Privacy Policy

1. Who we are

RareFourth Hire ("RareFourth," "we," "us") is a hiring-evaluation company operated by [Company Legal Name], a company incorporated in India under the Companies Act, 2013 (CIN: [___]). We are contracted by employers ("Clients") to conduct and assess job interviews on their behalf.

This Policy explains how we handle personal data when you interact with us — whether you are a candidate taking an interview or a Client using our services. In most candidate interviews we act as a Data Processor on behalf of the Client, who is the Data Fiduciary deciding to hire. Where we determine the purpose and means ourselves, we act as the Data Fiduciary. Your rights are described in Section 8.

2. Information we collect

From candidates:

• Identity & contact data — name, email, phone number, and an identity-verification photo taken at the start of the interview.
• Interview responses — typed answers, submitted code, spoken answers (audio), and their transcripts.
• Proctoring data — periodic still images from your device webcam and, where enabled, a secondary (mobile) camera; automated observations about whether additional people, devices, or screens are visible.
• Integrity / behavioral signals — events such as tab switches, exiting full-screen, window resizing, paste actions, and developer-tools usage, along with response timing.
• Technical data — browser type, device and screen information, IP address, and connection quality.

From Clients:

• Account details (name, work email, company), the role and evaluation criteria you brief us on, and billing information.

3. How we use information

• To conduct, adapt, and proctor the interview.
• To evaluate answers against a structured rubric and generate a private scorecard, red flags, and a hire/no-hire recommendation for the Client.
• To detect and evidence cheating, impersonation, or outside assistance.
• To deliver results to the Client and provide support.
• To secure, maintain, and improve our service (in aggregated or de-identified form wherever practical).
• To comply with applicable Indian law.

We do not sell your personal data, and we do not use candidate interview content to train third-party AI models.

4. Automated evaluation

Your interview is conducted and initially scored by an automated system. The output is a recommendation provided to the Client; the hiring decision is made by the Client, who can review the underlying evidence. See our separate AI Terms for how the system works, its limits, and how to request human review.

5. Consent and lawful processing

We process your personal data based on the consent you give through the notice presented before your interview, as required under the Digital Personal Data Protection Act, 2023 (DPDP Act). Camera-based proctoring involves sensitive personal data under the IT (SPDI) Rules, 2011, and is carried out only with your explicit consent. You may withdraw consent at any time (Section 8), though this may mean the interview cannot be completed. We also process data where necessary to comply with Indian law.

6. Sharing and sub-processors

We share information with:

• The Client who commissioned your interview (results, evidence, recording artifacts).
• Service providers that host and power our platform, under contract and confidentiality — including cloud hosting, database/storage providers, and AI model providers used for evaluation and vision analysis. A current list of sub-processors is available at [link] or on request.
• Authorities or advisors where required by law or to protect our rights.

Some providers may store or process data outside India. We transfer personal data abroad only as permitted under the DPDP Act, 2023 (i.e., other than to any territory restricted by the Government of India) and under confidentiality obligations.

7. Retention

We retain interview data for as long as needed to deliver and support the evaluation, then according to our agreement with the relevant Client and applicable law. Proctoring images and recordings are kept only as long as necessary to substantiate the evaluation, and are then deleted or de-identified. Specific periods are available on request.

8. Your rights

Under the DPDP Act, 2023, as a Data Principal you may: access a summary of your personal data and how it is processed; request correction, completion, updating, or erasure; nominate another person to exercise your rights in case of death or incapacity; and use our grievance-redressal mechanism. You may also complain to the Data Protection Board of India. Because we often process candidate data on a Client's behalf, we may route your request to that Client. To exercise any right, contact our Grievance Officer (Section 12).

9. Security

We follow reasonable security practices and procedures as required under Section 43A of the IT Act, 2000 and the SPDI Rules, 2011, including encryption in transit, access controls, and least-privilege practices. No system is perfectly secure, but we work to protect information against unauthorized access, loss, or misuse.

10. Children

Our service is not directed to individuals under 18. We do not knowingly evaluate minors.

11. Changes

We may update this Policy; material changes will be posted here with a new effective date.

12. Contact

[Company Legal Name] · [privacy@rarefourth.com]
Grievance Officer: [Name] · [email] · [phone]. We will acknowledge and address grievances within the timelines prescribed under applicable Indian law.