Privacy Policy

Contents

1. Our Role as Data Processor
2. Collection of Personal Information
3. Candidate & Applicant Data
4. Use and Processing of Collected Information
5. AI Features and Automated Processing
6. Email and Calendar Integrations
7. Payment Processing
8. Managing Information
9. Disclosure of Information & Subprocessors
10. Retention of Information
11. Transfer of Information
12. Region Specific Notices
13. Cookies
14. Data Analytics
15. Privacy of Children
16. Do Not Sell My Personal Information
17. Information Security
18. Changes and Amendments
19. Acceptance of This Policy
20. Contacting Us

01 Our Role as Data Processor

Kabuna is an applicant tracking system ("ATS") that helps companies manage their hiring pipelines. Because of this, our role under data protection laws depends on whose data is involved:

• Customer account data (information about the recruiters and admins who sign up to use Kabuna): we act as the Data Controller.
• Candidate and applicant data (information about people whose CVs, applications, or profiles are uploaded into Kabuna by our customers): we act as the Data Processor, and the customer (the hiring company) is the Data Controller.

02 Collection of Personal Information

You can access and use the Website and Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features offered on the Website, you may be asked to provide certain Personal Information (for example, your name and email address).

We receive and store any information you knowingly provide to us when you create an account, publish content, make a purchase, or fill any forms on the Website. When required, this information may include the following:

• Account details (such as user name, unique user ID, password)
• Contact information (such as email address, phone number)
• Basic personal information (such as name, country of residence)
• Organization details (such as company name and team members you invite)
• Payment information (such as billing details, processed by our payment provider)
• Any other materials you willingly submit to us (such as job descriptions, branding assets, feedback)

Some of the information we collect is directly from you via the Website and Services. However, we may also collect Personal Information about you from other sources such as authentication providers (e.g. Google or Microsoft Sign-In) and our integration partners.

You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the features on the Website. Users who are uncertain about what information is mandatory are welcome to contact us.

03 Candidate & Applicant Data

On behalf of our customers (hiring companies), we process Personal Information about candidates and applicants. This data is collected by our customers — for example when a candidate applies via a careers page, is uploaded from a CV, imported from a spreadsheet, or sourced from a public profile. Categories of candidate data we may process on our customers' behalf include:

• Name, email address, phone number, and location
• CV / resume files and their parsed contents
• Employment history and education history
• Links to public profiles (e.g. LinkedIn)
• Application responses to questions set by the customer
• Interview notes, internal evaluations, scorecards, and feedback
• Email and calendar communications sent or received through the platform
• Activity in the candidate timeline (stage changes, decisions, comments)

We do not use candidate data for our own marketing or to train general-purpose AI models. Candidate data is processed solely to provide the Services to the hiring company that controls it.

Candidate rights: if you are a candidate and wish to exercise rights of access, correction, deletion, restriction, or portability over your data, please first contact the company you applied to. If you cannot reach them, you may also contact us at support@kabuna.io and we will assist or route your request to the relevant customer.

04 Use and Processing of Collected Information

We act as a data controller and a data processor when handling Personal Information. We act as a data controller for information about our direct users (recruiters and admins), and as a data processor under our customer's instructions for candidate data. Where a customer requires it, we enter into a separate Data Processing Agreement that supplements this Policy.

Information we collect may be used for the following purposes:

• Create and manage user accounts and organizations
• Deliver the Services (pipeline management, interview scheduling, email, reporting)
• Send administrative information
• Send product and service updates
• Respond to inquiries and offer support
• Request user feedback
• Improve user experience
• Detect, prevent, and address fraud, abuse, and security incidents
• Respond to legal requests and prevent harm
• Run and operate the Website and Services

05 AI Features and Automated Processing

Some Kabuna features use third-party large language models (for example to parse a CV, summarize a candidate profile, or draft a message). When these features are used:

• Inputs are sent to a model provider (e.g. OpenAI) under a data processing arrangement that prohibits the provider from using the data to train its general-purpose models.
• Outputs are stored only within the customer's workspace and visible only to authorized users of that workspace.
• AI suggestions are decision-support, not automated decisions. Hiring decisions are made by the customer's users.

06 Email and Calendar Integrations

Customers may optionally connect third-party email and calendar services such as Google and Microsoft to enable in-app features like sending and receiving candidate emails and scheduling interviews. When a user connects an account:

• We access only the data needed to provide the requested functionality, and only under the permissions the user granted during connection.
• We do not use data from connected accounts to develop, improve, or train any non-individualized product features.
• Users can disconnect an integration at any time from the settings page; doing so revokes our access and removes stored tokens.

Kabuna's use of information received from Google APIs adheres to Google API Services User Data Policy, including the Limited Use requirements.

07 Payment Processing

In case of Services requiring payment, you may need to provide payment account information, which will be used solely for processing payments. We use third-party payment processors ("Payment Processors") to assist us in processing your payment information securely. Card data is collected and stored by the Payment Processor, not by Kabuna.

Payment Processors adhere to the latest security standards as managed by the PCI Security Standards Council. Sensitive and private data exchange happens over a TLS-secured communication channel and is encrypted and protected with digital signatures.

Please note that the Payment Processors may collect some Personal Information from you, which allows them to process your payments. The Payment Processors' use of your Personal Information is governed by their respective privacy policies.

08 Managing Information

You are able to delete certain Personal Information we have about you. The Personal Information you can delete may change as the Website and Services change. When you delete Personal Information, however, we may maintain a copy of the unrevised Personal Information in our records for the duration necessary to comply with our obligations to our affiliates and partners.

If you would like to delete your Personal Information or permanently delete your account, you can do so on the settings page of your account on the Website or simply by contacting us at support@kabuna.io.

09 Disclosure of Information & Subprocessors

Depending on the requested Services or as necessary to complete any transaction or provide any Service you have requested, we may share your information with our contracted companies and service providers (collectively, "Service Providers" or "Subprocessors") we rely upon to assist in the operation of the Website and Services available to you, and whose privacy policies are consistent with ours or who agree to abide by our policies with respect to your information. We will not sell your information to unaffiliated third parties.

Service Providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. Categories of Service Providers we use include:

• Cloud infrastructure (Amazon Web Services)
• Transactional email delivery (Amazon Simple Email Service)
• User authentication (Amazon Cognito)
• Payment processing
• AI model providers (used for optional AI-powered features)
• Customer-enabled integrations (e.g. Google, Microsoft, LinkedIn, Slack)

We may also disclose any Personal Information we collect, use, or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

10 Retention of Information

We will retain and use your Personal Information for the period necessary to comply with our legal obligations, as long as your user account remains active, to enforce our Policy, resolve disputes, and unless a longer retention period is required or permitted by law.

Candidate data is retained for as long as the customer (hiring company) chooses to retain it. Customers may delete candidate data at any time, and have controls to delete or anonymize candidate records on request. If a customer account is terminated, customer and candidate data may be retained for up to 60 days before permanent deletion, unless the customer requests immediate deletion.

We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted.

11 Transfer of Information

Kabuna is primarily hosted on Amazon Web Services in the European region (eu-central-1, Frankfurt). Where information must be transferred outside of your region (for example to a Subprocessor located elsewhere), we rely on appropriate safeguards such as Standard Contractual Clauses and the safeguards offered by our Subprocessors.

12 Region Specific Notices

Disclosures for Residents of the USA

If you are a resident of California, Colorado, Connecticut, Delaware, Iowa, Maryland, Utah, or Virginia, you have certain rights and we aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. These rights include:

• Right to know and right to access: You have the right to request certain information we have collected about you.
• Right to correct: You have the right to request that we correct your inaccurate Personal Information.
• Right to delete: You have the right to request deletion of your Personal Information.
• Right to opt-out: You have the right to opt-out of the sale of your Personal Information. Kabuna does not sell Personal Information.
• Right to consent to or limit use: You have the right to consent to the use of your Sensitive Personal Information and to direct us to restrict its use.
• Right to non-discrimination: You have the right to not be discriminated against for exercising your rights.

To exercise any of your rights, simply contact us using the details below.

Disclosures for the EEA, UK, and Other Regions

If you reside in the European Economic Area, the United Kingdom, or a country not specifically mentioned in this policy, we are committed to protecting your personal data in accordance with the GDPR and internationally recognized privacy principles. Your rights include:

• The right to access, correct, or delete your personal data.
• The right to restrict or object to certain types of processing.
• The right to withdraw consent for data processing.
• The right to data portability, where applicable.
• The right to opt out of targeted advertising and data sales, where required by law.
• The right to file a complaint with a relevant data protection authority.

If you are a candidate, please direct these requests first to the hiring company you applied to, who is the controller of your data.

13 Cookies

Our Website and Services use "cookies" to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

We may use cookies to collect, store, and track information for security, authentication, and personalization, and for statistical purposes. Please note that you have the ability to accept or decline cookies. Most web browsers automatically accept cookies by default, but you can modify your browser settings to decline cookies if you prefer.

14 Data Analytics

Our Website and Services may use third-party analytics tools that use cookies, web beacons, or other similar information-gathering technologies to collect standard internet activity and usage information. The information gathered is used to compile statistical reports on User activity. We use the information obtained from these analytics tools to monitor the performance and improve our Website and Services. We do not use third-party analytics tools to track or collect any personally identifiable information of our Users.

15 Privacy of Children

We do not knowingly collect any Personal Information from children under the age of 16. Kabuna is a business product intended for use by hiring teams and adult job applicants. If you are under 16, please do not submit any Personal Information through the Website and Services. If you have reason to believe that a child under 16 has provided Personal Information to us through the Website and Services, please contact us to request that we delete that child's Personal Information from our Services.

16 Do Not Sell My Personal Information

Kabuna does not sell Personal Information. You have the right to choose not to have your Personal Information sold or disclosed by contacting us. Upon receiving and verifying your request, we will confirm that no such sale has taken place and will cease any disclosure that constitutes a sale under applicable law.

17 Information Security

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in our control and custody. These include:

• Encryption of data at rest (AES-256) and in transit (TLS 1.2+)
• Role-based access controls (Admin, Recruiter, Hiring Manager, Viewer)
• Logical isolation between customer organizations
• Audit logging of key actions
• Least-privilege access for our personnel

However, no data transmission over the Internet or wireless network can be guaranteed to be 100% secure.

18 Changes and Amendments

We reserve the right to modify this Policy or its terms related to the Website and Services at any time at our discretion. When we do, we will post a notification on the main page of the Website. An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified.

19 Acceptance of This Policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services and submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and Services.

20 Contacting Us

If you have any questions, concerns, or complaints regarding this Policy, the information we hold about you, or if you wish to exercise your rights, we encourage you to contact us at:

support@kabuna.io

We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws.