PRIVACY POLICY

Introduction

We, at Referlly (hereinafter collectively referred to as "Referlly" “Presumelly” “Firm” “We” “Our” “Us”), are committed to respecting your online privacy and recognize the need for appropriate protection and management of any personally identifiable information you share with us. This Privacy Policy ("Policy") describes how we collects, uses, discloses and transfers personal information of users through Referlly (the "Platform"). We collect information from users to enhance their experience. Please note that we do not share or disclose your information with other users of this platform unless you expressly and voluntarily choose to disclose it. This policy applies to those who visit the Platform, or whose information Referlly otherwise receives in connection with its services (such as contact information of individuals associated with Referlly including partners) (hereinafter collectively referred to as "Users"). For the purposes of this Privacy Policy, "You" or “Your” shall mean the person who is accessing the Platform.

By accessing and/or using the “Referlly” or other services, you agree to this privacy policy and the Terms of Use of “Referlly” and give consent to the collection, transfer, operation, storage, disclosure and other uses of your information as described in this Privacy Policy. Please do not access or use our services (“Referlly”) by any means or technology which conceals your actual geo-location or is unable to provide accurate details of the location because some key features of this platform may not function effectively if location data is unavailable or inaccurate.

If you have any doubts about this Privacy policy or how “Referlly” uses your personal information, shared preferences, or similar technologies, please contact “Referlly” on [email protected] or else stop using the services altogether.

Types of Personal Information collected by Referlly

"Personal information" (PI) - means any information relating to an identified or identifiable natural person including common identifiers such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person and any other information that is so categorized by applicable laws. We collect information about you and/or your usage to provide better services and offerings. The Personal Information that we collect, and how we collect it, depends upon how you interact with us. We collect the following categories of Personal Information in the following ways:

• name, email address, when you sign up for alerts on the Platform;
• information that one would usually include in a resume, including name, contact details including e-mail address and mobile number, work experience, date of birth, educational qualifications, a copy of your resume, etc. when you register on the Platform;
• Transaction ID, Mode of payment and errors/status of transaction, transaction amount and/or, date & time information when the user makes any payment on Presumelly using third party payment gateway. We do not collect, store or process any credit card, debit card, banking information, UPI or any other bank account related information.
• information related to the job description or interview you are preparing for;
• information about the services that you use and how you use them, including log information and location information, when you are a user of the services through the Platform
• we may collect your Personal Information such as name, age, contact details, preferences, etc. through surveys and forms, when you choose to participate in these surveys etc.;
• when you visit the Platform, we use cookies to automatically collect, store and use technical information about your system and interaction with our Platform;
• when you use a device to access the Platform, Referlly may collect technical or other related information from the device as well as the device location;
• To the extent permitted by law, Referlly may record and monitor your communications with us to ensure compliance with our legal and regulatory obligations and our internal policies.
• If you choose to sign in with your social media account to access the Platform, or otherwise connect your social media account with the services of the Platform, you consent to our collection, storage, and use, in accordance with this Privacy Policy, of the information that you make available to us through the social media interface. Please see your social media provider's privacy policy and help centre for more information about how they share information when you choose to connect your account.
• In Referlly we may keep your account anonyms to other user until you wish to reveal your identity and data. Once you share your personal data with other user then Referlly does not take responsibility of your shared data with another user.

How Referlly may use your Personal Information

We will only use your personal data in a fair and reasonable manner, and where we have a lawful reason to do so.

We may process your Personal Information for the following purposes:

• Providing our services and products to you;
• Protecting our Users and providing you with customer support;
• We use information collected from cookies and other technologies, to improve your user experience and the overall quality of our services (for more information please refer to paragraph below).
• Improving the Platform and its content to provide better features and services.
• Conducting market research and surveys with the aim of improving our products and services.
• Sending you information about our products and services for marketing purposes and promotions;
• Sending you information about the job opportunities available on job portals including but not limited to Referllly according to your skillset and work experience;
• Preventing, detecting, investigating and taking action against crimes (including but not limited to fraud and other financial crimes), any other illegal activities, suspected fraud, or violations of Referlly’s Terms of Use in any jurisdiction
• To the extent required for identity verification, government sanctions screening and due diligence checks.
• Establishing, exercising or defending legal rights in connection with legal proceedings (including any prospective legal proceedings) and seeking professional or legal advice in relation to such legal proceedings.
• We may send you push notifications
• We may collect background data, device identifiers
• We may collect in app chat data

We may use the information collected, to improve your user experience and the overall quality of our services. We use multiple such 3rd party services like Google Analytics , Open AI, Google Bard, Cash Free, Stripe etc (Link to the 3rd party Privacy Policy is mentioned below, kindly go through the same). We may combine personal information from one service with information, including personal information, from other services to create a rich profile of you, to better your experience on “Referlly”

• Google Analytics: https://policies.google.com/privacy?hl=en-US
• Open AI: https://openai.com/policies/privacy-policy
• Cash Free: https://www.cashfree.com/privacypolicy/
• Google Bard: https://developers.generativeai.google/terms
• Stripe: https://stripe.com/en-in/privacy
• Google Vertex: https://transparency.google/our-policies/privacy-policy-terms-of-service
• RazorPay: https://razorpay.com/privacy-policy
• Anthropic: https://support.anthropic.com/en/collections/4078534-privacy-legal
• Midjourney: https://docs.midjourney.com/docs/privacy-policy
• Proxy Curl: https://nubela.co/proxycurl/privacy-policy
• Scarpin.io: https://www.scrapin.io/privacy-policy

Cookie and Other Tracking Technologies

Some of our web pages utilize "cookies" and other tracking technologies. A "cookie" is a small text file that may be used, for example, to collect information about web-site activity. Some cookies and other technologies may serve to recall Personal Information previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them.

You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser, but please note that if you choose to erase or block your cookies, you will need to re-enter your original user ID and password to gain access to certain parts of the Platform.

Tracking technologies may record information such as Internet domain and host names; Internet protocol (IP) addresses; browser software and operating system types; clickstream patterns; and dates and times that our site is accessed. Our use of cookies and other tracking technologies allows us to improve our Platform and the overall experience. We may also analyse information that does not contain Personal Information for trends and statistics. Please find the detailed information about cookies in our Cookie Policy.

The Basis/ Grounds which we rely on for collection and processing of your Personal Information

Your Personal Information is collected and processed by Referlly based on the following legal grounds depending upon the nature of Personal Information and the legitimate purposes for which it is processed.

We do not share your personal information with companies, organizations and individuals outside of “Referlly” & its partner companies unless one of the following circumstances applies:

We collect and store user communications, including chat messages, for the purpose of providing, maintaining, and improving our services.Chat messages may be stored temporarily or for a longer duration, depending on operational requirements, legal obligations, dispute resolution needs, or security monitoring.

We retain such data only for as long as is reasonably necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

With your consent:

We will share device-level information with companies, organizations or individuals outside of “Referlly” when we have your consent to do so. When you agree to our Privacy Policy, you provide us consent to share your device-level information (mainly used for analytics, and services purpose). We do not share your personally identifiable information with any entity outside “Referlly.” without obtaining your consent.

For external processing:

We provide information to our affiliates or other trusted businesses or persons to process it for us, based on our instructions and in compliance with Privacy Policy and any other appropriate confidentiality and security measures.

Compliance with a legal obligation:

Your Personal Information may be processed by Referlly, to the extent that such processing is necessary to allow Referlly to comply with a legal obligation. An example of this would be if Referlly is required to disclose your Personal Information to respond to a court order or if Referlly is required to retain specific records for a fixed period to comply with requirements under any applicable law.

International Data Transfers

Our services may be accessed by users located outside the country in which our servers are hosted. By using our services, users consent to the transfer, storage, and processing of their data across international borders. We comply with applicable data protection laws relevant to international users.Where required, we implement appropriate safeguards such as contractual clauses or equivalent legal mechanisms to ensure adequate data protection.

Why Do We Collect Information?

• We collect, store, use and process Personal Information for a variety of business purposes, including:
• to operate, improve and optimize Referlly; - to personalize our Services, understand our users and their preferences to enhance user experience and enjoyment using our Services and improve our users' experience.
• to help you connect with the appropriate job opportunities available on Job Portals/Referlly;
• to provide access to certain areas, functionalities and features of our Services
• to notify you about product updates, new products or promotional offers
• to send related information, including confirmations, technical notices, updates, security alerts and support and administrative messages
• to respond to your comments and inquiries and provide customer support services
• to prevent potentially prohibited or illegal activities and protect our users
• to measure interest in our Services
• to ensure internal quality control; and
• to verify Individual identity.
• Inform you about our products and services

“Referlly” may use your Personal Information to provide materials about offers, products and services that may be of interest, including content or services. “Referlly” may provide you with these materials by push notification, or email, as permitted by applicable law, including:

To deliver promotional information to you; to tailor content, and exciting offers; to notify you about products and services or upcoming special offers/events that may be interesting for you; and to notify you about rewards, surveys, contests or other promotional activities or events sponsored or managed by us or our business partners.

To ensure platform safety, prevent misuse, and comply with applicable laws, we may automatically scan and analyze chat communications using technical and organizational measures.

Such monitoring is conducted solely for purposes including but not limited to:

• Detection and prevention of fraud, abuse, harassment, or unlawful activities
• Ensuring compliance with our Terms of Service
• Protecting users and the integrity of the platform

This process is primarily automated and does not involve human review unless flagged for security, legal, or compliance reasons.

Information Sharing and Disclosure

We restrict access to your Personal Information to employees and/or consultants who we believe reasonably need to know/or that information to fulfil their jobs to provide, operate, develop, or improve our products or services.

Referlly does not disclose, transfer or share your Personal Information with others except with:

• Our affiliates and group companies to the extent required for our internal business and/or administrative purposes and/or general corporate operations and for provision of services aimed at helping you in your career enhancement. We share your personal information with job portals to help you find out appropriate career opportunities (This is to inform you that Referlly is owned and operated by Referlly (Registered Partnership Firm));
• Third parties including enforcement, regulatory and judicial authorities, if we determine that disclosure of your Personal Information is required to a) respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims; or b) investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Referlly’s Terms of Use or as otherwise required by law;
• In the event of a merger, acquisition, financing, or sale of assets or any other situation involving the transfer of some or all of Referlly’s business assets we may disclose Personal Information to those involved in the negotiation or transfer.
• Third party service providers and marketing partners that Referlly engages to a) provide services over the Platform on Referlly’s behalf; b) maintain the Platform and mailing lists; or c) communicate with you on Referlly’s behalf about offers relating to its products and/or services. Referlly will take reasonable steps to ensure that these third-party service providers are obligated to protect your Personal Information and are also subject to appropriate confidentiality / non-disclosure obligations

Referlly does not intend to transfer Personal Information without your consent to third parties who are not bound to act on Referlly’s behalf unless such transfer is legally required.

If your Personal Information is transferred outside India, we take the necessary steps to protect your Personal Information in accordance with applicable data protection laws.

We do not sell or share chat content with other users or third parties for commercial purposes.

However, we may access, preserve, or disclose chat data if required to do so by law, regulation, legal process, governmental request, court order, or to:

• Enforce our legal rights
• Investigate potential violations
• Protect the safety, rights, or property of users or the public

Such disclosure will be limited to what is legally necessary and proportionate.

Third Party Content:

Please be aware that the Platform sometimes contains links to other sites that are not governed by this Privacy Policy. Users may be directed to third-party sites for more information, such as advertisers, blogs, content sponsorships, vendor services, social networks, etc.

Referlly makes no representations or warranties regarding how your information is stored or used on third-party servers. We recommend that you review the applicable privacy statements and policies of each third-party site linked from the Platform to determine their use of your personal information.

Children

To use the Platform, you agree that you must be the minimum age (described in this paragraph below) or older.

The minimum age for these purposes shall be eighteen (18), however if local laws require that you must be older for Referlly to be able to lawfully provide the services over the Platform to you then that older age shall apply as the applicable minimum age. We do not knowingly collect personal information of individuals under the age of eighteen years. If we get to know that personal information of such individuals is present in our systems, we will delete such information.

Retention of Personal Information

Your Personal Information will not be retained by Referlly any longer than it is necessary for the purposes for which the Personal Information is processed and/or in accordance with legal, regulatory, contractual or statutory obligations as applicable.

At the expiry of such periods, your Personal Information will be deleted or archived in compliance with applicable laws

Controlling your personal information

You have the right to invoke your rights which are available to data principals in relation to your Personal Information which is being processed by Referlly.

In the event of a data breach that compromises personal data, we will take prompt and appropriate action to contain, assess, and remediate the incident.

Where required by applicable law, we will notify affected users and relevant regulatory authorities within the prescribed timeframes, providing details of:

• The nature of the breach
• The data affected
• Steps taken to mitigate risks
• Recommended actions for users, if applicable

We maintain reasonable technical and organizational safeguards to minimize the risk of such incidents

Confidentiality and Security

The security and confidentiality of your Personal Information is important to us and Referlly has invested significant resources to protect the safekeeping and confidentiality of your personal data. When using external service providers acting as processors, we require that they adhere to the same standards as Referlly does. Regardless of where your Personal Information is transferred or stored, we take all steps reasonably necessary to ensure that personal data is kept secure.

We seek to ensure compliance with the requirements of the Digital Personal Data Protection Act, 2023 and Information Technology Act, 2000 and Rules made there under to ensure the protection and preservation of your privacy. We have physical, electronic, and procedural safeguards that comply with the laws prevalent in India to protect your Personal Information.

We ensure that appropriate technical and organisational security measures are in place to secure your data.

Social media

Referlly operates channels, pages and accounts on some social media sites to inform, assist and engage with customers. Referlly monitors and records comments and posts made on these channels about itself in order to improve its products and services.

We encourage you to communicate your personal information through the specified channels mentioned at the end of the policy.

Changes to this Privacy Policy

Referlly reserves the right to update, change or modify this Privacy Policy at any time. The Privacy Policy shall come to effect from the date of publication of such update, change or modification.

Disclaimer

Referlly does not store any account related information or any credit / debit card details. Referlly shall not be liable for any loss or damage sustained by Users as a result of any disclosure (inadvertent or otherwise) of any information concerning the User's account, credit cards or debit cards in the course of any online transactions or payments made for any products and/or services offered through the Platform.

In case any Personal Information is shared by you with Referlly, which is not requested by Referlly during registration, (whether mandatorily or optionally), Referlly will not be liable for any information security breach or disclosure in relation to such information.