Privacy Policy

Effective Date: 9th May 2026

This Privacy Policy explains how Zarrow Technologies Private Limited (“Zarrow”, “we”, “us” or “our”) handles personal information in connection with its recruitment platform, website, forms, tools, communications, workflows, and related services.

This Privacy Policy applies to all persons who access, use, are referred to, are submitted to, communicate with, or otherwise interact with Zarrow, including Employers, Recruiters, Candidates, Referrers, visitors, authorised representatives, and other users.

The personal information we handle may include recruitment-related, candidate-related, employer-related, recruiter-related, referral-related, payment-related, tax-related, communication-related, platform-usage, and other information covered by this Privacy Policy.

Your use of Zarrow is also governed by our Terms of Use and any applicable role-specific terms, agreements, notices, or policies. Terms used but not defined in this Privacy Policy have the meanings given to them in the Terms of Use.

1. Information we collect

Zarrow may collect personal information directly from you, automatically when you use the Services, from other users, referrers, third parties, vendors, advertising or marketing partners, integrations, public sources, and professional sources where permitted by law. This may include information submitted through forms, surveys, questionnaires, free-text fields, uploads, emails, messages, cookies, logs, analytics tools, pixels, SDKs, device data, IP address, approximate location, and platform usage.

1.1 Account and identity information

This may include your name, email address, phone number, organisation name, role/title, account login details, profile details, details of professional history and information submitted during sign-up, onboarding, verification, or account use.

1.2 Recruiter information

If you are a recruiter, we may collect your work history, recruiting experience, specialisations, agency details, portfolio, past placements, role preferences, payout details, tax details, candidate-related information, candidate submissions, candidate records, role applications, communications, notes, files, documents, performance information, and platform activity.

1.3 Employer information

If you are an employer, we may collect company details, hiring requirements, job posts, hiring briefs, role information, team details, hiring manager details, feedback, interview updates, payment status, and communications.

1.4 Candidate information

If you are a candidate, or if your information is submitted to Zarrow by a recruiter, employer, referrer, or other authorised person, we may collect your name, contact details, resume/CV, LinkedIn or portfolio links, employment history, education, skills, compensation expectations, notice period, location preferences, interview feedback, hiring status, and other information relevant to recruitment.

1.5 Referral information

We may receive information about you from referrers who believe you may be suitable for an employer, role, or opportunity on Zarrow. We may collect information about the referrer, referred person, referral status, reward eligibility, payout details, tax details, and related communications.

1.6 Payment, tax, and compliance information

We may collect bank details, PAN, GST details, invoices, tax declarations, KYC information, payment records, billing details, and other information required for payouts, payments, accounting, tax, compliance, or legal purposes.

1.7 Usage and device information

We may collect information about how you use Zarrow, including IP address, device information, browser type, pages visited, actions taken, timestamps, log data, cookies, analytics data, and platform performance data.

1.8 Communications

We may collect messages, emails, calls, notes, feedback, support requests, interview updates, candidate comments, employer comments, recruiter questions, and other communications sent to, through or related to Zarrow.

2. How we use information

Zarrow uses personal information to operate, provide, secure, improve, and administer its recruitment platform and related services. This may include using information:

(a) to create, operate, maintain, and secure user accounts;

(b) to onboard and manage Users including Employers, Recruiters, Candidates, Referrers, authorised representatives, and other users;

(c) to provide Zarrow’s hiring, recruitment, referral, marketplace, workflow, and platform services;

(d) to match or assess roles, Recruiters, Employers, Candidates, Referrals, and hiring requirements;

(e) to manage Job Posts, User intake, hiring briefs, recruiter applications, Candidate submissions, Candidate locks, duplicate or conflict checks, shortlisting, interviews, feedback, offers, placements, payout workflows, and referral rewards;

(f) to prepare hiring briefs, candidate summaries, role intelligence, fit signals, duplicate/conflict checks, and other workflow assistance;

(g) to communicate with you about accounts, roles, Candidates, referrals, payments, payouts, invoices, support requests, policy updates, platform activity, and other service-related matters;

(h) to use automated tools, AI-assisted systems, machine-learning systems, and internal models to support role intake, hiring brief generation, candidate summaries, candidate matching, fit signals, rankings, recommendations, duplicate/conflict checks, recruiter notes, workflow assistance, quality review, analytics, platform improvement, system training, and related recruitment intelligence.

(i) to process invoices, payments, payouts, deductions, refunds, taxes, accounting records, compliance records, and related financial administration;

(j) to detect, prevent, investigate, or respond to spam, fraud, misuse, duplicate submissions, circumvention, unauthorised access, security incidents, policy breaches, or violations of Zarrow’s Terms, Ground Rules, agreements, or platform rules;

(k) to improve Zarrow’s services, product experience, analytics, reliability, security, workflows, user support, and business operations;

(l) to comply with legal, regulatory, tax, accounting, audit, reporting, dispute-resolution, and compliance obligations;

(m) to market, promote, and communicate about Zarrow’s services, including through relevant advertisements or communications where permitted by applicable law;

(n) to enforce Zarrow’s Terms of Use, Ground Rules, user agreements, referral policies, Job Post terms, and other applicable terms; and

(o) for other legitimate business purposes reasonably connected with Zarrow’s Services, platform operations, user relationships, security, compliance, analytics, product improvement, and business administration, where permitted by applicable law.

(p) for any other purpose disclosed to you, reasonably connected with Zarrow’s Services, or permitted by applicable law.

3. How we share information

1. Zarrow may share personal information where needed to operate Zarrow’s recruitment platform, provide the Services, administer hiring and referral workflows, process payments or payouts, comply with law, protect Zarrow’s rights, or carry out the purposes described in this Privacy Policy. We may share information:

(a) with Employers, where Candidate information is submitted for a role, hiring requirement, interview process, feedback process, or other recruitment workflow;

(b) with Recruiters, where role information, employer requirements, Candidate status, referral status, payout status, or platform workflow requires it;

(c) with Candidates, where communication, hiring updates, role information, consent-related communication, interview coordination, or Candidate-related workflow requires it;

(d) with Referrers or referred persons, where needed to operate referral programs, verify eligibility, calculate rewards, process payments, resolve disputes, or prevent misuse;

(e) with service providers, third parties, vendors, consultants, and operational partners who help Zarrow operate, provide, secure, support, or improve the Services, including cloud hosting providers, analytics providers, communication tools, payment processors, accounting tools, customer support tools, background verification providers, legal advisers, tax advisers, auditors, banks, and compliance providers;

(f) with government authorities, regulators, courts, law enforcement, professional advisers, banks, payment providers, auditors, or other persons where required or permitted by law, legal process, tax requirements, accounting requirements, compliance obligations, dispute resolution, enforcement of terms, or protection of Zarrow’s rights, users, platform, or safety;

(g) with another entity or relevant persons in connection with a merger, acquisition, financing, investment, restructuring, sale of assets, transfer of business, insolvency, change in control, or similar transaction; and

(h) with your consent, at your direction, or as otherwise permitted by applicable law.

2. Aggregated, de-identified, or anonymised information. Zarrow may create, use, retain, store and share aggregated, de-identified, or anonymised information derived from personal information for analytics, reporting, benchmarking, research, product improvement, business planning, marketing, and other lawful business purposes. Zarrow will not attempt to re-identify anonymised information, except where permitted or required by applicable law.

3. Referral and reward information: When you participate in a referral program, Zarrow may share limited referral-related information with the Referrer, Referred Recruiter, Referred Employer, or other relevant parties as necessary to operate the referral program, verify eligibility, calculate rewards, process payments, resolve disputes, and prevent fraud or abuse. This may include referral status, approval status, eligible earnings, amounts credited or paid, reward calculations, payment status, and other information reasonably required to administer the referral program. For example, where a Referrer is eligible for a percentage-based referral reward, Zarrow may share limited information about the Referred Recruiter’s eligible first-placement earnings or the Referred Employer’s eligible payments/earnings, as applicable, to explain or calculate the Referrer’s reward.

4. Business transfers and financing. If Zarrow is involved in a merger, acquisition, financing, investment transaction, fundraising, restructuring, sale of assets, transfer of business, insolvency, bankruptcy, or similar transaction, all personal information collected by Zarrow may be shared with or transferred to the relevant third party, buyer, successor, investor, potential investor, adviser, or other participant in the transaction. Such sharing or transfer may occur as part of due diligence, negotiation, completion, or post-completion integration, subject to applicable law.

5. We do not sell personal information to advertisers. However, we may share limited information with advertising, analytics, or marketing partners to measure campaign performance, improve our Services, or show relevant communications, where permitted by law. We do not share Candidate Personal information, Candidate Referrals, resumes, or sensitive payment, tax, KYC, or financial information with advertising partners for targeted advertising purposes.

4. Candidate information submitted by recruiters or employers

1. Recruiters and employers must only submit information including candidate information where they have the right to do so.

2. If you submit any information including company, candidate or any other user information to Zarrow, you are responsible for ensuring that the candidate is aware that their information may be shared with Zarrow and the relevant user or employer or recruiter for hiring-related purposes.

3. Zarrow may use candidate information for the purposes described in this Privacy Policy, including to evaluate role fit, manage candidate submissions, conduct duplicate or conflict checks, communicate about hiring processes, maintain records, and operate the platform.

5. Legal basis and consent

1. By using Zarrow, submitting information, creating an account, applying for roles, posting jobs, submitting candidates, participating in referrals, or otherwise interacting with Zarrow, you consent to the collection and use of information as described in this Privacy Policy and any related notice provided to you. Where applicable law requires separate or specific consent for any processing activity, Zarrow may seek such consent.

2. Where we collect sensitive personal data or information, including financial information, bank account details, tax information, KYC information, or other information requiring specific consent under applicable law, we will collect and process such information on the basis of your consent and for the purposes described in this Privacy Policy, applicable agreements, payout terms, payment workflows, tax requirements, compliance requirements, or other notices provided to you.

3. You may withdraw consent where applicable. However, withdrawal of consent may affect our ability to provide some or all Services to you.

4. We may also process information where permitted by applicable law, including for legal compliance, employment or recruitment-related purposes, fraud prevention, security, claims, contractual performance, or other lawful purposes.

6. Cookies and analytics

Zarrow may use cookies, pixels, SDKs, analytics tools, and similar technologies to operate the platform, remember preferences, improve performance, understand usage, detect misuse, and improve user experience. You may be able to disable cookies through your browser settings, but some parts of Zarrow may not work properly without them.

7. Data retention

1. We keep personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, maintain records, comply with legal, tax, accounting, audit, and regulatory obligations, resolve disputes, enforce agreements, prevent fraud or misuse, and protect Zarrow’s rights. Zarrow may also retain information in an anonymised or aggregated form where it no longer identifies you personally.

2. Where information is no longer required, we may delete, anonymise, or securely retain it as permitted by law.

3. Some recruitment records may need to be retained for a reasonable period to manage candidate ownership, duplicate submissions, hiring history, payouts, disputes, compliance, business operations, tax purposes, and platform integrity.

8. Security

We use reasonable technical, organisational, and administrative measures to protect personal information from unauthorised access, loss, misuse, alteration, or disclosure. However, no system is completely secure. You are responsible for keeping your account credentials confidential and for promptly informing us of any unauthorised use of your account.

9. Your rights

1. Subject to applicable law, you may request access to, correction, updating, or deletion of your personal information, withdraw consent where processing is based on consent, or raise a privacy-related grievance with Zarrow.

2. Zarrow will consider and respond to such requests in accordance with applicable law. Zarrow shall be required to act on a request only to the extent required by applicable law. Where the law does not require Zarrow to fulfil a request, Zarrow may decide whether to accept, reject, limit, or defer the request at its discretion, including based on business, operational, legal, tax, accounting, dispute-resolution, fraud-prevention, platform-integrity, or recordkeeping reasons.

3. Zarrow may verify your identity before acting on any request. Some requests may not be fulfilled where continued retention or processing is necessary or permitted under applicable law.

10. Children’s information

Zarrow is designed for adult users and professional recruitment-related use. Persons below 18 years of age should not create an account, access, or use Zarrow.

Zarrow does not knowingly seek or collect personal information from persons below 18 years of age. If Zarrow becomes aware that such information has been submitted or collected improperly, Zarrow may delete, restrict, or otherwise handle that information in accordance with applicable law. If you believe that personal information of a person below 18 years of age has been provided to Zarrow improperly, you may contact us at team@zarrow.ai.

11. International transfers

Zarrow may store, process, access, or transfer personal information in India or outside India in connection with the purposes described in this Privacy Policy, including for providing, operating, securing, improving, supporting, marketing, administering, or enforcing the Services, subject to applicable law. Where applicable law requires, Zarrow will take reasonable steps to ensure that any recipient of personal information outside India provides a comparable level of protection to that required under applicable law, and that such transfer is made where necessary for the performance of lawful purposes described in this Privacy Policy, with consent where required, or as otherwise permitted by applicable law.

12. Updates to this Privacy Policy

1. Zarrow may revise this Privacy Policy to reflect changes in its Services, platform features, data practices, legal requirements, business operations, or security and compliance processes.

2. When this Privacy Policy is updated, Zarrow will indicate the updated date and may provide notice through email, in-product notice, website notice, or any other method considered appropriate or required under applicable law.

3. The updated Privacy Policy will apply from the date it is posted or from any later effective date stated in the updated version.

4. If you continue to access, use, or interact with Zarrow after the updated Privacy Policy becomes effective, your information will be handled in accordance with the updated Privacy Policy, subject to applicable law.

5. Where required by applicable law, Zarrow may seek additional notice, consent, or acknowledgement for specific changes.

13. GRIEVANCE OFFICER

In accordance with the Information Technology Act, 2000 and the rules made thereunder, the name and contact details of Zarrow’s Grievance Officer are provided below.

Name: Abhinav Arora
Designation: Director
Email: grievanceofficer@zarrow.ai
Address: C-95, Vivek Vihar, Delhi-110095

Note: The Grievance Officer acts in such capacity on behalf of Zarrow Technologies Private Limited. The designation of a Grievance Officer does not create any personal contractual obligation or guarantee by the individual named above.

Zarrow will acknowledge and resolve grievances in accordance with applicable law.