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PRIVACY POLICY

(Version 2.0)

1. Introduction & Scope

This Privacy Policy is provided in connection with the interview and candidate evaluation platform ("Platform") accessible at https://my.dream.jobs/ (the "Website").

Data Controller: dream.jobs Prep Platform, registered at Street, Praha 11000, Czechia The Data Controller determines the purposes and means of processing candidate personal data and is responsible for all hiring decisions.

Data Processor: JobMojito, operated by FreshMint ai OÜ, an Estonian entity with registered address at Sepapaja tn 6, 15551, Tallinn, Estonia. JobMojito delivers the platform technology, hosts data, and processes personal data on behalf of dream.jobs Prep Platform.

This Privacy Policy explains how personal data is processed through the Platform:

  • dream.jobs Prep Platform acts as Data Controller, determining what candidate data is collected and for what purpose.

  • JobMojito acts as Data Processor, operating the platform infrastructure and processing data on documented instructions from dream.jobs Prep Platform.

For more information about JobMojito's security practices and compliance, please visit trust.jobmojito.com.

2. Data Processing by JobMojito (Processor)

JobMojito processes candidate interview data strictly on documented instructions from dream.jobs Prep Platform.

2.1 Categories of Candidate Data Processed

Depending on dream.jobs Prep Platform's configuration, this may include:

  • Candidate name and contact details

  • CV or application materials

  • Audio and/or video interview recordings

  • Interview transcripts

  • Structured rubric-based evaluation outputs

  • Limited behavioural/speech analytics (e.g., pronunciation, cadence, sentiment)

  • System-generated score breakdown

The Platform:

  • Does not autonomously accept or reject candidates.

  • Does not make automated employment decisions.

  • Requires human review by dream.jobs Prep Platform for all hiring outcomes.

2.2 AI Usage

The Platform uses AI-assisted tools to:

  • Generate structured summaries.

  • Apply dream.jobs Prep Platform-defined rubric scoring.

  • Analyse limited behavioural or speech characteristics where enabled by dream.jobs Prep Platform.

In EU employment deployments, behavioural scoring components are disabled by default unless explicitly configured by dream.jobs Prep Platform.

2.3 No Model Training on Identifiable Candidate Data

JobMojito does not use identifiable candidate interview data for:

  • Training AI foundation models;

  • Fine-tuning shared models across customers; or

  • Independent product development purposes.

Product improvement activities rely only on aggregated and anonymised statistical insights that cannot re-identify individuals.

3. Data Controller Responsibilities

dream.jobs Prep Platform, as Data Controller, is responsible for:

  • Ensuring a lawful basis exists for processing candidate data.

  • Providing appropriate transparency to candidates.

  • Conducting Data Protection Impact Assessments (DPIAs) where required.

  • Ensuring human oversight of all hiring decisions.

  • Responding to data subject rights requests.

3.1 Website Visitors

Data collected through the Website may include:

  • IP address

  • Browser/device data

  • Usage analytics

  • Cookie identifiers

Purpose:

  • Website functionality

  • Security

  • Analytics

  • Service improvement

Legal basis:

  • Legitimate interest

  • Consent (where required for cookies)

3.2 Account Registration

Data processed may include:

  • Name

  • Business email

  • Organisation details

  • Account credentials

  • Billing information (where applicable)

Purpose:

  • Account administration

  • Service provision

  • Customer support

  • Security

  • Legal compliance

Legal basis:

  • Contract performance

  • Legitimate interest

4. Retention of Personal Data

4.1 Candidate Data

  • Candidate interview data: 12 months default (configurable by dream.jobs Prep Platform)

  • Behavioural scoring data: aligned with interview data

  • AI scoring logs: retained 12 months

  • Security & access logs: retained 12 months

  • Infrastructure logs: retained 30-90 days

Data is deleted automatically at retention expiry or upon dream.jobs Prep Platform's instruction.

4.2 Trial Accounts

  • Recruiter accounts: deleted 30 days after expiry if inactive

  • Trial interview data: deleted 30-60 days after trial expiry unless converted to paid account

4.3 Backups

Encrypted system backups operate on a rolling cycle (maximum 30 days). Deleted data is purged automatically once backup cycles expire.

5. International Data Transfers

Primary processing occurs within EU-hosted cloud infrastructure operated by JobMojito.

Where personal data is transferred outside the European Economic Area or UK:

  • Standard Contractual Clauses (SCCs) or UK Addendum are implemented where required;

  • Appropriate technical and organisational safeguards are applied.

A current list of sub-processors is available at trust.jobmojito.com.

6. Data Subject Rights

6.1 Candidate Data

Candidates should direct rights requests (access, rectification, deletion, objection) to dream.jobs Prep Platform, the Data Controller.
JobMojito supports dream.jobs Prep Platform in fulfilling such requests in accordance with the Data Processing Agreement.

6.2 Website / Account Data

Individuals may request:

  • Access to personal data

  • Rectification

  • Erasure

  • Restriction of processing

  • Data portability (where applicable)

  • Objection to processing

Requests can be made via the contact details provided on the Website.

7. Security Measures

JobMojito implements technical and organisational safeguards including:

  • Encryption in transit and at rest

  • Role-based access control

  • Tenant-level data separation

  • Secure cloud infrastructure

  • Logging and audit controls

  • Incident response procedures

Security and access logs are retained for a minimum of 12 months.

For more details, please visit trust.jobmojito.com.

8. Human Oversight & Automated Decision-Making

The Platform does not make fully automated employment decisions.
AI-generated outputs are assistive only.
Final hiring decisions are made by dream.jobs Prep Platform's recruiters.
Behavioural and speech analytics are supplementary and cannot independently determine candidate outcomes.

9. Biometric Processing (If Activated)

Biometric voiceprint identification functionality is disabled by default.

Where enabled by dream.jobs Prep Platform:

  • Processing is subject to separate contractual terms;

  • Controller lawful basis and DPIA obligations apply;

  • Biometric data is retained only for limited periods.

Biometric processing is not part of the core AI scoring system.

10. Changes to This Policy

This Privacy Policy may be updated periodically. Material changes will be communicated through appropriate channels.

Last updated on March 2025