Privacy Policy

1. Who We Are

HRHandle is operated by Aleksandre Merabishvili, Individual Entrepreneur, identification number 01019062001, Tbilisi, Georgia ("we", "us", "our").

We are the data controller for the personal data of our customers (account holders and their team members). For candidate data that you enter into the Service, you are the data controller and we act as a data processor on your behalf.

Contact: support@hrhandle.com

2. What Data We Collect

2.1 Account and Organization Data

• Name and email address of account holders and team members
• Organization name, country, and configuration settings
• Usage activity within the Service (e.g. actions taken, features used)
• If you sign in with Google or Microsoft: your account name, email address, and profile picture, provided via OAuth. We never receive your Google or Microsoft password.
• Billing records: your plan, billing cycle, amounts, currency, payment status, and the order and payment identifiers from our payment provider, Flitt (operated in Georgia by TPAY LLC), plus the details it returns for each payment: the masked card number (first six and last four digits), card type, bank reference and approval code. You enter your card or wallet details on Flitt's payment page, which may also ask for your email and phone number; Flitt and the acquiring bank, TBC Bank, process them under their own terms. We pass Flitt only your email address, and we never receive or store full card numbers. When you subscribe we also record that you accepted the Terms and automatic renewal, with the time and your IP address.
• Support requests: when you contact us by email or through our support form, your name, email address, and message.

2.2 Integration Data

• If you connect LinkedIn: your LinkedIn OAuth access token, used solely to post vacancies on your behalf. We do not access your LinkedIn connections or personal feed.
• If you connect Google Calendar: your Google OAuth access and refresh tokens, used solely to create and manage interview calendar events on your behalf.
• If you connect Zoom: your Zoom OAuth access and refresh tokens, used solely to create Zoom meetings when scheduling video interviews on your behalf.
• If you connect Microsoft: your Microsoft OAuth access and refresh tokens, used solely to create Teams meetings and Outlook Calendar events when scheduling interviews on your behalf. We do not access your emails, contacts, or any other Microsoft data.
• If you connect Calendly: your Calendly OAuth tokens and a webhook signing key, used to list your event types, build scheduling links for candidates, and record the interviews candidates book.
• If your admins add Slack or Microsoft Teams notifications: the incoming-webhook addresses they enter, used to post notifications to the channels they choose.

2.3 Vacancy Data

• Job titles, descriptions, responsibilities, departments, locations, and requirements
• Salary information and hiring timelines
• Evaluation criteria and scores entered by your team

2.4 Candidate Data

You enter candidate data into HRHandle as part of your recruitment process, or candidates submit it themselves through your public application page. This may include:

• Full name, email address, and phone number
• Current company and position, years of experience
• LinkedIn profile URL
• CVs, resumes, cover letters, and other uploaded documents
• Information extracted from uploaded CVs (work experience, education) — see Section 5.1
• Recruiter notes, evaluations, interview records, and offers
• Application status and history
• For candidates who apply through the public application page: the IP address from which the application was submitted. We use it to prevent abuse (rate limiting and duplicate-submission detection). It is stored with the application record and deleted 30 days after the application, or with the application if that is deleted sooner.

Some of this data may be copied by your recruiters from LinkedIn, or bulk-imported from a CSV or Excel file by an organization owner or admin. You are responsible for ensuring you have a lawful basis to collect and store this data under applicable law, regardless of how it was entered.

2.5 Candidate-facing pages and emails

When a candidate applies for a role, we create a private status page at /status/<token> that shows only that candidate's own application. The token is a random 32-character string and is the only credential — there is no login. The page shows the role title, the employer's name, the application date, the date of the last status change, and a simplified status (Applied / In review / Interview / Decision / Closed). It does not show recruiter notes, evaluation scores, internal pipeline stages, or any other internal data. The candidate can also withdraw the application from this page, with an optional reason that only the recruiter sees; any active offer is then withdrawn as well. The link stops working when the application is removed.

When a recruiter sends an offer, a separate private offer page at /offer/<token> shows the role title, employer name, the offer terms the recruiter entered, and an optional personal note. The candidate can accept or decline there; a decline reason, if given, is visible only to the recruiter.

When a recruiter shares a candidate's evaluation with someone outside HRHandle, a private page at /scorecard/<token> shows only the candidate's name, the role, the organization's name, the evaluation answers and scores, and who shared it and when. It does not show contact details, application status, notes, AI-generated content, or offer terms. The recruiter can revoke the link at any time.

On your behalf, HRHandle can send these emails to candidates: an application confirmation (with the status-page link); optional status-change emails when an application moves to "Under review" or "Interview" (off by default, enabled by an admin); and interview invitations, offers, and rejection emails, which are sent only when a recruiter chooses to send them.

3. How We Use Your Data

• To provide, operate, and improve the Service
• To manage your subscription and process payments (through Flitt)
• To send emails: account invitations and password resets, notifications to your team, the candidate emails described in Section 2.5, and replies to support requests
• To protect the Service from abuse: bot protection (Cloudflare Turnstile) on sign-in, sign-up, password, application, and support forms, and rate limiting
• To monitor for errors and technical issues (via Sentry)
• To comply with legal obligations

We do not use your data or your candidates' data for advertising or marketing purposes, and we do not sell data to third parties.

4. Legal Basis for Processing

• Contract performance: processing necessary to deliver the Service under our Terms
• Legitimate interests: keeping the Service secure and reliable, preventing abuse and fraud, and monitoring service health
• Legal obligation: complying with applicable laws, including accounting and tax rules
• Consent: where you have explicitly provided it

5. Service Providers (Sub-processors)

We use the following providers to run the Service:

Providers marked "optional" are used only if your organization connects them. All providers are contractually obligated to process data only as instructed and to maintain appropriate security measures.

5.1 AI-assisted features

Some features send data to Google's Gemini API to help recruiters — never to replace their judgement. CV parsing runs when a CV is uploaded; every other feature runs only when a recruiter clicks its button.

• CV parsing — when a CV (PDF or Word) is uploaded by a recruiter, or by a candidate on your application page, we extract its text on our server and send the text to Gemini to pull out structured fields (name, contact details, work experience, education) that pre-fill the form.
• Job-description suggestions — suggests the "About the job", "Responsibilities", or "Requirements" section from the role data the recruiter entered. No candidate data is sent. Nothing is added to the vacancy unless the recruiter applies it.
• Inclusive-language check — scans the vacancy text for phrasing that may deter some candidates and suggests neutral wording. Only vacancy text is sent; the recruiter decides whether to apply any suggestion.
• Assessment suggestions — proposes evaluation criteria and open-ended questions from the vacancy text. Only vacancy text is sent; each suggestion is added only when the recruiter clicks "Add".
• AI Fit Analysis — off by default; an owner or admin enables it for the organization (organizations in the EU/EEA must also confirm an acknowledgement). When a recruiter runs it, we send the vacancy's criteria and only job-relevant parts of the application — experience, education, languages, years of experience, and screening answers, plus an optional CV excerpt with the candidate's name, email addresses, phone numbers, and links removed. Identity data (name, photo, age, gender, nationality, ethnicity, marital status, address, health, religion) is never sent. The result — how well the application matches each criterion, with supporting evidence, and no overall score — is saved with the candidate's record for your team to review.

AI output is informational only. No AI feature in HRHandle makes an automated decision about a candidate — no automatic ranking, rejection, or advancement. Every hiring decision is taken by a person on your team, so Article 22 GDPR (automated decision-making with legal or similarly significant effect) does not apply.

We record an internal log entry each time an AI feature is used (who, which feature, when) for traceability under the EU AI Act. This log does not contain the AI output.

We use Google's paid Gemini API. Under Google's paid-services terms, Google may not use your prompts or responses to train or improve its models; it retains them briefly only for abuse detection. If an AI feature is unavailable, the recruiter simply completes the task manually.

6. International Data Transfers

Your data is stored on servers in the United States (AWS us-east-1, North Virginia), and some providers listed above process data in other countries. If you are located in the European Economic Area or Georgia, this involves a transfer of personal data outside your jurisdiction. We rely on standard contractual clauses and our providers' data processing agreements to ensure an adequate level of protection.

7. Data Retention

We retain your account, organization, and candidate data for as long as your account is active.

After your account is terminated (by you or by us), you have 30 days to request an export of your data. During this window the data remains recoverable. After it, your account, organization, and all associated candidate data, documents, and application records are permanently deleted, except where we are required by law to keep specific records longer (for example, payment and invoicing records under Georgian tax law).

Payment records (order, amount, masked card details, refunds, and your acceptance of the Terms) are kept for 5 years from each payment, also after your account is deleted, as payment-card rules and Georgian law require. They are then deleted. We also keep a record of which personal data we passed to whom, when and on what legal basis, for as long as the data itself.

While your account is active, a candidate or document you delete is marked for deletion immediately and permanently removed within 30 days. Backup snapshots taken before deletion are kept under Supabase's backup-retention policy, and our own encrypted nightly backups for 30 days; neither is used to restore individual deleted records.

8. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access the personal data we hold about you
• Correct inaccurate data
• Request deletion of your data ("right to be forgotten")
• Object to or restrict certain processing
• Receive your data in a portable format
• Withdraw consent where processing is based on consent

To exercise any of these rights, contact us at support@hrhandle.com. We will respond within 30 days. Candidates whose data was entered by an employer should contact that employer first, as it is the data controller.

9. Cookies and Analytics

We use cookies and browser storage in three categories:

9.1 Essential

Required for sign-in, sessions, security (CSRF and bot protection), and remembering your preferences, such as staying signed in and your interface language. They are set by Supabase Auth and our own code, and cannot be disabled without breaking the Service; the Cloudflare Turnstile security check also processes technical browser data. We do not use advertising or cross-site tracking cookies.

9.2 Product analytics

• PostHog (hosted in the EU) — records page views, clicks, and product events. Person profiles are created only for signed-in users; anonymous visitors to the landing page and application pages do not get one.
• Vercel Analytics — counts page views and basic traffic signals (referrer, country, device type) without cross-site tracking cookies.

We do not send candidate personal data (name, email, CV content) to either analytics tool.

9.3 Error monitoring

Sentry collects technical error details (stack traces, browser and OS, request metadata) when something fails. Before an error is sent, we remove known personal-data fields (names, emails, phone numbers, CV content, and similar), so error reports do not contain candidate personal data.

10. Security

We implement appropriate technical and organizational measures to protect your data, including encrypted transmission (TLS), row-level security on all database tables, role-based access controls, bot protection, and signed URLs for document access.

11. Children

The Service is not directed at persons under 18. We do not knowingly collect personal data from anyone under 18.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or via a notice within the Service. The "last updated" date at the top of this page shows the most recent revision.

13. Contact

Data controller: Aleksandre Merabishvili, Individual Entrepreneur
Identification number: 01019062001
29 Tskneti Highway, Tbilisi, Georgia
support@hrhandle.com
Phone: +995 599 89 29 17