Privacy Policy

1. Introduction

Neato Select Private Limited (“Neato”, “we”, “us”, “our”), having its registered office at 317, 3rd Floor, Vardhaman City Plaza 2, Asaf Ali Road, New Delhi – 110006, operates the Neato mobile application, website and related digital platforms (“Platform”) through which it provides staffing, recruitment, placement and workforce-related services for Business Staffing, Household Staffing and Facility Management Staffing.

This Privacy Policy (“Policy”) explains how Neato collects, uses, discloses, stores and protects personal information relating to Customers, Customer representatives, candidates and Staff Members (each a “Data Principal”) in connection with the Platform and Neato’s services.

This Policy is issued in accordance with the Digital Personal Data Protection Act, 2023 (“DPDP Act”), the Information Technology Act, 2000 and the rules made thereunder (including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021), and forms part of, and shall be read together with, Neato’s Master Staffing Services Agreement & App Terms and Conditions.

By registering on, accessing or using the Platform, the Data Principal consents to the collection, use and disclosure of personal information as described in this Policy, to the extent such consent is required under applicable law.

2. Scope and Applicability

2.1This Policy applies to personal information collected by Neato through the Platform, customer support channels, offline registration forms, WhatsApp/SMS communications, and in the course of providing Business Staffing, Household Staffing and Facility Management Staffing services.

2.2This Policy applies to:

• (a) Customers and their authorised representatives;
• (b) candidates who register with Neato for placement opportunities;
• (c) Staff Members placed or deployed by Neato; and
• (d) any other individual whose personal information is shared with Neato in connection with a Staffing Engagement.

2.3This Policy does not apply to information collected by third-party websites, applications or services that may be linked from the Platform, which are governed by their own privacy policies.

3. Definitions

3.1“Personal Data” means any data about an individual who is identifiable by or in relation to such data, as defined under the DPDP Act.

3.2“Sensitive Personal Data or Information” includes, without limitation, financial information (such as bank account or payment details), government-issued identification numbers (such as Aadhaar, PAN or passport), biometric information (where collected), and any other category so classified under applicable law.

3.3“Data Principal” means the individual to whom the Personal Data relates, including Customers, candidates and Staff Members.

3.4“Data Fiduciary” means Neato, which determines the purpose and means of processing Personal Data collected through the Platform.

3.5“Processing” means any operation performed on Personal Data, including collection, storage, use, sharing, disclosure, or erasure.

4. Personal Information We Collect

4.1Information provided by Customers: name, mobile number, email address, business/household address, GST details (where applicable), staffing requirement details, payment and billing information, and communications with Neato.

4.2Information provided by or about candidates and Staff Members: name, date of birth, gender, contact details, residential address, photograph, educational qualifications, work experience, identity proof (such as Aadhaar, PAN, voter ID, driving licence, or passport), address proof, police verification/background-check information (where conducted), bank account details (for payroll purposes under the Neato Payroll / Managed Workforce Model), emergency contact details, and references.

4.3Information collected automatically: device information, IP address, mobile operating system, app usage data, log data, approximate or precise location (where permission is granted), booking history, in-app clicks and taps, and cookies or similar tracking technologies used on the Platform.

4.4Information collected from third parties: information received from verification agencies, background-check partners, payment gateways, analytics and advertising partners, and, where applicable, previous employers or references provided by a candidate.

4.5Sensitive Personal Data or Information: Neato collects government identification numbers, financial/bank details and, where relevant to a specific engagement, health-related information (for example, where disclosed for household staffing suitability) only where necessary for the purposes described in this Policy and with the consent of the Data Principal, or as otherwise permitted by law.

4.6Neato does not knowingly collect more Personal Data than is reasonably necessary for the purposes set out in this Policy.

4.7Consequence of not providing Personal Data: where Neato needs to collect certain Personal Data by law or under the terms of the Master Staffing Services Agreement & App Terms and Conditions, and the Data Principal does not provide that data, Neato may be unable to process the relevant Staffing Engagement, create an account, or otherwise provide the affected service, and may need to limit or decline access to the Platform to that extent.

5. How We Use Personal Information

Neato may use Personal Data for the following purposes:

• (a) registration and account creation on the Platform;
• (b) sourcing, screening, verification and background checks of candidates;
• (c) candidate matching and placement against a Customer’s staffing requirement;
• (d) issuing Booking Confirmations, Deployment Particulars and Service Acknowledgements;
• (e) processing payments, Subscription/Service Fees, invoicing and, where applicable, Staff Member payroll under the Neato Payroll / Managed Workforce Model;
• (f) customer support and grievance redressal;
• (g) sending service-related communications, including Booking Confirmations, payment reminders and staffing updates;
• (h) improving and personalising the Platform;
• (i) fraud prevention, safety and security;
• (j) compliance with applicable law, including labour, tax and data protection law; and
• (k) enforcing this Policy and the Master Staffing Services Agreement & App Terms and Conditions.

6. Legal Basis and Consent

6.1Neato processes Personal Data on the basis of the Data Principal’s consent, obtained at the time of registration, acceptance of the Master Staffing Services Agreement & App Terms and Conditions, or at the point of collection, and, where applicable, on the basis of “legitimate uses” recognised under the DPDP Act (such as for a specified purpose for which the Data Principal has voluntarily provided their Personal Data).

6.2Where consent is the basis of processing, the Data Principal may withdraw such consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal, by contacting Neato as set out in Clause 15 (Grievance Officer and Contact) below. Withdrawal of consent may affect Neato’s ability to provide some or all of its services to the Data Principal.

6.3Where a candidate or Staff Member’s Personal Data is provided to Neato by a Customer or by a third party, the person providing such information warrants that it has obtained any consent necessary under applicable law to share such information with Neato.

7. Sharing and Disclosure of Personal Information

7.1Internal sharing: Neato may share Personal Data with its affiliates and group entities, where applicable, solely for the purposes described in Clause 5 above.

7.2Sharing with Staff Members and Customers: Neato may share a Customer’s relevant contact and deployment details with the Staff Member assigned to that Staffing Engagement, and may share a candidate’s or Staff Member’s relevant identity, verification and profile details with the Customer, strictly to the extent necessary to perform the Staffing Engagement.

7.3External third parties: Neato may share Personal Data with

• (a) verification and background-check partners;
• (b) payment gateways and payment processors, for processing payments and refunds;
• (c) cloud hosting, storage, communication (SMS/WhatsApp/email) and technology service providers engaged by Neato;
• (d) analytics and advertising partners who assist Neato in understanding Platform usage and improving its services;
• (e) professional advisors, including legal and accounting advisors, where reasonably necessary;
• (f) government or regulatory authorities, courts, or law-enforcement agencies, where required by applicable law or in response to a valid legal process; and
• (g) an affiliate, successor or acquirer of Neato’s business, subject to applicable law and Clause 7.6 below.

7.4Neato requires such third parties to use Personal Data only for the specific purpose for which it is shared and to apply reasonable security practices consistent with applicable law, and does not permit them to use Personal Data for their own independent purposes.

7.5Neato does not sell Personal Data to third parties for their independent marketing purposes.

7.6Business transitions: if Neato is involved in a merger, acquisition, restructuring, or sale of all or part of its business or assets, Personal Data may be transferred as part of that transaction. Neato will ensure that any such transferee remains bound by commitments consistent with this Policy in respect of Personal Data already collected, to the extent required by applicable law.

8. Cross-Border Transfer of Personal Data

8.1Personal Data is primarily stored and processed on servers located in India.

8.2Where Neato engages a service provider (such as a cloud hosting or technology provider) that processes or stores Personal Data outside India, such transfer shall be carried out in accordance with the DPDP Act and any conditions or restrictions notified by the Central Government from time to time.

9. Data Storage and Security

9.1Neato implements reasonable security practices and procedures, including administrative, technical and physical safeguards, to protect Personal Data against unauthorised access, alteration, disclosure or destruction, in accordance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and the DPDP Act.

9.2Access to Personal Data within Neato is restricted to personnel who require such access to perform their functions.

9.3While Neato takes reasonable measures to protect Personal Data, no method of transmission over the internet or electronic storage is completely secure, and Neato cannot guarantee absolute security.

9.4In the event of a Personal Data breach that is likely to affect a Data Principal, Neato shall take such steps and provide such intimation as may be required under the DPDP Act and applicable law.

10. Payments

10.1Payments made through the Platform are processed by Razorpay Software Limited, a third-party payment gateway. Neato does not store full card details on its own servers; such data is encrypted and handled in accordance with the Payment Card Industry Data Security Standard (PCI-DSS), as managed by the PCI Security Standards Council.

10.2Transaction data (such as a limited/masked portion of card details, or UPI IDs) may be retained by the payment gateway only for as long as necessary to complete and reconcile the relevant transaction, in accordance with the payment gateway’s own policies and applicable Reserve Bank of India guidelines on storage of payment data.

10.3The Customer is encouraged to review the privacy policy and terms of the applicable payment gateway before making a payment through the Platform.

11. Data Retention

11.1Neato retains Personal Data only for as long as is necessary to fulfil the purposes described in this Policy, including for the duration of the Customer’s or Staff Member’s relationship with Neato and thereafter for such period as may be required to comply with legal, accounting, tax, regulatory or dispute-resolution requirements.

11.2Where a Data Principal withdraws consent or requests erasure, and retention is no longer necessary for the specified purpose or required by law, Neato shall erase the Personal Data in accordance with the DPDP Act.

12. Rights of the Data Principal

Subject to the DPDP Act and its rules, a Data Principal has the right to:

• (a) obtain a summary of the Personal Data being processed by Neato and the processing activities undertaken;
• (b) request correction, completion or updating of inaccurate or incomplete Personal Data;
• (c) request erasure of Personal Data that is no longer necessary for the purpose for which it was collected, subject to legal retention requirements;
• (d) withdraw consent at any time, as described in Clause 6.2;
• (e) nominate another individual to exercise these rights on the Data Principal’s behalf in the event of death or incapacity, in the manner prescribed under the DPDP Act; and
• (f) file a grievance with Neato’s Grievance Officer, and thereafter, if unresolved, approach the Data Protection Board of India.

To exercise these rights, a Data Principal may write to Neato at contact@neatonow.com or contact the Grievance Officer using the details in Clause 15 (Grievance Officer and Contact) below. Neato may require reasonable proof of identity before acting on a request, and shall endeavour to respond to access and correction requests within 7 (seven) working days, and to opt-out or unsubscribe requests within 10 (ten) business days, of receipt.

Account and data deletion: a Data Principal may request deletion of their Platform account and associated Personal Data by writing to contact@neatonow.com. Neato shall process such requests within 7 (seven) working days, following which the Data Principal will lose access to the Services. Notwithstanding such deletion, records relating to completed transactions, payments and Staffing Engagements shall be retained for such period as is required under applicable law, including tax, labour and accounting law.

13. Cookies and Tracking Technologies

13.1The Platform may use cookies, SDKs, and similar tracking technologies to remember Customer preferences, enable app functionality, analyse usage patterns, and improve the Platform.

13.2Where the Platform requests access to location, camera, contacts, storage or notification permissions on a Customer’s device, such access is used only for the specific functionality for which it is requested, and the Customer may withdraw such permission through their device settings, subject to any resulting limitation on Platform functionality.

14. Children’s Data

14.1The Platform is intended for use by persons who are at least 18 years of age, in accordance with the Eligibility clause of the Master Staffing Services Agreement & App Terms and Conditions.

14.2Neato does not knowingly collect Personal Data of children (as defined under the DPDP Act) through the Platform. Where household staffing services involve interaction with a Customer’s children (for example, in the case of Nannies), any incidental information collected shall be limited to what is necessary for providing safe and suitable staffing services, and processed with appropriate care and, where required, verifiable parental/guardian consent.

14.3If Neato becomes aware that it has inadvertently collected Personal Data of a child otherwise than as permitted by law, it shall take reasonable steps to delete such information.

15. Grievance Officer and Contact

15.1In accordance with the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 and the DPDP Act, Neato has appointed a Grievance Officer/Data Protection Contact to address queries, requests and grievances relating to Personal Data.

15.2Grievance Officer / Data Protection Contact details:

15.3Neato shall acknowledge and address grievances within the timelines prescribed under applicable law. If a Data Principal is not satisfied with the resolution provided, they may approach the Data Protection Board of India, once constituted and operative under the DPDP Act.

16. Third-Party Links and Services

The Platform may contain links to, or integrations with, third-party websites, applications or services (including payment gateways and communication providers). This Policy does not apply to such third-party services, and Neato encourages Data Principals to review the privacy policies of any third-party service they access.

17. Marketing Communications and Opt-Out

17.1Neato may, with appropriate consent or as otherwise permitted by law, send promotional or informational communications relating to its services through email, SMS, WhatsApp, push notifications, or other channels.

17.2A Data Principal may opt out of receiving marketing communications at any time by using the unsubscribe/opt-out mechanism provided in such communications or by contacting Neato using the details in Clause 15. Opting out of marketing communications does not affect Neato’s ability to send service-related or transactional communications necessary for providing its services.

18. Changes to This Policy

18.1Neato may update this Policy from time to time to reflect changes in its practices, technology, legal or regulatory requirements.

18.2The updated Policy shall be identified by a revised “Last updated” date and, where required by law or where the change is material, Neato shall notify Data Principals through the Platform or other appropriate means, and seek fresh consent where required under applicable law.

18.3Continued use of the Platform following an update to this Policy constitutes acknowledgement of the updated Policy, without prejudice to any rights the Data Principal may have under applicable law.

19. Governing Law and Jurisdiction

This Policy shall be governed by and interpreted in accordance with the laws of India, including the DPDP Act. Subject to the dispute resolution and arbitration provisions of the Master Staffing Services Agreement & App Terms and Conditions, courts at New Delhi, India shall have jurisdiction over matters arising from or connected with this Policy, to the extent permitted by law.

20. Relationship with the Master Agreement

This Policy forms part of, and should be read together with, Neato’s Master Staffing Services Agreement & App Terms and Conditions. In the event of any conflict between this Policy and the Master Staffing Services Agreement & App Terms and Conditions specifically in relation to the processing of Personal Data, this Policy shall prevail to the extent of such conflict.