1. Data Roles & Responsibilities
BT1 operates under clearly defined roles to ensure compliance with
global data protection laws:
- Data Processor: BT1 acts as a processor when handling
candidate data on behalf of our enterprise customers.
- Data Controller: BT1 acts as a controller for
business-related data, account management, and service improvement analytics.
2. Categories of Personal Data
Candidate & Interview
Data
Includes names, contact details, audio/video
recordings, transcripts, and AI-generated scores or insights.
Customer & Business Data
Includes account credentials, billing information,
and professional contact details of platform users.
Website & Usage Data
Includes IP addresses, browser types, interaction logs,
and cookie-based analytics.
3. Data Processing Framework
BT1’s legal basis for data processing is established through a
multi-layered framework combining contractual necessity, data subject consent, and strict alignment with
global data protection principles.
All processing activities are:
- Clearly defined: Specific purposes for every data element
processed.
- Contractually governed: Bound by enterprise-grade Data
Processing Addendums (DPA).
- Technically enforced: Logic-level controls prevent data
leakage or misuse.
- Continuously monitored: Real-time compliance tracking and
periodic internal audits.
This ensures that BT1 operates as a
trusted, regulator-ready processor, capable of supporting highly regulated institutions while
maintaining strict adherence to privacy and data protection obligations.
4. Information Security Program
BT1’s information security program is built upon a holistic,
risk-based framework that integrates advanced technical safeguards with robust organizational controls.
Holistic Approach: By leveraging secure cloud infrastructure, strict access governance, comprehensive
monitoring, and formalized policies, BT1 ensures the confidentiality, integrity, and availability of all
processed data.
Our security architecture includes:
- Infrastructure Security: Enterprise-grade hosting with SOC 2
Type II compliant providers.
- Encryption: Data encrypted at rest via AES-256 and in
transit using TLS 1.3 protocol.
- Access Governance: Multi-factor authentication (MFA) and
Role-Based Access Control (RBAC) across all systems.
- Continuous Monitoring: Real-time logging, vulnerability
scanning, and incident response readiness.
5. Core Data Principles
We adhere to the highest international standards of data
governance, ensuring your information is handled with the utmost care:
- Purpose Limitation: We process data only for the provision
of the agreed-upon services.
- Data Minimization: We only collect what is strictly
necessary for the AI Interview and assessment engine.
- Accuracy & Integrity: Systems designed to ensure data
remains consistent and up-to-date throughout its lifecycle.
- Accountability: Clear documentation and transparency
regarding our data processing methodologies.
6. EU Artificial Intelligence Act (AI Act)
BT1 is committed to the ethical development of AI. In alignment with
the EU AI Act, we implement human-in-the-loop designs and rigorous bias mitigation practices to support
human-led decision-making.
7. Data Retention
We retain data only as long as necessary. Typically, interview
recordings are kept for 24 months unless requested otherwise by the customer or candidate.
8. Data Sharing and Disclosure
We may share your information with:
- Customers, as directed through use of the Services
- Service providers and subprocessors that support our
operations
- Professional advisors (e.g., legal, accounting)
- Authorities where required by law
All subprocessors are subject to contractual
confidentiality and data protection obligations.
9. International Data Transfers
For data transfers outside the EEA, we utilize Standard
Contractual Clauses (SCCs) and other approved mechanisms to ensure a consistent level of protection.
10. AI Data Safety & Ethics
As an AI-first platform, BT1 implements specific safeguards for data
used in machine learning and automated decision-making:
- Data Anonymization: PII is stripped or masked before being used
for
model optimization.
- Bias Prevention: Regular auditing of evaluation logic to ensure
fair treatment of all candidates.
- Linguistic Privacy: Audio and video data processed with strict
privacy-preserving techniques.
11. Compliance & Governance
This approach enables BT1 to meet the stringent security
expectations of financial institutions and regulated environments, positioning it as a trusted and
security-mature technology partner.
We maintain active alignment with:
- GDPR (General Data Protection Regulation)
- LGPD (Lei Geral de Proteção de Dados)
- Industry-specific regulatory requirements for talent
selection.
12. Cookies & Tracking Technologies
BT1 uses cookies and similar technologies to operate, analyze, and
improve our Services. You can manage your cookie preferences through your browser settings at any time.
13. Children's Privacy
The Services are not directed to children under 16. We do not
knowingly collect personal data from children.
14. Changes to This Policy
We may update this Data Policy from time to time. We will notify you
of significant changes by updating the "Last updated" date and, if appropriate, through other
communication channels.
15. Contact & Data Subject Rights
If you have any questions regarding our data policy or wish to
exercise your rights, please contact our Compliance Department:
Right to Human Review:
You have the right to request a human review of any AI-generated outputs and to express your point
of view.