Vacadoo Privacy and Personal Data Processing Policy

This Policy sets out how personal data is processed when you use the Vacadoo service, including the website and the Telegram bot (the “Service”).

The Operator (the data controller) is the person who operates the Service; contact details are provided in Section 13 of this Policy.

By using the Service, the User confirms that they have read this Policy and the Public Offer. Where processing requires separate consent, the Service requests it separately.

1. What data is processed

Depending on the features used, the Operator may process the following data:

1. Telegram data: Telegram ID, username, display name, interface language, and other information that Telegram passes to the bot under its own rules.

2. Resume: the PDF file, the resume text, and the information it contains, including name, contact details, work experience, education, skills, professional interests, and any other information the User has voluntarily included.

3. Profile: structured information derived from the User’s resume and settings, as well as a machine representation of the Profile used for matching against vacancies.

4. Preferences and settings: desired positions, seniority level, work format, regions, languages, and other criteria selected by the User.

5. Service interaction data: commands and features used, ratings and actions taken on vacancies, support requests, and the fact of following links to vacancies. For a link click, the vacancy identifier, the date and time of the click, and the associated Telegram ID may be recorded.

6. Purchase data: the selected feature, amount, currency, date, payment status, transaction identifier, and other information needed to confirm payment and grant access. The Operator does not receive or store full bank card details.

7. Generated documents and requests: the vacancy text and other information provided by the User for creating a tailored resume, as well as technical data about the fulfilment of the request.

8. Correspondence: messages and materials the User sends to support or through feedback features.

2. Sources of data

The Operator receives data:

• directly from the User;
• from Telegram when the User interacts with the bot;
• from payment platforms when a payment is made;
• automatically when the User uses the Service’s features;
• from publicly available vacancy sources — only with respect to information about vacancies and employers, and not to enrich the User’s resume with hidden personal data.

3. Purposes of processing

Data is processed for the following purposes:

• creating and maintaining the Profile;
• analysing the resume;
• matching the Profile against vacancies;
• creating and sending the daily Digest;
• creating a tailored resume at the User’s request;
• accounting for trial and paid access;
• accepting and confirming payments;
• supporting Users and handling requests;
• detecting resume-processing errors and improving the quality of the Service;
• recording clicks on vacancy links, evaluating the usefulness of results, and improving matching;
• protecting the Service and preventing fraud and abuse;
• complying with legal requirements and protecting the Operator’s legitimate rights.

4. Legal bases

Depending on the applicable law and the purpose of processing, the Operator processes data:

• to perform the Offer and provide the features requested by the User;
• on the basis of the User’s consent, where such consent is required;
• to comply with obligations established by law;
• for the Operator’s legitimate interests, including ensuring security, preventing abuse, providing support, and improving the quality of the Service, provided such interests are not overridden by the User’s rights.

Withdrawing consent does not affect the lawfulness of processing carried out before its withdrawal. If the processing of certain data is necessary for the operation of the Service, deleting that data or withdrawing consent ends the provision of the corresponding features.

5. Automated processing and artificial intelligence

5.1. The Service uses automated tools and artificial intelligence technologies to analyse resumes, build the Profile, match vacancies, and create documents.

5.2. The results of automated processing are advisory in nature, do not constitute an employer’s decision, and do not create legal consequences for the User.

5.3. To perform certain operations, data may be transferred to providers of artificial intelligence technologies acting on the Operator’s instructions and only to the extent necessary to provide the corresponding feature.

5.4. The Operator does not use Users’ resumes, Profiles, or other data to train its own or third-party artificial intelligence models.

6. Who data may be shared with

To the extent necessary for the operation of the Service, data may be shared with:

• Telegram — to run the bot and deliver messages;
• payment platforms — to accept payments, confirm transactions, and process refunds where they are mandatory;
• providers of artificial intelligence technologies — to analyse text and create documents;
• infrastructure and technical support providers — to keep the Service running and secure;
• professional advisers — where necessary to protect the Operator’s legitimate rights;
• state authorities, courts, and other authorised parties — where disclosure is required by law.

The Operator does not sell personal data, does not rent it out, and does not share it with third parties for their own advertising.

Some recipients may be located outside the User’s or the Operator’s country. In such cases, the transfer is carried out in compliance with the requirements of applicable law.

7. Retention periods

7.1. The original PDF file or resume text is stored for 7 calendar days from upload, unless the User requests its earlier deletion. This period is used to detect and correct processing errors and to handle User requests. After 7 days, the original resume is deleted automatically.

7.2. The Profile, Telegram ID, settings, and related Service interaction data are stored for as long as they are needed to provide the Service, or until deleted by the User.

7.3. A document created at the User’s request is stored for as long as the Profile exists and is deleted together with the Profile.

7.4. The User can delete the Profile and related data using the deletion command available in the Telegram bot or by sending a request to support@vacadoo.cv.

7.5. After deletion, only the minimum information may be retained that is necessary to:

• comply with mandatory legal requirements;
• confirm payments and handle claims;
• prevent repeated use of trial access and other abuse;
• protect the Operator’s rights in connection with a dispute.

Such information is stored no longer than the corresponding purpose or the law requires.

8. Special categories of data

8.1. The Service does not request information about health, religious or political beliefs, biometric data, or other special categories of data.

8.2. The User is advised not to include such information in their resume or requests unless it is needed for their job search.

8.3. If the User voluntarily includes such information in their resume, it is processed only as part of the submitted material and to fulfil the User’s request, where a legal basis exists.

9. User rights

To the extent provided by applicable law, the User has the right to:

• obtain information about the processing of their data;
• access their data and receive a copy of it;
• request the correction of inaccurate or incomplete data;
• request the deletion of their data;
• withdraw consent;
• restrict processing or object to it;
• receive their data in a portable format, where such a right applies;
• lodge a complaint with the competent data protection authority.

To exercise these rights, the User can use the Telegram bot’s features or send a request to support@vacadoo.cv. The Operator may request information necessary to verify the identity of the requester and to protect the data from unauthorised access.

10. Security

The Operator takes reasonable legal, organisational, and technical measures to protect data from unauthorised access, alteration, disclosure, loss, and destruction. No method of data processing can guarantee absolute security.

11. Website, cookies, and the payment page

11.1. The Service’s account area (app.vacadoo.cv) uses session cookies to authenticate the User and its own first-party cookies for the Service’s product analytics. These cookies are not used for advertising tracking and are not shared with third parties. Beyond that, the website does not use cookies or similar technologies to track visitors, but it may collect anonymised visit and click statistics for the Service’s own product analytics.

11.2. The website contains information about the Service and may be used to proceed to payment via a link generated by the Service (in the Telegram bot or the account area).

11.3. The payment platform may process data independently in accordance with its own privacy policy. The Operator does not control the processing that the payment platform carries out for its own mandatory purposes.

11.4. If cookies, analytics, or other tracking technologies are introduced on the website, this Policy will be updated, and consent will be requested where required by law.

12. Changes to this Policy

12.1. The Operator may amend this Policy. A new version is published on the Service’s website and takes effect on the date specified in it.

12.2. If a change requires the User’s new consent, the Service will request it separately.

13. Contacts

Data controller: Individual Entrepreneur Sviatoslav Azizov (sole proprietor), IIN 931004050223, Republic of Kazakhstan.

Privacy contact: support@vacadoo.cv