Privacy Policy

Last Updated: 2024-12-29

1. Introduction

This Privacy Policy explains how Woberry AB ("we", "us", or "our") collects, uses, and protects your personal information in compliance with GDPR and Swedish data protection laws.

By using our services, you agree to the practices described in this policy.

2. Data We Collect

We collect:

● Account Information: Name, email, contact details

● Resume/CV Data: Employment history, education, skills

● Usage Data: Feature usage, preferences, settings

● Technical Data: IP address, device information, cookies

● Payment Data: Processed securely by Stripe (we never store full payment details)

3. How We Use Data

● Provide and improve our services

● Personalize your experience

● Process payments

● Communicate service updates

● Analyze usage patterns

● Prevent fraudulent activity

4. Data Retention

We retain different types of data for different periods:

● Account information: As long as your account is active, plus 12 months after account closure

● Resume/CV data: As long as your account is active, plus 3 months after account closure (unless you request earlier deletion)

● Usage data: 24 months from collection

● Technical data: 12 months from collection

● Payment data: As required by Swedish accounting law (7 years for transaction records)

5. AI Processing of Resume Data

Our service utilizes artificial intelligence technology, including ChatGPT, to help users create and enhance resumes and cover letters. Here's how we process your data with AI:

● AI Data Processing: When you use our AI assistance features, your inputs and existing resume data may be processed by our AI systems to generate content suggestions.

● Third-Party AI Providers: We may use services from OpenAI or similar providers. When using these services, limited data may be transmitted to these providers solely for the purpose of generating responses.

● Data Minimization: We implement techniques to limit the personal data shared with AI providers to what is strictly necessary for the service.

● AI Training: Your resume data is NOT used to train the underlying AI models. We implement controls to prevent your personal information from being used for AI model training.

● AI Content Storage: Drafts and iterations created during the AI assistance process are stored according to our general data retention policies in section 5.

7. Data Sharing

We may share data with:

● Payment processors (Stripe)

● Cloud service providers

● Legal authorities when required by Swedish or EU law

● Third parties only with your explicit consent

● AI service providers (such as OpenAI) when you use our AI-assisted resume building features

We never sell your personal data.

8. Data Security

We implement measures appropriate to the nature of the data and our organization size, including:

● Encryption of sensitive data at rest and in transit

● Access controls and authentication

● Incident response protocols

● Confidentiality agreements

● Data processing agreements with our third-party processors

● Periodic security reviews

9. International Data Transfers

Some of our service providers, including NeonDB and Vercel, may process and store your personal data outside the European Economic Area (EEA).

The following categories of data may be transferred internationally:

● Account information

● Usage data

● Technical data

For such transfers, we rely on:

● Standard Contractual Clauses (SCCs) approved by the European Commission

● Additional technical safeguards where possible, such as encryption and pseudonymization

● Vendor commitments regarding data access controls

● AI service provider data (when using resume building AI features)

We have conducted a transfer impact assessment for our major service providers and continue to monitor the legal landscape regarding international data transfers.

You can request information about these safeguards by contacting us using the details in section 12.

10. Your Rights

Under GDPR, you have the right to:

● Access your data

● Request correction

● Delete data

● Restrict processing

● Data portability

● Withdraw consent

● Lodge complaints with Integritetsskyddsmyndigheten (Swedish Data Protection Authority)

● Specifically for AI-processed data, you can request information about what resume data has been processed using AI technologies and opt out of AI processing while still using our manual resume tools.

We will respond to your requests within 30 days.

11. Cookies & Tracking

We use:

● Essential cookies (session management)

● Analytics cookies (Plausible Analytics)

● Preference cookies

Manage settings via cookie banner or browser controls

12. Children's Privacy

Our services are not intended for individuals under 18 years of age.

We do not knowingly collect personal information from children.

If we become aware that we have collected personal data from a child without parental consent, we will take steps to delete that information.

13. Policy Changes

● We will notify you of material changes via email or website notice at least 14 days before they take effect

● Material changes that significantly affect your rights will not be applied retroactively without your consent

● Continued use after changes take effect constitutes acceptance

● Previous versions will be archived and available upon request

14. Contact Us

Email: support@woberry.com

Postal Address:

Woberry AB

Perstorpsvägen 6

392 40 Kalmar, Sweden