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Privacy Policy

Roshanee

Owned and Operated by IndiHire Private Limited

INTRODUCTION, APPLICABILITY, DEFINITIONS, DATA COLLECTION & PURPOSES

IndiHire Private Limited (“IndiHire”, “Company”, “we”, “our”, or “us”), the owner and operator
of the Roshanee platform (“Platform”), values your privacy and is committed to protecting your
Personal Data in accordance with the Digital Personal Data Protection Act, 2023 (“DPDP Act”),
the Digital Personal Data Protection Rules, as applicable, the Information Technology Act, 2000,
CERT-In Directions and other applicable laws.

This Privacy Policy explains how we collect, use, store, disclose, retain and otherwise process
Personal Data when you use our Platform, including our website located at roshanee.co,
associated mobile applications (if any), community portals, knowledge hubs, recruitment services,
events, webinars, newsletters and all related services.

This Privacy Policy forms an integral part of the Terms of Use governing access to the Platform.

By accessing or using the Platform, creating an account, registering for events,
subscribing to newsletters, applying for opportunities, participating in community
discussions or otherwise submitting your Personal Data, you acknowledge that you
have read and understood this Privacy Policy.

Where your consent is required under applicable law, we shall seek such consent before
processing your Personal Data.

1. OUR DETAILS

The Platform is owned and operated by:

IndiHire Private Limited

Corporate Identification Number (CIN):
U74140DL2011PTC215157

Registered Office:
709, Bhandari House 91,
Nehru Place,
New Delhi – 110019

Email:
info@roshanee.co

Website:
roshanee.co

For the purposes of the DPDP Act, IndiHire Private Limited acts as the
Data Fiduciary.

2. SCOPE

This Privacy Policy applies to every individual interacting with the Platform including,
but not limited to:

This Privacy Policy applies irrespective of whether you access the Platform through:

3. DEFINITIONS

Account means a registered account created by a User on the Platform.

Applicable Law means all laws, regulations, notifications, circulars and governmental directions applicable to the processing of Personal Data.

Consent shall have the meaning assigned under the DPDP Act.

Cookies means small text files placed on your browser or device for remembering preferences, authentication, analytics and improving user experience.

Data Fiduciary means IndiHire Private Limited.

Data Principal means the individual to whom Personal Data relates.

Personal Data means any data about an individual who is identifiable by or in relation to such data.

Processing includes collection, recording, organization, storage, adaptation, retrieval, consultation, use, disclosure, sharing, transmission, alignment, restriction, deletion or destruction of Personal Data.

Platform means the website, applications, community portals and services operated under the brand “Roshanee”.

User means any person accessing or using the Platform.

4. APPLICABILITY

This Privacy Policy applies whenever you:

5. PRINCIPLES OF DATA PROCESSING

We process Personal Data in accordance with the following principles:

We collect only such Personal Data that is reasonably necessary for the purposes
identified in this Privacy Policy.

6. CATEGORIES OF PERSONAL DATA WE COLLECT

Depending upon your interaction with the Platform, we may collect the following categories of Personal Data.

A. Identity Information
B. Contact Information
C. Professional Information
D. Community Profile Information

As visible in your profile page, we may collect information such as:

E. Recruitment Information

Where recruitment features become available, we may collect:

F. Communication Information
G. Technical Information

When you use the Platform, we may automatically collect:

H. Usage Information
I. Authentication Information
J. Cookies and Similar Technologies

We may collect:

Details regarding cookies are provided in the Cookie Notice forming part of this Privacy Policy.

7. PERSONAL DATA WE DO NOT INTENTIONALLY COLLECT

Unless specifically required for a lawful purpose, we do not intentionally collect:

If such information is inadvertently received, we shall take appropriate measures to securely delete or anonymize it unless retention is required under applicable law.

8. HOW WE COLLECT YOUR PERSONAL DATA

We collect personal data through multiple channels.

A. Information You Provide Directly

Examples include:

B. Information Automatically Collected

We automatically collect technical and usage information through:

C. Information Received from Third Parties

Subject to applicable law, we may receive Personal Data from:

9. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA

Your Personal Data may be processed for one or more of the following purposes:

Account Management
Community Services
Recruitment Services
Knowledge Hub
Events
Communication
Security
Platform Improvement
Compliance

10. PURPOSE LIMITATION

We shall process Personal Data only for the purposes specified in this Privacy Policy or such other purposes as may be notified to you at the time of collection, unless otherwise required or permitted under applicable law.

We will not process your Personal Data for purposes incompatible with those for which it was originally collected without obtaining fresh consent where required under applicable law.

11. CONSENT

Roshanee processes your Personal Data in accordance with the Digital Personal Data Protection Act, 2023.

Where required under applicable law, we shall seek your free, specific, informed,
unconditional and unambiguous consent before processing your Personal Data.

Your consent may be obtained through one or more of the following methods:

Where consent is sought, the request shall:

Consent shall remain valid until withdrawn, unless otherwise required by law or where
continued processing is necessary for a lawful purpose.

12. WITHDRAWAL OF CONSENT

You may withdraw your consent at any time by:

Withdrawal of consent shall not affect the lawfulness of processing undertaken before such withdrawal.

Where withdrawal of consent makes it impossible for us to continue providing certain services,
your access to those services may be suspended or discontinued.

Upon withdrawal, we shall cease processing your Personal Data unless processing is required:

13. ACCURACY OF PERSONAL DATA

You represent and warrant that:

You agree to promptly update your profile whenever there is any material change to your information.

The Company shall not be responsible for losses arising from inaccurate or outdated information provided by you.

14. USER RESPONSIBILITIES

By using the Platform you agree that you shall not:

Users remain solely responsible for Personal Data voluntarily published in public areas of the Platform.

15. COOKIES AND SIMILAR TECHNOLOGIES

The Platform uses Cookies and similar technologies to improve functionality,
maintain security, personalize user experience and generate analytical insights.

Cookies may be temporary (Session Cookies) or remain on your device after your browsing session (Persistent Cookies).

The Platform may also use:

16. TYPES OF COOKIES

A. Strictly Necessary Cookies

These Cookies are essential for:

Without these Cookies certain Platform functions may not operate.

B. Functional Cookies

These Cookies remember your preferences including:

C. Performance Cookies

These Cookies enable us to understand:

D. Analytics Cookies

These Cookies help us measure:

Analytics information is aggregated wherever reasonably possible.

E. Security Cookies

Security Cookies assist in:

17. MANAGING COOKIES

You may control Cookies through:

Disabling certain Cookies may affect the functionality of the Platform.

18. ANALYTICS

We may use analytical tools to understand how users interact with the Platform.

Analytics may include:

Where possible, analytics information is aggregated or pseudonymised.

Analytics information is used to:

19. EMAIL COMMUNICATIONS

We may send communications relating to:

Operational communications necessary for providing Platform services may continue even if you opt out of promotional communications.

20. MARKETING COMMUNICATIONS

Subject to applicable law and your communication preferences, we may send:

You may opt out of promotional communications at any time by:

Opting out shall not affect mandatory service-related communications.

21. COMMUNITY CONTENT

The Platform enables users to participate in professional networking and community engagement.

Information voluntarily posted in public sections of the Platform may become visible to other users.

Such information may include:

Users should exercise caution before publishing Personal Data in publicly accessible areas.
The Company cannot guarantee that information voluntarily disclosed in public forums will remain private.

22. USER GENERATED CONTENT

You retain ownership of content submitted by you.

However, by uploading or publishing content on the Platform, you grant IndiHire a
non-exclusive, worldwide, royalty-free, revocable licence to:

This licence exists solely for operating, maintaining and improving the Platform.

23. ARTIFICIAL INTELLIGENCE AND AUTOMATED PROCESSING

The Platform may use artificial intelligence, machine learning or automated systems to improve user experience.

Such systems may be used for:

Automated systems are intended to support human decision-making and not replace independent human judgment in material decisions affecting users, unless otherwise permitted under applicable law.

24. PROFILING

The Platform may create user profiles based upon:

Profiling enables us to:

We do not sell profiling information to third parties.

25. THIRD-PARTY SERVICES

The Platform may integrate with trusted third-party service providers for operational purposes.

Such providers may include:

Each third-party service provider is contractually required to implement appropriate security measures and process Personal Data only in accordance with our instructions and applicable law.

26. SOCIAL MEDIA INTEGRATIONS

Where enabled, you may choose to interact with the Platform using third-party social networking services including professional networking platforms.

If you voluntarily link your account, we may receive information authorized by you or permitted by the relevant platform, such as:

The collection and processing of such information remain subject to this Privacy Policy.

Your interactions with third-party platforms are governed by their respective privacy policies.

27. THIRD-PARTY LINKS

The Platform may contain links to websites operated by third parties.

We do not control such websites and are not responsible for:

Users should review the privacy policies of third-party websites before providing Personal Data.

28. BUSINESS COMMUNICATIONS

Where you interact with IndiHire in a business or professional capacity, we may process business contact information for purposes including:

Such processing shall remain limited to the purposes for which the information was provided.

29. LEGAL BASIS FOR PROCESSING UNDER APPLICABLE LAW

Depending upon the circumstances, Personal Data may be processed on the basis of:

30. NO SALE OF PERSONAL DATA

The Company does not sell Personal Data to data brokers or unrelated third parties for monetary consideration.

Where Personal Data is shared with service providers, such sharing is undertaken solely for the purposes described in this Privacy Policy and subject to appropriate contractual and technical safeguards.

31. DISCLOSURE OF PERSONAL DATA

We do not disclose your Personal Data except as described in this Privacy Policy,
with your consent, or as otherwise permitted or required under applicable law.

Any disclosure shall be limited to the minimum Personal Data reasonably necessary
for the applicable purpose.

32. CATEGORIES OF RECIPIENTS

Subject to this Privacy Policy, we may disclose Personal Data to the following
categories of recipients.

A. Group Companies

Personal Data may be shared with IndiHire Private Limited and its subsidiaries,
affiliates, holding companies, successor entities, or companies under common
control for purposes including:

All such entities shall process Personal Data in accordance with this Privacy
Policy and applicable law.

B. Authorized Employees

Access to Personal Data is restricted to employees who require such access for
legitimate business purposes.

Such personnel may include:

Access is governed through role-based access controls and the principle of least privilege.

C. Service Providers

We may engage third-party service providers for functions including:

Each service provider is required by written agreement to:

D. Professional Advisors

Personal Data may be disclosed where reasonably necessary to:

Such recipients are bound by legal or contractual confidentiality obligations.

E. Regulatory Authorities

We may disclose Personal Data where required to:

Such disclosures shall only occur where required by applicable law or pursuant
to a valid legal process.

F. Business Partners

Where a webinar, event, certification programme or community initiative is jointly
organized with a business partner, limited Personal Data may be shared strictly
for administering such programme.

Where required by law, separate consent shall be obtained before sharing Personal Data
for such purposes.

33. NO UNAUTHORIZED DISCLOSURE

We shall not:

34. CROSS-BORDER TRANSFER OF PERSONAL DATA

The Platform may utilize infrastructure, cloud hosting, analytics providers,
or technology partners located outside India.

Accordingly, your Personal Data may be transferred to, stored in, or processed
in jurisdictions outside India, subject to applicable law.

Where cross-border transfers occur, we shall ensure that:

Where applicable law restricts transfers to specified jurisdictions, the Company
shall comply with such restrictions.

35. DATA LOCALIZATION

Where any category of Personal Data is required by applicable law or regulatory
direction to remain within India, the Company shall ensure compliance with such requirement.

Nothing in this Privacy Policy shall be interpreted as permitting transfers prohibited by law.

36. SECURITY OF PERSONAL DATA

The Company implements reasonable technical and organizational measures designed
to protect Personal Data against:

Security measures are periodically reviewed and enhanced in light of technological
developments and evolving risks.

No security system is completely immune from compromise. While we strive to protect
Personal Data, we cannot guarantee absolute security.

37. TECHNICAL SECURITY MEASURES

Depending on operational requirements, the Company may implement safeguards including:

Security controls are reviewed periodically based on risk assessments.

38. ORGANIZATIONAL SECURITY MEASURES

We maintain administrative safeguards including:

39. ACCESS CONTROLS

Personal Data is accessible only to authorized personnel on a need-to-know basis.

Access rights are:

40. DATA MINIMIZATION

The Company seeks to collect only the Personal Data reasonably necessary for
identified purposes.

We periodically review Personal Data holdings to remove information that is:

41. STORAGE OF PERSONAL DATA

Personal Data may be stored using secure infrastructure operated by:

Storage architecture may include redundancy, backups and disaster recovery systems designed to enhance resilience.

42. RETENTION OF PERSONAL DATA

Personal Data shall be retained only for as long as necessary to:

Where Personal Data is no longer required, it shall be securely deleted, anonymized or irreversibly de-identified, unless retention is required by law.

43. INDICATIVE RETENTION PERIODS

Unless a longer retention period is required by law or necessary for legal proceedings, Personal Data may generally be retained as follows:

CategoryTypical Retention
User Account InformationUntil account deletion plus up to 180 days for operational and backup purposes.
Customer Support RecordsUp to 3 years.
Event Registration RecordsUp to 3 years.
Webinar Attendance RecordsUp to 3 years.
Newsletter Subscription DataUntil unsubscribed or consent withdrawn.
Security LogsUp to 365 days.
Authentication LogsUp to 365 days.
Audit LogsUp to 7 years where required for compliance.
Financial RecordsAs required under applicable tax and corporate laws.
Recruitment Records (where applicable)Up to 2 years from last interaction unless consent is withdrawn earlier.

These periods are indicative and may be modified where required by law or legitimate operational needs.

44. ACCOUNT DELETION

You may request deletion of your account by contacting us through the mechanisms provided on the Platform or by emailing the Grievance Officer.

Upon verification of the request, we shall:

Deletion from live systems may occur before deletion from encrypted backups, which are overwritten in accordance with our backup lifecycle.

45. BUSINESS CONTINUITY AND BACKUPS

To maintain operational resilience, Personal Data may be included in secure backup systems.

Backup copies are:

Backup data is not ordinarily restored except where necessary for recovery or legal compliance.

46. CHILDREN’S PERSONAL DATA

The Platform is intended primarily for professionals, recruiters, employers, and individuals aged eighteen (18) years or above.

We do not knowingly collect Personal Data from children where prohibited under applicable law.

Where processing of a child’s Personal Data is permitted or required under applicable law, such processing shall be undertaken only after obtaining verifiable consent from the parent or lawful guardian and in compliance with applicable statutory requirements.

If we become aware that Personal Data has been collected from a child without the required authorization, we shall take reasonable steps to delete such information.

47. FRAUD PREVENTION

We may process Personal Data for the purposes of:

Such processing may include monitoring login behaviour, unusual account activity and security events.

48. SECURITY INCIDENTS AND PERSONAL DATA BREACHES

The Company maintains documented procedures for identifying, assessing, containing, investigating and responding to security incidents involving Personal Data.

Where a Personal Data breach is likely to trigger reporting obligations under applicable law, the Company shall:

49. BUSINESS REORGANIZATION

In the event of:

Personal Data may be transferred to the successor entity, subject to applicable law and appropriate safeguards.

The successor entity shall be required to honor the commitments contained in this Privacy Policy or provide an equivalent level of protection.

50. PRIVACY BY DESIGN

The Company endeavors to incorporate privacy considerations throughout the lifecycle of its products and services.

Privacy considerations may include:

51. ACCOUNTABILITY

The Company maintains internal governance measures to promote compliance with applicable privacy and data protection laws.

These measures may include:

52. RIGHTS OF DATA PRINCIPALS

IndiHire recognizes and respects the rights available to Data Principals under the Digital Personal Data Protection Act, 2023 and other applicable laws.

Subject to applicable law, you may exercise the following rights:

A. Right to Access Information

You may request information regarding the processing of your Personal Data, including:

B. Right to Correction and Completion

If your Personal Data is inaccurate, incomplete or outdated, you may request that it be corrected, updated or completed.

You may also update certain information directly through your account settings where such functionality is available.

C. Right to Erasure

Subject to applicable law, you may request deletion of your Personal Data where:

The Company may retain certain information where retention is necessary to:

D. Right to Withdraw Consent

Where processing is based on your consent, you may withdraw such consent at any time through the mechanisms described in this Privacy Policy.

Withdrawal of consent shall not affect processing undertaken before such withdrawal.

E. Right to Grievance Redressal

You have the right to seek redressal of grievances relating to the processing of your Personal Data by contacting the Grievance Officer designated by the Company.

The Company shall endeavor to acknowledge and address grievances within the timelines prescribed under applicable law.

F. Right to Nominate

Where provided under applicable law, you may nominate another individual to exercise your rights under the DPDP Act in the event of your death or incapacity.

The Company may require reasonable documentation before acting upon such requests.

53. EXERCISING YOUR RIGHTS

Requests relating to Personal Data may be submitted through:

Before processing any request, the Company may require verification of your identity to prevent unauthorized disclosure, alteration or deletion of Personal Data.

Where a request is submitted by an authorized representative, additional proof of authority may be required.

54. RESPONSE TIMELINES

Upon receipt of a valid request, the Company shall:

Where additional time is reasonably required due to the complexity or volume of requests, the Company shall communicate the expected timeframe to the requester.

55. LIMITATIONS ON RIGHTS

The exercise of rights under this Privacy Policy may be limited where:

Any refusal to act on a request shall be based on applicable law and communicated with appropriate reasons where legally permissible.

56. DATA PRINCIPAL RESPONSIBILITIES

As a user of the Platform, you agree to:

You remain responsible for all activities conducted through your account unless unauthorized use is promptly reported to the Company.

57. USER CONTENT AND PROFESSIONAL INFORMATION

The Platform is intended to facilitate professional networking and knowledge sharing.

Information that you intentionally make visible to other users, such as:

May be accessible to other users of the Platform in accordance with your privacy settings and the functionality of the relevant feature.

You should avoid publishing confidential, proprietary or sensitive Personal Data in publicly accessible sections of the Platform.

58. COMPLIANCE WITH APPLICABLE LAW

The Company shall process Personal Data in accordance with applicable legal and regulatory requirements.

Nothing in this Privacy Policy shall limit the Company’s ability to:

59. CHANGES TO THIS PRIVACY POLICY

The Company reserves the right to amend this Privacy Policy from time to time to reflect:

Where material changes are made, the Company shall take reasonable steps to notify users through appropriate means, including:

Continued use of the Platform after the effective date of the revised Privacy Policy constitutes acknowledgment of such revised Privacy Policy to the extent permitted by law.

60. GRIEVANCE OFFICER

In accordance with applicable law, the Company has designated a Grievance Officer to address concerns relating to the processing of Personal Data.

Grievance Officer

Name: Saurabh Kumar

Designation: Grievance Officer

Company: IndiHire Private Limited

Address:
709, Bhandari House 91,
Nehru Place,
New Delhi – 110019

Email:
info@roshanee.co

The Grievance Officer shall endeavor to respond to grievances within the timelines prescribed under applicable law.

61. CONTACT US

For questions relating to this Privacy Policy or the processing of your Personal Data, please contact:

Privacy Team

Company: IndiHire Private Limited

Email:
info@roshanee.co

Website:

www.roshanee.co

62. GOVERNING LAW

This Privacy Policy shall be governed by and construed in accordance with the laws of India.

63. DISPUTE RESOLUTION

Any dispute arising out of or relating to this Privacy Policy shall be subject to the exclusive jurisdiction of the competent courts at Bengaluru, Karnataka, unless otherwise required by applicable law.

Nothing contained herein shall restrict the rights of a Data Principal to seek remedies available under applicable law.

64. SEVERABILITY

If any provision of this Privacy Policy is held to be invalid, unlawful or unenforceable by a competent court or authority, the remaining provisions shall continue in full force and effect.

65. WAIVER

Failure by the Company to enforce any provision of this Privacy Policy shall not constitute a waiver of such provision or any other provision.

66. ENTIRE PRIVACY POLICY

This Privacy Policy constitutes the entire privacy notice governing the processing of Personal Data through the Platform and supersedes prior versions of the Privacy Policy to the extent of any inconsistency.

Get in Touch

Questions? We’d love to hear from you.

                                       info@roshanee.co

                                  +91 99586 34591

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