Privacy Policy

Effective Date: June 1, 2025

Introduction

careeo.tech ("careeo.tech", "we", "us", or "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 at https://careeo.tech, our AI-powered voice and video interviewing platform, and related services (collectively, the “Services”).

For the purposes of this Privacy Policy, "you" or "your" refers to either a Client (a company, organization, or agency using our Services for recruitment and interviewing) or an Individual User (an individual participating in interviews initiated by our Clients, or otherwise directly using our 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.

Information We Collect

We collect various types of information to provide and improve our Services.

Personal Information

This is information that can directly or indirectly identify you. We collect this when you (as a Client or an Individual User) register for an account, schedule an interview, or contact us. This may include:

  • Name
  • Email address
  • Phone number
  • Resume and professional background
  • Any other information you provide directly to us or our Services.

Interview Data

Our platform records and transcribes interviews conducted through our Services. This includes:

  • Audio and video recordings of interviews
  • Transcripts of interview conversations
  • Responses to interview questions

Usage Data

We automatically collect information about your interaction with our Services and website. This data helps us understand how our Services are used and improve their functionality. This may include:

  • IP address
  • Browser type and version
  • Operating system
  • Referring/exit pages
  • Pages visited
  • Time and date of visits
  • Duration of visits
  • Clicks and interactions on the website (via analytics tools)

Special Categories of Personal Data

Our Services are designed to avoid the collection of sensitive personal data (e.g., racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health data, sex life or sexual orientation, genetic data, or biometric data for the purpose of uniquely identifying an individual). While our AI may sometimes ask questions that could elicit such information due to the nature of large language models, we explicitly guide candidates not to provide this type of data even if asked.

We do not intentionally process or store such special categories of personal data for specific purposes under GDPR, nor do we derive insights from it. If such data is inadvertently provided by a user or included by a hiring company in their questions, it is treated as incidental and not processed for any specific purpose related to these categories.

How We Use Personal Information

We use the information we collect for the following specific purposes, each supported by a lawful basis under data protection laws like the GDPR:

  • Providing and Operating Our Services: We use your Personal Information to facilitate AI-powered voice and video interviews, allow our Clients to create and manage their interview processes, enable Individual Users to participate, and deliver all related functionalities. Our lawful basis for this processing is the performance of a contract with you (as an Individual User, or with our Client as part of our service agreement).
  • Communicating With You: We use your information to respond to your inquiries, provide customer support, send you updates about our Services, and keep our Clients informed about service-related matters. This communication is based on the performance of a contract with you or our Client, and also on our legitimate interests to ensure effective communication and provide excellent support.
  • Improving and Analyzing Our Services: We analyze usage patterns and monitor the effectiveness of our Services and website. This helps us understand how our Platform is used, identify trends, and continuously enhance its functionality and user experience. This processing, particularly involving User Content, is performed on anonymized or de-identified data as described in our Terms (Section 6.3), and is based on our legitimate interests to grow and optimize our business.
  • Complying with Legal Obligations: We process your information when it's necessary to comply with applicable laws, regulations, legal processes, or governmental requests. This is a matter of compliance with a legal obligation that we are subject to.
  • Internal Business Operations: Your data is used for essential internal operations, accurate record-keeping, and general administration of our business. Our lawful basis for this is our legitimate interests in the efficient and proper management of our company.

Sharing Your Personal Information

We may share your information with the following categories of recipients:

  • Our Clients (Hiring Companies): Interview Data (audio, video, transcripts, responses) and relevant Personal Information (name, email, resume) are shared with the Client (the hiring company) that initiated the interview process. This sharing is fundamental to our service provision.
  • Service Providers: We engage trusted third-party vendors to assist us in operating our Services (acting as sub-processors), such as hosting providers, payment processors, communication services, and analytics services (e.g., Google Analytics, Microsoft Clarity). These providers are obligated to protect your information and act on our instructions.
  • AI Service Providers: We share raw audio and transcripts of interviews with AI models provided by third parties, such as OpenAI, to enable core functionalities like transcription and summarization. For service improvement purposes, any use of such data for AI model training or refinement occurs only after the data has been anonymized or de-identified, as detailed in our Terms (Section 6.3). These providers may process data in various international locations according to their own privacy policies and terms of service. We rely on their standard contractual clauses or other lawful transfer mechanisms where applicable for international transfers.
  • Legal Obligations: When required by law, regulation, legal process, or governmental request, or to protect our rights, property, or safety, or that of our users or the public.
  • Business Transfers: In connection with a merger, acquisition, financing, reorganisation, bankruptcy, or sale of all or a portion of our assets, your information may be transferred to the acquiring entity or successor.

International Data Transfers

As careeo.tech is a global service, your personal data may be stored and processed in countries outside of your country of residence, including outside the European Economic Area (EEA) and the United Kingdom (UK).

By default, we store data in the EU unless otherwise specified by our Clients.

When we transfer your personal data to countries that do not provide an adequate level of protection as determined by the European Commission or the UK government, we implement appropriate safeguards. This often includes reliance on standard contractual clauses (SCCs) approved by the European Commission, or other valid transfer mechanisms.

When using third-party service providers (sub-processors) like OpenAI, data may be processed in locations outside the EU/UK. We rely on the privacy policies and data protection commitments of these providers, which typically include compliance with international data transfer regulations, such as using SCCs for transfers from the EU/UK. While we strive for robust data protection, please be aware that data processing in non-EU/UK jurisdictions may be subject to different data protection laws.

Data Security

We are committed to protecting your Personal Information. We implement industry-standard technical and organizational security measures to protect your Personal Information from unauthorized access, disclosure, alteration, or destruction. These measures include:

  • Encryption of data in transit and at rest where appropriate.
  • Access controls to restrict unauthorized personnel from accessing Personal Information.
  • Regular security assessments and updates.
  • Employee training on data protection and security.

However, no method of electronic transmission or storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

Data Retention

We retain your Personal Information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, provide our Services to you or our Clients, and comply with legal, accounting, or reporting obligations.

We store data as long as the Client or the Individual User uses our Services or until they explicitly request deletion. We do not promise to store data indefinitely.

Even after a Client or Individual User requests data deletion, certain categories of data, such as those required for business operations, taxation, and legal compliance, may be retained for the necessary periods as mandated by law. Furthermore, anonymized or de-identified User Content may be retained indefinitely for service improvement and AI model training purposes, as outlined in our Terms (Section 6.3).

Your Data Protection Rights

Under applicable data protection laws, particularly the GDPR and UK GDPR, you have certain rights regarding your Personal Information. We are committed to upholding these rights:

  • Right to Access: You have the right to request a copy of the Personal Information we hold about you.
  • Right to Rectification (Correction): You have the right to request that we correct any inaccurate or incomplete Personal Information we hold about you.
  • Right to Erasure (Deletion): You have the right to request the deletion of your Personal Information, subject to certain legal and contractual obligations or legitimate interests.
  • Right to Restriction of Processing: You have the right to request that we restrict the processing of your Personal Information under certain circumstances.
  • Right to Data Portability: You have the right to receive your Personal Information in a structured, commonly used, and machine-readable format, and to transmit that data to another controller, where technically feasible.
  • Right to Object: You have the right to object to the processing of your Personal Information for specific purposes, particularly where processing is based on legitimate interests.
  • Right to Withdraw Consent: Where we rely on your consent as the lawful basis for processing, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, please contact us using the contact details provided below. We will respond to your request in accordance with applicable data protection laws.

You also have the Right to Lodge a Complaint with a supervisory authority, particularly in the Member State of your habitual residence, place of work, or place of the alleged infringement if you believe that our processing of your Personal Information violates applicable law.

California Privacy Rights

This section supplements the information contained in the rest of our Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act (CPRA). Any terms defined in the CCPA/CPRA have the same meaning when used in this notice.

When careeo.tech acts as a business (data controller) collecting your Personal Information directly (e.g., for managing your direct account with careeo.tech, or for website usage data), you, as a California resident, have the following rights:

  • Right to Know: You have the right to request that we disclose to you the categories and specific pieces of Personal Information we have collected about you, the categories of sources from which we collected it, the purposes for collecting or selling it, the categories of third parties with whom we share it, and the categories of Personal Information disclosed for a business purpose.
  • Right to Delete: You have the right to request the deletion of your Personal Information that we collected from you, subject to certain exceptions.
  • Right to Opt-Out of Sale/Sharing: careeo.tech does not "sell" or "share" Personal Information as those terms are defined under the CCPA/CPRA. We do not sell or share your Personal Information to third parties for monetary or other valuable consideration or for cross-context behavioral advertising.
  • Right to Correct Inaccurate Personal Information: You have the right to request the correction of inaccurate Personal Information we maintain about you.
  • Right to Limit Use and Disclosure of Sensitive Personal Information: careeo.tech does not collect or process sensitive personal information for purposes that would trigger the right to limit its use and disclosure under the CCPA/CPRA.
  • Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.

When careeo.tech acts as a service provider (data processor) for a Client (e.g., processing interview data on behalf of a hiring company), your CCPA/CPRA rights should typically be exercised directly with that Client (the business/data controller).

To exercise your California privacy rights, please contact us at team@careeo.tech. We may need to verify your identity before fulfilling your request.

Children's Privacy

Our Services are not intended for individuals under the age of 13. We do not knowingly collect Personal Information from children under 13. If we become aware that we have collected Personal Information from a child under 13, we will take steps to delete such information promptly.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any significant changes by posting the new Privacy Policy on our website and updating the "Effective Date" at the top. We encourage you to review this Privacy Policy periodically for any changes.

Your Consent

By using our Services, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy. If we make any material changes to this Privacy Policy, your continued use of the Services after such changes will constitute your acceptance of the updated policy.

Contact Us

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

Email: team@careeo.tech
Website: https://careeo.tech