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Brondem Privacy Policy

This Policy explains what data Brondem collects from HR users and candidates, why the data is needed, where it is stored, who it may be shared with, and how to request access, correction, deletion, or restriction of processing. Where Brondem acts as an independent data controller, that controller and the operator of the Brondem service is an individual entrepreneur (FOP) Bahrii Yaroslav Serhiiovych, RNOKPP 3909904696. Registered address: Ukraine, 62002, Kharkiv Oblast, Bohodukhiv Raion, settlement Krasnokutsk, Berehova Street, building 4. Contact for personal-data matters: [email protected].

Last updated: 3 October 2026 Applies to: brondem.com, HR dashboard, Telegram bot, and Brondem Mini App
1

General provisions

Brondem is a SaaS platform for initial candidate screening. An HR user creates an interview, questions, and criteria, while a candidate completes the initial stage through the Telegram bot or Mini App. The service collects answers and related data and may generate an assistive AI report for HR.

This Policy applies to the Brondem public website, HR dashboard, Telegram bot, Mini App, and related service features. It should be read together with the Terms of Use and Public Offer.

2

Data Brondem collects

2.1. HR user data

CategoryExamplesPurpose
AccountName or display name, email, login method, avatar, language, role, linked Telegram account, and settings.Registration, login, access recovery, profile, and system notifications.
Company and teamEmployer name and type, owner and HR roles, team invitations, interviews, questions, candidate sources, reminders, and notification settings.HR dashboard operation, access control, teamwork, and screening analytics.
Company verificationPublic and legal name, employer type, website or page, work email, comment, status, and verification result.Confirming submitted information, showing trust status, and enabling related features.
Subscription and supportPlan, period, status, limits, add-on volumes, payment history, requests, and technical notification-delivery details.Providing paid features, usage accounting, support, refunds, and payment disputes.

2.2. Candidate data

CategoryExamplesPurpose
Telegram and Mini AppTelegram ID, username, profile first and last name, language, temporary profile photo, and Mini App launch data.Creating and protecting the interview session, linking it to an interview, communication, and duplicate prevention.
Answers and profileText or selected answers, phone, email, city, experience, candidate description, CV, or links where required by the vacancy and provided by the candidate.Conducting initial screening and providing results to the HR company.
Files and sourceCVs, documents, images, links, file name, type, and size, and the source or campaign of the interview link.Material exchange, storage control, and candidate-source analytics.
Interview progressStages and timing, answer length, pauses, text entry and pasting, technical events, and the result of checking that the candidate is human.Interview operation, funnel analytics, abuse prevention, and evaluation context where the relevant features are available.
ResultsScores, brief overview, strengths and weaknesses, recommendation, assistive risk signals, HR decision and note, and candidate-notification delivery status.Assistive analysis and manual review by the HR company.

2.3. Technical data and logs

Brondem may process a network address, browser or device data, login and access-recovery events, request route and outcome, errors, important actions, abuse attempts, and notification-delivery statuses. This is necessary for service operation, support, auditing, account protection, and incident investigation.

2.4. Payment data

Brondem may store payment status, amount, currency, plan or additional limit, billing period, payment identifier, and information needed for subscription activation, accounting, a refund, or a dispute. Full bank card details and CVV/CVC are processed by the payment provider.

2.5. Use of paid features

To account for limits and review refunds or disputed payments, Brondem may consider created interviews, completed interviews, generated reports, occupied storage, files, team seats, additional volumes, and export or download events.

3

Purposes of data processing

  1. Account and team. Registration, login, access recovery, user invitations, roles, and company settings.
  2. Interviews and attempts. Storing questions and materials, conducting interviews through Telegram or Mini App, and collecting profile and contact details where requested by the HR company.
  3. Analytics and reports. Generating assistive scores, AI reports, candidate lists, source statistics, exports, and manual HR decisions.
  4. Company verification. Checking submitted information and granting, refusing, or revoking verification status without disclosing internal criteria.
  5. Files and notifications. Storing attachments, CVs, reminders, invitations, and email or Telegram notifications and recording delivery results.
  6. Payments and limits. Confirming payments, activating access, recording use, refunds, disputes, and financial compliance.
  7. Support and security. Responding to requests, diagnosing errors, auditing, and protection against spam, fraud, attacks, and circumvention.
  8. Legal compliance. Accounting, tax, and contractual obligations and responses to lawful requests.
5

Data controller and processor

For candidate screening, the HR company or employer usually determines the purpose, vacancy content, questions, required fields, criteria, and subsequent use of results. In this context, the company is the data controller and Brondem processes data on its instructions to operate the service.

For HR accounts, company verification, payments, support, notifications, technical logs, and its own legal obligations, Brondem may act as an independent controller.

Practical meaning

A candidate may contact either the HR company conducting the screening or Brondem about data processing. Brondem will handle the request within its technical capabilities and applicable legal obligations.

6

AI analysis

Questions, expected answers, candidate answers, and related completion signals may be used to generate a report. Brondem uses OpenAI services to provide certain artificial intelligence functionality. As part of this processing, OpenAI may receive data only to the extent necessary to provide the relevant AI functionality.

AI does not make hiring decisions

An AI report is solely an assistive tool for preliminary analysis of candidate answers. No hiring decision is made by Brondem or exclusively by automated means. The final invitation, rejection, or next-stage decision is made by a human representative of the employer / HR company.

Risk signals are not proof of fraud or a violation. They only indicate a possible need for additional manual review. The HR company / employer is responsible for the legality of invitations, rejections, additional interviews, or hiring.

7

Data sharing with third parties

Brondem does not sell personal data. Data may be shared with providers only to the extent needed for a specific function, under a contract, lawful request, or other proper basis. The provider set may change provided this does not reduce user rights and protections.

Infrastructure provider

Provides computing resources and the service operating environment.

Payment provider

Processes payments, bank card data, and, where necessary, refunds or payment disputes on its side.

Telegram

Supports the bot, Mini App, and notifications and processes data under its own rules.

OpenAI

Receives data needed to generate an assistive report.

File storage

Used for CVs, attachments, and other service materials.

Email provider

Supports invitations, access recovery, notifications, support, and other service emails.

Competent authorities

Data may be provided to government authorities, courts, or law-enforcement bodies only where lawful grounds exist.

8

Where and how data is stored

9

Retention periods

Brondem retains data no longer than needed for processing purposes, plan terms, contract performance, legal compliance, protection of rights, and abuse investigations. Unless another period is set by a plan, contract, company settings, or law, reasonable retention periods appropriate to the data's purpose apply.

CategoryGeneral retention approach
HR account dataRetained while the account is active and for a reasonable period needed for contractual, legal, financial, or disputed matters.
Company and interview dataRetained while the account or interview is active or while needed to provide the service, unless law or company settings require otherwise.
Candidate interview dataRetained while needed by the HR company for screening or until deletion, access restriction, or anonymization, unless law requires otherwise.
Temporary Telegram photoRetained for a limited time to display the candidate profile, after which it is deleted or becomes unavailable.
FilesStored on the server and deleted upon user request.
AI reportsRetained with the related interview session or candidate record unless a plan or company settings provide otherwise.
Payments and company verificationRetained for periods needed for accounting, status confirmation, lawful requirements, and disputes.
Payments and financial documentsUp to 5 years or longer if required by law, accounting, a refund, chargeback, dispute, or legal hold. They are separated from the company's working data.
BackupsTarget period is 30 days. After restoration, irreversible deletion markers are applied again.
10

User and candidate rights

Depending on applicable law, a user or candidate may have rights to access, correction, deletion, restriction of processing, withdrawal of consent, objection, and information about data transfers.

Access to data
Correction of inaccurate data
Deletion of data
Restriction of processing
Withdrawal of consent
Objection to processing
Transfer information
GDPR rights, where applicable

A request may be sent to [email protected]. The requester should state their role and information that will help locate the record. Brondem may request additional identity verification to avoid disclosing data to a third party.

11

Data deletion and anonymization

An HR company may delete or request deletion of interviews, candidate records, and materials available to it. A candidate may contact the HR company or Brondem directly. Depending on the grounds and technical status, data may be deleted, access may be restricted, or data may be anonymized.

During anonymization, Telegram identifiers, OAuth identifiers, email, name, contacts, profile, answer texts, files, AI content, and report content are removed. Minimal technical deletion evidence, security logs, and financial documents may remain for defined periods without candidate content. A deleted marker is not physical file deletion: storage cleanup is confirmed by a separate reliable task.

12

Cookies and local storage

Brondem uses necessary cookies, localStorage, and sessionStorage for login, session maintenance and renewal, account protection, language selection, interface operation, and return after payment. Drafts, filters, onboarding state, service flags for payment or company checks, and short-lived cached profile data may also be stored locally.

TypePurpose
Necessary cookiesAuthorization, session renewal, and access protection.
Local and session storageLanguage, interface settings, drafts, filters, and technical login and payment state.
Advertising and analyticsNot used without separate notice or consent where such consent is required.
13

Data security

Brondem applies organizational and technical safeguards, including role-based access control, logical separation of company data, logging of important events, access checks, and abuse-prevention measures. Details of security mechanisms are not published for security reasons.

Limitation of guarantees

No digital service can guarantee absolute security. Brondem takes reasonable measures to reduce risks but does not claim complete invulnerability.

14

Contacts for data requests

Personal data requests
Access, correction, deletion, anonymization, restriction of processing, and questions about AI analysis and data transfers.
[email protected]
Service: Brondem
Privacy, support, payment: [email protected]
Security: [email protected]
Technical questions about decision notifications: [email protected]
15

Frequently asked questions

Does Brondem store bank card details?

No. Full card details are processed by the payment provider. Brondem stores only information needed for payment, subscription, accounting, or a dispute.

Why is company verification needed?

It helps confirm employer-provided information and display a trust status. Brondem may refuse or revoke status because of inaccurate data or violations.

Does AI decide whom to hire?

No. An AI report is an assistive tool. The HR company or employer is responsible for the hiring decision.

Does a risk signal prove a violation?

No. It is only a reason for additional manual review.

Can candidate data be deleted?

Yes, through the HR company or Brondem. Depending on law, security, accounting, and disputes, data may be deleted, restricted, or anonymized.