Privacy Statement for California Residents

Effective date: March 15, 2026

 

This privacy statement (‘California Privacy Statement’) supplements the information contained in the Privacy Statement of HCLSoftware (‘HCLSoftware’ or ‘we’) and applies solely to visitors, users, and others who reside in the State of California (‘you’). We adopt this California Privacy Statement to comply with the California Consumer Privacy Act of 2018 (‘CCPA’), as amended by the California Privacy Rights Act of 2020 (‘CPRA’), and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this California Privacy Statement.

Your Rights Under the CCPA

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This California Privacy Statement explains those rights.

Information We Collect

We collect information that relates to, is capable of being associated with, or could reasonably be linked to you or one of your devices (‘personal information’). In particular, we have collected the following categories of personal information within the last twelve (12) months as described here:
HCLSoftware Privacy Statement.

Sources of Personal Information

We obtain the personal information listed above from the following categories of sources:

• You or your authorized parties or agents. Authorized parties or agents include, but are not limited to, parties such as attorneys, guardians, and those with powers of attorney; communicating via including emails, phone calls, and texts or visits to office.
• Business partners & Affiliates;
• Service providers;
• Our websites and mobile apps, social media pages, or any time you visit, use, or interact with any of the features or services available on our mobile or online applications; and
• Prospective employees or employees.

Use of Personal Information

We collect, use, disclose or share the personal information for one or more of the following business or commercial purposes:

• To fulfill or meet the reason for which the information is provided;
• To provide you with information, products or services that you request from us;
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you;
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections;
• To improve our website and present its contents to you;
• For testing, research, analysis and product development;
• As necessary or appropriate to protect the rights, property or safety of us, yours or others;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• As described to you when collecting your personal information or as otherwise set forth in the CCPA; and
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Disclosure of Personal Information

We may disclose your personal information to third parties for a business or commercial purpose. When we disclose personal information for a business or commercial purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We disclose your personal information for a business purpose to the following categories of third parties:

• Affiliates and subsidiaries;
• Internet service providers;
• Advertising networks;
• Data analytics providers;
• Service providers, which include nonaffiliated entities providing operating systems, platforms and other services to support day-to-day operations; and
• Government, regulatory, or legal authorities.

We maintain reasonable administrative, technical, and organizational safeguards designed to protect personal information in accordance with applicable California privacy and security requirements.

Sharing and Sale of Personal Information

HCLSoftware does not “sell” or “share” your personal information within the meaning of the 00CCPA and we have not done so within the past 12 months. We only disclose your information as described in this policy and in the HCLSoftware Privacy Statement.

When you visit an HCLSoftware website, third party targeting cookies, if any, will only be present if that is in accordance with our Online Cookie Statement, and in line with your cookie choices that are presented to you on the website.

Automated Decision-Making

HCLSoftware does not use automated decision-making technologies, including profiling, that produce legal or similarly significant effects concerning consumers.

“Automated decision-making technology” or “ADMT” means any technology that processes personal information and uses computation to replace human decision-making or substantially replace human decision-making. (1) For purposes of this definition, to “substantially replace human decision-making” means a business uses the technology’s output to make a decision without human involvement. Human involvement requires the human reviewer to: (A) Know how to interpret and use the technology’s output to make the decision; (B) Review and analyze the output of the technology, and any other information that is relevant to make or change the decision; and (C) Have the authority to make or change the decision based on their analysis in subsection (B). (2) ADMT includes profiling that replaces human decision-making or substantially replaces human decision-making. (3) ADMT does not include web hosting, domain registration, networking, caching, website-loading, data storage, firewalls, anti-virus, anti-malware, spam- and robocall-filtering, spellchecking, calculators, databases, and spreadsheets, provided that they do not replace human decision-making.”

Your Rights and Choices

CCPA provides you with specific rights regarding your personal information. This section explains those rights.

Access to Specific Information and Data Portability: You have the right to request that we disclose certain information to you about our collection, use, disclosure, and/or sale of your personal information (if applicable) over the past 12 months. Once we receive and confirm your verifiable request, we will disclose to you:

• The categories of personal information we have collected about you;
• The categories of sources for the personal information we collected about you;
• Our business or commercial purpose for collecting, selling or sharing (if applicable) your personal information;
• The categories of third parties to whom we disclose your personal information;
• The categories of personal information that the business disclosed about you for a business purpose; and
• The specific pieces of personal information we collected about you (also known as right to ‘data portability’).

Correction or Deletion: You can request rectification (correction, updating or modification) or deletion of the personal information that HCL has collected from your use of our services. We will comply with your request as required by law, but this right does not apply where HCL needs to retain the personal information in order to provide goods or services to you, detect or resolve security issues or functionality-related issues, comply with the law, and carry out internal business requirements.

Limit the Use and Disclosure of Personal Information: You have the right to request that we limit the use and disclosure of your personal information that we have collected about you. Once we receive and verify your request, and to the extent required by applicable law, we will:

• Restrict our use of your personal information to only those purposes necessary to provide you with the goods or services you have requested;
• Limit disclosures of your personal information to third parties except as necessary to perform the services you have requested or as otherwise permitted by law; and
• Notify relevant service providers and partners of your request to limit use and disclosure of sensitive personal information.

Opt-out: You have the right to opt out of advertisements that third parties may target you. You can review the third-party advertising cookies and opt out of their use via the Cookie Preferences tool which is found on our webpage or in our Online Cookie Statement here. Please note that your opt-in/out selection through this tool applies to the browser and device you are using. If you access HCL website across multiple devices or browsers or if you clear your browser settings, you may have to make this selection again.

Opt Out of Sharing for Cross‑Context Behavioral Advertising: You have the right to opt out of the sharing of your personal information for cross‑context behavioral advertising (also known as targeted advertising). This means you can choose not to allow the use of your personal information by third parties to deliver ads based on your activities across different websites, apps, or online services.

Once we receive and verify your opt‑out request, we will:

• Update our advertising settings to limit or stop the sharing of your personal information with advertising partners for cross‑context behavioral advertising;
• Honor opt‑out preference signals, such as Global Privacy Control (GPC), where required by applicable law; and
• Apply your request to the browser or device from which the signal or request was submitted.

You can exercise this right by using the Cookie Preferences tool on our website, enabling privacy preference signals in your browser

Access and Opt Out of Certain Automated Decision‑Making or Profiling Activities: You have the right to request meaningful information about, and to opt out of, certain automated decision‑making processes or profiling activities that produce legal effects or similarly significant effects about you. These activities may include decisions made using algorithms, machine learning, or other automated technologies that evaluate, analyze, or predict aspects of your behavior, preferences, or characteristics.

Upon receiving and verifying your request, we will:

• Disclose whether we use automated decision‑making or profiling that results in decisions with legal or significant effects about you;
• Provide information about the logic involved, as well as the nature and purpose of the processing, to the extent required by law;
• Offer you the option to opt out of such processing where required by applicable law; and
• Implement your opt‑out choice within the time period required by applicable law.

No Retaliation After Exercising Your Rights: We will not discriminate against you, or retaliate in any way, for exercising your privacy rights, including but not limited to:

• Your right to access, correct, delete, or limit the use of your personal information;
• Your right to opt out of the sale or sharing of your personal information;
• Your right to opt out of cross‑context behavioral advertising; or
• Your right to opt out of certain automated decision‑making or profiling activities.

This means that we will continue to provide you with the same level of service and access to our goods or services even after you exercise any of your rights, unless the action you request prevents us from legally or technically providing those goods or services.

Should you choose to exercise any of your rights under the CCPA, HCLSoftware will not discriminate against you in any way. We will not charge you different prices for goods or services, whether through denying benefits or imposing penalties, provide you with a different level or quality of goods or services, or threaten you with any of the above actions.

How to Exercise Your Rights Under the CCPA

To exercise any of the rights described above, please submit a verifiable consumer request to us by either of the two options below:

- Emailing us at HCLSWPrivacy@hcl-software.com; or
- Submitting your request through our Data Subject Request Portal.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request. The verifiable consumer request must:

- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information (or an authorized representative).
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request if we cannot verify your identity and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity and/or authority to make the request. To protect your personal information, we will verify your identity before responding to certain requests. The verification process may require you to provide information that we already maintain about you or information related to your prior interactions with us. The information required will depend on the nature of the request and the sensitivity of the personal information involved.

We make an effort to respond to a verifiable request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing, by mail or electronically, at your option. We will deliver our written response by email or through the Data Subject Request Portal.

You can designate an authorized agent to make a request under the CCPA on your behalf provided that (1) it is a natural person or a business entity registered with the Secretary of State of California; and (2) you have authorized the agent to act on your behalf.

Authorized agents may use the Data Subject Request Portal for further instructions. To protect your information, please note that we may take steps to verify your identity and we will also ask for a signed permission from you authorizing the authorized agent to submit a request on your behalf.

How Long Do We Retain Your Personal Information?

We retain your personal information for as long as it is necessary to fulfil the purposes for which it was collected, or longer if required to fulfil our legal and contractual obligations. Retention periods vary depending on the category of personal information, the purposes for which it is processed, applicable legal requirements, and legitimate business needs.

After expiration of the retention period, we will ensure that there are appropriate measures in place to secure the information and protect it from further use.