PPL — Privacy Policy

1. Introduction

Zeqi Technology Ltd. ("Zeqi", "we", "us", or "our") operates the PPL platform ("Platform"), an AI-powered hiring intelligence service that helps organisations structure job briefs, screen candidates, and deliver fit recommendations.

This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and the rights you have in relation to your data. It applies to all users of the Platform, including hiring company representatives ("Clients") and job candidates ("Candidates").

We process personal data in accordance with the DIFC Data Protection Law No. 5 of 2020 and its subsequent amendments ("DIFC DP Law").

2. Who This Policy Applies To

This policy applies to:

• Clients — representatives of hiring companies who create accounts, manage job briefs, and review candidate recommendations.
• Candidates — individuals who apply for roles through the Platform or whose applications are processed by the Platform.
• Visitors — anyone who accesses our public-facing pages, including job listings.

The Platform is not intended for individuals under 18 years of age. Use of the Platform by anyone under 18 is strictly prohibited. We do not knowingly collect personal data from minors. If we become aware that data has been collected from a person under 18, we will delete it without undue delay.

3. Information We Collect

3.1 From Clients

• Account registration details (email address, password)
• Name and role within the organisation
• Company information (name, industry, locations, headquarters, culture, hiring context)
• Job brief details (role requirements, salary ranges, preferences)
• Onboarding conversation data used to configure company profiles

3.2 From Candidates

• Name and contact information (email, phone number)
• CV / resume (uploaded files and parsed content)
• Assessment responses and results (including personality and competency assessments)
• Professional profile links (e.g. LinkedIn, GitHub) when voluntarily provided
• Application metadata (submission date, referral source)
• Referring domain captured when a candidate lands on a job page, used only for client channel analytics

3.3 Payment and Billing Data

When Clients subscribe to paid plans or purchase credits, we collect:

• Subscription type and billing cycle
• Transaction history and credit balance
• Payment processor identifiers

We do not store credit card numbers or payment card details on our servers. All payment card processing is handled entirely by our third-party payment processor, which maintains its own security certifications and privacy obligations.

3.4 Automatically Collected Data

• Device and browser information
• IP address
• Pages visited and interactions within the Platform
• Cookies and similar technologies (see Section 8)

4. Legal Basis for Processing

Under the DIFC DP Law, we process personal data on the following grounds:

• Contractual necessity — to provide the Platform services you have signed up for, including account management, brief creation, candidate screening, and billing.
• Legitimate interest — to improve the Platform, ensure security, prevent fraud, and deliver relevant recommendations. We balance these interests against the rights and expectations of data subjects.
• Consent — where you have explicitly opted in, such as for analytics cookies or receiving marketing communications. You may withdraw consent at any time.
• Legal obligation — to comply with applicable laws, including tax, accounting, and regulatory requirements.

5. How We Use Your Information

We use personal data to:

• Create and manage user accounts
• Structure job briefs and company profiles
• Process and analyse candidate applications
• Generate AI-assisted fit reports and screening recommendations
• Conduct personality and competency assessments
• Process payments, manage subscriptions, and maintain billing records
• Send transactional communications (e.g. application confirmations, account notifications)
• Improve Platform performance, reliability, and user experience
• Detect and prevent security threats and fraudulent activity

We do not sell personal data to any third party.

We do not use candidate data for advertising purposes.

6. AI and Automated Processing

The Platform uses artificial intelligence and automated tools to assist in the hiring process. Specifically, AI is used to:

• Parse and extract information from CVs and resumes
• Evaluate candidate-to-role fit based on brief requirements
• Generate screening scores and fit summaries
• Analyse assessment responses
• Structure company profiles and job briefs from conversational input

The data that informs AI analysis includes the information provided by Clients (role requirements, company context) and by Candidates (CV content, assessment responses, and profile information).

PPL does not make hiring decisions. All AI outputs are advisory in nature. Final evaluation, selection, and hiring decisions remain solely with the hiring organisation. The Platform is a decision-support tool — not a decision-maker.

Candidates have the right to request human review of any automated assessment outcome. Such requests can be submitted to support@therightppl.com.

7. Third-Party Service Providers

We share personal data with third-party service providers who process data on our behalf, strictly for the purposes described in this policy. These providers are contractually bound to handle data securely and only as instructed by us.

Categories of providers include:

• Cloud infrastructure and database providers — for hosting, data storage, and authentication services
• AI processing providers — for candidate screening, document analysis, and natural language processing
• Payment processing providers — for handling subscription billing and payment transactions
• Email delivery providers — for sending transactional and service-related communications
• Analytics providers — for understanding Platform usage and improving the user experience (subject to your cookie consent preferences)
• Security and fraud prevention providers — for protecting the Platform against automated abuse
• File storage and document processing providers — for secure CV storage and text extraction

We do not sell, rent, or trade personal data with third parties for their own marketing or commercial purposes.

8. Cookies and Tracking Technologies

We use cookies and similar technologies on the Platform. Cookies are small text files stored on your device that help us provide and improve our services.

Essential Cookies

These are necessary for the Platform to function and cannot be disabled. They include authentication session cookies that keep you logged in and security cookies that protect against fraud.

Analytics Cookies

With your consent, we use analytics cookies to understand how users interact with the Platform, which pages are visited, and how features are used. This data helps us improve the Platform experience. Analytics cookies are only activated after you provide consent via our cookie banner.

Managing Your Preferences

When you first visit the Platform, you will be presented with a cookie consent banner where you can accept or reject non-essential cookies. You can change your preference at any time by clearing your browser cookies and revisiting the Platform. You may also configure your browser to block or delete cookies, though this may affect Platform functionality.

9. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this policy, or as required by law. Our retention periods are:

Candidates may request early deletion of their data at any time (see Section 11). Upon receiving a valid deletion request, we will remove the data within 30 days, except where retention is required by law.

10. Data Security

We implement reasonable technical and organisational safeguards to protect personal data against unauthorised access, loss, misuse, alteration, and destruction. These measures include:

• Encryption of data in transit and at rest
• Access controls and authentication mechanisms
• Regular security assessments
• Audit logging of data access and modifications
• Secure hosting with established cloud infrastructure providers

11. Your Rights

Under the DIFC DP Law, you have the following rights in relation to your personal data:

• Right of access — request a copy of the personal data we hold about you
• Right to rectification — request correction of inaccurate or incomplete data
• Right to erasure — request deletion of your personal data
• Right to restrict processing — request that we limit how your data is used
• Right to object — object to processing based on legitimate interest
• Right to withdraw consent — where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing

To exercise any of these rights, please contact us at support@therightppl.com. We will respond to requests within 30 days.

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the DIFC Commissioner of Data Protection.

12. International Data Transfers

By using the Platform, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside the United Arab Emirates where Zeqi Technology Ltd. or its service providers operate. Where such transfers occur, we ensure that appropriate safeguards are in place in accordance with the DIFC DP Law to protect your personal data.

13. Data Protection Officer

Zeqi Technology Ltd. is in the process of appointing a Data Protection Officer (DPO) in accordance with the DIFC DP Law.

In the interim, all data protection enquiries and requests should be directed to support@therightppl.com. Once a DPO has been appointed, their contact details will be published here.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. When we do, we will revise the "Effective Date" at the top of this page. We encourage you to review this page periodically to stay informed about how we protect your data.

15. Contact Us

If you have questions about this Privacy Policy or wish to exercise your data protection rights, please contact us: