Spectrum Talent Management Limited including its subsidiaries or affiliated companies (hereinafter collectively referred to as “Spectrum”, “Company”, “We”, “Us”, “Our”) is dedicated to protecting and respecting the individual’s legal rights of privacy and data protection while collecting, storing, using and transmitting the Personal Data to provide our recruiting, employment, outsourcing, and consulting services.

This Privacy Policy (“Policy”) provides a framework of understanding of Our privacy and data protection practices and sets out how We collect, use, process, disclose and transfer the Personal Data, across our website, www.stmpl.co.in, other sites We own and operate, mobile applications and Spectrum HR Platform (collectively, the “Platform”) of the individuals who browse, or access the Platform or provide information on or through the Platform in connection with its services (“Services”) (hereinafter, collectively referred to as “You”, “Your”). The Company will make every effort to protect such personal information through the accurate and safe handling thereof in accordance with this Policy as well as the laws and regulations applicable to personal information and related guidelines.

This Policy applies to all individuals (including our clients, the individuals whose personal information is collected from clients or other third parties, job applicants and prospective employees) who provide Us with their Personal Data.


Information We collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information.
“Voluntarily provided” information refers to any information You knowingly and actively provide Us when using or participating in any of Our services and promotions.
“Automatically collected” information refers to any information automatically sent by Your devices while accessing Our products and services.


When You visit our website, Our servers may automatically log the standard data provided by Your web browser. It may include Your device’s Internet Protocol (IP) address, Your browser type and version, the pages You visit, the time and date of Your visit, the time spent on each page, and other details about Your visit.
Additionally, if You encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about Your device, what You were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.
Please be aware that while this information may not be personally identifiable by itself, it may be possible to combine it with other data to personally identify individual people.


We collect device data such as information about Your computer, phone, tablet, or other device You use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.


We collect location data such as information about Your device’s location, which can be either precise or imprecise. How much information We collect depends on the type and settings of the device You use to access the Services. For example, We may use GPS and other technologies to collect geolocation data that tells Us Your current location (based on your IP address). You can opt out of allowing Us to collect this information either by refusing access to the information or by disabling Your location setting on Your device. However, if You choose to opt out, You may not be able to use certain aspects of the Services.


Depending upon the Services You avail and the manner You interact with Us, We may use and collect the Personal Data. The following categories of the Personal Data is collected by Us to provide better services and offerings to You.

1. Contact Information: This category includes data such as name, age, gender, email address, password, country, city, contact number.

2. Recruitment purposes: Your previous work history, performance appraisals, qualifications, information about incidents in the workplace, health information, personal history, opinions from referees, information in relation to absences from work due to leave, illness or other causes and our assessment of You as a prospective candidate for recruitment, including any psychometric or skills testing.

3. Unique identifiers: This category includes data such as customer number, account number, subscription number, rewards program number), system identifiers (including username or online credentials), device advertisers, advertising IDs and IP address.

4. Government-issued identification information numbers: This category includes data such as social security number, driver’s license number, and passport number. Further, we may collect any Personal Data that would be required by the Company to ensure compliance with any applicable laws.

5. Financial information: Data such as bank account number and details and payment card information and other ancillary information that is required to fulfil contractual, legislative, filing and reporting obligations (including the payment of salary and wages).

6. Transaction and Commercial Information: This category includes data such as customer account information, qualification data, purchase history and related records (returns, product service records, records of payments, credits etc.), records related to downloads and purchases of products and applications, non-biometric data collected for consumer authentication (passwords, account security questions), customer service records.

7. Inferred Information derived from other information listed in this section: We create inferred and derived data elements by analysing our relationship and transactional information.

8. Online & Technical Information, including internet or other electronic network activity information: This category includes data such as IP address, MAC address, SSIDs or other device identifiers or persistent identifiers, online user ID, encrypted password, device characteristics (such as browser information), web server logs, application logs, browsing data, viewing data, website and app usage, cookies, web beacons, clear gifs and pixel tags.

9. Other Information: We may collect Your information such as name, age, contact details, preferences, etc. through surveys and forms, when You choose to participate in these surveys etc. When You communicate with or use the Platform to communicate with other users (such as partners) on our platform, We collect information about Your communication and any information You choose to provide.

10. Cookies: When You visit the Platform, We use cookies to automatically collect, store and use technical information about Your system and interaction with Our Platform.

11. Permissible information: To the extent permitted by law, the Company may record and monitor Your communications with Us to ensure compliance with our legal and regulatory obligations and our internal policies. This may include communications through telephone, by email, via the contact form, via a link contained in an email sent by us or via some other electronic message offered to you, via the chat function, web care, surveys or (panel) surveys, the (mobile) website, if you sign up for newsletters or via social media. This may also include recording of telephone conversations.

12. Collection of anonymized data: We may also collect and/or generate anonymized and aggregated information from Your use of the Platform. The anonymized or aggregated information is not Personal Data since We are not able to re-identify You using any means available to Us from that anonymized or aggregated information. The anonymized and aggregated information is used for a variety of functions, including to help Us identify and remediate any bugs, and to improve the performance of Our Platform. We may share this information with third parties for Our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying You.‍


1. Our use of Your Personal Data shall depend on the purpose for which You have interacted with Us. Below is the list of purposes for which We may process Your Personal Data:

  • – Creation of Your account and sending You the agreements or other promotional materials;
  • – Facilitation of payment, in connection with chargeable Services or your employment/engagement with the client, as the case may be;
  • – Automated processing in order to provide Our Services;
  • – Enhancing and optimizing Our Services and improving the users experience and the quality of Our Services and Platform;
  • – Handling of complaints, questions, disputes and participation in social media;
  • – Acceptance and issuing of offers to current and potential clients and performance of contracts with the Company.


2. We may also use the Personal Data for the purpose of the following:

  • – Analysing market trend and/or conducting research;
  • – Communicating marketing or promotional information about Our products and Services, which could be done directly, but also for instance via social media campaigns on Facebook, for example, and/or search engines like Google. Preventing, detecting, investigating and taking action against crimes, any other illegal activities, suspected fraud, or violations of Company’s Terms of Service in any jurisdiction;
  • – Establishing, exercising or defending legal rights in connection with legal proceedings and seeking professional or legal advice in relation to such legal proceedings
  • – Complying with any applicable law, regulation, legal process or enforceable governmental request.


3. We generally collect the Personal Data to provide the Services requested by You or to fulfil Your request. Where additional, optional information is sought, You will be notified of this at the point of collection. Further, We process the Personal Data, so long as We have a ground under the law to do so. Accordingly, We process the Personal Data based on one of the following conditions:

  • – Performance of a contract: Herein, We process the Personal Data as it is necessary in order to fulfil Our obligations set forth under a contract or for the performance of Our agreement with You;
  • – Legal obligation: Herein, We process the Personal Data in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;
  • – Legitimate interests: Herein, We process Your Personal Data information where it is in Our legitimate interest in running a lawful business. We will only rely on such a ground where an assessment has been performed balancing the interests and rights involved and the necessity of the processing in order to provide our Services, products and features to You. Few examples of Our legitimate interests are: (i) to offer information and/or services to individuals who visit the Platform or (ii) to prevent fraud or criminal activity and to safeguard our IT systems etc; In some cases, we will ask You for Your specific permission to process Your Personal Data and we will only process Your Personal Data in this way if you agree to us doing so. You may withdraw your consent at any time by requesting Us at info@stmpl.co.in


4. To the extent permissible under the applicable law, We may use and disclose any non-personal data (data which is does not contain any information that can be used to identify natural person) for any purpose, any non-personal data. However, in the event We combine any non-personal data with Personal Data, then We will only use and disclose such combined information for the purposes described above while it is so combined.


We may share Personal Data as necessary for Our legitimate professional and business needs, to carry out Your requests, and/or as required or permitted by an applicable law. The Personal Data may be shared with the third parties only if is for the purposes identified or in the event You consent for the sharing of such Personal Data. Proper assurances will be obtained for the third parties that they will comply with the rules or policies specified under this Policy and subsequently notify the Company if it makes a determination it can no longer meet this obligation. We will take all the reasonable steps to prevent or stop unauthorized use or disclosure of the Personal Data by the third parties.

1. Do not rent or sell Personal Data: We do not rent, list or sell the Personal Data with any third parties.

2. Internally: Your personal data will be used and shared amongst Our employees and contractors who are working on providing Your services to You on a need-to-know basis.

3. Professional advisers: This would include lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

4. Legal obligation: Further, We may disclose information about You: (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials, or (iii) when We believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We may disclose Personal Data to third party rights owners, or others in the good faith belief that such disclosure is reasonably necessary to: (a) enforce our Terms of Service and this Policy; (b) respond to claims that an advertisement, posting or other content violates the rights of a third party; (c) respond to any authority, having the right to receive such information under law; or (d) protect the rights, property or personal safety of the users or the general public.

5. Suppliers: This would include service providers who support our business including IT and communication suppliers and outsourced business support to ensure Our service runs smoothly.

6. Sale or Merger: In the event of any proposed or actual reorganization, sale, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of the Company or of any Company assets, We may disclose or transfer Your Personal Data to such third party. Should such an event take place, We will endeavour to direct the transferee to use the Personal Data in a manner that is consistent with this Policy.

7. Advertising networks and analytics service providers: This is to support and display ads on our website, apps and other social media tools.


The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Policy. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.

To ensure the safe and thorough management of Your personal information, we adhere to a deletion process that aims to either completely remove Your data from Our servers or retain it solely in anonymized form. Our services are designed to protect against accidental or malicious deletion of information. However, it’s important to note that there may be occasional delays between the time You initiate a deletion and when copies are effectively removed from both Our active and backup systems.

We uphold the principle of retaining Your personal information only for the duration necessary to fulfil its intended purpose, as outlined in our Policy. For instance, if You have provided personal information while creating an account, we may retain this data as long as Your account remains active on Our system. If Your personal information is no longer required for such purposes, We will promptly delete it or anonymize it by removing any identifiable details.

Nevertheless, there are certain circumstances where We may need to retain Your personal information for legitimate business or legal reasons. These may include obligations related to compliance with applicable laws, accounting or reporting requirements, or the need for archiving in the public interest, scientific research, historical research, or statistical analysis. Additionally, certain data may be retained for extended periods to fulfil purposes such as ensuring security, preventing fraud and abuse, or maintaining financial records.


Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.


Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

1. Comply with a legal obligation

2. Protect and defend the rights or property of the Company

3. Prevent or investigate possible wrongdoing in connection with the Service

4. Protect the personal safety of Users of the Service or the public

5. Protect against legal liability


At Spectrum, the security of Your data is of utmost importance. We take extensive measures to safeguard the information You provide, ensuring protection against loss, unauthorized access, disclosure, and misuse. These measures are designed to align with the sensitivity of the data We collect, process, and store, as well as the current advancements in technology. Spectrum has obtained internationally recognized security certifications, reflecting Our commitment to maintaining robust security practices.

However, it is important to note that due to the inherent nature of communication and information processing technology, We cannot guarantee absolute security against external intrusions while transmitting data over the Internet or when it is stored in Our systems. Additionally, when You click on a link leading to a third-party website, please be aware that You will be leaving our site, and We do not have control over or endorse the content found on such third-party sites.

You are responsible for selecting any password and its overall security strength, ensuring the security of Your own information within the bounds of Our services. For example, ensuring any passwords associated with accessing Your personal information and accounts are secure and confidential.


Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.


We reserve the right to revise this Policy or any part of it from time to time, to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. You are advised to review this Policy periodically for any changes. Changes to this Policy are effective when they are posted on this page.

If the changes are significant, or if required by applicable law, We will contact You (based on your selected preferences for communications from Us) and all Our registered users with the new details and links to the updated or changed policy.

Your continued use of Our website, products, services or provision of further personal information to Us constitutes Your deemed acceptance of the revised Privacy Policy. Please note that for material changes, Your continued use of Our website, products, services or provision of further personal information to Us once You have been notified of the revised Privacy Policy constitutes Your deemed acceptance of the revised Privacy Policy.


If you have any questions about this Policy, You can contact us via email at info@stmpl.co.in


This Policy was last updated on 24-5-2024.