Last Updated : 1st December, 2024

At Sarla Aviation Private Limited ("Company," "we," "our," or "us"), an entity registered under the Indian Companies Act, 2013 bearing Corporate Identification Number U30305KA2024PTC183670, and, with its principal place of business located at Bengaluru, Karnataka, India, we are committed to safeguarding the privacy and personal data of all individuals who engage with us.

This Privacy Policy governs the collection, use, storage, disclosure, and protection of information provided to us by:

• Visitors to our website,

• Individuals applying for career opportunities with us, including citizens of any country, and

• Other parties who interact with our services or platforms, either directly or indirectly.

Our Privacy Policy has been made in compliance with applicable Indian data protection laws, including the Digital Personal Data Protection Act, 2023, Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules"). In addition, it aligns with global data privacy standards, ensuring robust data protection practices regardless of jurisdiction.

We recognize the importance of your personal information and are dedicated to transparency, accountability, and lawful data processing. This policy outlines:

• The types of personal and sensitive data we may collect;

• The purposes for which such data is used;

• How we ensure compliance with relevant legal and regulatory frameworks; and

• Your rights regarding the access, correction, and deletion of your data.

By interacting with our website, submitting applications for employment, or otherwise engaging with us, you acknowledge that you have read and understood this policy. If you do not agree with any terms herein, we advise you to refrain from using our website or any services herein.

For any queries or concerns regarding this Privacy Policy, or if you wish to exercise your rights under applicable laws, please refer to the Contact Information section below to reach our designated Grievance Officer.

Data We Collect

At Sarla Aviation Private Limited, we collect and process various categories of personal data to deliver our services, manage career applications, and improve user experience. The types of data we collect include but are not limited to:

• Personal Identification Information

  • Full Name, Gender, Email Address, Phone Number

• Career-Related Information

  • Curriculum Vitae (CV), Qualifications and Certifications, Employment History, References and Portfolio Links, Expected Salary Details

• Usage and Activity Data

  • Time Spent on the Website, Pages Viewed, Interaction Logs (e.g., clicks, searches, navigation patterns)

• Technical Information

  • Internet Protocol (IP) Address, Browser Type and Version, Device Information (e.g., operating system, screen resolution)

• Communication Data

  • Feedback, queries, or messages submitted via website forms or email communication.

• Preference and Survey Data

  • User Preferences (e.g., product interests, subscriptions), Survey Responses

• Cookies and Tracking Data

  • Browsing Behaviour (e.g., location, browsing history, interactions with advertisements), Cookies used for analytics, performance tracking, and user personalization

• Special Categories of Data

  • Nationality (for regulatory or compliance purposes), Identity Proof Documents (e.g., Passport, Aadhaar, PAN, or equivalent)

Purpose of Data Collection and How we Use it

At Sarla Aviation Private Limited, we collect personal data for specific, lawful, and transparent purposes. Our data processing practices are designed to ensure that we meet legal obligations and protect the rights of individuals while enhancing the experience of our website visitors, potential employees, and other stakeholders. We process personal data in compliance with the Digital Personal Data Protection Act, 2023 and other applicable laws, ensuring transparency and minimizing risks.

When you interact with our website or submit your personal details, such as name, email address, or CV, the data is processed primarily to provide you with the services you have requested or to manage career opportunities with us. For example, if you apply for a position at Sarla Aviation, we collect your name, contact information, CV, and other employment details to evaluate your suitability for the role. The data is processed only for this purpose and retained for as long as necessary for recruitment purposes, after which it is securely deleted if no longer required.

Your email address, for instance, may be used to send you updates about your job application status or respond to queries you have submitted through the website. In addition, if you opt-in, your email address will be added to our mailing list to receive newsletters, promotional material, and updates regarding our services and innovations in the eVTOL industry. You have the right to withdraw your consent for receiving marketing communications at any time, and we make it easy for you to unsubscribe from these communications with just a click.

We also collect data related to your interactions with our website, such as time spent on different pages or areas of interest, in order to improve user experience and optimize our website’s performance. This helps us tailor the content, layout, and functionality of the website based on user behaviour and preferences. For instance, by analysing which areas of the site users visit most frequently, we can prioritize enhancements or introduce new features that cater to the needs of our visitors.

In addition to improving user experience, we may use the data to monitor and protect our website from potential security threats, ensuring that your personal data remains safe from unauthorized access or misuse. We also process personal data for compliance with applicable legal requirements, such as verifying the identity of individuals for security or regulatory purposes, such as when a user submits an identity proof document.

We understand that the security and confidentiality of your personal data is of utmost importance. Therefore, we take all reasonable steps to protect your data from misuse, loss, or unauthorized access. Our data processing practices are designed to minimize risks, and we ensure that only authorized personnel have access to your data when required.

However, please note that in the event of a personal data breach, we are obligated to inform the affected individuals and the Data Protection Board promptly, as required by law. This ensures that appropriate steps can be taken to mitigate any harm or impact.

In processing your data, we strictly adhere to the principle of data minimization. We collect only the data necessary for the purposes stated above. If any other uses of your personal data are identified, we will seek your explicit consent before processing such additional information.

Finally, it is important to clarify that by providing your personal data through our website or other channels, you acknowledge and consent to the use of your information as outlined in this privacy policy. We also emphasize that your data will never be shared with third parties without your express consent, except where necessary for operational purposes (e.g., third-party service providers for website maintenance, email distribution, or payment processing) and in compliance with applicable laws.

We are committed to safeguarding your privacy and ensuring that your data is processed in a lawful, fair, and transparent manner. Should you have any concerns about how your data is processed or wish to withdraw consent at any time, please contact us through the channels provided in our Contact Information section.

Legal Basis for Processing Data

At Sarla Aviation Private Limited, the processing of personal data is conducted strictly in accordance with the legal bases set forth under the Digital Personal Data Protection Act, 2023 (“Act”) and other Laws & Regulations. Each instance of data processing is anchored in lawful purposes, ensuring transparency, accountability, and compliance with applicable laws while safeguarding the rights of individuals.

Consent-Based Processing

In compliance with Section 4(1)(a) of the Act, personal data is processed with the explicit and informed consent of the data principal (the individual to whom the data relates). Consent is obtained through a clear affirmative action, and the data principal is informed about:

• The specific data being collected,

• The purpose of its collection,

• The manner in which rights can be exercised, and

• The process to withdraw consent, as per Sections 5 and 6.

For example, when a user submits their CV for a job application, or an website user enters email id for receiving news from us, they are explicitly consenting to the use of their data for evaluating their suitability for employment or sending relevant promotional or news related items of the Company or industry. If at any point the user wishes to withdraw consent, they can do so easily, and we will cease processing their data except where retention is mandated by law

b.Processing for Legitimate Uses

As permitted under Section 7, certain data is processed without requiring explicit consent for purposes deemed legitimate under the Act, such as:

• Regulatory Compliance: Personal data may be processed to comply with applicable laws and regulations. For instance, identity documents like Aadhaar or passport numbers may be collected and processed to meet aviation industry safety standards or other statutory obligations.

• Security Measures: Technical data such as IP addresses may be processed to prevent cyberattacks or unauthorized access, ensuring the safety of digital systems and data.

• Grievance Redressal: Data submitted through website forms or communication channels may be processed to respond to user inquiries or complaints effectively.

c. Performance of Contractual Obligations

Under Section 4(1), processing is lawful if necessary to execute a contract or agreement with the data principal. For example:

• Data provided by job applicants is processed to evaluate their qualifications and fulfil recruitment objectives.

• Email addresses and contact numbers are used to communicate with candidates regarding their application status or employment offers.

d. Compliance with Legal Obligations

In accordance with Section 7(d), data is processed to comply with judgments, decrees, or legal orders. For instance, if regulatory authorities require records of employee qualifications or identity verification for compliance audits, such data is lawfully disclosed to fulfil those obligations.

e. Retention and Minimization

We ensure that data is retained only as long as necessary to achieve the specified purposes or comply with applicable laws, as required by Section 8(7). For example, CVs of applicants who are not selected for a role are securely deleted once the recruitment process concludes unless statutory obligations require otherwise.

f. Accountability and Security

Under Section 8(4), we adopt appropriate technical and organizational measures to ensure compliance with the Act. Personal data is safeguarded against breaches through robust encryption, secure storage systems, and controlled access measures.

By adhering to these legal bases for processing data, Sarla Aviation Private Limited ensures that personal data is processed responsibly, in compliance with the Act, and in a manner that balances individual rights with legitimate business needs.

User Rights

At Sarla Aviation Private Limited, we value your rights as a data principal under the Digital Personal Data Protection Act, 2023, and other applicable laws. We are committed to providing you with tools and processes to exercise these rights effectively, ensuring your privacy and control over your personal data. Below, we outline your rights and how you can exercise them.

• 1. Right to Access Personal Data

  • You have the right to request a summary of the personal data we process about you. This includes details about the type of data collected, the purpose of processing, and any third parties with whom your data has been shared..

• 2. Right to Correction and Updating

  • If any personal data we hold about you is inaccurate, incomplete, or outdated, you can request that it be corrected or updated.

• 3. Right to Erasure

  • You can request the deletion of your personal data when it is no longer required for the purposes for which it was collected or when you withdraw your consent

• 4. Right to Withdraw Consent

  • Where data processing is based on your consent, you have the right to withdraw it at any time. The withdrawal will not affect the legality of data processing that occurred before the withdrawal.

• 5. Right to Data Portability

  • If technically feasible, you can request a copy of your personal data in a commonly used, machine-readable format. This allows you to transfer your data to another service provider, ensuring you maintain control over your information.

• 6. Right to Grievance Redressal

  • You have the right to raise a grievance if you believe your data has been mishandled or if we have not adequately addressed your concerns. We provide a user-friendly mechanism to file complaints, and you will receive a response within a reasonable time as prescribed under the Act.

• 7. Right to Nominate

  • In the event of your incapacity or death, you can nominate another individual to exercise your rights on your behalf.
    
    

How to Exercise Your Rights

To exercise any of the rights outlined above, you may contact us. Please include specific details about your request so that we can process it efficiently. For security purposes, we may require you to verify your identity before fulfilling your request.

In some cases, certain rights may be subject to limitations as permitted under the law, such as data required to comply with ongoing legal obligations or protect legitimate interests.

No Collection of Payment Information

Sarla Aviation Private Limited does not collect, process, or store any payment-related information from its users. We do not request or handle financial details such as credit card numbers, debit card details, UPI IDs, bank account numbers, or any other payment-related credentials.

Our website and services are designed solely for informational purposes, recruitment, and operational interactions, and we do not engage in any direct financial transactions with our users through our platform. Should any payment-related interaction be required in the future, it will be conducted through authorized third-party platforms, and details of such arrangements will be explicitly disclosed.

If you encounter any request for payment information purporting to be from Sarla Aviation, please report it immediately to us through the Contact Information provided in this Privacy Policy.

Security Practices and Procedures

At Sarla Aviation Private Limited, we implement robust technical and organizational measures to protect your personal data from unauthorized access, loss, alteration, or misuse. Our practices include:

• Encryption: Sensitive data is encrypted during transmission and storage.

• Access Controls: Data access is restricted to authorized personnel only, based on operational requirements.

• Regular Audits: We conduct periodic security assessments to identify and mitigate risks.

• Incident Response: In the event of a data breach, affected individuals and the Data Protection Board will be notified promptly, as per legal requirements.

While we take every reasonable step to secure your data, no system is entirely foolproof. We encourage users to report any suspicious activities immediately through the Contact Information provided in this policy.

Cookies and Tracking Technologies

Sarla Aviation Private Limited uses cookies and similar tracking technologies to enhance your browsing experience, analyse website traffic, and improve our services. Cookies help us understand user behaviour and preferences, enabling us to tailor our content accordingly.

We do not use cookies to collect sensitive personal data or track users for targeted advertising. You can manage your cookie preferences through your browser settings, including disabling cookies if desired. However, disabling cookies may impact certain functionalities of our website.

Governing Law and Jurisdiction

This Privacy Policy is governed by and construed in accordance with the laws of India, including the Digital Personal Data Protection Act, 2023, and other applicable laws.

Any disputes arising from or relating to this Privacy Policy shall be subject to the exclusive jurisdiction of the courts located in Bengaluru, Karnataka, India.

Changes to This Privacy Policy

Sarla Aviation Private Limited reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or other operational needs.

If we make material changes, we will notify users through prominent notices on our website or by email (where applicable). The updated Privacy Policy will include the "Last Updated" date for transparency.

Contact and Grievance Redressal

If you have any questions, concerns, or complaints regarding this Privacy Policy or the handling of your personal data, please feel free to contact us at: hello@sarla-aviation.com

For grievances related to your data privacy right, you may reach out to our designated Grievance Officer:

Mr. Vikash Singh
Email : Vikash.singh@sarla-aviation.com