Privacy Policy
1) Who we are
 
Inicio Careers Ltd (“we”, “us”, “our”) is the data controller for personal data processed through our website and services. We comply with the UK GDPR and Data Protection Act 2018.
- Contact: hello@iniciocareers.com
 - Registered address: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
 - Company number: 15150338
 
2) Data we collect
 
Personal Data: We collect personal data you provide directly, such as:
- Name, email address, or phone number (only when voluntarily provided)
 - Career-related information, including education, skills, and job preferences
 - Information submitted through our app or forms (e.g. CV data)
 
Automatically Collected Data: We collect technical and behavioural data such as:
- Browser type, IP address, device identifiers
 - Pages visited, features used, and time spent on our platform
 - Cookies and similar technologies 
 
3) How we use your data
 
We process your data to:
- Provide personalised career insights and recommendations
 - Improve, maintain, and secure our platform
 - Communicate service updates and relevant information
 - Comply with legal and regulatory obligations
 
We rely on performance of a contract and legitimate interests to process non-sensitive data necessary for running our service, and explicit consent where required - e.g. sharing data with third parties such employers or educational institutions or using AI models that could process identifiable data.
4) Use of AI and Third-Party Technologies
 
- We use OpenAI large language models (LLMs) to support features like text analysis, voice-to-text transcription and text generation.
 - We do not share personally identifiable information (e.g., name, email, phone) with OpenAI without your explicit consent and only when explicitly required for the relevant task.
 - Data sent to LLMs is anonymised or pseudonymised wherever feasible.
 - We do not permit our user data to be used to train either our own or third-party models.
 - We do not carry out solely automated decision-making producing legal or similarly significant effects.
 
5) Data Sharing and Disclosure
 
- We do not sell your personal data.
 - We may share aggregated or anonymised insights with partners that do not identify you.
 - We use vetted processors (e.g., cloud hosting, analytics) under Data Processing Agreements and appropriate safeguards.
 - We disclose data only when required by law, regulation, court order, or lawful request from authorities.
 - We will not share your personally identifiable data with third parties without your explicit consent.
 
6) Children
 
Our services are not intended for users under 18. We do not knowingly collect children’s data. If you believe we have, contact us to delete it.
 
7) Data Storage and Security
 
- All data is securely stored on Google Cloud servers located in London (UK).
 - We employ encryption, access control, and regular audits to prevent unauthorised access, loss, or alteration.
 - Where third-party processors are used, we ensure they meet GDPR-level data protection standards through formal Data Processing Agreements (DPAs).
 - We primarily process and store data in the UK. If data is transferred outside the UK (e.g. to trusted sub-processors), we ensure compliance with UK GDPR by using adequacy decisions or standard contractual clauses.
 
8) Data Retention
 
We retain personal data only as long as necessary for the purposes described above or as required by law. Users may request deletion of their data at any time by contacting us.
 
9) Your Rights
 
Under UK GDPR, you have the right to:
	•	Access – Request a copy of your data
	•	Rectify – Correct inaccurate or incomplete data
	•	Erase – Request deletion of your data
	•	Restrict or Object – Limit or oppose processing in certain cases
	•	Data Portability – Request a copy in a commonly used format
To exercise any of these rights, please contact hello@iniciocareers.com. You also have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner's Office (ICO). You can contact them at https://ico.org.uk/concerns/.
Where we rely on your consent to process data, you have the right to withdraw that consent at any time.
10) Changes to this policy
 
We may update this Privacy Policy periodically. Any changes will be posted here with an updated “Last Modified” date. Continued use of our services after such changes constitutes acceptance of the revised policy.
Last Modified: 31st October 2025