Privacy Policy

We value your privacy and process personal data in accordance with the EU General Data Protection Regulation (GDPR). This Privacy Notice explains how we (TECH DUCK L.L.C.-FZ) collect, use, and protect your personal data when you interact with our telegram bot - @aina_hr_assistant_bot ("Service").

By using the Service and continuing the conversation, you acknowledge that you have read and accepted the terms of this Privacy Notice. Our Privacy Notice may be updated from time to time to reflect changes in our practices or legal requirements. The version applicable to you is always the one marked by the date in the "Last Updated" section.

The Service is intended for individuals aged 18 and above only. We do not knowingly collect or process personal data of individuals under the age of 18, and you must not provide or upload any personal data if you are under 18 years old.

If you are seek position at our company, we act as the Data Controller. If you are applying through our Service to a position at one of our client companies, that company is the Data Controller, and we act as a Data Processor on its behalf under the terms of our Data Processing Agreement (DPA), available at https://aina-tech.io/product/en/dpa. In certain cases, we may also act as an independent controller for specific processing (e.g. aggregate analytics to improve our Service).

Personal Data We Collect

Through the bot conversation in Telegram, we will ask you to provide personal information necessary for the recruitment process. This includes:

Full name (first name and last name)
Age/Date of birth
Desired salary (compensation expectations)
Location (your current city and country of residence)
CV/Resume Details: We may ask you to attach your CV, and we will collect the information it contains, such as your contact details (e.g. phone number, email address), educational background, work experience, skills, and any other personal data you have included in your resume
Additional Information: Any other information you voluntarily provide during the Telegram chat interview (e.g. answers to questions about your qualifications or availability)

Please do not include sensitive personal data (such as racial or ethnic origin, political opinions, health information, etc.) in your application, as we do not intentionally collect or use such data.

Purpose and Legal Basis for Processing

We collect and use the above data solely for recruitment purposes, i.e. to evaluate your candidacy for employment, to communicate with you during the hiring process, and to make hiring decisions (or recommendations to our client, if they are the prospective employer). The legal bases under GDPR for processing your personal data are:

Legitimate Interests (GDPR Art. 6(1)(f))

It is in our legitimate interest to process your data in order to assess your qualifications and fit for the job position and manage the recruitment process. This includes reviewing your resume, asking you job-related questions via the bot, and contacting you about your application. In addition, we may process your contact details to inform you about relevant job opportunities, related career services and other marketing purposes where permitted by applicable law.

Pre-contractual Steps (GDPR Art. 6(1)(b))

In cases where you apply for a job with us, processing your data is necessary to take steps at your request prior to potentially entering into an employment contract. For example, we need to review your qualifications and conduct interviews before offering you a job.

Consent (GDPR Art. 6(1)(a))

We generally do not rely on consent for standard recruitment processing under GDPR. However, if we ever ask for optional information or to retain your data for future job openings beyond the current recruitment, we will seek your consent, and you are free to decline or withdraw that consent at any time.

Legal Obligation (GDPR Art. 6(1)(c))

In certain cases, we are legally required to process your personal data to comply with applicable laws and regulations. This may include, for example, maintaining records to demonstrate compliance with equal opportunity or anti-discrimination laws, responding to lawful requests from public authorities, or retaining certain information for tax, employment, or regulatory purposes. In such cases, we will process only the data that is strictly necessary to fulfill these legal obligations.

How We Use and Share Your Data

Your personal data is used internally. Within our company (when we are recruiting for ourselves), this means your data will be accessible only to relevant HR personnel and hiring managers who are involved in the evaluation of your application. All our staff who handle personal data are bound by confidentiality obligations.

If you are applying to a job at one of our client companies via our Service, we will transmit your answers and CV to that client, since they are the ones conducting the hiring. In that case, the client's employees will process your data in accordance with their own privacy policies (we advise you to review the hiring company's privacy notice with all details about processing).

We treat your personal information with care and do not sell or rent your data to any third parties. However, we do share data with certain third-party service providers as necessary to operate this Service. In particular:

Cloud Hosting (AWS)
Telegram (The initial collection of your data takes place through the Telegram platform. Your responses are transmitted via Telegram's servers to our bot. While we do not directly provide your data to Telegram, the very fact of communicating through the messenger means that the content of your messages temporarily passes through Telegram's infrastructure. Data processing within Telegram is governed by Telegram's own Privacy Policy, which we do not control. We recommend that you use the official Telegram application and take appropriate measures to protect your account. Once your messages are received by our bot, we store and process them in our own database in accordance with this Privacy Notice)
OpenAI (USA) – processes candidate resumes, answers and communications to generate AI-based recommendations.
Google (Gemini, USA/EU) – processes candidate responses and interview data for AI-assisted analysis.
Other relevant Processors. Processing on behalf of our Client employers is governed by our Data Processing Agreement (DPA), which forms part of the contractual terms with each Client. You can review the current version at https://aina-tech.io/product/en/dpa.

No other third parties will receive your personal data unless required by law. We would only disclose data to governmental authorities or regulators if we are legally compelled to do so (for example, for law enforcement requests or audits), in which case we would ensure such disclosure is permissible under data protection laws.

Automated Decision-Making

We may use artificial intelligence (AI) and automated tools to assist in the recruitment process, for example to organize candidate data, identify relevant skills from your CV, or generate summaries for HR review. However, we do not make hiring decisions solely on the basis of automated processing. All final decisions regarding your candidacy are made by human recruiters or hiring managers. This means you will not be subject to decisions that produce legal or similarly significant effects based only on automated processing.

Data Storage and International Transfers

We store European Economic Area (EEA) candidates' personal data on secure servers provided by AWS within the EEA.

In certain cases, candidate data may also be processed by trusted AI providers, such as OpenAI (USA) and Google Gemini (USA/EU depending on the service region). This may involve transfers of your data outside the EEA, including to the United States.

Whenever such transfers occur, we use Standard Contractual Clauses (SCCs) and other safeguards to ensure your data is protected in line with EU requirements.

Data Retention

We will retain your personal data only for as long as necessary to fulfill the purposes described above.

If your application is successful and you become employed by us (or by the client company you applied to), your personal data will be transferred into your employee file and retained for the duration of your employment (and for any additional period required by employment laws). In that case, you will be provided with an employee privacy notice outlining how your data is used in the context of employment.

Technical and Organisational Measures

We apply appropriate technical and organisational measures to protect your personal data, including secure encrypted transmission and storage, strict access controls limited to authorised HR staff, hosting on protected servers, regular monitoring and logging of system access and other measures in line with GDPR requirements.

Your Data Protection Rights (EU Candidates)

Under the GDPR, you have several important rights with regard to your personal data. These include:

Right of Access: You can request confirmation of whether we are processing your personal data and obtain a copy of the data we hold about you.
Right to Rectification: If any of your personal data is inaccurate or incomplete, you have the right to have it corrected or updated.
Right to Erasure: You have the right to request deletion of your personal data (the "right to be forgotten") in certain circumstances – for example, if the data is no longer necessary for the purposes it was collected, or if you withdraw consent and we have no other legal basis to continue processing. We will honor valid requests for erasure and also notify any processors holding the data to do the same, provided no overriding legal obligations apply.
Right to Restrict Processing: You can ask us to restrict or suspend the processing of your data (for instance, while verifying its accuracy or if you object to our processing). During the period of restriction, we will store your data securely and not use it except as allowed by you or required by law.
Right to Data Portability: You have the right to receive the personal data you provided to us in a structured, commonly used, machine-readable format, and to have that data transmitted to another controller where technically feasible, when processing is based on your consent or a contract and carried out by automated means. For example, you may request that we export the data you gave us so you can transfer it to another recruiting system.
Right to Object: You have the right to object to our processing of your personal data where we rely on legitimate interests as the legal basis (Article 21 GDPR). If you file such an objection, we will consider it and stop or adjust processing unless we have compelling legitimate grounds that override your interests or it is needed for legal claims. Note that you also have an unconditional right to object at any time if we were to process your data for any direct marketing (which we do not do in the context of recruitment).
Right not to be subject to automated decisions: As noted, we do not make hiring decisions purely by automated means. If that ever changes, you would have the right to human review of any automated decision affecting you.
Right to Withdraw Consent: In the rare cases where we process your data based on your consent (for example, you agreed to let us keep your CV for future opportunities), you have the right to withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of any processing done before the withdrawal, and it will not affect processing that is based on other lawful grounds. If you withdraw consent, we will cease the specific processing that was based on consent (and, if no other legal basis applies, we will delete your data).

To exercise any of your rights, please contact us using the information in the Contact section below. We will respond to your request as soon as possible, and in any case within the timeframe required by law (generally within one month for GDPR requests). Please note there are some exemptions and limitations to these rights under the GDPR; if any apply, we will explain this in our response.

Finally, you have the right to lodge a complaint with a data protection supervisory authority in the EU.

Contact Us

If you have any questions about this Privacy Notice or wish to exercise your rights, please contact us. You can reach us by email at main@aina-tech.com. You may also write to our EU Representative appointed under Article 27 GDPR at the following address:

Senocom Ltd
Private Limited Company (Ltd), incorporated under the laws of the Republic of Cyprus
Registration Number: HE458429
Registered Office: Germasogeia, Kapsalion 4, Floor 2, Flat/office 203, Block B, 4044 Limassol, Cyprus
Email: roman@senocom.com
Phone: +357 95554422

If you are applying through our Service to a job at another company, you may also contact that company directly, as they are the primary data controller for your application.

Company HQ Contact

TECH DUCK L.L.C.-FZ
Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.
Email: main@aina-tech.com

Retention

Data is stored until the vacancy is closed and deleted within 30 days, unless the candidate has provided explicit consent for longer storage (e.g., inclusion in a talent pool or consideration for future vacancies), or unless otherwise required by law.

AI Transparency

AINA uses AI to support recommendations and structuring of candidate data, but final hiring decisions are always made by human employers.

As part of this process, candidate data may be processed by trusted AI providers, including OpenAI and Google Gemini, solely for the purpose of generating recruitment insights.