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Privacy Policy

CVLAYER - Privacy & Personal Data Protection Policy

Data Controller

This Privacy Policy governs the collection, processing, and protection of personal data of Users and Candidates within the scope of AI-powered HR and interview services provided via https://cvlayer.com (“Platform”) by Ömer Engin ÖZ (“Company”). The Company acts as the “Data Controller” pursuant to the Law on Protection of Personal Data No. 6698 (“KVKK”).

What Personal Data Do We Collect?

Our Platform collects the following categories of data to manage digital recruitment, asynchronous/live video interviews, and CV analysis processes:

  • Identity & Contact Data: Name, surname, email address, phone number, and company information of corporate users and interview candidates.
  • Visual & Audio Data: Camera (video) and microphone (audio) recordings during interviews conducted via the video interview platform.
  • Professional & CV Data: CVs uploaded for analysis, educational background, certificates, work experience, and competency information.
  • Transaction & Digital Trace Data: IP address, browser information, login/logout logs, and cookie records.

Purposes and Legal Basis for Processing

Your personal data is processed for the following purposes based on the legal grounds set out in Articles 5 and 6 of KVKK:

  • Processing corporate memberships and managing billing operations.
  • Organizing video interview sessions and transcribing audio recordings.
  • Analyzing candidate CVs using AI algorithms and generating “Candidate Evaluation Reports”.
  • Ensuring system security and preventing fraudulent activities.

Transfer of Personal Data to Third Parties and Abroad

Your personal data (CV content, video and audio transcripts) may be transferred to:

  • Global cloud providers such as Amazon Web Services (AWS) and Cloudflare for server hosting and data storage,
  • Relevant API providers (e.g., Dyte) for video conferencing infrastructure,
  • OpenAI and similar AI service providers for NLP processing and CV analysis reports,

Data is transferred abroad with appropriate administrative and technical measures in compliance with KVKK. Corporate Users are solely responsible for obtaining explicit consent from their candidates.

Cookies and Tracking Technologies

Our Platform uses cookies to improve user experience, manage sessions, and ensure security. You may disable cookies in your browser settings at any time; however, this may prevent the Platform from functioning properly.

Data Security and Retention

The Company implements technical and administrative measures including 256-bit SSL encryption, authorization matrices, and encrypted databases. Data is retained for as long as required by the processing purpose or by applicable legal retention periods (at least 2 years for log records under Law No. 5651), after which it is securely destroyed or anonymized.

When you delete your account, your personal data (name, email, CV content, analyses, etc.) is permanently erased. We retain only an irreversible, salted one-way hash of your email address, solely to prevent repeated abuse of the sign-up (welcome) credit. This hash cannot be used to recover your identity, email, or any other data, and is used exclusively for this single purpose (fraud/abuse prevention — legitimate interest). Additionally, at the moment of deletion, anonymous usage statistics that cannot be linked to your identity in any way (e.g. how many times which features were used) may be retained for product improvement; such records do not constitute personal data.

Anonymous Salary Statistics (Opt-in Only)

In the salary negotiation guide and the free offer-check tool, and only if you give explicit consent by ticking the relevant checkbox, your job title, city, experience-range, salary/offer amount and currency are recorded fully anonymously, without any link to your identity. These records contain no name, email, user ID or IP address and cannot be traced back to you. The anonymous data is used solely to produce aggregate salary statistics (e.g. market bands per position), and no statistic is published before a sufficient sample size is reached. If you do not tick the checkbox, none of this information is stored; anonymized data does not constitute personal data.

User and Candidate Rights (KVKK Article 11)

As data subjects, you have the right to learn whether your personal data is processed, request information, request correction or deletion. You may submit your requests to [email protected]. Requests will be concluded free of charge within 30 days.