Privacy Policy

Consent

By registering for or using Disamina Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy. Your continued use of the Services signifies your ongoing consent. If you do not agree with any part of this Policy, your sole recourse is to immediately cease using Disamina Services.

Information collected through the Disamina may be processed, transferred, stored, and accessed in India and in other jurisdictions where Disamina, its affiliates, service providers, customers, or other users of the Services are located. By accessing or using the Disamina Services, you explicitly consent to the transfer, processing, use, and storage of your information in these jurisdictions. Disamina may, at its discretion, require users to reconfirm their consent to this Privacy Policy upon accessing the Disamina platform or utilizing specific Services, especially in cases of significant policy updates or changes in data processing activities.

Personal Information

To provide and improve Disamina's services, we must collect certain information about you. The types of personal information we collect depend on how you interact with our Services.

Information You Provide

We collect information you directly provide to us, which may include:

• Account and Profile Information: When you create an account or use our Services, we collect your name, email address, phone number, job title, company name, and any other details you add to your profile.
• User Content: We store any content, information, or data you submit, upload, or create using our Services. This includes things like resumes, job applications, feedback, and other materials.
• Communication Data: When you contact us for support or other reasons, we collect and store the content of your communications, such as emails or chat messages.

Information We Collect Automatically

When you use our Services, we automatically collect information about your activity. This data helps us understand how our Services are used and how we can make them better.

• Usage and Log Data: We collect information about your interactions with our Services, including your IP address, browser type, operating system, and the pages you visit. This data helps us monitor the performance of our platform and troubleshoot issues.
• Cookies and Tracking Technologies: We use cookies, pixel tags, and other similar technologies. These are small files stored on your device that help us remember your preferences, enhance your experience, and analyze how our Services are being used.
• Device Information: We collect information about the devices you use to access our Services, such as the device type and unique device identifiers.

Other Information We May Collect

• Payment Information: If you make a purchase, we collect necessary payment details (like your credit card number, billing address, and transaction details) to process your payment securely.
• Location Information: We may collect your general location information (like your city and country) based on your IP address. We will only collect more precise location data if you give us specific permission through your device settings.

Important Note: Our Services are not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected data from a child under 18 without parental consent, we will take steps to delete that information.

We use the information we collect to provide, maintain, and improve our Services, to communicate with you, to process payments, and to comply with our legal obligations. The full details on how we use your information are outlined in other sections of this Privacy Policy.

Non-Personal Information

Non-Personal Information ("NPI") is data that does not directly identify you as an individual. We collect NPI to understand trends, improve our services, and enhance your experience on the Disamina platform. This type of information may include:

• Technical Data: The type of web browser and operating system your computer uses, device information, and IP addresses (when not linked to identifiable personal data).
• Usage Data: Pages you visit on Disamina, the date and time of your access, and how you navigate our platform.
• De-identified Information: Personal information that has been anonymized so it can no longer be used to identify you.

We use NPI to analyze user behavior, customize our Services, and improve their content and functionality. For instance, we might analyze aggregate demographic data to better tailor our offerings. This aggregated data does not identify any individual and is treated as NPI under this Privacy Policy.

We may also use third-party tools that employ cookies and similar technologies to track NPI, such as website traffic and visitor trends in aggregate. This helps us generate statistical reports and benchmark the performance of our Services, ultimately allowing us to enhance the Disamina experience for all users.

Specific Data Collection for Assessment Proctoring, AI Video Interview and Integrity

Certain Disamina Services, particularly those related to online assessments and AI Video Interview, may require us to collect specific types of data to ensure the integrity and fairness of the process. This is done based on the requirements set by the Recruiting Organization or Organization administering the assessment or assessments created by Disamina. Depending on the specific setup, these activities may include:

• Session Recording: Recording assessment and interview sessions using one or more cameras (e.g., webcam, mobile device camera).
• Screen Recording: Recording the screen activity of your computer during the assessment and interview.
• Voice Recording: Recording voice during assessment and interview sessions using one or more cameras/mics.
• Environment Check: Reviewing your surroundings (environment check) before or during the test to ensure a secure testing environment.
• Object and Activity Monitoring: Monitoring for the presence or use of unauthorized objects, suspicious activities, or suboptimal proctoring activities that alter your test-taking environment.
• AI Proctor Oversight (if applicable): Use of AI proctors who may invigilate the exam in real-time.
• System-Generated Flags: Employing automated systems that flag anomalies during the test based on predefined standard operating procedures for human review.
• Facial Analysis (for verification and integrity): Utilizing technologies, including potentially Microsoft APIs, for specific requirements related to facial matching (to verify identity) and facial detection (to ensure exam integrity and detect unauthorized presence).

How We Use Your Information

We use the information we collect to provide, maintain, and improve Disamina's Services. Our use of your information depends on your role and how you interact with our platform:

For Employees, Contractors, and Operators of Recruiting Organizations or Any Institutions:

• Provide Services: Deliver the Disamina Services you have requested, create and manage your accounts, and monitor for unauthorized activity.
• Communicate: Send you important information about the Services you're using, respond to your customer support requests, inform you about new features, invite your feedback, and provide policy updates.
• Improve Services: Analyze the collected information to understand user needs and continuously enhance our Services.

We limit access to your personal information to our employees and contractors who have a legitimate business need to access and use this information for the purposes outlined herein.

For Candidates:

General Uses for All Users:

• Create and administer user accounts.
• Provide secure access to our Services.
• Maintain accurate records.
• Continuously improve our Services and user experience.
• Comply with legal and regulatory requirements.
• Understand and analyze user needs and preferences.
• Develop new products, features, and functionalities within our Services.
• Prevent cybercrimes, fraud, and other malicious activities.
• Generally provide, operate, and maintain the selected Disamina Services.

You have choices regarding the use of your information. You can decline certain types of information use by not providing the information in the first place or by exercising opt-out options where available. You can also disable cookies in your browser settings, though please note that this may affect the proper functioning of certain website features. We retain your Personal Information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, or as required by law. When we no longer have a legitimate need to process your information, we will securely delete, anonymize, or isolate your information, as appropriate.

Purpose and Legal Basis for Processing

The primary legal bases for collecting and processing Personal Information are to facilitate candidate evaluation for employment purposes and to ensure the integrity of interviews and assessments for recruiting organizations, as per our contractual obligations and legitimate interests.

Disclosure of Your Information

Unless explicitly stated otherwise in this Privacy Policy, Disamina will only share your Personal Information with third parties under specific, limited circumstances. We do not sell your Personal Information to third parties.

Sharing with Service Users and Providers:

• To Users of Services: We may disclose Personal Information and aggregate anonymous information to other users of our Services (for example, providing Candidate information to Employers) to fulfill the purpose of our Services.
• To Third-Party Service Providers: We engage trusted companies, agents, contractors, or others to perform functions on Disamina's behalf (e.g., cloud hosting). In such cases, these third parties may have access to your Personal Information, but only to the extent necessary to perform their specific functions as outlined to deliver the Services. They are contractually obligated to use such information solely for the agreed-upon purposes and to maintain its confidentiality.

Business Transfers and Affiliates:

• Affiliates: Disamina may disclose Personal Information and aggregate anonymous information to our affiliated businesses, divisions, and units to achieve the necessary objectives for effective Service delivery.
• Corporate Transactions: We reserve the right to disclose and transfer user information, including Personal Information, in connection with a corporate sale, merger, dissolution, acquisition, or similar transaction involving Disamina. In such an event, you will be notified via email and/or a prominent notice on our website or platform of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

Limited Sharing for Specific Purposes:

• Marketing and Promotions: We do not share mobile contact information with third parties or affiliates for marketing or promotional purposes. While information sharing with subcontractors for support services (like customer service) is permitted, all other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties for promotional messaging.

Legal and Safety Disclosures:

• Law Enforcement and Legal Compliance: We may cooperate with law enforcement authorities in investigating and prosecuting website or platform users who violate our terms or engage in behavior that is harmful (or illegal) to other users or to Disamina. We may transfer and disclose information about our users, including Personal Information, to enforce this Privacy Policy and other rules governing your use of our Services, protect our rights or property, protect someone else's safety or welfare, or comply with a law or regulation, court order, or other legal process. In such scenarios, your rights to amend or delete the data may require legal approvals.

Aggregate Anonymous Information:

• Disamina may also disclose aggregate anonymous information (which does not identify any individual) to clients, business partners, merchants, investors, potential buyers, and other related third parties if we deem such disclosure, in our discretion, to have sound business reasons or justification.

Intellectual Property Rights

All content, trademarks, logos, domain names, user interfaces, and the overall "look and feel" of the Disamina website and Services (collectively referred to as "Intellectual Property") are the sole and exclusive property of Disamina. You are strictly prohibited from using, copying, reproducing, distributing, transmitting, broadcasting, displaying, selling, licensing, or otherwise exploiting any such Intellectual Property for any purpose whatsoever without our prior written consent.

Third-Party Services and Links

The Disamina website and Services may include references and links to other websites and services provided by third parties, including Recruiting Organizations. Any Personal Information you provide directly to these third-party sites or services (including communications between Candidates, Employees, Recruiting Organizations facilitated through our Services) is provided directly to that third party. Such information is subject to that third party's privacy and security policies. Disamina is not responsible for the content, privacy practices, or security policies of any third-party sites or services to which links are displayed on our Services. We strongly encourage you to review the privacy and security policies of any third parties before providing them with your Personal Information.

Log Files

Disamina follows a standard procedure of using log files. These files record visitors and users when they access our websites and use our applications. This is a common practice among hosting companies as part of their hosting services analytics. The information collected by log files includes Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamps, referring/exit pages, and potentially the number of clicks. This information is not linked to any data that is personally identifiable. The purpose of collecting this information is for analyzing trends, administering the site, tracking user movement on the website, and understanding application usage.

Cookies and Tracking Technologies

From time to time, Disamina may use "cookies," "web beacons," or similar technologies to enhance your experience and convenience when using our Services. A cookie is a small text file recorded temporarily or persistently on a hard drive by a web page server; it is not used to deliver viruses or other harmful programs to your computer. Instead, cookies enable Disamina to recognize you without requiring repeated logins when you use the Services. Web beacons are graphics designed to collect web log information, such as pages viewed or messages opened. By relying on cookies, web beacons, and similar technologies, Disamina can deliver a more efficient and personalized service. Additionally, these technologies allow Disamina to monitor traffic patterns, Service usage, and session information to make the Services more useful and effective.

Children's Privacy

To use the Disamina platform, you must be at least 18 years old, or the age of majority in your jurisdiction, whichever is greater. This is the minimum age required for Disamina to lawfully provide our services to you. If you are under the age of 18 or the age of majority in your jurisdiction, you may only use the Disamina platform under the direct supervision of your parent, legal guardian, or another responsible adult.

Testimonials

We may display personal testimonials of satisfied customers on our website, in addition to other endorsements. With your explicit consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, please contact us at support@disamina.ai.

Referrals

If you choose to use our referral service to invite a user to our website or platform, we will ask you for your friend's name and email address. We will automatically send your friend a one-time email inviting them to visit the site. We store this information solely for the purpose of sending this one-time email and tracking the success of our invite program. Your friend may contact us at support@disamina.ai to request that we remove this information from our database.

Newsletters

If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails at any time by following the unsubscribe instructions included in these emails, or by contacting us at support@disamina.ai.

Processing of Information and Your Data Rights

Disamina is committed to delivering best data privacy practices and complies with the requirements of global privacy regulations, including GDPR (General Data Protection Regulation), LGPD (Lei Geral de Proteção de Dados), CCPA (California Consumer Privacy Act), PDPA (Personal Data Protection Act), and PIPEDA (Personal Information Protection and Electronic Documents Act) for general users. At Disamina, we respect your control over your Personal Information. As a data principal or data subject (terms used in various data protection laws), you have specific rights concerning how your data is processed by us. Disamina empowers you to keep your Personal Information accurate and current. At any time, you can reach out to us using the contact details provided in the "Contact Information" section below to:

• Rectify, update, or correct your Personal Information.
• Confirm whether or not we are processing your Personal Information.
• Access your Personal Information or exercise your right to data portability.
• Restrict the continued disclosure of your Personal Information to any third party by Disamina, under certain circumstances.

If you wish to delete your Disamina account or data, you can typically do so directly reaching out to the contact details provided under “Contact Information” section or submit your request here.

Data Integrity and Security

Disamina maintains reasonable and appropriate security measures to ensure the accuracy and integrity of Personal Information. We have implemented robust physical and technical safeguards to protect Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.

• Disamina actively monitors its Services to thwart all attempts of breaches and unauthorized access. We have a dedicated team for data security and incident management, who act swiftly if our system monitoring mechanisms suspect or detect any unauthorized access.
• We restrict access to your Personal Data to only those employees of Disamina, our affiliates, and third-party service providers who reasonably need it to provide Services.
• All Disamina employees and contractors undergo thorough background checks, verification, and periodic data privacy training.
• We have implemented commercially reasonable electronic, physical, and procedural safeguards designed to help protect against the loss, unauthorized access or disclosure, alteration, or destruction of the information under our control.
• All Personal Information and sensitive information collected by us is encrypted in transit using TLS 1.3 and at rest using AES 256 algorithms.

International Data Transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that differ from the laws of your country (and, in some cases, may not be as protective). Your personal information may be transferred to and processed in different countries around the world where our group companies and third-party service providers and partners operate, including in India, the European Union/European Economic Area, and the USA. This means that when we collect your personal information, we may process it in any of these locations. However, we have implemented appropriate safeguards to ensure that your personal information remains protected in accordance with this Privacy Policy and applicable laws. If you are from the EEA or the UK, these safeguards include implementing the European Commission’s Standard Contractual Clauses or UK Standard Contractual Clauses for transfers of personal information between our group companies and with our third-party service providers and partners. These clauses require non-EEA/UK companies to protect EEA/UK personal information they process in accordance with European Union or UK data protection law.

Data Retention

We retain your personal information for as long as it is required for the purposes stated in this Privacy Policy. Sometimes, we may retain your information for longer periods as permitted or required by law, such as to maintain suppression lists, prevent abuse, if required in connection with a legal claim or proceeding, to enforce our agreements, for tax, accounting, or to comply with other legal or contractual obligations. When we no longer have a legitimate need to process your information, we will delete or anonymize your information from our active databases. We will also securely store the information and isolate it from further processing on backup systems until deletion is possible according to our data lifecycle policies.

Compliance with This Privacy Policy

Disamina makes every effort, including periodic reviews, to ensure that the Personal Information you provide is used in conformity with this Privacy Policy. If you have any concerns about our adherence to this Privacy Policy or the manner in which your personal information is used, please write to us at support@disamina.ai. We will contact you, and if required, coordinate with the appropriate regulatory authorities to effectively address your concerns.

Notification of Changes

Disamina may modify this Privacy Policy at any time. We will notify you of any changes by posting an announcement on our Service or by sending an email to your primary email address. If we make significant changes to this Privacy Policy that affect your rights, we will provide you with at least 30 days' advance notice of the changes by email to your primary email address. If you believe that the updated Privacy Policy affects your rights with respect to your use of our products or services, you may terminate your use by sending us an email within 30 days of receiving the notification. Your continued use of the Services after the effective date of the changes to the Privacy Policy will be deemed your agreement to the modified Privacy Policy. You will not receive email notification of minor changes to the Privacy Policy. If you are concerned about how your personal information is used, you should check back on our privacy policy page periodically.

Contact Information

If you have any concerns or issues with respect to this Privacy Policy, please email us and we will endeavor to reply to you within 72 hours.

Disamina Corp Private Limited

Patna, Bihar, India

Email: support@disamina.ai