Privacy Policy

Effective Date: April 10, 2025

Introduction

ТОВ КАРІОТЕХ (TOV KARIOTEKH), a limited liability company established under the laws of Ukraine, operating under the brand name "careeo.tech" ("careeo.tech", "we", "us", "our"), is committed to protecting your privacy and handling your personal data transparently and securely. This Privacy Policy explains how we collect, use, disclose, transfer, and safeguard your information when you access or use our website, AI-powered voice interviewing platform, and related services (collectively, the "Services").

This Privacy Policy should be read in conjunction with our Terms and Conditions of Service ("Terms"). By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy.

1. Information We Collect

We collect different types of information in connection with the Services:

1.1. Information You Provide Directly: When you register for an account, use the Services (e.g., as an interviewer or interviewee), contact support, or otherwise communicate with us, we may collect personal data, including: Identifiers (e.g., name, email address, phone number). Professional Information (e.g., resume/CV content, employment history, educational background, skills – typically provided by candidates or employers). Account Credentials (e.g., username, password). Communication Content (e.g., feedback, support requests).

1.2. Interview Data: When interviews are conducted using our Services, we collect data related to those interviews ("Interview Data," which forms part of "User Content" as defined in the Terms). This includes: Audio and/or video recordings of interviews. Transcripts generated from interview recordings. Responses provided to interview questions (whether spoken or written). Associated metadata (e.g., date, time, duration, participants).

1.3. Information Collected Automatically: When you interact with our Services, we automatically collect certain technical and usage data, potentially including: Device Information (e.g., IP address, browser type and version, operating system, device identifiers). Usage Information (e.g., pages visited, features used, time and date of access, duration of visits, clickstream data, error logs). Location Information (e.g., general geographic location derived from IP address). This information is often collected using cookies, web beacons, and similar tracking technologies.

2. How We Use Your Information

We use the information we collect for various purposes:

2.1. Providing and Managing Services: To operate, maintain, and provide the features and functionality of the Services; to create and manage accounts; to facilitate interviews; to provide customer support.

2.2. Communication: To communicate with you regarding your account, service updates, security alerts, support responses, and potentially for marketing purposes (where permitted by law and subject to your opt-out rights).

2.3. Service Improvement: To understand how users interact with our Services; to analyze usage patterns; to monitor and improve the performance, functionality, and user experience of our Services; for research and development.

2.4. AI Model Training and Development: This is a core function. We use data, particularly Interview Data (including recordings, transcripts, and responses), to train, validate, test, maintain, and improve our proprietary artificial intelligence models that power the Services. This helps enhance accuracy, fairness, and effectiveness. We may also utilize aggregated or anonymized data in collaboration with, or using tools from, trusted third-party partners for the purpose of advancing AI research and model development related to recruitment and interviewing technologies. We implement measures to protect privacy during these processes, such as anonymization or aggregation where feasible.

2.5. Legal Compliance and Safety: To comply with applicable laws, regulations, legal processes, or governmental requests; to enforce our Terms; to detect, prevent, and respond to fraud, abuse, security risks, or technical issues; to protect the rights, property, or safety of careeo.tech, our users, or the public.

3. Legal Basis for Processing

If you are in the European Economic Area (EEA) or UK, our legal basis for collecting and using the personal data described above will depend on the data concerned and the specific context. We primarily rely on:

  • Contract Necessity: Processing necessary to perform our contract with you (the Terms) to provide the Services.
  • Legitimate Interests: Processing for our legitimate interests (e.g., improving the Services, AI model training for core functionality, security, communication), provided these are not overridden by your data protection interests or fundamental rights and freedoms.
  • Consent: Where required by law or for specific purposes (e.g., certain types of marketing, or potentially specific uses of sensitive data if collected), we will obtain your consent.
  • Legal Obligation: Processing necessary to comply with our legal obligations.

4. How We Share Your Information

We may share your information in the following circumstances:

4.1. Service Providers: With third-party vendors, consultants, and other service providers who perform services on our behalf (e.g., hosting providers, cloud computing services, communication tools, analytics providers, payment processors). These providers are contractually obligated to protect your data and use it only for the services we request.

4.2. Third-Party AI Partners/Platforms: As described in Section 2.4, we may share aggregated, anonymized, or potentially pseudonymized data with trusted third parties involved in AI research or providing AI-related tools, under strict contractual terms that protect confidentiality and limit use. We will not share identifiable Interview Data with third parties for their independent AI training purposes without a clear legal basis, such as explicit consent where required.

4.3. Business Transfers: In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company. Your information may be transferred as a business asset.

4.4. Legal Requirements: If required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

4.5. To Protect Rights: If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of careeo.tech, our users, or others. This includes exchanging information for fraud protection and security purposes.

4.6. With Your Consent: We may share your information for other purposes if we have obtained your explicit consent to do so.

5. Consent Regarding Interview Data Use for AI Training

By participating in an interview using the careeo.tech Services, you acknowledge and agree to:

  • The recording of the interview (audio and/or video) and the generation of transcripts.
  • The use of this Interview Data (recordings, transcripts, responses) by careeo.tech for the AI training and development purposes described in Section 2.4 of this Privacy Policy, which are integral to providing and improving the AI-powered Services. This includes training our proprietary models and potentially contributing to related AI development using tools or platforms from trusted third parties under safeguards.
  • careeo.tech will endeavor to use anonymization or aggregation techniques where feasible for AI development to protect privacy, but you acknowledge that effective training may require processing potentially identifiable data under secure conditions.

If you do not agree to this use of your Interview Data, you should not participate in interviews using the careeo.tech Services.

6. Data Security

We implement reasonable and appropriate administrative, technical, and physical security measures designed to protect the security, confidentiality, and integrity of your personal data against unauthorized access, disclosure, alteration, or destruction. However, please be aware that no security measures are perfect or impenetrable, and we cannot guarantee absolute security.

7. Data Retention

We will retain your personal data only for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements, or to resolve disputes. The retention period for Interview Data used in AI training may extend beyond the closure of an account, subject to anonymization or aggregation where feasible and applicable legal requirements.

8. Your Data Protection Rights

Depending on your location and applicable law (such as GDPR in the EEA/UK or Ukrainian data protection law), you may have the following rights regarding your personal data:

  • Right to Access: To request copies of your personal data.
  • Right to Rectification: To request correction of inaccurate or incomplete data.
  • Right to Erasure ('Right to be Forgotten'): To request deletion of your data under certain conditions.
  • Right to Restrict Processing: To request the limitation of processing under certain conditions.
  • Right to Data Portability: To request transfer of your data to another organization, or directly to you, under certain conditions.
  • Right to Object: To object to processing based on legitimate interests or for direct marketing.
  • Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw it at any time (this will not affect past processing).
  • Rights related to Automated Decision-Making: To request information about and potentially contest decisions made solely based on automated processing, if applicable and producing legal or similarly significant effects.

To exercise these rights, please contact us at team@careeo.tech. We may need to verify your identity before responding to your request. You also have the right to lodge a complaint with a competent data protection supervisory authority (e.g., the Ukrainian Parliament Commissioner for Human Rights, or your local EU DPA).

9. International Data Transfers

Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ. careeo.tech is based in Ukraine. If we transfer personal data subject to laws like GDPR outside of the EEA, UK, or Switzerland, we will ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission or other legally recognized transfer mechanisms.

10. Children's Privacy

Our Services are not directed to individuals under the age of 16 (or a lower age if permitted by applicable law in your jurisdiction for consent purposes). We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a child without parental consent, we will take steps to delete such information promptly.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will post any changes on this page and update the "Effective Date" at the top. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. For significant changes, we may provide more prominent notice.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Email: team@careeo.tech