Effective Date: May 6, 2026
Version: 1.1
Welcome to Talent-Ray. Your privacy is important to us, and we are committed to protecting the personal information you share with us. This Privacy Policy explains how we collect, use, and safeguard your information when you use our HR evaluation platform.
1. Data Controller
Talent Ray FZ-LLC
Premises No. HD49A, First Floor, in5 Tech, Dubai Internet City, Dubai, United Arab Emirates
Email: [email protected]
Talent Ray FZ-LLC is licensed by the Dubai Development Authority (TECOM) and is the data controller responsible for personal data processed through our HR evaluation platform.
2. Information We Collect
2.1 Registration Data
- Name and email address
- Password (stored using bcrypt encryption)
- Social login tokens (Google/Microsoft/LinkedIn) - session only
- IP address and user agent (retained for 90 days)
2.2 Assessment Data
- Test responses and answers
- AI-generated evaluation scores
- Test session data (timing, completion status)
- Anti-cheat snapshots — captured client-side only when suspicious behaviour is detected during a test, transmitted to our servers and retained for 30 days
We do not record video of you during assessments, and we do not process biometric data (facial geometry, face recognition, or similar). Snapshots are still images captured locally in your browser only when our cheat-detection logic flags suspicious behaviour, and are used solely as evidence of the integrity event.
2.3 CV/Resume Data
- Personal information (name, email, phone)
- Professional history and education
- Skills and language proficiencies
- Original resume file and AI-parsed data
3. How We Use Your Information
We use your information for:
- Providing our HR evaluation services
- Processing and scoring assessments
- Ensuring test integrity through proctoring
- Generating candidate reports for employers
- Improving our AI evaluation algorithms
- Complying with legal obligations
- Communicating service updates
4. Legal Basis for Processing
| Data Type | Legal Basis |
|---|---|
| Account data | Contract performance |
| Assessment data | Contract performance |
| International transfers | SCCs + Explicit consent |
| Security logs | Legitimate interest |
5. Data Retention
| Data Category | Retention Period |
|---|---|
| Account/Profile data | Account duration + 1 year |
| CV/Resume data | 3 years |
| Test results | 3 years |
| Anti-cheat snapshots | 30 days maximum |
| Session logs | 90 days |
| Consent records | Permanent (legal requirement) |
6. International Data Transfers
Your data may be processed by our AI service providers located outside your country:
| Provider | Location | Purpose | Safeguards |
|---|---|---|---|
| OpenAI | USA | AI evaluation | SCCs, DPA |
| Anthropic | USA | AI analysis | SCCs, DPA |
| Google AI | USA | AI analysis | SCCs, DPA |
| ElevenLabs | USA/EU | Voice synthesis | DPA |
| Stripe (planned — not yet active) | USA/Ireland | Payments | PCI-DSS, DPA |
We ensure appropriate safeguards through Standard Contractual Clauses (SCCs) and Data Processing Agreements (DPAs) with all sub-processors.
7. Data Sharing
We do not sell your personal data. We share information with:
- Employers: Assessment results and reports (the purpose of the service)
- AI Service Providers: For evaluation processing (under DPAs)
- Legal Authorities: When required by law
8. Your Rights Under GDPR
You have the right to:
- Access your personal data
- Rectify inaccurate data
- Erase your data (“right to be forgotten”)
- Restrict processing
- Data portability - receive your data in a structured format
- Object to processing
- Withdraw consent at any time
- Lodge a complaint with a supervisory authority
To exercise your rights, contact us at [email protected] or use the Privacy Settings in your account.
9. Consent Management
You can manage your consents through:
- Privacy Settings page in your account
- Direct request to [email protected]
Consent Types
- Privacy (Core): Required to use the platform
- International Transfer: Required for AI-powered features
- Analytics: Optional - no impact on core functionality
10. Data Security
We implement industry-standard security measures:
- Encryption at rest and in transit (TLS/SSL)
- bcrypt password hashing
- Role-based access control
- Audit logging
- Automatic data deletion workers
- Regular security assessments
11. Automated Decision-Making
Our platform uses AI for candidate evaluation. Important safeguards:
- AI provides recommendations, not final hiring decisions
- All final decisions are made by human recruiters
- Candidates can contest automated assessments
- Human oversight is always available
12. Cookies
We use cookies for:
- Essential: Platform functionality
- Analytics: With your consent, to improve our service
See our Cookie Policy for details.
13. Children’s Privacy
Our platform is designed for job candidates (typically adults). We do not knowingly collect data from individuals under 18 without appropriate authorization.
14. Changes to This Policy
We may update this Privacy Policy periodically. Changes will be posted on this page with an updated effective date. For significant changes, we will notify you via email.
15. Applicable Law and Cross-Border Compliance
The processing of personal data described in this Privacy Policy is primarily governed by the United Arab Emirates Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“PDPL”), as Talent Ray FZ-LLC is licensed and operating in the UAE.
In addition, where applicable, we apply the following overlays:
- EU/EEA candidates and customers: the EU General Data Protection Regulation (Regulation 2016/679, “GDPR”)
- Turkish candidates and customers: Law No. 6698 on the Protection of Personal Data (“KVKK”)
- UK candidates and customers: the UK GDPR and Data Protection Act 2018
Where these laws grant additional or stricter rights than UAE PDPL, we will apply the higher standard.
16. Contact Us
For privacy questions or to exercise your rights:
Talent Ray FZ-LLC
Premises No. HD49A, First Floor, in5 Tech, Dubai Internet City, Dubai, United Arab Emirates
Email: [email protected]
This Privacy Policy is issued in compliance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, and applies the GDPR and KVKK as overlays for EU and Turkish data subjects respectively.
