Privacy Policy

Opening Statement & Scope Definition

This Privacy Policy describes how Infojini Inc. (“Infojini,” “Company,” “we,” “us,” or “our”) collects, uses, discloses, stores, and protects personal data during its operations. Infojini operates under a dual business model, providing comprehensive staffing and recruitment services as well as end-to-end information technology and consulting services to clients across multiple industries and jurisdictions. We recognize that the nature of our business requires the responsible handling of sensitive personal, professional, and project-related information, and we are committed to maintaining the highest standards of data protection and confidentiality.

This Privacy Policy applies to all individuals and entities whose personal data is processed by Infojini, including but not limited to job applicants, candidates, current and former employees, independent contractors, consultants, clients, client representatives, website visitors, vendors, service providers, and other business partners. It governs personal data collected through our websites, online platforms, recruitment activities, staffing engagements, IT service delivery, contractual relationships, communications, and other interactions with Infojini.

This Privacy Policy is effective as of 02/01/2026 and supersedes all prior versions. Infojini may update this Privacy Policy from time to time to reflect changes in legal requirements, business practices, or technological developments. The most current version will always be made available through our official websites and communication channels, and continued use of our Sites or services following such updates constitutes acceptance of the revised policy.

By accessing or using Infojini’s websites, platforms, or digital services (collectively, the “Sites”), you acknowledge that you have reviewed and understood this Privacy Policy and our Terms of Service. If you do not agree with our Terms of Service or this Privacy Policy, you must immediately discontinue use of our Sites. Your continued access to or use of the Sites is expressly conditioned upon such agreement.

Given Infojini’s multinational operations, this Privacy Policy applies globally and is intended to align with data protection requirements across the jurisdictions in which we operate. Where local laws impose additional or more stringent obligations, Infojini will comply with such requirements to the extent applicable.

Core Privacy Commitments

Infojini’s approach to privacy is guided by a set of foundational principles that reflect our commitment to ethical data stewardship and the trust placed in us by candidates, employees, clients, and partners. We believe transparency is essential, and we are committed to clearly explaining how and why personal data is collected and used. We limit the collection of personal data to what is relevant, adequate, and necessary for legitimate business purposes and ensure that data is processed only for clearly defined and lawful objectives.

We are dedicated to protecting personal data through appropriate technical, administrative, and organizational safeguards designed to prevent unauthorized access, disclosure, alteration, or loss. Accountability is central to our privacy program, and we take responsibility for ensuring that personal data is handled in accordance with this Privacy Policy and applicable laws throughout its lifecycle.

Infojini is committed to compliance with global data protection and privacy regulations, including the Health Insurance Portability and Accountability Act (HIPAA), the California Consumer Privacy Act and California Privacy Rights Act (CCPA/CPRA), applicable U.S. state privacy laws, and other national and regional data protection frameworks relevant to our operations as a staffing and IT services provider. Where industry-specific or contractual requirements apply, we integrate those obligations into our data protection practices.

Infojini determines the purposes and means of processing personal data in the course of providing its services and is responsible for ensuring that such processing is carried out in accordance with applicable data protection laws. Where Infojini processes personal data on behalf of a client, such processing is governed by contractual arrangements and carried out strictly in accordance with client instructions and applicable law.

We regularly review, assess, and enhance our policies, procedures, and security measures to address evolving legal standards, emerging risks, and best practices in data protection. Our goal is the continued confidence of those who entrust us with their personal and professional information.

Categories of Data Collected

Infojini collects various types of personal information necessary to conduct our staffing and IT services business. The specific data we collect depends on your relationship with us and the context of your interactions:

• Job Candidates and Employees: If you are a job applicant or an employee (including consultants placed through our staffing services), we collect information needed to assess qualifications, facilitate placement, and manage employment. This includes identifying details (full name, email address, telephone number, physical address), professional qualifications (such as your resume/CV, educational background, employment history, job titles, technical skills, certifications, and references), and other application or onboarding information. We may also collect government-issued identification numbers or documents (e.g. Social Security number, passport or work permit details) and eligibility-to-work information as required by law, as well as demographic data like your preferred work location. In some cases, and only if permitted by law, we might gather sensitive personal data such as information about your racial or ethnic origin, health or disability status, or background check results – typically this occurs if you voluntarily provide such data (for example, for equal opportunity monitoring) or if required for a specific position/client requirement. Any sensitive information is handled with extra care and security. If you become an Infojini employee, we will also collect data necessary for HR, payroll, and benefits administration (e.g. date of birth, emergency contacts, bank account details for salary, and performance-related information).
• Clients and Business Contacts: For clients, vendors, or other business partners, we collect business contact information of key personnel. This includes names, work emails, phone numbers, job titles, company affiliation, and other information relevant to our professional relationship. We may also collect communications with you (such as inquiries, proposals, and contract details) and any personal information contained in the project materials you provide to us. For example, if as a client you give us access to data or systems for an IT project, that data may incidentally include personal information (such as your employees’ or customers’ data). In such cases, we treat all such information as confidential and process it solely for the purposes of delivering the contracted services, in accordance with any applicable data processing agreements.
• Website Users and Marketing Leads: When you visit our website or interact with us online, we collect certain information about your device and usage of our site. This includes standard log and analytics data – e.g. your IP address, browser type, operating system, pages viewed, dates/times of access, and referring website – which helps us understand and improve website performance. If you fill out forms on our site (such as a “Contact Us” form, newsletter subscription, event registration, or blog sign-up), we will collect the information you choose to provide, such as your name, email address, phone number, company name, and the content of your inquiry. We also collect information through cookies and similar tracking technologies, as described in the Cookies section of this policy, which may include data about your browsing behavior on our site. Additionally, if you engage with Infojini on third-party platforms (for example, by clicking our ads or interacting via social media), we may receive certain information about you from those sources as permitted by their privacy policies.

Methods of Data Collection

We collect personal data through multiple channels:

• Directly from You: In most cases, we receive your personal data directly from you. For instance, you provide data to us when you apply for a job (through our online application portal or by sending us your resume), when you sign up on our website (e.g. to download a whitepaper or subscribe to updates), when you correspond with us by email or phone, or during interviews and other recruitment or project discussions. We will inform you at the time of collection which information is required (for example, to consider your job application or to enter into a contract) and which is optional. If you choose not to provide certain required information, we may not be able to proceed with the corresponding service or engagement (for example, missing information on a job application may prevent us from evaluating your candidacy).
• Through Automated Means: As you use our website or IT systems, we may automatically collect technical data using cookies, web beacons, and other tracking technologies. This data collection is explained further in our Cookies and Tracking Technologies section below. Such an automated collection helps us understand how users interact with our digital properties and enables us to optimize user experience and security. We do not use automated technologies to make any decisions that would have a legal or significant impact on an individual without human review (no fully automated profiling for e.g. hiring decisions is conducted without appropriate safeguards).
• From Third Parties: We may also obtain personal data about you from third-party sources. For example, in the recruitment context, we might receive leads or candidate information from staffing partners, recruiting agencies, job boards, or professional networking sites. If a client is looking to fill a role, they might share with us a candidate’s details or we might find your professional information on a public platform like LinkedIn and reach out about an opportunity. We also might collect information from references you provide or from background check providers, education verification services, and similar vendors as part of the hiring process. For instance, where applicable and with your authorization if required, we could conduct employment verification or criminal record checks using trusted third-party agencies. Additionally, for our marketing and business development, we might receive contact details from events, webinars, or marketing affiliates with whom you have shared your information. Any personal data we receive from third parties is treated in accordance with this Privacy Policy and any additional restrictions imposed by the source. We ensure that third parties are legally permitted to share your data with us.

No Automated Decision-Making: Infojini does not make decisions that produce legal or similarly significant effects on individuals based solely on automated processing without meaningful human involvement.

No Collection of Children’s Data: Infojini’s services are professional in nature and not directed to children. We do not knowingly collect personal information from anyone under the age of 13 (and in certain jurisdictions, under the age of 16). If you are a parent or guardian and believe that a minor has provided personal data to us without your consent, please contact us using the information in the Contact Us section, and we will take steps to promptly delete such data from our systems.

Purpose of Processing Personal Data

We process personal data solely for legitimate business purposes in connection with our staffing and IT services, as well as to operate our website and comply with legal obligations. The purposes for which Infojini collects and uses personal information include:

• Recruitment and Talent Placement: The core of our staffing service is matching candidates with job opportunities. We use candidate personal data to assess your qualifications and suitability for employment opportunities, to contact you for interviews or discuss potential roles, and to present your candidacy to our clients/prospective employers. This involves evaluating information from your resume/CV, application forms, interview notes, test results (if any), and reference checks. We may also use your data to verify your identity and work eligibility, and to make employment offers or enter into contracts for employment or engagement. If you are hired through Infojini, we will use your personal information for onboarding and HR management (payroll, benefits, performance tracking, etc.). We may retain your profile to consider you for future positions that match your skills, unless you request otherwise, in which case we will respect your preference as required by law.
• Service Delivery and Project Execution: For clients who engage in our IT services or consultancy, we use personal data to deliver those services in accordance with our contractual obligations. This includes using client contact information to communicate about project requirements, milestones, and support; processing any personal data contained in client-provided materials strictly for the purpose of the project (for example, analyzing a dataset that includes personal information as part of a software development or data analytics project); and managing the business relationship (such as billing and contract management). We also use personal data from our own team members and any client personnel involved to coordinate project activities and ensure quality service delivery.
• Communications and Customer Service: We may use your contact information (email, phone number, mailing address) to send service-related communications. This includes responding to inquiries you submit to us (about our services, job openings, etc.), sending administrative information such as changes to terms or policies, informing candidates and clients about status updates, and providing customer support. If you have an account or portal access with us, we use your data to maintain your account and provide you with necessary functionalities and information. Telephone numbers provided to us may be used to call or text you with important notices or updates related to our services, in accordance with applicable laws and with your consent where required (for instance, sending SMS updates about job applications if you have opted in – see “Messaging Policy” on our site for details).
• Marketing and Promotions: We strive to keep our clients and prospective talent informed about our offerings, insights, and events. With your consent or as otherwise permitted by law, we may use your email or other contact details to send you newsletters, industry updates, event invitations, surveys, or promotional materials about our staffing and IT solutions. For example, if you subscribe to our updates or if you are an existing client, we might send you content such as technology whitepapers or announcements of new services that could interest you. You can opt out of marketing communications at any time, as discussed in the “Your Rights and Choices” section below. We do not engage in excessive or intrusive marketing, and we do not sell or rent your personal information to third-party marketers. Any marketing emails we send will include an unsubscribe mechanism.
• Analytics and Product Improvement: We process certain data to understand how our services are used and to improve our offerings. This includes analyzing website usage patterns (via cookies and analytics tools) to enhance user experience and website performance, reviewing feedback from candidates and clients to improve our recruitment process and IT services, and performing internal quality checks or audits. We may combine data from different sources (for example, aggregating website analytics with customer inquiry trends) to get a fuller picture of how to tailor our services to user needs. When possible, we use aggregated or de-identified information for these purposes, which does not identify any individual directly.
• Legal Compliance and Protection: We may process personal data as needed to comply with laws and regulations that apply to us. This includes using and retaining information for compliance with employment laws, tax and accounting rules, immigration requirements (e.g. verifying work visas), and responding to lawful requests by public authorities. We also process personal data to establish, exercise, or defend against legal claims. For instance, we may retain records of recruitment processes or project communications if we reasonably anticipate a need to address a dispute or regulatory inquiry. Additionally, we will use and disclose personal data if necessary to protect the rights, safety, or property of Infojini, our employees, clients, or others. This can include fraud prevention, verifying identity to prevent unauthorized access to systems, and cooperating with law enforcement investigations or court orders. If you visit our offices, please be aware that for security we may have CCTV cameras in public or high-security areas; any footage is used solely for security and safety purposes and is typically overwritten after a short period unless needed to investigate an incident.
• Other Purposes with Consent: If we ever need to process your personal data for a purpose materially different from the ones above, we will only do so with your consent (to the extent required by law). For example, if we ever wish to feature a success story or testimonial that includes your personal information, we would seek your permission. You have the right to withdraw consent at any time for processing that is based on your consent, as described in “Your Rights” below, and we will then cease processing your data for that purpose.

Legal Bases for Processing

We always ensure that we have a valid legal basis to process your personal data. Depending on the context, our processing may be justified by one or more of the following bases recognized under GDPR and other laws:

a. Consent – where you have given us clear consent for a specific purpose (e.g. you opted in to receive marketing emails);
b. Contract – where processing is necessary to perform a contract with you or to take pre-contractual steps at your request (for instance, using candidate data to place you in a job, or processing client data to deliver a project);
c. Legal Obligation – where we need to process data to comply with a legal obligation (such as employment regulations, court orders, or mandatory record-keeping); and
d. Legitimate Interests – where processing is necessary for our legitimate business interests or those of a third party and not overridden by your data protection rights.

Our legitimate interests include running and improving our business (e.g. securing our IT systems, understanding our website traffic, communicating with clients and candidates about relevant opportunities), developing our workforce and client base, and safeguarding our legal rights. When relying on legitimate interests, we carefully consider the potential impact on your rights and expectancies, and we will provide you with the right to object as required by law. For California residents, we process personal information for the above purposes as outlined in this Policy and in doing so aim to meet the requirements of the CCPA/CPRA – please refer to the Your Rights and Choices section for specific California rights.

Disclosure of Personal Data (Data Sharing)

Within Infojini: Personal data will be accessed by authorized personnel within Infojini who need it to perform their job duties. This typically includes our recruitment team, account managers, human resources, IT administrators, and other support staff on a need-to-know basis. All Infojini employees and contractors are bound by confidentiality obligations and trained in data protection to ensure your information is handled properly.

With Clients (Job Placements): One of the primary instances of data sharing is when we submit candidate information to our clients (the companies seeking to hire or engage talent) in the course of our staffing services. If you are a job candidate, we will share your relevant personal information with prospective employers (our clients) for evaluation against their job openings, but only with your knowledge. For example, when you apply to a job through Infojini or express interest in opportunities, you understand that your resume and related details will be presented to clients who have positions that match your profile. We limit the information shared to what is necessary for the hiring decision (generally, your resume, contact details, and any additional info the client requires, such as work samples or background check results if applicable). Our clients are contractually obligated to use such information solely for considering you for employment/engagement and not for other purposes. If a client wishes to retain your data for future roles or another purpose, we will ensure that any such handling is consistent with applicable law (for instance, the client may need to provide you with their own privacy notice if required).

With Service Providers: We use third-party vendors and service providers to support our operations, and we may need to share personal data with them to perform services on our behalf. These third parties include, for example:

• IT and cloud service providers (for hosting databases, email, and our website),
• Applicant Tracking Systems or HR Information Systems (platforms we use to manage candidate and employee data),
• Background check and verification services (to perform education, criminal, or credit checks with your authorization),
• Payroll processors and benefits administrators (to handle compensation and benefits for our employees/consultants),
• Travel or relocation agencies (if we arrange travel or visa for a candidate, with their consent), and;
• Marketing and analytics providers (for website analytics, email marketing campaigns, customer relationship management, etc.).

In all cases, these service providers are contractually bound to protect your data. We require them to use the personal information only for the purposes we specify and in line with this Privacy Policy, and to implement adequate security measures. We remain responsible for the handling of your personal data by any service provider working on our behalf, and we will take appropriate steps to ensure that they uphold the confidentiality and integrity of your information.

With Affiliates and Partners: Infojini is headquartered in the United States (10015 Old Columbia Road, Suite B 215, Columbia, MD 21046, USA) and operates globally, including in India. We may share personal data with our affiliated entities or subsidiaries (for instance, an Infojini branch or partner in another country) if necessary to fulfill the purposes described in this Policy. For example, if a recruiting effort or IT project involves collaboration between our U.S. and India teams, relevant data may be accessed by team members in both locations. All Infojini affiliates are required to follow our privacy and security practices. In some cases, we may also collaborate with strategic partners or subcontractors to deliver a service (e.g. a local agent assisting with recruiting for a client). Such sharing will be limited to what is necessary for the collaboration and under confidentiality agreements.

Legal Requirements and Protection: We may disclose personal information to third parties (such as courts, law enforcement or regulatory authorities, auditors, or outside legal counsel) when we believe in good faith that such disclosure is necessary to:

• Comply with a law, regulation, valid legal process or governmental request;
• Enforce our contracts or policies (including investigating potential violations);
• Detect, prevent, or address fraud, security, or technical issues; or
• Protect the rights, property, or safety of Infojini, our users, clients, employees, or the public.

For instance, if required by a government audit or subpoena, we might need to provide employment records or other relevant data. We will endeavor to notify you of any such disclosure when permitted to do so.

Business Transfers: If Infojini undergoes a business transition such as a merger, acquisition by another company, reorganization, or sale of all or part of its assets, personal data we hold may be transferred to the successor entity as part of the transaction. If such a transfer occurs, the use of your personal data will still be governed by this Privacy Policy (unless and until it is replaced by an updated policy, of which you would be notified). We will ensure that any acquirer or merger partner is contractually obligated to protect personal information in a manner consistent with the commitments we make here.

No Sale of Personal Information: Infojini does not sell personal data to third parties for monetary consideration. Any sharing of personal data with service providers or partners is limited to what is necessary to provide our services and is governed by contractual and legal safeguards. In the context of the CCPA, we also do not “sell” personal information as that term is defined in the law (meaning we do not share personal information with third parties for their own marketing or other purposes outside of providing our services). If this ever were to change, we would update this Policy accordingly and provide California consumers with a right to opt-out.

Anonymized or Aggregated Data: We may share anonymized or aggregated information (which cannot be used to identify any individual) with third parties for research, marketing, analytics, or other purposes. For example, we might publish reports or statistics about industry hiring trends or website usage patterns. Such information will not contain any personal data and is not subject to individual privacy rights.

Data Retention

Retention Period: Infojini retains personal data only for as long as necessary to fulfill the purposes for which it was collected, and thereafter for legitimate and lawful purposes such as complying with record retention obligations, resolving disputes, and enforcing our agreements. There is no single retention period applicable to all data; rather, the duration for which we keep your information depends on the context and nature of the data, as well as legal requirements. We consider several criteria to determine appropriate retention periods, including: the value and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the volume and nature of the data, and the applicable legal or regulatory requirements that mandate certain data be kept for specific periods.

In practical terms, this means:

• Candidate Data: If you apply for a job or submit your resume to us, we will retain your information for the duration of the recruitment process for that position. If you are not selected for a role, we may keep your data on file for a reasonable period to consider you for future opportunities that may arise, and to maintain a record of our interaction. This retention also allows us to answer any follow-up inquiries about our recruitment decisions or to fulfill our obligations under employment laws. If you prefer that we do not keep your data for new opportunities, you may request deletion after the conclusion of a recruitment process – we will honor such requests unless we have a legal obligation or another legitimate reason to retain the data (e.g. certain information may need to be retained for defending against discrimination claims or for audit purposes). In certain jurisdictions, we may seek your consent to retain your application data for future roles, in which case we will abide by the timeframe communicated in that consent.
• Employee and Consultant Data: If you work for Infojini (whether as a direct employee or as a consultant placed at a client), we will retain your personal data for the duration of your employment/engagement and for an appropriate period thereafter. Post-termination, we typically retain HR records for a number of years as required by law or company policy (for example, to provide references, process final payments, or comply with tax, payroll, and pension record obligations). Certain information may be kept longer if required (such as contracts, payment records, and documents related to benefits or legal compliance). We securely archive and restrict access to data from former personnel and delete or anonymize data when no longer needed.
• Client and Vendor Data: For our business contacts (clients, vendors, partners), we retain personal data for as long as the business relationship is active and thereafter as needed for relevant business records. Contractual and transactional information is generally kept for the duration of the contract plus any retention period required or recommended under law (e.g. accounting and financial records are often kept for a minimum number of years). We may also retain correspondence or project materials for a time to ensure we can manage any post-contract issues or re-engage in future.
• Website and Marketing Data: Information collected from website visitors (logs, analytics) is typically aggregated and retained for a shorter period, unless used for security analysis. Cookies have varying lifespans; some cookies (especially functional ones) are session-based and expire when you close your browser, while others (like certain analytics or preference cookies) may persist for a set period unless cleared (see Cookies section for options to manage). If you unsubscribe from marketing communications, we will maintain minimal contact information on a suppression list indefinitely to honor your opt-out choice.

In all cases, when personal data is no longer necessary for the purposes for which it was collected, and we have no further lawful reason to retain it, we will either irreversibly anonymize it (so that it can no longer be associated with an individual) or securely delete/destroy it. If deletion is not immediately feasible (for example, because the data is stored in archives), we will ensure the data remains securely stored and isolated from further active use until deletion is possible.

Legal and Regulatory Requirements: We may need to retain certain information for longer periods if required to do so by law. For example, in some jurisdictions, employee payroll records must be kept for a certain number of years, or laws may require us to maintain information related to placements for statutory periods. Additionally, if any litigation, audit, or investigative proceeding is underway or anticipated, we will preserve relevant data until those issues are fully resolved. Generally, we will only retain your personal information for as long as necessary to fulfill the purposes we collected for and to satisfy legal, accounting, or reporting requirements, or as necessary to resolve disputes. We periodically review the data we hold and erase or anonymize that is no longer needed. If you have any specific questions about our data retention practices for your personal data, you can contact us (see Contact Us section) for more detail.

Data Security Measures

Protecting Your Data: Infojini takes the security of personal data very seriously. We implement robust technical and organizational measures designed to protect your information from unauthorized access, loss, misuse, or disclosure. These measures are continually updated and aligned with industry best practices to ensure ongoing confidentiality, integrity, and availability of personal data.

Our security program includes, but is not limited to:

a. Access controls (personal data is accessible only by authorized personnel on a need-to-know basis, and access to systems is protected by strong authentication methods and role-based controls).
b. Network and system security (firewalls, intrusion detection systems, anti-malware tools, and regular security monitoring are in place to guard against external threats), and;
c. Physical security (our offices and data centers have access restrictions and surveillance to prevent unauthorized entry).

We also maintain policies and training for our staff to ensure they understand their data protection responsibilities and follow best practices (such as secure handling of data and prompt reporting of any suspected incidents).

In particular, the personal data you provide to us is stored on secure computer systems that have limited access and are located in controlled facilities. We utilize reputable cloud service providers and take advantage of their security features and certifications (for example, compliance with standards like ISO 27001, if applicable). We conduct periodic risk assessments and audits of our security measures, and we have an incident response plan in place to handle any security breaches swiftly and effectively.

Payment and Financial Information: Although Infojini’s primary services (staffing and IT consulting) typically do not involve collecting online payments from individuals, any financial information that we do collect (for example, banking details for payroll or expense reimbursement, or credit card information for service fees) is handled with the highest level of care. We comply with relevant security standards for processing financial data and only use third-party payment processors that are PCI-DSS compliant when credit card processing is involved. We do not store payment card details on our own servers when a third-party processor is used.

No Guarantee: Despite all these precautions, it is important to note that no method of transmission over the Internet or electronic storage is completely infallible. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security of data transmitted to our website or that we maintain. However, once we receive your data, we do our best to ensure its safety on our systems. If we become aware of a data breach that affects your personal data, we will notify you and the appropriate authorities as required by law.

Your Responsibility: You also play a role in keeping your data secure. We encourage you to use strong passwords for any accounts related to our services and to maintain the confidentiality of your account credentials. Please be cautious about phishing attempts or suspicious communications asking for personal information. Infojini will never ask you for sensitive information (like passwords) via email. If you suspect any unauthorized activity or encounter an email that appears to come from us but seems fraudulent, please notify us so we can investigate.

Your Rights & Choices

Access and Correction: You have the right to know whether we are processing your personal data, and if so, to access that data and understand how it is being used. Upon request, we will provide you with information about the personal data we hold about you, including the categories of data, sources, purposes of processing, and any third parties with whom it has been shared, as required by law. If any of the personal information we have about you is inaccurate or outdated, you have the right to request a correction or update. We encourage you to keep your information with us up-to-date (for example, if you are a candidate and your contact details or job experience change, let us know so we can update our records). We will promptly rectify any incorrect or incomplete data about you upon verification of the new information.

Erasure (Right to be Forgotten): You have the right to request that we delete your personal data when it is no longer needed for the purposes for which it was collected, or when you withdraw consent (where consent was the basis for processing), or when processing is unlawful, or if required by law to delete. When we receive a valid deletion request, we will erase your personal data from our records, unless an exception applies. Common exceptions include situations where we must retain data to comply with a legal obligation or to establish or defend legal claims. For example, if you are or were an Infojini employee, we may not be able to delete all your records immediately due to labor law requirements; or if you applied for a job, we may retain minimal information demonstrating that our hiring processes were conducted fairly and in compliance with law. If we cannot fulfill a deletion request for a specific reason, we will inform you of that reason (unless restricted by law).

Objection to Processing: You have the right to object to our processing of your personal data in certain circumstances. Direct Marketing: You can always object to or opt out of your data being used for direct marketing purposes – if you do so, we will cease using your data for that purpose promptly. Legitimate Interests: If we are processing your data based on our legitimate interests (or those of a third party), you may object to this processing if you feel it impacts your fundamental rights and freedoms. In such cases, we will re-evaluate the necessity of processing your data for our interests versus the impact on you. If your objection is valid, we will limit or stop processing the data in question. Note that in some cases we may demonstrate compelling legitimate grounds that override your objection (for example, continuing to process data if it is needed for a legal claim).

Restriction of Processing: You have the right to request that we restrict or pause the processing of your personal data in certain scenarios. This might apply if you contest the accuracy of your data (until we verify or correct it), if the processing is unlawful but you prefer restriction over deletion, or if we no longer need the data but you want us to retain it for the establishment, exercise, or defense of legal claims. When processing is restricted, we will store your data securely and not use it except in limited circumstances (such as with your consent or for legal reasons). We will inform you before lifting any restriction.

Data Portability: To the extent required by applicable law, you have the right to receive certain personal data you have provided to us in a structured, commonly used, and machine-readable format, and to have that data transmitted to another data controller where technically feasible. This right applies to personal data processed by us by automated means, where the processing is based on your consent or on a contract with you. If you request it, and where legally mandated, we will provide you with an electronic file of your most basic personal information (for example, contact details and resume information you provided) so that you can transfer it to another recruitment agency or employer.

Withdrawal of Consent: Where we rely on your consent for processing (such as for sending marketing emails or processing certain sensitive data), you have the right to withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, and it will not affect processing of your personal data under other legal bases (e.g. processing that is necessary for a contract or required by law). If you withdraw consent for marketing, we will remove you from our marketing lists. If you withdraw consent that was needed for us to provide you a service (for example, if you withdraw consent to process a background check that is mandatory for a job placement), we will inform you if that withdrawal means we cannot continue the service or engagement.

California Privacy Rights: If you are a resident of California, in addition to the rights above (many of which align with CCPA/CPRA rights), you have the right to request that we disclose what categories of personal information we have collected, used, and disclosed about you in the past 12 months, including the sources of that information, the business purposes, and the categories of third parties with whom we shared it. You also have the right to request a copy of the specific pieces of personal information we collected about you (a data portability request, as described earlier). You have the right to request deletion of your personal information (with similar exceptions as noted above). California law also provides a right to opt out of the “sale” or “sharing” of personal information – as noted, Infojini does not and will not sell your personal information, and we do not share it for cross-context behavioral advertising except with your consent via cookies (see Cookies section). If that practice ever changes, we will provide a clear opt-out mechanism. Finally, you have the right not to receive discriminatory treatment for exercising any privacy rights. Infojini will never deny services, charge different prices, or provide a different quality of service because you exercised your privacy rights. California consumers (or their authorized agents) can exercise their rights by contacting us as described below; we will verify your identity as required (for example, by confirming information we have on file) before fulfilling the request.

How to Exercise Your Rights: You can exercise the rights described above at any time by contacting us (see Contact Us section for communication methods). For certain requests, we may provide self-service options (for instance, an unsubscribe link in emails for opting out of marketing). When you contact us with a privacy request, please be specific about which right you seek to exercise and the context (e.g. if you are a candidate, employee, website user, etc., and what data the request pertains to) so we can respond most effectively. We will need to verify your identity to ensure that we do not disclose or delete data to the wrong person – we may ask you to provide certain information to confirm you are the data subject or an authorized agent. We will respond to your request within the timeframe required by law. These services are generally provided free of charge; however, if requests become excessive or unfounded, we reserve the right to charge a reasonable fee or refuse the request as allowed by law. If you disagree with our handling of a request or have concerns about our data practices, you also have the right to lodge a complaint with a supervisory authority or regulatory body in your jurisdiction (for example, a Data Protection Authority in the EU, or a state Attorney General in the US). We would, however, appreciate the chance to address your concerns directly, so we encourage you to reach out to us first.

Cookies and Tracking Technologies

Use of Cookies: Our website uses cookies and similar tracking technologies to provide, personalize, and improve our online services. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. Cookies serve various functions: they can enable certain site features, remember your preferences (like language settings), and collect information about your interaction with the site. We use cookies to help identify and track visitors, their usage of our website, and their access preferences. For example, cookies allow us to recognize your browser as a previous visitor and save any preferences you set; they also help us analyze which sections of the site are popular and how users navigate through it, so we can make improvements. Cookies by themselves do not tell us your email address or otherwise directly identify you, unless you choose to provide such information to us (for example, by filling out a form).

Types of Cookies: The cookies on our website may be categorized as follows:

• Necessary Cookies: These are essential for the operation of our site. They enable core functionality such as security, network management, and accessibility. For instance, if we have a login portal or a form, necessary cookies might help authenticate you or keep track of your input as you fill out multi-page forms. You can set your browser to block or alert you about these cookies, but some parts of the site may not function properly without them.
• Preference/Functional Cookies: These cookies allow our website to remember choices you make and provide enhanced, more personal features. For example, if you select a preferred language or region on our site, we use these cookies to remember your preference so that the next time you visit, content can be displayed in your chosen language.
• Analytics/Performance Cookies: We use these cookies to collect information about how visitors use our site – for example, which pages are visited most often, or if users get error messages on certain pages. These cookies help us understand and improve how our website performs. We might use third-party analytics tools (like Google Analytics) that set up their own cookies to track user interactions. The information collected is typically aggregated and anonymous. We do not use these cookies to identify individual visitors; they are only used to compile statistics that help us develop better content and resolve usability issues.
• Advertising/Marketing Cookies: Infojini may engage in limited advertising, such as remarketing campaigns. Remarketing cookies (also known as targeting cookies) record information about your visit to our site, such as pages viewed or links followed, and enable us (or our advertising partners) to show you relevant advertisements on other websites you visit. For example, if you visited our site and showed interest in our services, you might later see an Infojini ad on a Google search results page or on another site within Google’s advertising network. Third-party vendors like Google or AdRoll may place cookies on your browser for this purpose. These cookies do not store directly identifying information, but they use unique identifiers to associate your browser with a profile of interests based on your browsing history. If you prefer not to receive targeted ads, you can opt out as described below.

Web Beacons and Similar Technologies: In addition to cookies, our website and emails may use small electronic files known as web beacons (also called clear gifs, pixel tags, or single-pixel gifs). Web beacons are tiny graphics embedded on web pages or in emails that are used to check whether a user has accessed certain content. For example, if we send you an email newsletter, it may contain a beacon that tells us if you opened the email or clicked on a link. This helps us gauge the effectiveness of our communications and tailor future content. These technologies often work in conjunction with cookies. If you disable cookies, the web beacon may still record an anonymous visit from your device, but it will not be associated with cookie information.

Your Choices for Cookies: You have the right to control or limit how cookies are used on your devices. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies or alert you when cookies are being sent. Browser Settings: Check your browser’s help section for instructions on how to refuse cookies or delete existing cookies. Keep in mind that if you disable or delete certain cookies, parts of our site may become inaccessible or not function properly (for example, you might have to re-enter preferences each time, or some interactive features might not work). Cookie Banner: When you first visit our site, you will see a cookie consent banner. This banner allows you to accept or reject different categories of cookies (except strictly necessary ones). You can update your preferences at any time by accessing our cookie settings.

Opt-Out of Analytics and Advertising: For Google Analytics, Google provides an opt-out mechanism through a browser add-on (the “Google Analytics Opt-out Browser Add-on”) which you can download and install to prevent data from being used by Google Analytics on websites that use it. For interest-based advertising, you can manage your preferences via tools like the Google Ad Preferences page or opt out of targeted ads via the Network Advertising Initiative’s consumer opt-out or the Digital Advertising Alliance’s opt-out page. If you opt out of interest-based advertising, you will still see ads, but they may be less relevant to your interests. On mobile devices, you can usually limit ad tracking via the device settings (for example, selecting “Limit Ad Tracking” on iOS or opting out of Ads Personalization on Android).

Use of Cookies by Third Parties: Some content or applications on our site may be served by third parties, including analytics companies, social media widgets, and advertising providers. These third parties may set their own cookies (third-party cookies) on your browser. For example, if we embed a YouTube video or a social media “share” button, those platforms may set cookies to track content views or interactions. We do not have control over third-party cookies. This Privacy Policy covers the use of cookies by Infojini’s site only and not by any third-party sites or services. We encourage you to review the privacy policies of any third-party sites you visit for their use of cookies and how you can manage them.

Where required by applicable law, your consent for the use of cookies is obtained through our cookie consent mechanism. You may manage your preferences at any time. If you have questions about our use of cookies, you can contact us for more information.

International Data Transfers

Infojini operates on a global scale, and during our business your personal data may be transferred to, and processed in, countries other than the country in which you reside. For example, if you are an EU-based candidate applying for a role with a U.S. client, your data will likely be transferred to the United States; or if you are a U.S. client working with our team in India, your contact information and project data will be accessed from India. The laws of these other countries may not provide the same level of data protection as the laws in your home country. However, we take measures to ensure that your personal data remains protected according to the standards of this Privacy Policy wherever it is processed.

Within Infojini: Transfers of personal data between Infojini’s U.S. headquarters and any international branches (such as our operations in India) are governed by internal policies and agreements that ensure an adequate level of protection. All our employees globally are bound by confidentiality and data protection obligations. We treat data privacy as a universal principle, regardless of geographic location.

Transfers from the EU/EEA or UK: If you are located in the European Economic Area (EEA) or the United Kingdom and your personal data needs to be transferred to a country that the European Commission (or UK authorities) has not recognized as providing an adequate level of data protection (such as the United States or India), we will implement appropriate safeguards in line with GDPR requirements. Standard Contractual Clauses (SCCs): In most cases, we rely on the European Commission’s approved Standard Contractual Clausesas a transfer mechanism, often as part of our data processing agreements. These clauses contractually bind the receiving party to protect the personal data to EU privacy standards. Additional Safeguards: We also assess on a case-by-case basis whether additional technical or organizational measures are needed to ensure transferred data is secure – for instance, encryption in transit, data minimization, or pseudonymization of data before transfer. Adequacy Decisions: Where applicable, we may transfer data to countries that have been deemed “adequate” by the European Commission (meaning they are recognized as having strong data protection laws, such as Canada, Japan, etc.), in which case SCCs may not be required.

Other International Transfers: For transfers out of other countries with data export restrictions (for example, Brazil, or the newly enacted data protection law in India), we comply with those local requirements. This could involve obtaining your consent for the transfer, or using contract clauses or certifications permitted under those laws. For instance, India’s law might permit transfers under certain government-approved contracts or frameworks. We monitor global regulatory developments and adjust our transfer practices accordingly.

Third-Party Service Providers: Many of our third-party service providers (such as cloud hosts or SaaS tool providers) are global companies. Whenever we engage a vendor to process personal data on our behalf, we first determine where that data will be stored or accessed to understand the protections it will receive. If a service provider will access data from outside the United States or operate in a different jurisdiction, we ensure that appropriate data protection safeguards are in place. For example, if we use a third-party cloud service to handle personal data of our customers, we will have a contract requiring that provider to adhere to U.S. privacy laws and frameworks – such as the California Consumer Privacy Act (CCPA) and other applicable state data privacy laws – in protecting that information. These agreements also stipulate that the provider may only use the personal data for our specified purposes and cannot further share or sell it, consistent with U.S. privacy requirements. Additionally, we limit the personal data we share with any vendor to only what is necessary for them to perform their services.

Your Expectations: By interacting with Infojini (e.g. applying for a job or using our website), you acknowledge that your personal data may be transferred internationally as described. We want to reassure you that no matter where your data is processed, we will take appropriate steps to protect it. This includes honoring your data protection rights (as detailed above) globally. If you reside in a region that grants you specific rights or protections, we will apply those regardless of where data is processed.

If you have questions about our international data transfer practices, or need more information about the specific safeguards in place for a given transfer of your personal data, please contact us. We can provide copies of relevant contractual terms or other details, to the extent allowed under confidentiality obligations.

Children’s Privacy

As noted earlier, Infojini’s services and website are not directed to children under the age of 13, and we do not knowingly solicit or collect personal information from children under 13 (or under the applicable age of consent in relevant jurisdictions, which is 16 in parts of the EU). Our business is focused on professional services (staffing and IT consulting) and corporate clients, and therefore by its nature does not target minors. We ask that individuals under 18 (or the age of majority in their location) refrain from submitting any personal information to us. If you are a parent or guardian and believe your child under the stated age has provided personal data to Infojini, please contact us immediately. We will take steps to investigate and, if appropriate, delete the information from our records.

For minor employees (in the unlikely event we engage anyone under 18 as part of an internship or apprenticeship, for example), we comply with all applicable child labor and data privacy laws, and we would collect and process data only with requisite consents and protections. However, our general policy is that we do not hire or place minors in our staffing operations unless permitted by law and with parental consent.

We do not knowingly use any personal data of minors for marketing or any other processing. Additionally, our website does not feature content that would knowingly be of interest to children, nor do we allow minors to create accounts or publicly post information on our site. If our website contains any interactive feature and we learn that a user is underage, we will remove their information promptly.

Updates to This Privacy Policy

Policy Changes: Infojini may update or revise this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other operational reasons. If we make changes, we will post the updated policy on our website with a new “Last Updated” date. We encourage you to review this page periodically to stay informed about how we are protecting your information. If the changes are significant, we will provide a more prominent notice of the update. For example, we may notify you via email (if we have your email on file) or display a notice on our website’s homepage. In certain cases, if required by law, we may seek your consent to material changes.

If you have questions, concerns, or complaints regarding the handling of your personal information, or wish to exercise your rights under applicable data protection laws, you may contact Infojini using the details provided below. Infojini will review and address such requests or complaints in accordance with applicable law and contractual obligations. Where required by law, unresolved concerns may be escalated to the appropriate supervisory or regulatory authority.

Any changes to this Privacy Policy will become effective when posted, unless indicated otherwise. Continued use of our services or website after a Privacy Policy update constitutes acceptance of the changes, to the extent permitted by law. However, if the changes materially affect how we handle personal data that we collected from you under a previous version of the policy, we will seek to obtain your consent for the new practices or give you a clear opportunity to opt out. We will not reduce your rights under this Privacy Policy without your explicit consent.

This Privacy Policy is an integral part of our Terms of Use and any agreements we have with you. We stand by our commitments to protect your privacy and will always indicate when the Policy was last updated. (Last Updated date is provided at the top of this document.)

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please do not hesitate to contact us. We value your feedback and the opportunity to address your queries promptly. You may reach Infojini’s privacy team through the following:

• Email: You can email us at contactus@infojiniconsulting.com with the subject line “Privacy Inquiry.” This is our dedicated email address for privacy and data protection queries. We will endeavor to respond to your email within a reasonable timeframe, typically within 30 days or sooner if required by law.
• Postal Mail: You may also write to us at the following address:

  Legal Department
  Infojini  Inc.
  10015 Old Columbia Road, Suite B 215
  Columbia, MD 21046
  United States of America

Please include your contact information and a detailed description of your request or concern. If you are contacting us to exercise any of your data subject rights, please specify the nature of your request (e.g., access, deletion, etc.) and the context (such as if you are an employee, candidate, website user, etc.), so we can assist you more efficiently.

• Telephone: For urgent matters, you may call our main office at (410) 919-9440. Please ask to speak with a member of the legal or compliance team. Note that for certain requests (like access or deletion of data), we will likely follow up in writing to ensure proper verification and record-keeping.

We are committed to resolving any complaints about our collection or use of your personal data. If you contact us with a privacy-related complaint, we will investigate and respond to you promptly. If you feel that we have not addressed your concerns satisfactorily, and you are entitled to do so, you may also file a complaint with your local data protection authority (the Information Commissioner’s Office in the UK, or a state Attorney General’s office in the US). However, we kindly request that you allow us the opportunity to deal with your concerns first.

Thank you for entrusting Infojini Consulting with your personal data. We are dedicated to maintaining that trust by treating your information with care and respect, and by continuing to strengthen our privacy and security practices in alignment with global standards