Privacy Policy

1. Who We Are

Wackowave Management Consulting Services (OPC) Private Limited (“Wackowave”, “we”, “us”, or “our”) is incorporated under the Companies Act, 2013 in India. We operate globally through nodes in India, USA, and Brazil.

For GDPR purposes, we act as a data controller for personal data submitted through wackowave.com and our associated platforms. For data processed on behalf of clients, we act as a data processor.

Data Controller Contact:
Navneet Chalana, Founder & CEO
Email: navneet@wackowave.com
Phone / WhatsApp: +91 98180 83597

2. Information We Collect

We collect information in the following ways:

• Information you provide directly: Name, email address, phone number, company name, job title, and any message content submitted via contact forms, email, HubSpot scheduling, WhatsApp, or Microsoft Teams.
• Professional information: For candidates engaging with TalentWave — resume/CV data, work history, skills, references, and background check data (processed through our AI verification platform).
• Newsletter subscriptions: Email address and name submitted through our Microsoft Forms newsletter subscription.
• Technical data: IP address, browser type and version, operating system, referring URLs, pages visited, and time spent on pages — collected automatically when you use our website.
• Cookie data: As described in Section 5 below.

3. How We Use Your Information

We use personal data for the following purposes:

• Responding to enquiries and providing requested services
• Processing technology staffing requirements and candidate submissions (TalentWave)
• Sending our monthly newsletter to subscribed users
• Scheduling and managing meetings booked through HubSpot
• Improving our website and service offerings through analytics
• Complying with legal and regulatory obligations
• Protecting the security and integrity of our platforms

We do not sell, rent, or trade personal data to third parties for marketing purposes.

4. Legal Basis for Processing (GDPR)

For individuals in the European Economic Area (EEA) and United Kingdom, we process personal data under the following legal bases:

• Consent (Article 6(1)(a)): Newsletter subscriptions, non-essential cookies. You may withdraw consent at any time.
• Contract performance (Article 6(1)(b)): Processing necessary to fulfil service agreements with clients and candidates.
• Legitimate interests (Article 6(1)(f)): Website analytics, security monitoring, business communications. We have assessed that our legitimate interests do not override your fundamental rights.
• Legal obligation (Article 6(1)(c)): Where we are required to process data to comply with applicable law.

5. Cookies & Tracking

Our website uses the following categories of cookies:

• Necessary cookies: Essential for website functionality. Cannot be disabled. These include session management and security tokens.
• Analytics cookies: Help us understand how visitors interact with our website. No personally identifiable information is stored. Enabled only with your consent.
• Marketing cookies: Used to serve relevant advertisements. Enabled only with your explicit consent.

You can manage your cookie preferences at any time using the Cookie Settings panel in our website footer. Preferences are stored locally and expire after 365 days.

6. Data Sharing & Third Parties

We share personal data with the following third parties, each bound by appropriate data processing agreements:

• HubSpot Inc. (USA) — Meeting scheduling and CRM. HubSpot Privacy Policy
• Zoho Corporation — Recruitment management (Zoho Recruit). Zoho Privacy Policy
• Microsoft Corporation — Teams communications and Forms. Microsoft Privacy Statement
• Meta Platforms (WhatsApp) — Messaging. WhatsApp Privacy Policy
• Hostinger International — Web hosting. Subject to appropriate data processing agreement.

We may also disclose personal data where required by law, court order, or regulatory authority.

7. International Data Transfers

Wackowave operates globally with nodes in India, USA, and Brazil. Your data may be processed in any of these jurisdictions. For transfers from the EEA or UK, we implement appropriate safeguards including Standard Contractual Clauses (SCCs) where required.

India’s Digital Personal Data Protection Act 2023 (DPDPA) governs our data processing activities in India. We comply with all applicable provisions.

8. Data Retention

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by law:

• Client and candidate records: 7 years from last engagement (legal/contractual requirement)
• Newsletter subscriber data: Until unsubscription, then 30 days
• Website analytics data: 26 months (aggregated, anonymised)
• Cookie consent records: 365 days from consent date
• General enquiry emails: 3 years from last contact

9. Your Rights

Depending on your jurisdiction, you may have the following rights:

• Access: Request a copy of the personal data we hold about you
• Rectification: Request correction of inaccurate or incomplete data
• Erasure: Request deletion of your personal data (“right to be forgotten”)
• Restriction: Request we restrict processing of your data
• Portability: Receive your data in a structured, machine-readable format
• Objection: Object to processing based on legitimate interests
• Withdraw consent: At any time, where processing is based on consent
• Lodge a complaint: With your national data protection authority (EEA/UK) or India’s Data Protection Board

To exercise any right, email navneet@wackowave.com with the subject line “Data Rights Request”. We will respond within 30 days.

10. Children’s Privacy

Our website and services are not directed at individuals under 18 years of age. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a minor, please contact us immediately at navneet@wackowave.com.

11. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction. These include:

• TLS/HTTPS encryption for all data in transit
• AES-256 encryption for sensitive data at rest
• Role-based access controls on all systems
• Regular security reviews and penetration testing
• Employee training on data protection obligations

No method of transmission over the internet is 100% secure. We cannot guarantee absolute security, but we are committed to protecting your data using industry-standard practices.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The “Last updated” date at the top of this page will reflect any changes. For material changes, we will notify affected users by email where we hold your contact information. Continued use of our website after changes are posted constitutes acceptance of the updated policy.

13. Contact & Complaints

For any privacy-related questions, requests, or complaints:

• Email: navneet@wackowave.com
• WhatsApp: +91 98180 83597
• Address: Wackowave Management Consulting Services (OPC) Pvt. Ltd., Ghaziabad, Uttar Pradesh, India

EEA/UK residents may also lodge a complaint with their local supervisory authority. India residents may contact the Data Protection Board of India once established under the DPDPA 2023.