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Privacy Policy

How C-Factor AI collects, uses, and protects your data. Written to be readable, not evasive.

EFFECTIVE · JANUARY 15, 2026 · VERSION 1.0
 
  • Draft note for the C-Factor AI team: This is a policy template that reflects standard SaaS practice, GDPR requirements, and C-Factor AI's ethical positioning. Have your legal counsel review before publishing. Specific jurisdictional requirements (CCPA, LGPD, PDPA, etc.) may need to be added based on your target markets.
Section 01

Introduction

C-Factor AI is a product of The Talent Games, a global talent assessment technology company with headquarters in Dubai, UAE, and operations across Asia, MENA, Europe, and the Americas.

Data controller: The Talent Games FZ-LLC, with registered address in Dubai Media City, Dubai, United Arab Emirates. For customers based in the European Economic Area, our EU representative can be reached at the contact details in Section 14.

  • Our summary in one line: we collect what we need to run the platform, we don't sell your data, and candidates keep meaningful rights over their information.
Section 02

Who we are

C-Factor AI is a product of The Talent Games, a global talent assessment technology company with headquarters in Dubai, UAE, and operations across Asia, MENA, Europe, and the Americas.

Data controller: The Talent Games FZ-LLC, with registered address in Dubai Media City, Dubai, United Arab Emirates. For customers based in the European Economic Area, our EU representative can be reached at the contact details in Section 14.

Section 03

Information we collect

Information you give us directly

When you contact us, request a demo, sign up for our platform, or take an assessment or interview, we collect:

  • Identity data: name, email address, job title, company, country
  • Contact data: phone number, professional address (if provided)
  • Assessment & interview data: for candidates, your responses to assessments, video and audio recordings of interviews, and the AI-generated scoring and analysis of those responses
  • Communications: messages you send us through email, forms, or our platform

Information we collect automatically

When you use our website or platform, we may automatically collect:

  • Device and browser data: IP address, browser type, device type, operating system, language
  • Usage data: pages viewed, features used, timestamps, referrer URLs
  • Cookie and tracking data: as described in Section 11

Information from third parties

If your employer uses C-Factor AI as part of their hiring process, we receive your contact information and the role details from them. If we integrate with an ATS (Applicant Tracking System) or HRIS on behalf of a customer, we may receive candidate information through that integration.

Section 04

How we use it

We use the information we collect to:

  • Provide the platform: delivering assessments, running interviews, generating candidate reports, and enabling recruiters and hiring managers to review and act on results
  • Communicate with you: responding to inquiries, scheduling demos, sending platform notifications, and providing customer support
  • Improve the platform: analysing usage patterns, testing new features, and refining our AI models — with important limits described in Section 6
  • Marketing (with consent): sending occasional updates about product features, industry insights, and events, if you have opted in
  • Legal compliance: meeting our obligations under applicable law, including responding to legitimate requests from regulators and authorities

We do not sell your personal data. We do not use candidate assessment data to train models for other customers without explicit consent.

Section 05

Legal basis for processing

Under the EU General Data Protection Regulation (GDPR) and similar laws, we process personal data on one of the following bases:

  • Contract: to deliver the services our customer (your employer, in the candidate case) has contracted us to provide
  • Consent: for marketing communications, optional cookies, and any use of your data that requires explicit consent under applicable law
  • Legitimate interests: to run and improve our platform, provided our interests do not override your rights and freedoms
  • Legal obligation: to meet requirements under tax, employment, and regulatory law

Where consent is the basis, you can withdraw it at any time by contacting us or using the unsubscribe link in any marketing email.

Section 06

Candidate data — a special note

If you are a candidate taking an assessment or interview through C-Factor AI, you should know how your data is handled specifically:

  • Your data belongs to the hiring employer, not to us. We process it on their behalf as a data processor. Your employer (the “controller”) decides what happens with your data, how long they keep it, and whether they share it with you.
  • C-Factor AI never rejects candidates on its own. Every hiring decision is reviewed and made by a human at the employer. We produce scored recommendations; humans decide.
  • We do not use your data to train models for other customers without your explicit and separate consent.
  • You can request access to your interview score and its explanation from the hiring employer. Under GDPR (and similar regimes), you have a right to know how automated decisions about you were made.
  • You can request deletion of your data at any time by contacting us or the hiring employer.

For more on our ethical AI framework, see our Ethical AI page.

  • Candidates first. If your data rights conflict with a customer's business preference, we err on the side of candidate rights. This is a principle, not a policy we can be talked out of.
Section 07

How we share your information

We share data only in the following circumstances:

  • With your employer (candidates only): Assessment and interview results are shared with the hiring team at the employer that invited you. This is the whole point of the process, and it is disclosed to you before you take the interview.
  • With service providers: We use trusted third-party providers to run our platform — cloud hosting (AWS), analytics, email delivery, and support tools. These providers are bound by data processing agreements and can only use your data on our instructions.
  • With legal or regulatory authorities: Where required by law, court order, or regulatory investigation.
  • In a business transaction: If The Talent Games is acquired, merged, or reorganised, your data may be transferred as part of that transaction. You will be notified of any material change in ownership or use of your data.

We do not share personal data with advertisers, data brokers, or unrelated third parties.

Section 08

International data transfers

C-Factor AI operates globally. We offer regional data residency for enterprise customers, with hosting in the EU, UK, UAE, Singapore, and US on AWS enterprise infrastructure.

Where personal data is transferred outside the European Economic Area, we rely on:

  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • Adequacy decisions where they exist
  • Additional safeguards as required by supervisory authorities and the Schrems II ruling

Enterprise customers can request full technical and organisational details under NDA.

Section 09

Data retention

How long we keep your data depends on the type of data and the legal basis for processing:

  • Website visitor data: up to 24 months after your last visit, unless you request earlier deletion
  • Customer platform data: for the duration of the contract, plus a defined post-termination window (typically 90 days) unless a longer period is legally required
  • Candidate assessment and interview data: retention is configured by the hiring employer, typically 90 days to 2 years. Candidates can request earlier deletion at any time.
  • Marketing lists: until you unsubscribe, or after 3 years of no engagement
Section 10

Your rights

Depending on where you live, you have some or all of the following rights over your personal data:

  • Right of access: know what data we hold about you and get a copy
  • Right to rectification: correct inaccurate or incomplete data
  • Right to erasure (“right to be forgotten”): request that we delete your data
  • Right to restrict processing: ask us to pause how we use your data
  • Right to data portability: receive your data in a machine-readable format
  • Right to object: to processing based on legitimate interests, and to direct marketing
  • Right to withdraw consent: at any time, without affecting the lawfulness of past processing
  • Right to lodge a complaint: with your local data protection authority

To exercise any of these rights, contact us at the address in Section 14. We will respond within 30 days.

Section 11

Cookies & tracking

We use cookies and similar technologies to run our website, remember your preferences, and understand how visitors use the site. We use three broad categories:

  • Strictly necessary cookies: for the site to function. These cannot be turned off.
  • Analytics cookies: to understand aggregate usage patterns and improve our content. You can opt out.
  • Marketing cookies: to measure campaign performance and personalise messages. Only set with your consent.

You can manage your cookie preferences through our cookie banner at any time. See our Cookies Policy for a full list of cookies used.

Section 12

Security & children's privacy

Security measures

We take security seriously. Our platform is hosted on AWS enterprise infrastructure with encryption at rest and in transit. We hold ISO 27001 certification, undergo regular penetration testing, and maintain incident response processes with defined response times.

No system is perfectly secure. If a data breach occurs that materially affects your data, we will notify you and the relevant supervisory authorities within the timeframes required by law (72 hours under GDPR).

Children’s privacy

C-Factor AI is a B2B product and is not directed at children under 16 (or the equivalent age in your jurisdiction). We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, contact us and we will delete it promptly.

Section 13

Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will change the “Effective” date at the top and, for material changes, notify you by email (if we have your address) or through a prominent notice on the website.

Historical versions of this policy are available on request.

Section 14

Contact us

Questions, requests, or complaints about this Privacy Policy or how we handle your data? Reach us at the contacts below. We aim to respond within 5 business days.

GENERAL INQUIRIES

Privacy, data rights, or general questions

SALES INQUIRIES

Enterprise contracts, DPAs, or evaluation