In Brief: If you are a candidate and/or employee of the Client (i.e. an End-User) who has availed of our Services, we also process your personal data to the limited extent necessary to provide the Services required by the Client.

Purpose: We collect, store and process your personal data on behalf of our Clients (a) to provide them Services, in accordance with the agreements we have with them and subject to their instructions; (b) to improve the quality of the Service to the Clients.

Storage: All your personal data is deleted, should you not complete the sign-up process on the End-User Website.

If you complete the sign-up process, then your information is kept for the duration as specified by the Client or until your account is deleted. We may need to continue storing some of your personal data if we are subject to a legal obligation that requires this, or for exceptional legitimate interests (for example, if you file a legal claim against us). When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize your persona data.

Legal Basis: (a) To continue performing the contract between our Client and us for the provision of the Services; (b) your valid and informed consent; and/or (c) legitimate interest.

Personal data we collect: We collect, store and process your personal data on behalf of our Clients and your potential employers. In such cases, we act as a data processor of the Client and collect and process your personal data on their behalf and in accordance with their instructions. The two categories of your personal data from and about you to provide our Services to the Client which are broadly:

a. personal data you provide voluntarily on the End-User Website (for example, your education, username and password, your activities and other information provided by you on the End-User Website);

b. personal data we may receive about you from our Clients; and/or

c. personal data (for example mouse movements, IP address, browser information, time stamps) which may be collected and processed during the use of the End-User Website.

but only after confirming that our Clients have obtained your valid and informed consent or are otherwise legally permitted or required to provide us with your personal data.

Personal data what we do not collect: When using our Services, candidates and/or employees may be asked to provide certain personal data about themselves, at the employer’s request. However, you should not be asked by our Clients (i.e. your potential employers) to provide to us are such things as –

a. protected health information;

b. financial information;

c. date of birth;

d. social security information or other government-issued identification numbers and/or other sensitive personal data.

Therefore, if you have questions or concerns about the processing of your personal data, you should contact the relevant potential employer directly or refer to their own separate privacy policies.

Functioning of the Software and use of your Personal Data: Candidates can complete a job interview through our assessments on the End-User Website, which may include information such as –

a. work history;

b. skills;

c. experience;

d. work style; and/or

e. other answers to questions, as well as submissions through various types of media, such as video and audio interviews, questionnaires, tasks, assignments, training exercises, and the like.

During all of the assessments, video and audio recordings will be made of you to gather physiological responses so that we can provide relevant information to you and/or our Client (or your employer). We may use your personal and video information in a variety of ways for operation of the experience and analytics, including:

a. To operate, maintain, enhance, and provide all of the Software and Services found in our assessments, and to personalize outcomes to your preferences and interests.

b. To support you regarding our assessments, for customer service purposes, or regarding content that you have submitted to our assessments.

c. To understand and analyze the usage outcomes, trends, interests, and preferences of our users, to improve the way our assessments work and looks, and to create new features and functionality.

As per legal basis, we may use the automatically collected personal data (for example, mouse movements, mouse clicks, IP address, browser information, time stamps) to: (a) monitor and analyze the effectiveness of the application and evaluation activities; (b) monitor aggregate usage metrics such as total number of users, pages and media and features of our assessments accessed.

Sharing of your personal data: We may disclose your personal data to the following categories of recipients:

a. to your potential employer, who is our Client;

b. to your current employer, who is our Client;

c. to our third party services providers who provide data processing services to us (for example, to provide functionality on, or help to enhance the security and features of our assessments;

d. to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary: (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights and/or (iii) to protect your vital interests or those of any other person; in connection with any proposed purchase, reorganization, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Privacy Policy; and/or

e. to any other person with your express consent to the disclosure.

For more information about how your personal data is shared with third parties, you should contact the relevant employer or refer to their own separate privacy policies.

Security: We use appropriate technical and organizational measures to protect the personal data that we collect and process about you, including data encryption, secure hard drives, secure networks, cloud storage and backup, anti-malware protection, up-to-date operating systems, and team access on a need-to-know, need-to-have basis. The measures we use are designed to provide a high level of security appropriate to the risk of processing your personal data.

Sub-processors: We only use trustworthy Sub-Processors that only process your personal data on our behalf– our current hosting provider is Amazon AWS services whose data servers are located within the European Union and comply. Further details about the Sub-Processor are provided later in this policy. However, the particular Sub-Processor may be subject to change over time.

Other Recipients: None. We do not transfer your data to any other recipients.

Third Country Transfers: None. We process your data within the European Economic Area and the European Union.

Cookies: We use necessary cookies and optional cookies on the Public Website in accordance with the Cookie Policy as available here https://neurolytics.ai/cookie-policy/. You may choose to opt-in the use of the optional cookies on the Public Website.

Your Rights: You have the right to access, to rectify, to erasure, to object, to restrict processing, to data portability, to withdraw your consent and to launch a complaint with the relevant data protection authority. If you wish to exercise your rights in regard to your personal data, you should contact your employer or prospective employer (i.e. our Client) directly since they are the data controller and we only act on their instructions.  We will assist our Client, where necessary, to respond to your request in accordance to their instructions and the terms of our agreements with them