Privacy Policy
Last Updated: February 1, 2026
1. Introduction
This Privacy Policy explains how Apture Ltd. ("Apture," "we," "us," or "our"), a company registered in Poland, collects, uses, discloses, and protects personal information through our recruitment technology platform available at useapture.com (the "Service").
Apture provides AI-powered candidate evaluation tools that help recruiters analyze resumes and make informed hiring decisions. This policy applies to:
- Recruiters and Users ("Users"): Individuals who create accounts and use our Service to evaluate candidates
- Candidates: Individuals whose resumes and personal information are uploaded to our Service by Users
Our Role in Data Processing
- For User Data: Apture acts as a data controller under GDPR, determining the purposes and means of processing your personal data.
- For Candidate Data: Apture acts as a data processor under GDPR, processing candidate information on behalf of and under the instructions of Users.
2. Information We Collect
2.1 User Data (Collected from Recruiters)
When you create an account and use our Service, we collect:
| Category | Data Elements | Source |
|---|---|---|
| Identity Information | Full name, username | Account registration, profile settings |
| Contact Information | Email address | Account registration |
| Business Information | Company name, company description, hiring preferences, website URL | Profile settings |
| Financial Information | Stripe customer ID, subscription status, payment history | Payment processing |
| Usage Information | Number of roles created, CVs processed, feature usage | Service activity |
| Authentication Data | User ID, session tokens | Login activity |
2.2 Candidate Data (Processed on Behalf of Users)
When Users upload candidate resumes to our Service, we process:
| Category | Data Elements | Source |
|---|---|---|
| Identity Information | Full name | Extracted from CV |
| Contact Information | Email address, location | Extracted from CV |
| Professional Information | Employment history, job titles, work experience, skills | Extracted from CV |
| Educational Information | Degrees, certifications, educational institutions | Extracted from CV |
| Documents | Resume/CV files | User upload |
| AI-Generated Analysis | Match scores, strengths, areas for improvement, recommendations | Generated by our AI |
2.3 Technical Data
We automatically collect certain information when you use our Service:
- Device Information: Browser type, operating system, device identifiers
- Log Data: IP address, access times, pages viewed, referring URLs
- Cookies and Tracking Technologies: See Section 10 for details
3. How We Use Information
3.1 User Data
We use User data to:
- Provide the Service: Create and manage your account, process subscriptions, enable features
- AI-Powered Analysis: Analyze candidate CVs against your job requirements and company profile
- Billing and Payments: Process payments, manage subscriptions, send invoices
- Communications: Send service updates, respond to inquiries, provide support
- Analytics: Understand how our Service is used, improve features, fix bugs
- Legal Compliance: Comply with applicable laws, respond to legal requests
3.2 Candidate Data
We process Candidate data to:
- CV Analysis: Extract information from resumes and generate AI-powered assessments
- Matching: Compare candidate qualifications against job requirements
- Recommendations: Generate hiring recommendations for Users
- Storage: Maintain candidate records as directed by Users
4. Legal Basis for Processing (GDPR)
For Users in the European Economic Area (EEA), United Kingdom, and Switzerland, we process personal data based on the following legal grounds:
4.1 User Data
| Processing Purpose | Legal Basis |
|---|---|
| Account creation and service provision | Contract Performance (Art. 6(1)(b)) |
| Payment processing | Contract Performance (Art. 6(1)(b)) |
| Service communications | Contract Performance (Art. 6(1)(b)) |
| Analytics and service improvement | Legitimate Interests (Art. 6(1)(f)) |
| Marketing communications | Consent (Art. 6(1)(a)) |
| Legal compliance | Legal Obligation (Art. 6(1)(c)) |
4.2 Candidate Data
For Candidate data, Users (recruiters) are the data controllers and must ensure they have an appropriate legal basis to process candidate information and share it with Apture for processing.
5. International Data Transfers
Apture is based in Poland (European Union). However, we use service providers located outside the EEA, including in the United States. When we transfer personal data outside the EEA, we ensure appropriate safeguards are in place through Standard Contractual Clauses (SCCs).
You have the right to request a copy of the SCCs or other safeguards we use for international transfers. Contact us at support@useapture.com.
6. Automated Decision-Making and AI Processing
Apture uses artificial intelligence (Google Gemini) to extract information from uploaded CVs, generate candidate match scores, identify strengths and areas for improvement, and suggest recommended next steps.
We do not make solely automated decisions with legal or similarly significant effects on candidates.
Our AI serves as a recommendation and analysis tool. All AI-generated assessments are visible to Users, editable by Users, and non-binding. A human recruiter is always in the decision-making loop.
7. Data Retention
7.1 User Data
We retain User data for as long as your account is active. After account deletion, data is deleted within 30 days. Billing records are retained for 7 years for legal/tax compliance.
7.2 Candidate Data
Candidate data is retained according to the instructions of the User (data controller). When a User deletes their account, all associated candidate data is deleted within 30 days.
8. Your Rights Under GDPR
If you are in the EEA, UK, or Switzerland, you have the following rights:
- Access: Request a copy of your personal data
- Rectification: Request correction of inaccurate data
- Erasure: Request deletion of your data ("right to be forgotten")
- Restriction: Request limitation of processing
- Portability: Receive your data in a structured, machine-readable format
- Objection: Object to processing based on legitimate interests
- Withdraw Consent: Withdraw consent at any time
For Users: Contact us at support@useapture.com with your request.
For Candidates: Contact the recruiter/organization that uploaded your CV.
You have the right to lodge a complaint with a supervisory authority. Our lead supervisory authority is the Polish Data Protection Authority (UODO) at https://uodo.gov.pl.
9. California Privacy Rights (CCPA/CPRA)
California residents have additional rights including the right to know, delete, correct, and opt-out of sharing for cross-context behavioral advertising.
To submit requests, email support@useapture.com with "California Privacy Request" in the subject line.
10. Cookies and Tracking Technologies
We use essential cookies for authentication and security, analytics via Google Tag Manager, and localStorage for saving drafts and preferences.
You can manage cookies through your browser settings. For opt-out options, visit:
- Google Analytics Opt-Out: https://tools.google.com/dlpage/gaoptout
- Google Ad Settings: https://adssettings.google.com
11. Data Security
We implement appropriate technical and organizational measures to protect personal data, including encryption in transit and at rest, role-based access controls, and regular security monitoring.
12. Children's Privacy
Our Service is not directed to individuals under 16 years of age. We do not knowingly collect personal information from children under 16.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will update the "Last Updated" date and notify you of material changes by email or through the Service.
14. Contact Information
If you have questions regarding this Privacy Policy, please contact us:
Apture Ltd.
Email: support@useapture.com