1. Introduction

At Nagarro, we recognize the importance of your personal privacy and are committed to safeguarding it. Our Global Privacy Notice provides comprehensive details on how Nagarro and its group companies (“Nagarro,” “we”) process your personal data and outlines your rights concerning this processing. This Privacy Notice applies to all Nagarro entities and their business operations.

We adhere to the highest standards of data protection and comply with all relevant data protection laws. For information specific to certain jurisdictions with unique requirements, please refer to the relevant section of our Privacy Notice.

This policy applies specifically to visitors of this domain and explains how we collect and use data through this site, including the use of cookies and third-party tools for analytics, marketing, and scheduling. For more general information, please refer to the Global Privacy Policy on our corporate website.

2. Website Visitors

Nagarro collects personal data at its websites in two ways: (1) directly (for example, when you provide personal data to sign up for a newsletter or register on website); and (2) indirectly (for example, through our website’s technology such as cookies and web beacons).

2.1. Categories Of The Personal Data Processed

Nagarro may collect your personal data directly from the website visits and some information will be collected automatically. Nagarro may use, store, and track your personal data within our Customer Relationship System (CRM)/Content Management System (CMS) to effectively manage our website operations.

We may collect or process (or may have collected or processed in the preceding 12 months) the following categories of personal data:

• Contact Information: The information provided by you directly via the contact form

• Diagnostic Information: Automatically collected from your device by the website such as internet protocol (IP) addresses, region or general location where your computer or device is accessing the internet, browser type, operating system

• Usage Information: Information about your use of Nagarro’s website, including history of the pages you view, browsing time, navigation behavior, click tracking, and resources you access or download

• Interaction Information: Provided by you such as any query, form submissions, survey, comment, or upload any content on our website

• Preference Information: User-provided preferences for receiving communications about our activities, publications, and details about how you engage with our communications

• Chatbot Interaction Information: When you engage with our AI chatbot, we may collect your messages, interaction timestamps, anonymized session identifiers, and usage patterns to improve the chatbot experience and provide relevant support.

We are dedicated to protecting your privacy and want to assure you that our website does not intentionally collect sensitive personal information. Sensitive personal information includes data such as your ethnic origin or race, marital status, political opinions or affiliations, ideological views or activities, trade union membership, religious beliefs, physical or mental health, genetic or biometric information, sexual orientation, social security details, or information about administrative or criminal proceedings. To ensure your privacy, we advise that you refrain from providing any of this sensitive personal information through our website.

2.2. Purpose Of Personal Data Processing

We use your personal data solely for the purposes specified below and will not use it for any other purposes:

• Identify you once you register on our website and to provide better usability, troubleshooting, and site maintenance

• Enable marketing and sales-related communications and related purposes

• Offer curated content tailored to your preferences

• Know your interest in participating in marketing and promotional events

• Facilitate communication with you, including contacting you and responding to your queries or requests

• Monitor and enhance the performance of AI-driven chatbot interactions and personalize support based on user behavior

2.3. Legal Basis Of Processing

The applicable privacy and data protection laws provide for certain justifiable grounds for collection and processing of personal data, commonly referred to as legal basis of processing. We primarily rely on the following legal bases:

• Consent: Nagarro may need to obtain your explicit consent for processing your data when it does not fall under legitimate interests or other legal bases. You have the right to withdraw your consent at any time. To do so, you can click the “Unsubscribe” link, update your preferences, or contact our global data privacy team at globalprivacy@nagarro.com.

• Legitimate Interest: Nagarro may use this legal basis to administer usage of our website and your interaction with the website.

3. Children’s Privacy

This website is not intended for children under eighteen (18) years. We do not knowingly collect, disclose, or otherwise process the personal data of children under 18 years of age through our website.

4. Transfer Of Personal Data To Third Parties

Your data collected on the website is stored on HubSpot servers hosted in the EU region. We may also use trusted third-party service providers, including:

• Google Analytics (for performance and usage tracking)

• Calendly (to facilitate scheduling)

• Plerdy (for behavior analytics and conversion tracking)

• Chatbase (to power our website’s AI chatbot functionality and collect interaction data)

• Framer (website hosting and platform)

Each third-party tool is used in accordance with its own privacy policy and applicable data protection standards.

5. Cookies

To enhance your experience on our website, we may use cookies. A cookie banner is displayed to inform you that cookies may be stored on your device.

Cookies are small pieces of data that a website sends to your computer’s web browser while you are navigating through it. Cookies serve many purposes, but mainly, they enable you to navigate between pages easily, remember your preferences, and eventually improve user experience. These cookies stored on your machine can also help identify your computer. Cookies used on this website can be either set up by our website or by a third-party website. Moreover, these cookies can be “session” or “persistent” cookies: a session cookie is a cookie that is automatically deleted when the user closes the browser, whereas a persistent cookie is a cookie that remains stored in the user’s terminal device until it reaches a defined expiration date.

Nagarro also uses cookies to improve the quality of our service, including logging in, storing your preferences, and tracking your web page visits and actions. Kindly note that Nagarro does not currently respond to Do Not Track (DNT) signals from your web browser.

For more details on tracking technology, please visit our Cookie Policy.

6. Third-Party Links

Our Site may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. Please review their policies before providing personal information.

7. Marketing Activities

Nagarro may send you sales and marketing emails to develop or maintain a business relationship in accordance with applicable marketing laws. Our targeted e-mail messages typically include web beacons, cookies, and similar technologies that allow us to know whether you open, read, and click on any links. Based on your interactions with our website, you may receive targeted advertisements from Nagarro on platforms such as LinkedIn, Twitter, Facebook, and Google. We tailor these ads to match your interests and preferences, ensuring relevant content.

8. Transfer Of Personal Data

Nagarro may engage third parties as processor for certain data processing tasks, but this does not diminish our responsibility to ensure privacy compliance. Nagarro remains fully accountable for the actions of any processor acting on its behalf. Nagarro ensures that a data processing agreement is in place with processors, which mandates adequate privacy and security measures to protect personal data and address data subject requests.

In addition, Nagarro has implemented appropriate safeguards when transferring personal data to jurisdictions that do not provide equivalent data protection as required by the applicable laws. These safeguards help maintain robust data protection standards and ensure compliance with relevant regulations.

Nagarro has a data-sharing framework that facilitates data transfer between the Nagarro group companies. Nagarro does not sell or share your Personal Information with third parties for their direct marketing purposes.

9. Security And Privacy Of Personal Data Processing

Nagarro has a well-established privacy program designed to comply with applicable privacy laws and implement effective privacy controls. The privacy program includes establishing and maintaining data privacy framework, conducting Data Protection Impact Assessments (DPIAs), managing Data Subject Rights, and providing comprehensive Data Privacy Training.

Nagarro employs comprehensive security controls, encompassing administrative, physical, and technical measures, to safeguard your personal information. Nagarro’s ISMS is ISO 27001:2022 certified, demonstrating adherence to the highest standards of information security. Nagarro’s practices are designed to meet its clients’ security controls and industry standards for data security and privacy, ensuring robust protection of your personal data.

10. Retention Of Personal Data

Personal data will not be retained for longer than necessary to fulfill the purposes described in this privacy notice, unless a longer retention period is mandated by law or for legitimate business reasons. Once personal data is no longer required for legal or business purposes, it will be securely disposed of to ensure its protection.

11. Your Data Privacy Rights

Subject to the laws of your country, you may have certain rights as a data subject including but not limited to right to information, access, rectification, erasure, object, restriction of processing, right to lodge a complaint with a supervisory authority, relating to your personal data that we process.

You can raise any concerns regarding the processing of your personal data by contacting us at dpo@nagarro.com. To help protect your privacy and security, Nagarro will take reasonable steps to verify your identity before taking steps to execute your rights e.g. access to your personal data. When Nagarro receives your request, Nagarro will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests, as may be required by applicable law.

Depending upon the circumstances and the request, Nagarro may not be permitted to provide access to personal data or otherwise fully comply with your request. Nagarro reserves the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/ or to deny your requests in case your request is unfounded, excessive or otherwise unacceptable under applicable law.

12. California Consumer Privacy Act Privacy Note

Nagarro is committed to complying with the strictest data protection laws applicable in each jurisdiction where we operate or conduct business with clients. If you are a resident of California, this section of our policy applies to you (in addition to the Nagarro Global Privacy Notice) under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

For purposes of this section “Personal Information”, “Business”, and “Consumer” has the meaning given in the California Consumer Privacy Act (“CCPA”). For California consumers, the CCPA requires businesses to disclose about Personal Information processing and their rights such as:

Don’t Sell and share Personal information

Nagarro does not sell Personal Information, however, we may share Personal Information with authorized service providers or business partners who are bound by contractual limitations regarding their retention, use, and disclosure of such Personal Information. Nagarro may share your Personal Information within Nagarro or with any of its affiliates, Business partners, Service providers; Auditors, and government authorities, where applicable.

Kindly note that Nagarro does not offer any financial incentives, price, or service differences in exchange for personal information. Therefore, we are not required to provide a Notice of Financial Incentive under the CCPA/CPRA.

Limit use and disclosure of sensitive information, Alternative Opt-out

Nagarro values your privacy and does not collect California residents’ sensitive personal data unless necessary.. To exercise your data subject rights, including limiting the use and disclosure of sensitive information or opting out, please reach out at dpo@nagarro.com.

Right to non-discrimination

Nagarro is committed to protecting your privacy rights under the California Consumer Privacy Act (CCPA). We will not discriminate against you for exercising any of your CCPA rights. This means we will not deny you goods or services, charge you different prices or rates, or provide a different level or quality of goods or services as a result of exercising your rights under the CCPA.

If you are a resident of California and you wish to exercise your data subject rights as called out above, please refer to section “Your Data Privacy Rights.”

13. Contact Your Local Data Protection Authority

If you are unhappy with how we safeguard your personal data, depending on the laws of the countries where you reside, you have the right to bring a complaint to your local data protection authority.

14. How To Contact Us

If you have any questions, concerns or complaints about this privacy policy or our privacy practices, please contact Nagarro data protection officer:

Email: dpo@nagarro.com

Mail correspondence: Baierbrunner Straße 15, 81379 Munich, Germany

15. Modification Of The Privacy Notice

Nagarro reserves the right to update our data privacy practices and revise this notice as needed. Nonetheless, our commitment to safeguarding your privacy and protecting your data remains unchanged. Please note that this privacy notice will regularly be updated to reflect any changes in the way we handle your personal data or any changes in applicable laws.