Aikho Client Terms & Privacy
Legal documentation and compliance policies for hiring companies and business clients using Aikho's AI-powered recruitment service.
This document does not apply to job seekers. Candidates engaging with Aikho are governed by a separate, candidate-facing agreement available at /candidate-terms.
IN5 Tech, Dubai Internet City, Dubai, UAE
Les Hauts Puits, 16150 Chabanais, France
Legal: legal@aikho.ai
Privacy Policy
The Headlines
- Aikho is the data controller for the personal data we collect. We decide why and how we use it, and we're accountable for it.
- Candidates and Clients are dealt with separately. When we share a candidate dossier with a hiring company, the company becomes its own controller for what it does next. We don't act as their processor.
- Interview audio stays with us. Never transmitted to the hiring company, never used to build voiceprints, never used to train AI.
- You're in control of your data. Access, correction, deletion, portability, objection — all available in one place. privacy@aikho.ai is the single front door for any request.
- Our AI is high-risk under the EU AI Act. We're the Provider; Clients deploying it in the EU are the Deployer. We document this end-to-end.
1. About this Policy
This Privacy Policy describes how Aikho Tech FZ-LLC ("Aikho", "we", "us", "our") processes personal data of job candidates, of Client representatives, and of users of the Aikho platform. It is provided alongside our Data Processing & AI Compliance Notice (v2.5, May 2026) for Clients, and the Data Sharing Agreement between Independent Controllers that governs our contractual relationship with hiring companies.
2. Controller & Contact
Data Controller: Aikho Tech FZ-LLC, IN5 Tech, Dubai Internet City, Dubai, UAE.
Data protection contact: privacy@aikho.ai
Legal & compliance contact: legal@aikho.ai
EU Representative (Article 27 GDPR): Hugues Pringault, Les Hauts Puits, 16150 Chabanais, France. For data subjects located in the European Economic Area, our EU representative can be contacted at this address or by email at privacy@aikho.ai.
3. Our role under the GDPR
Aikho is the data controller of all personal data Aikho collects and processes in connection with its recruitment service. Aikho decides the purposes and the means of that processing, in accordance with Article 4(7) GDPR.
The Client (hiring company) is the data controller of the personal data the Client receives from Aikho and processes within its own systems for its own hiring decisions. Each Party acts as an Independent Controller, in accordance with the EDPB Guidelines 07/2020 on the Concepts of Controller and Processor, which recognise sequential processing operations by recruitment service providers and their clients as a arrangement between Independent Controllers.
The contractual relationship between Aikho and the Client is governed by the Data Sharing Agreement between Independent Controllers (Article 6 GDPR), which is provided with the master services agreement and signed before any Hiring Brief begins.
3.5 Sourcing modes
Aikho engages candidates through three sourcing modes. In each mode, Aikho conducts the candidate engagement, evaluation and selection under its own methodology, and informs the candidate in accordance with Article 13 or Article 14 GDPR as applicable.
- Sourcing by Aikho. Aikho identifies candidates from publicly accessible professional sources and from Aikho's candidate community. Aikho notifies the candidate under Article 14 GDPR within thirty days of first contact, identifying Aikho as the controller and informing the candidate of the right to decline.
- Applications submitted to Aikho. Candidates submit applications directly to Aikho through application pages hosted by Aikho, which the Client may reference in its external communications. The candidate enters the Aikho environment from the first interaction, accepts the Aikho Candidate Terms before submitting any data, and is informed under Article 13 GDPR. Aikho is the controller from the moment of collection. The Client does not access raw applications prior to Aikho's evaluation and selection.
- Candidates referred by the Client. The Client may refer candidates to Aikho for engagement. The Client warrants in the Data Sharing Agreement that it has obtained the candidate's informed consent to the transfer, or that it relies on another valid lawful basis under Article 6 GDPR. Upon receipt, Aikho contacts the candidate on its own terms, issues an Article 14 GDPR notice identifying Aikho as the controller and the Client as the source of the introduction, and requests the candidate's acceptance of the Aikho Candidate Terms and consent to the AI interview prior to any substantive processing. The candidate may decline at any time, in which case Aikho deletes the data received.
3.6 Communications with candidates
During Aikho's phase of the recruitment process, Aikho communicates with the candidate in its own name. Where the Client provides a decision concerning a candidate, Aikho may transmit that decision to the candidate as a factual matter, identifying the Client by name. Aikho does not communicate with candidates on behalf of the Client. From the moment the Client takes over the candidate file — whether by retrieving the file into the Client's own systems, by direct engagement with the candidate, or by such other moment as the Parties agree in writing — the Client communicates with the candidate directly and Aikho ceases to communicate with the candidate on that file.
4. The Aikho service
Aikho operates an AI-powered recruitment service with two distinct components:
- The Hiring Brief service: in response to a Client's hiring need, Aikho sources, evaluates and selects candidates and transmits a shortlist to the Client.
- The Aikho candidate community: an ongoing platform that supports candidates in their career, irrespective of any specific Client engagement.
Aikho conducts all exchanges with candidates. The Client does not participate in or observe these exchanges. Where a candidate progresses to the Client's own internal interview process, that interaction takes place outside the Aikho service.
5. Categories of personal data
| Category | Description |
|---|---|
| Identification & contact | Name, email, phone number, location, professional social profiles. |
| Professional profile | CV or resume, work history, education, languages, salary expectations, role preferences. |
| AI interview data | Interview transcript, candidate responses, derived competency scores. |
| AI evaluation outputs | Fit assessment, scoring rationale, Big 5 personality inference where applicable. |
| Voice and audio | Interview audio recordings, used solely for evaluation and quality assurance. Never transferred to the Client; not used to create biometric voiceprints; not used to train AI models. |
| Communications | Records of exchanges between Aikho and the candidate (outreach, status updates, follow-ups). |
| Account & usage data | Account metadata, authentication events, platform interaction logs. |
Aikho transmits to the Client only the candidate dossiers Aikho selects to present and that the candidate has agreed to share with the Client. Interview audio recordings and biometric voice analysis data are never transmitted to the Client.
6. Lawful basis
Aikho relies on the following lawful bases under Article 6 GDPR:
| Lawful basis | Scope |
|---|---|
| Art. 6(1)(a) GDPR — Consent | AI interview, audio recording, and processing of any data the candidate volunteers under Art. 9 GDPR. |
| Art. 6(1)(b) GDPR — Contract | Performance of the Aikho service contract with the candidate (Aikho Candidate Terms). |
| Art. 6(1)(f) GDPR — Legitimate interest | Operating the recruitment service, identifying suitable candidates from publicly accessible professional sources, and transmitting candidate dossiers to Clients in connection with Hiring Briefs. Art. 14 transparency applies. |
For Article 9 GDPR special category data, Aikho relies on the candidate's explicit consent (Art. 9(2)(a)). Aikho does not solicit such data and instructs candidates not to share it during the AI interview.
7. Automated decision-making (Art. 22 GDPR)
AI evaluation informs but does not replace human judgment. A candidate may request human review of any automated decision that significantly affects them by contacting privacy@aikho.ai.
8. Data sharing & disclosures
We do not sell personal data. We share data with:
- Clients (hiring companies): we transmit selected candidate dossiers under our Data Sharing Agreement between Independent Controllers, with the candidate's agreement.
- Sub-processors: cloud infrastructure, communication, AI providers, etc. See Section 8 of this document for the full list.
- Corporate transactions: in the event of a merger or acquisition, under appropriate safeguards.
- Legal/regulatory bodies: when required by law.
9. International transfers
Aikho's production infrastructure operates on Google Cloud Platform in me-central1 (Doha, Qatar). Where personal data is transferred from the EEA, the United Kingdom, or Switzerland to a third country that is not the subject of an adequacy decision, Aikho relies on the Article 46 GDPR safeguards in the Google Cloud Data Processing Addendum, which incorporates the EU Standard Contractual Clauses (2021), the UK International Data Transfer Addendum, and Swiss FADP provisions.
Clients requiring strict EU-only data residency across the entire candidate lifecycle may contract a dedicated europe-west1 (Belgium) deployment under the Enterprise tier. Contact legal@aikho.ai for scope and pricing.
10. Children's data
The Service is not intended for individuals under 18. We do not knowingly collect data from children.
11. Changes to this Policy
We will notify you of any material changes via the Service or by email. The updated policy will be posted with a new "Last Updated" date.
Terms of Service
Who this Terms of Service is for.
This Terms of Service applies to Clients and Hiring Organizations using the Aikho platform. Candidates (job seekers) are not bound by this document; they are governed by a separate agreement available at /candidate-terms.
Clients / Hiring Organizations are bound by the Aikho Client Terms (see §4.1), supplemented by a Master Services Agreement (MSA) and a Data Sharing Agreement between Independent Controllers (DSA) signed off-platform. The DSA is a confidential bilateral contract and is not published on this site; its existence and substance are summarised in §4 of this document.
1. Acceptance & Eligibility
By accessing or using the Aikho platform ("Service"), you agree to be bound by these Terms of Service ("Terms"), together with our Privacy Policy (including the Cookie Policy and Data Retention schedules), EU AI Act & Responsible AI Policy, and Acceptable Use Policy, all of which are incorporated herein by reference. Clients are additionally bound by the MSA and the Data Sharing Agreement between Independent Controllers signed with Aikho. Together these documents constitute the entire agreement between you and Aikho Tech FZ-LLC ("Aikho," "we," "us," or "our") governing your use of the Service.
To use the Service, you must: (a) be at least 18 years of age; (b) have the legal capacity to enter into a binding agreement; (c) not be prohibited from using the Service under applicable law; and (d) provide accurate and complete registration information.
If you are using the Service on behalf of an organization, you represent and warrant that you have the authority to bind that organization to these Terms.
2. Definitions
- "Client", "Employer" or "Hiring Organization" means an organization that uses the Service for recruitment purposes.
- "Candidate" means an individual whose data is processed by Aikho in connection with a Hiring Brief. Candidates are not Users of these Terms of Service; they are governed by a separate candidate-facing agreement.
- "User Content" means any content the Client uploads or submits to the Service.
3. Service Description
Aikho is an AI-powered recruitment and career services platform that connects candidates with hiring organizations. Aikho is a service — you access and use it via our Service; you do not purchase, license, or install any software.
Our Service uses AI to assist with various stages of the recruitment process, including candidate screening, assessments, communications, and workflow automation. While AI assists with operational tasks, the Hiring Organization retains full control over consequential hiring decisions.
4. Client Terms
4.1 Aikho Client Terms (Hiring Organizations)
This section forms the Aikho Client Terms. It applies in addition to the Master Services Agreement (MSA) and the Data Sharing Agreement between Independent Controllers (DSA) signed between Aikho and the Client. The DSA is a confidential bilateral contract and is not published on this site; Clients receive a copy as part of the MSA process. Its substance is summarised in §4 (Data Sharing Agreement) of this document.
As a Hiring Organization, you acknowledge and agree that:
- Hiring decisions. You are responsible for job requirements, hiring criteria, and all hiring decisions made using the Service. AI evaluation informs but does not replace your human judgment.
- Independent Controller. You act as an Independent Controller under the GDPR for the personal data you receive from Aikho and process within your own systems. You are responsible for your own lawful basis for that subsequent processing.
- EU AI Act Deployer obligations. Where you use the system in the European Union, you are the Deployer under Article 3(4) AI Act. Aikho provides a Deployer Information Package on signature of the MSA; you remain responsible for your own Fundamental Rights Impact Assessment where applicable.
- Employment law compliance. You must comply with all applicable employment, non-discrimination and equal opportunity laws when using AI-generated assessments and recommendations.
- No re-identification or re-use. You may use candidate data transmitted by Aikho only for the hiring need described in the Hiring Brief, and only in accordance with the DSA. You may not use such data to train or evaluate machine-learning models, nor share it outside your organization without a separate lawful basis.
5. Account Registration & Management
To access certain features of the Service, you must create an account. You agree to:
- Provide accurate, current, and complete registration information.
- Maintain the security and confidentiality of your login credentials.
- Promptly update your account information if it changes.
- Accept responsibility for all activities that occur under your account.
- Notify Aikho immediately of any unauthorized use of your account.
Aikho reserves the right to suspend or terminate accounts that violate these Terms, remain inactive for extended periods, or pose security risks.
6. User Content & Licenses
Your Data: You retain ownership of data you provide to the Service, including candidate contact information, CVs, and application materials ("Your Data"). You may export Your Data at any time through the Service or upon request.
Service Outputs: Assessments, interview recordings, transcripts, and other outputs generated by the Service ("Service Outputs") are proprietary to Aikho. You are granted a non-exclusive, non-transferable license to access and use Service Outputs for your internal recruitment purposes during the term of your subscription. Service Outputs may not be exported, copied, or transferred outside the Service without Aikho's prior written consent.
AI Processing: You acknowledge that Your Data may be processed by AI to provide the Service's functionality, including generating Service Outputs.
On Termination: Upon termination, you may request export of Your Data within 30 days. Access to Service Outputs will cease upon termination. Aikho will delete Your Data in accordance with our retention policy.
Representations: You represent and warrant that: (a) you own or have the rights to submit Your Data; (b) Your Data does not infringe any third-party rights; and (c) Your Data complies with all applicable laws.
7. Acceptable Use & Fair Usage
Your use of the Service is subject to our Acceptable Use Policy (Section 11 of this document). You agree not to use the Service for any unlawful purpose or in any manner that could damage, disable, or impair the Service.
Reasonable Use: The Service, including features described as "unlimited," is provided for normal business recruitment operations. Usage must remain within reasonable parameters consistent with legitimate hiring activities.
Single-Role Integrity: Each active hiring position is intended to address a specific, distinct hiring need. Using a single position to aggregate disproportionate volumes of candidates for unrelated roles, or to circumvent standard recruitment ratios, is not permitted.
Right to Limit: In the event of excessive traffic, abnormal usage patterns, or activity suggesting usage outside of standard parameters, Aikho reserves the right, at its sole discretion and without prior detailed justification, to: (a) throttle or limit the processing of new assessments for the affected position; (b) temporarily restrict the position's visibility to manage infrastructure load; (c) request additional information regarding the nature of the hiring activity.
High-Volume Operations: Clients anticipating significant deviations from typical usage patterns (e.g., bulk candidate imports, mass assessment campaigns) should notify Aikho in advance to ensure adequate resource allocation.
8. Fees & Payment
Subscription Plans: Access to certain features requires a paid subscription. Fees, billing cycles, and payment terms are specified in your subscription agreement or order form.
Payment Terms: All fees are due as specified in your agreement. Late payments may incur interest charges and may result in suspension of access.
Taxes: Fees are exclusive of applicable taxes, which you are responsible for paying.
Refunds: Fees are generally non-refundable except as required by applicable law or as specified in your subscription agreement.
9. Intellectual Property
Aikho's IP: The Service, including its software, algorithms, AI models, user interface, documentation, and all related intellectual property, is owned by Aikho and protected by intellectual property laws. Nothing in these Terms grants you any rights to Aikho's intellectual property except the limited license to use the Service.
Feedback: If you provide suggestions, ideas, or feedback about the Service, you grant Aikho the right to use such feedback without restriction or compensation.
10. Confidentiality
Confidential Information: Each party agrees to maintain the confidentiality of the other party's confidential information and not to disclose it to third parties except as necessary to perform obligations under these Terms or as required by law.
Exceptions: Confidentiality obligations do not apply to information that: (a) is or becomes publicly available; (b) was known prior to disclosure; (c) is independently developed; or (d) is lawfully obtained from a third party.
11. Data Protection
Personal data processing is governed by our Privacy Policy and, for Hiring Organizations, by the Data Sharing Agreement between Independent Controllers provided with the master services agreement. By using the Service, you acknowledge that you have read and understood these documents.
Aikho and the Hiring Organization each act as Independent Controllers under the GDPR. The Hiring Organization is responsible for ensuring it has appropriate legal bases for its own subsequent processing of candidate data under applicable data protection laws.
12. Disclaimers & Warranties
Service Nature: Aikho is a recruitment and career services offering. There is no Service Level Agreement (SLA), no guaranteed uptime, and no committed availability metrics. Your use of the Service is subject to the disclaimers below.
As-Is Basis: THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING BUT NOT LIMITED TO WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, OR UNINTERRUPTED AVAILABILITY.
No SLA: Aikho does not provide any service level commitments, uptime guarantees, or performance warranties. The Service may be unavailable, modified, or discontinued at any time without prior notice.
AI Limitations: Aikho does not warrant that AI-generated assessments, recommendations, or outputs are accurate, complete, or suitable for any particular purpose. You are responsible for reviewing and validating AI outputs before making hiring decisions.
Service Availability: While Aikho strives to maintain reasonable availability, we do not guarantee uninterrupted or error-free access to the Service. Maintenance, updates, and technical issues may affect availability at any time.
13. Limitation of Liability
TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW:
- Exclusion of Damages: AIKHO SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING LOSS OF PROFITS, DATA, BUSINESS OPPORTUNITIES, OR GOODWILL.
- Liability Cap: AIKHO'S TOTAL LIABILITY FOR ANY CLAIMS ARISING FROM THESE TERMS OR THE SERVICE SHALL NOT EXCEED THE GREATER OF: (A) THE FEES PAID BY YOU IN THE TWELVE (12) MONTHS PRECEDING THE CLAIM; OR (B) ONE HUNDRED US DOLLARS ($100) FOR FREE USERS.
- Hiring Decisions: AIKHO IS NOT LIABLE FOR ANY HIRING DECISIONS MADE BY EMPLOYERS USING THE SERVICE, INCLUDING DECISIONS BASED ON AI-GENERATED ASSESSMENTS OR RECOMMENDATIONS.
14. Indemnification
You agree to indemnify, defend, and hold harmless Aikho and its officers, directors, employees, and agents from and against any claims, damages, losses, liabilities, costs, and expenses (including reasonable attorneys' fees) arising from: (a) your use of the Service; (b) your User Content; (c) your violation of these Terms; or (d) your violation of any third-party rights.
15. Term & Termination
Term: These Terms remain in effect until terminated by either party.
Termination by You: You may terminate your account at any time by following the account deletion process in the Service or by contacting us.
Termination by Aikho: Aikho may suspend or terminate your access to the Service at any time, with or without cause, upon reasonable notice. We may terminate immediately for violations of these Terms or applicable law.
Effect of Termination: Upon termination: (a) your right to access the Service ceases immediately; (b) Aikho may delete your data in accordance with our retention policies; (c) provisions that by their nature should survive termination shall survive, including Sections 9-14, 17, and 18.
16. Modifications to Terms
Aikho may modify these Terms at any time by posting the revised Terms on our website and updating the "Last Updated" date. Material changes will be communicated via email or through the Service at least thirty (30) days before they take effect.
Your continued use of the Service after the effective date of revised Terms constitutes your acceptance of the changes. If you do not agree to the revised Terms, you must stop using the Service.
17. General Provisions
Entire Agreement: These Terms, together with the Privacy Policy and any applicable subscription agreement, constitute the entire agreement between you and Aikho regarding the Service.
Severability: If any provision of these Terms is found to be unenforceable, the remaining provisions shall remain in full force and effect.
Waiver: Failure to enforce any provision of these Terms shall not constitute a waiver of that provision or any other provision.
Assignment: You may not assign your rights or obligations under these Terms without Aikho's prior written consent. Aikho may assign its rights and obligations without restriction.
Force Majeure: Neither party shall be liable for delays or failures in performance resulting from circumstances beyond its reasonable control, including natural disasters, war, terrorism, labor disputes, government actions, or internet outages.
Notices: Notices to Aikho should be sent to legal@aikho.ai. Notices to you will be sent to the email address associated with your account.
18. Governing Law & Dispute Resolution
Governing Law: These Terms are governed by and construed in accordance with the laws of the United Arab Emirates, without regard to conflict of law principles.
Dispute Resolution: Any dispute arising from or relating to these Terms or the Service shall first be attempted to be resolved through good-faith negotiation. If negotiation fails, disputes shall be resolved by the courts of Dubai, United Arab Emirates, which shall have exclusive jurisdiction.
Individual Proceedings: Where permitted by applicable law, you agree that disputes will be resolved on an individual basis. This provision does not apply in jurisdictions where class action waivers are unenforceable.
19. Contact Information
For questions about these Terms, please contact us at:
- Email: legal@aikho.ai
- Privacy inquiries: privacy@aikho.ai
- Address: Aikho Tech FZ-LLC, IN5 Tech, Dubai Internet City, Dubai, UAE
Data Sharing Agreement between Independent Controllers
This section summarises the data-protection relationship between Aikho and its Clients (hiring companies). It is provided alongside, and does not replace, the Data Sharing Agreement between Independent Controllers signed with each Client as part of the master services agreement.
Independent Controllers
Aikho and the Client each act as Independent Controllers within the meaning of the GDPR. Aikho is the controller of personal data processed in connection with its recruitment service (sourcing, AI interviews, evaluation). The Client is the controller of the personal data it receives from Aikho and processes within its own systems for its own hiring decisions.
This arrangement reflects EDPB Guidelines 07/2020 on the Concepts of Controller and Processor, which recognise sequential processing operations by recruitment service providers and their clients as a relationship between Independent Controllers.
Aikho's commitments to Clients
- Process personal data in accordance with this Notice and the GDPR.
- Transmit to the Client only candidate dossiers Aikho has selected to present and that the candidate has agreed to share. Interview audio recordings and biometric voice analysis data are never transmitted to the Client.
- Implement appropriate technical and organisational security measures (Article 32 GDPR); see the Security Policy section.
- Handle data subject rights requests relating to Aikho-held data as the single point of contact. The Client redirects any such request to Aikho.
- Notify the Client and supervisory authorities of qualifying personal data breaches within 72 hours.
- Not use Client data, candidate data or Hiring Brief data to train, fine-tune or improve any AI or machine-learning model.
AI Act roles
Aikho is the Provider (Art. 3(3) AI Act) of the recruitment evaluation system. Where the Client uses the system in its own activities within the European Union, the Client is the Deployer (Art. 3(4) AI Act). Aikho provides Clients with a Deployer Information Package on signature of the master services agreement. See Section 6 for details.
Security Policy
Aikho implements technical and organisational measures appropriate to the risk presented by the processing, in accordance with Article 32 GDPR.
| Measure | Detail |
|---|---|
| Encryption | TLS 1.3 in transit; AES-256 at rest. |
| Access control | Role-based access; multi-factor authentication for administrative access; least privilege. |
| Logging & monitoring | Audit logging of access to candidate data; centralised log aggregation; anomaly alerting. |
| Tenant segregation | Logical segregation between Clients; strict data firewall between Hiring Brief-specific data and platform-level candidate data. |
| Sub-processor controls | Written data processing agreements with each sub-processor; SOC 2 Type II certification or equivalent for material sub-processors. |
| AI training data | No client data, candidate data or Hiring Brief data is used to train, fine-tune or improve any AI or machine-learning model, by Aikho or by any AI sub-processor. |
| Personnel obligations | All Aikho personnel subject to confidentiality obligations and documented data protection training. |
| Incident response | Documented procedure; 72-hour notification to the Client and to supervisory authorities for qualifying personal data breaches. |
EU AI Act & Responsible AI
Classification
Aikho's recruitment evaluation system is classified as a high-risk AI system under Annex III of Regulation (EU) 2024/1689 (the EU AI Act).
Roles under the AI Act
- Aikho is the Provider of the system within the meaning of Article 3(3) AI Act.
- The Client is the Deployer within the meaning of Article 3(4) AI Act, where the Client uses the system in its own activities within the European Union.
AI Act roles and GDPR roles are independent of each other. Aikho's status as Provider does not affect its status as Independent Controller under the GDPR.
Deployer Information Package
Aikho provides the Client with a Deployer Information Package on signature of the master services agreement, covering:
- The system's intended purpose
- Known limitations
- Human oversight guidance
- Documentation needed to support a Fundamental Rights Impact Assessment where applicable
Our Responsible AI commitments
- Maintaining human oversight of consequential hiring decisions
- Testing our systems for bias and fairness
- Providing transparency to candidates when AI is used
- Not using Client, candidate or Hiring Brief data to train AI models
Data Retention
Aikho retains personal data only for as long as necessary to fulfil the purposes for which it was collected, unless a longer retention is required by law.
Retention periods
| Data category | Retention period |
|---|---|
| Shortlisted candidate profile and evaluation data (in the Client's private Talent Pool) | For the duration of the Client's subscription, or as defined in the master services agreement. |
| Non-shortlisted candidate data (accessible to the Client during the active Hiring Brief only) | Inaccessible to the Client after Hiring Brief closure. Aikho retains under its own controllership in accordance with this Policy. |
| Interview audio recordings | Up to 12 months from interview date. Never transferred to the Client. Never retained in the Talent Pool. |
| Candidate communications | Duration of active Hiring Brief plus 12 months. |
| Business and billing records | 7 years, as required by applicable accounting and tax law. |
Data deletion
Candidates may delete their account, profile and all applications at any time. Deletion is applied immediately in live systems and completed within 30 days across backups, subject to any legal retention obligation.
Subprocessors
Aikho engages sub-processors to deliver its service. Aikho contracts with each sub-processor on its own behalf and remains responsible for their compliance with applicable data protection terms. Aikho will notify Clients at least 30 days before adding or replacing a sub-processor that materially affects the processing of Hiring Brief data.
Sub-processor categories
Sub-processors fall into the following functional categories. The detailed list — including legal entity names, processing locations and transfer safeguards for each — is provided to Clients as part of the Aikho Data Processing & AI Compliance Notice on signature of the master services agreement.
| Category | Purpose | Primary data regions |
|---|---|---|
| Cloud infrastructure | Hosting, compute, storage, database, AI/LLM processing | Middle East (primary) / EU (Enterprise tier) |
| Real-time communication | Voice/video interview infrastructure, speech-to-text | EU / USA |
| Candidate sourcing & enrichment | Profile data collection, contact enrichment, social platform integrations | EU / North America |
| Email & communications | Transactional email and candidate communications | USA (EU-US DPF) |
| ATS integrations | Connecting to the Client's applicant tracking system (zero-storage) | North America |
| Application monitoring | Error tracking and performance monitoring (no candidate PII) | USA (EU-US DPF) |
| Billing | Subscription and payment processing (no candidate PII) | USA (EU-US DPF) |
Full sub-processor register
The complete, named sub-processor register is part of our offline Data Processing & AI Compliance Notice (v2.5). Clients receive it with the master services agreement. Prospects under NDA may request a copy at legal@aikho.ai.
Transfer safeguards
All international data transfers rely on Article 46 GDPR safeguards: Standard Contractual Clauses (2021), UK International Data Transfer Addendum, Swiss FADP provisions, or the EU-US Data Privacy Framework where applicable. Transfer Impact Assessments (TIAs) are conducted for transfers to countries outside the EEA without an adequacy decision.
Your Rights
Candidates may exercise the following rights at any time by contacting privacy@aikho.ai. Aikho is the single point of contact for rights requests relating to data Aikho holds. The Client redirects any candidate contact concerning Aikho-held data to Aikho.
| Right | Description |
|---|---|
| Right of access (Art. 15) | Request a copy of all data Aikho holds about you. |
| Right to rectification (Art. 16) | Request correction of inaccurate data. |
| Right to erasure (Art. 17) | Delete your account, profile and all applications at any time. Deletion is applied immediately in live systems and completed within 30 days across backups, subject to any legal retention obligation. |
| Right to object (Art. 21) | Aikho will cease the relevant processing and remove you from active pipelines. |
| Right to portability (Art. 20) | Request an export of your data. |
| Right to withdraw consent (Art. 7) | Withdrawal does not affect the lawfulness of prior processing. |
| Right not to be subject to a solely automated decision (Art. 22) | AI evaluation informs but does not replace human judgment. Request human review of any automated decision that significantly affects you. |
How to exercise your rights
Contact us at privacy@aikho.ai. We will respond within one month for GDPR requests, extendable by two months for complex requests. You may also delete your account at any time through your account settings.
Right to complain
If you believe your data protection rights have been violated, you have the right to lodge a complaint with your local supervisory authority.
US State Privacy Rights
This section applies to residents of US states that grant specific consumer privacy rights, including California (CCPA/CPRA), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA) and Texas (TDPSA). To the extent any state law gives you a right not already covered in Section 9 (Your Rights), this section adds those state-specific rights.
Our role under US state laws
Aikho acts as the "business" (CCPA) or "controller" (other states) of the personal information it collects in connection with its recruitment service. Hiring companies that receive a candidate dossier from Aikho act as a separate business/controller for their own subsequent processing.
No sale, no sharing for cross-context advertising
Aikho does not sell your personal information within the meaning of the CCPA, and does not "share" it for cross-context behavioral advertising. We do not use personal information of candidates for advertising or targeted marketing. We have not sold or shared personal information in the preceding 12 months and have no plans to do so.
Categories of personal information collected
In the preceding 12 months, Aikho has collected the following CCPA categories of personal information about candidates:
- Identifiers (name, email, phone, account ID).
- Customer records (CV, contact details).
- Professional or employment-related information (work history, education, skills, salary expectations).
- Audio, electronic and similar information (AI interview recordings and transcripts — never disclosed to Clients).
- Internet or other electronic network activity (account metadata, authentication events, platform interaction logs).
- Geolocation (approximate location, work region preferences).
- Inferences drawn from the above (AI fit assessment, competency scoring rationale, personality inference where applicable).
We do not knowingly collect "sensitive personal information" as defined by the CPRA, with the exception of audio recordings (limited to evaluation and quality assurance, never used to infer characteristics) and any data the candidate volunteers. Candidates are instructed not to share such data during the AI interview.
Sources, purposes, and disclosures
Sources: directly from the candidate, from publicly accessible professional sources (e.g. LinkedIn), and from the Client where the Client refers a candidate to Aikho.
Business purposes: operating the recruitment service, identifying suitable candidates for Hiring Briefs, transmitting candidate dossiers to Clients with the candidate's agreement, communicating with candidates, service security, audit, debugging, and compliance with law.
Disclosures for a business purpose: to Clients (only with the candidate's agreement and only the dossier), to sub-processors listed in Section 8, and to legal/regulatory bodies where required.
Your US state privacy rights
- Right to know / access the personal information we hold about you.
- Right to correct inaccurate personal information.
- Right to delete personal information we have collected, subject to legal retention requirements.
- Right to portability — a copy of your personal information in a portable format.
- Right to opt out of sale or sharing for cross-context behavioral advertising (not applicable to Aikho — we do neither).
- Right to limit use of sensitive personal information (California): you can request that we limit our use of interview audio to the evaluation purpose.
- Right to opt out of profiling producing legal or similarly significant effects (Virginia, Colorado, Connecticut). You may request human review of any AI-driven decision that significantly affects you.
- Right to non-discrimination for exercising your rights. Aikho will not retaliate against candidates who exercise these rights.
- Right to appeal (Virginia, Colorado, Connecticut): if we refuse to act on your request, you may appeal the decision by writing to privacy@aikho.ai with "Appeal" in the subject line. We will respond within 60 days.
How to exercise your US state rights
Submit a verifiable request to privacy@aikho.ai. We will respond within 45 days (extendable by an additional 45 days where necessary, with notice). To verify your identity, we may ask you to confirm information we already hold about you. You may use an authorized agent to submit a request on your behalf; we will verify the agent's authority.
"Shine the Light" (California Civil Code §1798.83)
California residents may request information about disclosures of personal information to third parties for their direct marketing purposes. Aikho does not disclose personal information for third-party direct marketing purposes.
Notice of Financial Incentive
Aikho does not offer financial incentives in exchange for personal information.
Breach Notification
In the event of a data breach affecting your personal data, we will notify relevant regulatory authorities and affected individuals as required by applicable law.
Where required by GDPR, we will notify the relevant supervisory authority within 72 hours of becoming aware of a qualifying breach. We will notify affected individuals without undue delay when the breach is likely to result in a high risk to their rights and freedoms.
Acceptable Use Policy
This policy prohibits unlawful activity, misuse of AI outputs, and any actions that would compromise the Service's security or integrity.
Prohibited Activities
- Using the Service for any illegal or unauthorized purpose
- Attempting to gain unauthorized access to any part of the Service
- Interfering with or disrupting the integrity or performance of the Service
- Using AI outputs to make discriminatory hiring decisions
- Attempting to reverse engineer or extract proprietary algorithms
- Sharing account credentials with unauthorized parties
Fair Usage & Service Limits
Reasonable Use: The Service, including features described as "unlimited," is provided for normal business recruitment operations. Usage must remain within reasonable parameters consistent with legitimate hiring activities.
Single-Role Integrity: Each active hiring position ("slot") is intended to address a specific, distinct hiring need. Using a single position slot to aggregate disproportionate volumes of candidates for unrelated roles, or to circumvent standard recruitment ratios, is not permitted.
Right to Limit: In the event of excessive traffic, abnormal usage patterns, or activity suggesting usage outside of standard parameters, Aikho reserves the right, at its sole discretion and without prior detailed justification, to:
- Throttle or limit the processing of new assessments for the affected position
- Temporarily restrict the position's visibility to manage infrastructure load
- Request additional information regarding the nature of the hiring activity
High-Volume Operations: Clients anticipating significant deviations from typical usage patterns (e.g., bulk candidate imports, mass assessment campaigns) should notify Aikho in advance to ensure adequate resource allocation.
Consequences of Violations
Violations of this policy may result in suspension or termination of your account, legal action, and notification to law enforcement authorities where appropriate.
