Commercial Privacy Policy

Effective Date: February 10, 2026

Your Privacy Matters

At Reppls, our mission is to connect professionals around the world to help them be more productive and successful. Central to this mission is our commitment to transparency about the data we collect, how it is used, and with whom it is shared.

Scope: This Commercial Privacy Policy applies specifically to Commercial Customers (companies, recruiters, and hiring teams) and the data they process using our AI recruitment tools. This policy is distinct from our standard user policy.

1. Data We Collect

1.1 Data You Provide to Us (Customer Data)

  • Registration: To create a commercial account, you need to provide data including your business name, business email address, and billing information.
  • Candidate Data: We collect data that you upload or that candidates submit to your specific job openings via our Services. This includes names, emails, CVs/Resumes, job application responses, and interview video recordings. You (the Customer) retain ownership of this data.
  • Service Inputs: We collect data when you configure AI agents, set up interview questions, or input scoring criteria.

1.2 Data From Others

  • Candidates: We receive personal data when candidates apply to your job postings or complete AI interviews invited by you.
  • Integrations: If you integrate Reppls with your Applicant Tracking System (ATS), we receive data necessary to sync candidate profiles and statuses.

1.3 Service Use

We log usage data when you visit or use our Services, including platform technology, such as when you view candidate reports, play interview videos, or export data. We use log-ins, cookies, device information, and internet protocol ("IP") addresses to identify you and log your use.

1.4 Cookies and Similar Technologies

We use cookies and similar technologies to collect data to recognize you and your device(s) on, off, and across different services and devices.

1.5 Your Device and Location

When you visit or leave our Services, we receive the URL of both the site you came from and the one you go to. We also get information about your network and device, including IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or your mobile carrier.

1.6 Communications

We collect information about you when you send, receive, or engage with messages in connection with our Services (e.g., support tickets or email outreach to candidates initiated via the platform).

2. How We Use Your Data (Strictly Limited for Commercial Customers)

We use your data to provide, support, and secure our Services. Crucially, we separate commercial data from our general public model training.

2.1 Service Delivery

We use Customer Data solely to:

  • Conduct AI interviews and assessments on your behalf.
  • Process and rank candidates based on your specific criteria.
  • Provide you with transcripts, scores, and analytics.

2.2 NO AI Model Training on Customer Data

Reppls represents and warrants that we do NOT use your Customer Data (including candidate CVs, video interview recordings, transcripts, or assessment results) to train, fine-tune, or improve our artificial intelligence models, Large Language Models (LLMs), or algorithms for the benefit of other customers or third parties. Your data is processed in isolation to generate results only for your account.

2.3 Customer Support

We use data to investigate, respond to, and resolve complaints and Service issues at your specific request.

2.4 Security and Investigations

We use data for security, fraud prevention, and investigations. We may use your data if we think it's necessary for security purposes or to investigate possible fraud.

3. How We Share Information

3.1 Controlled Sharing & Shared Links

Unlike our standard consumer platform, Customer Data is generally treated as Confidential Information and is not visible to the public. However, the Service includes features that allow you to share data externally at your discretion:

  • Shared Links: If an Authorized User generates an expirable link to a candidate's profile, CV, or interview recording, that specific data will be accessible to anyone who possesses the link.
  • Customer Control: You control who receives these links and can set expiration parameters (if supported by the feature). We do not index these links in search engines, but we cannot control how you or your recipients share them.

3.2 Service Providers (Sub-processors)

We use trusted third-party service providers (e.g., cloud hosting, video processing) to help us provide our Services. They will have access to your information only as reasonably necessary to perform tasks on our behalf and are obligated not to disclose or use it for other purposes.

3.3 Legal Disclosures

We may need to share your data when we believe it's required by law or to help protect the rights and safety of you, us, or others.

3.4 Change in Control or Sale

We may share your data if our business is sold to others, but it must continue to be used in accordance with this Privacy Policy.

4. Your Rights and Obligations

4.1 Data Retention and Deletion

  • Retention: We retain Customer Data only as long as your account is open or as needed to provide you Services.
  • Deletion: Upon termination of your commercial agreement, Reppls will delete all Customer Data from its active production systems within 30 days, unless a longer retention period is required by law.

4.2 Data Controller vs. Processor

  • Customer (You): You act as the Data Controller for all candidate data you upload or collect. You are responsible for ensuring you have the legal basis to collect this data.
  • Reppls (Us): We act as the Data Processor. We process data only in accordance with your written instructions (this Policy and the Terms of Service).

4.3 Access and Control

You have full control to export, correct, or delete candidate data directly through the Reppls dashboard.

5. Other Important Information

5.1 Security

We implement enterprise-grade security safeguards designed to protect your data, such as HTTPS encryption in transit and AES encryption at rest. We regularly monitor our systems for possible vulnerabilities and attacks.

5.2 Cross-Border Data Transfers

We transfer, process, and store your information outside of your country of residence, to wherever we or our service providers operate. We take steps to protect your data, including using standard contractual clauses approved by the European Commission.

5.3 Lawful Bases for Processing

We will only collect and process personal data about you where we have lawful bases. For Commercial Customers, the primary basis is Contract (processing is necessary for the performance of the Commercial Terms of Service).

5.4 Direct Marketing

We do not share your commercial data or your candidates' data with third parties for their direct marketing purposes.

5.5 Contact Information

If you have questions or complaints regarding this Privacy Policy, you can contact us at:

Reppls Data Protection Officer

  • Email: maksim@reppls.com.
  • Address: 1111B S Governors Ave STE 21573 Dover, DE 19904 US

If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.