Privacy Policy

"Personal Data" means any data about an individual who is identifiable by or in relation to such data, as defined under the DPDP Act.

"Processing" means any operation performed on Personal Data, including collection, storage, use, sharing, disclosure, and erasure.

"Data Fiduciary" means the Company, which determines the purpose and means of processing your Personal Data.

"Data Principal" means you, the individual to whom the Personal Data relates.

"Consent Manager" means a person registered with the Data Protection Board of India who enables a Data Principal to give, manage, review, or withdraw consent through an accessible, transparent, and interoperable platform, where applicable under the DPDP Act framework.

2.1 Personal Data you provide directly:

• Phone number (used for OTP-based login and identity verification);
• Name, email address, date of birth (for age verification);
• Work experience, educational background, skills, certifications, preferred job locations and industries;
• Resume content, career goals, and any other information you choose to add to your profile;
• Communications you send us, including support requests and feedback.

2.2 Information collected automatically:

• IP address, device identifiers, device type, operating system, and browser type;
• Pages visited, features used, actions taken on the platform, referral source, timestamps, and session duration;
• Approximate location derived from your IP address or device settings (with your permission, where required).

2.3 Information from third parties and Messaging Platforms:

• If you interact with Dev. through WhatsApp or another connected Messaging Platform, we receive your phone number, message content you send to us, and delivery/read metadata from that platform, subject to that platform's own terms;
• We may receive information about you from job boards, course providers, or other partners where you have separately authorised such sharing (e.g., applying to a job through a partner integration).

2.4 Payment information. Payment card and similar financial instrument details are collected and processed directly by our third-party, RBI-authorised payment processors, in accordance with the Reserve Bank of India's data storage and localisation requirements. We do not store your full payment card details on our own servers.

3.1 In accordance with the DPDP Act, we provide notice, at or before the time we seek your consent, of the Personal Data being collected and the purpose for which it will be processed, in clear and plain language.

3.2 We process your Personal Data primarily on the basis of your consent, which you may give, manage, or withdraw at any time (see Section 8). Where you withdraw consent, all processing of your Personal Data based on that consent will cease as soon as reasonably practicable, without affecting the lawfulness of processing carried out before withdrawal.

3.3 In limited circumstances, we may process Personal Data without consent where permitted under "certain legitimate uses" recognised by the DPDP Act, including: (a) where you have voluntarily provided the data for a specified purpose and have not indicated you do not consent to its use; (b) compliance with any judgment, order, or legal obligation under Indian law; (c) responding to a medical emergency involving a threat to your life or immediate health; or (d) for purposes related to employment, where applicable.

We use your information to:

• Provide, personalise, operate, and improve the Dev. platform and its features;
• Match you with relevant jobs, courses, mentors, and career guidance, including through automated and AI-assisted recommendation systems;
• Build, refine, and score resumes tailored to your target roles;
• Send job alerts, account notifications, OTPs, and service updates via email, SMS, WhatsApp, or other connected Messaging Platforms;
• Analyse usage trends, conduct research, and improve our product;
• Detect, investigate, and prevent fraud, abuse, security incidents, and violations of our Terms of Use;
• Comply with applicable legal, regulatory, and law enforcement obligations.

4.1 Automated decision-making. Certain features (such as job matching, resume scoring, and content ranking) rely on automated or AI-assisted processing. We do not use fully automated decision-making to produce legal or similarly significant effects concerning you (such as denying you access to the Service) without an avenue for human review. You may contact us to request review of an automated outcome that materially affects you.

We do not sell your Personal Data. We may share information with:

5.1 Service providers. Third-party vendors who help us operate, host, analyse, and improve Dev., including cloud hosting providers, SMS/OTP gateways, customer support tools, and analytics providers such as Mixpanel and Vercel Analytics. These vendors are bound by data processing agreements and may only process your data on our instructions and for the purposes we specify.

5.2 Messaging Platforms. If you connect Dev. to WhatsApp or another Messaging Platform, relevant information (such as your phone number and message metadata) is shared with and processed by that platform's operator (e.g., WhatsApp/Meta) in accordance with that operator's own privacy policy, which you are responsible for reviewing separately. See also our Terms of Use, Section 8.

5.3 Employers, recruiters, and course providers. Where you choose to apply for a job or enrol in a course through the Service, we share the information necessary to process that application or enrolment (e.g., your resume and contact details) with the relevant employer, recruiter, or course provider, who will separately act as a data controller/fiduciary for that information under their own privacy practices.

5.4 Legal authorities. Where required by law, court order, government request, or to protect the rights, property, or safety of the Company, our Users, or the public.

5.5 Business transfers. In connection with a merger, acquisition, financing, or sale of assets, in which case we will provide notice before your Personal Data becomes subject to a different privacy policy.

5.6 Aggregated or de-identified data. We may share data that has been aggregated or de-identified such that it can no longer reasonably be used to identify you, including for research, benchmarking, or product improvement.

6.1 Your Personal Data may be stored, processed, and transferred to countries outside India, including where our cloud infrastructure or service providers are located, in accordance with the DPDP Act.

6.2 We will not transfer Personal Data to any country or territory that the Central Government of India has restricted by notification under the DPDP Act.

6.3 Where you are located outside India (e.g., in the European Union, United Kingdom, or elsewhere), your Personal Data may be transferred to and processed in India and other countries whose data protection laws may differ from those of your home jurisdiction. Where applicable, we implement appropriate safeguards (such as contractual protections with our processors) for such transfers.

7.1 We use cookies, local storage, and similar technologies to authenticate your session, remember your preferences, secure the platform, and understand how you use Dev.

7.2 We use analytics tools (e.g., Mixpanel, Vercel Analytics) that collect pseudonymous data about interactions on the platform, such as pages viewed, features used, and general usage patterns.

7.3 Where required by law, we will present a consent banner allowing you to accept or decline non-essential cookies before they are set. You can also control cookies through your browser settings, though some features of the Service may not function properly without them.

7.4 We do not currently respond to "Do Not Track" browser signals, as no uniform industry standard exists for interpreting them.

Subject to verification of your identity and applicable exceptions under law, you have the right to:

8.1 Right to access. Obtain a summary of the Personal Data we hold about you and the processing activities undertaken with respect to that data.

8.2 Right to correction and completion. Request correction of inaccurate or misleading Personal Data, and completion of incomplete Personal Data.

8.3 Right to erasure. Request deletion of your Personal Data, which we will honour unless retention is necessary for the specified purpose, to comply with law, or for the establishment, exercise, or defence of legal claims.

8.4 Right to withdraw consent. Withdraw your consent to processing at any time, with effect for future processing (see Section 3.2).

8.5 Right to nominate. Nominate another individual to exercise your rights under the DPDP Act in the event of your death or incapacity, by writing to us at the contact details in Section 13.

8.6 Right to grievance redressal. Raise a grievance regarding our handling of your Personal Data with our Grievance Officer (Section 13); if unresolved, you may escalate the complaint to the Data Protection Board of India.

8.7 Right to opt out. Opt out of non-essential communications (marketing, promotional job alerts, etc.) at any time, without affecting your ability to receive essential service messages (e.g., OTPs, security alerts).

To exercise any of these rights, contact us at support@develup.in or write to our Grievance Officer. We will respond within the timelines prescribed under the DPDP Act and its rules.

9.1 We retain your Personal Data for as long as your account is active, or as reasonably necessary to provide the Service, comply with our legal obligations, resolve disputes, and enforce our agreements.

9.2 If you request account deletion, we will erase your Personal Data within 30 days, except where retention is required by applicable law (e.g., tax, accounting, or regulatory record-keeping requirements) or is necessary for the establishment, exercise, or defence of legal claims.

9.3 Where the purpose for which Personal Data was collected is no longer being served and retention is not otherwise required by law, we will erase such data or anonymise it, in line with the purpose-limitation principle under the DPDP Act.

10.1 We implement reasonable security practices and procedures, including encryption of data in transit, access controls, and monitoring, that are commensurate with the sensitivity of the Personal Data we process, consistent with our obligations under the DPDP Act and, to the extent applicable, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

10.2 No method of transmission over the internet or electronic storage is completely secure. While we work to protect your Personal Data, we cannot guarantee its absolute security.

10.3 Breach notification. In the event of a personal data breach that is likely to affect your rights, we will notify the Data Protection Board of India and affected Data Principals without undue delay, in the manner and within the timelines prescribed under the DPDP Act and its rules.

10.4 You play a role in keeping your account secure: do not share your OTP, password, or account credentials with anyone, and notify us immediately if you suspect unauthorised access to your account.

The Service may contain links to, or integrate with, third-party websites, job boards, course providers, and Messaging Platforms (including WhatsApp) that are not owned or controlled by us. This Policy does not apply to such third parties, and we encourage you to review their privacy policies separately. We are not responsible for the privacy practices of any third party.

12.1 By providing your phone number or email and opting in, you consent to receive job alerts, product updates, and promotional messages via email, SMS, or WhatsApp/Messaging Platforms.

12.2 You may opt out of promotional communications at any time by following the unsubscribe/opt-out instructions provided, updating your account preferences, or writing to us. We honour applicable Indian telecom regulations, including registration on the National Customer Preference Register (NCPR/DND) where relevant to voice/SMS communications.

12.3 Essential, transactional, or service-related messages (e.g., OTPs, security alerts, and account notices) are not considered promotional and may continue even if you opt out of marketing messages.

In accordance with the Information Technology Act, 2000, the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, and the DPDP Act, the details of our Grievance Officer are as follows:

Grievance Officer: Tejas Gowda

Email: support@develup.in

Address: 88, 20th Main Road, 2nd Block, Rajajinagar, Bengaluru, Karnataka, India — 560010

The Grievance Officer will acknowledge complaints within twenty-four (24) hours of receipt and endeavour to resolve them within fifteen (15) days, in accordance with the timelines prescribed under applicable law. If you are not satisfied with our resolution, you may escalate your complaint to the Data Protection Board of India.

Dev. is not intended for, and may not be used by, anyone under 18 years of age, consistent with our Terms of Use. We do not knowingly collect Personal Data from anyone under 18. If we become aware that we have collected Personal Data from someone under 18, we will take steps to promptly delete such data and terminate the associated account.

15.1 Dev. is operated from India, and your Personal Data will generally be processed in accordance with Indian law, including the DPDP Act.

15.2 European Economic Area, UK, and Switzerland. If you are located in these regions, our processing of your Personal Data may also be subject to the General Data Protection Regulation (GDPR) or the UK GDPR. Our legal bases for processing include your consent, the performance of a contract with you, and our legitimate interests in operating and improving the Service. You have rights to access, rectify, erase, restrict, or port your data, and to object to certain processing, in addition to the rights described in Section 8.

15.3 Where mandatory local data protection law grants you additional or different rights than those described in this Policy, those local rights will apply to the extent required by law.

15.4 United States. If you are a resident of California or another US state with a comprehensive privacy law (e.g., Virginia, Colorado, Connecticut, Utah), you have rights broadly similar to those in Section 8, including the right to know/access the Personal Data we hold about you, the right to delete it, the right to correct inaccurate Personal Data, the right to opt out of the "sale" or "sharing" of Personal Data (we do not sell or share your Personal Data for cross-context behavioural advertising), the right to limit use of sensitive Personal Data, and the right not to receive discriminatory treatment for exercising these rights. You may exercise these rights, or designate an authorised agent to do so on your behalf, by contacting us at the details in Section 13. We will verify your request using information reasonably available to us before acting on it.

15.5 Messaging consent (TCPA). Where we send you SMS, WhatsApp, or other automated text messages or calls, we do so only with your prior express consent, obtained at sign-up or opt-in. Consent to receive such messages is not a condition of using the Service. Message and data rates may apply, and message frequency varies. You may withdraw consent and opt out at any time by replying "STOP" to a text message, using the opt-out option in a WhatsApp/Messaging Platform conversation, or writing to us at the details in Section 13.

We may update this Privacy Policy from time to time. The "Last updated" date at the top of this page reflects the most recent version. Where changes are material, we will provide notice through the Service, email, or a connected Messaging Platform. Continued use of Dev. after changes take effect constitutes your acceptance of the revised Policy.

For questions about this Privacy Policy or to exercise your rights, email us at support@develup.in, or write to our Grievance Officer as set out in Section 13.