Privacy Policy – Zwayam

1. Introduction and Scope

Zwayam Digital Private Limited (a wholly owned subsidiary of Info Edge (India) Limited; “we”, “us”, “our” or “Zwayam”) values your privacy and is committed to safeguarding your personal data. Personal data refers to information about an individual that can identify them and relates to them, such as name, email address, phone number, among others (“Personal Data”).

We provide recruitment automation “Services” (as defined in our Terms and Conditions or specific service agreements) to our business customers (“Clients”). In providing our clients such Services, we process Personal Data of candidates or other end-users of our Clients. If you are a candidate or other end user of our Clients, we process your Personal Data only as a “Data Processor” on behalf of our Clients. For transparency, this Privacy Policy also explains how we process Personal Data as a Data Processor to our Clients. However, do note that we process such data solely on the instructions of, and under the control of our Clients, and expressly disclaim liability with respect to such Personal Data. Please refer to the respective Client’s privacy policy to better understand how your information is processed.

Info Edge (India) Limited provides several other services and platforms. This Privacy Policy is limited to provision and administration of the Zwayam website or Services. If you are a user of any other Info Edge service or platform, please refer to the privacy policy of the specific service or platform.

We recommend reviewing this Privacy Policy along with our Terms and Conditions, any specific service agreements, and any privacy notices provided when we collect your Personal Data. If there is a conflict between this Privacy Policy and a specific notice, the terms of the specific notice will prevail.

In limited circumstances, namely when you make business enquiries, for instance, when you contact us for a demo or with a query about our Services, we process business contact information and limited Personal Data as a “Data Fiduciary”/ “Data Controller”. Please note that we act as a Data Fiduciary/Data Controller only in these limited circumstances, details of which are provided in Section 7 of this Privacy Policy.

2. What data do we process and why?

The Personal Data we process depends on the activity and the purpose for which such Personal Data is required.

As a Data Processor we provide recruitment solutions to our Clients. For this, we process candidates’ Personal Data on the instructions of our Clients. Broadly, we use such Personal Data to administer the Services and comply with the Client’s instructions, including recruitment administration, candidate screening, scheduling interviews and managing communication, maintaining candidate records, among other tasks. Please contact the Clients for specific details of the Personal Data collected and the corresponding purpose for such processing. In providing Services, we may collect and process the following details of candidates on the Clients’ instructions:

• Candidate name and contact details, such as phone numbers, email addresses, residential address;
• Demographic details, such as gender, age/ date of birth, marital status;
• Photographs;
• Parent(s)’ details;
• Government issued identity proof(s) such as Aadhaar, PAN, passport, driver’s licence, voter ID;
• Prior work experience / employment information, including roles, work locations, project experience, salary details, experience certificates;
• Educational information, including school/ university details, qualifications, certifications, publications;
• Benefits related information such as EPF, ESIC (employee’s state insurance cooperation) details and nominee information;
• Social media profiles such as LinkedIn profile; and
• Any additional information which our Clients may collect and share with us for processing your candidature.

3. Who do we share your data with?

We share your Personal Data with third parties, in accordance with this Privacy Policy or as required by law.

1. Business Administration: To enable Zwayam to provide Services, Personal Data may be shared by Zwayam either with its own employees, officers, agents, directors’, other corporate entities and its parent entity (both in India and outside India) working on Zwayam’ s behalf to provide Services. This data is shared strictly in a need to know basis.
2. Legal and regulatory purposes: In limited circumstances, we may be required to disclose Personal Data processed on behalf of our Clients to government authorities or other third parties, where mandated by applicable law, legal process, or regulatory obligation.
3. Sharing with Third Parties: Where we process Personal Data on behalf of our Clients, we may share it with third parties such as background verification service providers strictly at the Clients’ direction. Additionally, if you provide explicit consent or make a specific request, we may share your Personal Data with other parties for purposes outside the scope of this Privacy Policy, as applicable.

4. How long do we keep your Personal Data?

As a Data Processor, Zwayam stores Personal Data for such duration as determined by the Clients. Unless otherwise determined by the Clients for a lesser period, Zwayam retains candidate Personal Information between three to maximum of six months depending on the Services availed by the Client. Please note that Zwayam may retain this information beyond the duration agreed to with the Client where mandated or obligated to do so under applicable law.

5. How do we protect your Personal Data?

We are committed to safeguarding your Personal Data with a range of technical and organizational measures to protect it from unauthorized access, misuse, alteration, or loss. We enforce strict requirements for employees, agents, contractors, and third parties to ensure compliance with this Privacy Policy. While we employ safeguards such as firewalls, data encryption, and access controls. If you have concerns or believe your interaction with us may no longer be secure, please contact us using the details in the “Contact Us” section below.

6. Your rights with Zwayam acting as a Data Processor

If you are a candidate or other end user of a Client, we only process your data on the Client’s behalf and on their instructions. If your Personal Data is processed by us as a Data Processor, please reach out to the Client directly to exercise your rights with respect to such Personal Data. We will redirect any communication or request received for exercise of rights with respect to such Personal Data to the relevant Client for their action.

7. Business Enquiries

We act as a Data Controller only in limited circumstances, namely when you make business enquiries, for instance, when you contact us for a demo or with a query about our Services on our website, we process business contact information and limited Personal Data. In such cases, we collect and process your Personal Data, including contact details, interaction data, preferences, and analytics information, to respond to your requests, communicate effectively, improve our Services, ensure compliance, and protect our business interests. This data may be shared on a strict need-to-know basis with authorized personnel, affiliates, and Sub Processors engaged for support services (e.g., cloud hosting, document signing), and may also be disclosed in the event of a corporate transaction.

We retain the Personal Data collected through business enquiries for as long as necessary to fulfil the purposes outlined above, comply with legal or contractual obligations, and maintain operational records. Once no longer required, such data is securely deleted. In certain cases, we may temporarily retain data to prevent fraud, resolve legal claims, or ensure regulatory compliance. We may also use anonymized or aggregated data for lawful analytics and service improvement. All Personal Data is stored on secure servers, including cloud infrastructure located in India.

As a Data Controller, we uphold your rights under applicable data protection laws. You have the right to request access to your Personal Data, seek rectification or erasure (subject to our legal retention obligations), file grievances with our Grievance Officer, and opt out of non-essential communications. To exercise your rights or raise queries, please contact us at privacy@zwayam.com. We may verify your identity before acting on your request and reserve the right to decline requests that are excessive, unfounded, or restricted by law.

8. Cookies and Tracking Technologies

When you visit our website, we may place a number of cookies in your browser. For example, we use cookies on our websites to understand visitor and user preferences, improve their experience, and track and analyse usage, navigational and other statistical information. Additionally, cookies may allow us to bring customized features to you. You can control the use of cookies at the individual browser level. If you elect not to activate the cookie or to later disable cookies, you may still visit Zwayam’s website, but your ability to use some features or areas of the website may be limited. We may use any of the following categories of cookies:

1. Essential Cookies: Essential cookies are sometimes called “strictly necessary” as without them we cannot provide the Services or basic functionality. For example, essential cookies help remember your preferences as you move around the website. Essential cookies also keep you logged in into a website. Without them the login functionality would not work.
2. Analytics Cookies: These cookies track information about visits to the website so that we can make improvements and report our performance. For example: analyse visitor and user behaviour so as to provide more relevant content or suggest certain activities. They collect information about how visitors use the website, the number of each user’s visits and how long a user stays on the website. We might also use analytics cookies to test new ads, pages, or features to see how users react to them.

9. Third Parties and Links

Some pages of our website may contain external links. You are advised to verify the privacy practices of such other websites. We are not responsible for the manner of use or misuse of information made available by you at such other websites. We encourage you not to provide personal information, without assuring yourselves of the privacy policies of other websites. Accessing or using these third-party options is done at your own discretion, and we highly recommend reviewing their privacy policies to understand how they treat your data.

10. Contact Us

You may contact us to exercise your rights or for notifying discrepancies / raising grievances with respect to your Personal Data by contacting our Grievance Redressal Officer at:

Email: privacy@Zwayam.com

11. Updates to this Privacy Policy

We may update this Privacy Policy at any time by making changes, additions, or removals to its sections. When there are significant updates regarding how we handle Personal Data, we will notify you by sending an email to the primary address linked to your account or by displaying a prominent notice on our website. By continuing to use our website and related Services after such updates, you agree to the revised policy, as permitted by law. To stay informed about our latest privacy practices, we encourage you to review this Privacy Policy regularly.