Sub-Processor / Data Transfer Summary

1. Purpose
2. Company and Group Structure
3. Current Providers and Processing Roles
4. Cross-Border Data Access
5. Regional Hosting and Access Controls
6. Customer Responsibility After Export
7. Security, Logging and Incident Response

1. Purpose

TalentFora.in uses group entities and third-party service providers to operate, host, secure, support, and improve the Platform.

This summary explains the main providers involved in processing or supporting customer and candidate data.

This Summary describes the categories of service providers and sub-processors that may process, host, access, store, transmit, secure, support, or otherwise handle customer and candidate information on behalf of TalentFora.in.

This Summary should be read together with the Privacy Policy, Terms & Conditions, and any applicable customer agreement.

Where personal data is processed, TalentFora.in seeks to ensure that such processing is carried out in accordance with applicable laws, including the Digital Personal Data Protection Act, 2023 ("DPDPA"), contractual obligations, and reasonable security practices.

2. Company and Group Structure

Softfoora Services Private Limited ("Softfoora") owns, operates, and provides the Platform. Softfoora Services Private Limited may provide engineering, development, infrastructure support, customer support, maintenance, debugging, AI support, cybersecurity support, and operational services in connection with the Platform.

For the purposes of applicable Indian law, "TalentFora.in" may act as a Data Fiduciary in relation to personal data processed through the Platform, except where processing is carried out solely on behalf of a customer pursuant to applicable contractual arrangements.

TalentFora.in may engage affiliated entities, contractors, consultants, cloud providers, infrastructure providers, payment processors, communications providers, analytics providers, and other service providers to support Platform operations.

3. Current Providers and Processing Roles

The following categories of providers may be engaged by Softfoora Services Private Limited from time to time. Specific providers may change as business, technical, security, operational, or regulatory requirements evolve.

TalentFora.in undertakes reasonable efforts to ensure that service providers with access to personal data are subject to appropriate contractual, confidentiality, privacy, and security obligations.

4. Cross-Border Data Access

Personal data processed through the Platform may be stored, accessed, transmitted, processed, supported, or backed up in India and other jurisdictions where TalentFora.in, its affiliates, infrastructure providers, cloud providers, support providers, or authorised service providers operate.

Where personal data is transferred outside India, TalentFora.in seeks to implement reasonable contractual, organisational, and technical safeguards appropriate to the nature of the data and applicable legal requirements.

Such safeguards may include:

• contractual confidentiality obligations;
• data processing agreements;
• encryption measures;
• pseudonymisation or anonymisation measures where appropriate;
• role-based access controls;
• logging and monitoring;
• need-to-know access restrictions;
• vendor due diligence procedures;
• incident response controls; and
• periodic security reviews.

TalentFora.in will comply with restrictions on cross-border transfers that may be imposed by applicable law, including any restrictions notified by the Government of India under the Digital Personal Data Protection Act, 2023.

5. Regional Hosting and Access Controls

Customer and candidate information may be hosted in different regions depending on service configuration, infrastructure architecture, customer requirements, technical considerations, legal obligations, and service availability.

Access to personal data is restricted to authorised personnel, contractors, and service providers who require such access for legitimate business, operational, support, security, compliance, or technical purposes.

Where reasonably practicable, Softfoora seeks to minimise access to personal data and applies access controls, monitoring measures, logging mechanisms, and security safeguards designed to protect such information.

Access to personal data may be limited, restricted, segmented, pseudonymised, anonymised, masked, or otherwise protected where appropriate.

6. Customer Responsibility After Export

Where customers download, export, transfer, disclose, copy, store, or otherwise access personal data outside the Platform, they become solely responsible for the subsequent use, storage, retention, deletion, disclosure, transfer, sharing, security, and legal compliance of such information.

Customers remain responsible for complying with applicable privacy laws, employment laws, confidentiality obligations, contractual obligations, cross-border transfer requirements, and data protection obligations relating to exported data.

TalentFora.in is not responsible for the handling of information after it has been exported or otherwise removed from the Platform by a customer.

7. Security, Logging and Incident Response

TalentFora.in implements reasonable technical, organisational, and administrative safeguards designed to protect information processed through the Platform.

TalentFora.in may maintain audit logs, access logs, system logs, monitoring records, and security records for periods required under applicable law, including applicable cybersecurity and CERT-In requirements.

Where required by law, TalentFora.in may investigate, preserve, disclose, report, or otherwise respond to cybersecurity incidents, security breaches, unlawful activity, legal requests, regulatory inquiries, or directions from competent authorities, including the Indian Computer Emergency Response Team (CERT-In), law enforcement agencies, courts, and government authorities.

Service providers and sub-processors may be required to cooperate with investigations, compliance reviews, incident response activities, and legal obligations applicable to the Platform.