JOBSUPI • UNLOCKING JOBUPIX LABS PRIVATE LIMITED
Data Privacy Policy
Governing your Personal Data on All Platforms & Services
Effective Date
May 21, 2026
Document Version
v2.0 (DPDP Compliant)
Jurisdiction
Republic of India
Legal Framework
DPDP Act 2023 | IT Act 2000
IMPORTANT NOTICE
This Policy is an electronic record within the meaning of the IT Act, generated by a computer system, and does not require any physical or digital signature. By registering on or using the platform in any manner, you, as a Data Principal under the DPDP Act, expressly and freely consent to the collection, storage, processing, and use of your personal data as described in this policy.
1. About This Policy & Who We Are
This Privacy Policy ("Policy") describes how UNLOCKING JOBUPIX LABS PRIVATE LIMITED ("Company," "JobsUPI," "we," "us," or "our"), a company incorporated under the Companies Act, 2013, with its registered office at AltF JMD Empire Square, Room No. MR1, 3rd Floor, JMD Empire Square, MG Road, Sikanderpur Ghosi, Sector 28, Gurugram, Haryana – 122002, collects, uses, processes, stores, shares, and protects your personal data when you use the JobsUPI platform, including the website www.jobsupi.com, mobile applications, WhatsApp channel, calling agent services, APIs, and all other interfaces through which we deliver our services (collectively, the "Platform").
This Policy is published in compliance with: (a) the Digital Personal Data Protection Act, 2023 ("DPDP Act"); (b) the Information Technology Act, 2000 ("IT Act") and the rules thereunder, including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules"); and (c) the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 ("Intermediary Guidelines").
CONSENT DECLARATION:
BY REGISTERING ON OR USING THE PLATFORM IN ANY MANNER, YOU, AS A DATA PRINCIPAL UNDER THE DPDP ACT, EXPRESSLY AND FREELY CONSENT TO THE COLLECTION, STORAGE, PROCESSING, AND USE OF YOUR PERSONAL DATA AS DESCRIBED IN THIS POLICY. IF YOU DO NOT AGREE TO THIS POLICY, YOU MUST NOT USE THE PLATFORM.
2. Definitions
Data Fiduciary
Means the Company, which determines the purpose and means of processing your personal data, as defined under the DPDP Act.
Data Principal
Means you — the individual whose personal data is being processed.
Personal Data
Means any data about an individual who is identifiable by or in relation to such data, whether directly or in combination with other information available or likely to be available with the Company.
Sensitive Personal Data
Means personal data that warrants special protection, including biometric data, financial data, health/medical data, data revealing caste, religion, or political opinion, sexual orientation, and any other data classified as sensitive under Applicable Law.
Processing
Means any automated or manual operation performed on personal data, including collection, recording, storage, use, disclosure, sharing, transfer, or erasure.
Consent
Means a freely given, specific, informed, unconditional, and unambiguous indication of your agreement to the processing of your personal data for a stated purpose, signified through a clear affirmative action.
3. What Personal Data We Collect
3.1 Data You Provide Directly
Job Seekers: Full name, mobile number, email address, date of birth, residential location (city/district/pin code), educational qualifications, work experience details, resume/CV, skills, language preferences, government-issued ID documents (for verification), profile photograph, salary expectations, and any other information you choose to add to your profile.
Employers / Job Providers: Company name, company registration or GST number, authorized person's name and designation, official email and phone number, job descriptions, company address, payment and billing details, and KYC documents as required for verification.
All Users: Any communications, feedback, complaints, or correspondence you submit to the Company.
3.2 Sensitive Personal Data
We may collect the following categories of Sensitive Personal Data, for which we seek specific, separate consent where required by Applicable Law:
Voice recordings and transcripts from AI-driven screening calls; facial photographs used for identity verification.
Payment card details (processed by third-party payment gateways), bank account details, salary history as disclosed in your profile.
Information you voluntarily disclose in your resume or profile regarding disability status or health conditions.
Only where voluntarily disclosed by you for accessing affirmative action job categories. Entirely optional.
3.3 Data Collected Automatically
- Device & technical data: IP address, device type, operating system, browser type, unique device identifiers, mobile network information.
- Usage data: Pages visited, features used, search queries, job listings viewed, applications submitted, time spent on Platform, clickstream data.
- Location data: Approximate location derived from IP address; precise GPS location if you grant permission.
- Cookies & tracking: As described in Section 9 of this Policy.
3.4 Data Collected Through Third Channels
- WhatsApp: Message content, interaction history, and contact data when you use our WhatsApp channel. (Subject to Meta's Privacy Policy).
- Calling agents & AI-driven calls: Call recordings, transcripts, call duration, and call metadata.
- Public sources: Profile information from professional networking platforms (e.g., LinkedIn) if linked.
- Verification providers: Results from background check processes conducted by third-party providers.
4. How and Why We Use Your Personal Data
We process your personal data only for the purposes described below, and only where we have a valid lawful basis for doing so under the DPDP Act.
| Purpose of Processing | Categories of Data Used | Lawful Basis (DPDP Act) |
|---|---|---|
| Facilitating job search and matching | Name, profile, resume, location, skills, preferences | Consent (Sec. 6) |
| Enabling employers to find candidates | Profile, resume, application data, contact details | Consent (Sec. 6) |
| Account creation and management | Name, email, phone, device data | Consent (Sec. 6) |
| Identity and employer verification | ID documents, GST/registration numbers, KYC data | Consent (Sec. 6) |
| AI-driven screening and matching calls | Voice recordings, call transcripts, biometric data | Specific Consent (Sec. 6) |
| Processing payments and billing | Payment data, billing address, GST number | Contract performance / Consent |
| Sending job alerts & communications | Email, phone, WhatsApp contact | Consent (Sec. 6) / can withdraw |
| Fraud detection and platform security | Usage data, device data, IP address, account activity | Legitimate use (Sec. 7) |
| Compliance with legal obligations | Any data as required by law | Legal obligation (Sec. 7) |
| Improving Platform & new features | Anonymized / aggregated usage data | Legitimate use (Sec. 7) |
| AI model training and improvement | Anonymized interaction data only — no personal data | Legitimate use (Sec. 7) |
| Business transfers (merger / acquisition) | User data as part of due diligence | Legitimate use (Sec. 7) |
5. Data Sharing & Disclosure
5.1 With Employers / Job Providers
When you apply for a job or express interest in a listing, we share your profile data, resume, and application information with the relevant employer. You expressly consent to this sharing by applying. Once your data is transferred to an employer, that employer becomes an independent data fiduciary/controller for your personal data. Their handling of your data is governed by their own privacy practices. The Company is not responsible for how employers process, store, or use your personal data after it has been shared with them. You should review the employer's privacy policy before accepting any offer.
5.2 With Third-Party Service Providers
We engage third-party service providers to help us operate the Platform. These providers may have access to your personal data only to the extent necessary to perform their specific function, and are bound by confidentiality and data processing agreements. Categories include:
5.3 With Open Network Participants
Where the Platform participates in or integrates with open digital networks, your data (in limited, purpose-specific form) may be shared with other verified network participants as part of the interoperability function. We will seek specific consent before sharing data in any such context.
5.4 For Legal Compliance & Business Transfers
We may disclose your personal data to courts, law enforcement, or regulatory bodies when required to do so by Applicable Law, or when necessary to protect the rights, safety, or property of the Company, our Users, or the public. In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the successor entity.
6. Cross-Border Data Transfers
The Company uses third-party service providers, including AI platform providers, cloud infrastructure, and analytics tools, some of which may be located or process data outside India. Where personal data is transferred outside India, the Company shall ensure that such transfers comply with any restrictions or requirements imposed by the Central Government under Section 16 of the DPDP Act, and that appropriate safeguards (including contractual data processing agreements with recipient entities) are in place. By using the Platform, you consent to such transfers to the extent they are necessary for the provision of Services to you.
7. Your Rights as a Data Principal
Under the DPDP Act, you have the following rights in relation to your personal data processed by us. You may exercise these rights by contacting the Grievance Officer at info@jobsupi.com.
Right to Access
Request a summary of your personal data being processed by us, the purposes of processing, and the list of entities with whom it has been shared.
Right to Correction & Erasure
Request correction of inaccurate or incomplete data, or erasure of data that is no longer necessary for the purpose it was collected.
Right to Withdraw Consent
Withdraw consent for any or all processing activities at any time. Withdrawal does not affect lawfulness of prior processing.
Right to Grievance Redressal
Lodge a complaint with our Grievance Officer. If not resolved within 15 days, escalate to the Data Protection Board.
Right of Nomination
Nominate another individual to exercise your rights in the event of your death or incapacity.
Response Timeline: We will acknowledge your request within 48 hours and endeavour to resolve it within 15 (fifteen) days. We may require you to verify your identity before acting on a request.
Escalation: If your grievance is not resolved to your satisfaction, you may approach the Data Protection Board of India once it is operational.
8. Data Retention
We retain personal data only for as long as is necessary for the purposes for which it was collected, subject to any longer retention period required by Applicable Law.
| Category of Data | Retention Period |
|---|---|
| Account and profile data | Duration of account + 2 years post-deletion |
| Job application data | 60 days post-application (active); 2 years (archived) |
| Payment and billing records | 7 years post-transaction |
| AI call recordings and transcripts | 90 days, unless required for legal proceeding |
| Background verification documents | Duration of engagement + 1 year |
| Communication logs | 2 years |
| Employer KYC documents | Duration of account + 5 years |
9. Cookies & Tracking Technologies
We use cookies and similar technologies (pixel tags, web beacons, local storage objects) on the Platform. We use four categories of cookies:
- Strictly Necessary Cookies: Essential for the Platform to function (login sessions, security tokens).
- Functional Cookies: Remember your preferences (language, location, display settings).
- Analytics Cookies: Help us understand how users interact with the Platform. We use third-party tools for this.
- Marketing / Targeting Cookies: Used to deliver relevant job alerts and third-party advertisements. You may opt out of these.
You can control cookie settings through your browser. We do not use cookies to track sensitive personal data such as health, religion, or political affiliation for advertising purposes.
10. Children's Data
The Platform is primarily intended for adults aged 18 and above. We do not knowingly collect personal data from children under the age of 13 without verifiable parental consent. For users aged 13–17, where they are permitted to use the Platform for legitimate job search purposes under Applicable Law, we require verifiable parental or guardian consent before processing their personal data.
In compliance with Section 9 of the DPDP Act, we do not: (a) track children's behaviour on the Platform for profiling or targeting purposes; (b) serve behavioural advertising to users we identify as minors; or (c) process any personal data of a child in a manner that is detrimental to their well-being.
11. AI & Automated Decision-Making
JobsUPI uses artificial intelligence and machine learning technologies as part of core Platform functions, including:
- Algorithmic job matching: An automated system ranks and recommends job listings to Job Seekers and candidate profiles to Employers.
- AI-driven screening calls: Automated voice calls may be used to conduct preliminary candidate screening. These calls are AI-generated and recorded.
- Automated fraud detection: Our systems automatically flag accounts and listings exhibiting fraudulent activity patterns.
What you should know: Automated processing may have a significant effect on your use of the Platform. Our algorithms are designed to be neutral, but if you believe an automated decision has adversely affected you, you may contact our Grievance Officer to request a human review.
12. Data Security
We implement industry-standard technical and organizational security measures to protect your personal data, including: (a) encryption of data in transit (TLS/SSL) and at rest; (b) access controls and role-based permissions; (c) regular security assessments; (d) secure software development lifecycle practices; and (e) contractual data security obligations for all third-party processors.
Data Breach Response: In the event of a personal data breach, we will notify the Data Protection Board of India as required under the DPDP Act, notify affected users, and take all necessary steps to contain the breach.
Limitation: No method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security, and you use the Platform at your own risk in this regard.
13. Grievance Officer
In accordance with the DPDP Act and Intermediary Guidelines, Rule 3(2)(a), the Company has appointed a Grievance Officer:
Physical Address
AltF JMD Empire Square, Room No. MR1, 3rd Floor, Gurugram, Haryana – 122002
Response Time
Acknowledgement within 24 hours; resolution within 15 days
14. Updates to This Policy
We may update this Policy from time to time to reflect changes in Applicable Law, our data practices, or Platform features. When we make material changes, we will: (a) update the effective date at the top of this Policy; (b) notify registered users via email or in-app notification; and (c) where required by Applicable Law, seek fresh consent for new processing activities. Your continued use of the Platform after the effective date of an updated Policy constitutes acceptance of the changes. If you do not agree to the revised Policy, you must stop using the Platform and may request deletion of your account.
JOBSUPI — UNLOCKING JOBUPIX LABS PRIVATE LIMITED
grievance@jobsupi.com •legal@jobsupi.com •www.jobsupi.com
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