India Guests Privacy Notice

Last updated: January 4, 2021

1. WHAT IS THE PURPOSE OF THIS DOCUMENT?

Comcast is committed to protecting the privacy and security of the personal information of its guests. This
privacy notice describes how we collect and use personal information about our Indian guests in the context
of our relationship (“personal information”).

This notice applies to current and former guests and does not form part of any contract of employment or
contract to provide services.

In this notice we will use the terms “Comcast”, “we”, “us” and “our” to refer to Comcast India Engineering
Centre 1 LLP that you are visiting as a guest, and other companies in the Comcast group of companies.

It is important that you read this notice, together with any other privacy notice that we may provide on
specific occasions when we are collecting or processing personal information about you, so that you are
aware of how and why we are using such information. We may update this notice at any time.

2. DATA PROTECTION PRINCIPLES

We observe the following principles in relation to personal information:

• We use it fairly, lawfully and in a transparent way, in accordance with applicable law;
• We process it for specific legitimate business purposes and do not process it in a manner
incompatible with those purposes;
• We collect personal information that is adequate, relevant and not excessive for the purpose
for which it is processed;
• We keep it accurate and (as necessary) up to date, and will rectify or erase inaccurate data
without undue delay;
• We keep it only as long as necessary for the purposes we collected it for;
• We take steps to keep it secure;
• We respect the rights given to individuals under data protection law;
• We will only transfer it to countries outside of India if we have in place adequate measures to
protect our guests’ data protection rights and the security of their data.
When we use the term “process” in relation to your personal information, we mean any action that can be
taken in relation to data, such as collection, access, storage, modification, correction, disclosure and
deletion.

3. THE KIND OF INFORMATION WE HOLD ABOUT YOU

Comcast collects, stores and uses various types of personal information about its guests. This information
will have been collected through the CCTV cameras and directly from you.

The kind of information we hold includes, where applicable:

• Contact information, such as name, home and business addresses, telephone numbers and email
addresses, etc.;

• Information about your use of Comcast information systems (where relevant and permitted by
local law), including user IDs, passwords, IP addresses and audit trails of system access; and
• CCTV footage and other information obtained through electronic means such as security pass

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records.

4. WHAT WILL COMCAST DO WITH YOUR PERSONAL INFORMATION?

The main purposes for which we use personal information include:

• Guests Planning such as planning for and welcoming future guests. We will process your personal
information to further our legitimate interests in ensuring our business is adequately equipped to
welcome guests;

• Administration, including where applicable guests’ feedback surveys, and investigating and
resolving queries, complaints, issues and concerns raised by guests. Typically, we will need to
process your personal information in this manner to further our legitimate interests.

• Performance of Comcast’s Business Operations, such as providing, managing and supporting

our information and communication systems , data administration, crisis management and
contacting guests in emergency situations, managing and protecting intellectual property,
managing the environmental impacts associated with Comcast’s operations, protecting the
occupational health and safety of our guests, and preparing analyses and reports related to the
above. We process your personal information in this manner on the basis of our legitimate interests
in ensuring our organisation is properly and efficiently administered and operated. There may be
times when we need to collect certain limited health information from you, particularly in relation to
COVID-19, in accordance with guidance by the government or Data Protection Authority, if and to
the extent that this is necessary to meet legal obligations of the company in assuring the health and
safety of our workplace, for the vital interests of protecting your health and the health of others
present in our offices, and for the public interest in the health and safety of the general public and
disease control. Any health-related data that we process shall be processed in accordance with this
privacy policy, applicable data protection law, and shall not be used beyond what is necessary for
these purposes in relation to COVID-19. Where necessary and appropriate, we will provide more
detailed information to you at the time of the processing;

• Legal and Regulatory Requirements, such as complying with legal, regulatory and fiscal
obligations. We will process your personal information in this manner to comply with legal
obligations, or where necessary to defend or exercise our legal rights, or where we have a legitimate
interest in protecting our organisation, investigating and resolving issues and concerns, and
conducting or responding to audits and legal or regulatory requests and investigations; and

• Security Management, such as to ensure network and information security (including preventing
unauthorised access to our computer and electronic communications systems and preventing
malicious software distribution), monitoring (including through use of CCTV) and controlling access
to Comcast premises, monitoring your use of our information, communications and collaboration
systems to ensure compliance with our IT policies and to prevent data loss, and corporate device
management. In most cases, it will be necessary for us to process your personal information in this
manner as we have a legitimate interest in protecting our premises, assets, information and staff
from physical and cybersecurity threats.

5. WHO IS YOUR PERSONAL INFORMATION DISCLOSED TO?

(a) Within Comcast
Comcast restricts access to your personal information to people within Comcast who have a “need to know”
that information in connection with their role, to carry out the purposes mentioned above.

As a global company doing business across national borders, there are many situations where this “need
to know” requires your personal information to be transferred to Comcast in the United States or another

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country, including countries whose laws may provide no or less legal protection for personal information.
However, we take the privacy and security of your personal information very seriously, and we take steps
to protect your personal information in every country where it is held or accessed, including by putting in
place appropriate safeguards. Please contact us if you would like more information regarding our security
practices.

(b) Outside Comcast

We will share your personal information with third parties outside Comcast where it is necessary to
administer our reception processes, where required by law, or where we have another legitimate interest to
do so.
Suppliers: Comcast shares personal information with authorised third party suppliers that have a “need to
know” that information, such as technology service providers and administration suppliers (e.g. survey
providers). . It is our practice to require our third party suppliers to take appropriate security measures to
protect your personal information, and to only allow them to process your personal information for specified
purposes and in accordance with our instructions.
Transfers outside India: These third party suppliers may be based in the United States or another country.
It is our practice to require our third party suppliers to put in place measures to ensure that your personal
information is treated by them in a way that is consistent with, and which respects, applicable Indian law.

Other third parties: Generally, Comcast will only disclose personal information to third parties other than
Comcast’s suppliers:
• when required to do so by law, regulation or court order;
• in response to a legitimate request for assistance by the police or other law enforcement agency;
• to seek legal advice from Comcast’s external lawyers or in connection with litigation with a third
party; or
• in connection with the sale, purchase or merger of a business.

6. EXERCISING YOUR RIGHTS

Under certain circumstances, by law you have the right to:

• Request access to your personal information. This enables you to receive a copy of the personal
information that we hold about you;
• Request correction of the personal information that we hold about you. This enables you to have
any incomplete or inaccurate information we hold about you corrected;
• Request erasure of your personal information. This enables you to ask us to delete or remove
personal information where there is no good reason for us continuing to process it. You also have
the right to ask us to delete or remove your personal information where you have exercised your
right to object to processing (see below);
• Object to processing of your personal information where we are relying on a legitimate interest (or
those of a third party) and there is something about your particular situation which makes you want
to object to processing on this ground. You also have the right to object where we are processing
your personal information for direct marketing purposes;
• Request the restriction of processing of your personal information. This enables you to ask us
to suspend the processing of personal information about you, for example if you want us to establish
its accuracy or the reason for processing; and
• Request the transfer of your personal information to another party.

If you have any questions about this privacy notice or how we handle your personal information, please
contact our Privacy department at Comcast_Privacy@comcast.com.

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7. RETAINING YOUR PERSONAL INFORMATION

We will keep your personal information for as long as is necessary to fulfil the purposes we collected it for,
including for the purpose of satisfying legal, accounting and reporting requirements. To determine the
appropriate retention period for personal information, we consider the amount, nature and sensitivity of the
information, the potential risk of harm from unauthorised use or disclosure of the personal information, the
purposes for which we process the personal information and whether we can achieve those purposes in
other ways, the applicable legal requirements and our legitimate interests. For example, we will keep certain
information about former guests (e.g. name, dates of visit) for as long as necessary for our legitimate
interests in keeping this information as part of our organisational history and to confirm the facts of their visit
with us.

Privacy Contact

Comcast_Privacy@comcast.com

Chief Privacy Officer, Comcast, 1701 JFK Boulevard, Philadelphia, Pennsylvania, 19103, United States

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