Privacy Policy

At Cloutra, we believe that the future of global socio-economic growth is powered by the right talent meeting the right opportunity. To achieve this, we have built an AI-driven recruitment suite that prioritizes data integrity, transparency, and security. We are committed to protecting the personal information of our website visitors, our clients, and the candidates who interact with our autonomous agents.

This Privacy Policy (the "Policy") is designed to provide a transparent overview of how Cloutra ("we," "us," or "our") collects, uses, processes, and safeguards personal information. Whether you are a recruiter looking for "Decision-Ready Intelligence" or a candidate participating in a "Competency Assessment," this document outlines your rights and our obligations under global data protection frameworks, including the GDPR (General Data Protection Regulation).

Cloutra operates as an Advantageous Force Multiplier. Our mission is to collapse the screening cycle and eliminate manual drudgery through 100% accurate, standardized evaluation. In doing so, we adhere to the following core privacy principles:

• Transparency: We are clear about how our AI evaluates candidate responses against specific scorecard weights.
• Purpose Limitation: We only collect the data necessary to verify experience authenticity and facilitate the hiring process.
• Security by Design: We implement enterprise-grade technical safeguards to ensure your data remains protected throughout the 24/7 recruitment workflow.

This Policy applies to all personal information collected through our website (cloutra.ai) and our AI Recruitment Suite. By using our platform or participating in an AI-led interview, you acknowledge the practices described in this Policy.

Cloutra acts as a Data Controller when we determine the purposes and means of processing personal data for our own business operations. This applies to:

• Website Visitors: Individuals browsing cloutra.ai.
• Direct Clients: Individuals or representatives of companies who purchase a subscription or sign up for a demo.
• Marketing: Individuals who subscribe to our newsletters or professional insights.

In these instances, Cloutra is responsible for managing your data and responding directly to your privacy requests.

Cloutra acts as a Data Processor (or "Service Provider") when we provide our AI Recruitment, ATS Grading, and AI Interviewer services to our Clients (Employers and Recruiters).

• The Client is the Data Controller: The employer using Cloutra to fill a role is the one who decides which candidates to invite, what "Scorecard Weights" to apply, and how long to store the results.
• Cloutra's Role: We process candidate data (resumes, interview recordings, and scores) strictly according to the Client's instructions.

If you are a candidate applying for a job through a company that uses Cloutra:

• Your primary legal relationship regarding your data is with the Employer.
• If you wish to access, correct, or delete the data submitted during your application or AI Interview, you should direct your request to the Employer first.
• Cloutra will assist the Employer in fulfilling these requests as required by our data processing agreements and applicable law.

• Contact & Identity Data: Name, email address, phone number, and physical address (if provided).
• Professional History (The "ATS Data"): Resumes, CVs, cover letters, and portfolios. This includes your work history, education, skills, and certifications.
• Multimedia Assessment Data: Video recordings captured during the Interview Assessment phase.
• Self-Reported Data: Responses to evaluation questions.

• Technical Data: IP address, browser type, device identifiers, and operating system. We use this to ensure the security and integrity of the interview process.
• Usage Data: Information about how you interact with the Cloutra platform, such as the duration of an interview session or the features used within the dashboard.
• Cookies & Tracking: We use essential cookies to maintain your session and analytical cookies to improve platform performance. (See our Cookie Policy for details).

As an AI-first platform, we generate data derived from your primary inputs:

• Transcription Data: Text-based transcriptions of your video/audio interview responses.
• Evaluation Metadata: Scoring markers based on your employer's specific "Scorecard Weights."
• Competency Markers: AI-detected indicators of experience authenticity.

Cloutra does not actively seek "Special Categories" of data (e.g., health, religion, or political affiliation) unless explicitly required by an employer for diversity and inclusion monitoring and permitted by local law. We encourage candidates not to include sensitive personal information in their resumes or interview responses.

We use Identity and Professional Data to power our AI Recruiter and ATS Grader. This includes:

• Sourcing & Engagement: Identifying and contacting potential talent to maintain "24/7 Recruitment Momentum."
• Automated Screening: Comparing resumes against specific job descriptions to "Collapse the manual drudgery" of initial vetting.

Multimedia and Transcription data are used to facilitate the AI Interviewer phase:

• Interview Execution: Conducting interactive, autonomous video interviews.
• Experience Verification: Analyzing responses to verify "Experience Authenticity."
• Standardized Scoring: Applying your predefined "Scorecard Weights" to ensure "100% Accurate Evaluation" across all candidates.

We process and aggregate data to provide Recruiters and Employers with actionable outputs:

• Executive Summaries: Generating brief, high-level overviews of candidate potential.
• Ranked Shortlists: Organizing candidates based on objective performance metrics to accelerate final hiring decisions.

• Proctoring & Fraud Prevention: Ensuring the person interviewed is the person who applied and preventing unauthorized platform use.
• System Optimization: Analyzing usage patterns to improve AI accuracy and "Humanize" the digital interaction experience.

For our direct clients and website visitors, we use data to:

• Manage accounts and billing.
• Respond to inquiries and provide technical support.
• Send professional insights and product updates (where consent is provided).

Cloutra's AI processes data through two primary modules:

• The ATS Grader (Resume Analysis): The AI extracts key skills, work history, and educational milestones from your resume and compares them against the Employer's specific Scorecard Weights.
• The AI Interviewer (Competency Assessment): During video interviews, the AI analyzes your verbal responses and looks for Experience Authenticity by comparing your answers to industry-standard benchmarks.

Our AI is designed to provide 100% Accurate Evaluation. Unlike human recruiters, who may be influenced by fatigue or unconscious bias, Cloutra applies the exact same logic and scoring criteria to every candidate in the pipeline.

While Cloutra provides "Decision-Ready Intelligence," we do not make final hiring or firing decisions.

• The AI as a Filter: The AI ranks and highlights top talent based on data.
• The Human as the Decider: The final selection, interview, and job offer are always conducted by a human recruiter or hiring manager.

• Continuous Calibration: We regularly audit our models to ensure they align with the provided Scorecards.
• Verification Metrics: We provide recruiters with transcriptions and video recordings so they can manually verify any AI-generated insight before taking action.

• Candidate Interviews: When you participate in a Competency Assessment, you provide consent for Cloutra to record your audio/video and analyze your responses.
• Marketing: When you sign up for our newsletter or professional insights, we rely on your consent to send you communications.
• Withdrawal: You have the right to withdraw your consent at any time, though this may impact your ability to continue in a specific recruitment process.

• Service Delivery: For our Clients, we process data to provide the "AI Recruitment Suite" features they have subscribed to.
• Application Process: For Candidates, processing your resume is a necessary step to facilitate your job application with the Employer.

• Hiring Efficiency: Helping Employers "Collapse the manual drudgery" of recruitment to find top-tier talent faster.
• Platform Security: Detecting and preventing fraud or proctoring violations during AI interviews.
• Product Improvement: Analyzing anonymized data to refine our "Decision-Ready Intelligence."

In rare cases, Cloutra may be required to process or disclose personal data to comply with a legal obligation, such as a court order, government request, or to protect our legal rights.

• Standard Cycle: Typically, data is retained for the duration of the recruitment process for a specific role.
• Extended Talent Pools: If an Employer wishes to keep your profile for future opportunities, they may retain your data for a longer period, subject to your consent or their legitimate interest.
• Candidate Requests: If you wish to have your data removed from an Employer's database, you must contact that Employer directly.

• Account Data: Retained for as long as your account is active or as needed to provide you with our AI Recruitment Suite.
• Marketing Data: Retained for marketing purposes until you unsubscribe or withdraw your consent.
• Technical Logs: Server logs and proctoring metadata are typically purged or anonymized within 6 to 12 months, unless required for ongoing security investigations.

Once the retention period expires, or upon a valid deletion request, Cloutra employs industry-standard protocols to:

• Permanently Delete: Irreversibly remove the data from our active production servers.
• Anonymize: Convert data into a non-identifiable format to be used strictly for improving AI accuracy.

Notwithstanding the above, Cloutra may retain certain information for longer periods if required to comply with legal obligations, resolve disputes, or enforce our agreements.

• Data at Rest: All personal information, including resumes, video recordings, and AI-generated scores, is stored using Advanced Encryption Standard (AES-256).
• Data in Transit: Information exchanged between your device and our platform is encrypted using Transport Layer Security (TLS 1.2 or higher).

• Internal Access: Access to candidate data is strictly limited to authorized Cloutra personnel who require it for platform maintenance or technical support.
• Client Access: Employers only have access to the data of candidates who have applied for their specific roles, enforced via role-based access control (RBAC).

• Session Validation: Ensuring the interview environment remains secure and the candidate's identity is verified throughout the session.
• Audit Logs: Maintaining a digital paper trail of all data processing activities for compliance audits.

• Continuous Monitoring: We conduct regular security scans and vulnerability assessments to identify and mitigate potential threats in real-time.
• Incident Response: In the unlikely event of a data breach, Cloutra has a robust incident response plan to notify affected Data Controllers and regulatory authorities in accordance with applicable laws.

While we implement rigorous safeguards, the security of your data also depends on your actions. We encourage Clients to use strong passwords and protect their login credentials to ensure the integrity of their Cloutra dashboard.

By using our platform, participating in an Interview Assessment, or submitting a resume to the ATS Grader, you acknowledge that your personal information will be transferred to our servers in the United States. The data protection laws in the US may differ from those in your country of residence; however, Cloutra implements rigorous safeguards to ensure your data remains protected to a standard equivalent to your local regulations.

Regardless of where your data is processed, Cloutra applies the same Security-First architecture described in Section 8. We ensure that our US-based development and hosting environment remains a secure Advantageous Force Multiplier for recruiters worldwide.

You have the right to request a copy of the personal information Cloutra holds about you, including your contact details, resume data, and interview transcriptions.

If you believe any information we hold is inaccurate, you have the right to request a correction to ensure our accurate evaluation is based on up-to-date data.

You may request that we delete your personal information. Note for Candidates: Since Cloutra often acts as a Data Processor, if you want your application deleted from a specific company's records, you should contact that Employer directly.

You have the right to object to the processing of your data or ask us to restrict how we use it, including the right to object to Automated Decision-Making (Section 5). If you prefer not to be evaluated by an AI, you may request a manual review from the Employer.

• The Right to Know: What categories of data we collect and whether it is sold or shared (Cloutra does not sell your personal data).
• The Right to Opt-Out: Of any future sale of information, though Cloutra operates on a service-fee model, not a data-selling model.
• Non-Discrimination: We will not provide a different level of service if you choose to exercise your privacy rights.

To make a request regarding your data, please contact us at privacy@cloutra.ai. To protect your privacy, we will take steps to verify your identity before granting access or making changes.

We do not knowingly collect, maintain, or process personal information from children. If you are under the age of 18, please do not attempt to use our AI Recruitment Suite or participate in an Interview Assessment.

If we become aware that we have inadvertently collected personal information from a child under the age of 18 without verifiable parental consent, we will take immediate steps to deactivate the associated account and delete the data from our servers. If you are a parent or legal guardian and believe your child has provided personal information to Cloutra, please contact us at info@cloutra.com.

As a Hiring Facilitator, Cloutra encourages employers to ensure their job postings and recruitment cycles are directed toward candidates who meet the legal age requirements for employment in their respective regions.

If you have any questions, concerns, or requests regarding this Privacy Policy, our AI evaluation methods, or your personal data, please reach out to our privacy team.

• Email: info@cloutra.com
• Cloutra AI, Inc., United States

Cloutra has appointed a Data Protection Officer to oversee our global compliance with GDPR and other data protection frameworks. You may contact the DPO directly at dpo@cloutra.ai.

If you have identified a potential vulnerability within the Cloutra AI Recruitment Suite, please contact security@cloutra.ai.

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by updating the effective date at the top of this policy and, where appropriate, sending a notification via the Cloutra Dashboard or email.

By continuing to use the Cloutra platform, you acknowledge that you have read and understood this Privacy Policy.