PRIVACY POLICY
Last Updated: 2 September 2026
Koyo is committed to protecting your privacy and to being transparent about how we collect and use your personal data. Koyo is an AI-powered interviewing product operated by Incanus Technologies Private Limited and its affiliates (“Newton School,” “Koyo,” “we,” “us,” or “our”).
This Privacy Policy describes the personal data we collect and process when you visit our website or use our AI-powered interview services and applications (collectively, the “Services”). When we refer to your “data” or “information,” we mean personal data as defined under applicable law — information that identifies, relates to, or could reasonably be linked to you as an identifiable individual.
Please read this Privacy Policy carefully. If you do not agree with it, you should not access or use the Services.
1. Scope of This Privacy Policy
The data we collect and how it is handled depends on how you interact with Koyo. You may use our Services as a:
- Visitor to our website;
- Employer Representative using Koyo on behalf of an organisation;
- User — an employee or contractor of an employer granted access to the platform; or
- Candidate — an individual invited by an employer to participate in an AI-powered interview or assessment.
When you use Koyo as a User or Candidate, your employer acts as the data controller and Newton School (operating Koyo) acts as the data processor, processing your data solely on the employer’s instructions and in accordance with the applicable Commercial Terms (including the Data Processing Addendum). When you interact with us directly as a Visitor or Employer Representative, Newton School acts as the data controller.
2. How We Collect Your Data
We collect and process your data through the following means:
Automatically
We automatically collect certain technical and usage data when you access or use the Services, including information about your device, browser, IP address, activity logs, pages visited, and interactions with the platform.
Provided by You
We collect data you provide when you create or access an account, participate in an AI interview, submit audio, video, or written responses, or communicate with us for support.
Provided by Employers
If you are a User or Candidate, the employer who invited or authorised your access may provide us with personal data about you, such as identifying information and interview configuration details.
Received from Third Parties
We may receive information from third-party service providers that support hosting, analytics, security, identity verification, or platform functionality.
3. Data We Collect and Process
Data We Automatically Collect
- IP address and approximate location
- Browser, device, and operating system information
- Usage logs, timestamps, and interaction data
- Performance and diagnostic data
Data You Provide to Us
- Identifiers: name, email address, phone number, and username
- Professional or employment information, such as role-related details and experience (where provided)
- Interview interactions and results: responses, transcripts, audio and video recordings, AI-generated summaries, scores, and structured insights (collectively, “Interview Results”)
Certain interview features may require the collection of audio, video, or facial images. These features are enabled at the employer’s discretion. We will provide sufficient notice before collecting such data, and where required by law, obtain your consent through a separate, explicit mechanism.
We may receive professional or identifying information from third-party providers assisting employers with candidate sourcing or platform integrations, where permitted by applicable law.
4. How We Use Your Data
We use your data to:
- Provide, operate, maintain, and improve the Services;
- Conduct AI-powered interviews and generate Interview Results;
- Make Interview Results available to the relevant employer;
- Detect, prevent, and address security threats or fraud;
- Ensure compliance with applicable terms and laws;
- Communicate with you regarding service-related matters; and
- Improve our Services using anonymised or aggregated data only.
All hiring and employment decisions are made solely by employers. Koyo provides AI-generated insights to assist employers— it does not make employment decisions on their behalf.
Visitor and Employer Representative data is retained only for as long as permitted by law or necessary for legitimate business purposes. User and Candidate data is retained in accordance with the duration specified in the employer’s agreement with Koyo, or as otherwise required by applicable law. Following termination of that agreement, data will be deleted or returned in accordance with the applicable Commercial Terms.
5. Where and How We Store Your Data
Data collected through the Services is hosted on Amazon Web Services (AWS) infrastructure located in the AWS Mumbai region (ap-south-1). As a standard practice, candidate and interview data is stored within India and is not transferred outside India except where a specific integration or service provider requires it and is disclosed to the relevant employer.
Our underlying cloud infrastructure provider maintains SOC 2 Type II attestation. Newton School is separately pursuing ISO/IEC 27001 certification for its own application and organizational security controls.
6. How We Disclose Your Data
We may disclose your data to the following parties:
- Employers — Interview Results and related assessment data;
- Service Providers — hosting, analytics, security, and support vendors acting on our behalf. The list of sub-processors is available at our website;
- Affiliates — Newton School group entities, where lawful;
- Integrations — third-party services enabled by employers;
- Legal Authorities — where required by law, court order, or to protect the rights and safety of individuals; and
- Business Transfers — in connection with a merger, acquisition, or sale of assets.
We do not sell personal data.
7. Automated Processing and AI Features
Koyo uses artificial intelligence and automated processing to analyse interview responses and generate structured insights for employers. Koyo does not make final or binding decisions through automated processing alone, and does not train AI models on identifiable personal data. Any model improvement uses only anonymised, aggregated, or synthetic data.
Visitors
Where Automated Tools are used in a demonstration or trial context, Koyo acts as the data controller. We will notify you before any data collection begins and, where required by law, obtain your consent through a separate, explicit mechanism. Browsing the website does not constitute consent.
Employer Representatives
When you enable Automated Tools for candidate assessments, your organisation acts as the data controller for candidate data and is responsible for providing required notices and obtaining any necessary consents. Koyo processes that data solely on your organisation’s instructions under the applicable Commercial Terms.
Users (Employer Staff)
Your access to the platform and the processing of your account data is governed by your employer’s subscription and the applicable Commercial Terms. Your employer acts as the data controller for your activity on the platform.
Candidates
The employer who invited you is the data controller for your personal data and is responsible for establishing a valid legal basis for its processing before your assessment begins. Koyo will display a clear notice at the start of any assessment identifying what data is collected and for what purpose. Participating in an assessment does not constitute consent — where consent is required, it will be sought through a separate, explicit mechanism before data collection begins. Assessment outputs are shared with the employer; all hiring decisions rest solely with them. For concerns about how your data was processed, contact us at grievance@newtonschool.co.
Proctoring
Certain assessments may include proctoring features enabled at the employer’s discretion, which may involve audio/video recording, facial monitoring, and behavioural analysis. Candidates will be notified before any proctoring begins.
8. Security of Your Data
We use a combination of technical and organizational measures designed to protect your data from unauthorized access, use, alteration, or disclosure, including:
- Encryption of data in transit and at rest
- Role-based access controls limiting internal access on a need-to-know basis
- Logical separation of data between employer accounts
- Ongoing monitoring of our hosting environment
No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If you have questions about the security of your data, you can contact us using the details in Section 13.
9. Cookies and Similar Technologies
We use cookies and similar technologies to operate and secure the Services, analyse usage and performance, and improve functionality and user experience. You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may limit the functionality of the Services.
10. Your Rights
Depending on your jurisdiction, you may have the right to:
- Access your personal data;
- Correct inaccurate or incomplete data;
- Request deletion or restriction of processing;
- Request data portability; and
- Object to certain types of processing.
If you are a Visitor or Employer Representative, you may exercise these rights by contacting us directly at grievance@newtonschool.co.
If you are a User or Candidate, your employer is the data controller for your data and privacy-related requests should generally be directed to your employer in the first instance. Koyo will support employers in fulfilling such requests as required by applicable law and the applicable Commercial Terms. You may also contact Koyo directly at grievance@newtonschool.co for concerns about how your data has been processed.
11. Children
11.1 The Services are intended for individuals aged 18 and above. A person under 18 may access the Services only through an account held by a parent or lawful guardian, in accordance with Clause 2.2 of our Terms of Use.
11.2 Where we process the personal data of a person under 18, we do so on the verifiable consent of their parent or lawful guardian, limited to what is necessary to provide the Services. We do not track or behaviourally monitor children, direct advertising at them, or process their data in any manner likely to have a detrimental effect on their well-being.
11.3 If we become aware that a person under 18 has registered otherwise than through a parent or lawful guardian, we will suspend the account and delete the data collected, retaining only what applicable law requires.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. Updates take effect upon posting, and the “Last Updated” date at the top of this Policy reflects the most recent revision. We encourage you to review this Policy periodically.
13. Grievance Redressal
In accordance with the Information Technology Act, 2000, the Information Technology (Intermediary Guidelines) Rules, 2011, and the Digital Personal Data Protection Act, 2023, any grievances or concerns relating to the collection, use, storage, disclosure, or processing of personal data on our platform may be directed to our designated Grievance Officer.
The Grievance Officer will acknowledge and resolve complaints in accordance with the timelines prescribed under applicable law. The contact details of the Grievance Officer are as follows:
- Name: Priteesh
- Designation: Grievance Officer
- Email: grievance@newtonschool.co
- Phone: +91 6364462371
- Hours: Monday – Friday, 10:00 AM to 4:00 PM (IST)
Last Updated: 2 September 2026 • Incanus Technologies Private Limited • grievance@newtonschool.co