Privacy policy
Last updated
What data of yours we process, on what legal basis, how long we keep it, who else receives it and how to exercise your rights. Whatever another page already publishes is referred to rather than repeated, so the two can never contradict each other.
This policy does not repeat the facts Transparency already derives from the code itself: the purposes, the retention periods and the list of providers live there and are cited from here.
Who is responsible for your data
The controller is MatchAccuracy. Its identification details —company name, tax number and registered address— are published in the legal notice, which is where article 10 of the Spanish information society services act requires them, and are not repeated here.
- Contact for data matters
- datos@matchaccuracy.com
No data protection officer has been appointed.
What data we process, and where it comes from
We process four groups of data, and not all of it comes from you.
- What the person inviting you gives us
- Your name and your email address reach us from the recruiter who invites you, before you have given us anything.
This is the case covered by article 14 GDPR, and that is why it is said here: the first time we know of you, you have written nothing.
- What you give us
- Your CV, your answers to the test and, if you request one, the explanation with which you ask for an adjustment.
- What the test produces while you take it
- The video and audio of the session, one camera frame per answer and the irregularity signals: window switching, multiple tabs and a disconnected camera.
- What the identity check produces
- The result of comparing a frame from your camera with the photo on your identity document, and the two facial crops that were compared.
This is biometric data: a special category under article 9 GDPR.
Why we process it, and on what basis
The purposes are the ones Transparency publishes and are not extended here. What this page adds is the legal basis for each of them, which is written nowhere else.
- Assessing your answers for the role
- Pre-contractual measures (art. 6(1)(b))
- Reading your CV to prepare the recruiter's file
- Pre-contractual measures (art. 6(1)(b))
- Detecting and documenting irregularities during the test
- Legitimate interest in the integrity of the process (art. 6(1)(f))
- Checking that the person taking the test is you (1:1 match)
- No applicable art. 9(2) exception — see the explanation below
- Showing your portrait in the recruiter's list
- Legitimate interest, with a written balancing test (art. 6(1)(f))
- Storing your city when the role requires being on site
- Pre-contractual measures (art. 6(1)(b))
- Keeping your CV for future processes
- Your consent, separate and revocable (art. 6(1)(a))
The facial match processes biometric data and is mandatory: the test cannot start without it. That is why it does not rely on your explicit consent (art. 9(2)(a)): consent you cannot refuse without losing the service is not freely given (arts. 4(11) and 7(4)). And we have not identified any other article 9(2) exception that covers this processing. The controller has decided to keep the match with that gap stated and to accept the risk it carries, rather than publish a basis its own impact assessment contradicts. It is said here because it is what there is, and because you are better off knowing: you can complain to the Spanish data protection authority on this very ground, through the route in the rights section.
What the system decides on its own
No artificial intelligence assesses you, scores you, ranks you or filters you. The questions are written by a person, marking is deterministic and approval is always human. What does happen without human intervention is this, and that is why it is said.
- Automatic disqualification by result
- If the percentage of correct answers falls below 80%, the system marks the application as not validated. It is a software rule written in the code, not a model.
- Automatic disqualification for an incomplete test
- Abandoning the test, disconnecting the camera or connecting a second screen produce the same result, by the same route.
- Approval is never automatic
- No path approves anyone on its own: when there is no disqualification, the application waits for a person to review it.
- A facial match that does not agree rejects nobody
- It flags the application for human review.
On any of these decisions you can ask for human intervention, express your point of view and contest it (art. 22(3) GDPR), through the route in the rights section.
What is read from your CV, and what is guessed
Fields written in the CV are extracted from it: name, email, phone, years of experience, date of first job, public GitHub and LinkedIn profiles, roles held, and a speciality and tags from a closed list supplied by the client. There are also two fields the model does not read but produces, and they are declared because saying otherwise would be inaccurate.
- Sex
- If the CV does not state it, it is inferred from the given name. It is a guess, not a reading, and it plays no part in the decision: the file the recruiter uses to decide does not show it.
- Inconsistencies
- Free prose in which the model flags gaps or contradictions in the history. It is the only output that reads as a caution about the person; it does not score or rank, and the decision remains human.
On both of them you can exercise rectification and objection as on any other data.
How long we keep each thing
Each class of data has its own period and the moment it starts counting from. These periods are the ones the system executes: they are read from the same module that applies them, and a test in this repository turns red if the published table and the module diverge.
The two classes that are a special category under article 9 —the facial match with its crops, and the adjustment request— carry the shortest periods in the table: 72 hours and 30 days.
The full table, class by class:
The table says at what point each class is deleted. It does not say whether the sweep for your class has already run: that is a different question, and this page does not answer it until it can answer it with a fact.
Who else receives your data
The providers involved in the processing, what they do it for, what they receive and where they are, are named in Transparency and only there. The list is derived from the code.
The full list, provider by provider:
We do not sell your data and we do not disclose it to anyone outside that list. The only lookup that leaves it is the VAT number check of a company against the European Commission public registry, which receives no candidate data.
There is a transfer outside the European Economic Area, and it reaches three of the recipients. None of the three receives your CV, the session video or anything from the facial match, and each one carries its stated safeguard —standard contractual clauses, and two of them are also certified under the EU-US adequacy framework—. The model that reads your CV never leaves the European Economic Area: it is always invoked through a European inference profile that routes to six regions, all of them in the Union.
Your rights
You can exercise, at any time and without giving reasons, the rights of access, rectification, erasure, objection, restriction and portability, and you can also ask for a person to review a decision that affects you.
We answer within the legal period of one month. Losing the link to your test takes no right away from you: your email address is enough to find you.
How to exercise them:
And if we do not answer, or the answer does not satisfy you, you can complain to the Spanish data protection authority (www.aepd.es).
Changes to this policy
When it changes, the date of the last update will be published and, if the change affects what we do with data we already hold, notice will be given by email before it is applied.