Rolenod

Privacy Policy (DRAFT)

Version 2026-10-17. Draft for lawyer review. Describes processing under Regulation (EU) 2016/679 (GDPR).

1. Controller and contact

Controller: [COMPANY NAME] S.R.L., CUI [CUI / VAT NUMBER], [REGISTERED ADDRESS, ROMANIA]. Contact: [CONTACT EMAIL]. Data protection officer / privacy contact: [DPO NAME / PRIVACY CONTACT — or state that no DPO is appointed].

2. Data we process

Special-category data warning. A CV may reveal information such as health, disability, ethnicity, religion, political opinion, trade-union membership or sexual orientation, or contain a photo. We do not ask for this data and do not intentionally use it. Please remove it from your CV before uploading. If you include it, you ask us to process it only to provide the Service [LAWYER: assess Art. 9 GDPR basis (explicit consent) and whether a dedicated consent/filtering is needed].

3. Purposes and legal bases

PurposeLegal basis (Art. 6 GDPR)
Providing the account and the Service (CV structuring, matching, drafts)Performance of a contract, 6(1)(b)
Sending your CV to an AI provider for processingContract, 6(1)(b); and your consent given at signup, 6(1)(a) — withdrawable [LAWYER: confirm choice of basis]
Payments, invoicing, tax and accounting recordsLegal obligation, 6(1)(c)
Security, abuse prevention, service improvement without using your CV contentLegitimate interests, 6(1)(f) [LAWYER: LIA]
Evidence of your consentsLegal obligation / legitimate interests (accountability), 6(1)(c)/(f)
Marketing emails (if ever offered)Consent, 6(1)(a) — not enabled currently

4. Human approval and automated decisions

AI is used to extract CV data, score job fit and draft text. These outputs are suggestions. Nothing is submitted to an employer without your own review and approval, and we do not take decisions about you that produce legal or similarly significant effects (Art. 22 GDPR) [LAWYER: confirm]. The Service does not guarantee any employment outcome.

5. Recipients and processors

We do not sell personal data.

6. International transfers

Some providers may process data outside the EEA (for example the LLM provider or the MoR) [PLACEHOLDER: list countries]. Where this happens we rely on [LAWYER: adequacy decision / EU–US Data Privacy Framework certification / Standard Contractual Clauses plus transfer assessment — specify per provider].

7. Retention

8. Your rights

You have the right of access, rectification, erasure, restriction, portability, objection, and to withdraw consent at any time (without affecting earlier processing). You can download your data (JSON) and delete your account using the in-product functions [UI: /settings; API: GET /api/account/export, DELETE /api/account], or write to [CONTACT EMAIL]. You may complain to the Romanian data protection authority (ANSPDCP, dataprotection.ro) or the authority in your country. [LAWYER: confirm response times and wording.]

9. Cookies and similar technologies

We use only strictly necessary cookies/storage for authentication and session security [CONFIRM by auditing the final app; list names and durations]. We do not currently use advertising or analytics cookies [CONFIRM]; if that changes we will request consent beforehand. The Merchant of Record checkout may set its own cookies, governed by its policy.

10. Security

Access to data is restricted per user in the database (row-level security), transport is encrypted, and prompt/CV content is not written to application logs [CONFIRM]. No system is perfectly secure; we will notify authorities and users of breaches as required by law.

11. Children

The Service is not intended for persons under [MINIMUM AGE].

12. Changes

We will update this policy as needed and record the version accepted by you. Current version: 2026-10-17.

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