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Effective date: 2026-04-23. Last updated: 2026-04-23.
This Privacy Policy explains how Vaibhav Kadam, operating CVCL as a sole proprietor ("we", "us", the "Controller"), collects, uses, and shares information when you use the CVCL service at cvcl.online (the "Service"). It is written to satisfy the requirements of the EU General Data Protection Regulation ("GDPR"), the UK GDPR, and the California Consumer Privacy Act / California Privacy Rights Act ("CCPA / CPRA"). By using the Service you agree to this policy and to our Terms of Service.
Vaibhav Kadam, sole proprietor, with a registered address at Bank Colony Street, Vita - 415311, Maharashtra, India, is the data controller for personal data processed through the Service. You can contact us about anything in this policy at vaibhav.kadam@cvcl.app.
Under GDPR every category of personal data must have a lawful basis (Art. 6, and Art. 9 for special categories). Here is ours:
| Category | Examples | Lawful basis (GDPR Art. 6) |
|---|---|---|
| Account data | Email, password hash (bcrypt), display name, Google profile photo URL when you sign in with Google. | Contract (b), needed to provide the Service. |
| CV / resume content | The files you upload, parsed JSON, edits made in the editor, generated tailored CV + cover letter PDFs / DOCX. | Contract (b), this is the Service. |
| Job descriptions you paste | Free-text JD, company name, role, location, and job-scanner search criteria. | Contract (b). |
| Voice recordings + transcripts (mock interview) | Audio of your interview session and the bot's responses, the speech-to-text transcript, and the LLM feedback document derived from it. | Contract (b) + your consent (a) at the point you click "Start mock interview". You may delete the recording at any time from the session page. |
| Payment metadata | Razorpay payment ID, amount, currency, status. We never see your card or bank details. | Legal obligation (c), accounting / tax records. |
| Usage logs | IP address, user-agent, request paths, timestamps, generation cost / token counts. | Legitimate interests (f), security, abuse prevention, debugging, capacity planning. |
We do not knowingly collect special categories of personal data (Art. 9 GDPR, health, religion, political opinions, etc.). If your CV happens to mention such data, we process it only insofar as needed to render your CV.
We do not train machine-learning models on your content. We do not sell or rent your personal data to anyone.
We use a small, stable set of third-party processors. Each is bound by a Data Processing Agreement under Art. 28 GDPR.
| Processor | Purpose | Region | Privacy policy |
|---|---|---|---|
| OpenAI | LLM generation + scoring + mock-interview brain. We send the relevant portions of your CV and the JD; OpenAI states API traffic is not used to train its models. | USA | openai.com |
| ElevenLabs | Real-time text-to-speech for the interviewer voice. They receive the bot's text output (not your audio). | USA | elevenlabs.io |
| Deepgram | Speech-to-text transcription of your mock-interview audio. | USA | deepgram.com |
| Razorpay | Payment processing (and KYC where required). We never see your card / bank details. | India | razorpay.com |
| SendGrid (Twilio) | Email delivery, verification, password reset, receipts. Receives your email address and the email body. | USA | twilio.com |
| Sign-in (if you use Google login). Shares your email, name, profile picture with us. | USA | google.com | |
| Cloudflare (Turnstile) | Anti-bot challenge on signup / demo. Receives your IP and a behavioral signal; not used for advertising. | USA / global edge | cloudflare.com |
| DigitalOcean | Hosts the application servers, Postgres database, and Spaces object storage (CV files + mock-interview audio recordings). | EU + USA | digitalocean.com |
Our application servers, Postgres database, and object storage all run in DigitalOcean's Frankfurt (Germany) region, inside the EEA. Several sub-processors listed in Section 4 (notably OpenAI, Stripe, Deepgram, ElevenLabs, SendGrid) operate from the United States. For transfers outside the EEA we rely on the European Commission's Standard Contractual Clauses (where the recipient is in a country without an adequacy decision), supplemented by the technical and organisational measures described in Section 8 (Security).
You have the right to:
You have the right to:
To exercise any right, email vaibhav.kadam@cvcl.app. We respond within 30 days (GDPR) / 45 days (CCPA), and may verify your identity via the email on your account before acting on the request.
We encrypt traffic with TLS. Passwords are stored as bcrypt hashes, never plaintext. Payment secrets stay inside Razorpay's vault. Session tokens are short-lived JWTs. Access to the production database and object storage is restricted to authorised engineers and audited. No system is perfectly secure; if we become aware of a breach affecting your data we will notify you and the relevant supervisory authorities within 72 hours of discovery (Art. 33 / 34 GDPR).
See our dedicated Cookie Policy for the full inventory and how to change your choice.
We use AI to score how well your CV matches a JD and to rewrite bullets in the JD's vocabulary. These scores and rewrites are recommendations, they have no legal effect on you and they do not gate access to anything outside the Service. You always see the output before deciding what to do with it.
The Service is not intended for people under 18 and we do not knowingly collect personal data from minors. If you believe a minor has used the Service, email us and we will delete the account.
We may update this policy. Material changes will be announced via email to the address on your account at least 14 days before they take effect, and the Cookie banner will re-prompt for any new processing that requires consent. The "last updated" date at the top of this page always reflects the current version.
Privacy questions, data-subject requests, breach reports: vaibhav.kadam@cvcl.app.
Vaibhav Kadam · Bank Colony Street, Vita - 415311, Maharashtra, India