PRIVACY POLICY
Last Updated: 26^th Feb, 2025

1. INTRODUCTION

• Welcome to Clarifyme.ai (“Website” or “Platform” “we,” “our,” or “us”).
• This Privacy policy applies to all users (“You” or “Your”) of Clarifyme.ai, including both visitors who browse our website and registered users who actively engage with our Platform services.
• We collect, use, and disclose personal information through our web-based platform and browser extension, which records, transcribes, and summarizes recruitment interviews.
• We are committed to protecting your privacy in compliance with the Australian Privacy Act 1988 (Cth) and, where applicable, other relevant data protection regulations including but not limited to the General Data Protection Regulation (GDPR) in the European Union and the California Consumer Privacy Act (CCPA) in the United States.

2. USER AGE POLICY AND AGE RESTRICTION COMPLIANCE

• Our services are not intended for children under 13, and we do not knowingly collect their data. If such data is inadvertently collected, it will be deleted immediately.
• We comply with COPPA and relevant international laws on minors’ data protection. Users aged 13–18 may use our services only with parental or guardian consent where required by law. We may request confirmation of consent and take steps to verify age or delete accounts if necessary.

3. YOUR CONSENT

• By accessing our services, you agree to the practices described in this Privacy Policy. Continued use of our services implies consent to data collection, processing, and sharing as outlined herein. You have the right to withdraw consent at any time, which may affect your access to certain features of our services.

4. WHAT INFORMATION DO WE COLLECT?

• Information Provided by You
  • 1.1. When you engage with our Platform, we may collect certain information that you provide directly to us. This includes, but is not limited to
    • 1.1.1. Contact Details: Any communication data, such as email address, phone number, or social media handle, that you use to contact us or that you input when subscribing to updates, newsletters, or support.
    • 1.1.2. Account Information: When you register, you provide details such as your official email address, username, password, and, if applicable, your organization or company name.
    • 1.1.3. Profile Data: Information you choose to include in your profile, such as your job title, preferences, interests, and areas of expertise.
    • 1.1.4. Billing Information: If you purchase our services, we may collect payment-related information, including billing address and payment method details (note: payment details are usually processed securely through a third-party payment processor stripe).
    • 1.1.5. User-Generated Content: Any feedback, inquiries, reviews, posts, or messages you share on our platform or through direct communication.
    • 1.1.6. Other Voluntary Information: Any feedback, inquiries, or information you submit through support requests.
  • Automated Collection of Information
    • 2.1. When you interact with our services, we automatically gather certain information to enhance user experience and optimize our services. This information include but are not limited to:
      • 2.1.1. Device and Usage Data: IP address, device type, browser type, and interaction history with our website or app.
      • 2.1.2. Usage Metrics: Pages visited, time spent on the platform, clickstreams, and user navigation. Device Information: Details about the device you use to access our platform, including device type, operating system, browser type, and version.
      • 2.1.3. Log Data: This includes IP address, access times, and activity logs (e.g., pages visited, features used, duration of stay, and interaction patterns).
      • 2.1.4. Usage and Interaction Data: Information on how you engage with our platform, such as clickstreams, navigation paths, preferences, and engagement metrics. This helps us understand usage patterns and improve user experience.
      • 2.1.5. Performance Metrics: Data related to service performance, such as load times and response times, which helps us maintain a smooth experience for users.
    • Information Collected for Recruitment and Screening Purposes
      • 3.1. For the purpose of providing our recruitment support services, we collect and process recorded sessions, transcriptions, and summaries to provide recruitment support, including automated interview summaries, screening insights, and data organization.
      • 3.2. Recorded Sessions: Interactions between recruiters and candidates are securely recorded via our browser extension for accurate transcription, in compliance with data protection laws. The audio is further deleted after each recording.
      • 3.3. Transcriptions: Using advanced language processing, recorded conversations are transcribed into searchable text, treated as confidential, and used solely for recruitment purposes.
      • 3.4. Summaries: Proprietary algorithms generate structured summaries capturing key points, candidate responses, and recruiter feedback, accessible only to authorized recruiters within the platform.
    • Information from Third Parties
      • 4.1. We may receive information about you from third-party sources when you interact with external platforms or partners, including:
        • 4.1.1. Third-Party Integrations: When you log in or integrate with platforms like Google, we may access limited data per your privacy settings, such as basic profile details.
        • 4.1.2. Service Partners: We may receive data from marketing or analytics partners to understand user behaviour and improve services.
        • 4.1.3. Public Sources: Publicly available information or shared public profiles may be used for analysis, research, or verification.

5. COOKIES AND TRACKING TECHNOLOGIES

• We may use cookies and similar tracking technologies to collect and use personal data, including for interest-based advertising. Our use of cookies and tracking technologies includes:
  • 1.1. Essential Cookies: These cookies are necessary for the operation of our platform. They enable you to move around the platform and use its features.
  • 1.2. Performance and Analytics Cookies: These cookies collect information about how you use our platform, allowing us to improve its functionality and user experience. For example, these cookies help us understand which pages are visited most frequently and how users navigate the site.
  • 1.3. Functionality Cookies: These cookies allow our platform to remember your choices (such as your username, language, or the region you are in) and provide enhanced, more personalized features.
  • 1.4. Advertising Cookies: These cookies are used to deliver advertisements more relevant to you and your interests. They also help limit the number of times you see an ad and measure the effectiveness of advertising campaigns.
• You have choices regarding the use of cookies and tracking technologies, including adjusting browser settings to refuse cookies, using opt-out mechanisms from industry-wide initiatives, and setting privacy preferences for specific tracking technologies

6. WHY WE COLLECT YOUR INFORMATION

• We collect information from users to enhance our services, improve user experience, and ensure compliance with applicable laws. The purposes for data collection include but are not limited to:
  • 1.1. To Provide and Improve Services:
    • 1.1.1. We collect personal information to create and manage user accounts, verify identities, and ensure a seamless sign-in experience, enabling personalized platform access.
    • 1.1.2. For recruitment-related activities, we process recorded sessions, transcriptions, and summaries to provide automated insights, detailed transcriptions, and data organization for efficient candidate assessments.
    • 1.1.3. By analysing user preferences and interactions, we tailor features, tools, and content to enhance user experience. Additionally, we monitor device and usage data to ensure platform stability, optimize load times, and improve overall performance.
  • 1.2. To Enhance User Experience and Personalization:
    • 1.2.1. We may use activity data to deliver personalized content, including suggested articles, recruitment tools, and relevant features based on usage history and preferences. By storing user settings such as language, theme, and content choices, we ensure a consistent experience across interactions. Analysing user behaviour enables us to offer tailored recommendations and platform guidance, enhancing navigation and overall platform usability.
  • 1.3. To Communicate with you:
    • 1.3.1. We may use your contact information to provide important updates on your account, policy changes, technical issues, and security alerts. Collected data helps our support team respond to queries, troubleshoot issues, and offer personalized assistance. With your consent, we may send marketing materials, feature updates, and offers, which you can opt out of at any time.
  • 1.4. To Conduct Analytics and Understand Usage Patterns:
    • 1.4.1. We may collect data on interactions and engagement metrics to refine our offerings, improve content relevance, and enhance platform usability. Usage data provides insights into trends and patterns, allowing us to innovate and develop new features based on user interests and feedback.
  • 1.5. To Ensure Security and Prevent Fraud
    • 1.5.1. We may use collected information to detect, investigate, and prevent suspicious activity, unauthorized access, and fraud, ensuring a secure platform. Data helps assess risks, protect user information, and prevent security breaches. We implement industry-standard security measures, including encryption and monitoring, to safeguard user data.
  • 1.6. To Comply with Legal and Regulatory Requirements
    • 1.6.1. We process information to comply with legal obligations, including the GDPR, CCPA, and Australian Privacy Act 1988 (Cth). In response to lawful requests, such as subpoenas or government orders, we may be required to disclose specific user data. Additionally, we analyse user interactions with ads and promotional content to optimize marketing efforts and deliver relevant sponsored or partner material.

7. HOW WE PROCESS YOUR INFORMATION

• Your personal information is processed in strict compliance with privacy standards, including the principles of data minimization, purpose limitation, and lawful processing. Our data processing practices are as follows:
  • 1.1. Data Minimization: We collect only the information necessary to fulfil the stated purposes. For example, we collect minimal recruitment data required to provide transcriptions, summaries, and other relevant recruitment support functionalities, in compliance with privacy regulations.
  • 1.2. Purpose Limitation: Information is used exclusively for the purposes specified in this Privacy Policy. Recruitment data, for example, is processed solely for recruitment and screening purposes and is not repurposed for marketing or other unrelated activities.
  • 1.3. Legal Grounds for processing:
    • 1.3.1. Consent: For certain data collection and processing activities, such as marketing and email communication, we rely on user consent. Users can withdraw consent at any time, without impacting the lawfulness of processing based on consent before its withdrawal.
    • 1.3.2. Contractual Necessity: Some data is processed to fulfil contractual obligations, such as providing services or creating user accounts.
    • 1.3.3. Legitimate Interests: Processing of certain data, such as usage metrics and device information, is necessary for us to maintain, improve, and secure our Platform.

8. SHARING AND DISCLOSURE OF INFORMATION

• Sharing with Third Parties
  • 1.1. We may share your information with trusted third parties, such as analytics providers, payment processors, and cloud storage services, under strict confidentiality and data protection agreements.
• Legal Compliance
  • 2.1. We may disclose personal information when required by law, to comply with legal requirements, subpoenas, or court orders, or to protect user rights, property, or public safety.
• Business Transfers
  • 3.1. In the event of a merger, acquisition, or asset sale, user data may be transferred under confidentiality and security obligations, with prior user notification.
• Publicly available content
  • 4.1. If users interact with our Platform in a way that makes certain data public, this information may be accessible to other users or the general public, subject to user preferences and settings.

9. COMPLIANCE WITH DATA PROTECTION LAWS AND REGULATIONS

• We are committed to ensuring the privacy and protection of user data in accordance with applicable data protection laws and regulations. Our data processing practices reflect our dedication to compliance and our responsibility to safeguard personal information.
  • 1.1. Australian Privacy Act 1988 (Cth): We adhere to the Privacy Act and the Australian Privacy Principles (APPs), ensuring transparency, data security, and user rights regarding access and correction of personal information.
  • 1.2. General Data Protection Regulation (GDPR): For users in the European Union (EU), we comply with GDPR requirements, ensuring data protection and user rights, including access, rectification, erasure, restriction, and data portability. We process data based on lawful grounds such as consent, contractual necessity, and legitimate interest, in accordance with GDPR standards.
  • 1.3. California Consumer Privacy Act (CCPA): For users in California, we comply with the CCPA, ensuring consumer rights over personal information. Residents can request data access, deletion, and opt out of certain data sharing. We do not sell personal data to third parties.
  • 1.4. Other International Privacy Standards: In jurisdictions beyond Australia, the EU, and US, California, we adhere to applicable data protection laws and industry best practices. For international data transfers, we implement safeguards such as Standard Contractual Clauses or equivalent mechanisms to ensure high data protection standards.

10.YOUR LEGAL RIGHTS

• We respect and uphold your legal rights concerning your personal information. Depending on your jurisdiction, you may have the following rights regarding the information we collect and process:
  • 1.1. Right to Access: You can request access to your personal data, and upon identity verification, we will provide a copy along with processing details as required by law.
  • 1.2. Right to Rectification: You may request corrections or updates to inaccurate or incomplete data, subject to legal verification.
  • 1.3. Right to Erasure (Right to be Forgotten): Under certain conditions, you can request data deletion, except where retention is legally required or for legitimate business purposes.
  • 1.4. Right to Restrict Processing: You can request processing restrictions in specific cases, such as data accuracy disputes or objections based on legitimate interests.
  • 1.5. Right to Object: You may object to data processing based on legitimate interests or for direct marketing unless overriding legal grounds require continued processing.
  • 1.6. Right to Data Portability: For data collected via consent or contractual necessity, you can request its transfer in a structured, machine-readable format.
  • 1.7. Right to Withdraw Consent: If processing is based on consent, you may withdraw it anytime without affecting prior lawful processing.
• To exercise any of your rights, please contact us through the details provided at the end of this Privacy Policy. We may need to verify your identity before fulfilling requests, in compliance with legal requirements, to protect your privacy and data security.

11. DATA PROTECTION AND SECURITY

• We implement robust security measures to safeguard user information against unauthorized access, loss, alteration, or disclosure. Our security protocols include:
  • 1.1. Encrypted Data Storage: All sensitive information is encrypted using industry-standard algorithms for secure storage and transmission.
  • 1.2. Secure Serverless Infrastructure: Our serverless platform, hosted on AWS and Runpod, includes multi-layered security measures such as firewalls, access controls, and network monitoring.
  • 1.3. Access Control Measures: User data access is role-based and restricted to authorized personnel, with recruitment data available only to designated users.
  • 1.4. Regular Security Audits: Regular assessments, including vulnerability scans and penetration testing, help identify and mitigate security risks.
  • 1.5. User-Managed Privacy Settings: Users can manage privacy settings, including data retention and consent preferences, ensuring transparency and control over personal information.

12. DATA RETENTION

• We retain your data for as long as necessary to fulfil the purposes outlined in this policy, comply with legal obligations, or resolve disputes. Data that no longer serves a legitimate purpose will be securely deleted.

13. INTERNATIONAL DATA TRANSFERS

• We operate globally, and your data may be transferred to, and processed in, countries other than your country of residence. We implement appropriate safeguards, including standard contractual clauses and other measures as required by applicable law, to protect your personal information during cross-border transfers.

14. AUTOMATED DECISION-MAKING AND PROFILING

• We do not engage in automated decision-making or profiling that significantly affects users. Any profiling conducted for service improvement or analytical purposes is conducted in an anonymized manner to ensure no direct impact on individual users.

15. JURISDICTION AND DISPUTE RESOLUTION

• This Privacy Policy, and any disputes related to it or to our services, is governed by the laws of the Commonwealth, without regard to conflict of law principles.
• Jurisdiction: Any disputes related to this policy shall be subject to the exclusive jurisdiction of the ACT Magistrates Courts. By using our services, you agree to submit to these courts for dispute resolution.
• Dispute Resolution: Before taking legal action, we encourage users to contact us at support@clarifyme.ai. for prompt issue resolution.

16. ACKNOWLEDGMENT AND ACCEPTANCE OF TERMS

• By using our services, you confirm that you have read, understood, and accepted the terms of this Privacy Policy.

17. POLICY UPDATES

• We regularly review and update this policy to align with legal standards, technology, and service changes. Significant modifications will be communicated to users to ensure transparency and informed decision-making.

CONTACT US:

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

• Email: support@clarifyme.ai.