Privacy Policy

This policy was updated on 01 September 2026.

Introduction

This Privacy Policy explains how Tech Mahindra Limited, its affiliates and group entities (collectively, "Tech Mahindra", "TechM", "we", "us" or "our") process personal data through the Welcome Application. The Welcome Application supports onboarding of employees joining a Tech Mahindra subsidiary.

The Tech Mahindra entity through which an individual is registering, joining or being onboarded determines the purposes and means of the relevant processing and acts as the controller or data fiduciary, as applicable. Tech Mahindra Limited administers the Welcome Application and may also process personal data for group-level technology, security, compliance and support purposes.

Scope

This Policy applies to subsidiary onboarding employees who access or use the Welcome Application and to personal data processed in connection with their onboarding, identity verification, account activation, support and application security. A separate workforce privacy policy may apply to broader employment processing outside the Welcome Application.

Personal Data We Process

Category Data Elements
Identity Data Name and other identity details entered or made available for onboarding
Contact Data Email address and contact details required for onboarding communications
Employment and Onboarding Data Subsidiary association, onboarding status and information required to complete or verify onboarding
Verification Data Information used to verify details provided, including identity or employment-history details where permitted by law
Authentication Data One-time-password delivery and verification records, login events and session identifiers
Technical and Usage Data IP address, browser/device information, security logs, pages or features accessed and diagnostic data
Support Data Questions, service requests, correspondence and issue details

Purposes and Lawful Bases

Purpose Personal Data Used Applicable Basis
Provide and administer onboarding Identity, contact, employment and onboarding data Steps connected with employment or engagement; performance of contractual obligations; permitted employment-related processing; legitimate uses; consent where required
Verify information and authenticate access Identity, verification, contact, OTP, login and security data Legal or contractual requirements; legitimate interests in accurate records and secure access; consent where required
Communicate about onboarding and provide support Contact, onboarding and support data Contract-related necessity; legitimate interests in service delivery; legitimate uses; consent where required
Operate, secure, troubleshoot and improve the application Technical, usage, authentication and support data Legitimate interests in security, reliability, fraud prevention and service improvement
Meet legal, regulatory, audit and recordkeeping requirements Relevant identity, onboarding, verification, technical and communication data Compliance with legal obligations and permitted employment-related processing
Establish, exercise or defend legal claims Relevant records associated with a claim or investigation Legal obligations and legitimate interests in protecting rights and resolving disputes

Where consent is used, it will be requested by a clear affirmative action for specified purposes. Consent may be withdrawn at any time through the contact listed in the Contact and Grievance Redressal section.

Withdrawal does not affect processing lawfully completed before withdrawal. If required information is not provided, Tech Mahindra may be unable to complete the relevant onboarding, verification, account or support activity.

How We Share Personal Data

Access is limited to recipients that need the information for an authorized purpose. Depending on the onboarding activity, recipients may include:

Service providers must process personal data only for authorized purposes and under applicable confidentiality, security, contractual and legal obligations. Tech Mahindra does not sell personal data processed through the Welcome Application.

International Data Transfers

The Welcome Application may involve access to or processing of personal data outside the country in which the data was collected, including within the Tech Mahindra group or by approved service providers.

Where applicable law requires transfer safeguards, Tech Mahindra uses a legally recognized mechanism, such as an adequacy decision, standard contractual clauses, an applicable data-transfer agreement or another approved safeguard.

Retention and Deletion

Personal data is retained only for as long as necessary for onboarding, verification, account administration, security, support, audit, legal compliance, dispute resolution and enforcement of agreements.

When data is no longer required, Tech Mahindra deletes it, anonymizes it or securely isolates it until deletion is possible.

Cookies and Similar Technologies

The Welcome Application may use cookies, session tokens and similar technologies for authentication, secure session management, request routing, security and operation of the application.

Strictly necessary technologies do not ordinarily require optional consent because the service may not function securely without them.

The exact live cookie inventory, provider and expiry must be displayed through the Cookie Policy or cookie settings and updated whenever the application or its providers change.

Security and Incidents

Tech Mahindra applies appropriate technical and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access.

Measures may include access controls, authentication, encryption in transit, logging, monitoring, vulnerability management, backup controls, supplier due diligence, training and incident-response procedures.

No online service is completely secure. Suspected unauthorized access, loss or abuse should be reported promptly through an approved Tech Mahindra incident channel or to dpo@techmahindra.com.

Individual Rights

Right Description
Access and Information Ask whether personal data is processed and obtain information or a copy.
Correction and Completion Correct inaccurate data and complete incomplete data.
Erasure Request deletion where a legal ground for deletion applies.
Restriction Request restriction of processing where recognized by applicable law.
Portability Receive eligible data in a structured, commonly used, machine-readable format.
Object Object to eligible processing based on legitimate interests or direct marketing.
Withdraw Consent Withdraw consent without affecting processing completed lawfully before withdrawal.
Grievance Redressal Raise a privacy grievance with Tech Mahindra.
Nomination under Indian Law Nominate another individual to exercise applicable rights in the event of death or incapacity.
Complaint Complain to the competent data-protection authority or statutory body.

To exercise a right or raise a grievance, email dpo@techmahindra.com with the subject "Welcome Application Privacy Request".

Automated Decision-Making

The Welcome Application is not intended to make decisions based solely on automated processing that produce legal or similarly significant effects.

Children

The Welcome Application is intended for workforce onboarding and is not directed to children. Tech Mahindra does not knowingly collect personal data from children.

Your Responsibilities

Contact and Grievance Redressal

Tech Mahindra Data Protection Office / Grievance Contact
Email: dpo@techmahindra.com

Include the relevant Tech Mahindra subsidiary, onboarding reference if available, country of residence, the request or grievance and a preferred contact method.

Changes to this Policy

Tech Mahindra may update this Policy to reflect changes in the Welcome Application, processing activities, service providers, legal requirements or privacy practices.

The revised Policy will be posted with an updated effective date. If a change materially affects individuals or requires new consent, Tech Mahindra will provide additional notice or obtain consent before the new processing begins where required.