PRIVACY POLICY

Dutybell – Website, Job Marketplace, Staffing & Career Services

Effective Date: 11 November 2026
Last Updated: 11 November 2026
Website: https://dutybell.com
Brand: Dutybell
Operating Entity: Veronica Educare Private Limited

1. INTRODUCTION

At Dutybell, we recognise that privacy and the protection of personal information are important to our users, candidates, employers, business partners and customers.

Dutybell is a staffing company integrated with a technology-powered job marketplace. We provide recruitment facilities, staffing solutions, HR services, employer tools, candidate services, career consultation, professional assessments, training programmes and other related digital services.

In delivering these services, we may collect, receive, store, use, process and share personal information relating to individuals who interact with our website, platform, forms, applications, services and business operations.

This Privacy Policy explains:

• What personal information we collect.
• How and why we collect personal information.
• How we use and process personal information.
• When and with whom we share personal information.
• How we protect and retain personal information.
• How candidates and employers can manage their information.
• What privacy rights are available to individuals.
• How users can contact us regarding privacy-related concerns.

This Privacy Policy applies to all individuals accessing or using:

1. The Dutybell website and associated digital platforms.
2. Candidate registration and job-seeker accounts.
3. Employer registration and recruitment dashboards.
4. Job posting and job application facilities.
5. Staffing and recruitment services.
6. HR outsourcing and managed services.
7. Career consultation and career-development services.
8. DBJET (Dutybell Job Entry Test).
9. Dutybell Academy and related educational services.
10. Online forms, service requests and customer support facilities.
11. Other products, services and digital facilities operated under the Dutybell brand.

By accessing our website or using our services, you acknowledge that you have been provided access to this Privacy Policy.

Where consent is the applicable legal basis for processing, we will obtain consent through an appropriate mechanism before processing the relevant personal information.

If you do not agree with this Privacy Policy, you should discontinue the relevant activity or service, subject to any legal or contractual obligations that may continue to apply.

2. ABOUT THE DATA CONTROLLER / DATA FIDUCIARY

For purposes of applicable Indian data-protection legislation, the organisation determining the purpose and means of processing personal data will be the relevant Data Fiduciary.

For the services operated under the Dutybell brand, the proposed operating entity is:

Company Name: Veronica Educare Private Limited
Brand Name: Dutybell
Website: https://dutybell.com

Compliance Officer

Name- Rakesh Kumar Purohit

Email- compliance@dutybell.com

For privacy-related enquiries, requests, complaints or concerns, individuals may contact us through the details provided in the Contact and Grievance Redressal section of this Policy.

Where another organisation independently determines the purpose and means of processing information, that organisation may have separate privacy responsibilities.

3. DEFINITIONS

For the purposes of this Privacy Policy:

3.1 Personal Data / Personal Information: Any information about an identifiable individual, including information that directly or indirectly identifies a person, as covered by applicable law.

3.2 Data Principal: The individual to whom personal data relates under the Digital Personal Data Protection Act, 2023.

3.3 Data Fiduciary: The person or organisation that determines the purpose and means of processing personal data.

3.4 Data Processor: A person or organisation that processes personal data on behalf of a Data Fiduciary.

3.5 Processing: Any operation performed on personal data, including collection, recording, organisation, storage, use, sharing, retrieval, disclosure, correction, erasure or destruction.

3.6 Candidate / Job Seeker: An individual who registers on Dutybell, uploads a resume, applies for employment, accesses career services or participates in recruitment activities.

3.7 Employer: An organisation, company or authorised representative using Dutybell for recruitment, job advertising, staffing or HR-related services.

3.8 User: Any individual accessing or using the Dutybell website or services.

3.9 Third Party: Any external service provider, organisation, employer, recruiter, institution, payment processor or other entity receiving information for an authorised purpose.

3.10 Consent: A freely given, specific, informed, unconditional and unambiguous indication of agreement to the processing of personal data for a specified purpose, where consent is the applicable legal basis.

4. PERSONAL INFORMATION WE COLLECT

The type of personal information collected depends on how you interact with Dutybell and which services you use.

We may collect the following categories of information.

4.1 Personal Identification Information

This may include:

• Full name.
• Date of birth, where required.
• Gender, where voluntarily provided or lawfully required.
• Photograph or profile picture.
• Identity-related information, where necessary for verification.
• Other information provided through registration or service forms.

4.2 Contact Information

This may include:

• Email address.
• Mobile number.
• Residential or communication address.
• City, state and country.
• Preferred contact details.
• Emergency contact information, where necessary for a particular service.

4.3 Candidate and Professional Information

For candidates and job seekers, we may collect:

• Resume or CV.
• Educational qualifications.
• Academic records and certifications.
• Employment history.
• Work experience.
• Current and previous designations.
• Skills and professional competencies.
• Technical and non-technical qualifications.
• Industry preferences.
• Expected salary and current compensation, where provided.
• Preferred job locations.
• Notice period and availability.
• Career objectives.
• Portfolio links and professional profiles.
• References and employment-related information.
• Other information voluntarily supplied during recruitment or career-service activities.

4.4 Employer and Business Information

For employers and business representatives, we may collect:

• Company or organisation name.
• Business address.
• Company website.
• Industry and business category.
• Business email address.
• Contact person’s name and designation.
• Official telephone number.
• Recruitment requirements.
• Manpower requirements.
• Job descriptions.
• Salary budgets.
• Hiring locations.
• Company registration or verification documents, where required.
• Billing and invoicing information.
• Purchase orders and commercial correspondence.

4.5 Account and Login Information

When users register on Dutybell, we may collect:

• Username.
• Email address.
• Encrypted or securely stored password credentials, as applicable to the authentication system.
• Account type.
• User role.
• Registration date.
• Login activity.
• Account preferences.
• Account verification status.
• Password-reset and authentication records.

We do not intend to collect users’ plain-text passwords through ordinary support communications.

4.6 Career Service Information

When individuals purchase or use our career services, we may collect:

• Resume documents.
• Career consultation details.
• Career goals and professional interests.
• Interview preparation requirements.
• Interview feedback.
• Job readiness assessment responses.
• Training preferences.
• Certification information.
• Career transition requirements.
• Information required to provide the purchased service.

4.7 DBJET Assessment Information

For DBJET participants, we may collect:

• Candidate identification details.
• Registration information.
• Assessment responses.
• Test scores.
• Performance reports.
• Assessment completion status.
• Attempt records.
• Certificates issued.
• Assessment-related communication.
• Information necessary to provide associated career assistance.

4.8 Dutybell Academy Information

Where individuals enrol in Dutybell Academy programmes, we may collect:

• Student name and contact information.
• Educational background.
• Course or programme selection.
• Enrolment information.
• Training attendance.
• Assessment results.
• Academic progress.
• Certification or programme-completion records.
• Information required for communication with educational partners, where applicable.

4.9 Payment and Transaction Information

When you purchase a paid service, we may collect or receive:

• Customer name.
• Billing details.
• Email address.
• Transaction reference number.
• Order identification.
• Payment status.
• Payment date.
• Purchased service details.
• Refund status.
• Invoice and GST-related information, where applicable.

Online payments are processed through Razorpay or another payment method expressly authorised by Dutybell.

Dutybell does not intend to collect or store complete card numbers, CVV numbers, UPI PINs, card PINs or confidential payment authentication credentials through its own website systems.

Such payment information is handled through the applicable payment provider and financial institution’s authorised systems.

4.10 Technical and Website Usage Information

When users visit our website, certain technical information may be collected automatically, depending on the website configuration and tools enabled.

This may include:

• IP address.
• Browser type and version.
• Device information.
• Operating system.
• Website access time.
• Pages visited.
• Referring website.
• Session information.
• Website interaction records.
• Approximate location derived from technical information.
• Error logs and diagnostic information.

4.11 Communication and Support Information

When users contact Dutybell, we may collect:

• Emails and correspondence.
• Customer support requests.
• Contact form submissions.
• Service enquiries.
• Complaints and feedback.
• Documents supplied for investigation.
• Records of communication with our support team.

4.12 Information from Third Parties

Where legally permitted and necessary, we may receive information from:

• Employers and recruitment partners.
• Background verification agencies.
• Educational institutions.
• Training partners.
• Payment service providers.
• Business clients.
• Publicly available professional sources.
• Other authorised service providers.

We will process such information for the relevant disclosed purposes and in accordance with applicable law.

5. HOW WE COLLECT PERSONAL INFORMATION

Dutybell may collect personal information through the following methods.

5.1 Direct Collection

We collect information directly when users:

• Register for an account.
• Complete candidate registration forms.
• Create employer accounts.
• Upload resumes.
• Apply for jobs.
• Post job vacancies.
• Submit employer service requests.
• Purchase career services.
• Enrol in assessments or training programmes.
• Complete DBJET registration.
• Contact customer support.
• Submit feedback or complaints.

5.2 Automatic Collection

We may automatically collect certain technical information through cookies, server logs, analytics tools and other website technologies, depending on the tools configured on our website.

5.3 Third-Party Collection

We may receive information from authorised employers, recruiters, service providers, payment processors, verification partners and other organisations where such collection is lawful and necessary.

5.4 Information Provided by Other Individuals

An employer, recruiter or authorised representative may submit candidate-related information on behalf of an individual.

Such persons must have the necessary authority or other lawful basis to provide that information.

Where required, appropriate notice and consent must be obtained from the concerned individual.

6. PURPOSES FOR WHICH WE USE PERSONAL INFORMATION

We collect and process personal information only for specified, legitimate and lawful purposes.

Depending on the services used, these purposes may include the following.

6.1 Account Creation and Management

We use information to:

• Register user accounts.
• Verify user identity.
• Authenticate login requests.
• Manage candidate and employer dashboards.
• Maintain account records.
• Provide account-related support.
• Protect accounts from unauthorised access.

6.2 Recruitment and Job Marketplace Services

We use candidate and employer information to:

• Facilitate job applications.
• Display relevant job opportunities.
• Match candidate profiles with recruitment requirements.
• Facilitate employer-candidate communication.
• Process applications.
• Support interview scheduling.
• Provide recruitment-related notifications.
• Enable authorised resume access.
• Manage job postings and candidate applications.

6.3 Staffing and Recruitment Services

We may process information to:

• Identify potential candidates.
• Evaluate professional qualifications.
• Conduct recruitment screening.
• Coordinate interviews.
• Support client hiring requirements.
• Manage workforce deployment.
• Facilitate employment-related documentation.
• Provide staffing and recruitment services.

6.4 HR and Employer Services

We may process relevant business and employee information to:

• Deliver HR managed services.
• Support recruitment process outsourcing.
• Coordinate payroll and tax services.
• Assist with HR administration.
• Conduct HR audits.
• Support employee onboarding and offboarding.
• Facilitate training and development.
• Manage workforce-related projects.
• Provide agreed HR advisory services.

6.5 Career Services

We may use information to:

• Prepare and improve resumes.
• Conduct career consultations.
• Provide interview preparation.
• Deliver job readiness programmes.
• Facilitate career transition services.
• Conduct employability assessments.
• Provide relevant professional development support.

6.6 DBJET Services

We may process participant information to:

• Register candidates for DBJET.
• Administer assessments.
• Record examination responses.
• Calculate and maintain scores.
• Generate scorecards and reports.
• Issue certificates.
• Provide associated career guidance.
• Maintain assessment records.

6.7 Dutybell Academy

We may process information to:

• Manage course enrolments.
• Communicate programme information.
• Track training progress.
• Coordinate assessments.
• Maintain educational records.
• Facilitate course delivery and certification.

6.8 Payment and Financial Transactions

We process relevant information to:

• Generate orders.
• Initiate payment requests.
• Confirm successful transactions.
• Maintain invoices.
• Manage refunds.
• Reconcile payment records.
• Prevent fraudulent transactions.
• Fulfil accounting and tax obligations.

6.9 Customer Support and Communication

We use information to:

• Respond to enquiries.
• Resolve complaints.
• Provide service updates.
• Send order confirmations.
• Communicate assessment information.
• Send important account notifications.
• Provide assistance relating to purchased services.

6.10 Security and Fraud Prevention

We may process information to:

• Detect suspicious account activities.
• Prevent fraudulent registrations.
• Protect candidate and employer information.
• Investigate unauthorised access.
• Maintain website security.
• Comply with lawful requests from competent authorities.

6.11 Marketing and Promotional Communication

Subject to applicable consent and communication laws, we may use contact information to send:

• Service announcements.
• Career-related information.
• Job alerts.
• Employer updates.
• New service announcements.
• Promotional offers.
• Newsletters.
• Events and programme invitations.

Users may opt out of promotional communications at any time.

Essential service, transaction, security and legal notifications may continue where necessary.

6.12 Legal and Regulatory Compliance

We may process information to:

• Comply with applicable laws.
• Respond to lawful government or regulatory requests.
• Maintain statutory records.
• Resolve disputes.
• Enforce contractual rights.
• Prevent or investigate unlawful activities.

7. LEGAL BASIS FOR PROCESSING PERSONAL DATA

Dutybell processes personal data in accordance with applicable Indian data-protection legislation.

Depending on the circumstances, processing may be based on:

7.1 Consent

Where consent is required, we will seek the individual’s consent for the specified purpose before processing the relevant personal data.

Consent must be freely given, specific, informed, unconditional and unambiguous, with a clear affirmative action.

7.2 Certain Legitimate Uses Recognised by Law

Where applicable, personal data may be processed for legitimate uses specifically recognised under the Digital Personal Data Protection Act, 2023.

These may include certain purposes involving:

• Voluntarily provided personal data for a specified purpose.
• Performance of functions or compliance with obligations under law.
• Certain employment-related purposes.
• Other legitimate uses expressly recognised by applicable legislation.

7.3 Contractual and Service-Related Requirements

Where applicable under law, we may process information necessary to provide a service requested by an individual or to fulfil an accepted contractual engagement.

7.4 Legal Obligations

We may process or retain information where required by applicable laws, court orders or lawful directions issued by competent authorities.

We do not intend to use personal information for unrelated purposes without an appropriate lawful basis.

8. CANDIDATE PRIVACY AND RESUME SHARING

Candidate information requires particular care because resumes and professional profiles may contain substantial personal details.

8.1 Candidate Profile Information

Candidates may create profiles and submit resumes through Dutybell.

Information may include personal details, contact information, educational qualifications, employment history and professional skills.

8.2 Sharing with Employers

Where a candidate applies for a job, relevant application information may be shared with the employer or authorised recruiter associated with that vacancy.

8.3 Resume Downloads

Employers with authorised access to Dutybell’s recruitment facilities may view or download candidate resumes in accordance with the applicable platform permissions and service plan.

8.4 Candidate Matching

We may use candidate qualifications, experience, skills and job preferences to identify potentially relevant job opportunities and recruitment requirements.

8.5 Candidate Responsibility

Candidates are responsible for ensuring that information submitted in their resumes and profiles is accurate and that they have the right to provide any included personal information.

8.6 Third-Party Recruitment

Once candidate information is shared with an employer or recruiter, that recipient may process it independently for recruitment and employment purposes.

The recipient’s own privacy policy and legal obligations may apply to its subsequent processing.

8.7 Candidate Profile Management

Candidates may request correction or deletion of information, subject to applicable law, contractual requirements and legitimate record-retention obligations.

9. EMPLOYER AND BUSINESS INFORMATION

Dutybell may collect business and professional information from employers, recruiters, companies and authorised representatives.

Such information may be used to:

• Create employer accounts.
• Publish vacancies.
• Facilitate candidate sourcing.
• Manage recruitment requirements.
• Deliver staffing and HR services.
• Prepare proposals and quotations.
• Process payments and invoices.
• Communicate service updates.
• Maintain business records.

Employers must ensure that any personal data supplied about employees, applicants or other individuals is provided lawfully and with the necessary authority.

Employers are responsible for their independent processing of candidate and employee information after receiving it through Dutybell, subject to their actual role and applicable law.

10. SHARING AND DISCLOSURE OF PERSONAL INFORMATION

Dutybell does not sell personal information to third parties as a commercial data product.

However, we may share personal information in the following circumstances where authorised and legally permitted.

10.1 Employers and Recruiters

Candidate information may be shared with employers and authorised recruiters for:

• Job applications.
• Recruitment screening.
• Candidate evaluation.
• Interview scheduling.
• Hiring-related communication.
• Employment-related processes.

10.2 Staffing and Business Clients

Where a candidate participates in a staffing or recruitment engagement, relevant information may be shared with the client organisation for the agreed recruitment or deployment purpose.

10.3 Payment Service Provider – Razorpay

Dutybell uses Razorpay as its online payment gateway.

When a customer makes a payment, relevant transaction information may be shared with Razorpay and associated financial institutions or payment networks to:

• Initiate and process payments.
• Authenticate transactions.
• Confirm payment status.
• Detect and prevent payment fraud.
• Process refunds where applicable.
• Resolve transaction disputes.
• Maintain payment records.

Razorpay processes payment-related information under its applicable terms, privacy policy and legal obligations.

Dutybell does not intend to collect or retain confidential payment authentication credentials such as UPI PINs, card PINs or CVVs.

10.4 Technology and Hosting Providers

We may share information with authorised service providers responsible for:

• Website hosting.
• Cloud storage.
• Database management.
• Website maintenance.
• Security monitoring.
• Backup management.
• Technical support.

10.5 Communication and Email Service Providers

We may use external providers for:

• Email delivery.
• OTP communication.
• SMS notifications.
• Customer support.
• Transaction notifications.
• Service-related communications.

Such providers may process the information necessary to deliver the relevant communication.

10.6 Analytics and Website Tools

Where configured, we may use analytics and performance tools to understand website traffic, user interactions and service performance.

The information collected may include technical identifiers, device information and website usage records.

10.7 Background Verification and Assessment Partners

Where necessary for a particular recruitment or staffing engagement, relevant information may be shared with authorised background verification, assessment or professional verification providers.

Such sharing shall be subject to appropriate authority, notice, consent or other applicable lawful basis.

10.8 Educational and Training Partners

Where Dutybell facilitates educational programmes or training through third-party institutions, relevant enrolment and academic information may be shared with the applicable partner to deliver the requested programme.

10.9 Professional Advisors

We may share relevant information with lawyers, accountants, auditors, consultants and other professional advisors where necessary for legitimate business or legal purposes.

10.10 Government and Regulatory Authorities

We may disclose information where required by:

• Applicable Indian laws.
• Court orders.
• Government directions.
• Regulatory requirements.
• Lawful investigations.
• Other legally enforceable requests from competent authorities.

10.11 Business Transfers

In the event of a merger, acquisition, restructuring, sale or transfer of business operations, relevant information may be transferred to the successor or acquiring entity, subject to applicable law and necessary safeguards.

10.12 Other Authorised Disclosures

We may share information with third parties where the individual has provided appropriate authorisation or where another lawful basis permits such disclosure.

11. RAZORPAY AND PAYMENT DATA PRIVACY

Dutybell uses Razorpay to facilitate online payments.

The following provisions apply to transactions made through the payment gateway.

11.1 When a user proceeds to checkout, the user may be redirected to or interact with Razorpay’s authorised payment interface.

11.2 Relevant transaction information may be transmitted to Razorpay to process the payment.

11.3 Payment methods may include those enabled through the applicable checkout interface, subject to availability and eligibility.

11.4 Razorpay and the relevant financial institutions may independently process payment-related information under their applicable policies and regulatory obligations.

11.5 Dutybell may receive transaction confirmation, payment status, transaction reference, order details and related payment information.

11.6 Dutybell does not intend to store complete card credentials, CVV numbers, UPI PINs, card PINs or confidential banking authentication credentials.

11.7 Users should review Razorpay’s privacy policy and applicable payment terms before completing a transaction.

11.8 Any payment dispute or transaction-related enquiry may be directed to Dutybell through its official support channels. We may coordinate with Razorpay or the relevant bank where necessary.

12. COOKIES AND TRACKING TECHNOLOGIES

Dutybell may use cookies and similar technologies to support website functionality and improve user experience.

Cookies are small text files stored on a user’s device by a website.

12.1 Essential Cookies

These cookies may be necessary for:

• Website navigation.
• Login and authentication.
• User sessions.
• Security.
• Form functionality.
• Basic website operations.

12.2 Functional Cookies

These may help remember:

• User preferences.
• Language settings.
• Display preferences.
• Other selected website settings.

12.3 Analytics Cookies

Where enabled, analytics cookies may help us understand:

• Website traffic.
• Page views.
• Visitor behaviour.
• Website performance.
• User interaction patterns.

12.4 Marketing Cookies

Where enabled and legally permitted, marketing technologies may help measure promotional campaign performance and provide relevant advertising or communications.

12.5 Third-Party Cookies

Some third-party services integrated into our website may place their own cookies or similar identifiers.

Their use may be governed by their respective privacy policies.

12.6 Managing Cookies

Users may manage or disable cookies through their browser settings or an available website cookie-preference mechanism.

Disabling essential cookies may affect account access, forms, dashboards or other website functionality.

Where applicable, Dutybell will obtain consent for non-essential cookies and similar tracking technologies.

13. DATA RETENTION AND DELETION

Dutybell retains personal information only for as long as reasonably necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable law.

The retention period may depend on the type of information and the service involved.

13.1 Account Information

Account information may be retained while an account remains active and for an appropriate period after closure where necessary for legal, security, contractual or operational purposes.

13.2 Candidate and Resume Information

Candidate profiles and resumes may be retained while the account remains active or while the candidate uses recruitment services.

After account closure or a valid deletion request, information shall be erased or anonymised where legally permissible and subject to applicable retention obligations.

13.3 Employer Information

Employer account and business information may be retained during the business relationship and for the applicable contractual, accounting and legal retention periods.

13.4 Payment and Financial Records

Payment records, invoices and transaction information may be retained for the periods required under applicable accounting, taxation and financial regulations.

13.5 Assessment and Certification Records

DBJET scores, assessment reports, certificates and related records may be retained for verification, service delivery, certificate validation, dispute resolution and other disclosed purposes.

13.6 Communication and Support Records

Emails, complaints and service-related communication may be retained for the period necessary to resolve enquiries, maintain records and fulfil legal obligations.

13.7 Security and Technical Records

Server logs, authentication records and security information may be retained for appropriate periods necessary to protect the website, investigate incidents and comply with applicable law.

13.8 Deletion and Anonymisation

When personal information is no longer required for the relevant purpose and there is no legal obligation to retain it, Dutybell shall take appropriate steps to delete or anonymise it.

13.9 Legal Retention Exceptions

Information may be retained where necessary for:

• Tax and accounting compliance.
• Employment and statutory obligations.
• Contractual disputes.
• Legal proceedings.
• Regulatory investigations.
• Prevention of fraud.
• Other lawful purposes.

14. PERSONAL DATA SECURITY

Dutybell recognises the importance of protecting personal information against unauthorised access, misuse, alteration, disclosure, loss or destruction.

Depending on the nature of the information and the technical systems used, we may implement appropriate security measures, including:

• Secure website connections using HTTPS/SSL.
• Password protection and access controls.
• Restricted access to personal information.
• Website and server security measures.
• Regular software and security updates.
• Backup and recovery arrangements.
• Security monitoring.
• Appropriate authentication mechanisms.
• Access restrictions for authorised personnel.
• Secure payment processing through Razorpay.

We endeavour to ensure that third-party service providers handling personal information maintain appropriate security measures.

However, no website, electronic transmission or data storage system can be guaranteed to be completely secure.

Users should maintain strong passwords, avoid sharing authentication credentials and notify us promptly if they suspect unauthorised access to their accounts.

15. PERSONAL DATA BREACHES

In the event of a personal data breach affecting information processed by Dutybell, we shall take appropriate steps in accordance with applicable law.

Such steps may include:

15.1 Investigating the nature and extent of the incident.

15.2 Taking reasonable measures to contain and mitigate the breach.

15.3 Implementing appropriate corrective and security measures.

15.4 Informing affected individuals and competent authorities where required by applicable law.

15.5 Maintaining relevant incident records.

15.6 Cooperating with authorised government or regulatory authorities.

Where the DPDP Act and Rules require notification, Dutybell shall follow the prescribed notification requirements and timelines, including notifications to affected Data Principals and the Data Protection Board of India, as applicable.

16. CROSS-BORDER DATA TRANSFERS

Dutybell may use technology providers, hosting services, communication systems or other service providers that process or store information outside India.

Where personal data is transferred or processed outside India, Dutybell shall take appropriate steps to comply with applicable Indian data-protection requirements.

Such transfers shall be subject to applicable restrictions, government notifications, contractual safeguards and other legal requirements.

Dutybell shall not knowingly transfer personal data to a jurisdiction where such transfer is prohibited under applicable Indian law.

17. YOUR PRIVACY RIGHTS

Subject to applicable law and the relevant commencement provisions, individuals may have the following rights concerning their personal data.

17.1 Right to Access Information

You may request information about the personal data processed by Dutybell and the relevant processing activities, as provided under applicable law.

17.2 Right to Correction

You may request correction of inaccurate or misleading personal information maintained by us.

17.3 Right to Completion

You may request completion of incomplete personal information, where applicable.

17.4 Right to Erasure

You may request deletion of personal information where it is no longer necessary for the relevant purpose and deletion is permitted under applicable law.

17.5 Right to Withdraw Consent

Where processing is based on consent, you may withdraw your consent at any time through the applicable mechanism or by contacting us.

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

17.6 Right to Grievance Redressal

You may raise privacy-related complaints and seek resolution through our designated grievance mechanism.

17.7 Right to Nominate

Where applicable under the DPDP Act, you may nominate another individual to exercise your rights in the event of your death or incapacity, in accordance with the prescribed requirements.

17.8 Right to Approach the Data Protection Board

Where applicable, you may approach the Data Protection Board of India through the prescribed mechanism after following the relevant grievance process.

17.9 Reasonable Verification

We may request reasonable information to verify your identity or authority before processing a privacy request.

We shall not request unnecessary personal information solely for verification.

18. HOW TO EXERCISE YOUR PRIVACY RIGHTS

To submit a request concerning your personal information, contact:

Email: compliance@dutybell.com

Subject: Privacy Request – Dutybell

Please include:

• Your full name.
• Registered email address, where applicable.
• Contact information.
• Description of the request.
• Relevant account or service reference, where necessary.
• Any additional information reasonably required to verify your identity.

Examples of requests include:

• Request to access personal information.
• Request to correct account details.
• Request to update a resume.
• Request to delete an account.
• Request to withdraw consent.
• Request to stop promotional communication.
• Request concerning unauthorised disclosure.
• Request concerning personal data security.

We shall review and respond to requests within the timelines prescribed by applicable law.

Where a request cannot be fully granted due to legal retention requirements or other lawful restrictions, we shall communicate the applicable reason to the extent legally required.

19. CONSENT WITHDRAWAL AND ITS EFFECTS

Where personal data processing is based on consent, individuals may withdraw consent through the available mechanism or by contacting Dutybell.

Upon receiving a valid withdrawal request:

19.1 We shall stop the relevant consent-based processing, subject to applicable law.

19.2 We may discontinue services that cannot reasonably be delivered without the relevant personal information.

19.3 We may retain information where required by law or necessary for another lawful purpose.

19.4 Withdrawal of consent shall not invalidate processing carried out lawfully before the withdrawal.

19.5 Where personal information has been shared with a Data Processor acting on our behalf, we shall take appropriate steps concerning the relevant processing in accordance with applicable law.

19.6 Where information has already been shared with an independent employer or another Data Fiduciary, that organisation may have separate obligations concerning its processing and retention.

20. MARKETING AND COMMUNICATION PREFERENCES

Dutybell may communicate with users regarding services, job opportunities, assessments, training programmes and promotional activities.

Communications may include:

• Email.
• SMS.
• Telephone calls.
• Website notifications.
• Account dashboard notifications.
• Other authorised electronic communication channels.

20.1 Essential service communications may include registration confirmation, payment confirmation, interview updates, assessment notifications, account security alerts and service-delivery information.

20.2 Promotional communications shall be sent subject to applicable consent and communication requirements.

20.3 Users may unsubscribe from marketing emails through the unsubscribe facility, where provided.

20.4 Users may also contact compliance@dutybell.com to request cessation of promotional communication.

20.5 Opting out of promotional messages shall not automatically stop essential service, security, transaction or legal communications.

21. THIRD-PARTY WEBSITES AND SERVICES

Our website may contain links to external websites, platforms or services.

These may include:

• Razorpay.
• Employer websites.
• Recruitment platforms.
• Educational institutions.
• Training partners.
• Social media platforms.
• Other business and technology services.

When you access a third-party website or service, its own privacy policy and terms may apply.

Dutybell does not control the independent privacy practices of external websites.

Users are encouraged to review the applicable privacy policies before sharing personal information with third parties.

22. CHILDREN’S PRIVACY

Dutybell’s recruitment marketplace and career services are primarily intended for adults and individuals eligible to participate in the relevant services.

Under the Digital Personal Data Protection Act, 2023, a child is generally an individual who has not completed eighteen years of age.

Dutybell does not knowingly seek to collect or process children’s personal data in violation of applicable law.

Where a service is lawfully made available to a person below eighteen years of age, Dutybell shall comply with the applicable requirements relating to parental or lawful guardian consent and any restrictions imposed by law.

Where we become aware that personal information has been collected in violation of applicable requirements, we shall take appropriate corrective steps.

23. EMPLOYEE, STAFFING AND WORKFORCE DATA

In connection with staffing, recruitment, HR outsourcing, payroll, training and workforce management services, Dutybell may process information relating to employees, temporary staff, contractual workers and other workforce members.

Such information may include:

• Employee identification details.
• Contact information.
• Employment history.
• Designation and department.
• Attendance information.
• Payroll-related information.
• Leave and benefits information.
• Statutory employment records.
• Training and performance records.
• Other information required for the agreed HR service.

23.1 Information shall be processed only for the purposes permitted by the relevant staffing or HR service arrangement and applicable law.

23.2 Where Dutybell acts as a Data Processor on behalf of an employer or client, processing shall be governed by the relevant contractual instructions and data-processing arrangements.

23.3 Where Dutybell independently determines the purposes and means of processing, it shall fulfil its applicable responsibilities as a Data Fiduciary.

23.4 Employers and clients must ensure that personal information provided to Dutybell has been collected lawfully and that they possess the necessary authority to share it.

23.5 Access to workforce information shall be restricted to authorised persons who require it for service delivery or legal compliance.

23.6 Employee and workforce information shall not be used for unrelated purposes without an appropriate lawful basis.

24. DATA ACCURACY AND USER RESPONSIBILITIES

Users are responsible for providing accurate, complete and current information when using Dutybell.

You agree to:

• Provide truthful registration details.
• Keep your contact information updated.
• Submit accurate educational and employment information.
• Upload documents that you are authorised to share.
• Avoid sharing another person’s personal information without permission or other lawful authority.
• Notify Dutybell if you identify incorrect information associated with your account.
• Maintain the confidentiality of your login credentials.

Dutybell may request clarification or updated information where necessary for service delivery, security or legal compliance.

25. AUTOMATED TOOLS AND TECHNOLOGY-BASED PROCESSING

Dutybell may use technology-based tools to support website operations, recruitment activities, candidate matching, assessments, reporting and service delivery.

Where such tools are used, their functions may include:

• Search and filtering.
• Candidate profile matching.
• Job recommendation.
• Assessment scoring.
• Performance reporting.
• Website analytics.
• Fraud detection.
• Administrative automation.

Where applicable, Dutybell shall provide appropriate transparency about the processing involved.

Technology-based tools shall not remove any rights or protections available to individuals under applicable law.

Where a human review process is available or legally required, relevant decisions may be reviewed by authorised personnel.

Dutybell will not represent an automated recommendation or assessment result as a guaranteed hiring decision.

26. DATA PROCESSORS AND AUTHORISED PERSONNEL

Dutybell may engage employees, contractors, consultants and third-party processors to provide services and maintain its digital infrastructure.

Such persons may access personal information only to the extent necessary for their assigned responsibilities.

We shall take appropriate steps to ensure that relevant service providers and authorised personnel are subject to confidentiality and security obligations.

Where applicable, data-processing agreements or contractual safeguards may be implemented.

27. CHANGES TO THIS PRIVACY POLICY

Dutybell may revise this Privacy Policy to reflect:

• Changes in applicable laws.
• Changes in data-protection requirements.
• Introduction of new services.
• Changes in website functionality.
• Changes in technology providers.
• Changes in data collection or processing practices.
• Security or operational improvements.

Updated versions shall be published on the Dutybell website with a revised effective date.

Where changes materially affect individuals’ privacy rights or require renewed consent, we shall provide appropriate notice and obtain consent where legally required.

Users are encouraged to review this Policy periodically.

28. GRIEVANCE REDRESSAL AND PRIVACY CONTACT

Dutybell is committed to addressing privacy-related concerns and complaints through an appropriate grievance mechanism.

Individuals may contact us regarding:

• Unauthorised collection of personal data.
• Incorrect personal information.
• Unauthorised disclosure.
• Account access concerns.
• Requests for correction or erasure.
• Consent withdrawal.
• Marketing communication preferences.
• Personal data breaches.
• Other privacy-related concerns.

Grievance Officer / Privacy Contact

Name- Sudam Charan Mishra

Email- grievance@dutybell.com

Complaints shall be acknowledged and addressed within the timelines prescribed by applicable Indian law.

Where a Data Protection Officer is required under applicable law, the relevant officer’s contact details shall be published separately or included here as appropriate.

29. GOVERNING LAW

This Privacy Policy shall be governed by the laws of India.

Matters relating to personal data protection, privacy rights, information security and data processing shall be subject to applicable Indian legislation, including the Digital Personal Data Protection Act, 2023 and its Rules, as and when the relevant provisions come into force.

Nothing in this Privacy Policy shall restrict any mandatory statutory rights or remedies available to individuals.

30. CONTACT US

For questions, concerns or requests relating to this Privacy Policy, please contact:

Dutybell

Website: https://dutybell.com

Operating Entity: Veronica Educare Private Limited

Compliance Officer

Name- Rakesh Kumar Purohit

Email- compliance@dutybell.com

YOUR PRIVACY MATTERS TO US

Dutybell is committed to handling personal information responsibly, transparently and securely.

We aim to collect only the information necessary to provide our recruitment, staffing, HR, career-development and digital services, and to process that information in accordance with applicable Indian laws.

Dutybell – Connecting Talent, Employers and Opportunities.