Privacy & Legal Policies

1. Controller & Contact

Data Controller: Aikho Tech FZ-LLC, IN5 Tech, Dubai Internet City, Dubai, UAE.

Privacy Lead: Hugues Pringault — privacy@aikho.com

EU Representative (Article 27 GDPR): Hugues Pringault, Les Hauts Puits, 16150 Chabanais, France — privacy@aikho.com. For data subjects located in the European Economic Area, our EU representative can be contacted at this address or by email.

2. Definitions

• Personal Data: Any information related to an identified or identifiable natural person.
• Processing: Any operation performed on Personal Data.
• Special Categories/Sensitive Data: Data revealing racial/ethnic origin, health, or biometric data (such as a voiceprint).

3. Data We Collect

We collect and process information depending on how you use our services. When you create an account, you authorize us to use your data to provide recruitment and career services, including contacting you about opportunities and sharing your profile with potential employers.

For employers using our services, the relationship is governed by our Data Processing Addendum. We collect only data necessary for our services.

Candidate Data:

This includes information you provide directly or that is collected during your use of the Service, such as:

• Profile & Identity: Full name, contact details, professional background (CV, education, skills, work history), and application information.
• Interview Data: Audio recordings, transcripts, and AI-generated analysis from your interactions. Before any AI interview, you will be clearly informed that you are interacting with an AI system and asked to consent to audio recording. Audio recordings are considered biometric data and require your explicit consent. If you do not consent, you will not be able to proceed with the AI interview for that application. You may contact the hiring organization directly to inquire about alternative assessment methods; the availability of alternatives is at the hiring organization's discretion.
• Behavioral: Job views, application patterns, and AI matching scores.

Recruiter / Employer Data:

This includes your company's information, user account details, and hiring preferences.

Technical & Usage Data:

We automatically collect data about your device, IP address, and how you use the Service, as well as information from cookies for security, analytics, and personalization.

Data from Third Parties:

We may receive data from your employer or other third-party providers. When you choose to authenticate or connect with a third-party service, you authorize us to collect the profile information you have made available through that service. We may also collect publicly available data to enrich your profile.

4. Purposes of Processing (How We Use Data)

We use data for the following purposes:

For Employers (as Processor):

We process candidate application data to enable client-side recruitment activities, including sourcing, screening, and communication. This also includes facilitating communications for a given hiring cycle between a client and their candidate (e.g., follow-ups, status updates, interview scheduling, and requests for information) via channels like email, SMS, and messaging apps.

For You (as Controller):

By creating an account, you authorize Aikho to process your data for recruitment, job search, and career development purposes. All interactions with our Service may be used to improve your experience and help you find opportunities.

• Recruitment Services: Matching your profile with opportunities, sharing your profile with employers, facilitating introductions, and enabling employers to contact you directly.
• Communications: Contacting you via the channels you provide with opportunities, recommendations, and service updates.
• Service Improvement: Using de-identified data for analytics and to improve our services.

Automated Decision-Making (Article 22 GDPR):

Certain operational decisions may be made by our AI agents without direct human intervention at the time of the decision, including pre-screening of CVs based on criteria defined by the hiring organization. These decisions may result in a candidate not being progressed to the next stage. In all such cases:

• The hiring organization retains full visibility over all automated decisions and can review, modify, or reverse them at any time.
• Both the candidate and the hiring organization are informed of the reasoning behind such decisions upon request.
• Candidates may request human review of any automated decision that significantly affects their candidacy by contacting privacy@aikho.com or through their hiring contact.

5. Legal Bases for Processing

We process your data based on the following legal grounds:

• Contract: To provide our services to you and fulfill our agreement with you.
• Consent: Where you have given us specific permission, such as for voice recordings during interviews.
• Legitimate Interests: To improve our services, ensure security, and operate our business effectively, where these interests do not override your rights.
• Legal Obligations: To comply with applicable laws and regulations.

You may contact us at privacy@aikho.com for more information about the specific legal basis for any particular processing activity.

6. Data Sharing & Disclosures

We do not sell Personal Data. We share data with:

• Employers/Recruiters: We share your application data with employers to whom you apply. As a career services platform, we may also proactively submit your profile to hiring organizations you have not applied to when opportunities match your qualifications, facilitate introductions, and transmit your contact information so employers may contact you directly.
• Service Providers/Subprocessors: Cloud infrastructure, email/SMS, payment processors, and AI service providers. See Section 8 for details.
• Corporate Transactions: In the event of a merger or acquisition, under appropriate safeguards.
• Legal/Regulatory Bodies: When required by law.

7. International Data Transfers

• Global Transfers: We may transfer data to our cloud infrastructure provider's data centers in various regions.
• GDPR & UK GDPR: We rely on recognized transfer mechanisms (e.g., Standard Contractual Clauses) as required.
• PIPL Compliance: For data originating from China, we will comply with PIPL requirements, including obtaining separate consent and executing a Standard Contract with the overseas recipient.
• UAE PDPL Compliance: We follow permitted transfer grounds and safeguards.

8. Security Measures

We protect data with industry-standard security measures, including encryption, access controls, network security, and continuous monitoring. Data is logically segregated to prevent unauthorized access.

9. Data Retention

We retain your data for as long as necessary to provide our services and fulfill the purposes described in this policy. Retention periods vary based on the type of data, your relationship with us, and applicable legal requirements.

You may request deletion of your data at any time by contacting us at privacy@aikho.com. Some data may be retained as required by law or for legitimate business purposes.

10. Your Rights

You have rights regarding your personal data, including access, correction, deletion, and objection. For AI-assisted decisions, you may request an explanation and human review. See Section 9 of this document for details on exercising your rights.

11. Children's Data

The Service is not intended for individuals under 18. We do not knowingly collect data from children.

12. 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.

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), Data Processing Addendum, Responsible AI Policy, and Acceptable Use Policy, all of which are incorporated herein by reference and together 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

• "Candidate" means an individual who uses the Service to seek employment opportunities.
• "Employer" or "Hiring Organization" means an organization that uses the Service for recruitment purposes.
• "User Content" means any content you upload or submit 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. User Types & Specific Terms

4.1 Terms for Candidates

By creating an account, you authorize Aikho to provide recruitment and career services on your behalf. This includes using your profile to connect you with employers, proposing job opportunities, facilitating introductions, and enabling employers to contact you directly. All interactions you have with the Service may be used to improve your experience and match you with relevant opportunities.

You acknowledge and agree that:

• Aikho may use your data to provide recruitment services, including sharing your profile with potential employers.
• Aikho may contact you via the communication channels you provide with opportunities and service updates.
• Your data may be processed by AI to provide personalized services.
• You may opt out of communications or request deletion of your account at any time.

4.2 Terms for Hiring Organizations

As a Hiring Organization, you acknowledge and agree that:

• You are responsible for job requirements, hiring criteria, and all hiring decisions made using the Service.
• You must comply with all applicable employment laws when using AI-generated assessments and recommendations.
• Your access to candidate data is governed by your agreement with Aikho and applicable data protection laws.

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 the Data Processing Addendum. By using the Service, you acknowledge that you have read and understood these documents.

Hiring Organizations using the Service to process candidate data are responsible for ensuring they have appropriate legal bases and consents for such processing 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.com. 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.com
• Privacy inquiries: privacy@aikho.com
• Address: Aikho Tech FZ-LLC, IN5 Tech, Dubai Internet City, Dubai, UAE

This policy explains how we use cookies and similar technologies. We use necessary cookies for core functionality, performance cookies for analytics, and optional marketing cookies only with your explicit consent.

Types of Cookies We Use

Managing Your Cookie Preferences

You can manage your cookie preferences at any time through our cookie consent banner or your browser settings. Disabling necessary cookies may affect service functionality.

For users in China, we obtain separate and explicit consent for all non-essential cookies as required by PIPL.

Third-Party Cookies

We may use third-party services that set their own cookies. These third parties have their own privacy policies governing the use of cookies. We do not control third-party cookies.

This addendum governs the processing of Personal Data when Aikho provides services to hiring organizations.

Data Processing Relationship

Aikho acts as Controller for data of registered users and as Processor for certain data provided by hiring organizations. The specific relationship is defined in your agreement with Aikho.

Our Commitments

When processing data on behalf of hiring organizations, Aikho will:

• Process data only as instructed and in compliance with applicable law.
• Implement appropriate security measures.
• Assist with data subject requests and regulatory inquiries.
• Notify you of data breaches without undue delay.
• Delete or return data upon termination as instructed.

Enterprise clients may request a full Data Processing Agreement that includes additional terms and Standard Contractual Clauses.

We implement industry-standard technical and organizational security measures to protect your data, including encryption, access controls, network security, and continuous monitoring.

Our security practices include staff training, background checks, incident response procedures, and regular security assessments. Data is logically segregated to prevent unauthorized access.

We use artificial intelligence throughout our recruitment services. While AI assists with operational tasks, hiring organizations retain control over all consequential hiring decisions. Candidates are informed when AI is used in their application process.

Our Commitments

We are committed to:

• Maintaining human oversight of key hiring decisions
• Testing our systems for bias and fairness
• Providing transparency about AI use in our services
• Complying with applicable AI regulations

Regulatory Compliance

Our AI systems are designed to comply with applicable regulations, including the EU AI Act. We maintain appropriate documentation, oversight mechanisms, and testing procedures as required by law.

We retain Personal Data only as long as necessary for the purposes described in this policy, and in accordance with our legal obligations.

Retention Periods

Retention periods vary depending on the type of data, your relationship with us, and applicable legal requirements. The following are indicative retention periods:

• Candidate Profiles: Duration of your account plus 24 months after account closure, unless you request earlier deletion.
• Application Data: As defined in our agreement with the hiring organization, or 24 months after the hiring cycle concludes.
• Interview Recordings: Up to 12 months, subject to applicable agreements and consent.
• Assessment Data: As defined in our agreement with the hiring organization, or 24 months after generation.
• Business Records: 7 years as required by applicable legal and accounting obligations.

These periods are indicative and may be adjusted based on contractual agreements with hiring organizations or applicable legal requirements.

Data Deletion

We have processes in place to ensure data is deleted when no longer needed. You may request deletion of your data at any time, subject to any legal retention obligations.

We engage subprocessors to deliver our service. To protect our competitive position, we publish subprocessor categories below. A detailed list of specific subprocessors (including legal entity names and locations) is available to our enterprise clients upon request as part of the Data Processing Addendum.

Subprocessor Categories

Transfer Safeguards

All international data transfers are protected by appropriate safeguards, including Standard Contractual Clauses (SCCs) and adequacy decisions where applicable. Transfer Impact Assessments (TIAs) are conducted for all transfers to countries outside the European Economic Area to evaluate the level of data protection in the recipient country.

Depending on your location, you have certain rights regarding your personal data. These rights may vary based on applicable data protection laws.

Your Data Protection Rights

• Access: Request a copy of the personal data we hold about you.
• Rectification: Request correction of inaccurate or incomplete data.
• Erasure: Request deletion of your personal data, subject to legal retention requirements.
• Restriction: Request that we limit how we use your data in certain circumstances.
• Portability: Receive your data in a structured, commonly used format and transfer it to another service.
• Objection: Object to processing based on legitimate interests or for direct marketing purposes.
• Withdraw Consent: Where processing is based on consent, withdraw that consent at any time. Note that withdrawing consent for certain processing (such as voice recordings) may affect your ability to continue with active applications, as the interview cannot be completed without the recording.
• Automated Decisions: Request human review of decisions made solely by automated means that significantly affect you.

How to Exercise Your Rights

To exercise any of these rights, contact us at privacy@aikho.com. We will respond within 30 days (or within one month for GDPR requests, extendable by two months for complex requests).

You may delete your account at any time through your account settings or by contacting us.

Right to Complain

If you believe your data protection rights have been violated, you have the right to lodge a complaint with a supervisory authority in the country where you reside, work, or where the alleged violation occurred.

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.

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.