Privacy Policy
Last Updated: December 2024
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1. Overview
At Idynic, we take your privacy seriously. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI-powered career development platform.
[COMPANY LEGAL NAME - ⚖️ REVIEW REQUIRED] (“we”, “us”, or “our”) operates the Idynic platform and is the data controller responsible for your personal information.
Key Points:
- We collect professional and personal data to provide our AI services
- Your data is NOT used to train third-party AI models by default
- We use encryption and security best practices
- You have control over your data, including deletion rights
- We comply with GDPR, CCPA, and other privacy regulations
2. Information We Collect
2.1 Information You Provide Directly
When you create an account or use our Service, you may provide:
- Account Information: Name, email address, password
- Professional Information: Resume, work history, skills, education, certifications
- Career Stories: Narrative descriptions of your professional experiences, achievements, and projects
- Opportunity Information: Job descriptions, company details, application materials
- Communications: Messages sent to our support team or through the platform
- Payment Information: Billing details (processed by Stripe - we do not store full credit card numbers)
2.2 Information Collected Automatically
- Usage Data: Pages visited, features used, time spent, click patterns
- Device Information: Browser type, operating system, device identifiers, IP address
- Log Data: Server logs, error reports, API requests
- Cookies & Similar Technologies: See Section 5 for details
2.3 Information from Third-Party Sources
We may receive information from:
- Social Login Providers: If you sign in via Google, LinkedIn, etc., we receive basic profile information
- Public Sources: Publicly available professional information (LinkedIn, company websites) if you authorize us to enrich your profile
- Analytics Providers: Aggregated usage analytics from services like Google Analytics
3. How We Use Your Information
We use your personal information for the following purposes:
3.1 To Provide the Service
- Parse and analyze your resume to extract professional identity markers
- Generate AI-powered career insights and recommendations
- Match you with relevant opportunities
- Create tailored solution profiles and application materials
- Maintain and improve your identity graph
3.2 To Communicate with You
- Send service-related notifications and updates
- Respond to your inquiries and support requests
- Send administrative messages about your account
- Send marketing communications (only with your consent - you can opt out anytime)
3.3 To Improve and Develop the Service
- Analyze usage patterns to understand how features are used
- Conduct research and development for new features
- Train and improve our internal AI models (using anonymized data)
- Troubleshoot technical issues and bugs
- Conduct A/B testing and experimentation
3.4 For Security and Legal Compliance
- Detect and prevent fraud, abuse, and security incidents
- Enforce our Terms of Service
- Comply with legal obligations and law enforcement requests
- Protect our rights, property, and safety, and that of our users
3.5 Legal Basis for Processing (EU/EEA Users)
Under GDPR, we process your data based on:
- Contract Performance: To provide the Service you signed up for
- Legitimate Interests: To improve the Service, prevent fraud, and ensure security
- Consent: For marketing communications and optional data processing (you can withdraw consent anytime)
- Legal Obligation: To comply with applicable laws
4. AI Processing & Third-Party Services
⚠️ Important: AI Data Processing Disclosure
4.1 Third-Party AI Providers
We use the following third-party AI services to power our features:
- OpenAI: For natural language processing and content generation
- Anthropic (Claude): For advanced reasoning and analysis tasks
- [OTHER AI PROVIDERS - ⚖️ REVIEW REQUIRED]
4.2 AI Training Opt-Out
By default, your data is NOT used to train third-party AI models.
We have opted out of AI training with our providers wherever this option is available. This means:
- OpenAI does not use your data to improve their models (we use their zero-retention API)
- Anthropic does not train on your data
- Your professional information remains private and confidential
4.3 Our Internal AI Models
We may use anonymized, aggregated data to improve our own AI models and Service features. This means:
- All personally identifiable information is removed before use
- Data is aggregated across many users to identify patterns
- Individual users cannot be re-identified from this data
- You can opt out of this by emailing privacy@idynic.com with subject line “Opt Out of Internal Training”
4.4 Other Third-Party Services
We also use the following service providers:
- AWS (Amazon Web Services): Cloud hosting and data storage
- Stripe: Payment processing
- Google Analytics / PostHog / [ANALYTICS - ⚖️ REVIEW REQUIRED]: Usage analytics
- SendGrid / [EMAIL PROVIDER - ⚖️ REVIEW REQUIRED]: Email delivery
All third-party services are bound by data processing agreements and are required to protect your information in accordance with applicable laws.
⚖️ REVIEW REQUIRED: Verify list of all third-party processors. Ensure Data Processing Agreements (DPAs) are in place with all vendors. Confirm GDPR Standard Contractual Clauses (SCCs) for international transfers.
7. Data Security
We implement industry-standard security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction.
7.1 Technical Safeguards
- Encryption in Transit: TLS/SSL encryption for all data transmitted over the internet
- Encryption at Rest: AES-256 encryption for data stored in databases and file systems
- Access Controls: Role-based access controls (RBAC) and principle of least privilege
- Authentication: Multi-factor authentication (MFA) for sensitive operations
- Logging & Monitoring: Security event logging and anomaly detection
- Firewalls & Intrusion Detection: Network security controls and threat monitoring
7.2 Organizational Safeguards
- Employee Training: Regular security and privacy training for all staff
- Background Checks: Screening for employees with access to sensitive data
- Confidentiality Agreements: All employees sign NDAs
- Incident Response Plan: Defined procedures for security incidents and data breaches
- Regular Audits: Periodic security assessments and penetration testing
7.3 Data Breach Notification
In the event of a data breach that affects your personal information, we will:
- Notify affected users without undue delay (within 72 hours for GDPR compliance)
- Provide details about the breach and potential impact
- Describe steps we are taking to address the breach
- Recommend actions you can take to protect yourself
- Notify supervisory authorities as required by law (e.g., ICO for UK, CNIL for France)
7.4 Limitations
While we use reasonable security measures, no method of transmission or storage is 100% secure. We cannot guarantee absolute security of your information.
You are responsible for:
- Keeping your password confidential
- Not sharing your account with others
- Logging out of shared devices
- Reporting suspicious activity immediately
8. Data Retention
⚖️ REVIEW REQUIRED: Specific retention periods
We retain your personal information only as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, and resolve disputes.
8.1 Retention Periods by Data Type
Active Account Data
Retention: While your account is active
Includes: Profile information, career data, identity graph, application materials, usage history
Closed Account Data
Retention: 30 days after account closure (for recovery)
After 30 days, all personal data is permanently deleted, except as noted below
Financial Records
Retention: [X YEARS - ⚖️ REVIEW REQUIRED]
Includes: Payment history, invoices, tax records (required for legal and accounting purposes)
Legal/Compliance Records
Retention: [X YEARS - ⚖️ REVIEW REQUIRED]
Includes: Records related to legal claims, investigations, regulatory requirements
Anonymized Analytics
Retention: Indefinitely
Aggregated, anonymized data that cannot be linked back to you individually may be retained for research and improvement
Backup Copies
Retention: Up to 90 days
Backup systems may retain data for disaster recovery purposes; backups are securely deleted after 90 days
8.2 Data Deletion
When you delete your account or request data deletion:
- Your personal data is marked for deletion and removed from active systems within 30 days
- Backup copies are automatically purged within 90 days of the deletion request
- We may retain minimal information (email, user ID) in a suppression list to prevent accidental re-creation of your account
- Anonymized, aggregated data derived from your information may be retained indefinitely
⚖️ REVIEW REQUIRED: Retention periods must comply with applicable laws (GDPR, tax laws, financial regulations, statute of limitations for legal claims). Specific retention periods should be determined based on jurisdiction and business needs.
9. Your Privacy Rights
You have the following rights regarding your personal information (specific rights may vary based on your location):
Right to Access
Request a copy of the personal information we hold about you. We will provide this within 30 days in a commonly used format.
Right to Correction
Request correction of inaccurate or incomplete personal information. You can also update most information directly in your account settings.
Right to Deletion
Request deletion of your personal information, subject to certain legal exceptions (e.g., financial records we're required to retain).
Right to Data Portability
Request your data in a structured, machine-readable format (JSON, CSV) that can be transferred to another service.
Right to Object
Object to processing of your personal information based on legitimate interests or for direct marketing purposes.
Right to Restrict Processing
Request that we limit how we use your data while you contest accuracy or object to processing.
Right to Withdraw Consent
Withdraw consent for processing based on consent (e.g., marketing emails) at any time without affecting prior lawful processing.
Right to Opt-Out of Sale/Sharing
Opt-out of the “sale” or “sharing” of your personal information for targeted advertising (CCPA/CPRA). Note: We do not currently sell personal information.
How to Exercise Your Rights
To exercise any of these rights:
- Account Settings: Update most information directly in your account
- Email: Send requests to privacy@idynic.com
- Subject Line: Clearly state your request (e.g., “Data Access Request”, “Deletion Request”)
- Verification: We may ask for identity verification to prevent fraud
We will respond to your request within 30 days.
10. GDPR Rights (EU/EEA Users)
If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR) and equivalent laws.
10.1 Data Controller
[COMPANY LEGAL NAME - ⚖️ REVIEW REQUIRED] is the data controller responsible for your personal information.
10.2 Legal Basis for Processing
We process your data under the following legal bases:
- Contract (GDPR Art. 6(1)(b)): To provide the Service you signed up for
- Legitimate Interests (GDPR Art. 6(1)(f)): To improve the Service, prevent fraud, ensure security
- Consent (GDPR Art. 6(1)(a)): For marketing communications and optional features (you can withdraw consent anytime)
- Legal Obligation (GDPR Art. 6(1)(c)): To comply with tax, financial, and other legal requirements
10.3 Right to Lodge a Complaint
You have the right to lodge a complaint with your local supervisory authority if you believe we have violated GDPR:
- UK: Information Commissioner's Office (ICO) - ico.org.uk
- Ireland: Data Protection Commission (DPC) - dataprotection.ie
- Germany: Your state's Datenschutzbehörde
- Other EU countries: See EDPB member list
10.4 Data Protection Officer
⚖️ REVIEW REQUIRED: If required by GDPR, we have appointed a Data Protection Officer (DPO). You can contact our DPO at: dpo@idynic.com
Note: A DPO is required if you engage in large-scale processing of special categories of data or systematic monitoring of individuals. Determine if this applies.
11. CCPA Rights (California Users)
If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).
11.1 Your CCPA Rights
- Right to Know: Request details about the personal information we collect, use, and disclose
- Right to Access: Request a copy of your personal information
- Right to Deletion: Request deletion of your personal information
- Right to Correction: Request correction of inaccurate information (CPRA)
- Right to Opt-Out: Opt-out of sale or sharing of personal information for targeted advertising
- Right to Limit Use: Limit use of sensitive personal information (CPRA)
- Non-Discrimination: We will not discriminate against you for exercising your CCPA rights
11.2 Categories of Personal Information Collected
We collect the following categories of personal information:
- Identifiers (name, email, IP address)
- Professional information (resume, work history, skills)
- Commercial information (subscription, payment history)
- Internet activity (usage data, browsing behavior)
- Inferences drawn from the above (career interests, skill assessments, opportunity matches)
11.3 Do Not Sell or Share My Personal Information
We do not sell your personal information and have not sold personal information in the past 12 months.
Under CCPA, “sharing” includes disclosing personal information for cross-context behavioral advertising. We do not currently engage in this practice.
11.4 Exercising CCPA Rights
To exercise your CCPA rights:
- Email: privacy@idynic.com
- Subject: “CCPA Request - [Right you're exercising]”
- We will verify your identity before processing
- We will respond within 45 days (extendable by 45 days if necessary)
11.5 Authorized Agents
You may designate an authorized agent to make CCPA requests on your behalf. The agent must provide written authorization or a power of attorney.
12. Children's Privacy
⚖️ REVIEW REQUIRED: Age restrictions and COPPA compliance
Our Service is not intended for individuals under the age of [18 / 16 / 13 - ⚖️ SPECIFY].
We do not knowingly collect personal information from children under [AGE]. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at privacy@idynic.com.
If we learn that we have collected personal information from a child under [AGE] without parental consent, we will delete that information as quickly as possible.
COPPA Compliance (U.S.)
If our Service is directed to children under 13 in the United States, we comply with the Children's Online Privacy Protection Act (COPPA) by:
- Obtaining verifiable parental consent before collecting data
- Providing parents with notice of our information practices
- Allowing parents to review, delete, or refuse further collection of data
- Not conditioning participation on disclosure of more data than necessary
Current Policy: Our Service is NOT currently directed to children under 13, and we do not knowingly collect their information.
⚖️ REVIEW REQUIRED: Determine appropriate minimum age (varies by jurisdiction: 13 in U.S. under COPPA, 16 in EU under GDPR for consent, 18 for employment-related services). Implement age verification if necessary.
13. International Data Transfers
⚖️ REVIEW REQUIRED: Data transfer mechanisms
Your personal information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that are different from the laws of your country.
13.1 Where We Store Data
We primarily store and process data in:
- United States: [AWS REGIONS - ⚖️ REVIEW REQUIRED]
- Europe: [AWS EU REGIONS - ⚖️ IF APPLICABLE]
13.2 Safeguards for International Transfers (EU/EEA)
If you are in the EU/EEA and your data is transferred outside the EEA, we use the following safeguards:
- Standard Contractual Clauses (SCCs): We use EU-approved Standard Contractual Clauses with third-party processors
- Adequacy Decisions: We transfer data to countries recognized by the European Commission as providing adequate protection (e.g., UK, Switzerland, Japan)
- Data Processing Agreements: All processors sign DPAs committing to GDPR-level protection
13.3 Third-Party Processors
Our key third-party processors and their locations:
- AWS (Amazon Web Services): U.S. (covered by SCCs)
- Stripe: U.S. (covered by SCCs)
- OpenAI: U.S. (covered by SCCs)
- Anthropic: U.S. (covered by SCCs)
⚖️ REVIEW REQUIRED: Verify that all international data transfers are covered by appropriate safeguards (SCCs, adequacy decisions, or other approved mechanisms). Ensure DPAs with third-party processors include required transfer provisions. Consider impact of Schrems II decision on U.S. transfers.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we make material changes, we will notify you by:
- Updating the “Last Updated” date at the top of this page
- Sending you an email notification (to the address associated with your account)
- Displaying a prominent notice on the Service or in your account dashboard
- For significant changes affecting your rights, we may require you to affirmatively accept the new policy
We encourage you to review this Privacy Policy periodically. Your continued use of the Service after the effective date constitutes acceptance of the updated policy.
For non-material changes (typos, clarifications, additional examples), we may update this policy without notice, but the “Last Updated” date will always reflect the most recent version.
15. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
Privacy Team
Email: privacy@idynic.com
Response Time: Within 30 days
Data Protection Officer (if applicable)
Email: dpo@idynic.com
⚖️ REVIEW REQUIRED: Required if engaging in large-scale GDPR processing
Mailing Address
[COMPANY LEGAL NAME - ⚖️ REVIEW REQUIRED]
[STREET ADDRESS - ⚖️ REVIEW REQUIRED]
[CITY, STATE ZIP - ⚖️ REVIEW REQUIRED]
[COUNTRY - ⚖️ REVIEW REQUIRED]
Important: This document contains sections marked “⚖️ REVIEW REQUIRED” which must be reviewed and customized by qualified legal counsel before use. This Privacy Policy is provided as a template and should not be relied upon without professional legal review, particularly for GDPR, CCPA, and international compliance.