This policy explains how Sergei Rakov Information Technology (“we”, “us”) handles personal data in HunterFlow (the “Service”) — both data about our customers (recruiters and hiring managers) and data about the candidates they contact through the Service.
1. Our role
- For our customers’ account, billing and usage data we are the controller.
- For candidate data, the recruiter who runs a search decides which candidates to contact and why. We store candidate profiles in our own database, and the same profile information may be used when searches by more than one of our customers find the same person. If you are a candidate, you can write to us directly and we will help, or contact the recruiter who approached you.
2. Data about customers
- Account data: name, email address and password (stored only as a secure hash).
- Connected accounts: from a professional networking account you connect — your name, headline, profile identifiers and the identifiers of your connections. To pick up candidate replies, the Service regularly reads your most recent conversations in that account. Messages in conversations with candidates, including messages you send yourself outside the Service, are stored and analysed by AI (for example to notice that you have declined a candidate). Messages from people who are not candidates are not stored in our database, but may remain for a limited time in processing logs. You sign in through a secure page of our integration partner; we never receive your password.
- Recruiter profile: from your connected professional profile, AI estimates whether you recruit for your own company or for clients, and which company you work for. You can change this in your account menu.
- Content you create: job descriptions, interview scripts, messages and notes.
- Billing data: your package, minutes used, invoices and payment status. Card payments are handled by Stripe; we never see or store your full card number.
- Technical data: IP address and server logs, used for security and to determine your country so that your connected accounts are accessed from a matching region. We keep your most recent IP address and country for this. The country is looked up locally; your IP address is not sent to a third party for this.
- Cookies and analytics: one strictly necessary session cookie that keeps you signed in. We do not use advertising or analytics cookies. Our public website uses privacy-friendly analytics that do not use cookies and do not store IP addresses.
3. Data about candidates
What we may hold about a candidate:
- professional profile information visible to the recruiter on the professional networks they connect — name, headline, location, experience, education, skills and profile link;
- information from third-party professional data providers, including, for some profiles, business and personal contact details such as email addresses and phone numbers;
- messages exchanged with the candidate and their answers to screening questions;
- AI assessments such as fit scores and summaries;
- voice interview audio recordings, transcripts and interview analyses;
- contact details, if the candidate provides them.
4. How we use data
- To provide the Service (performance of our contract with the customer): finding and contacting candidates, drafting and sending messages, generating screening questions, running voice interviews and preparing summaries.
- Billing and accounting (contract and legal obligations).
- Security and abuse prevention (our legitimate interest in keeping the Service safe).
- Service emails such as email verification and alerts about your interview minutes. We do not send marketing emails without your consent.
We do not sell personal data. We do not use customer or candidate data to train our own AI models.
5. AI and automated processing
The Service uses AI models to write messages, rank candidates, generate questions, conduct voice interviews and analyse them. Some messages are sent automatically on the recruiter’s behalf. AI assessments support the recruiter; the Service does not make hiring decisions, and the recruiter reviews the results and decides.
6. Voice interviews
Before an interview starts, the candidate is told that they will speak with a virtual assistant and that the conversation is recorded. Starting the interview is voluntary. The recording, transcript and analysis are made available to the recruiter for review.
7. Who we share data with
- the recruiter who runs the job, for data about the candidates they contact;
- service providers who process data on our behalf: cloud hosting (servers in Germany, EU), payment processing (Stripe), email delivery, AI language model providers, a voice AI provider, an integration provider for connected accounts, a messaging provider and professional data providers;
- authorities, when the law requires it;
- a successor, if our business is sold or reorganised, under the same protections.
8. International transfers
Our servers are in Germany (EU). Some providers process data in other countries, including the United States. Where the law requires it, we rely on appropriate safeguards such as standard contractual clauses.
9. How long we keep data
- Account data: while your account is open. After you close it, we delete or anonymise it within 90 days.
- Candidate data, including interview recordings: while it is needed to provide the Service, or until we delete it at the candidate’s or the recruiter’s request.
- Billing records: as long as tax and accounting law requires (in the UAE, at least 5 years).
- Server logs: for a short period, for security and troubleshooting.
10. Security
Data is encrypted in transit (HTTPS), passwords are stored as secure hashes, our database is not reachable from the internet, administrative tools require authentication and access is limited to people who need it.
11. Your rights
Depending on where you live — including under the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) and, where applicable, the EU and UK GDPR — you may have the right to access, correct or delete your personal data, to restrict or object to its processing, to receive a copy of it and to withdraw consent. To use these rights, write to info@hunterflow.si. Candidates can also contact the recruiter directly; we will pass on requests that concern the recruiter’s data. We reply within 30 days. You may also complain to your data protection authority.
12. Children
The Service is not intended for anyone under 18.
13. Changes
We may update this policy. For material changes we will notify customers by email or in the Service. The date at the top shows the latest version.
14. Contact
Privacy questions: info@hunterflow.si. See also our Terms of Service.