DATA PROCESSING AGREEMENT

NoKuJob™ — A Product of AJ Human AI® Private Limited

Last Updated: July 07, 2025

1. DEFINITIONS

Controller: User/Student (you)
Processor: AJ Human AI® Private Limited (we)
Personal Data: As defined in GDPR Article 4(1)
Processing: As defined in GDPR Article 4(2)
Sub-processor: Third-party processors we engage

2. SCOPE AND PURPOSE

Category	Details
Subject matter	CV creation, job research, staff-assisted application submission (ONLY with per-application approval from Controller), application tracking
Duration	Subscription period + retention period
Nature	Collection, storage, analysis, document creation, application submission (with per-application approval), deletion
Purpose	Creating CVs, cover letters, identifying jobs, submitting applications with explicit approval, providing dashboard and audit trail
Data subjects	Registered users
Data types	Names, contact info, education, work experience, skills, visa info

3. PROCESSOR OBLIGATIONS

Process only on documented instructions
Staff bound by confidentiality (NDAs signed)
Implement security measures per GDPR Article 32
Assist with data subject rights (GDPR Chapter III)
Assist with breach notification
Delete data upon termination
Submit applications ONLY with per-application approval from Controller
Do NOT access Controller's email, LinkedIn, Indeed, or personal accounts
ONLY submit through employer career website application forms
Maintain complete audit trail with timestamps, IP addresses, approval records

4. SECURITY MEASURES (GDPR Article 32)

Technical: AES-256 encryption, TLS 1.2+, Argon2 hashing, RBAC, CSRF protection, rate limiting

Organizational: NDAs, security training, access controls, incident response plan, audit logs

5. SUB-PROCESSORS

Sub-processor	Purpose	Location
Razorpay	INR payment processing	India
Wise	International payments	EU/Global
Cloud hosting (AWS or equivalent)	Infrastructure	India/Global
Email service provider	Notifications	Varies

30-day notice for new sub-processors; 15-day objection window

6. DATA SUBJECT RIGHTS ASSISTANCE

Access: Within 30 days
Rectification: Within 5 days
Erasure: Within 30 days
Portability: CSV/JSON format
Consent withdrawal: Effective immediately (includes application submission authorization revocation)

7. DATA BREACH NOTIFICATION

Within 48 hours of discovery, with full details: nature of breach, data affected, potential consequences, steps taken

8. INTERNATIONAL TRANSFERS

EU SCCs (European Commission Decision 2021/914) for EU/EEA
UK IDTA for UK transfers
Transfer Impact Assessments conducted

9. AUDIT RIGHTS

Annual audit with 30-day notice

10. TERMINATION

Data deleted within 90 days of subscription end
Payment records retained 7 years (legal requirement)
Backup data removed within backup rotation cycle

11. GOVERNING LAW

GDPR for EU/EEA, UK GDPR for UK, Privacy Act 1988 for Australia, DPDP Act 2023 for India

12. CONTACT

AJ Human AI® Private Limited
CIN: U62099KL2025PTC095861 | GSTIN: 32ABDCA3587H1ZQ
Official: official@nokujob.com | Support: support@nokujob.com | Phone: +91 80758 76201
Address: Thapasya Building, Smart Business Centre - 2, Infopark Phase 1, Kakkanad, Kochi, Kerala 682042, India