children/minors under the age of 18. It is our policy never to knowingly collect or maintain information about anyone under the age of 18, except as part of an engagement to provide professional services, in which case we process personal information under the instructions of the client or as part of corporate social responsibility initiatives, where consent from the parents or legal guardians forms the basis of processing. Although, we do not intentionally and directly collect information from individuals under 18 years of age, we may occasionally receive details about children attending performances and other events that we host with their parents or guardians In any case:;

We shall not undertake such processing of personal data that is likely to cause any detrimental effect on the well-being of the child.
We shall not undertake tracking or behavioral monitoring of children or targeted advertising directed at children.

III. What legal grounds do we have for processing your personal information?

In the normal course, we would rely upon consent given by you at the time you provided your personal data to us as the basis for processing your personal information.

You may withdraw, and/or review your consent at any time by contacting us at in-fmprivacy@bsraffiliates.com

Legitimate use - Personal data may be processed by us for any of the following uses, namely:

for the specified purpose for which you have voluntarily provided 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;
for fulfilling any obligation under any law for the time being in force in India on any person to disclose any information to the State or any of its instrumentalities, subject to such processing being in accordance with the provisions regarding disclosure of such information in any other law for the time being in force;
for compliance with any judgment or decree or order issued under any law for the time being in force in India, or any judgment or order relating to claims of a contractual or civil nature under any law for the time being in force outside India;
for responding to medical emergency involving a threat to the life or immediate threat to the health of the data principal or any other individual during an epidemic, outbreak of disease, or any other threat to public health;
for taking measures to ensure safety of, or provide assistance or services to, any individual during any disaster, or any breakdown or public order
for the purposes of employment or those related to safeguarding the employer from loss or liability, such as prevention of corporate espionage, maintenance of confidentiality of trade secrets, intellectual property, classified information or provision of any service or benefit sought by a Data Principal who is an employee.

IV. Why do we need personal data?

We aspire to be transparent when we collect and use personal data and tell you why we need it, which typically includes:

Providing professional advice and discharging responsibilities and providing deliverables in relation to professional services rendered. Our services may include reviewing client files for quality assurance purposes, which may involve processing personal data for the relevant client.
Promoting our professional services, products and capabilities to existing and prospective business clients, enhancing business relationships and securing new opportunities.
Sending invitations and providing access to guests attending our events and webinars or our sponsored events.
Personalizing online landing pages and communications we think would be of interest based on interactions with us.
Administering, maintaining, and ensuring the security of our information systems, applications and websites.
Authenticating registered users to certain areas of our websites.
Seeking qualified candidates, and forwarding candidate career inquiries to our relevant teams internally.
Processing online requests, including responding to communications from individuals or requests for proposals and quotations.
Complying with legal and regulatory obligations relating to anti-money laundering, terrorist financing, fraud and other forms of financial crime.
Compiling health and safety data (directly or indirectly) following an incident or accident. Indirect data can take many forms including an incident report, first aider report, witness statements and CCTV footage.
Collecting health data to assess, monitor and control spread of infectious diseases and to provide a safe environment for our employees, clients and suppliers.

V. Do we share personal data with third parties?

We may occasionally share personal data with trusted third parties to help us deliver efficient and quality services. These recipients are contractually bound to safeguard the data we entrust to them. We may engage with several or all of the following categories of recipients:

Overseas firms, where necessary for administrative purposes and to provide professional services to our clients (e.g., when providing services involving advice from overseas firms in different territories) and enhancing business relationships and securing new opportunities. Such information may also be shared with KPMG International on need basis or as contractually agreed with them.
Parties that support us as we provide our services (e.g., providers of telecommunication systems, mailroom support, IT system support, archiving services, document production services and cloud-based software services).
Professional advisers, including lawyers, auditors and insurers.
Parties that support us with anti-money laundering, conflict management and independence checks.
Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation.
Health government bodies and external service providers to assess, monitor and control the spread of infectious diseases.
Payment, marketing and recruitment services providers.

Firm will not transfer the personal information you provide to any third parties for their own direct marketing use.

VI. Do we transfer your personal data outside India?

To the extent permissible, we may store personal data on servers located outside India. Unless it is restricted by law, we may transfer personal data to overseas firms and third-party organizations situated outside India, when we have a business reason to engage with these organizations. Each such organization is required to safeguard personal data in accordance with our contractual obligations and applicable data protection legislation.

VII. How we use Cookies?

Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes.

On some of our web sites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as "user- input" cookies may still be required for necessary functionality. Such cookies will not be blocked using this notification banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser's cookies.

Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser's settings (often found in your browser's Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our web sites' features.

Below is a list of the types of cookies used on our web sites:

Purpose	Description	Type & Expiry
Performance (i.e., User's Browser)	Our web sites are built using common internet platforms. These have built-in cookies which help compatibility issues (e.g., to identify your browser type) and improve performance (e.g., quicker loading of content).	Session Deleted upon closing the browser.
Security (e.g. Asp .NET) Cookies	If you register for access to a restricted area, our cookies ensure that your device is logged for the duration of your visit. You will need your username and password to access the restricted areas.	Session Deleted upon closing the browser.
Site Preferences	Our cookies may also remember your site preferences (e.g., language) or seek to enhance your experience (e.g., by personalizing a greeting or content). This will apply to areas where you have registered specifically for access or create an account.	Session Deleted upon closing the browser.
Analytical	We use several third-party analytics tools to help us understand how site visitors use our web site. This allows us to improve the quality and content on for our visitors. The aggregated statistical data cover items such as total visits or page views, and referrers to our web sites. For further details on our use of Google Analytics, see below.	Persistent, but will delete automatically after two years if you no longer visit https://bsr-co.in or https://bsr-co.com
Site visitor feedback	We use a third-party survey tool to invite a percentage of visitors to provide their feedback. Cookies are used to prevent visitors from being invited multiple times. The first cookie (1) is set if the visitor is not invited to participate in the survey and is used to ensure visitors are not invited after their first page view. The second cookie (2) is set if the visitor is invited to participate in the survey and is used to ensure the visitor is not invited again to participate for a period of 90 days.	1. Session Deleted upon closing the browser. 2. Persistent Deleted automatically after 90 days or presenting survey invite.
Social sharing	We use third party social media widgets or buttons to provide you with additional functionality to share content from our web pages to social media websites and email. Use of these widgets or buttons may place a cookie on your device to make their service easier to use, ensure your interaction is displayed on our webpages (e.g., the social share count cache is updated) and log information about your activities across the Internet and on our web sites. We encourage you to review each provider's privacy information before using any such service. For further details on our use of social media widgets and applications.	Persistent, but will be deleted automatically after two years if you no longer visit https://bsr-co.in or https://bsr-co.com

VIII. What are your data protection rights?

Right to access information about your personal data – You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.

Right to correction, completion, updation and erasure of personal data- You can ask us to correct, update our records if you believe they contain incorrect or incomplete information about you. Further, you can ask us to erase your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.

Right to Grievance Redressal – You have the right to have readily available means of grievance redressal in respect to any act or omission regarding the performance of our obligations in relation to the processing of your personal data, or the exercise of your rights. You can write to us at in-fmdpgrievofficer@bsraffiliates.com for redressal of any grievances in this regard. We shall respond to you within30 days.

Right to nominate in the event of death or incapacity- You may nominate an individual, who shall in the event of your death or incapacity exercise the right vested with you with respect to processing of your personal data by the Firm.

Right to Withdraw Consent - You can withdraw your consent that you have previously given to one or more specified purposes to process your personal data. The consequences of the withdrawal shall be borne by you and such withdrawal shall not affect the legality of processing of the personal data, based on consent provided prior to Withdrawal If you would like to exercise your rights by withdrawing your consent, you can write to us at in-fmprivacy@bsraffiliates.com . We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds, in which case this will be communicated to you.

IX. What about personal data security?

We have put in appropriate technical and organizational measures to comply with our obligations to safeguard your personal data. We aim to ensure that access to your personal data is limited only to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information. We may apply pseudonymization, de- identification and anonymization techniques in efforts to further protect personal data.

If you have access to parts of our websites or use our services, you remain responsible for keeping your user ID and password confidential. Please be aware that the transmission of data via the Internet is not completely secure. Whilst we do our best to try to protect the security of your personal data, we cannot ensure or guarantee the security of your data transmitted to our site; and any such transmission shall be at your own risk.

X. How long do we retain personal data

We retain personal data to provide our services, stay in contact with you and to comply with applicable laws, regulations and professional obligations that we are subject to. Unless a different time frame applies as a result of business need or specific legal, regulatory or contractual requirements, we retain such personal data as per the retention policy of the Firm.

XI. Do we link to other websites?

Our websites may contain links to other sites, including sites maintained by other firms that are not governed by this Privacy Statement. Please review the destination websites’ privacy notices before submitting personal data on those websites. Whilst we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites.

XII. Who can you contact for privacy questions or concerns?

If you have questions or comments about this Privacy Statement or how we handle your personal data, please direct your correspondence to the Firm’s Data Privacy team at in-fmprivacy@bsraffiliates.com.
We aim to respond within 30 days from the date we receive privacy-related communications.

If you are not satisfied with the response that you received, you may also contact the Firm’s Privacy Liaison at in-fmdatapl@bsraffiliates.com or the Privacy grievance officer at in-fmdpgrievofficer@bsraffiliates.com.