PRIVACY POLICY

Effective Date: January 12, 2026

Version: 1.0

This Privacy Policy (hereinafter referred to as the "Policy") defines the procedure by which the Prooflooker service (hereinafter referred to as "We", "Service", "Provider") collects, uses, stores, and protects user personal data.

We take the protection of your privacy with the utmost responsibility. The processing of personal data is carried out in accordance with the requirements of the Law of Ukraine "On Personal Data Protection", as well as the General Data Protection Regulation (GDPR).

1. GENERAL PROVISIONS AND DATA CONTROLLER

1.1. The Data Controller (Owner) of personal data is:

Prooflooker Service

Registration Address: Ukraine

Email for privacy inquiries: [email protected]

1.2. By using the website https://prooflooker.com/ or the platform https://my.prooflooker.com/, you confirm that you have read this Policy and agree to its terms.

2. USER CATEGORIES AND DATA SCOPE

We collect different types of data depending on your role in the system.

2.1. Recruiters (Clients)

Individuals who register to conduct verifications.

Personal Data: Email, Full Name, Google Profile Data (when logging in via Google Auth).

Financial Data: Payment history and credit allocation. Note: We do not store full payment card details. Payment processing is handled by our partner — JSC "Universal Bank" (Monobank).

Technical Data: IP addresses, activity logs, cookies.

Purpose: Provision of access to the Service (SaaS), invoicing, client support.

Legal Basis: Performance of the Contract (Public Offer).

2.2. Candidates (Verification Subjects)

Individuals whose data is verified through the Service.

Resume (CV) Data: Full Name, contacts (email, phone), employment history, education, skills.

Files: Uploaded resume files (PDF, DOCX) and supporting documents.

Verification Results: Experience confirmation status, referee comments.

"Silent Verification": Technical tokens confirming access to corporate email.

Legal Basis:

Before the Candidate logs in: Legitimate Interest of the Recruiter (subject to the Recruiter's warranty of legal data acquisition).

From the moment the Candidate logs in: Explicit Consent. The verification process does not begin until the Candidate completes authorization and clicks the "I Agree" button.

2.3. Referees (Contact Persons)

Data: Full Name, Job Title, Work Email, feedback regarding the Candidate's performance.

Purpose: Confirmation of the Candidate's professional background.

3. ARTIFICIAL INTELLIGENCE AND AUTOMATION

3.1. AI Parsing: We use the API of OpenAI (USA) for the automated parsing of resume text. OpenAI does not use the data we transmit to train their models.

3.2. Anti-Fraud Analysis: The system automatically analyzes data for suspicious activity (IP address mismatches, temporary emails, etc.).

3.3. No Automated Decisions (GDPR Art. 22): The Service does not make automated legally significant decisions regarding the Candidate (e.g., automatic refusal of employment). All Prooflooker reports are exclusively informational/recommendatory in nature. The final hiring decision is made by a human (the Recruiter).

4. DATA STORAGE AND SUB-PROCESSORS

To ensure the operation of the Service, we engage trusted technical partners (sub-processors). Your data may be processed on the servers of the following companies:

5. SECURITY AND "SILENT VERIFICATION"

5.1. Data Protection: All traffic is encrypted (SSL/TLS). Account access is protected by One-Time Passwords (OTP), which eliminates the risk of password brute-forcing.

5.2. Cloudflare Security: The website is protected by the Cloudflare firewall, which filters malicious traffic.

5.3. "Silent Verification" Privacy: When using the corporate email confirmation feature, the Service interacts with the mail provider via a secure OAuth/SSO protocol.

Important: We only receive a technical token confirming successful authorization. We DO NOT read, store, or analyze the content of your emails, contact lists, or calendars.

6. CROSS-BORDER DATA TRANSFER

Your data is stored primarily in the EU (Germany). However, due to the use of Cloudflare, Google, and OpenAI services, some technical data and files may be transferred to the USA. We guarantee that these providers ensure an adequate level of data protection in accordance with international standards (Standard Contractual Clauses or Data Privacy Framework).

7. DATA RETENTION PERIODS

7.1. Recruiters: For the duration of the account + 3 years after the last activity.

7.2. Candidates: 1 (one) year from the moment the verification is completed. This allows the Recruiter to access report history. Files on Cloudflare servers are deleted synchronously with the deletion of the record in the database.

7.3. Incomplete Verifications: If a Candidate has not provided consent, their data is automatically deleted after 30 days.

8. USER RIGHTS

You have the right to:

Access your data.

Request correction of errors.

Request complete deletion of data ("Right to be Forgotten").

Withdraw consent for processing.

Receive a data export in a machine-readable format.

To exercise these rights, email us at: [email protected].

9. CHILDREN'S PRIVACY

The Service is intended exclusively for professional use. We knowingly do not collect or process personal data of persons under the age of 18.

10. COOKIES

We use cookies to maintain user sessions and ensure security (e.g., Cloudflare cookies to detect bots). Disabling cookies may result in the inability to log in to the system.

11. CHANGES TO THIS POLICY

We may update this Policy. The current version is always available on this page. In the event of significant changes, we will send a notification to your email address.

Contact Information:

Prooflooker Service

Email: [email protected]