Privacy Policy for Clients of Selectr AI

Last updated: July 11, 2025

This Privacy Policy outlines how Selectr AI ("Selectr", "we", "us", or "our") collects, uses, shares, and protects personal data in the course of providing services to our clients — recruiters, employers, or hiring managers ("you", "your").

By accessing or using our services, you acknowledge and agree to the practices described in this Privacy Policy.

1. Scope

This Privacy Policy applies to personal data we process in relation to:

• Client representatives (e.g., users creating and managing recruiter accounts);
• Communications and interactions between Selectr AI and clients;
• Usage data collected during interaction with our platform;
• Candidate data processed and shared with you via our services.

It does not apply to how you, as an independent data controller, handle candidate data after receipt (see section 5).

2. Who Is the Data Controller?

Selectr AI acts as:

• The data controller for personal data related to client users (e.g., recruiter email, login, IP address);
• The data controller for candidate data before it is shared with you;
• After the candidate data is shared with you, you become an independent data controller of that data.

Both parties assume responsibility for their own compliance with applicable data protection laws, including the GDPR.

3. What Data We Collect

We may collect and process the following personal data related to you or your organization:

a. Client Representative Information

• Full name, job title, and role
• Company name and address
• Business email address and phone number
• Account credentials (if applicable)
• Billing and invoicing information

b. Platform Usage Data

• IP address, browser type, device info
• Login times, pages visited, and interaction logs
• Support queries and communications

c. Candidate Data Accessed by You

We track when and how you access candidate profiles (for audit and compliance purposes only — we do not monitor your evaluation decisions).

4. How We Use Your Data

We use your personal data for the following purposes:

• To create and manage your client account
• To provide technical support and service updates
• To process transactions and manage billing
• To ensure compliance with our Terms of Use and data protection obligations
• To monitor service performance and prevent misuse

We do not use your data for marketing without your explicit consent.

5. Your Role as an Independent Data Controller

When you receive candidate data via Selectr AI, you become an independent data controller with regard to that data. This means:

• You must determine your own lawful basis for processing the data;
• You are responsible for honoring data subject rights under GDPR (e.g., access, erasure, objection);
• You must store and use candidate data lawfully and securely;
• Selectr AI does not monitor your use of candidate data and assumes no liability for downstream processing.

We can provide a Controller-to-Controller Agreement upon request.

6. Lawful Bases for Processing

We process your data under the following lawful bases:

• Contractual necessity – to provide the services you requested;
• Legitimate interests – to ensure security, prevent fraud, and improve service quality;
• Legal obligation – where required by law (e.g., tax, accounting);
• Consent – where legally required (e.g., optional communications).

7. Data Sharing

We may share your data:

• With third-party service providers (e.g., hosting, analytics, payment processors) under strict data processing agreements;
• With legal authorities if required by law;
• Within Selectr’s corporate structure, for operational purposes.

We do not sell or rent your personal data.

8. International Transfers

Your data may be processed outside the EEA. Where applicable, we use:

• European Commission–approved Standard Contractual Clauses (SCCs);
• Other lawful mechanisms to ensure adequate protection.

9. Data Retention

We retain client data for as long as necessary to:

• Provide services;
• Fulfill legal obligations (e.g., tax or audit requirements);
• Resolve disputes and enforce our agreements.

Inactive or terminated accounts are deleted or anonymized after a reasonable period.

10. Data Security

We apply appropriate technical and organizational measures to protect your personal data, including:

• Secure storage and access control;
• Encryption where applicable;
• Regular monitoring and security audits.

11. Your Rights (Under GDPR)

You have the right to:

• Access your data;
• Correct inaccurate or outdated information;
• Request deletion of your data (where legally possible);
• Restrict or object to certain types of processing;
• Receive a copy of your data in portable format;
• File a complaint with a supervisory authority.

To exercise these rights, email us at: gdpr@getselectr.com

12. Changes to This Privacy Policy

We may revise this Privacy Policy from time to time. The most current version will always be available on our website. Material changes will be communicated to registered clients via email.

13. Contact Us

If you have questions, requests, or would like to obtain a copy of our standard data sharing terms:

• Email: legal@getselectr.com