Privacy Policy

Last updated: January 6, 2025

1. Introduction

Welcome to Zaya ("we", "our", or "us"), operated by Ctrl Alt Compete Ltd. (Company No. 16454103), trading as Zaya. We are committed to protecting your personal information and your right to privacy in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Information We Collect

During your participation in the Zaya MVP Pilot, we may collect:

• Account Information: Name, email address, password (encrypted)
• Profile Data: CV/resume, LinkedIn profile, career history, skills, education
• User-Generated Content: Journal entries, notes, career narratives
• Usage Data: How you interact with our platform, features used, time spent
• Feedback: Comments, suggestions, and survey responses
• Technical Data: IP address, browser type, device information

3. How We Use Your Information

We use your information solely for:

• Evaluating Zaya's features and functionality
• Generating and refining your Zaya Profile
• Improving the product through research and analysis
• Providing technical support and responding to inquiries
• Sending transactional emails and pilot program updates
• Ensuring platform security and preventing misuse

4. Legal Basis for Processing

We process your personal data based on your explicit consent (Article 6(1)(a) GDPR), which you provide when joining the pilot program. You may withdraw your consent at any time by contacting us.

5. Data Sharing and Disclosure

We do not share your personal data with external recruiters or third parties without your explicit permission. Your information may only be shared with:

• Service providers who assist in operating our platform (under strict confidentiality)
• Legal authorities if required by law or to protect our rights
• A successor entity in case of merger or acquisition (with continued privacy protection)

6. AI-Generated Content

Zaya uses large language models (LLMs) to generate content including CVs, profile narratives, and career summaries. Please note:

• AI-generated content may contain inaccuracies or misinterpretations
• You are responsible for reviewing and approving all generated content
• Your input data is processed by our AI providers under data processing agreements
• We do not use your data to train external AI models

7. Data Retention

Your personal data will be retained for up to 12 months after the conclusion of the pilot program, unless you request earlier deletion. After this period, your data will be securely deleted or anonymized for research purposes.

8. Your Rights

Under UK GDPR, you have the right to:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your data ("right to be forgotten")
• Restriction: Limit how we process your data
• Portability: Receive your data in a machine-readable format
• Object: Object to certain types of processing
• Withdraw Consent: Withdraw consent at any time

To exercise any of these rights, please contact us at privacy@meetzaya.com.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. This includes encryption, secure hosting, and regular security assessments.

10. International Transfers

Your data may be processed by service providers located outside the UK. Where this occurs, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the ICO.

11. Children's Privacy

Zaya is not intended for individuals under 16 years of age. We do not knowingly collect personal data from children under 16.

12. Changes to This Policy

We may update this privacy policy from time to time. We will notify you of any material changes by email or through the platform.

13. Contact Information

If you have any questions about this privacy policy or our data practices, please contact us:

14. Complaints

If you believe we have not handled your personal data appropriately, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):