Privacy Notice (GDPR)
Career Coach AI — AI Interview Preparation Coach For Users in the European Economic Area and United Kingdom
Effective date: June 02, 2025 Last updated: June 02, 2025
1. Introduction
ICI Tech Teknoloji A.Ş. processes your personal data in compliance with the EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and, where applicable, the UK GDPR.
| Data Controller | ICI Tech Teknoloji A.Ş. |
| Website | /en/ |
| app@icitech.com.tr | |
| Country of establishment | Republic of Turkey |
EU Representative (Article 27 GDPR): We are in the process of designating an EU representative. Updated contact details will be published at /en/privacy once appointed.
Data Protection Officer: We do not currently meet the mandatory DPO threshold under Article 37 GDPR. Contact: app@icitech.com.tr.
2. Sensitive Nature of Career Data
Career Coach AI processes professional and career-related data. While most of this data does not qualify as special category data under GDPR Article 9, certain categories are sensitive in nature and we treat them with heightened care:
Salary expectations and negotiation discussions reveal financial expectations. Career weaknesses identified through practice sessions relate to professional self-assessment. Target company preferences and job application data reveal employment intentions. Career switching context may reveal motivations not shared publicly.
We process this data only on the basis of contract performance (Art. 6(1)(b)) or, for voice recording, with your explicit consent (Art. 6(1)(a)).
3. AI Provider and Data Transfers
When you submit a practice answer, coaching request, or coach chat message, that content is transmitted to a third-party AI service provider via API. This constitutes an international transfer of personal data.
The identity of the current AI provider and the applicable GDPR transfer mechanism are disclosed at /en/privacy/ai-provider. We rely on Standard Contractual Clauses or the provider's own GDPR-compliant transfer mechanism. A data processing agreement under Article 28 GDPR is in place with our AI provider.
The AI provider commits to: not using API inputs for general model training; applying appropriate security measures; and processing data only as instructed by us.
4. Voice Practice and Microphone
When you use voice practice mode, your spoken answer is captured by the microphone, transcribed, and the transcript is transmitted to the AI provider for feedback. We rely on your explicit consent (microphone permission) as the legal basis for capturing and processing voice data. You may withdraw consent at any time by revoking microphone permission in device settings. Revoking microphone access disables voice practice only.
5. Automated Decision-Making
Career Coach AI generates automated feedback scores across 5 metrics. These scores are provided to you for personal use in improving your interview performance. We do not use automated scoring to make decisions with legal or similarly significant effects about you (Article 22 GDPR). Scores do not affect your employment prospects, creditworthiness, or any legal entitlement.
6. Data We Process
Account information: Email, password (hashed), optional display name and profile photo.
Career profile data: Target role, seniority level, industry, target company preferences.
Interview practice content: Written or spoken answers, session questions, session history. Transmitted to AI provider.
Voice recordings and transcripts: Audio from voice practice and generated transcripts. Processed by AI provider.
Career coach chat content: Messages covering salary, career switching, promotion, and interview strategy. Transmitted to AI provider.
Performance and scoring data: 5-metric session scores, radar analysis, trend history.
Job Tracker data: Company names, positions, interview stages, follow-up dates, notes.
Subscription data: Tier, purchase date, transaction ID.
Device and technical data: Device type, OS version, app version, truncated IP, crash logs.
7. Legal Bases (GDPR)
| Purpose | GDPR Legal Basis |
|---|---|
| Account creation and management | Art. 6(1)(b) — Performance of contract |
| Processing interview content for feedback | Art. 6(1)(b) — Performance of contract |
| Transmitting content to AI provider | Art. 6(1)(b) — Performance of contract |
| Voice recording and transcription | Art. 6(1)(a) — Explicit consent |
| Career profile and personalization | Art. 6(1)(b) — Performance of contract |
| Job Tracker data | Art. 6(1)(b) — Performance of contract |
| Progress scoring and analytics | Art. 6(1)(b) — Performance of contract |
| App quality and crash analysis | Art. 6(1)(f) — Legitimate interests |
| Security monitoring | Art. 6(1)(f) — Legitimate interests |
| Subscription management | Art. 6(1)(b) — Performance of contract |
| Support requests | Art. 6(1)(b) — Performance of contract |
| Legal obligations | Art. 6(1)(c) — Legal obligation |
| Marketing | Art. 6(1)(a) — Consent |
8. What We Do Not Do
We do not sell personal data or career content. We do not use interview answers or coaching content for advertising. We do not share career data, salary information, or job tracker data with advertising networks. We do not use advertising identifiers. We do not use AI-generated scores to make legally significant decisions about you. We do not represent or act on behalf of any employer.
9. Your Rights Under GDPR
Right of access (Art. 15): Obtain a copy of your personal data — email app@icitech.com.tr.
Right to rectification (Art. 16): Correct inaccurate data in-app or via email.
Right to erasure (Art. 17): Delete account via Settings → Account → Delete Account.
Right to restriction (Art. 18): Limit processing — contact app@icitech.com.tr.
Right to data portability (Art. 20): Receive data in machine-readable format — Settings → Privacy → Export or contact us.
Right to object (Art. 21): Object to legitimate interest processing — contact app@icitech.com.tr.
Right to withdraw consent (Art. 7(3)): Revoke microphone permission in device settings. Withdraw marketing consent in Settings → Privacy → Marketing Preferences.
Right not to be subject to automated decisions with significant effects (Art. 22): Career Coach AI scores are informational feedback tools only — they do not produce legal effects.
Right to lodge a complaint (Art. 77): Contact your national supervisory authority.
Email app@icitech.com.tr — subject "GDPR Data Subject Request — Career Coach AI". Response within one month, free of charge.
10. Right to Lodge a Complaint
| Country | Authority | Website |
|---|---|---|
| 🇫🇷 France | CNIL | https://www.cnil.fr |
| 🇩🇪 Germany | BfDI + state DPAs | https://www.bfdi.bund.de |
| 🇪🇸 Spain | AEPD | https://www.aepd.es |
| 🇬🇧 United Kingdom | ICO | https://ico.org.uk |
| Other EEA | Your national DPA | https://edpb.europa.eu/about-edpb/about-edpb/members_en |
11. International Data Transfers
ICI Tech Teknoloji A.Ş. is established in Turkey. No adequacy decision exists for Turkey under GDPR Article 45. For EEA/UK transfers, we rely on Standard Contractual Clauses, the AI provider's own GDPR-compliant transfer mechanism, and UK IDTAs where applicable. Details at /en/privacy/ai-provider.
12. Data Retention
Account data: duration plus 3 years after deletion. Interview content and transcripts: duration plus 1 year after deletion. Voice recordings: per in-app settings; cloud copies deleted within 30 days of account deletion. Job Tracker data: duration plus 1 year after deletion. Subscription records: 10 years. Support communications: 3 years. Crash logs: 12 months.
13. Security
TLS 1.2+ in transit; encryption at rest. AI provider transmissions encrypted. Breach notification: Supervisory authority within 72 hours (Art. 33); users notified without undue delay for high-risk breaches (Art. 34).
14. Children's Privacy
Career Coach AI is for users 18 and older. Contact app@icitech.com.tr for immediate deletion if a child has submitted data.
15. Cookies
Our website uses cookies with a consent banner. The FAQ states that analytics and marketing tags load only after cookie consent is provided on the website. Manage via the cookie banner on first visit.
16. Changes
Material changes notified 14 days in advance. Current version: /en/privacy/gdpr.
17. Contact Us
Email: app@icitech.com.tr Subject: "GDPR Data Subject Request — Career Coach AI" Website: /en/
Acknowledge within 5 business days, resolve within one month.