Informed Interview Intelligence Platform Privacy Policy

INFORMED DECISIONS LTD.

Last Updated 3/30/24

At Informed Decisions we take privacy seriously. Please read this Privacy Policy to learn how we collect, process, use and store personal information.

 If you have any questions about this Privacy Policy please contact us at info@informedecisions.io.

While we recommend that you read the entire policy, a summary of our treatment of personal data can be found in Schedule A at the end of this Privacy Policy.

This Privacy Policy (this “Policy”) describes how Informed Decisions Ltd. (“Informed Decisions”, the “Company”, “we”, “our” or “us”), may collect, store, use, process and/or share information collected by or transmitted on or to our software based interview facilitation platform (the “Platform”).

We are committed to maintaining the privacy of those who use the Platform to conduct interviews and assessments (“Interviewers”) and candidates and/or employees who are assessed and/or interviewed with the help of the Platform (“Candidates”).

This Policy explains: 

• What information we collect and why we collect it. 
• How we use that information. 
• Interviewers’ and Candidates’ rights with regard to the collection of such information. 
• Our role as a data processor of Candidates’ information 

1) Background & Application of this Privacy Policy

a. The Platform. Our Platform provides an interview platform which supports our clients in conducting interviews and assessing Candidates while at the same time providing feedback to Interviewers on their interview behaviors and techniques.

b. Applicability of this Policy to Candidates’ and Interviewers’ Personal Data. While this Policy describes our collection, use and processing of all personal data collected via the Platform, our relationship to Candidates and, in certain respects, to Interviewers, is not a direct one. With respect to Candidates, and in certain respects to Interviewers, Informed Decisions is a data processor who processes data transmitted to the Platform by Informed Decisions’ customers (each, a “Customer”) pursuant to a contractual agreement between the Customer and Informed Decisions. With respect to Candidates and, in certain respects to Interviewers, the applicable Customer is the data controller responsible for obtaining consent for the collection, use, storage and processing of personal data by Informed Decisions in accordance with the terms of this Privacy Policy. We enter into a contractual relationship with each Customer pursuant to which the Customer undertakes to gain consent from Interviewers and Candidates prior to transmitting personal data regarding Interviewers or Candidates to the Platform.

c. Modifications to this Policy. We reserve the right to revise, amend, or modify this Policy at any time by posting the modified Policy at https://informedecisions.io/informed-interview-intelligence-platform-privacy-policy/. Please review this Policy often so that you will remain updated regarding our current policies. If you are a Customer, we will notify you of any changes to the Policy that we consider to be material modifications by sending an email to the email address affiliated with your account. You hereby agree that your continued use of the Platform after we’ve posted the modified Policy at the aforementioned link or, if applicable, notified you via email of the modified Policy, indicates and constitutes your agreement to be bound by the modified Policy. If you don’t agree to be bound by the modified Policy, then you may no longer use the Platform. 

2) Personal Information We Collect & Where We Get it From

We collect personal data: (i) from Customers and Interviewers directly and manually, (ii) from Customers via integration with our Customers’ applicant tracking system, human resources management systems, and other similar software, (iii) via our transcription function when it is used by an Interviewer as part of an interview conducted using the Platform, and (iv) through automated tracking technologies. Below is a detailed list of what infromation we collect and how it is collected:

a. Peronal Data Collected Regarding Interviewers.

• Name & Contact Information: The Customer provides us with the name and contact information for Interviewers who will be using the Platform to interview and assess Candidates as well as receive feedback on the Interviewers’ own interviewing process and patterns.
• Place of Residency/Origin; Gender; Ethnicity; Veteran Status; Disability; Education; Experience: The Interviewer will be requested to provide this information on setting up the Interviewer’s account on the Platform.
• Interview Scores, Notes & Transcription: While conducting interviews, the Interviewer will be asked to input scores for the Candidate and other interview notes, and the entire interview may be recorded and transcribed on the Platform. Such inputs and transcript may contain a variety of personal data unique to each interview.
• Usage Information: The Platform will automatically collect informaton regading the Interviewer’s usage of the Platform.

b. Personal Data Collected Regarding Candidates.

• Name & Contact Information: The Customer will either provide us the name and contact information of Candidates manually or via enabling an integration between the Platform and the Customer’s Applicant Tracking System (“ATS”) or Human Capital Management System (“HCMS”)
• Place of Residency/Origin; Gender; Ethnicity; Veteran Status; Disability; Education; Experience; Academic Scotres: The Customer will either provide us the above information manually or via enabling an integration between the Platform and the Customer’s Applicant Tracking System (“ATS”) or Human Capital Management System (“HCMS”). The Customer may also request the information from the Candidate via the Platform.
• Interview Scores, Notes & Transcription: While conducting interviews, the Interviewer will be asked to input scores for the Candidate and other interview notes, and the entire interview may be recorded and transcribed on the Platform. Such inputs and transcript may contain a variety of personal data unique to each interview.

c. Automatic Information Collection & Tracking Technologies. When you use the Platform, our technology may automatically collect a variety of technical information as well as information regarding your usage of the Platform. We may either collect such information ourselves or authorize third party service providers to collect this information on our behalf utilizing their software tools integrated into the Platform. Information collected via automated tracking technologies may include: IP address, browser and device characteristics, operating system, location information and usage information regarding the way you use and interact with the Platform.

We use cookies and other similar tools to conduct web analytics, in order to optimize the Platform’ performance and functionality. Web browser settings can allow you to control the cookies stored on your hard drive. If you choose to disable cookies, you will still be able to use the Platform but certain functionalities may be limited.

3) How We Use the Personal Data We Collect

a. Use of Interviewers’ Personal Data.

• Facilitation of Interview & Assessment of Candidate: Certain information regarding the Interviewer such as the Interviewer’s identity and items included in the notes and transcription of the interview are used to facilitate the conduct, review and assessment of the interview to determine whether to hire a Candidate.
• Monitoring Interviewer Assessment Patterns: Information such as Interviewer’s Place of Residency/Origin; Gender; Ethnicity; Veteran Status; Disability; Education; Experience are compared to certain personal details regarding Candidates and used, together with Candidate scores and notes, as part of the Platform’s assessment of patterns in the way that an Interviewer conducts interviews and assesses Candidates.
• Usage Information: Data regarding the Interviewer’s usage of the Platform are used to improve the Platform.

b. Use of Candidates’ Personal Data.

• Facilitation of Interview & Assessment of Candidate: Certain information regarding the Candidate such as the Candidates identity and contact information and items included in the notes and transcription of the interview are used to facilitate the conduct, review and assessment of the interview to determine whether to hire a Candidate.
• Monitoring Interviewer Assessment Patterns: Information such as Candidates’ Place of Residency/Origin; Gender; Ethnicity; Veteran Status; Disability; Education; Experience are used, together with Candidate scores and notes are compared to certain personal details regarding the Interviewer as part of the Platform’s assessment of patterns in the way that an Interviewer conducts interviews and assesses Candidates.

c. Use of Anonymized & Aggregated Data. ‍Notwithstanding anything to the contrary in this Policy, we may use, share and sell aggregated or anonymized data either collected by us or generated from information collected by us for any purpose and without restriction including to develop, improve and commercialize products and services.

4) Who we Share Personal Data With

We understand the importance of limiting the sharing of personal data with third parties to what is reasonably necessary for providing and improving our products and services and otherwise fulfilling the purposes for which the information is collected. We may share personal data in the following circumstances:

• With Developers: Informed Decisions’ software and technology developers have access to information that is related to or useful for the development and improvement of our software, machine learning algorithms, products and services.
• Our Service Providers: We may share information with contractors, service providers and other third parties we use to support the Platform and our products, services and business operations.
• Business Transfers:We may share or transfer information in connection with, or during negotiations of, any merger, sale of Informed Decisions’ assets, financing, or acquisition of all or a portion of our business.
• Affiliates:We may share information with our affiliates. Affiliates include any parent company, subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• Comply with Applicable Law:We may share your information as required by any court order, law, legal process or government or regulatory request.
• Enforce Our Rights:We may share information as reasonably necessary to enforce our rights arising from any contract between us and the applicable Customer or Interviewer.
• Protect Our Rights:We may share or transfer information if we believe it is necessary to protect our rights.

The third parties with whom we share information pursuant to the above may be located in countries other than your own, and we may send them information we receive. We use commercially reasonable safeguards, including a variety of legal mechanisms such as contracts, to ensure your rights are protected and that your personal information remains secure and is only transferred to trustworthy third parties with privacy policies and security requirements reasonably similar to our own, and who only use such personal information for the reasons we have authorized. As an Israeli company, the primary authority supervising our activities is the Israeli Privacy Protection Authority, and you have the right to file a complaint to it or any other relevant supervisory authority. 

5) How We Protect Personal Data

a. Protective Measures. We use a combination of physical, technological, and organizational controls to protect the personal information we collect.

• We use AMAZON AWS for data processing and storage, and data is stored on secure servers.
• We retain data for the period of time that we deem necessary depending on the purposes for which it is collected and the permitted uses we make of the data. While data is retained, it is protected, when we deem it no longer necessary to be retained, we destroy the data. Notwithstanding the above, we will retain data as required by applicable law.
• When we transfer personal information to third parties, we use secure channels to transfer information and we ensure the recipients of the information are subject to confidentiality agreements that protect the information being transferred.
• All of our employees and contractors sign confidentiality agreements with us.  

b. Inherent Risk. Despite the above measures, no safeguards are guaranteed and any collection or transfer of personal data poses risks. No electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Furthermore, we cannot guarantee that third parties will abide by their confidentiality obligations or data security responsibilities.

c. Breach Protocols. As a result of the aforementioned risks, Informed Decisions has risk mitigation protocols in place, including protocols for responding to data breaches which include assessing whether it is reasonable in the circumstances to believe that a breach has created a real risk of significant harm to an individual and, if such a risk is confirmed, reporting the breach to the relevant authorities and to the affected individuals.

6) Your Rights & How to Exercise Them

Depending on where you are located geographically and where your residency is, applicable privacy law may provide you certain rights regarding your personal information beyond what is explicitly provided for in this Policy. If you have any questions about our information management practices or to exercise your rights, please contact us at info@informedecisions.io with your request and we will respond promptly.

Specifically, if you are located within the European Union (the “EU”) or the European Econnomic Area (the “EEA”) you may be afforded specific rights regarding your information. Subject to eligibility, you may have:

• The right to access– the right to request Our copies of your personal data. You may be charged a small fee for this service.
• The right to rectification– the right to request the correction of any information you believe is inaccurate or completion of any information you believe is incomplete.
• The right to erasure– the right to request the erasure of your personal data, under certain conditions.
• The right to restrict processing– the right to request that we restrict the processing of your personal data, under certain conditions.
• The right to object to processing– the right to object to the processing of your personal data, under certain conditions.
• The right to data portability– the right to request the transfer of your data to another organization, or directly to you, under certain conditions.

Generally, wirh regard to personal data collected regarding Interviewers and Candidates, Informed Descisions is a “Data Processor.” Therefore, for detailed information concerning the exercise of your rights, you should contact the applicable Customer (e.g. the company with respect to which you were a Candidate or Interviewer who participated in an interview that utilized the Platform).

Regardless of your relationship with us, should you wish to file a request regarding any of the above you may contact us at info@informedecisions.io and we will make our best efforts to facilitate your request.

SCHEDULE A

Summary of the Personal Data Informed Decision Collects & How We Use It

Candidates’ Personal Data

Interviewers’ Personal Data