Privacy Policy

1. DATA CONTROLLER

The data controller is:

VOCATING SA
20, Rue du Roveray
1207 Geneva

EU representative (Article 27 GDPR): [to be completed].

If, at any time, you have questions or concerns about our privacy practices, please contact us at privacy@vocating.ai.

2. WHAT PERSONAL DATA DO WE COLLECT?

2.1 PERSONAL DATA YOU PROVIDE

When you register for, or access the Services, we collect personal data (“Personal Data”) necessary to create and manage a User Profile, such as your name and email address.

In the context of the Services, you may also voluntarily provide professional and career-related information such as your CV, employment history, education, skills, career preferences, job search criteria and other related information.

We may also process content you provide, including chat messages, conversation history, and uploaded files.

If you choose to use voice input features, we may also process audio data that you voluntarily submit through the VOCATING App(s).

Where voice features are enabled, the Company may process voice data, including vocal characteristics such as tone, pitch, rhythm, and speech patterns (“Voice Metrics”).

Voice Metrics may be used to infer communication style or emotional signals (such as confidence, hesitation, or engagement) solely to enhance the relevance of AI-generated outputs. Such inferences are automated, may be inaccurate, and are not used to make decisions producing legal or similarly significant effects.

By voluntarily submitting personal data, including, where applicable, sensitive personal data, information through the VOCATING App(s), you expressly consent to its processing by us by clicking the “I expressly consent the processing of my sensitive personal data” button, for the purposes set out in this Privacy Policy and to the extent necessary to provide the Services. If you do not wish to provide such information or do not consent to its processing, please refrain from submitting it through the App(s).

You acknowledge that any professional or career-related data you provide is submitted at your own discretion and responsibility.

You are strongly discouraged from submitting confidential sensitive personal data (such as health data, political opinions, religious beliefs, or data relating to criminal proceedings), unless strictly necessary.

You must not submit confidential informing belonging to third parties, including trade secrets, internal employer documents, or non-public HR data.

Subscriptions are purchased exclusively through the Apple App Store or Google Play. Apple or Google process your payment under their own privacy policies. We receive only a transaction identifier, the product purchased, the date and the subscription status. We never receive or store your payment card details.

You remain responsible for ensuring that any data submitted through the VOCATING App(s) complies with applicable data protection laws and confidentiality obligations.

It is your responsibility to refrain from entering personal sensitive data related to third parties into the VOCATING App(s).

By clicking the “I consent to receiving newsletters and marketing emails” button, we will use your name and email address for this purpose. This consent is optional and can be withdrawn at any time.

2.2 LOCAL STORAGE, DEVICE IDENTIFIERS AND ANALYTICS

We use local storage, device identifiers, and analytics tools to operate and improve the Services. Local storage helps save your preferences and login state. Device identifiers are used for app functionality, security, and analytics. We may also use third-party analytics to understand how users interact with the app and to enhance performance. You can manage or limit data collection through your device settings. Please note that disabling these features may limit some functionalities of the Services.

2.3 LOG DATA

When you use the Services, we may automatically collect certain log data to help us maintain and improve the Services. This may include the device’s Internet Protocol (“IP”) address, your device type, operating system, app version, browser type, identification numbers associated with your devices, your mobile carrier, crash reports, timestamps of usage and other technical information.

3. FOR WHICH PURPOSE DO WE USE YOUR PERSONAL DATA

3.1 PERSONAL DATA

Personal Data may be collected to:

provide the Services;
contact or identify you;
grant you access to the VOCATING App(s) and our Services;
comply with any requirement imposed by applicable law or by an order of a court or competent governmental or regulatory authority;
provide and improve our Services and customer service;
personalize and improve your experience;
debug, monitor performance, ensure security, and understand how users interact with the VOCATING App(s);
manage enquiries;
provide or offer software updates product announcements, newsletters or marketing communications, where you have provided your consent or where the law otherwise permits us to do so; and
generate career-related insights such as CVs, job applications and professional recommendations;
analyze professional profiles and career preferences to provide personalized insights;
improve AI models, methodologies, and outputs using aggregated or anonymized data;
develop statistical indicators, benchmarks, and analytical products relating to career paths, skills, and employability trends;
process voice inputs and analyze Voice Metrics to enhance communication insights and personalize recommendations;
process messages and uploaded content to generate responses, summaries, and search functionalities;
process audio data for speech-to-text and text-to-speech features;
extract and index content from uploaded documents for search and retrieval.

3.2 ANALYTICS

As explained above, we may also collect some data (ourselves or by using third party services) by using logging and cookies, such as IP addresses, which can sometimes be correlated with Personal Data. We use this data for the above purposes and to monitor and analyze the use of the Service, for the Service’s technical administration, to increase our Service’s functionality and user-friendliness, and to verify users have the authorization needed for the Service to process their requests.

4. INFORMATION SHARING AND DISCLOSURE

4.1 YOUR ACCESS

Your Personal Data will be displayed in your User Profile, you can update it at any time.

4.2 ACCESS BY THE COMPANY

The Company and any employee of the Company who needs to access your Personal Data to comply with the Company’s contractual or legal obligations will have access to your Personal Data.

4.3 COMPLIANCE WITH LAWS AND LAW ENFORCEMENT REQUESTS; PROTECTION OF THE COMPANY’S RIGHTS

We may also disclose to third parties your Personal Data, or data collected from cookies and other logging data, when we have a good faith belief that disclosure is reasonably necessary to:

comply with a law, regulation or compulsory legal request;
protect the safety of any person from death or serious bodily injury;
prevent fraud or abuse of the Company, its Services or its users; or
to protect an overriding interest of the Company.

4.4 TRANSFER OF DATA

Your Personal Data is stored in Vocating’s own database hosted on Google Cloud Platform in the Zurich region, Switzerland. The following providers process Personal Data on our behalf, under data processing agreements and with contractual commitments not to use your data to train their models:

Google Cloud Platform (hosting and database, Zurich, Switzerland)
Google Cloud Vertex AI (generation of AI feedback, insights and recommendations)
Google Cloud Speech-to-Text and Text-to-Speech (voice features)
ElevenLabs (text-to-speech, United States)
Cartesia (text-to-speech, United States)
Brevo (transactional and marketing emails, European Union)
Apple Inc. and Google LLC (app distribution, in-app purchases)
Infomaniak (email hosting, Switzerland)

This may include the transmission of profile, program content and voice data (including Voice Metrics) to these providers strictly for the purpose of providing the Services. Where a provider processes data from the United States, transfers rely on the Swiss-US Data Privacy Framework, the EU-US Data Privacy Framework or Standard Contractual Clauses. We do not train our own models on identifiable Personal Data. Aggregated or anonymized data may be used and shared for analytics, benchmarking and product development, provided it does not allow identification of Users. We may also disclose Personal Data to supervisory authorities or when required by law.

5. DATA RETENTION AND STORAGE

We may retain and use your Personal Data as long as you use the Services and as long as necessary to comply with our contractual and legal obligations.

Career-related data (including CVs, professional history, career preferences, and AI-generated outputs) may be retained for the duration of your use of the Services in order to ensure continuity, personalization, and improvement of your experience.

Audio data submitted via voice features is processed transiently and is not retained beyond what is strictly necessary to provide the Services, unless explicitly stored as part of your interaction history. Derived textual data (such as transcriptions) may be retained as part of your interaction history.

Aggregated or anonymized datasets derived from Personal Data may be retained for longer periods for research, statistical analysis, benchmarking, and product development purposes, provided that such data does not allow the identification of individual Users.

Personal Data is retained only for as long as necessary for the purposes described in this Privacy Policy, unless longer retention is required or permitted by law. Thereafter, the data is deleted or anonymized.

Retention periods:

- Account and program data (profile, answers, experiments, goals, interaction history, transcriptions): for the life of your account, then deleted within 30 days of account deletion. Backup copies are overwritten within 90 days.
- Audio data: processed transiently and not retained beyond what is necessary to provide the voice features; transcriptions are retained as part of your interaction history.
- Log, device and analytics data: 12 months.
- Subscription transaction records: 10 years, as required by Article 958f of the Swiss Code of Obligations.
- Support correspondence: 24 months after the last exchange.
- Marketing consent records: 3 years after the last contact.

Data may be retained longer where required by law or to establish, exercise or defend legal claims.

6. SECURITY

We integrate artificial intelligence technology provided by Google Cloud Vertex AI to generate responses, insights and recommendations from your profile, program content, messages and transcribed voice inputs. Voice features rely on Google Cloud Speech-to-Text, Google Cloud Text-to-Speech, ElevenLabs and Cartesia. For further information, please refer to the privacy documentation of these providers.

The Company applies technical and organizational measures to protect Personal Data from unauthorized access, loss, misuse, alteration, or disclosure, including access controls, encryption when needed, and contractual safeguards with service providers.

Voice data and Voice Metrics are subject to the same level of protection as other Personal Data and are processed with strict access limitations and appropriate security controls.

Personal Data is stored on servers located in Switzerland. Where processing involves access by service providers from outside Switzerland, appropriate safeguards (such as Standard Contractual Clauses) are implemented.

7. RIGHTS AND REQUESTS

To delete your Vocating account and the Personal Data linked to it, open the Vocating app, go to Profile and tap Delete account. You can also request deletion without using the app at https://vocating.ai/delete-account. Deletion is completed within 30 days.

You have the right to view, amend or delete the Personal Data that we hold about you, including sensitive data. If any of the Personal Data we hold on you is inaccurate or incomplete, you may directly amend your Personal Data in your User Profile.

You may also request the deletion of your career-related data, including CVs, professional profiles, and AI-generated outputs, at any time.

You may also request the deletion of the Personal Data or object to their processing or request to restrict their processing, except in the event that the request is unfounded, for instance in presence of a legal basis or an overriding interest of the Company.

You may object to or withdraw your consent to the processing of voice data and Voice Metrics at any time by disabling voice features in the application settings or by contacting the Company.

Where GDPR applies, you also have the right to data portability and the right to withdraw your consent at any time. You further have the right to lodge a complaint with the competent data protection supervisory authority.

To exercise any of these rights, write to privacy@vocating.ai. We respond within 30 days and may ask you to verify your identity. You may lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (www.edoeb.admin.ch) or, if you reside in the EU/EEA, with your national data protection authority (for France: www.cnil.fr).

8. CHANGES TO OUR PRIVACY POLICY

The Company may update this Privacy Policy by posting a new version on the VOCATING App(s). By continuing to use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.

Version 1.1, effective 15/10/2026. Previous version: 1.0 dated 20/04/2026 (available on request).

9. CHILDREN

The Services are intended for users aged 18 and over. Users aged 16 or 17 may use the Services only with the consent of a parent or legal guardian. We do not knowingly collect Personal Data from anyone under 16. If we become aware that we have, we delete it.

10. COOKIES AND WEBSITE ANALYTICS

The website vocating.ai uses strictly necessary cookies and, subject to your consent, analytics cookies. You can accept, refuse or change your choice at any time through the ‘Privacy choices’ link in the website footer. The Vocating mobile app does not use advertising identifiers or third-party advertising SDKs.

11. CONTACT

VOCATING SA, Rue Du-Roveray 20, c/o Vallea SA, 1207 Geneva, Switzerland. privacy@vocating.ai.