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Privacy Policy

Version: draft 1 · Effective: date · 14 min read

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This policy explains what personal data Almost Senior handles, why, who else touches it, how long we keep it, and what you can do about it. It follows the EU General Data Protection Regulation (GDPR), the UK GDPR, and the Law of Georgia on Personal Data Protection of 14 June 2023.

1. Who is responsible

The controller of your data is Vladislav Pavlenko, an individual entrepreneur registered in Georgia, identification number 302343079, registered address 179 David Aghmashenebeli Avenue, floor 3, apartment 8, Didube district, Tbilisi, Georgia.

  • Privacy questions and requests: [email protected]

  • Everything else: [email protected]

  • Representative in the EU: name and address, if appointed

  • Representative in the UK: name and address, if appointed

  • Data protection officer: none appointed / name

The Almost Senior team works on the service on our behalf. Team members can access personal data only to run and support the service, and are bound to keep it confidential. written agreement with each team member who has access

2. The short version

  • We keep what you give us (email, CVs, the vacancies you work on) so the service can work, plus technical data needed for security. Analytics cookies and screen recordings only if you agree.

  • Your CV text goes to an AI model only when you ask for it to be read, adapted, or turned into a letter. We use only model endpoints that don't train on it and don't keep it.

  • We don't sell your data and don't show it to employers.

  • Our database and app servers are in the EU.

  • You can download all your data or delete your account yourself in Settings → Data.

3. What we collect

Account. Email address, name, profile photo (only if you sign in with Google, taken from your Google account), how you sign in (email code or link, password, Google), interface language, when you signed up and last signed in. Passwords are stored by our authentication provider only as a hash.

Your CVs and application materials. Everything you put in your CVs (contact details, work history, education, skills, and anything else you choose to write), the vacancies you add yourself, adapted CV versions, cover letters, your adaptation settings and notes, application statuses and your saved prompts.

Please don't put in your CV more about yourself than an employer needs. If you choose to include sensitive details (such as health, religion, or a photo), we process them only to provide the service to you. legal basis for special categories

Activity in the feed. Vacancies you saved, hid (with the reason, if you gave one) or opened.

AI usage records. For each AI request: the time, the feature (reading a CV, adapting, letter), the model, the number of tokens, the cost and whether it succeeded. No text of your CV or the vacancy is kept in these records.

Payments (when the paid plan launches). Paddle, our reseller, collects your payment details. We receive from Paddle what we need to switch your plan on and help you: email, country, plan, subscription status and dates, and the Paddle customer and transaction IDs. We never receive full card numbers.

Security data. IP address and browser information in server and sign-in logs, a browser check by Cloudflare Turnstile when you sign in or use guest CV reading, and counters that stop abuse (section 6).

Using the service without an account.

  • Builder draft: stays in your browser (local storage) and is not sent to us until you save it to an account.

  • PDF download: the CV you print is sent to our PDF service, which makes the file and stores it for up to 30 days so you can download it.

  • Reading a CV file planned, 1–2 times without an account: the file's text is sent to the AI model to fill the builder. We don't keep the file or the result on our servers; the result goes back to your browser.

  • Feed: vacancies you opened and your filter choices are kept in your browser only.

Analytics and advertising cookies (only if you agree). See the Cookie Policy.

Screen recordings and heatmaps (only if you agree to "recordings" in the cookie banner, a choice separate from analytics). We use PostHog to record how visitors use four places: the landing page, the vacancy feed, the template gallery and the CV builder. We never record the sign-in window, the legal pages, Settings, "My vacancies", your saved CVs or the admin pages, and recording stops the moment you leave a recorded page.

  • What a recording contains: the page as it looked, where the pointer moved, clicks, scrolling and page changes (the address without its query and hash), a random visitor ID, your browser and screen size, and a country-level location confirm, if the IP address is dropped by the project setting.

  • What is hidden: the content of every input field, always (what you type, including in the builder and the sign-in window). Anything marked as private in the page is hidden too, and so are contact links (email, phone). In the CV builder all text and images are hidden, so a recording shows layout and clicks, never what your CV says. The CV preview and sign-in window are not recorded at all.

  • What we don't do: we don't link recordings to your account, name or email (we never send them to PostHog), we don't record console messages or network contents, and we don't use recordings to make decisions about you.

Messages to support. Whatever you write to us, and your email address.

People mentioned in vacancies. Vacancy texts come from public sources and can name recruiters or hiring managers. When we collect a vacancy we remove personal contact details (names in contact lines, personal email addresses, phone numbers, messenger handles and personal profile links). Company names and company links stay. If something about you is still shown, write to us and we'll remove it.

4. Why we use it and on what legal basis

Each legal basis below is under the GDPR and the UK GDPR, and under the matching ground of the Georgian Law.

Run your account and the features you use: storing CVs, adapting them, letters, PDFs, the feed, the tracker
Legal basisContract: needed to provide the service you asked for
Sell and manage the paid plan, with Paddle
Legal basisContract
Keep accounting and tax records
Legal basisLegal obligation
Protect the service: sign-in checks, rate limits, abuse counters, security logs
Legal basisLegitimate interest in keeping the service safe and available
Count AI usage and cost per account, including after you delete it (without a link to you)
Legal basisLegitimate interest in managing costs and limits
Answer your messages
Legal basisContract, or legitimate interest if you are not a user
Analytics and advertising measurement
Legal basisConsent, which you can withdraw at any time in cookie settings
Screen recordings and heatmaps, to find what is confusing or broken
Legal basisConsent, which you can withdraw at any time in cookie settings
Show vacancies that mention people (section 3)
Legal basisLegitimate interest in showing public job information; contacts are removed

We don't send marketing emails. If we ever do, we'll ask for your consent first. We only send emails needed to sign in and to run your account and payments.

5. AI processing

  • When. Only when you start an action: reading a CV file into the builder, adapting a CV to a vacancy, writing a cover letter.

  • What is sent. The text of your CV and of the vacancy, and the settings you chose (style, language, your note).

  • Who processes it. We send requests through OpenRouter, Inc. (USA), which routes them to a model provider. Every request requires an endpoint that does not use prompts for training and keeps zero data (zero data retention). If no such endpoint is available, the request fails rather than going elsewhere. Today the requests go to Venice — confirm legal entity and country. If the provider changes, we'll update this list.

  • No training, no human review. We don't train models on your data and don't read your AI requests.

  • No automated decisions about you. The ATS check is calculated by our own rules, without AI, to help you choose vacancies. Neither these results nor the AI output is used to make decisions about you, and none of it is shared with employers.

  • You check the result. AI can be wrong. Read everything before you use it (see the Terms).

6. Security and abuse prevention

  • Your sign-in session is kept in secure cookies that page scripts can't read.

  • Browsers never talk to the database directly; only our server can reach it.

  • Connections are encrypted (HTTPS). Requests to the PDF service are signed.

  • To stop bots, sign-in and guest CV reading use Cloudflare Turnstile, which looks at technical signals such as your IP address, browser and TLS details. It does not read what you type.

  • Planned with guest CV reading: To count free attempts we keep a random device ID in a cookie and short-lived counters made from a one-way, keyed hash of your IP address and of the uploaded file. Counters are deleted after 2 days.

7. Who receives your data

We use these service providers. They process data on our instructions under data processing terms, unless marked as an independent controller.

Supabase, Inc.
What forDatabase and sign-in
DataAll account and service data
WhereEU, region, e.g. Frankfurt, Germany
Railway Corporation
What forRuns our app servers
DataData passing through requests; server logs
WhereEU, region, e.g. Amsterdam, Netherlands
Amazon Web Services
What forMakes PDF files and stores them temporarily
DataThe CV you download as PDF
WhereEU, Frankfurt, Germany
Cloudflare, Inc.
What forDomain name service, network protection and the Turnstile browser check
DataIP address, browser and request data
WhereGlobal network
OpenRouter, Inc.
What forRoutes AI requests
DataCV and vacancy text in a request; not stored
WhereUSA
Venice — entity
What forRuns the AI model
DataCV and vacancy text in a request; not stored
Wherecountry
Email provider, e.g. via Supabase SMTP
What forSends sign-in codes and links
DataEmail address
Wherecountry
Google LLC / Google Ireland Ltd
What for"Sign in with Google" (only if you use it); analytics and ad measurement (only with consent)
DataGoogle sign-in: name, email, photo. Analytics: see Cookie Policy
WhereUSA / EU
PostHog, Inc.
What forScreen recordings and heatmaps (only with consent). Processes on our instructions
DataRecordings with inputs and, in the builder, all text hidden; random visitor ID; clicks and page changes
WhereEU cloud, Frankfurt, Germany; the company is in the USA confirm DPA signed with PostHog, and the transfer mechanism for its US staff's access
Paddle (Paddle.com Market Limited)
What forReseller and merchant of record for the paid plan. Independent controller under its own privacy notice
DataPayment and billing data
WhereUK and as stated by Paddle

We may also share data with professional advisers (accountant, lawyer) under confidentiality, with authorities when the law requires it, or with a buyer of the service if it changes hands (we'll tell you first). We don't sell personal data and don't share it with employers or data brokers.

8. International transfers

Our database, app servers and PDF service are in the EU. Data leaves the EU in these cases:

  • Georgia. We, the controller, are in Georgia and access the data from there to run the service. transfer mechanism for access from Georgia

  • USA. Some providers are US companies or process in the US (OpenRouter, the model provider, Cloudflare, Google). PostHog stores recordings in the EU, but is a US company. We rely on the EU–US Data Privacy Framework where the provider is certified, and otherwise on the European Commission's Standard Contractual Clauses (with the UK Addendum for UK users). check certification of each provider

  • Under Georgian law, we transfer data only to countries the Georgian supervisory authority recognises as adequate, or under a contract with appropriate safeguards. confirm current adequacy list

You can ask us for a copy of the safeguards at [email protected].

9. How long we keep data

Account, CVs, vacancies you added, adapted versions, letters, feed activity, settings
How longUntil you delete them or your account
Copies in database backups
How longUp to N days after deletion depends on Supabase plan
PDF files
How longUp to 30 days, then deleted automatically. Deleted earlier when you delete your account
PDFs made without an account
How longUp to 30 days
Guest CV reading: the file and the result
How longNot stored on our servers
Abuse counters planned
How long2 days
AI usage records
How longOn account deletion, the link to you is removed; the anonymous cost record stays
Vacancies in the feed
How longThe text is erased when the vacancy closes (unless a user saved it); the record is deleted 60 days later
Server and sign-in logs
How longN days Railway / Supabase log retention
Payment and tax records
How longAs long as Georgian tax law requires: N years
Support emails
How longN months after the conversation ends
Analytics data (with consent)
How long2 months in Google Analytics
Screen recordings and heatmap data (with consent)
How long30 days in PostHog confirm the retention set in the project, then deleted automatically
Accounts nobody uses
How longnone / delete after N months of inactivity, with a warning email

10. Your rights

You have the right to:

  • access your data and get a copy — Settings → Data → Your data → Download (JSON) gives you your data in one JSON file export gap: once fixed, say "everything we hold";

  • correct it — edit it in the app, or write to us;

  • delete it — Settings → Data → Delete account removes your account and all its data at once; this can't be undone;

  • move it to another service (data portability) — the same JSON file;

  • object to processing based on legitimate interest;

  • restrict processing while a complaint is being checked;

  • withdraw consent at any time — cookie settings in the site footer (analytics and recordings separately). Recording stops at once and the PostHog cookies are deleted from your browser; this doesn't affect what happened before. To have recordings already made deleted, write to [email protected]: since they aren't tied to your account, tell us roughly when you visited and from which browser;

  • complain to a supervisory authority: in Georgia, the State Audit Office (which took over from the Personal Data Protection Service) confirm; in the EU, the authority in your country; in the UK, the Information Commissioner's Office.

For anything you can't do in the app, write to [email protected] from your account email. We reply without undue delay and within one month at the latest; where Georgian law sets a shorter deadline, we follow it. confirm Georgian deadline We may ask you to confirm your identity. It's free.

11. Age

The service is for people aged 16 and over. If you think a younger child has given us data, write to us and we'll delete it.

12. Cookies

We use cookies and browser storage that the service needs to work, and, only with your consent, analytics, advertising and screen recording cookies. Details and the full list: Cookie Policy.

13. Changes

If we change this policy in a way that matters, we'll tell you by email or in the app before it takes effect. The date at the top shows the latest version.

This policy is written in English. The Russian version is a translation; if they differ, the English text applies.

Almost Senior · 2026
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