[This notice describes how personal information about you may be used and disclosed and how
you can get access to this information. Please review it carefully.]
I. Wipro Limited (“we” or “us”) respects and is committed to the protection of your Sensitive
and Personal Information and your privacy. This Personal Data Protection Notice (“Notice”),
prepared in accordance with the applicable laws of GDPR, explains how Wipro processes your
personal data as part of the Winners’ Circle platform. This Notice supplements but does not
supersede nor replace any other consent(s) you may have previously provided to us in respect to
your personal data.
IDENTITY OF THE Entity collecting the personal data: Your employer will be your primary
data controller for all employment related data processing activities.
II. DEFINITIONS
For the purposes of this Notice:
i. “Affiliates” means Wipro Limited and/or related companies, including their related
companies;
ii. “Partner(s)” means customer(s), vendor(s), authorized service partner(s) and/or business
partner(s);
iii. “Personal data” shall mean data, whether true or not, about an individual who can be
identified from that data, or from that data and other information to which the organization has or
is likely to have access.
iv. “Processing” means any operation or set of operations which is performed upon personal
data, whether or not by automatic means, such as collection, recording, organization, storage,
adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or
otherwise making available, alignment or combination, blocking, erasure or destruction.
All further data protection relevant terms depend on Art. 4 GDPR.
III. WHAT PERSONAL DATA DO WE PROCESS?
The Winner’s Circle application collects the, the following categories of personal data:
[Employee name, Employee corporate email address, Date of joining, information
associated with usage of Winner’s circle services such as awards, points, gift vouchers etc. ]
IV. PROCESSING PURPOSE(S)
As part of the Winner’s Circle Program, we will process your Personal Data, for the following
purposes:
[Receiving and giving our rewards as per the Winners’ Circle program, company feed posts
view, email notifications for receiving and giving out awards and appreciations, delivery of
points related to awards via corporate email address, viewing Winners’ Circle leaderboard,
viewing of monetary and non-monetary awards received by Colleagues, viewing of virtual wallet
and points statement, redemption of Gift vouchers associated with rewards received (as points),
service anniversary feed view, service anniversary notifications with associated points (if any).
The amount of data collection will depend on the extent you utilize the Winner’s Circle
application and its various facilities.
V. RECIPIENTS OF PERSONAL DATA
Our Partners and Affiliates for the purposes of collecting and using your personal information as
described in this Notice are as follows:
i. Usage & Sharing: Your personal data, including sensitive personal will be shared only with
certain Wipro employees and/or vendor partners who have a legitimate business need & and are
authorized to access such data in connection with the above stated purpose(s).
ii. Categories of recipients internal to Wipro:
[Winners’ Circle Program team]
iii. Categories of recipients external to Wipro:
[The service provider that manages the Winner’s Circle application for Wipro will have access to
information to the extent necessary for administration and system management purposes,]
iv. Data transfer to a recipient outside the European Union:
[Yes, data will be transferred outside of the European Union to a third party service provider.
Once data is received by Vantage Circle, only System Admin will have access to this data within
Vantage Circle.
VI. DATA RETENTION
Winners’ Circle team will retain data for 6 month. Once confirmed, Vantage Circle team will
apply this procedure
VII. YOUR RIGHTS
Under the General Data Protection Regulation (“GDPR”) and relevant EU member state law
thereunder, you have a number of rights with regard to your personal data and in this respect, you
have the following rights which will be subject to the applicable data protection laws.
i. You have the right to check whether we hold or use your Personal Data and request access to
such data
ii. You have the right to obtain rectification of inaccurate personal data
iii. You have the right to obtain the erasure of personal data under the conditions of Art. 17
para 1 lit. a – f GDPR
iv. You have the right to obtain restriction of processing under the conditions of Art 18 para. 1
lit. a – d GDPR
v. You have the right to data portability under the conditions of Art. 20 GDPR
vi. You have the right to object to processing of personal data under the conditions of Art. 21
GDPR
vii. You have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR)
viii. You have the right to withdraw your consent at any time with effect for the future under
the individual conditions of the consent.
Your written request for access to Personal Data or correction and/or deletion of Personal Data or
for information regarding policies and procedures and types of Personal Data handled by us
including how we store and transfer it can be directed to us at [Winners’ Circle team]. You
may also contact the EU data privacy officer at dpo-europe@wipro.comfor any data privacy
concerns.
