Privacy Policy

Processing of Personal Data in the Recruitment System
Updated: September 22, 2025

1. General Provisions

This Privacy Policy ("Policy") describes how we collect, use, disclose, and safeguard personal information of users of the recruitment system ("System") in accordance with applicable U.S. federal and state privacy laws, including the California Consumer Privacy Act (CCPA), Virginia Consumer Data Protection Act (VCDPA), and other applicable regulations.

By using the System, you acknowledge that you have read and understood this Policy. Your use of the System constitutes acceptance of our data practices as described herein.

Note: If you are a California resident, please see Section 16 for additional information about your rights under the California Consumer Privacy Act (CCPA).

2. Data Controller

The data controller and service provider is SofiHR LLC, a Delaware limited liability company.

Contact Information:

  • Email: info@sofihr.com

    For privacy inquiries and data subject requests

  • Mailing Address

    Available upon request for official correspondence

Personal data is processed and stored in secure facilities within the United States and may be transferred to third-party processors as described in this Policy. We take appropriate measures to ensure the security and confidentiality of your data during storage and transmission.

3. Purposes of Personal Data Processing

Your personal data is processed exclusively for the following purposes:

  • Recruitment for Vacant Positions

    Assessment of candidate's compliance with vacancy requirements

  • Conducting Interviews and Testing

    Assessment of professional skills and competencies

  • Building Candidate Database

    Storing information for future vacancies

  • Providing Feedback

    Informing about assessment results

4. Categories of Personal Data Processed

The System processes the following categories of personal data:

  • Identification Data

    Full name, date of birth, contact information (phone, email)

  • Professional Data

    Education, work experience, skills, test results

  • Streaming Data

    Video and audio recordings of interviews (with your consent)

  • Technical Data

    IP address, device information, cookies

5. Legal Basis for Processing

We collect and process personal information based on the following legal grounds:

  • Consent

    Where you have provided explicit consent to process your personal information for specific purposes

  • Contract Performance

    Where processing is necessary to provide services requested by you or by our HR clients

  • Legitimate Business Interests

    Where processing is necessary for our legitimate business interests, such as fraud prevention, system security, and service improvement (balanced against your privacy rights)

  • Legal Compliance

    Where processing is necessary to comply with applicable federal, state, or local laws and regulations

Note: You may withdraw your consent at any time by contacting us at info@sofihr.com. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

6. Personal Data Retention Periods

We store your personal data only for the time necessary to achieve the processing purposes specified in this Policy.

Specific Retention Periods:
  • Candidate Personal Data

    Up to 12 months after completion of the recruitment process

  • Video and Audio Interview Recordings

    No more than 60 calendar days from the interview completion date

  • Analysis and Assessment Results

    Up to 12 months after completion of the recruitment process

  • Data Processing Consents

    Stored during the data processing period + 3 years

After the specified periods, all personal data is subject to automatic deletion or anonymization.

7. Processing of Video and Audio Data

During interviews, the System may record video and audio of candidates with their explicit consent. This data is used for interview assessment purposes only and is NOT used for biometric identification, facial recognition, or voice pattern creation.

Purposes of Video and Audio Data Processing:
  • Interview Content Analysis

    Transcription and evaluation of candidate responses to interview questions

  • Hiring Decision Support

    Providing HR managers with comprehensive candidate assessments

  • Quality Assurance

    Ensuring fair and consistent evaluation processes

Important Notice: Video and audio recordings are used exclusively for recruitment purposes. We do not sell or share this data for marketing purposes. Recordings may be shared with third-party service providers for transcription services under strict confidentiality agreements. All recordings are automatically deleted after 60 days or upon your request, whichever comes first.

Your Rights: You may request deletion of your video/audio recordings at any time by contacting info@sofihr.com. Please note that deletion of recordings may affect our ability to process your application.

8. Your Privacy Rights

Subject to applicable law, you have the following rights regarding your personal information:

  • Right to Know

    Request information about the categories and specific pieces of personal information we have collected, used, disclosed, or sold

  • Right to Access

    Obtain a copy of your personal information in a portable and readily usable format

  • Right to Correction

    Request correction of inaccurate or incomplete personal information

  • Right to Deletion

    Request deletion of your personal information, subject to certain exceptions

  • Right to Opt-Out

    Opt out of the sale or sharing of your personal information (Note: We do not sell personal information)

  • Right to Non-Discrimination

    Exercise your privacy rights without receiving discriminatory treatment

  • Right to Withdraw Consent

    Withdraw your consent to data processing at any time (where processing is based on consent)

How to Exercise Your Rights: To exercise any of these rights, please contact us at info@sofihr.com. We will respond to your request within 45 days (or as otherwise required by applicable law). We may need to verify your identity before processing your request.

Authorized Agents: You may designate an authorized agent to make requests on your behalf. To designate an authorized agent, please provide written authorization or a power of attorney.

9. SofiHR as a Platform Aggregator

Important to understand: SofiHR is a platform aggregator providing recruitment services for HR professionals and organizations.

Types of HR Clients:
  • HR Professionals (Individuals)

    Individual platform users

  • Organizations (Legal Entities)

    Corporate platform clients

  • HR Professionals in Organizations

    Mixed type with organization affiliation

How the Platform Works:
  • HR Clients Post Vacancies

    On their own behalf or on behalf of organizations

  • Candidates Undergo Interviews

    On the platform using our technologies

  • Results are Transferred to HR Clients

    For making hiring decisions

Information: After transferring data to HR clients, we do not control how they process your data. Contact HR clients to exercise your rights regarding data stored by them.

10. Personal Data Protection Measures

The following measures are applied to protect your personal data:

  • Data Encryption

    Protection during transmission and storage

  • Access Control

    Restriction of access to personal data to authorized persons only

  • Security Monitoring

    Constant system security control

  • Regular Updates

    Security system updates

11. Transfer of Personal Data to Third Parties

Your personal data is NOT transferred to third parties, except in the following cases:

  • With Your Explicit Consent

    Only with written consent

  • As Required by Law

    In cases provided by applicable legislation

  • For Rights and Security Protection

    In case of security threats or rights violations

11.1. Service Providers and Data Processors

We may engage third-party service providers to assist with audio/video transcription, data storage, payment processing, and other business functions. These service providers are contractually obligated to:

  • Process Data Only as Directed

    Follow our specific instructions and not use your data for their own purposes

  • Implement Security Measures

    Maintain appropriate technical and organizational security safeguards

  • Comply with Privacy Laws

    Adhere to applicable U.S. federal and state privacy regulations

  • Data Retention Limits

    Delete or return data when services are completed or upon our request

Third-Party Services: We may use cloud-based transcription services (e.g., AWS Transcribe, Google Cloud Speech-to-Text) and secure cloud storage providers (e.g., AWS S3, Google Cloud Storage). All service providers are carefully vetted and bound by strict data processing agreements.

12. Cookies and Analytics

The System uses cookies for:

  • User Authorization

    Saving session and settings

  • Usage Analytics

    Improving system performance

  • Security

    Protection against fraudulent activities

Important: You can disable cookies in your browser settings, but this may affect system functionality.
13. Changes to Privacy Policy

We reserve the right to make changes to this Policy. When making significant changes:

  • User Notification

    Email notification about changes

  • Date Update

    Indication of new effective date

  • Right to Withdraw Consent

    Right to withdraw consent if disagreeing with changes

14. Contact Information

For all questions related to this Privacy Policy or to exercise your privacy rights, please contact us:

  • Email: info@sofihr.com

    Privacy inquiries and data subject requests

  • Support Service

    Available through the feedback form in the System

We will respond to your inquiries within 45 days of receipt (or as otherwise required by applicable law).

15. Governing Law and Dispute Resolution

This Privacy Policy is governed by and construed in accordance with the laws of the State of Delaware, United States, without regard to its conflict of law provisions.

Any disputes arising out of or relating to this Policy shall be resolved in the state or federal courts located in Delaware, and you consent to the jurisdiction of such courts.

By using the System, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.

16. Additional Rights for California Residents (CCPA)

If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with additional rights regarding your personal information:

Categories of Personal Information Collected:
  • Identifiers

    Name, email address, phone number, IP address

  • Professional/Employment Information

    Resume, work history, education, skills, interview responses

  • Audio/Visual Information

    Video and audio recordings of interviews

  • Internet/Network Activity

    Device information, browsing activity, interaction with our System

Your CCPA Rights:
  • Right to Know

    Request disclosure of categories and specific pieces of personal information we collect, use, disclose, or sell

  • Right to Delete

    Request deletion of personal information we have collected from you, subject to certain exceptions

  • Right to Opt-Out of Sale

    We do not sell your personal information to third parties

  • Right to Non-Discrimination

    We will not discriminate against you for exercising your CCPA rights

Important Notice: We do NOT sell your personal information. We do NOT share your personal information for cross-context behavioral advertising. In the preceding 12 months, we have disclosed personal information to service providers for business purposes as described in Section 11.1.

To exercise your CCPA rights, please contact us at info@sofihr.com. We will verify your identity before processing your request and respond within 45 days.

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Important Notice: This Privacy Policy complies with applicable U.S. federal and state privacy laws, including CCPA, VCDPA, and other state privacy regulations. If you have questions, concerns, or wish to exercise your privacy rights, please contact us at info@sofihr.com.