Privacy Policy

1. Controller

This Privacy Policy explains how we process personal data in connection with the PAIR platform. The controller under the EU General Data Protection Regulation (GDPR) is:

RIGHT-WAY.AI e.U.
Hausfeldstrasse 65b/2, 2232 Deutsch Wagram, Austria
FN 623615g
Email: support@pair.careers

2. Scope of This Policy

This Policy applies to:

  • Visitors of our website pair.careers and related pages,
  • Business customers using the PAIR platform,
  • Candidates whose data is processed through PAIR on behalf of our customers.

3. Categories of Data

Depending on your relationship with us, we may process in particular:

  • Account data: name, email address, company, role, login data.
  • Usage data: log files, IP address, device information, browser data, interaction with features.
  • Candidate data: CVs, application details, contact data, professional experience, skills, interview notes.
  • Call data: call metadata, audio recordings (where legally permitted and configured), speech-to-text transcripts, AI-generated summaries.
  • Support data: content of support requests and communication.

4. Purposes and Legal Bases

We process personal data for the following purposes and on the following legal bases (Art. 6 GDPR):

  • Provision of the Service: to operate PAIR, manage accounts, provide features and integrations (Art. 6(1)(b) GDPR – performance of a contract).
  • Customer support & communication: to respond to inquiries and support requests (Art. 6(1)(b) and (f) GDPR).
  • Security & fraud prevention: to secure our infrastructure, detect misuse, monitor access (Art. 6(1)(f) GDPR – legitimate interests).
  • Product improvement & analytics: to analyze usage and improve features, where possible using aggregated or pseudonymized data (Art. 6(1)(f) GDPR; if required, Art. 6(1)(a) GDPR – consent).
  • Compliance: to comply with legal obligations, e.g. tax, accounting or regulatory requirements (Art. 6(1)(c) GDPR).

Where we rely on consent (e.g. optional analytics cookies or call recording in certain jurisdictions), you can withdraw this consent at any time with effect for the future.

5. Processing of Candidate and Call Data

For HR customers, PAIR processes candidate data and call-related data as a processor in accordance with a separate Data Processing Agreement.

Call recordings and transcripts: Where enabled by the customer and where legally permitted, we may record AI screening calls and generate transcripts and summaries. These recordings and transcripts are:

  • Used to provide structured evaluation and summaries to the customer’s HR team.
  • Stored securely and deleted after a defined retention period (see section 7).

6. Third-Party Recipients and International Transfers

We may share personal data with:

  • IT infrastructure providers (hosting, databases, monitoring),
  • AI and analytics providers,
  • Email and communication providers,
  • Professional advisors (e.g. legal, tax) where necessary.

Where such providers are located outside the EU/EEA, we ensure an adequate level of protection through appropriate safeguards, such as the EU Standard Contractual Clauses and additional measures where required.

7. Retention Periods

We store personal data only for as long as necessary for the purposes described above or as required by law. In particular:

  • Account & contract data: for the duration of the contract and thereafter in accordance with statutory retention obligations (e.g. 7 years under Austrian commercial and tax law).
  • Log & security data: typically for a period of a few weeks to a maximum of 12 months, unless required longer for security incidents.
  • Candidate data: as agreed with the customer in the DPA and in accordance with applicable employment and anti-discrimination laws.
  • Call recordings & transcripts: normally for up to 6 months (180 days), unless a shorter period is configured by the customer or a longer period is legally required or permitted.

8. Your Rights (GDPR and Equivalent Laws)

You may have the following rights under applicable data protection laws:

  • Right of access to your personal data,
  • Right to rectification of inaccurate data,
  • Right to erasure (“right to be forgotten”),
  • Right to restriction of processing,
  • Right to data portability,
  • Right to object to certain processing based on legitimate interests,
  • Right to withdraw consent at any time (where processing is based on consent).

To exercise these rights, please contact us at support@pair.careers. Where we act as a processor for our business customers, requests may need to be directed to the respective customer (the controller).

9. Automated Decision-Making & AI

PAIR uses AI technologies to support recruiting workflows (e.g. scoring, call summaries, ranking). AI suggestions do not replace human judgement. Our intention is that decisions with legal or similarly significant effects (e.g. hiring, rejection) are always taken by humans and not solely based on automated processing.

10. Security

We implement appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. This includes access controls, encryption where appropriate and regular security reviews.

11. Complaints

If you believe that we are processing your personal data in violation of applicable law, you may contact us at any time. You also have the right to lodge a complaint with a supervisory authority, in particular with the data protection authority in your country of residence or in Austria:

Österreichische Datenschutzbehörde (Austrian Data Protection Authority)
Website: www.dsb.gv.at

12. Changes to This Policy

We may update this Privacy Policy from time to time. The current version is available on this page and applies from the date of publication.