PRIVACY POLICY

SEXUAL HARASSMENT PREVENTION & REDRESSAL POLICY

EQUAL OPPORTUNITY FOR Specially Gifted PERSONS

 


 
 
 

PRIVACY POLICY

This Privacy Policy outlines the manner in which Barcode Influencer Marketing Private Limited (hereinafter referred to as “Barcode,” “We,” “Us,” or “Our”) collects, uses, maintains, and discloses information collected from users (“You” or “Your”) on its platforms, including its website, mobile applications, and other related services (collectively referred to as the “Services”). By accessing or using the Services, You consent to the collection, use, transfer, storage, disclosure, and other uses of Your information (including personal and non-personally identifiable information) as described in this Privacy Policy.

Third-Party Services
Barcode may provide links to third-party websites, platforms, and services, including social media platforms such as Instagram, YouTube, Facebook. These third-party websites and services operate independently and are not controlled by Barcode. Barcode is not responsible for the content, practices, or privacy policies of any third-party sites or services. You are encouraged to review the privacy policies of such third parties before using their services.

Information We Collect

1. Personally Identifiable Information

We may collect personal information from You when You:

  • Register with Us as an influencer, talent, or client;
  • Participate in campaigns, promotions, or events;
  • Subscribe to newsletters or other marketing communications; or
  • Engage with Us via email, phone, or social media platforms.

Personal information may include, but is not limited to:

  • Name, email address, mailing address, phone number, and date of birth;
  • Social media handles, profile details, and engagement statistics;
  • Payment and billing information, such as bank account or UPI details; and
  • Any other information You voluntarily provide to Us.

2. Non-Personally Identifiable Information

We may also collect non-personal information, including but not limited to:

  • Browser type and version, operating system, device details, and IP address;
  • Pages accessed, time spent on pages, and interaction data;
  • Location data, if enabled on Your device; and
  • Referral sources, such as links clicked to access Our Services.

3. Social Media Integration

If You choose to connect Your social media accounts (e.g., Instagram, YouTube) with Our Services, Barcode may collect additional information, such as engagement metrics, follower counts, and media content. Use of such data will be governed by this Privacy Policy and subject to the respective social media platform’s policies.

How We Use Your Information

We may use the information collected from You for purposes including, but not limited to:

  • Facilitating influencer marketing campaigns and talent management services;
  • Managing campaign deliverables, performance tracking, and payments;
  • Communicating with You regarding campaigns, projects, or Services;
  • Sending newsletters, updates, or promotional content (if subscribed);
  • Enhancing and personalizing Your experience on Our platforms; and
  • Complying with legal, regulatory, and contractual obligations.

How We Protect Your Information

Barcode implements appropriate data security measures to safeguard Your information from unauthorized access, alteration, or disclosure. While we strive to protect Your data, no method of electronic transmission or storage is entirely secure. Barcode shall not be held liable for breaches beyond its reasonable control, such as unauthorized hacking or system failures.

Sharing of Information

We do not sell, trade, or rent Your personal information to third parties. However, We may share Your information with:
Trusted partners or affiliates to facilitate influencer campaigns or talent management;
Payment processors for transactions related to campaigns or services;
Regulatory authorities or law enforcement as required by law; and
Third parties in connection with mergers, acquisitions, or asset transfers involving Barcode.

Cookies

Barcode may use cookies and similar tracking technologies to improve Your experience on Our platforms. Cookies help track user activities, preferences, and session details. You may disable cookies through Your browser settings; however, doing so may limit certain functionalities of the Services.

Governance of This Privacy Policy
This Privacy Policy is governed by and complies with the applicable privacy and data protection laws of India, including but not limited to:

  • The Information Technology Act, 2000 (as amended);
  • The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011; and
  • The Digital Personal Data Protection Act, 2023 (DPDP Act).

Barcode is committed to ensuring compliance with these laws to protect the privacy and security of Your personal information. In case of any conflicts or inconsistencies between this Privacy Policy and the aforementioned laws, the provisions of the applicable law shall prevail.
By using Our Services, You agree that any disputes arising from this Privacy Policy will be subject to the jurisdiction of the courts in Mumbai, Maharashtra and governed by the laws of India.

Changes to This Privacy Policy

Barcode reserves the right to update or modify this Privacy Policy at any time. Changes will be effective immediately upon posting on Our website. Continued use of the Services after any such changes constitutes Your acknowledgment and acceptance of the revised Privacy Policy.

Contact Us

If You have any questions regarding this Privacy Policy or Our data practices, please contact Us at:
Email: info@barcodent.com
Address: Office Unit No 704, Signature, Veera Desai Road, Andheri West, Mumbai, Mumbai Suburban, Maharashtra, 400053

 

 
 
 

SEXUAL HARASSMENT PREVENTION & REDRESSAL POLICY

A. INTRODUCTION

Barcode Influencer Marketing Private Limited (hereinafter referred to as “Barcode” or “Employer”) is committed to creating and maintaining a safe and harassment-free work environment for all its employees, contractors, trainees, and visitors. Barcode has a zero-tolerance policy towards any form of sexual harassment or discrimination, irrespective of gender.

As a responsible organization, Barcode ensures that all employees are safeguarded against sexual harassment at the workplace and are able to work with dignity, a universal human right.

This Policy applies to all employees of Barcode, irrespective of their gender identity (women, men, or transgender individuals) and is deemed to be incorporated into their terms of employment. It also applies to individuals engaged on a fixed-term or short-term basis, including trainees, contractual staff, and visitors.

B. IMPORTANT DEFINITIONS

  1. Aggrieved Individual: A person, irrespective of age, employment status, or gender, who alleges to have been subjected to sexual harassment by the Respondent. This includes contractual staff, trainees, and visitors.
  2. Appropriate Government: As defined under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (“POSH Act”).
  3. Complainant: Any Aggrieved Individual or their representative (as per Rule 6 of the POSH Rules, 2013) who files a complaint of sexual harassment under this Policy.
  4. Employer: The entity responsible for the management, supervision, and control of the workplace, including appointment, removal, or termination of employees.
  5. Internal Committee (IC): The committee formed under Section 4 of the POSH Act to address complaints of sexual harassment against women.
  6. Disciplinary Committee (DC): The committee formed to address complaints of sexual harassment against men and transgender individuals, as well as other forms of harassment.
  7. Employees: Includes permanent, part-time, and contractual employees, as well as trainees engaged by Barcode.
  8. Respondent: The individual against whom a complaint of sexual harassment is filed.
  9. Workplace: Any establishment, enterprise, office, or location owned or controlled by Barcode, as well as places visited by employees in the course of employment, including transportation provided by the employer.

C. BACKGROUND

The POSH Act, 2013, was enacted to provide a safe, secure, and dignified working environment free from sexual harassment for women. While the POSH Act specifically addresses harassment against women, Barcode extends the scope of its policy to include all genders, ensuring a comprehensive framework for addressing and redressing complaints of sexual harassment.

D. DECLARATION

Barcode declares zero tolerance for sexual harassment. No employee, irrespective of gender, shall be subjected to sexual harassment at the workplace or during work-related activities outside the workplace.

E. OBJECTIVE

The objectives of this Policy are:

  1. To declare that sexual harassment against any individual is prohibited.
  2. To define the scope and coverage of sexual harassment.
  3. To create awareness among employees about the adverse impact of sexual harassment.
  4. To establish mechanisms (IC and DC) for redressal of complaints and ensure confidentiality and sensitivity during proceedings.
  5. To encourage employees to report incidents fearlessly.
  6. To provide appropriate penalties for proven cases and discourage false complaints.
  7. To ensure compliance with the POSH Act and related legal requirements.

F. MEANING AND SCOPE OF SEXUAL HARASSMENT

  1. What constitutes sexual harassment? Sexual harassment includes, but is not limited to:
  • Physical contact and advances
  • Demand or request for sexual favors
  • Making sexually colored remarks
  • Showing pornography
  • Sending inappropriate messages or content via any electronic medium
  1. Circumstances amounting to sexual harassment:
  • Explicit or implicit promise of preferential treatment in employment
  • Threats of adverse treatment in employment
  • Interference with work or creating a hostile work environment
  • Humiliating treatment affecting health or safety

G. POLICY AWARENESS

  1. Employee Responsibilities:
  • Abstain from any acts of sexual harassment.
  • Report incidents without fear or favor.
  • Foster a respectful work environment.
  • Avoid malicious complaints.
  • Seek clarification or assistance from the IC or DC when in doubt.
  1. Employer Responsibilities:
  • Provide a safe working environment.
  • Raise awareness of this Policy.
  • Constitute the IC and DC with clearly defined roles and tenures.
  • Facilitate investigations and ensure prompt action against proven offenders or false complainants.
  1. Complainant and Respondent:
  • Complaints by women are addressed by the IC; complaints by men and transgender individuals are addressed by the DC.
  • Complaints can be made against employees or non-employees, including visitors.
  • Consent obtained under duress from a subordinate by a senior employee will not be deemed voluntary.
  • Incidents outside the office (e.g., work events) are also covered.
  1. Internal Committee (IC):
  • The IC addresses complaints from women employees.
  • Tenure: Three years, renewable upon reappointment.
  • Members cease to hold office upon the expiration of tenure, cessation of employment, or superannuation.
  • The IC also hears complaints from external individuals if the harassment occurred in Barcode’s workplace.
  1. Filing Complaints:
  • Complaints must be in writing and submitted within three months of the incident (extendable by three additional months at the IC’s discretion).
  • Complaints may be submitted in physical or electronic form.
  • Detailed information (dates, incidents, witnesses) should be included.
  • IC/DC members will assist complainants in articulating their complaints if needed.

Committee Members (IC/DC):

Name of the Member Official Designation Designation of IC
Sonia Sarashetti Director – Branded Content Presiding Officer
Rahul Khanna CEO Internal Member
Chitra Legal Manager Internal Member
Shreya Suri Senior Executive (Corporate and Donor Relations) – Foundation for Excellence, Bangalore and Certified POSH Committee Member External Member (NGO/ Social Work)

 

H. PROCEDURE FOR HANDLING COMPLAINTS

  1. Conciliation Efforts:
  • Upon receipt of a complaint, the IC/DC may initiate conciliation, provided the complainant requests it.
  • No monetary settlement shall be treated as conciliation.
  1. Inquiry Process:
  • The IC/DC will conduct a fair, confidential, and unbiased inquiry.
  • Both parties will be given an opportunity to present their case.
  • Witnesses may be called to provide evidence if required.
  1. Disciplinary Actions:
  • Appropriate action will be taken against proven offenders within 60 days of the receipt of the report, which may include counseling , apology, written warning, withholding promotion and/or increments, suspension, termination, or any other action that the Employer may deem fit.
  • False complaints will attract penalties as a deterrent.

Barcode remains committed to upholding this Policy and ensuring a safe, inclusive, and respectful workplace for all.

 

 
 
 

EQUAL OPPORTUNITY POLICY

BACKGROUND

As an influencer marketing company, Barcode Influencer Marketing Private Limited (referred as “Barcode” or the “Company”) prioritizes diversity and inclusion. We offer equal opportunities to all employees, irrespective of background, and base recruitment solely on merit. Our aim is to create a supportive workplace culture where everyone feels respected and valued, enabling us to better connect with diverse audiences globally.

This Equal Opportunity Policy (hereinafter referred as “Policy”) is in accordance with the provisions of ‘The Rights of Persons with Disabilities Act, 2016’ (“hereinafter referred as Act”) and the rules made thereunder.

People or persons with disability, are hereinafter referred as “Specially Gifted”.

DEFINITIONS

Any words used in this Policy shall have the same meaning ascribed to it under the Act or rules made thereunder.

SCOPE

This Policy is applicable to all Specially Gifted which includes board members, employees, consultants, temporary employees, trainees / apprentices, job applicants of our Company and its subsidiaries. It also covers those employees who acquire disability during their work tenure. This Policy also applies to all aspects of employment, be it recruitment, training, working conditions, remuneration, transfers, employee benefits and career advancement.

EQUAL OPPORTUNITY FOR Specially Gifted PERSONS

With the aim of fostering an inclusive and supportive work environment, Barcode is dedicated to ensuring the following provisions for Specially Gifted individuals:

  • Provision of suitable facilities and amenities to facilitate their job responsibilities.
  • Implementation of accessibility standards in documents, communications, and information technology systems.
  • Assurance that any new facility, building, or renovation adheres to necessary infrastructure and amenities for accessibility.
  • Ensuring barrier-free accessibility and availability of assistive devices as needed.
  • Conducting company facilities, offices, events, and meetings in inclusive venues with reasonable accommodations for Specially Gifted individuals.
  • Providing necessary facilities for smooth and hassle-free travel during official trips.
  • Commitment to non-discrimination in all aspects of employment, including recruitment, training, working conditions, remuneration, transfers, benefits, and career advancement.
  • Prohibition of harassment or discrimination against Specially Gifted individuals by any employee or vendor, emphasizing respect and dignity at all times.
  • Ensuring all suitable positions are open to Specially Gifted individuals, with hiring, recruitment, and promotion based solely on merit and evaluation of skills and competence.
  • Facilitating the return to work at the same level for employees who acquire disabilities during employment. If necessary, transferring them to a suitable position with equivalent pay and benefits, with recourse to advice from a certifying surgeon for guidance.

LIAISON OFFICER

The Company has nominated Manager – Human Resources as the Liaison Officer. The Liaison Officer shall also ensure that there are no grounds of discrimination at the time of hiring, recruitment and there are appropriate facilities/amenities for Specially Gifted in the Company.

MAINTENANCE OF RECORDS

The Company will keep records that include the following details:

  • The count of Specially Gifted individuals employed and their employment start dates.
  • Names, genders, and addresses of Specially Gifted employees.
  • Descriptions of their disabilities.
  • Descriptions of the work they are engaged in.
  • Details of the facilities provided to them.

Information disclosed by an employee regarding their disability will be kept confidential and maintained in a separate file. Essential details about disabilities may be shared with managers, supervisors, and administrative personnel to facilitate necessary accommodations or support as required.

GRIEVANCE MECHANISM

Any aggrieved employee who is Specially Gifted, can raise their concerns/grievance arising out of this Policy directly to the Human Resources Department. The Company shall ensure that reasonable opportunity is provided to the Specially Gifted person, to effectively participate in the investigation process.

On investigation, if the employee against whom the complaint has been made, is found guilty of discriminatory behavior, he/she will be subjected to necessary disciplinary actions as per the rules of services.

During the investigation and thereafter, the Human Resources Department shall ensure confidentiality and protect the Specially Gifted person who has raised a concern/grievance under this Policy, in good faith and without any malafide intention.

AMENDMENT

Our Directors are authorized to amend the Policy, to give effect to any changes/amendments as maybe required from time to time.