Privacy Policy

Last updated: 2026-10-19

1. Data Controller

The data controller for this website is:
Portalix Management UG (haftungsbeschränkt)
Thalkirchner Str. 103
81371 Munich, Germany
Email: datenschutz@applicant.top
Phone: +49 179 2274171

2. Collection and Storage of Personal Data

2.1 What data is collected?

When using our applicant tracking system, the following data is collected:

Account data: Email address, name, company for account creation
Job postings: Job title, description, requirements (imported from HROnlineManager or manually entered)
Applicant data: Resumes (PDF), name, contact details, qualifications
AI analysis results: Scoring, classifications, summaries

2.2 Legal Basis

Your data is processed based on:

Art. 6(1)(b) GDPR: Contract fulfillment (use of SaaS platform)
Art. 6(1)(f) GDPR: Legitimate interest (platform security)

3. Data Processing Agreement (DPA)

As you process applicant data through our platform, we act as a data processor according to Art. 28 GDPR. A Data Processing Agreement (DPA) is provided upon request.

You as the customer are responsible for:

The lawfulness of collecting applicant data
Informing applicants about data processing
Compliance with retention periods
Deletion of applicant data after completion of the application process

4. AI-Powered Processing

Our platform uses AI for automated analysis of resumes and job postings. To ensure data protection, we use PrivacyProxy:

Before AI analysis: All personal data (names, email addresses, phone numbers, addresses, etc.) is automatically masked by PrivacyProxy
During analysis: The AI (OpenAI) only receives anonymized data without personal reference
After analysis: Results are unmasked by PrivacyProxy

Data protection benefits:

No personal data leaves the EU
OpenAI receives no real names, contact details, or other PII
Full GDPR compliance for AI usage

PrivacyProxy is hosted in Germany and is a service of Portalix Management UG.

5. Storage Duration

Your data is stored as follows:

Account data: Until account termination
Applicant data: According to your settings and legal retention periods (max. 6 months after end of application process recommended)
Billing data: 10 years (legal retention requirement)

6. Your Rights

You have the right at any time to:

Access (Art. 15 GDPR): What data do we have stored about you?
Rectification (Art. 16 GDPR): Correction of incorrect data
Erasure (Art. 17 GDPR): Deletion of your data
Restriction (Art. 18 GDPR): Restriction of processing
Data portability (Art. 20 GDPR): Export of your data
Objection (Art. 21 GDPR): Objection to processing

Contact for data protection inquiries:
Email: datenschutz@applicant.top

7. Hosting & Data Security

Our platform is hosted in Germany/EU. All data is transmitted encrypted (SSL/TLS). We take technical and organizational measures to protect your data.

8. Cookies

We only use technically necessary session cookies for authentication. No tracking cookies are used.

9. Third-Party Service Providers

9.1 Stripe (Payment Processing)

For payments, we use Stripe, Inc. Stripe is certified under the EU-US Data Privacy Framework.

9.2 PrivacyProxy (AI Analysis with Privacy)

For AI-powered analysis, we use PrivacyProxy, our own service by Portalix Management UG. PrivacyProxy masks all personal data before transmission to OpenAI, ensuring no PII is transferred to third-party providers.

Hosting: Germany (EU)
No storage of applicant data
Automatic PII masking before AI processing

9.3 Mailgun (Email Delivery)

For emails, we use Mailgun with EU infrastructure.

10. Right to Complain

You have the right to lodge a complaint with a data protection supervisory authority.

Competent authority:
Bavarian State Office for Data Protection Supervision (BayLDA)
Promenade 18, 91522 Ansbach, Germany
Email: poststelle@lda.bayern.de

11. Changes

We reserve the right to adapt this privacy policy. The current version can always be found on this page.

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