Data Governance and Privacy Shield Framework

1. Preamble

At CoDriveIT Private Limited, along with our affiliated entities (henceforth collectively denominated as "CDITPL"), we espouse an unwavering commitment to the inviolability of your digital privacy and accord paramount significance to the judicious stewardship and governance of any personally identifiable information entrusted to our care. This Privacy Policy ("Policy") meticulously delineates the modalities through which CDITPL aggregates, employs, disseminates, and transfers the personal information of users across its variegated digital ecosystem, encompassing, without limitation, its corporate websites, mobile applications, and other online interfaces, specifically including www.codriveit.com and its attendant services (collectively, the "Platform").

This Policy extends its regulatory ambit to all natural persons who access or interact with the Platform, as well as those whose personal information CDITPL may come to possess in the ordinary course of rendering its services (such as the contact particulars of individuals affiliated with our recruitment and consultancy partners) (hereinafter collectively referred to as "Users"). For the exigencies of this Privacy Policy, the terms "You" or "Your" shall be construed to denote the natural person accessing or utilizing the Platform.

2. Taxonomy of Personal Information Acquired by CDITPL

"Personal Information" (PI) is herein defined as any information appertaining to an identified or identifiable natural person. This encompasses conventional identifiers such as name, identification number, location data, online identifiers, or factors intrinsic to the physical, physiological, genetic, mental, economic, cultural, or social identity of said individual. It further subsumes any other information categorized as personal under the ambit of extant legal statutes.

At CDITPL Job Portal and Consultancy Services (“CDITPL”), we undertake the acquisition of Personal Information to furnish bespoke services and elevate the user experience. The typology and scope of information garnered are contingent upon the nature of your interaction with our platform and services. The ensuing taxonomy delineates the categories of Personal Information we may acquire and the methodologies employed for such acquisition:

• Registration for Notifications or Platform Enrollment: During these processes, we collect foundational identifiers such as your full name, electronic mail address, secure access credentials (password), geographical demarcation (country, city), telephonic contact number, and the corporate or organizational entity with which you are affiliated.
• Candidate Profile Genesis: The creation of a candidate profile may entail the collection of information conventionally featured in a curriculum vitae, such as your name, contact modalities (electronic mail and mobile telephony), academic qualifications, professional trajectory, extant and historical remuneration data, and any digital rendition of your resume voluntarily uploaded.
• Service Utilization Analytics: In the course of your engagement with our services, we meticulously collate data pertaining to the specific services accessed and your attendant usage patterns, encompassing system log data and granular location intelligence.
• Engagement via Surveys, Feedback Mechanisms, or Contests: Participation in these voluntary engagements may necessitate the collection of supplementary personal details, such as name, age, preferences, and contact information, contingent upon your election to participate.
• Provision of Sensitive Personal Information: You may elect to furnish sensitive categories of information, such as caste affiliation or eligibility for affirmative action programs. The provision of such data is entirely volitional and predicated upon your explicit and informed consent.
• User Communications and Interoperability: When you engage in communication with CDITPL, or interact with other platform participants such as employers or partners via our digital infrastructure, we archive the granular details of your communication and any personal data you elect to share therein.
• Technical Metadata Acquisition: Upon your ingress to our Platform, we deploy cookies and cognate tracking technologies to automatically harvest technical metadata pertaining to your device and browsing comportment, including Internet Protocol (IP) address, browser typology, and interactional data with our digital properties.
• Access to Affiliate Services via the Platform: Should you avail yourself of services proffered by our affiliates through the Platform's interface, your data may be shared with these entities in accordance with the stipulations articulated within this Privacy Policy. It is pertinent to note that the utilization of such affiliate services is additionally governed by their respective terms of service and privacy protocols, which we earnestly encourage you to peruse.
• Device-Specific Data Collection: When accessing our Platform via a computing device, we may collect granular device-specific data, encompassing technical specifications, operating system architecture, and precise location coordinates.
• Communication Monitoring (Legally Permissible): Where legally permissible, CDITPL reserves the prerogative to record and monitor your communications with us, including telephonic interactions, for purposes encompassing regulatory compliance, quality assurance protocols, and internal training initiatives.
• Social Media Integration or Authentication: Should you elect to authenticate your access to our Platform via your social media credentials or link such an account to our digital infrastructure, you thereby authorize us to collect, archive, and utilize information rendered accessible through the social media interface, in strict accordance with this Privacy Policy. We enjoin you to meticulously review the privacy configurations and policies of the pertinent social media platform to comprehend the modalities through which your information may be disseminated.

3. Permissible Utilization of Your Personal Information by CDITPL

At CDITPL Job Portal and Consultancy Services, we are resolutely committed to the ethical, transparent, and legally sound utilization of your personal data. We undertake the processing of your Personal Information solely when a valid juridical basis exists for such processing and in a manner that is strictly necessary and proportionate to the services we furnish.

The specific modalities of our data utilization are contingent upon the nature of your interaction with our digital ecosystem. We may process your Personal Information for the ensuing purposes:

• To effectuate the delivery of our services and products to you, including the dissemination of tailored job alerts, calendar synchronizations, pertinent search results, curated job or candidate recommendations (as applicable), and the facilitation of social media communication functionalities.
• To safeguard our user base and furnish efficacious customer support, encompassing the resolution of inquiries, the remediation of technical anomalies, and the assurance of a secure and seamless user experience.
• To augment your user experience through the strategic application of information gleaned via cookies and cognate technologies. This includes the personalization of your interaction with our platform and the iterative refinement of the overall quality and usability of our service offerings. (For granular details, please consult our Cookies Policy.)
• To enhance the functional efficacy and content relevance of our Platform, thereby ensuring superior functionality, optimal performance metrics, and enriched features for our user community.
• To conduct rigorous market research initiatives and user surveys, with the objective of discerning user preferences and iteratively refining our service portfolio.
• To disseminate marketing and promotional communications pertaining to our proprietary services and those of our affiliates, where explicitly permitted by applicable legal frameworks and subject to your duly registered preferences.
• To proactively prevent, meticulously detect, thoroughly investigate, and effectively respond to illicit activities, such as instances of fraud, financial malfeasance, and any contraventions of CDITPL’s Terms of Use, including the initiation of appropriate legal recourse where deemed necessary.
• To execute robust identity verification protocols, conduct comprehensive due diligence assessments, and perform mandatory government sanctions screenings, when mandated by prevailing legal statutes or internal regulatory frameworks.
• To establish, exercise, or defend our legal prerogatives, including in the context of ongoing or prospective legal proceedings, and to procure legal or professional counsel where deemed judicious.

4. Deployment of Cookies and Allied Tracking Technologies

Certain digital interfaces within the CDITPL Job Portal and Consultancy Services ecosystem strategically employ cookies and analogous tracking technologies to optimize user interaction and underpin essential site functionalities. A cookie, in this context, constitutes a diminutive text file archived within your browser, facilitating our comprehension of user comportment and preferences.

Specific cookies may retain previously furnished Personal Information to personalize your digital experience. These technological instruments contribute to the iterative enhancement of the Platform's operational efficiency and the refinement of user interaction paradigms.

The majority of contemporary web browsers afford users the granular capacity to manage cookie preferences, encompassing functionalities such as:

• Proactive notification upon the instantiation of a cookie.
• Selective authorization or proscription of all or specific typologies of cookies.
• Volitional or automated purging of archived cookies.

Caveat: Should you elect to proscribe or expunge cookies, certain integral functionalities of the Platform may be compromised, and you may be compelled to re-authenticate your credentials to access specific features.

Tracking technologies deployed within our Platform may automatically aggregate information such as:

• Internet domain and host name affiliations.
• Internet Protocol (IP) address allocations.
• Browser typologies and underlying operating system architectures.
• Clickstream data, encompassing visited pages, temporal engagement metrics, and navigational patterns.
• Access timestamps and temporal coordinates.

Our strategic deployment of cookies and allied tracking instruments facilitates the analysis of non-personal, aggregated datasets to discern prevailing trends, monitor site performance benchmarks, and iteratively enhance our service offerings. The utilization of this data is strictly governed by the tenets of this Privacy Policy and pertinent data protection legislation.

For a more granular exposition of our cookie utilization practices, we invite you to consult our dedicated Cookie Policy.

5. Juridical Foundation for the Collection and Processing of Personal Information

CDITPL undertakes the collection and processing of your Personal Information solely when a legitimate and lawful basis exists for such actions. The specific legal grounds upon which we predicate our processing activities may vary contingent upon the nature of the information in question and the contextual circumstances of its collection:

• Explicit Consent: In specific instances, we process your Personal Information based upon your freely given, specific, informed, and unambiguous consent. Where such consent is mandated by applicable data protection statutes, it will be solicited at the point of data collection, and processing will only commence subsequent to the affirmative provision of said consent.
• Compliance with Legal Imperatives: We may process your data when such processing is necessary for compliance with legal obligations to which we are subject, such as responding to lawful directives from law enforcement agencies, judicial authorities, or regulatory bodies, or to retain data in accordance with applicable statutory retention mandates.

6. Information Dissemination and Disclosure Protocols

We impose stringent limitations on access to your Personal Information, granting such access solely to those employees, contractual personnel, and third-party entities who necessitate such access to discharge their assigned duties or furnish services on our behalf.

CDITPL unequivocally refrains from the commercial sale or rental of your Personal Information. We may disclose such information only under the following circumscribed circumstances:

• Affiliated Entities and Corporate Group: With our affiliated entities for internal administrative exigencies or to deliver integrated services aimed at enhancing your professional trajectory or platform engagement.
• Recruitment Partners: Should your submitted resume align with the requisites of a specific employment opportunity, we may disseminate your pertinent details to prospective employers or recruitment intermediaries. By registering on the Platform and acceding to this Privacy Policy, you explicitly authorize such dissemination.
• Regulatory or Legal Mandates: To governmental authorities, law enforcement agencies, or legal representatives when compelled by legal mandate, or to safeguard our legitimate legal interests—such as compliance with a subpoena, judicial process, or the enforcement of our Terms of Use.
• Business Transition Events: In the event of a corporate merger, acquisition, reorganization, asset divestiture, or analogous transactional event, your data may constitute a transferred asset integral to the transaction.
• Third-Party Service Provisioners: With meticulously vetted third-party vendors engaged by CDITPL to manage essential operational facets such as data hosting, communications infrastructure, data analytics, or marketing initiatives. These external providers are contractually obligated to uphold the confidentiality and security of your Personal Information.
• Advertising Collaborators: To third-party advertising entities for the specific purpose of presenting tailored advertisements. These advertisers may infer certain characteristics about you based on your interactions with advertising content (e.g., demographic assumptions). However, we unequivocally do not furnish these entities with your directly identifiable personal information.
• International Data Transfers: Should your Personal Information be transferred beyond the territorial jurisdiction of India, we shall ensure that such transfers are executed in strict compliance with applicable legal frameworks and incorporate adequate data protection safeguards.
• Google API Utilization Governance: Any utilization and transfer of data received via Google APIs shall be governed by the Google API Services User Data Policy, including the stringent Limited Use stipulations therein.

7. Third-Party Content and External Hyperlinks

Our Platform may incorporate hyperlinks to external websites or third-party service providers. These links are provided solely for your convenience and informational enrichment. Upon your egress from our Platform and subsequent access to a third-party digital property, this Privacy Policy ceases to apply.

For illustrative purposes, services such as ‘Code 360’ are offered through our collaborative partnerships for skill enhancement and career development training. ‘Code 360’ is operated by Sunrise Mentors Private Limited under the brand designation Coding Ninjas. When accessing these affiliated services, the handling of your data will be governed by the privacy policies of Coding Ninjas. You are encouraged to review their privacy protocols, accessible on their respective digital interface.

CDITPL explicitly disclaims any responsibility or liability for the modalities of data utilization or archival employed by third-party platforms. We strongly advocate for a meticulous review of their respective privacy policies prior to any engagement with third-party content or services.

8. Privacy Safeguards for Minors

The Platform is exclusively intended for users who have attained the age of eighteen (18) years or the legally defined age of majority within their respective jurisdiction. By accessing and utilizing the Platform, you unequivocally affirm that you meet the requisite minimum age criterion.

If you are under the age of eighteen (or the legal age of majority in your jurisdiction), your access to and utilization of the Platform must be undertaken under the direct supervision and guidance of a parent, legal guardian, or responsible adult.

9. Data Retention Protocols

CDITPL shall retain your Personal Information only for the duration strictly necessary to fulfill the explicitly defined purposes for which it was collected, including:

• To facilitate the provision of contracted services.
• To adhere to mandatory legal, regulatory, or contractual obligations.
• To facilitate the resolution of potential disputes or the enforcement of our legal rights.

Upon the expiration of the applicable data retention period, your Personal Information shall be securely expunged, rendered anonymous through irreversible anonymization techniques, or archived in strict accordance with prevailing data protection legislation.

10. Mechanisms for Controlling Your Personal Information

You possess the inherent right to exercise the rights afforded to data principals or data subjects (as defined by applicable laws and regulations) with respect to your Personal Information undergoing processing by CDITPL (Career Development & IT Placement Limited).

CDITPL provides you with the means to maintain the accuracy and currency of your Personal Information. Should you, at any juncture, wish to:

a) Rectify, update, or otherwise correct your Personal Information; b) Obtain confirmation as to whether or not your Personal Information is being processed by our systems; c) Access your Personal Information or exercise your right to data portability; or d) Restrict the further dissemination of your Personal Information to third-party entities under specific legal exigencies—

We implore you to contact us utilizing the contact modalities detailed in Section 15 infra. To safeguard the integrity of your information, we may necessitate the provision of valid identification credentials prior to processing your request.

In accordance with pertinent data protection statutes, the exercise of certain rights may necessitate direct engagement with a relevant regulatory authority or a designated data protection officer. CDITPL, to the extent permitted by law, reserves the right to levy a reasonable administrative fee for the fulfillment of manifestly excessive or demonstrably unfounded requests. You acknowledge that these rights are not absolute and are subject to legal limitations and exceptions.

To effectuate the deletion of your account on our platform (e.g., naukri.com), you may utilize the dedicated account settings section accessible within your profile interface.

11. Confidentiality and Security Infrastructure

The security and confidentiality of your Personal Information constitute a matter of paramount importance to CDITPL. We have implemented a comprehensive suite of appropriate technical and organizational measures meticulously designed to safeguard your data against unauthorized access, disclosure, alteration, or destruction.

When engaging external service provisioners, we contractually mandate their adherence to the same rigorous standards of privacy and security that we ourselves uphold. Irrespective of the geographical location wherein your data is archived or transferred, CDITPL ensures that it benefits from an adequate level of protection commensurate with prevailing legal and industry best practice standards.

We are committed to full compliance with the stipulations of the Information Technology Act, 2000, and its associated rules and regulations, to ensure the robust preservation of your privacy rights. Our security infrastructure encompasses physical, electronic, and procedural safeguards implemented in strict accordance with applicable Indian legal frameworks. For a more detailed exposition of our security protocols, we invite you to visit: trust.naukri.com.

By utilizing our services and acceding to this Privacy Policy, you hereby acknowledge and agree that the security measures implemented by CDITPL are both adequate and reasonable for the protection of your Personal Information.

12. Social Media Engagement Protocols

CDITPL maintains official digital presences, including pages and accounts, across various social media platforms to facilitate communication with our user base and iteratively enhance our service offerings. We actively monitor and may archive posts or comments pertaining to our organization on these platforms to gain a deeper understanding of user feedback and sentiment.

We implore you to refrain from disseminating the following categories of information via social media channels:

• Sensitive Personal Data, including:
  • Special categories of data (racial or ethnic origin, political affiliations, religious or philosophical beliefs, health-related data, biometric or genetic data, etc.).
  • National identification numbers.
  • Records of criminal offenses or convictions.
• Content that is deemed inappropriate, offensive, or defamatory in nature.

CDITPL explicitly disclaims any responsibility or liability for user-generated content posted by external parties. Our organizational responsibility is strictly limited to the utilization of Personal Information posted or collected through our officially sanctioned channels by duly authorized personnel.

13. Amendments to this Privacy Policy

CDITPL reserves the unfettered right to amend, modify, or update this Privacy Policy at any time, at its sole discretion. Any such revisions shall become effective immediately upon their publication on the Platform. We earnestly encourage you to periodically review this policy to remain duly informed of the measures we undertake to protect your Personal Information.

14. Disclaimer of Liability

CDITPL does not archive any sensitive account-related information, such as credit or debit card credentials. We shall not be held liable for any loss or damage arising from the disclosure (whether intentional or unintentional) of such information during online transactions conducted on or via the Platform.

Should you voluntarily furnish CDITPL with any Personal Information that was not explicitly solicited during the registration process or the ordinary course of service utilization, CDITPL shall not be held liable for any attendant security breaches or unauthorized disclosures related thereto.

Should you have any inquiries or concerns regarding this Privacy Policy or the utilization of your Personal Information, we urge you to contact our designated Data Protection Officer, whose contact details are provided below.

15. Data Protection Officer / Grievance Officer

Should you have any complaints, concerns, or grievances regarding the processing of your Personal Information, you are invited to contact our Data Protection Officer / Grievance Officer at the following coordinates: