Pre-Launch Waitlist — Version 1.0
Effective Date: May 2026
In this Policy, the following terms carry the meanings set out below:
"Bruw" means the Bruw platform, a product currently under development, operated by its founder as a trade name pending formal incorporation.
"Data Fiduciary" means Bruw, being the entity that determines the purpose and means of processing Personal Data, as defined under the Digital Personal Data Protection Act, 2023.
"Data Principal" means the individual whose Personal Data is being collected — whether a Candidate or an Enterprise Contact.
"Candidate" means any individual who registers interest in Bruw as a prospective job-seeker or employee.
"Enterprise Contact" means any individual who registers interest in Bruw on behalf of a company, employer, or hiring organisation.
"Personal Data" means any data about an individual who is identifiable by or in relation to such data, as defined under the DPDP Act.
"DPDP Act" means The Digital Personal Data Protection Act, 2023.
"IT Act" means The Information Technology Act, 2000, read with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules").
"Waitlist" means the pre-launch registration form hosted on the Bruw website through which Data Principals express interest in the product prior to its official launch.
Bruw is an AI-powered hiring platform currently in pre-launch development. This Policy governs the collection, use, storage, and processing of Personal Data obtained through the Bruw Waitlist registration forms — one for Candidates and one for Enterprise Contacts.
Bruw is operated as a trade name. At the time of this Policy, no company has been formally incorporated. The founder of Bruw is the Data Fiduciary for the purposes of the DPDP Act and the IT Act. Upon incorporation, all rights, obligations, and liabilities under this Policy will transfer to the incorporated entity, and this Policy will be updated accordingly with a fresh consent notice issued to all registered Data Principals.
Bruw is committed to handling all Personal Data in compliance with the DPDP Act, the IT Act, and the SPDI Rules.
The following data is collected from Candidates at the time of Waitlist registration:
The following data is collected from Enterprise Contacts at the time of Waitlist registration:
Bruw collects and processes the Personal Data described in Clause 3 for the following specific, stated purposes:
Bruw will not process your Personal Data for any purpose beyond those listed above without obtaining fresh, specific consent from you prior to such processing.
Consent is obtained at the point of Waitlist registration through an explicit, affirmative checkbox on the registration form. The checkbox is not pre-ticked. Submission of the form without actively checking the consent box is not possible.
By checking the consent box, you confirm that:
Bruw will send marketing communications, promotional content, and early-access invitations to Data Principals who have given consent under Clause 5.1. Every such communication will include a clear, one-click unsubscribe mechanism. Unsubscribing from marketing communications does not withdraw your consent to other processing purposes under Clause 4 — those must be separately withdrawn as described in Clause 8.
If you provide your LinkedIn Profile URL or GitHub Profile URL on the Waitlist form, your consent under Clause 5.1 covers Bruw's future access to those profiles upon product launch for the purpose of building your candidate profile. You may withdraw this consent at any time by writing to the Grievance Officer at the contact details in Clause 11, or by deleting your Waitlist registration under Clause 8.3.
You may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal. Upon receipt of a withdrawal request, Bruw will cease processing your Personal Data and delete it within 15 business days, subject to Clause 7.2 (Retention).
All Personal Data collected through the Bruw Waitlist is stored exclusively on servers located in India, hosted on Amazon Web Services (AWS) and/or Google Cloud Platform (GCP) within their India-region infrastructure. No Personal Data is transferred outside India.
Bruw implements the following security measures in accordance with the Reasonable Security Practices standard under Rule 8 of the SPDI Rules, 2011:
Bruw does not guarantee absolute security of data transmission over the internet, and Data Principals submit Personal Data at their own risk to that extent. Bruw will promptly notify affected Data Principals of any breach that is likely to result in harm, as required by the DPDP Act.
Bruw will retain Personal Data collected through the Waitlist for a period of 24 months from the date of registration, or until the Data Principal withdraws consent and requests deletion, whichever is earlier.
Upon withdrawal of consent or a deletion request under Clause 8.3, Bruw will delete all Personal Data within 15 business days. Bruw may retain anonymised, non-identifiable aggregate data (for example, city-level or role-level demand statistics) which cannot be used to identify any individual.
Bruw will not retain Personal Data beyond the periods set out in Clauses 7.1 and 7.2 except where retention is required by applicable law or a court or regulatory order, in which case the Data Principal will be notified where legally permissible.
Under the DPDP Act, you have the following rights in respect of your Personal Data held by Bruw:
You have the right to request a summary of the Personal Data Bruw holds about you and the purposes for which it is being processed. Bruw will respond to access requests within 15 business days.
You have the right to request correction of any inaccurate or incomplete Personal Data held by Bruw. Bruw will effect corrections within 10 business days of a verified request.
You have the right to request deletion of all Personal Data held about you. Upon receipt of a verified erasure request or consent withdrawal, Bruw will delete all Personal Data within 15 business days, subject to Clause 7.2.
You have the right to raise a grievance with Bruw's Grievance Officer (see Clause 11). Bruw will acknowledge grievances within 48 hours and resolve them within 15 business days.
You have the right to nominate another individual to exercise your rights in the event of your death or incapacity, as provided under the DPDP Act.
To exercise any of the above rights, please write to the Grievance Officer at the contact details in Clause 11.
Bruw does not sell, rent, or trade your Personal Data to any third party under any circumstances.
Bruw may share your Personal Data with the following categories of third-party service providers solely to the extent necessary to fulfil the purposes in Clause 4:
All third-party service providers are contractually bound to process Personal Data only on Bruw's instructions and in compliance with applicable Indian law.
Bruw may disclose Personal Data if required to do so by a court order, statutory authority, or applicable law. Bruw will notify the affected Data Principal of any such disclosure to the extent permitted by law.
The Bruw Waitlist is intended for individuals aged 18 years and above. Bruw does not knowingly collect Personal Data from individuals under the age of 18. If Bruw becomes aware that Personal Data of a minor has been submitted, it will delete such data promptly. If you believe that a minor has submitted data through the Waitlist, please notify the Grievance Officer immediately.
In accordance with the DPDP Act and the IT Act, Bruw has designated the following Grievance Officer for the purpose of receiving and resolving complaints from Data Principals:
Bruw reserves the right to update this Policy at any time. Material changes — including changes resulting from incorporation of the company — will be communicated to all registered Data Principals via the email address provided at registration, at least 7 days before the updated Policy takes effect. Continued use of the Waitlist registration after notification of changes constitutes acceptance of the updated Policy. If you do not accept the updated Policy, you may request deletion of your data under Clause 8.3.
This Policy is governed by the laws of India. Any dispute arising out of or in connection with this Policy shall be subject to the exclusive jurisdiction of the courts at Mumbai, India.
The following consent notice texts are to be displayed immediately above the submission button on the respective registration forms. These notices must be accompanied by an unticked checkbox.
This Policy was prepared for internal and website use by Bruw. Version 1.0 — May 2026.