Privacy Policy

Core Platform & Job Tech

Applicable to: Job Seekers, Employers, and Institutions

1. Privacy Commitment

Apuphi is committed to protecting the personal data of all Users. This Privacy Policy explains what data we collect, how we use it, with whom we share it, and the rights you hold. This Policy applies to the Phase 1 Platform only (Job Seekers, Employers, and Institutions) and is compliant with the Digital Personal Data Protection Act, 2023 (DPDPA), the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and applicable international standards.

By using the Platform, you consent to the data practices described in this Privacy Policy.

2. Data We Collect

2.1 Registration and Identity Data

Full name, email address, phone number.
LinkedIn profile data (if registered via LinkedIn OAuth).
Profile photo (optional).
WhatsApp number (for OTP verification and platform notifications).

2.2 Job Seeker — Professional Profile Data

Work experience, job titles, employment history, notice period, and expected salary.
Educational qualifications, institution names, and graduation years.
Skills, certifications, and course completions.
Resume/CV files (master and job-specific tailored versions).
Portfolio links and project descriptions.
Career preferences, career goal settings, and career reset selections.
Apuphi Score and its component breakdown.

2.3 Job Application Data

Jobs applied to, application status, and timestamps.
Auto-Apply activation status and complete audit trail of automated applications.
Job match percentages and profile-to-JD analysis results.
Skill gap analysis results based on target role requirements.
External course listings clicked and affiliate link tracking data.

2.4 Interview Data

Interview schedules, calendar slots, and communication logs.
Video interview recordings (stored securely with access controls).
Real-time audio transcripts generated from in-platform interview sessions.
AI-generated interview reports (keyword analysis, communication assessment, sentiment analysis, recommendation flags).
Interviewer manual assessment notes and ratings.

2.5 Employer and Business Data

Company name, registered address, industry, and business type.
Business verification documents (company registration certificates, trade licences).
Job postings, ATS interaction data, and candidate shortlist/rejection records.
Recruiter sub-account details.
Subscription plan and billing history.

2.6 Device and Technical Data

IP address, browser type, operating system, and device identifiers.
Session identifiers, cookie data, and platform usage logs.
Feature engagement analytics (page visits, feature interactions, drop-off points).
Click tracking for affiliate course links and external job redirections.

2.7 Communication Data

WhatsApp messages triggered by the Platform (interview reminders, job alerts, upskilling nudges, application status updates).
Email communication history initiated by the Platform.
In-app notification history.
Support ticket content and resolution history.
Waitlist sign-up data (name, email, phone, professional interest).

2.8 Institution and Administrator Data

Institution name, registered address, AISHE code or equivalent accreditation identifier.
TPO / Placement Officer name, designation, official email address, and phone number.
Sub-admin account details (Department Coordinator names and emails).
Student onboarding data: CSV uploads containing student names, emails, courses, academic year, and department.
Institution plan tier, billing history, and subscription renewal records.
Employer coordination activity: companies invited, student lists shared (consented students only), interview drive schedules.
Placement activity logs: application tracking, shortlisting data, interview outcomes, selection records, department-wise placement ratios.
Skill gap analytics data: aggregated skill gap metrics, market skill demand data, certification gap percentages.
NAAC/NBA report export history (Premium Plan).

2.9 Payment Data

Subscription plan and transaction records (processed via third-party PCI-DSS-compliant payment gateways; Apuphi does not store full payment card details).
Invoice history and payment dispute records.

3. How We Use Your Data

3.1 Platform Operations

To create and maintain your account and verify your identity.
To generate and dynamically update your Apuphi Score.
To match your profile with relevant job listings using our proprietary AI algorithm.
To execute Auto-Apply submissions with your explicit prior consent and maintain a full audit trail.
To auto-tailor your resume to specific job descriptions for ATS compatibility, subject to your preview and approval.
To conduct and record in-platform video interviews and generate AI interview reports.
To enable the Career GPS and Career Reset features.

3.2 AI and Personalisation

To identify skill gaps and surface relevant external course listings.
To calculate and display job match percentages on listings.
To learn from your application history to improve profile auto-fill and smart suggestions over time.
To flag AI/automation risk for job roles and suggest safer alternative career paths.

3.3 Engagement and Notifications

To send transactional and contextual notifications via WhatsApp, email, and in-app channels.
Notification types: interview reminders, preparation tips, application status updates, upskilling nudges, new job match alerts, and interview report availability.
To enable institutions (with student’s explicit consent) to view placement activity and skill metrics.

3.4 Security and Fraud Prevention

To verify employer identity and prevent fraudulent job postings (Company Validation & Anti-Fraud Protection).
To detect and prevent unauthorised access, abuse, or malicious activity.
To maintain audit trails of all automated actions including Auto-Apply and agentic browser automation.

3.5 Analytics and Platform Improvement

To monitor platform health: DAU/MAU trends, retention rates, activation rates, and interview outcomes.
To analyse conversion funnels from sign-up to job placement.
To improve AI models for job matching, interview analysis, and skill assessment.
To generate anonymised aggregate insights for employer-facing market reports.

3.6 Commercial Data Products (Talent Intelligence)

Apuphi may create and commercially distribute Talent Intelligence Products derived from platform data. These products are used to generate revenue and sustain the platform’s free and subsidised services for users. This includes:

Aggregated, anonymised workforce and skills data: market-level insights such as skill demand trends, hiring velocity by industry, salary benchmarking, and talent pool distribution — with no individual user identifiable in any output.
Anonymised hiring trend reports sold to enterprise clients, government bodies, research institutions, staffing agencies, or educational institutions.
Skill gap intelligence products derived from platform-wide data, provided to course platforms, upskilling providers, or policy bodies.
Recruiter and talent acquisition insights (e.g. candidate availability by role, location, or skill cluster) sold to recruiting firms or enterprise HR teams — in fully anonymised, aggregated form only.

Where Apuphi intends to share data that could be linked back to individual users (even in pseudonymised form) with commercial third parties, Apuphi will seek your explicit opt-in consent at the time of collection or before such sharing occurs. You may opt out of commercial data use at any time through your account privacy settings or by writing to support@apuphi.com, without affecting your access to the Platform.

3.7 Legal and Compliance

To comply with applicable laws, regulations, and court orders.
To respond to lawful requests from government authorities.
To enforce these Terms and resolve disputes.

4. Legal Basis for Processing

Apuphi processes personal data on the following lawful bases under the DPDPA, 2023:

Consent:: For Auto-Apply activation, interview recording, institutional data sharing, WhatsApp engagement, and any commercial data sharing that involves pseudonymised or individually attributable data. Consent may be withdrawn at any time without affecting prior processing.
Contractual Necessity:: For account creation, subscription billing, and service delivery.
Legitimate Interests:: For platform security, fraud detection, analytics, product improvement, and the creation of fully anonymised aggregate data products, where these interests are not overridden by your data rights.
Legal Obligation:: For compliance with applicable regulatory and statutory requirements.

5. Data Sharing and Disclosure

5.1 Between Platform Users

Job Seeker profiles and resumes are shared with Employers whose listings match the candidate, or where the Job Seeker applies.
AI Interview Reports are shared with the interviewing Employer only after the Employer submits their manual assessment.
Student data (profile, resume, skill scores, application history, interview reports, and employer feedback) is shared with the student’s registered Institution only where the student has provided explicit prior consent. Students may withdraw this consent at any time through their account settings.
Institutions may share filtered, consented student lists with invited employers through the Employer Coordination Module. Only data belonging to students who have consented to institutional data sharing is included.
Aggregated, anonymised skill gap and placement analytics (no individual identifiers) may be included in NAAC/NBA-ready institutional reports.

5.2 Third-Party Service Providers

Apuphi engages third-party providers for:

Cloud infrastructure and storage (processed within India or under adequate international transfer safeguards).
Payment gateway processing (PCI-DSS compliant; Apuphi does not store full card details).
WhatsApp Business API for notification delivery.
Email service providers for transactional and engagement communications.
Analytics and monitoring tools (data anonymised or pseudonymised where possible).

All third-party providers are contractually bound to process data only as instructed by Apuphi and to maintain appropriate security standards.

5.3 Affiliate Partners

Click-through data (course name viewed, link clicked) is shared with affiliate course partners for commission tracking. No personal identity data is shared with affiliate partners.

5.4 Legal Disclosures

Apuphi may disclose personal data when required by applicable law, regulation, court order, or governmental authority, or when necessary to protect the rights, property, or safety of Apuphi, its Users, or the public.

5.5 Commercial Data Sharing and Talent Intelligence

Fully anonymised and aggregated data (where no individual user can be identified) may be shared with or sold to enterprise clients, recruiters, research institutions, government bodies, upskilling platforms, or other commercial partners without requiring individual user consent, as no personal data is involved.
Pseudonymised or profile-level data that could be linked back to an individual will only be shared with commercial third parties where the user has provided explicit opt-in consent. Such consent will be sought separately and clearly at the point of data collection or before any such sharing occurs.
Apuphi will never sell raw, identified personal data (name, contact details, and full profile) to third parties for their independent direct marketing use without your explicit consent.
Users may opt out of commercial data use at any time through their account privacy settings or by writing to support@apuphi.com. Opting out will not affect access to the Platform or any features.

6. Data Retention

Active accounts: Data retained for the duration of the account plus up to 3 years post-closure.
Interview recordings: Retained for 12 months post-interview.
Audio transcripts and AI reports: Retained for 12 months.
Payment and billing records: Retained for 7 years as required under Indian financial regulations.
Waitlist sign-up data: Retained for 2 years or until the User opts out.

After the applicable retention period, data is securely deleted or irreversibly anonymised.

7. Data Security

Apuphi implements industry-standard technical and organisational measures to protect your data:

Encryption of data at rest and in transit using TLS/SSL protocols.
Role-Based Access Control (RBAC) limiting internal access to personal data on a need-to-know basis.
Secure access controls for interview recordings and transcripts.
Mandatory employer verification before access to candidate data pools.
Complete audit trails for all automated actions (Auto-Apply, agentic browser automation).
Regular security audits and vulnerability assessments.

No method of electronic transmission or storage is 100% secure. Users are encouraged to maintain strong, unique passwords and enable all available security features on their accounts.

8. Your Data Rights

As a data principal under the DPDPA, 2023, you have the following rights:

Right to Access:: Request a copy of the personal data Apuphi holds about you.
Right to Correction:: Request correction of inaccurate or incomplete data.
Right to Erasure:: Request deletion of your personal data, subject to legal retention obligations.
Right to Withdraw Consent:: Withdraw consent for specific processing activities (e.g., Auto-Apply, WhatsApp notifications, institutional data sharing) at any time through your account settings or by writing to support@apuphi.com.
Right to Data Portability:: Request your profile data in a commonly used, machine-readable format.
Right to Grievance Redressal:: Lodge a complaint with Apuphi by writing to support@apuphi.com, or escalate to the Data Protection Board of India.

Requests should be submitted to support@apuphi.com. Apuphi will respond within 30 days of receiving a verifiable request.

9. Cookies and Tracking

Apuphi uses cookies and similar technologies to maintain session continuity, remember preferences, analyse platform usage, and track affiliate link click-throughs. You may manage cookie preferences through your browser settings. Apuphi does not serve third-party advertising cookies.

10. Users Under 18

Apuphi is open to users of all ages, including school and college students. Users under the age of 18 must have the consent of a parent or legal guardian before registering. Apuphi does not collect data from users under 18 beyond what is necessary for platform functionality. If we become aware that a user under 18 has registered without parental consent, we will take steps to notify the parent or guardian and, if required, delete the account. Parents or guardians with concerns may contact us at support@apuphi.com.

11. Cross-Border Data Transfers

Apuphi primarily processes data within India. Where data is transferred internationally for infrastructure purposes, such transfers are made subject to contractual safeguards compliant with the DPDPA, 2023 and applicable law.

12. Changes to this Privacy Policy

Apuphi may update this Privacy Policy to reflect changes in features, legal requirements, or operational practices. Users will be notified of material changes via registered email and in-app notification at least 14 days before the effective date. The updated date is displayed at the top of this document.

13. Contact Us

For all privacy-related queries, data rights requests, complaints, and general platform support, please contact us at:

Email: support@apuphi.com

Website: www.apuphi.com

Registered Office: Siliguri, West Bengal, India

Apuphi will endeavour to respond to all written requests within 30 days of receipt. If you are unsatisfied with our response to a privacy complaint, you may escalate to the Data Protection Board of India once constituted under the DPDPA, 2023.

Acknowledgement

By creating an account or using the Apuphi Platform, you confirm that:

You have read and understood these Terms and Conditions and Privacy Policy in their entirety.
You agree to be legally bound by these Terms.
You consent to the collection, use, and processing of your personal data as described in this Privacy Policy.
If you are under 18 years of age, you confirm that your parent or legal guardian has consented to your use of the Platform.
You understand that Phase 1 covers Job Seekers, Employers, and Institutions only, and that Mentor, Course Creator, and Task Worker features are not available in this phase.

This document constitutes the complete Terms and Conditions and Privacy Policy for the Apuphi Platform — Phase 1 (Job Seekers, Employers, and Institutions).