Privacy notice (draft for legal review)
Draft. Not yet approved by the employer or reviewed for GDPR, the ePrivacy Regulations or the EU AI Act. Do not rely on it until the placeholders are replaced.
Who is responsible
[Employer legal name], [address], is the data controller for applicant and prospect data processed in its sales challenge. Cnvertd (operated by [Creative IT legal name]) processes that data as a processor under a written agreement.
What we process about applicants
- Identity and contact details you give us when you register.
- Your recorded spoken introduction and mock calls, and transcripts of them.
- Your activity in the workspace: companies researched, emails sent and received, calls placed and their provider-reported outcomes, appointments booked.
- Reviewer decisions and notes about your assessment and your calls.
Automated assistance
Reviewers may use automated transcription and an automated scoring aid that summarises a call against the employer's rubric. It never grants or denies access to the challenge and never makes the hiring decision. A named person reviews and records every decision, and you may ask for a decision to be explained or corrected by contacting [contact]. Recordings and transcripts are not used to train any model.
Prospect data
Business contact details of prospective customers are processed on the basis of the employer's legitimate interest in direct marketing to businesses, subject to the employer's do-not-contact register and the contact rules configured in the platform. Prospects may object at any time and are then blocked from all further contact.
Call recording
[Recording is off / on]. Where recording is on, prospects are told at the start of the call, and recordings are kept for [retention period] for quality review only.
Retention
Applicant recordings and transcripts: [n] days after the hiring decision. Activity records: [n] months. Prospect contact history: [n] months, except do-not-contact entries which are kept indefinitely to honour them.
Where data is stored and who can see it
Data is stored on servers in Finland (EU). Applicants based outside the EEA access the platform from their location; [transfer assessment reference]. Reviewers see only their assigned candidates. Applicants never see each other's leads, notes, recordings or results.
Your rights
Access, rectification, erasure, restriction, portability and objection, and the right to complain to the Data Protection Commission. Contact [DPO or contact email].