Privacy Policy

1. Preamble and Scope of Application

• This Privacy Policy ("Policy") constitutes a legally binding instrument governing the collection, processing, storage, transfer, disclosure, and erasure of Personal Data and Non-Personal Data by Opshire, a service operated by Cogniva Core ("Platform," "we," "us," or "our"), in connection with your access to and use of the services accessible at opshire.ai and any associated digital properties (collectively, the "Service"). This Policy is issued in compliance with applicable data protection legislation, including but not limited to the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the Information Technology Act, 2000, and such other applicable statutes, regulations, rules, and judicial or quasi-judicial orders as may be in force from time to time.
• By accessing, registering on, or otherwise utilising the Service in any manner whatsoever, you, the Data Principal, unconditionally and irrevocably consent to the collection, processing, storage, and use of your Personal Data as described herein. A separate, explicit consent notice is presented to you at the point of account registration, as required under applicable law. If you do not agree to the terms of this Policy in their entirety, you must immediately discontinue all access to and use of the Service.
• This Policy applies exclusively to data collected through the Service and does not extend to data obtained through offline channels, third-party platforms, or any medium other than the Service.

2. Definitions

For the purposes of this Policy, the following terms shall bear the meanings ascribed to them hereunder:

• "Personal Data" means any data about an individual who is identifiable by or in relation to such data, as defined under the DPDP Act, 2023.
• "Data Principal" refers to the natural person to whom Personal Data relates, being the user of the Service.
• "Data Fiduciary" refers to Cogniva Core, operating the Service under the trade name Opshire, which alone or in conjunction with others determines the purpose and means of processing Personal Data.
• "Processing" means any operation or set of operations performed on Personal Data, including collection, recording, organisation, structuring, storage, adaptation, retrieval, use, disclosure, transmission, or erasure.
• "Consent" means a free, specific, informed, unconditional, and unambiguous indication of the Data Principal's agreement to the processing of their Personal Data, as required under the DPDP Act, 2023.
• "AI-Assisted Output" means any document, recommendation, or content generated through the Service's artificial intelligence capabilities based on inputs provided by the Data Principal.
• "Derivative Data" means aggregated, anonymised, de-identified, or computationally transformed data derived from Personal Data, from which no natural person is or can reasonably be identified.

3. Categories of Data Collected

We collect and process the following categories of data, to the extent necessary for the lawful purposes described in this Policy:

4. Purposes and Legal Bases for Processing

• We process Personal Data strictly on the basis of lawful grounds as recognised under applicable law, including the consent of the Data Principal, performance of a contractual obligation, and compliance with legal requirements, and solely for the following purposes:
• Provisioning, operating, and maintaining the Service in accordance with your subscription entitlements
• Executing algorithmic matching of your profile against available occupational listings in our database
• Generating AI-Assisted Output on your behalf based on data you have furnished to the Service
• Hosting, storing, and computationally processing Personal Data on our infrastructure as an intrinsic component of Service delivery
• Processing subscription fees, issuing tax-compliant invoices, and administering billing records
• Transmitting transactional communications including account verification, subscription confirmations, and payment receipts
• Dispatching service-related updates and, where you have not opted out, promotional communications regarding the Service
• Detecting, investigating, and mitigating fraudulent activity, security incidents, and violations of applicable terms
• Fulfilling obligations imposed by applicable statutes, regulatory directives, judicial orders, or law enforcement requirements

5. AI-Assisted Content — Data Use and Limitations

• The Service employs artificial intelligence and machine learning technologies to generate AI-Assisted Output, including curricula vitae, covering letters, and occupational recommendations, based exclusively on data voluntarily furnished by you. The Data Principal bears sole and exclusive responsibility for reviewing, verifying, and approving all AI-Assisted Output prior to submission to any prospective employer or third party; as with all AI-powered systems, outputs are generated on a probabilistic basis and may not in all instances reflect the full accuracy, completeness, or specific requirements of a given application, and Cogniva Core makes no representation or warranty in this regard.
• We shall not utilise your personally identifiable Personal Data or profile content for the purpose of training artificial intelligence models without obtaining your prior explicit and informed consent.
• We reserve the right to utilise Derivative Data — being anonymised, de-identified, and aggregated statistical data derived from platform usage — to improve the Service's algorithmic capabilities, model performance, and product features, in perpetuity, provided such data cannot reasonably be used to identify any individual.

6. Data Sharing and Third-Party Engagement

• We do not sell, rent, lease, barter, or otherwise commercially exploit your Personal Data to any third party for independent commercial purposes. We do not permit external advertising networks, data brokers, or marketing platforms to access, track, or profile users of the Service.
• We engage vetted third-party service providers acting as Data Processors solely to the extent necessary for the technical operation and delivery of the Service, including cloud infrastructure providers, database hosting services, payment processors, and job data aggregation services. Such engagement is governed by binding contractual obligations requiring appropriate technical and organisational safeguards and prohibiting any use of your Personal Data beyond the scope of service provision. The identity of such processors constitutes confidential commercial information and is not disclosed publicly.
• We may disclose Personal Data where required by law, including in response to a valid order issued by a competent court, governmental authority, or regulatory body, or where disclosure is necessary to protect the rights, property, or safety of Cogniva Core, its users, or the public.

7. Cookies and Tracking Technologies

The Service deploys cookies, session tokens, and analogous client-side tracking technologies to maintain authenticated sessions, preserve user preferences, and gather aggregated analytical data regarding Service usage. Where required by applicable law, we obtain your prior consent before placing non-essential cookies on your device. You may configure your browser to decline cookies; however, such configuration may impair certain functionalities of the Service.

8. Automated Logging and Operational Records

The Service automatically generates server-side log records upon each instance of access, including IP addresses, browser identification strings, pages accessed, and timestamps. These records are retained for security monitoring, anomaly detection, performance optimisation, and regulatory compliance, and are not associated with identified individuals except where required for security investigation purposes.

9. Data Storage, Hosting, and Derivative Processing Rights

• Cogniva Core shall host, store, retain, and computationally process all Personal Data furnished by the Data Principal on secured cloud database infrastructure engaged in accordance with Clause 6 of this Policy. By registering on the Platform and continuing to use the Service, the Data Principal grants to Cogniva Core an irrevocable, royalty-free, non-exclusive licence to:
• Host, store, index, structure, and retain Personal Data on the Data Fiduciary's designated cloud database infrastructure for the duration of the account and for any applicable statutory or contractual retention period thereafter;
• Computationally process Personal Data as necessary to render the Service, including without limitation the generation of embeddings, vector representations, metadata artefacts, algorithmic scoring outputs, and derivative computational products;
• Utilise Derivative Data derived from Personal Data — from which the Data Principal is not identifiable and cannot reasonably be re-identified — for the purposes of algorithmic refinement, quality assurance, model training, platform performance evaluation, and product development, in perpetuity;
• Maintain encrypted backup and disaster-recovery copies of Personal Data for operational resilience and business continuity, which copies may persist for a period not exceeding ninety (90) days beyond the primary deletion window stipulated in Clause 11;
• Retain non-personally-identifiable Derivative Data — including aggregated usage statistics, anonymised behavioural patterns, computational artefacts, and algorithmic training corpora — beyond the account retention period, provided such data cannot be reasonably linked to any identifiable Data Principal.
• The Data Principal expressly acknowledges that data storage, hosting, and computational processing constitute intrinsic, non-severable components of the Service, without which the Platform cannot lawfully or technically function. Any withdrawal of consent to such storage and processing shall necessarily result in the cessation of the Data Principal's access to the Service.
• Technical determinations regarding storage architecture, database configuration, encryption schema, and computational processing methodology remain within the exclusive discretion of Cogniva Core, and the Data Principal shall have no claim over or entitlement to influence such technical operations, save for the exercise of statutory rights under Clause 14 hereof.

10. International Data Transfers

Your Personal Data may be transferred to, stored in, or processed in jurisdictions outside the Republic of India. Where such transfers occur, we implement appropriate contractual and technical safeguards as required under applicable law, including Section 16 of the Digital Personal Data Protection Act, 2023, and any notifications issued by the Central Government thereunder. By using the Service, you acknowledge and expressly consent to such cross-border transfers subject to the protections described herein.

11. Data Retention and Erasure

We retain your Personal Data for the duration of your account's active status and for such period thereafter as is necessary to fulfil the purposes set out in this Policy or to comply with applicable legal obligations, including obligations arising under the Income Tax Act, 1961, and the Central Goods and Services Tax Act, 2017. Upon account deletion, we shall initiate deletion of your Personal Data from active systems within thirty (30) calendar days of the date of account closure. Encrypted backup and disaster-recovery copies may persist for an additional period not exceeding ninety (90) days as contemplated under Clause 9 hereof. Financial and transactional records shall be retained for the period mandated under applicable Indian taxation law. Derivative Data may be retained indefinitely in accordance with the licence granted under Clause 9.

12. Personal Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected Data Principals, we shall notify affected users and, where required, the relevant regulatory authority, in accordance with the timelines and manner prescribed under applicable law, including the DPDP Act, 2023. Such notification shall include, to the extent practicable, the nature of the breach, the categories of data affected, and the measures taken or proposed to address the breach.

13. Security of Personal Data

We implement and maintain commercially reasonable technical, administrative, and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, unlawful destruction, alteration, disclosure, or misuse. Such measures include Transport Layer Security encryption for data in transit, encryption at rest for sensitive Personal Data, role-based access controls, and periodic security reviews. Notwithstanding the foregoing, no security architecture is impenetrable, and we shall not be liable for any breach of security resulting from factors beyond our reasonable control. You acknowledge that the transmission of data over public networks involves inherent risks.

14. Rights of the Data Principal

• Subject to applicable law and such conditions and limitations as may be prescribed thereunder, you are entitled to exercise the following rights in respect of your Personal Data:
• Right of Access: Obtain confirmation as to whether your Personal Data is being processed and receive a summary thereof.
• Right of Correction and Completion: Demand rectification of inaccurate Personal Data and completion of incomplete Personal Data.
• Right of Erasure: Demand deletion of your Personal Data where processing is no longer necessary, subject to overriding legal obligations and to the retention rights of Cogniva Core in respect of Derivative Data and statutory records.
• Right to Grievance Redressal: Have grievances regarding the processing of your Personal Data addressed within the timelines prescribed under applicable law.
• Right of Nomination: Nominate another individual to exercise your data rights in the event of your death or incapacity, in accordance with the DPDP Act, 2023.
• To exercise any of the foregoing rights, submit a written request to support@opshire.ai. We reserve the right to verify your identity prior to processing any such request and to decline requests that are manifestly unfounded, excessive, or repetitive.

15. Rights of Users in Other Jurisdictions

If you access the Service from a jurisdiction outside India, including the European Economic Area or the United Kingdom, you may be entitled to additional rights under applicable data protection law, including restriction of processing, objection to processing, and data portability. Please direct such requests to support@opshire.ai.

16. Eligibility and Minors

The Service is directed exclusively at individuals who have attained the age of eighteen (18) years and possess the legal capacity to enter into binding contracts. We do not knowingly collect Personal Data of minors. If we become aware that Personal Data of a minor has been submitted to the Service without appropriate consent, we shall take immediate steps to delete such data. Please notify us at support@opshire.ai if you believe a minor has registered on the Service.

17. Modifications to This Policy

We reserve the right to amend this Policy at our sole discretion at any time. In the event of material modifications, we shall provide notice no fewer than thirty (30) calendar days prior to the effective date of such modifications. Your continued use of the Service following the effective date shall constitute your unconditional acceptance of the revised Policy. If you do not accept any modification, you must immediately discontinue use of the Service.

18. Grievance Officer and Contact

• In accordance with applicable law, including the Information Technology Act, 2000, the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, the Digital Personal Data Protection Act, 2023, and the Consumer Protection (E-Commerce) Rules, 2020, we have designated a Grievance Officer to receive and address grievances relating to the collection, processing, and handling of Personal Data. For all inquiries, complaints, or requests arising under this Policy, please contact:
• The Grievance Officer, Cogniva Core
• Operating under the trade name Opshire
• Registered Office: 164, 1st Cross Road, 1st Stage, Judicial Colony, AECS Layout 1st Stage, R.M.V. 2nd Stage, Bengaluru, Karnataka 560094, India
• Grievance Email: grievance@opshire.ai
• General Contact: support@opshire.ai
• Platform: opshire.ai
• We shall acknowledge grievances within twenty-four (24) hours of receipt and resolve them within fifteen (15) days from the date of receipt, or within such other timeframe as may be prescribed under applicable law.
• Data Principals dissatisfied with the resolution provided herein may approach the Data Protection Board of India upon its formal constitution, or such other competent authority as may be established under applicable law, including the appropriate Consumer Disputes Redressal Commission under the Consumer Protection Act, 2019.
• This Policy is governed by the laws of the Republic of India. All disputes arising under this Policy shall be subject to the exclusive jurisdiction of the courts of Bengaluru, Karnataka. Cogniva Core does not independently verify or guarantee the accuracy, authenticity, or continued availability of any occupational listing displayed on the Service.