Effective date: 9 July 2025

1. Who We Are

Celper AI is a recruitment software-as-a‑service platform operated by Vizionieriai, MB (Company code 307193245), Kaštonų g. 20, LT‑30112 Ignalina, Lithuania (“we”, “our”, “us”). We are committed to protecting your privacy and processing personal data in accordance with Regulation (EU) 2016/679 (GDPR) and other applicable data‑protection laws.

2. Personal Data We Collect

• Recruiter account data — name, business e‑mail, phone, company, login credentials, subscription details.
• Candidate data — CV/résumé information, application responses, interview recordings (stored for 30 days), assessment scores, recruiter notes.
• Analytics & usage data — IP address, device/browser info, pages viewed, clicks, session duration, and cookie identifiers (via Google Analytics & PostHog).
• Support communications — e‑mails, chat transcripts, call recordings (stored for 30 days) with our support team.

3. Purposes and Legal Bases

We process personal data for the purposes and under the GDPR legal bases listed below:

Purpose	Categories	Legal Basis
Provide and secure the Service	Recruiter account data, Candidate data	Art. 6(1)(b) Contract performance
AI‑driven recommendations for recruiters	Candidate data	Art. 6(1)(f) Legitimate interest in efficient recruitment (no fully automated decisions)
Analytics and product improvement	Analytics & usage data	Art. 6(1)(f) Legitimate interest; cookies subject to consent where required
Marketing e‑mails to recruiters	Recruiter account data	Art. 6(1)(a) Consent (checkbox at sign‑up) or Art. 6(1)(f) Soft opt‑in for existing customers
Customer support	Support communications	Art. 6(1)(b) Contract performance

4. Who is the Data Controller?

• For candidate data, the recruiter using Celper AI is the data controller and Vizionieriai, MB acts as a data processor under a separate Data Processing Agreement (Art. 28 GDPR).
  • For recruiter account data, website analytics, marketing lists, and support records, Vizionieriai, MB is the data controller.

5. Sub‑Processors & International Transfers

We use the trusted service providers below. Where they are located outside the EEA, transfers are protected by the EU–US Data Privacy Framework and/or Standard Contractual Clauses (SCCs).

Vendor	Service & Location	Safeguard
Google Firebase	Hosting & authentication (Belgium/EU)	Data stays in EEA
OpenAI, LLC	AI model inference (USA)	SCCs + EU–US DPF
PostHog, Inc.	Product analytics (EU Cloud, Frankfurt)	Data stays in EEA
Google Analytics	Site analytics (USA processing)	SCCs + EU–US DPF

6. Data Retention

• Candidate profiles are retained for as long as the recruiter keeps them in the platform. Recruiters can delete them at any time; we delete them within 30 days upon recruiter request or account closure.
  • Call recordings and support call logs are stored for 30 days.
  • Recruiter account data are kept for the life of the subscription plus 2 years for tax/contractual record‑keeping.
  • Aggregated, anonymised analytics are kept indefinitely.

7. Cookies & Tracking Technologies

We use first‑party session cookies essential for login and security, and Google Analytics cookies to measure site traffic. You can manage non‑essential cookies through the cookie banner or your browser settings.

8. Automated Decision‑Making

Celper AI provides ranking and rejection recommendations to recruiters. Final hiring decisions are always made by humans, so Article 22 GDPR on automated decisions does not apply.

9. How We Protect Your Data

We implement industry‑standard safeguards including TLS 1.2 encryption in transit, encryption at rest on Google Cloud, role‑based access controls, regular backups, and annual penetration tests. While we are not yet ISO 27001 certified, we follow its control framework.

10. Your Rights

You have the right to access, rectify, erase, restrict or object to processing, and to data portability. Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing. You also have the right to lodge a complaint with the Lithuanian State Data Protection Inspectorate or your local supervisory authority.

11. Contact & Data Protection Officer

If you have questions or wish to exercise your rights, contact us at:
info@celper.ai  |  +370 682 82299
Data Protection Officer: same contact details above.

12. Children

Our Service is not intended for use by anyone under 18. We do not knowingly collect children’s data.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify account owners by e‑mail at least 30 days before changes take effect.

© 2025 Vizionieriai, MB — All rights reserved.