Privacy Policy — IntervAI AI-Powered Hiring Platform

Version: 3.0 — June 2025
Owner: Team IntervAI
Last updated: 21.06.2025

1. Introduction

IntervAI ("we", "our", or "us") respects your privacy and is committed to protecting personal data in compliance with the General Data Protection Regulation (EU Regulation 2016/679 — GDPR), UK GDPR, and other applicable data protection laws. This Privacy Policy explains how we collect, use, process, share, and protect personal data when you use our AI-powered hiring platform.

This policy applies to our digital platform at Intervai — AI-powered Interview Platform, used to support AI-powered recruitment services and match candidates with potential employers (recruiters).

2. Data Controller

Company Name: IntervAI (Startup Phase)
Legal Status: Operating in MVP stage, not yet legally incorporated. This notice will be updated upon legal incorporation.
Contact Email: hello@intervai.net
Website: https://intervai.net
Address: [To be updated upon legal formation]

3. Categories of Personal Data We Process

A. Candidate Identity and Contact Details

Full name
Email address
Phone number
Profile photo (optional)
IP address
Postal address (optional)
LinkedIn or other social links (optional)

B. Application and Background Information

CV / resume (upload and extracted data)
Employment history
Education background
Certificates and qualifications
Language proficiency
Work authorization status
References

C. Motivation and Interaction

Cover letter or motivation answers
Desired role and salary expectations
Availability / start date
Recorded interview answers (text/audio)
Avatar-enabled or video-based self-presentations (optional)
Interaction logs (saved jobs, search preferences, feedback provided)

D. Technical and Analytical Data

Device type and browser
Date and time of access
Geolocation data (approximate)
Platform activity logs

E. Recruiter User Data

Name, email address, company name
Usage logs (login, activity, audit logs)

4. Purpose and Legal Basis for Processing

We process your data for the following purposes:

Purpose	Legal Basis
To enable creation of candidate profiles	Consent (Art. 6(1)(a) GDPR)
To match candidate profiles with recruiter requirements	Consent (Art. 6(1)(a)), Legitimate Interest (Art. 6(1)(f))
To facilitate AI-powered interviews	Consent, Legitimate Interest
To analyze performance and suggest improvements to candidates	Consent
To forward application details to recruiters	Consent
To improve product functionality (anonymized)	Legitimate Interest
To comply with legal obligations (e.g., tax, law enforcement)	Legal Obligation (Art. 6(1)(c))
Recruiter account management and platform operation	Legitimate Interest

5. How We Collect Your Data

We collect personal data:

Directly from you when you register, upload your CV, answer interview questions, or interact with the platform.
Indirectly via technical means such as cookies or analytics tools.
From third-party integrations (e.g., when you import data from LinkedIn).

6. Automated Processing and Profiling

Our platform may use AI tools to:

Evaluate interview answers
Provide feedback on speaking patterns, tone, clarity
Suggest strengths and improvement areas
Generate AI-based evaluation scores (skills, soft skills, fit)

These processes constitute AI-based profiling. The results are advisory only and do not constitute automated decision-making with legal or similarly significant effects (Art. 22 GDPR). Final hiring decisions are always made by human recruiters.

7. Right to Object to Profiling (Art. 21)

Candidates have the right to object to AI-based profiling at any time. To exercise this right, please contacthello@intervai.netprior to participating in the AI interview.

8. Data Sharing and Third Parties

We may share your personal data with:

A. Employers / Recruiters

Only for positions you explicitly apply for. Recruiters receive your full profile as submitted. Once shared, they become independent controllers of your data.

B. Sub-Processors / Vendors

We use third-party providers for hosting, AI processing, analytics, communications, and infrastructure. These include:

Vendor	Purpose	Data Location
AWS	Hosting, data storage	EU region
Azure	Speech Recognition (SR)	EU region
OpenAI	LLM processing (resume parsing, AI interviewer)	US (SCC applied)
SendGrid (Twilio)	Email delivery	US (SCC applied)

All processors operate under GDPR-compliant terms. International data transfers are protected by Standard Contractual Clauses (SCCs).

9. International Transfers (Art. 44–50)

Certain processors used by IntervAI (such as OpenAI and SendGrid) may process data outside the EEA, including the United States. These transfers are protected by Standard Contractual Clauses (SCCs) to ensure adequate protection of personal data. Where possible, EU-based data centers are selected (e.g., AWS, Azure).

10. Data Security Measures (Art. 32)

We employ the following safeguards:

HTTPS/TLS encryption
Role-based access control
Server-side encryption of stored data
Regular backups and audit logs
Pseudonymization where applicable
Secure data centers in EU regions where possible

Further details are provided in our Security Measures document.

11. Data Retention and Deletion

Active profiles are retained for up to 12 months.
You can delete your profile at any time by contacting hello@intervai.net.
Recruiters may delete data once the hiring process ends.
Some data may be retained anonymously for analytical purposes.
We may retain records as required by law (e.g., tax, legal defense).

12. Your Rights Under GDPR

As a data subject, you have the following rights:

Right of Access (Art. 15)
Right to Rectification (Art. 16)
Right to Erasure (Art. 17)
Right to Restrict Processing (Art. 18)
Right to Data Portability (Art. 20)
Right to Object (Art. 21), including objection to profiling
Right to Withdraw Consent (Art. 7)
Right to Lodge a Complaint with a supervisory authority (Art. 77)

To exercise these rights, contact hello@intervai.net. Requests will be handled within 1 month.

Supervisory Authority in Austria:
Datenschutzbehörde (DSB)
Barichgasse 40-42, 1030 Wien
Email: dsb@dsb.gv.at
Website: https://www.dsb.gv.at/

13. Recruiter Personal Data Handling

We collect and process recruiter user data (name, email address, company name, usage logs) for account management, platform operation, and security purposes. Recruiter users may exercise their GDPR rights (access, rectification, erasure, objection, portability) by contacting hello@intervai.net.

14. Cookies and Analytics

Essential Cookies (Consent not required)

Session management and authentication
Security features and CSRF protection
User preferences

Retention: Session or 30 days max

Analytics Cookies (Requires consent)

Google Analytics: Traffic analysis, user behavior
Google Tag Manager: Tag and event management

Retention: 26 months (Google default)
Data processor: Google LLC (US) - covered by DPA

You can use our platform with essential cookies only. Analytics cookies help us improve the service but are optional.

15. Changes to This Policy

We may update this Privacy Policy as our platform evolves or legal requirements change. Major changes will be communicated via email or in-app notification. The latest version is always available at https://intervai.net.

16. Contact

Team IntervAI
Email: hello@intervai.net

Disclaimer: IntervAI is currently in its MVP and pre-legal-incorporation phase. This Privacy Policy is effective from the date of publication and subject to formalization upon legal registration of the entity.
End of Document — Version 3.0 — June 2025