Last Updated: March 2025
1. INTRODUCTION
1.1 Welcome to our Privacy Policy. We are Scytale AI Ltd (“the Company”), and we take your privacy seriously. This Policy explains how we collect, use, and protect your personal data and applies to you when you apply as a candidate (“you”) through our recruiting platform, Comeet. It also outlines your rights regarding your personal data and how to exercise them.
1.2 We may have an additional privacy notice(s) explaining our own specific privacy practices related to your personal data (“Company Notice”).
1.3 Please note that this Notice is provided only for transparency purposes. If you have any questions related to your personal data, you should contact the Company directly.
1.4 We are the party responsible for the candidates’ personal data when it is provided to the Platform in the context of your candidacy. We determine the means and purposes for the processing of your personal data.
2. PERSONAL DATA PROCESSED
2.1 We receive personal data about you as a candidate for positions at the Company, such as:
2.1.1 Contact information and address;
2.1.2 Curriculum Vitae (resumé) information (including information such as skills, work experience, and education);
2.1.3 Notes submitted with the application;
2.1.4 URL of your LinkedIn and other online profiles;
2.1.5 The position for which you have been or are being considered;
2.1.6 The source who submitted your candidacy (e.g., recruiting agency, referral);
2.1.7 Email correspondences between you, the Company and between the Company and other sources (such as recruiting agency and referrals) about your candidacy;
2.1.8 Information from references and events in the lifecycle of your candidacy;
2.1.9 Your responses to questionnaires sent to you by us;
2.1.10 Information about your candidacy and employment options (such as availability to be hired and salary expectations);
2.1.11 Evaluations of your candidacy; and
2.1.12 Internal discussions within the Company about your candidacy and materials you or other parties (such as evaluators or background check providers) submitted in relation to your candidacy.
2.2 If you submit your candidacy by email or online, then you are the main source of the personal data. Your personal data can also originate from other sources, such as your LinkedIn profile, recruitment agencies, headhunters and referrals.
3. USE OF YOUR PERSONAL DATA
3.1 We utilise the personal data we collect for various purposes, including but not limited to:
3.1.1 To evaluate and consider candidates for positions in the Company;
3.1.2 To contact you for your candidacy status and interviews; and
3.1.3 To schedule meetings and interviews.
3.2 Overall, we process personal data for various purposes, ensuring compliance with our legal obligations and respecting users’ rights to privacy.
4. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
4.1 The lawful bases we rely on for processing personal information are (if applicable to us under privacy law):
4.1.1 You gave us your consent to the processing of your personal data (for one or more specific purposes);
4.1.2 Processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
4.1.3 Processing is necessary for the purposes of the legitimate interest; or
4.1.4 Processing is necessary for compliance with a legal obligation to which the controller is subject.
5. HOW DO WE SHARE PERSONAL DATA?
5.1 We may share your personal data with service providers and vendors who help us collect, process, and store your information. This includes Comeet as our recruitment platform provider. You can find Comeet’s privacy policy here. These Companies can only use your personal data to provide their services or as we allow.
5.2 We may share personal data in accordance with our privacy policy and legal obligations as follows:
5.2.1 Personal data may be shared with our corporate parent, subsidiaries, and corporate affiliates;
5.2.2 We may share your general recruitment status with third parties who submitted your candidacy to us;
5.2.3 Where a third party (like a Company employee or recruiting agency) submits your details to us, we may share your name, photo, and basic information about your recruitment status with them;
5.2.4 If you apply to a job opening using a unique referral link that was provided to you by an employee of the Company to which you are applying, the Company may share some of your general recruitment status, without identifying you by name, with the person that provided you the referral link. The purpose of sharing the above information is to operate incentive programs (i.e. employee referral bonus programs) of the Company and to provide feedback to third parties who submit candidates to the Company regarding their submission;
5.2.5 If we are required to disclose your information by a judicial, governmental and/or regulatory authority to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order; and
5.2.6 If we sell or transfer our business, shares or assets, or if we merge, restructure, or go through bankruptcy, we may share or transfer your personal data to the relevant third party, including during negotiations.
6. DATA RETENTION AND SECURITY
6.1 Retention: We will retain your personal data for as long as we need it to assess you as a candidate or as long as we have a valid legal basis. In accordance with our internal data retention policies and practices, we can decide whether to keep your personal data, delete it or pseudonymise/anonymise it. If this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.
6.2 Security: We implement industry standard measures to reduce the risks of damage, loss, unauthorised access, or use of your personal data. However, these measures do not provide absolute information security. We require our partners with whom we share personal data to implement appropriate security measures to protect your personal data.
7. INTERNATIONAL DATA TRANSFERS
7.1 We host your personal data in connection with our use of the Comeet platform either in the European Economic Area, in the US, in the country where we are located, or in countries deemed as providing an adequate level of data protection.
7.2 Your data will be accessible in the country where we or our service providers are located, the UK, the US, and countries deemed as providing an adequate level of data protection.
7.3 See here for the Comeet’s vendors. For more information, please contact us.
8. YOUR RIGHTS
8.1 You have the right at any time to request access or to modify your personal data. To exercise your data protection rights as listed below, please contact us at privacy@scytale.ai. Note that we may ask that you verify your identity first.
8.2 Your rights include;
8.2.1 Being informed about the personal data we process about you;
8.2.2 Accessing the personal data we process about you;
8.2.3 Rectifying or updating the personal data you have provided;
8.2.4 Requesting the deletion of your personal data;
8.2.5 Opting out or objecting to certain uses of your personal data;
8.2.6 Withdrawing consent at any time;
8.2.7 Exercising the right to data portability; and
8.3 If you choose to exercise any of your rights, we will handle these requests in accordance with applicable law, but please note that the exercise of some of those rights may have some consequences in your application as a candidate.
8.4 In the context of the Comeet platform, we do not use any automated decision-making related to your personal data.
9. MINORS
9.1 We do not knowingly or intentionally collect personal data about children who are under 18 years of age. If you have reason to suspect that children’s data is being collected, you are requested to immediately report it to us. If you have questions regarding children’s personal data, contact us.
10. CHANGES TO THIS PRIVACY NOTICE
10.1 From time to time, we may change or update this Notice. If we do so, we will make efforts to notify you of such changes by any means.
11. CONTACT US
11.1 If you would like to contact us to discuss any queries or concerns about this privacy policy or our data protection practices, contact us at privacy@scytale.ai.
