Personal Data Protection Policy

This policy explains how Rivo collects, uses, stores, and protects personal data, why that data is processed, and which rights data subjects have.

Rivo processes personal data in accordance with the Law of Georgia on Personal Data Protection and, where applicable, the General Data Protection Regulation (GDPR).

This policy covers Rivo’s automated, semi-automated, and non-automated processing of personal data.

It applies to platform users, candidates (job seekers), employer representatives, and partners whose personal data Rivo processes.

Rivo is the controller responsible for processing data. A processor is a legal entity that processes data for or on behalf of a controller. Personal data means any information relating to an identified or identifiable natural person. Special-category data includes data about racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health, sex life, criminal history and proceedings, victim status, and biometric or genetic data. Biometric data means a physical, mental, or behavioral characteristic unique enough to identify an individual.

Processing means any operation involving data, including collection, recording, organization, storage, alteration, use, transfer, disclosure, restriction, erasure, or destruction. Automated processing uses information technology; semi-automated processing combines IT and non-automated means. A data subject is the person to whom processed data relates. Consent is the data subject’s voluntary and informed permission for processing for a specific purpose. Written consent of the data subject means consent expressed in writing or an equivalent form to the processing of personal data for a specified purpose. An authorized person is any natural or legal person that processes data for or on behalf of the data processor. Restriction means temporarily suspending processing; depersonalization means changing data so linking it to a person becomes impossible or disproportionately difficult. An identification number is a personal identification number or another identification number defined by law that can identify a natural person.

List of the data subject’s personal data

Depending on the service used, Rivo may process:

• name, surname, phone number, and email address;
• CV information, work history, education, professional skills, and qualifications;
• uploaded education credentials such as licenses, certificates, diplomas, or school certificates;
• DISC assessment information and results;
• information supplied through AI features, including AI interviews;
• for employers and partners only, identification number and address where required for legal, billing, or contact purposes;
• for paid employer or partner services, payment and transaction information, but not full payment-card details;
• service or partnership agreements; and
• other information necessary to provide Rivo’s services or meet legal obligations.

Rivo processes only personal data necessary to operate the platform and provide its services. The principal categories, purposes, and legal bases are:

• Contact information: account creation, communication, and platform use, based on consent and performance of a contract.
• CV, education, work history, skills, application history, and other professional information: building a candidate profile, job matching, applications, and AI features, based on contract performance and consent.
• DISC assessment data: professional-profile analysis and recommendations, based on consent.
• Information supplied through AI features, including AI Interview: delivering AI services and improving candidate-to-job matching, based on consent and contract performance.
• Employer or partner payment and transaction information: billing and paid-service delivery, based on legal and contractual duties. Rivo does not store complete card details.
• Employer or partner identification, contract, and billing details: contracting, billing, and tax compliance, based on legal and contractual duties.
• Cookieless Umami analytics: page path with only standard UTM campaign parameters retained and without other query parameters or hashes, title, referrer, browser, operating system, device and screen, language, approximate location, anonymous session, events, and performance. IP is used to estimate location but is not stored. Processing supports measurement, security, and improvement under Rivo’s legitimate interests, balanced against data-subject rights.
• Measurement and advertising data: Google Ads Tag, Meta Pixel, TOP.GE, and - after consent - a pseudonymous Umami account ID may process IP address, device/browser data, a sanitized public-page URL, time, interactions, and ad-click identifiers. Limited cookieless measurement and TOP.GE rely on legitimate interests with an opt-out; Meta, Google full mode, and account linking rely on consent.
• Affiliate referral code: stored for 30 days to attribute registration, based on Rivo’s legitimate interest in accurate partner-program accounting.

Information supplied during an AI Interview is processed in real time to perform that feature and is not retained unless necessary to deliver the requested service or required by law. Rivo limits every category to what is necessary for its stated purpose.

Rivo processes personal data fairly, lawfully, and transparently, with full respect for each data subject’s rights and dignity. Personal data is:

• collected only for specific, clear, and legitimate purposes;
• processed only to the extent necessary for those purposes;
• kept accurate and updated where needed;
• stored only as long as the purpose or law requires; and
• deleted in accordance with legal requirements once the purpose has been fulfilled.

Rivo processes personal data only where at least one legal basis applies, including:

• the data subject’s consent;
• entering into or performing a contract;
• compliance with a legal obligation imposed on Rivo;
• Rivo’s or a third party’s legitimate interests, unless overridden by the data subject’s rights and freedoms;
• data that is publicly available or made public by the data subject; or
• another basis provided by law.

Rivo shares personal data only when necessary to operate the platform, provide a service, fulfill a user request, or meet a legal obligation. Recipients may include:

• an employer when a candidate applies for its vacancy or agrees to share a profile;
• service providers supporting hosting (including Cloudflare and Supabase), technical support, communications, and other platform functions;
• Flitt for card, Apple Pay, or Google Pay processing; full card details remain in Flitt’s secure environment and are not stored by Rivo;
• Umami Cloud for cookieless anonymous analytics under legitimate interests, with a pseudonymous account ID sent only after consent;
• Google Ads/Tag for legitimate-interest cookieless measurement on public, safe pages and consent-based full mode; TOP.GE for legitimate-interest public-page visit counting with an opt-out; and Meta Pixel only after consent;
• competent public authorities where law or a lawful request requires disclosure; and
• another party with the data subject’s consent or another legal basis.

Recipients receive only the access necessary for the stated purpose and must protect confidentiality and security. Some providers may process data outside Georgia. Anonymous Umami analytics and affiliate attribution are always active. Google remains cookieless before a choice and after rejection; TOP.GE turns off after rejection; Meta, Google full mode, and Umami account linking activate only after consent. Consent is stored for 180 days, while rejection applies through a session cookie across tabs for the current browser session.

Rivo’s role depends on whose purposes and instructions determine the processing.

8.1 Rivo as controller

Rivo is the controller when it determines the purposes and means of processing - for example, when an individual registers independently and uses Rivo’s services.

8.2 Rivo as processor

Rivo acts as a processor when it works with an employer or another company and processes candidate, employee, or other personal data on that company’s behalf, under its instructions and for its specified purposes.

9.1 Where and how data is stored

Rivo uses managed cloud and serverless environments: Cloudflare Pages for application hosting and its global CDN; Supabase on EU-based AWS infrastructure for the database and file storage; and Supabase-managed daily backups and point-in-time recovery (PITR).

9.2 Who can access data

Access follows least-privilege principles. Users and candidates can access only their own personal data. Organizations and employers can access only their vacancies and candidate profiles they are authorized to view or have purchased. Administrators receive only role-specific access enforced by system Row-Level Security rules.

9.3 How data is protected

Technical safeguards include passwordless email one-time-code (OTP) authentication, TLS 1.3 encryption in transit, and database Row-Level Security policies that strictly isolate users and organizations.

9.4 Retention

Rivo retains data until the user deletes the account or for one year after the last activity, after which inactive data is periodically deleted automatically.

9.5 Deletion

When an account or profile is deleted, database cascade rules permanently delete the candidate’s data, uploaded files, and submitted applications.

9.6 Recovery

Data cannot be recovered after final deletion.

When Rivo acts for an employer or another company, it processes personal data only under that company’s instructions, under the parties’ agreement, to the extent needed for the relevant service, and in compliance with law.

Rivo does not use such data for independent purposes. Access is limited to people who need the data for the relevant work. When the service ends, data is stored, returned, or deleted according to the employer’s instructions, the agreement, and applicable law.

Rivo may transfer personal data outside Georgia only where necessary to operate the platform, deliver a service, or work with an employer.

International transfers are made in accordance with applicable law and with appropriate safeguards for data security.

A data subject may ask whether and how Rivo processes their personal data. Subject to applicable law, they may:

• access their personal data and obtain copies;
• correct, update, or complete inaccurate, incomplete, or outdated data;
• request restriction or cessation of processing;
• request erasure or destruction;
• request data portability where provided by law;
• withdraw consent; and
• exercise other rights granted by law.

When Rivo processes data on an employer’s instructions, a request may be referred to that employer as controller; Rivo will assist the employer in reviewing and fulfilling it.

Consent may be withdrawn at any time where processing relies on consent. Withdrawal does not affect the lawfulness of processing completed before withdrawal.