Effective Date: 2 June 2026 | Version 2.0
Previous Versions available here
Wingify Software Pvt. Ltd. and its affiliates (“Wingify,” “we,” “us,” or “our”) are committed to protecting the privacy and security of personal data collected through our recruitment process. This Careers Privacy Notice (“Notice”) explains how we collect, use, share, retain, and protect your personal data when you visit wingify.com/careers or apply for a role with us.
This Notice is issued in compliance with applicable data-protection laws, including but not limited to the EU General Data Protection Regulation (GDPR), the UK GDPR, the California Consumer Privacy Act / California Privacy Rights Act (CCPA/CPRA), and India’s Digital Personal Data Protection Act, 2023 (DPDP Act). Where these laws differ, we apply the standard most protective of your rights.
This Notice applies to all individuals who:
Note for California Residents (CCPA/CPRA): This Notice also serves as Wingify’s required disclosure under California Civil Code § 1798.100 et seq. for personal information collected in the employment and pre-employment context.
Note for Indian Data Principals (DPDP Act): Wingify is a Data Fiduciary under the DPDP Act, 2023. This Notice constitutes the itemised notice required under Section 5 of the Act and is provided before or at the time of collection of your personal data.
Wingify acts as the Data Controller, Data Fiduciary, or equivalent legal role as defined under applicable data protection and privacy laws, including but not limited to the European Union General Data Protection Regulation (GDPR), the UK GDPR, the Digital Personal Data Protection Act, 2023 (India) (“DPDP Act”), and other applicable privacy regulations. As the Data Controller/Data Fiduciary, Wingify determines the purposes and means of processing Personal Data collected from job applicants, candidates, prospective employees, and other individuals participating in our recruitment process.
When you apply for a position or register for a recruiting event, we collect:
| Category of Personal Data | Specific Data Elements | Purpose of Collection |
| Identity & Contact | Full name; email address; phone number; city and country of residence | Candidate identification; scheduling communications |
| Professional Background | CV/résumé; work history; educational qualifications; professional skills and certifications; portfolio links | Assessing suitability for the applied role |
| Compensation Expectations | Current and expected salary or compensation range | Aligning offer with budget; compliance with applicable pay-transparency laws |
| Right-to-Work / Eligibility | Work authorisation status; visa or permit type (if applicable) | Legal compliance with local immigration and employment laws |
| Diversity & Inclusion | Gender; disability status; veteran status (where permitted by local law and collected with explicit consent) | Anonymised analytics to measure and improve D&I outcomes; never used in hiring decisions |
| Communications | Content of emails, messages, or correspondence exchanged with the Recruitment Team | Record-keeping; responding to your enquiries |
Special/Sensitive Categories: Where local law requires, we will seek your explicit consent before collecting any special-category data (e.g., disability, health information). Such data is never used to make or influence a hiring decision.
When you visit our Careers site, we and our service providers may collect technical data via cookies, and similar technologies, including:
We may supplement data you provide with information from:
We process your personal data on one or more of the following legal bases:
| Legal Basis | Applicable Law | When We Rely On It |
| Pre-contractual / contractual necessity | GDPR Art. 6(1)(b); UK GDPR Art. 6(1)(b); DPDP Act § 4 | Processing your application; scheduling and conducting interviews; extending and negotiating an offer |
| Legitimate interests | GDPR Art. 6(1)(f); UK GDPR Art. 6(1)(f) | Improving our recruitment processes; maintaining talent pool records (subject to legitimate-interest assessment); fraud and security prevention |
| Legal obligation | GDPR Art. 6(1)(c); UK GDPR Art. 6(1)(c); DPDP Act § 4; applicable employment law | Compliance with employment, immigration, anti-discrimination, and health & safety laws; responding to lawful regulatory requests |
| Consent | GDPR Art. 6(1)(a) & Art. 9(2)(a); DPDP Act § 6; CCPA (opt-in for sensitive PI) | Non-essential cookies; diversity data; retaining your profile for future roles; any special-category data |
CCPA/CPRA – No Sale or Sharing for Cross-Context Behavioural Advertising: Wingify does not sell your personal information and does not share it for cross-context behavioural advertising purposes as defined under the CCPA/CPRA. The opt-out right under Civil Code § 1798.120 is therefore not applicable; however, we honour all other rights set out in Section 8 below.
We use your personal data for the following purposes:
No Solely Automated Decision-Making: Wingify does not make final hiring decisions based solely on automated processing. Any automated screening tools (e.g., keyword matching, video analysis) are used only to assist, not replace human evaluation.
We may disclose your personal data to the following categories of recipients:
| Recipient Category | Examples | Safeguard |
| Internal Hiring Teams and External Interviewers | Recruiters, hiring managers, external interviewers and panel interviewers | Need-to-know access controls; internal data policies; Non-Disclosure Agreements |
| HR Technology & ATS Providers | Applicant tracking, scheduling, and assessment platforms | Data Processing Agreements; EU SCCs or equivalent transfer mechanism where applicable |
| Background Screening Agencies | Identity verification, criminal record, and reference-check providers | Only at offer stage; data processing agreements; your prior notification |
| Professional & Legal Advisers | Lawyers, auditors, insurers | Confidentiality obligations; shared only as necessary |
| Regulatory & Law Enforcement Authorities | Government bodies, courts, data-protection authorities | Disclosed only when legally required; we notify you where permitted by law |
| Corporate Transaction Parties | Buyers, investors, advisers in M&A or asset-sale scenarios | Confidentiality agreements; equivalent protection maintained |
We never sell your personal data to third parties for any commercial purpose. Processors are contractually prohibited from using your data for any purpose other than performing services on our behalf.
Wingify operates globally and may transfer and process your personal data to countries outside the jurisdiction in which it was collected, including to India, USA and other countries where Wingify or its processors maintain operations.
While transferring any personal data to a third-party, We ensure that transfers are protected by appropriate safeguards:
We retain your personal data only for as long as necessary for the purposes described in this Notice, or to meet applicable legal requirements.
| Scenario | Retention Period |
| Unsuccessful application | Maximum up to 6 years from the date of collection, unless you consent to longer retention for future roles. |
| Successful application (hired) | Data transferred to your employee file and retained as per our Employee Data Retention Policy. |
| Talent pool | Maximum Up to 6 years from the date of your consent, renewable with your further consent. |
At the end of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Anonymised data may be retained for statistical purposes without further restriction.
Wingify implements appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing, accidental loss, destruction, or damage, including:
In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay as required by applicable law.
Depending on your jurisdiction, you may exercise the following rights. We will respond within the timeframe prescribed by applicable law.
| Right | What It Means | GDPR / UK GDPR | CCPA / CPRA | DPDP Act |
| Access / Know | Confirm whether we hold your data; receive a copy of it and details of processing | ✔ Art. 15 | ✔ § 1798.110 | ✔ § 11 |
| Correction | Rectify inaccurate or incomplete data without undue delay | ✔ Art. 16 | ✔ § 1798.106 | ✔ § 12 |
| Deletion / Erasure | Request deletion of your data; subject to legal retention obligations | ✔ Art. 17 | ✔ § 1798.105 | ✔ § 13 |
| Restriction of Processing | Limit processing pending accuracy challenge or objection | ✔ Art. 18 | – (limited analogue) | – (grievance mechanism applies) |
| Data Portability | Receive your data in a structured, machine-readable format; request direct transfer to another controller | ✔ Art. 20 | ✔ § 1798.100(d) | ✔ |
| Object | Object to processing based on legitimate interests or for direct marketing | ✔ Art. 21 | ✔ Opt-out of sale/sharing | ✔ Withdrawal of consent |
| Withdraw Consent | Withdraw consent for consent-based processing at any time without affecting prior lawful processing | ✔ Art. 7(3) | ✔ | ✔ § 6(4) |
| Non-Discrimination (CCPA) | We will not discriminate against you for exercising any CCPA/CPRA right | – | ✔ § 1798.125 | – |
| Grievance / Complaint (DPDP) | Register a grievance with Wingify’s Data Protection Officer; escalate to the Data Protection Board of India | – | – | ✔ § 13 & § 19 |
How to submit a request: Email privacy@wingify.com with the subject line “Data Subject Request – [Right]”. We may request reasonable proof of identity before processing your request. We will not charge a fee for requests, unless they are manifestly unfounded or excessive.
Authorised Agents (CCPA): California residents may designate an authorised agent to submit requests on their behalf. We will verify the agent’s authorisation before responding.
Right to Lodge a Supervisory Complaint: If you are not satisfied with our response, you may lodge a complaint with your local supervisory authority (e.g., your national Data Protection Authority in the EEA/UK; the Data Protection Board of India under the DPDP Act; or the California Privacy Protection Agency under the CPRA).
Deviations: Please note that these rights are not absolute and may be subject to limitations, exceptions, or exemptions under applicable law. In certain circumstances, Wingify may be unable to comply fully or partially with a request where processing or retention of Personal Data is necessary to:
Where deletion of Personal Data is requested, Wingify may retain certain information for a longer period where retention is necessary to comply with legal obligations or in connection with actual or anticipated litigation, legal proceedings, regulatory investigations, audits, dispute resolution processes, grievance handling, enforcement activities, or the establishment, exercise, or defense of legal claims. In such cases, the retained Personal Data will be restricted to the extent reasonably necessary for the relevant purpose and will be securely maintained in accordance with applicable law.
If we are unable to fulfill your request, in whole or in part, we will inform you of the reasons for our decision, subject to any legal or regulatory restrictions.
Our Careers site and recruitment process are not directed to individuals under the age of 18 (or the applicable age of majority in your jurisdiction). We do not knowingly collect personal data from minors. If you believe we have inadvertently collected data from a minor, please contact us immediately at privacy@wingify.com and we will delete it promptly.
We reserve the right to update this Notice at any time to reflect changes in law, our data practices, or our services.
We encourage you to review this Notice periodically. Your continued participation in the recruitment process following the posting of changes constitutes acknowledgement of the updated Notice.
For questions, requests, or concerns about this Notice or our data practices, please contact:
| Contact | Details |
| Data Protection Officer | Keshav Kumar – privacy@wingify.com |
| Recruitment Team | careers@wingify.com |
| Registered Address | Wingify Software Private Limited, 703, 7th Floor, KLJ Towers, NSP, Pitampura, New Delhi – 110034, India |
| EU and UK Representative | Contact info for our EU GDPR representative:Rickert Rechtsanwaltsgesellschaft mbH C/O Wingify Software Pvt. Ltd. Colmantstraße 15, 53115 Bonn, GermanyEmail: art-27-rep-wingify@rickert.law Contact info for our UK GDPR representative:Rickert Services Ltd UK C/O Wingify Software Pvt. Ltd. PO Box 1487, Peterborough, PE1 9XX United KingdomEmail: art-27-rep-wingify@rickert-services.uk |
| Supervisory Authorities | EEA: Your national DPA | UK: ICO (ico.org.uk) | India: Data Protection Board of India | California: California Privacy Protection Agency (cppa.ca.gov) |
Thank you for considering Wingify as your next career destination. We value your privacy and are committed to keeping your personal data safe throughout the recruitment process.