Privacy Notice

FRACTAL ANALYTICS LIMITED (“Company” “we”, “us”, “our”) is committed to protecting the privacy and Personal Data of individuals in accordance with applicable data protection laws, including the Digital Personal Data Protection Act, 2023.

This Privacy Notice explains how we collect, use, disclose, and safeguard Personal Data of individuals (“Data Principals”) through our AI-powered recruitment and talent management platform, IQIGAI. It also outlines the rights available to Data Principals in relation to their Personal Data.

We Process Personal Data in a lawful, fair, and transparent manner, and only for specific and lawful purposes. By engaging with our services, you acknowledge that your Personal Data will be Processed in accordance with this Privacy Notice.

For the purposes of this Privacy Notice, the following terms shall have the meaning set out below:

All other terms not defined herein shall have the meanings ascribed to them under the Digital Personal Data Protection Act, 2023.

The Company may collect, hold, use, and Process the following categories of Personal Data, including but not limited to:

A. General Personal Data such as Full name, Email address, Mobile number, Gender, Location etc.

B. Professional / Employment Data such as Resume/CV, Work experience, Educational qualifications, Skills and certifications, Professional profiles (e.g., LinkedIn, GitHub, portfolio websites), References (if provided), Disability status or related information.

D. Assessment Data such as Responses submitted during assessments, Performance scores and evaluation outputs, Interaction data generated during assessments.

E. Proctoring Data such as Video recordings (via laptop or mobile camera), Audio recordings during assessments, Device and behavioral signals used to detect suspicious activity.

F. Technical & Usage Data such as IP address, Device information

The Company collects, holds, uses, and otherwise Processes the Personal Data of individuals for the purposes described below:

A. Based on Consent

• i. For candidate account creation on the IQIGAI platform
• ii. To enable review and evaluation of candidate profiles on the IQIGAI platform,
• iii. To conduct skill-based assessments and evaluations,
• iv. To detect suspicious activity, impersonation, or malpractice and to maintain the integrity of the assessment process.

B. Based on Legitimate use

• i. To respond to queries received from you,
• ii. To monitor, detect, and prevent unauthorized access or misuse,
• iii. To comply with applicable laws and regulatory requirements,
• iv. To respond to lawful requests from authorities.

As a part of our business operations, the Company may disclose the Personal Data in the manner detailed below. All disclosures are made subject to appropriate confidentiality and data protection safeguards.

• Internal stakeholders on a need-to-know basis
• Our affiliates for business and operational purposes
• Service providers and vendors (e.g., IT), subject to appropriate safeguards
• Regulatory authorities, government bodies, or law enforcement agencies, where required by law

The Company does not transfer Personal Data outside India. All Personal Data collected and Processed by us is stored and Processed within the territory of India.

In the event that cross-border transfer of Personal Data becomes necessary in the future, such transfer will be carried out in compliance with applicable legal and regulatory requirements, and this Privacy Notice will be updated accordingly.

The Company retains Personal Data of individuals processed through the IQIGAI platform for a period of five (5) years from the date of collection or last interaction, unless a longer retention period is required or permitted under applicable law.

The Company may retain Personal Data for longer periods where necessary to comply with legal, regulatory, or for the establishment, exercise, or defence of legal claims. Upon expiry of the applicable retention period, Personal Data will be securely deleted or anonymised.

The Company has adopted reasonable security safeguards in compliance with applicable laws to secure Personal Data. The Company also ensures that the third parties to whom Personal Data is transferred or disclosed will have at least the same level of security practices as that followed by the Company.

Our services are not intended for individuals below the age of 18 years. We do not knowingly collect or Process Personal Data of children.

In relation to your Personal Data, you have the following rights:

• Right to access: Individuals can request access to their Personal Data held by the Company.
• Right to correction: Individuals have the right to correct any inaccurate or incomplete Personal Data. The individual is responsible for informing the Company if there are any changes or inaccuracies to their Personal Data.
• Right to erasure: Individuals have the right to request the erasure of their Personal Data in certain circumstances. If you believe that we should discontinue the use of your Personal Data, you have the option to request the deletion of your Personal Data. The Company shall delete the Personal Data unless retention is necessary for compliance with any law for the time being in force.
• Right of grievance redressal: Individuals have the right to raise concerns or grievances regarding the Processing of your Personal Data.
• Right to nominate: Individuals have the right to nominate another individual to exercise their rights in case of death or incapacity.
• Right to withdraw consent: Individuals have the right to withdraw their consent for the activities they had consented for. The withdrawal of consent previously granted for the Processing of Personal Data does not affect the lawfulness of the Processing until the withdrawal. However, opting out will result in cessation of the respective activity or services

Exercising Your Rights

Requests to exercise the above rights may be submitted to us at:

Email: dpo@fractal.ai

We may require you to verify your identity before acting on your request, to ensure the security of Personal Data. We will respond to such requests as soon as possible and within the timelines prescribed under applicable law.

Data Principal/ Subject Request Procedure: To submit a Data Principal/Subject Request (DSR), individuals must complete the official DSR Form and send it to the Grievance Officer at dpo@fractal.ai. The form must include all required fields. Incomplete submissions will not be processed until all necessary details are provided.

Grievance Officer:

The name and contact details of the Company’s Grievance Officer are provided below:

Name: Ms. Somya Agarwal

You may write to the Company’s Grievance Officer at: dpo@fractal.ai

The Grievance Officer/Data Protection Officer will acknowledge and address complaints in a fair, timely, and transparent manner.

Escalation Mechanism:

If you are not satisfied with our response, you have the right to escalate your grievance to the appropriate authority, including the Data Protection Board of India, in accordance with applicable law. However, you are encouraged to contact the Company first, as we welcome the opportunity to investigate and resolve any concerns.

We are committed to cooperating with the Data Protection Board in the resolution of any complaints and ensuring that all concerns are addressed in a timely and appropriate manner.

The Company reserves the right to change this Notice, at our sole discretion at any time. Any material changes to this Notice will be notified to you via your submitted contact details. We also encourage you to review this Notice regularly for such changes.

Last Updated Date: 8 May 2026