PRIVACY POLICY

Effective Date: August 21, 2026

Sofia HR Inc. ("Sofia HR", "we", "us", or "our") respects user privacy and is committed to transparent and responsible processing of personal data.

This Privacy Policy explains what personal data we collect, how and for what purposes we use it, who we may share it with, how we protect it, and what rights users have regarding their data.

Sofia HR Inc. is registered in the State of Delaware, USA. Registered office: 8 The Green, Suite B, Dover, Kent County, Delaware 19901, USA.

1. Who This Policy Applies To

This Policy applies to:

• visitors to the Sofia HR website;
• representatives and employees of companies using Sofia HR;
• candidates participating in AI online interviews;
• employees of companies involved in shaping the work environment model;
• individuals who contact Sofia HR or request a product demo.

2. What Data We May Process

Depending on how you use Sofia HR, we may process the following categories of data.

Data Provided by the User

This may include:

• first and last name;
• email address;
• phone number;
• company name;
• job title;
• team size;
• job vacancy information;
• content of messages and inquiries;
• other information that the user voluntarily provides to us.

When requesting a website demo, we may also ask for your name, company, job title, phone number, preferred messenger, work email, team size, and number of vacancies.

Candidate Data

When using the Sofia HR platform, the following may be processed:

• information about professional experience;
• details about projects, tasks, and work situations;
• responses during the AI interview;
• information contained in the user's speech;
• interview analysis results;
• profile of working and cognitive patterns;
• compatibility metrics with a specific company, team, or work environment.

Sofia HR is designed to analyze how a person makes decisions and acts in a professional context. The system is not intended to determine a person's "value" or make a general assessment of their personality.

If audio or video is recorded or a transcription is created during the interview process, the respective data may also be processed as part of providing the service. Information about the specific format of recording and storage applies depending on the version of the service used.

3. How We Use Personal Data

We may use personal data for the following purposes:

• providing and maintaining the operation of Sofia HR;
• conducting AI online interviews;
• creating a profile of working and cognitive patterns;
• determining a candidate's compatibility with a specific work environment;
• forming and maintaining a company's work environment model;
• providing results to companies and candidates according to the service settings;
• processing product demo requests;
• communicating with users;
• providing technical support;
• ensuring the security of the platform;
• preventing abuse and fraud;
• analyzing and improving the operation of the service;
• complying with applicable laws;
• protecting the legitimate interests of Sofia HR and third parties.

4. AI Interviews and Profiling

Sofia HR uses artificial intelligence technologies to analyze user responses during an interview.

During the interview, the system may analyze features of how a person:

• makes decisions;
• reacts to changes;
• distributes responsibility;
• explains actions and reasons;
• approaches the resolution of work tasks;
• moves toward results.

Based on this analysis, Sofia HR generates a profile used to assess compatibility with a specific team or work environment.

Sofia HR's results are not a public rating of a person.
Sofia HR does not make final hiring decisions on behalf of the employer. The system's results are intended to support the decision-making process. Companies still independently conduct necessary interviews, evaluate professional skills, and make the final decision.

5. Legal Basis for Processing

Depending on the specific situation, the processing of personal data may be based on:

• user consent;
• the necessity to perform a contract or take steps at the user's request prior to entering into a contract;
• compliance with legal obligations;
• the legitimate interests of Sofia HR or third parties, provided such interests do not override the user's rights and freedoms;
• other grounds provided by applicable law.

If processing is based on consent, the user has the right to withdraw it at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

6. Data Sharing and Transfer

We may share personal data with:

• companies and employers participating in the relevant hiring process;
• providers of technical and infrastructure services;
• providers of analytical and marketing tools;
• professional consultants, auditors, and legal advisors;
• government authorities if required by law;
• other parties if the user has given appropriate permission or if the transfer is necessary to provide the service.

Sofia HR does not sell users' personal data to third parties.
Candidate results are not intended for public disclosure. Access to them is granted within the framework of the relevant process and according to the service settings.

7. Google and Meta

The website may use Google services and Meta tools, including Meta Pixel, for technical analysis of website performance, measuring the effectiveness of advertising campaigns, and understanding user interactions with the site.

Such tools may collect technical information, device details, browser info, actions on the site, approximate location, and other data in accordance with the settings of the respective service.

The use of optional analytical and marketing technologies is carried out in accordance with cookie consent settings, if such consent is required by applicable law.

8. International Data Transfers

Sofia HR Inc. is registered in the USA. Depending on the user's location and the infrastructure used, personal data may be processed or stored outside the user's country of residence.

If data protection laws require specific mechanisms for international data transfers, Sofia HR implements appropriate measures required by applicable law, including contractual or other legally mandated safeguards.

9. Data Retention

We retain personal data no longer than necessary for the purposes for which it was collected, taking into account:

• the nature and volume of the data;
• the purpose of processing;
• the duration of the relationship with the user;
• legal requirements;
• the need to resolve disputes;
• the necessity to ensure security and protect legitimate interests.

Upon expiration of the relevant period, data is deleted, destroyed, or anonymized unless further retention is required by law.

10. Data Security

Sofia HR takes reasonable technical and organizational measures to protect personal data from:

• unauthorized access;
• alteration;
• disclosure;
• destruction;
• accidental loss;
• misuse.

However, no method of transmission over the Internet or electronic storage can guarantee absolute security.

11. User Rights

In accordance with applicable law, including the GDPR (if it applies to the processing of your data), a user may have the right to:

• access their personal data;
• obtain a copy of their data;
• correct inaccurate or incomplete data;
• request the deletion of data;
• restrict processing;
• object to certain types of processing;
• receive data in a portable format;
• withdraw previously provided consent;
• not be subject to a decision based solely on automated processing, if such a right applies;
• lodge a complaint with a competent data protection authority.

To exercise their rights, users can contact Sofia HR using the contact details published on the website.

12. Children's Data

The Sofia HR service is intended for use in a professional and HR context and is not directed at children.

We do not knowingly aim to collect personal data from children without a valid legal basis and the necessary permissions.

13. Changes to the Policy

We may periodically update this Privacy Policy.
When changes are made, the new version will be published on the website with an indication of the effective date.
If changes significantly affect user rights, we may additionally notify users using legally provided methods.