Contents

  1. Who we are
  2. What data we collect
  3. Why we collect it
  4. How we use it
  5. Who we share it with
  6. How long we keep it
  7. How we protect it
  8. Your rights
  9. AI and automated decisions
  10. DPDP 2023 — India
  11. GDPR — European Union
  12. Cookies
  13. Changes to this policy
  14. Contact and grievances

1Who we are

SKILWI.ai is India's first Workforce Intelligence Operating System. We are operated by SKILWI Technologies, incorporated in Bangalore, Karnataka, India.

We provide a software platform that helps organisations understand the skills their employees have, identify gaps, run Training Needs Analysis (TNA), manage recruitment, and make workforce planning decisions.

For the purposes of India's Digital Personal Data Protection Act 2023 (DPDP 2023), SKILWI.ai is the Data Fiduciary. For the purposes of GDPR, SKILWI.ai acts as a Data Controller for our own marketing and website data, and as a Data Processor for employee and candidate data processed on behalf of our enterprise clients.

Our details

CompanySKILWI Technologies, Bangalore, Karnataka, India
Grievance OfficerLince A Antony — grievance@skilwi.ai

2What data we collect

We collect different types of data depending on whether you are a candidate (applying for a job through SKILWI.ai), an employee (whose employer uses SKILWI.ai), or a visitor to our website.

Candidate data

Data typeExamplesHow collected
IdentityName, email, phone numberCV upload or direct entry
Resume / CV contentWork history, education, skills, certificationsCV upload (PDF/Word)
Skill profileExtracted skills mapped to ESCO taxonomy, proficiency levels, match scoresAutomated AI extraction from CV
Assessment resultsPersonality assessment scores (TKI, DiSC, EQ-i) if conductedAssessment platform
Consent recordDate, time, purpose of consent givenConsent screen at CV upload

What we strip out: Our CV parser is configured to discard Aadhaar numbers, PAN numbers, date of birth, and biometric data unless your employer has explicitly enabled these for a specific, stated purpose. These fields are never used for matching or scoring.

Employee data (when your employer uses SKILWI.ai)

Data typeExamplesSource
ProfileName, role, department, seniority levelEmployer upload or HR system
Skill inventoryCurrent skills, proficiency levels, ESCO codes, confidence scoresCV import + manager assessments + learning completions
Performance dataReview scores, goal achievement, skill ratings from managerPerformance review submissions
Learning dataTraining assigned, in progress, completed, validatedPlatform tracking + LMS integration if enabled
Career dataCareer aspirations (if voluntarily entered), readiness scores, mobility matchesEmployee self-entry + automated calculation
Wellbeing signalsAnonymous pulse survey responses, aggregate burnout risk scoreWeekly 5-question pulse (anonymous)
Contact PIIPhone number (encrypted), Aadhaar last 4 digits (encrypted if collected), PAN (encrypted if collected)Employer HR records

Website visitor data

If you visit skilwi.ai, we collect standard web analytics data (pages visited, browser type, referring URL, time on page) if you accept analytics cookies. We do not collect this data if you decline cookies. We do not use third-party advertising cookies.

Demo request form data

If you fill in our demo request form, we collect your name, work email, company name, company size, and industry. This data is used only to contact you about a product demo and is never sold or shared with third parties for marketing.

3Why we collect it

We collect data only for specific, stated purposes. We do not collect data speculatively or "just in case."

PurposeLegal basis (DPDP 2023)Legal basis (GDPR)
CV parsing and candidate matchingConsent (given at CV upload)Consent / Legitimate interest (recruitment)
TNA and skill gap analysisConsent + Employer legitimate interestContract performance / Legitimate interest
Performance managementEmployer legitimate interestContract performance
Career pathing and internal mobilityEmployee consentConsent
Wellbeing pulse surveysAnonymous — consent not requiredAnonymous — consent not required
Decision intelligence (upskill vs hire)Employer legitimate interestLegitimate interest
Platform security and audit logsLegal obligationLegal obligation
Demo request follow-upConsent (form submission)Consent

Purpose limitation: Data collected for recruitment is not used for performance scoring without fresh consent. Data collected for TNA is not used for marketing. Each dataset has one primary purpose and does not migrate to another without your knowledge.

4How we use it

Concretely, here is what happens to your data inside SKILWI.ai:

5Who we share your data with

We do not sell your data. We do not share your data with advertisers. We share data only in the following limited circumstances.

Your employer

If you are a candidate or employee, your employer (who is our client) can see your skill profile, TNA results, and performance data. Your employer cannot see your individual wellbeing pulse responses — only anonymised team aggregates.

Sub-processors (technology partners)

PartnerPurposeData sharedLocation
Groq (Llama 3.3 70B)AI skill extraction and IDP generationCV text excerpts, skill names (no PII)USA
Google (Gemini 2.0 Flash)AI fallback for content generationAnonymised text prompts (no PII)USA / EU
Hostinger KVM2Server hosting and infrastructureAll platform data (encrypted at rest)EU (Amsterdam)
ChromaDBVector search for CV-JD matchingSkill embeddings (no raw PII)On-premise (same server)

Important: We are in the process of obtaining written confirmation from Groq and Google that they do not train their models on SKILWI customer data. Until this is confirmed in writing, we treat all AI provider calls as potentially retaining data and minimise PII in prompts accordingly.

Legal disclosure

We may disclose your data if required by Indian law, court order, or a lawful request from a government authority. We will notify you of any such request where legally permitted to do so.

6How long we keep your data

Data typeRetention periodReason
Rejected candidate profiles90 days after rejectionDPDP 2023 data minimisation requirement
Active candidate profilesDuration of recruitment process + 90 daysEmployer legal obligation
Employee skill profilesDuration of employment + 1 yearEmployer legal obligation / audit
Performance reviewsDuration of employment + 3 yearsLabour law compliance
Wellbeing pulse (aggregates only)2 years rollingTrend analysis — no individual data retained
CV files (raw)90 days after last useStorage cost + privacy minimisation
Demo request data2 years or until you opt outSales follow-up
Website analytics13 monthsStandard analytics retention
Audit/access logs5 yearsSecurity and legal compliance

You can request deletion of your data at any time. See Your Rights below.

7How we protect your data

We take security seriously. Here is what is currently implemented:

Upcoming: We are planning a full penetration test and VAPT assessment before onboarding our first enterprise client. Database access logging (who queried what PII and when) is scheduled for Sprint 3.

Data breach response

In the event of a data breach, we commit to notifying affected data principals within 72 hours of discovery (as required by GDPR) and as soon as reasonably practicable under DPDP 2023. We will notify the Data Protection Board of India and relevant EU DPAs as required by law.

8Your rights

You have the following rights over your personal data. To exercise any of these rights, contact us at privacy@skilwi.ai. We will respond within 30 days.

Right to Access

Request a copy of all personal data we hold about you, in a readable format.

Right to Rectification

Ask us to correct inaccurate data — for example, a skill incorrectly extracted from your CV.

Right to Erasure

Request deletion of your personal data ("right to be forgotten"). We will hard-delete all PII within 30 days.

Right to Portability

Receive your data in a machine-readable format (JSON) to transfer to another service. (GDPR only)

Right to Object

Opt out of automated profiling or TNA scoring. You can request human review of any AI-generated score.

Right to Withdraw Consent

Withdraw consent at any time. This does not affect processing done before withdrawal but stops future processing.

How to make a request

Email privacy@skilwi.ai with the subject line "Data Rights Request" and the following: your full name, email address used in SKILWI.ai, your employer (if an employee), and the specific right you wish to exercise. We will respond within 30 days. If we need to verify your identity, we will ask for confirmation before acting on the request.

9AI and automated decisions

SKILWI.ai uses artificial intelligence in several parts of the platform. We are transparent about where AI is used and what decisions it influences.

AI functionWhat it doesHuman oversight
CV skill extractionExtracts skills from your resume and maps them to the ESCO taxonomyEvery extracted skill is visible to the recruiter and candidate. You can dispute any extraction.
Candidate match scoringRanks candidates against a job description using a 5-signal weighted scoreScore is advisory only. Every score shows its reasoning. Hire/reject decisions are made by humans.
TNA gap analysisIdentifies skill gaps between an employee's current profile and their role requirementsGap results are presented as recommendations. Employees and managers can override any gap classification.
IDP generationWrites a personalised development plan narrative using Groq Llama 3.3 70B or Gemini 2.0 FlashAll AI-generated text is clearly marked as AI-generated. Managers and HR edit and approve before sharing.
Upskill vs hire recommendationCalculates the cost and timeline of upskilling vs external hiringOutput is a cost model, not a mandate. Leadership makes the final decision.

No AI makes a final hiring decision. SKILWI.ai scores and ranks candidates, but every hire, reject, and offer decision is made by a human recruiter or hiring manager. The platform is designed to inform decisions, not replace them.

Bias and fairness

We are aware that AI models can reflect biases present in training data. Our matching engine scores candidates on skill evidence, not on names, gender, location, or caste. We are planning a formal bias audit — testing the matching engine for gender, age, and location discrimination — scheduled before our first enterprise client onboarding.

If you believe an AI score has treated you unfairly, you have the right to request human review. Contact us at privacy@skilwi.ai.

10DPDP 2023 — India

The Digital Personal Data Protection Act 2023 applies to all personal data of Indian citizens processed by SKILWI.ai. This section sets out our obligations and your rights under DPDP 2023 specifically.

Data Fiduciary obligations

As a Data Fiduciary under DPDP 2023, SKILWI.ai commits to:

Consent under DPDP 2023

We obtain consent before collecting personal data. Consent must be:

Grievance redressal

DPDP 2023 requires us to have a Grievance Officer. Our Grievance Officer is:

NameLince A Antony
DesignationFounder and Data Fiduciary Representative
Response timeWithin 30 days of receiving a complaint

If you are not satisfied with our response, you may escalate to the Data Protection Board of India (once constituted) or approach a court of competent jurisdiction.

Cross-border data transfers

Some of your data is processed by our AI providers (Groq, Google Gemini) whose servers are located outside India, primarily in the United States. We process the minimum necessary data through these providers and are monitoring the Government of India's notifications on permitted cross-border transfer countries under DPDP 2023.

11GDPR — European Union

GDPR applies to SKILWI.ai when we process data of EU citizens — for example, if an EU-based company uses our platform or an MNC employee in India holds EU citizenship.

Our role under GDPR

When we process employee and candidate data on behalf of an enterprise client, we act as a Data Processor. The enterprise client is the Data Controller. If you wish to exercise GDPR rights over data held in an employer's SKILWI.ai account, please contact your employer first — they will instruct us accordingly.

For data we collect directly (website analytics, demo requests), we act as a Data Controller.

GDPR rights

In addition to the rights listed in Section 8, EU residents have the right to lodge a complaint with the Data Protection Authority (DPA) of your EU member state if you believe we have violated GDPR.

International transfers from the EU

Where we transfer EU personal data outside the EU/EEA, we use:

We are in the process of executing SCCs with Groq and Google for EU data transfers. Until these are finalised, we minimise EU PII in all AI provider calls.

Data Protection Officer

We do not currently have a formally appointed DPO. As we grow and our processing of EU data increases, we will appoint a DPO or engage a GDPR-specialist legal advisor. For all GDPR queries, contact privacy@skilwi.ai.

12Cookies

We use cookies on skilwi.ai. The cookie consent banner on our homepage lets you accept or decline non-essential cookies.

Cookie typePurposeCan be declined?
EssentialKeeps you logged in, remembers your theme preference (light/dark), cookie consent choiceNo — required to use the site
AnalyticsUnderstand which pages are visited and how (no personal data)Yes — decline in the banner
AdvertisingWe do not use advertising cookiesN/A

Your cookie preference is stored in your browser's localStorage under the key skilwi-cookie-consent. To change your preference, clear your browser's localStorage for skilwi.ai or contact us.

13Changes to this policy

We will update this policy as our practices evolve, as we add new features, or as laws change. When we make material changes, we will:

Continued use of SKILWI.ai after a policy change constitutes acceptance of the updated policy. If you disagree with a change, you may exercise your right to erasure or contact us to discuss.

14Contact and grievances

For any privacy-related question, data rights request, complaint, or grievance, use the channels below.

Get in touch

General privacyprivacy@skilwi.ai
Grievance (DPDP)grievance@skilwi.ai
General enquirieshello@skilwi.ai
Response timeWithin 30 days for data rights requests. Within 3 business days for general queries.
AddressSKILWI Technologies, Bangalore, Karnataka, India

Escalation

If you are not satisfied with our response to your complaint: