PIA (People Intelligence Assistant) — Privacy Policy

Last updated: December 2025

1. Introduction

At PIA ("we", "our") we operate an artificial intelligence platform for recruitment and selection processes. We are committed to transparency and to protecting our users’ data, distinguishing between Candidates (natural persons and data subjects) and Clients (contracting companies).

This Policy describes how we collect, use, store, and protect information, in compliance with Law No. 18.331 on Personal Data Protection (Uruguay) and applicable regulations.

When processing Candidate data, PIA primarily acts as a data processor on behalf of Clients, except for operational or legal aspects in which PIA may act as a data controller. For Client contact data, PIA acts as the data controller.

Responsible Entity

• Name: NEURALIS SAS
• RUT: 220409950014
• Address: Bulevar España 2710 apt. 101

2. Information We Collect 2.1 Data from natural persons (Candidates)

When you participate in an interview as a candidate, we collect, among others:

• Identification and contact data: full name, email address, phone number.
• Professional and academic data: digital résumé, employment history, education, and skills.
• Biometric and audiovisual data: video, audio, and image recordings from the interview.
• Evaluation data: transcript of responses and results of tests conducted on the platform.

We do not collect special categories of data (health, religion, sexual orientation, political opinions, etc.).

2.2 Data from legal entities (Clients/Companies)

For the commercial relationship we collect:

• Company name
• Tax identification number
• Contact information (email, phone)

3. Purpose of Processing

We process data for the following purposes:

1. Service delivery: enabling Clients to manage recruitment processes and enabling Candidates to apply through automated interviews.
2. AI-assisted evaluation: analyzing responses, reaction times, and patterns to generate reports on profile fit and competencies, without inferring sensitive characteristics.
3. Continuous improvement and statistics: using aggregated or anonymized data to optimize models, avatars, and algorithms.

When we act as a processor, we process data according to the Client’s instructions.

4. Use of Artificial Intelligence and Decision-Making

PIA uses language models and avatar technology to facilitate the process. AI acts as a support tool; the final hiring decision always belongs to the Client. We do not make automated decisions with legal effects without human review.

We do not use identifiable personal data (PII) to train public third-party models (e.g., ChatGPT).

5. Data Disclosure and Service Providers

We do not sell your personal data. We may share information with technology providers acting as processors/sub-processors under contracts requiring confidentiality and security measures.

Typical categories of recipients include:

• Cloud infrastructure and storage (e.g., AWS, MongoDB Atlas).
• Language, video, and avatar processing providers.
• Technical support and maintenance (monitoring, logging, security).
• Legal authorities, only when required by obligation or formal request.

A registry of providers and sub-processors is kept and available upon request.

6. International Data Transfers

Data may be stored and processed on infrastructure located outside Uruguay (e.g., United States). When transfers are made to countries without an adequate level of protection, we will implement the safeguards required by law (contractual clauses or other mechanisms authorized by the URCDP).

7. Data Retention and Anonymization

We retain data only for the period necessary to manage the selection process and comply with legal obligations or defense of claims. As a general rule, Candidate data will be retained for up to 24 months after the interview or process is completed, unless required otherwise by law or based on consent for a different period. After this period, we will securely delete or irreversibly anonymize the data.

Irreversibly anonymized data may be retained indefinitely for statistical or model-improvement purposes.

If the Client chooses not to record video, we will not store audiovisual content; only transcripts and analytical results will be retained under the aforementioned conditions.

8. Information Security

We implement technical and organizational measures including:

• Encryption of data in transit and at rest.
• Secure storage in AWS S3.
• Strict access controls to databases.

9. Your Rights and How to Exercise Them

As a data subject, you have the right to request confirmation of processing, access your data, rectify inaccuracies, request deletion, object to processing where applicable, and request human review of automated evaluations. To exercise these rights, send us a request including:

• Full name
• Contact information
• Scanned copy of your ID
• Clear description of your request

We will respond within a maximum period of 5 business days, in accordance with Law No. 18.331. You may also file a query or complaint before the URCDP if applicable.

10. Consent

A. Candidate Consent

When starting the interview and checking the corresponding box, you declare that you have read and understood this Policy and give your free, informed, and explicit consent for the processing of your data, including image and voice recording, generation of transcripts and reports, and data use according to the purposes described. Consent options will not be pre-checked, and you may accept or reject them granularly.

B. Consent and Legal Bases for Clients

For Clients, PIA will process contact and billing data on the basis of contract performance, compliance with legal obligations, and, where appropriate, legitimate interest. Consent for commercial communications will be requested when required by law, with the possibility of withdrawal by the data subject.

11. Contact

If you have any questions regarding this policy or how we handle your information, contact us at: martin@meetpia.ai

12. Changes to this Policy

We may modify this Policy to reflect changes to services, technologies, or legal requirements. When we make material changes affecting the rights of Clients or Candidates, we will notify you through a prominent notice on the platform and/or by email. If the law requires obtaining new consent, we will request it explicitly before applying the changes.