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Work in progress — requires legal review before launch

Privacy policy

Last updated: October 13, 2026

Here you find out what data about you CareerLab processes, why, on what legal basis, who we share it with, how long we keep it and what rights you have. In short: we use your data only to help you with your career, we do not sell it, and you can download or delete it at any time.

1.Who the controller is

The data controller is [Legal name SRL], registered office at [Registered address], tax ID [RO00000000], Trade Register no. [J00/0000/2026].

Data Protection Officer (DPO): [DPO name / firm], email [dpo@domeniu.ro], postal address [DPO address].

2.What data we process

  • Account data: name, email, preferred language. Your password is stored hashed by the authentication provider; we never see it.
  • Professional profile: experience, education, skills, foreign languages, city, target role, work preferences.
  • Documents: the resumes and files you upload or create on the platform.
  • Results: answers and scores in assessments, the Employability Index and its history.
  • Applications: the jobs you apply to and messages exchanged with employers through the platform.
  • Technical data: IP address, device and browser type, security and error logs.
  • Usage data: pages visited and actions in the app, only if you accept analytics cookies.
  • Payment data: [to complete once the processor is chosen]. Card details are processed directly by the payment processor; we never see them.

Special categories of data. Information about health or disability (for example, for reasonable accommodation at work or inclusion tracks) is processed only if you choose to provide it and only with your explicit consent, asked for separately (Art. 9(2)(a) GDPR). You can withdraw consent at any time and the data is deleted. We do not process biometric data and do not use emotion recognition.

3.Why we process it and on what basis

Purposes of processing, data used and legal basis
PurposeDataLegal basis (GDPR)
Creating and managing your accountAccount dataPerformance of contract, Art. 6(1)(b)
Calculating the Index and the next stepProfile, resultsPerformance of contract, Art. 6(1)(b)
AI features (resume suggestions, match explanations, recommendations)Text you submit, profilePerformance of contract, Art. 6(1)(b)
Sending applications to employersProfile, resume, messagesPerformance of contract, at your request, Art. 6(1)(b)
Profile visibility to recruitersProfileConsent, Art. 6(1)(a)
Accommodation and inclusion tracksHealth or disability dataExplicit consent, Art. 9(2)(a)
Account and security emailsEmailPerformance of contract, Art. 6(1)(b)
Newsletter and updatesEmailConsent, Art. 6(1)(a)
Usage analytics (PostHog)Usage dataConsent, Art. 6(1)(a)
Security, abuse prevention, logsTechnical dataLegitimate interest, Art. 6(1)(f)
Error monitoring (Sentry)Technical dataLegitimate interest, Art. 6(1)(f)
Invoicing and accounting recordsBilling dataLegal obligation, Art. 6(1)(c)

4.Who we work with (processors)

We only work with providers that have signed a data processing agreement (DPA) with us. We do not sell personal data or share it for advertising.

Providers, their role and where processing happens
ProviderRoleLocation and transfer
Supabase (via Lovable Cloud)Database, authentication, file storageEU ([region, e.g. Frankfurt])
VercelApplication hostingEU, fra1 region (Frankfurt). [Check US support transfers: SCCs / DPF]
AnthropicAI models for suggestions and text analysisUSA: international transfer under Standard Contractual Clauses (SCCs) [and DPF, if applicable]. [Confirm in the DPA: data is not used to train models.]
Brevo (Sendinblue SAS, France)Sending emailsEU. [Confirm in the DPA: server location and any non-EU sub-processors, with SCCs if any]
PostHogUsage analytics, only with your consentEU (eu.i.posthog.com)
SentryError monitoring[EU / USA, to confirm]; SCCs for transfers
[Payment processor]Payments[To complete]

Employers. When you apply to a job or make your profile visible to recruiters, the employer receives the data you choose to send and becomes a separate controller for it, with its own GDPR obligations.

5.How long we keep data

  • Account and profile: for as long as your account is active.
  • After a deletion request: a 30-day grace period in which you can change your mind; then the data is permanently deleted. Backups are overwritten within [35] days at most.
  • Inactive accounts: after [24] months without activity we notify you and, if you do not return, delete the account.
  • Job applications: [12] months after the ad closes, then anonymised.
  • Security logs: [12] months.
  • Billing data: 10 years, under Accounting Law no. 82/1991.
  • Proof of consent: for as long as we need to demonstrate it, even after withdrawal.

6.Your rights

  • Right of access: find out what data we hold about you.
  • Right to rectification: correct wrong data, directly from your profile.
  • Right to erasure: delete your account from Settings → Data.
  • Right to restriction: ask us to pause processing temporarily.
  • Right to data portability: download your data in a structured format, from Settings → Data.
  • Right to object: object to processing based on legitimate interest.
  • Right to withdraw consent at any time, as easily as you gave it.
  • Right not to be subject to a decision based solely on automated processing.

For any request, write to [dpo@domeniu.ro]. We reply within one month; for complex requests this can be extended by two more months, in which case we let you know.

7.Complaint to ANSPDCP

If you think we process your data incorrectly, you can write to us first. You always have the right to lodge a complaint with the Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP), 28-30 G-ral. Gheorghe Magheru Blvd., Sector 1, Bucharest, anspdcp@dataprotection.ro.

8.Artificial intelligence transparency

  • We use AI for: text suggestions in resumes and letters, explaining your match with a job, explaining the Index and recommending courses. AI-generated content is labelled as such.
  • Text you send to an AI feature is treated as data, not as instructions, and is sent to the AI provider only as far as needed for the answer.
  • Employer features that rank or filter candidates are high-risk under Regulation (EU) 2024/1689 (AI Act). Therefore: a human always makes the decision, there are no automated rejections, we log usage, monitor for possible discrimination and inform you when an employer uses such features on your application.
  • We do not use emotion recognition, nor face or voice analysis.
  • You can always ask for a recommendation about you to be reviewed by a human, at [dpo@domeniu.ro].

9.No solely automated decisions

The Employability Index and recommendations are calculated automatically, but they are information for you only: they have no legal effect and decide nothing in your place. No hiring or rejection decision is made solely by automated means (Art. 22 GDPR).

10.How we protect data

Data is encrypted in transit and at rest. Database access is restricted at row level (each user sees only their own data), and team access is minimal and logged. If a security breach affects you, we notify you as the law requires.

11.Minors

CareerLab is intended for people aged at least [16]. If you learn that a minor under that age has created an account, write to us and we will delete it.

12.Changes and contact

If we change anything important in this policy, we notify you by email or in the app before the change applies. Questions: [dpo@domeniu.ro].