Privacy Policy

Effective Date: November 1, 2025

Version: 1.0

I. Introduction

This Privacy Policy applies to personal information Welocity.ai (operated by NetConnect Private Limited) ("Welocity", "we", "our", "us") collects and uses about individuals who interact with us, including:

• Visitors to our website (www.welocity.ai) and platform
• Job candidates who use our AI-powered talent delivery services
• Enterprise clients and their representatives
• Individuals who register for our events, demos, or marketing communications.

Legal Basis and Compliance: Welocity processes personal data in accordance with the Digital Personal Data Protection Act, 2023 (India), the EU General Data Protection Regulation (GDPR), the UK GDPR, and applicable U.S. state privacy laws, including the California Consumer Privacy Act (CCPA/CPRA), where relevant.

Data Fiduciary/Controller Role: For candidate data, Welocity acts as a Data Processor on behalf of enterprise clients (the Data Fiduciaries/Controllers). For client contact data and platform usage data, Welocity acts as the Data Fiduciary/Controller. Welocity is committed to the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, and accountability under applicable data protection laws.

A. Overview

We're committed to protecting your privacy and handling your data transparently. This policy describes:

• What information we collect
• How we use and protect it
• Your rights regarding your personal data
• How to contact us with questions

B. About Welocity

Welocity.ai is an AI-native talent delivery platform that revolutionizes hiring through our "Uber of talent" model. Our platform features Octo, an AI assistant that conducts video interviews in 25+ languages, delivering pre-vetted candidates to enterprises in 7-12 days versus the industry standard of 45-60 days.

C. Scope Limitations

This Privacy Policy does not apply to:

• Candidate data processed on behalf of our clients: When you apply for positions through our platform with our enterprise clients, your data is governed by our contractual agreements with those clients. For questions about how a specific employer handles your application data, please contact them directly.
• Our own recruitment: If you apply to work at Welocity directly, this is covered by our separate applicant privacy notice.

In cases where Welocity acts as a Data Processor, we process data strictly as per the client's documented instructions and under a binding Data Processing Agreement (DPA).

II. Information We Collect

A. Information You Provide

For Candidates:

• Identity Information: Name, email, phone number, address
• Professional Information: Resume/CV, work history, education, skills, certifications
• Interview Data: Video recordings, audio recordings, responses to interview questions
• Assessment Results: Technical assessments, personality assessments, language proficiency
• Communication Records: Messages, emails, chat transcripts with our support team.
• Device and Usage Data: IP address, browser type, login timestamps, location (if permitted), and interactions with our platform.
• Special Category Data: Where required or voluntarily provided (e.g., gender, disability, ethnicity), this data will be processed only with explicit consent and for lawful diversity or compliance purposes.

For Enterprise Clients:

• Business Contact Information: Name, title, company, email, phone
• Account Information: Login credentials, preferences, usage data
• Payment Information: For success-based fees (10-16% of annual compensation)

Automatically Collected Data: When you use our platform, we collect technical data such as IP address, browser type, device identifiers, location data (if enabled), and user interaction logs for security, analytics, and improvement.

Consent Metadata: We maintain records of your consent choices, timestamps, IP addresses, and duration preferences to demonstrate compliance with applicable laws.

We do not collect more personal data than is necessary for the purposes identified in this Policy.

III. How We Use Your Information

Welocity processes your information only for specific and lawful purposes. The lawful bases include consent, contractual necessity, legitimate interests, and legal obligation, as applicable.

A. For Candidates

• Talent Matching: Using AI to match your profile with suitable positions
• Interview Processing: Conducting and analyzing video interviews through Octo
• Skills Validation: Assessing technical and soft skills

IV. How We Share Information

A. With Enterprise Clients

We share candidate profiles and assessment results with clients for positions you've applied to or been matched with. Candidate data is shared only with authorized client users under secure login access. Clients are responsible for handling such data in compliance with applicable laws.

B. With Service Providers

Technology Partners: Cloud hosting (AWS/Azure), video processing, AI/ML services

Payment Processors: Stripe, Razorpay for processing success fees.

All service providers are contractually required to implement equivalent data protection, confidentiality, and security measures as mandated under the DPDP and GDPR.

C. International Transfers

Your personal data may be transferred to data centers and service providers located outside your home country, including the European Union, the United States, or Singapore. Such transfers occur under Standard Contractual Clauses (SCCs) or other legally recognized safeguards ensuring an adequate level of protection.

V. Data Security

We implement industry-standard security measures including:

• Encryption in transit and at rest
• Access controls and authentication
• Regular security assessments and audits
• Incident response procedures
• Employee training on data protection

In the event of a confirmed personal data breach likely to result in harm, Welocity will notify the relevant Data Protection Authority and affected individuals in accordance with applicable law. Welocity periodically reviews and updates security policies to maintain compliance.

VI. Data Retention

Candidate Data:

• Active applications: Duration of hiring process plus 12 months
• Talent pool (with consent): Up to 2 years, renewable with consent
• Client Data: Duration of business relationship plus 5 years for legal/tax purposes
• Interview Recordings: 90 days after hiring decision, unless longer retention agreed with client.

We retain data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Upon expiry, data is securely deleted or irreversibly anonymized. Under the DPDP Act, personal data will be deleted upon withdrawal of consent or when its purpose has been fulfilled, unless retention is required for legal or regulatory obligations.

VII. Your Rights

Depending on your location, you may have the right to:

• Access your personal data
• Correct inaccurate information
• Delete your data (subject to legal obligations)
• Port your data to another service
• Object to certain processing
• Withdraw consent where processing is consent-based
• Opt-out of marketing communications

Right to Nominate:Under India's DPDP Act, you may nominate another individual to exercise your rights in the event of death or incapacity.

How to Exercise Your Rights

Email: privacy@welocity.ai

Form: www.welocity.ai/privacy-requests

We will respond within 30 days or as required by applicable law.

VIII. AI and Automated Decision-Making

Transparency About Octo AI Interviews

• How It Works: Octo conducts structured video interviews, analyzing responses for relevant skills and competencies
• Human Oversight: All AI assessments are reviewable by human recruiters
• Your Rights: You can request human review of any automated decisions
• No Discrimination: Our AI is regularly audited for bias and fairness.

We will not make any decisions that produce legal or similarly significant effects on you solely based on automated processing without your explicit consent, as required by Article 22 of the GDPR and equivalent provisions under the DPDP Act.

IX. Children's Privacy

Welocity does not knowingly collect or process personal data from individuals under the age of 18. If we learn that such data has been collected without proper consent, we will promptly delete it. Parents or guardians who believe their child has provided personal data may contact us for prompt deletion.

X. Do Not Sell or Share

Welocity does not sell or share personal data as defined under the California Consumer Privacy Act (CCPA/CPRA). U.S. residents may submit "Do Not Sell or Share" requests by emailing privacy@welocity.ai. We do not sell or share personal data for monetary or cross-context behavioral advertising purposes.

XI. Updates to This Policy

Any material changes to this Policy will be communicated via email or platform notice at least 15 days before the effective date. The most current version of this Policy will always be available on www.welocity.ai. Older versions may be archived for compliance verification.

XII. Contact Us

NetConnect Private Limited

Operating as Welocity.ai

Email: privacy@welocity.ai

Data Protection Officer

Email: dpo@welocity.ai

Questions?

We're committed to transparency. If you have any questions about how we handle your data, please contact our privacy team at privacy@welocity.ai.

Last Updated: November 2, 2025

Version: 1.0