1) Scope and roles

This Notice describes how SMPG processes personal data in the demo environment of TalentFit. For enterprise deployments, a separate DataProcessingAddendum (DPA) may apply. In the demo, SMPG is the controller of your data.

2) What we collect

• Account & access data: name (if provided), email, organization, role, access code, support messages.
• Assessment content: audio/video recordings, transcripts, text answers, timing, re-tries, microphone checks.
• Derived data: model features, embeddings, competency scores, confidence bands, quality and integrity signals.
• Device & usage data: IP address, approximate location, device/browser type, OS, settings, language, session identifiers, pages viewed, referral source, clickstream, crash logs.
• Cookies & similar tech: to keep you signed in, store preferences, run analytics, and prevent abuse. See Cookies below.

3) Why we process your data (lawful bases)

• Provide the Service: run the assessment, generate scores, and deliver results (contract/legitimate interests).
• Support & communication: respond to inquiries, provide onboarding and updates (contract/legitimate interests).
• Research & product improvement: develop, test, and improve models, prompts, and UX (legitimate interests; consent where required).
• Safety & integrity: detect abuse, fraud, bots, prompt-injection, or cheating; secure the Service (legitimate interests).
• Compliance: meet legal obligations and enforce our Terms (legal obligation/legitimate interests).

4) Sharing of data

We share data with:

• Service providers (processors) for hosting, storage, analytics, communications, transcription, and support, bound by contract to use data only as instructed.
• Your organization, if you access through an employer-provided code or email domain, for demo administration and evaluation results.
• Authorities, when required by law or to protect rights, safety, and security.
• Successors, in connection with a merger, acquisition, or corporate transaction.

We do not sell personal data.

5) International transfers

We may transfer data internationally. Where required, we use safeguards such as the EU Standard Contractual Clauses or UK IDTA.

6) Retention

We keep demo data for 90 days from your last activity, then delete or de-identify it, unless we need it longer for security, debugging, or legal reasons. Aggregated, non-identifiable data may be kept to improve the Service.

7) Your rights

Depending on your location, you may have rights to access, correct, delete, restrict, object, or export your data, and to withdraw consent. You may also have the right to opt out of automated decision-making where it has legal or similarly significant effects. Contact legal@smpgadvisors.com to exercise rights. We will verify your identity and respond within the time required by law.

8) Children

The Service is not directed to children under 16 (or the age defined by local law). Do not use the Service if you are under that age.

9) Security

We use administrative, technical, and physical safeguards appropriate to the risk (e.g., encryption in transit, access controls, logging, and least-privilege access). No system is perfectly secure.

10) Automated analysis and fairness

TalentFit uses AI/ML to analyze responses and produce scores. We evaluate models for quality and fairness and include human-in-the-loop options. Final employment decisions should not be based solely on automated outputs.

11) Cookies

• Strictly necessary: session management, security, access control.
• Functional: remembering settings.
• Analytics: understanding usage to improve the Service.

You can control cookies via your browser settings. Some features may not work without certain cookies.

12) Third-party links

The Service may link to third-party sites. We are not responsible for their privacy practices.

13) Changes to this Notice

We may update this Notice. The “Effective date” shows when changes took effect. Material changes will be highlighted in-product or by email where appropriate.

14) Contact us

Privacy questions or requests: legal@smpgadvisors.com.