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Privacy Notice

Version 2026-10-12.draft-1 / en-US

Draft for counsel review. Not yet in effect. Text in double braces is a placeholder that will be filled in before this document takes effect.

ApplyPilot has two parts: a cloud account service and a Local Agent that runs on your own computer. Most application data stays on your computer, but not all of it: some data is stored in our cloud, some passes through it, and AI document generation sends selected professional information to Google. This notice says exactly which. It is a draft prepared for legal review.

1. Who is responsible

{{LEGAL_ENTITY}} is responsible for the personal information described in this notice. Our {{PRIVACY_OWNER_ROLE}} is accountable for privacy and can be reached at {{PRIVACY_EMAIL}}.

Counsel review note: Controller identity, EU/UK representative (if required) and India grievance officer details are COUNSEL_REQUIRED.

2. What we store in our cloud

Account: your email address, first and last name, a password hash (Argon2id; we never store your password itself), whether your email is verified, your country of residence, billing country, and the countries where you want jobs.

Sign-in sessions: a hash of the session token, the browser user agent, the IP address used to sign in, and timestamps. These let you see and revoke your signed-in devices.

Paired devices: the device name, operating system label, Local Agent version, the device's public encryption key, a hash of the device secret, and whether the device is currently connected.

Settings and onboarding: your automation and notification preferences, your onboarding progress, and the structured resume and cover-letter starting information you explicitly approved for cloud storage during onboarding.

Subscription: your plan, status and renewal date, and our payment processor's customer and subscription identifiers. The processor sends us event records about your subscription; we keep them for billing records. We never receive your full card number.

Legal and consent records: which versions of these documents you accepted and when, your marketing preferences and any withdrawal, and your AI processing acknowledgement.

Privacy requests you send us and how we handled them.

Human-verification events: when an employer's website needs you to complete a security check, we store only the kind of check (for example CAPTCHA or MFA), the portal name (for example Workday), the status and timestamps. We do not store codes, tokens, cookies, page content, screenshots, job addresses or questions.

Security records: sign-in successes and failures, password changes, device pairing and revocation, and similar events, with the IP address where relevant.

3. What stays on your computer

The Local Agent keeps these in the workspace folder you choose, and in your operating system's credential store: your full professional profile and evidence library, generated resumes and cover letters, job descriptions, application history and status, application screenshots, the browser profile used for applications (including employer website cookies), the detailed record of each verification pause, and your applicant-site passwords and email app password.

Applicant-site passwords and your email app password are stored in your operating system's credential store (Windows Credential Manager), not in a plain file and not in our cloud.

4. What passes through our cloud without being stored

When you view your jobs, applications or profile in the dashboard, your browser asks your Local Agent for them through our relay. That data passes through our servers encrypted in transit (HTTPS) and is not written to our database or logs.

When you enter an applicant-site password or email app password in the dashboard, your browser encrypts it with your paired device's public key before sending it. Our servers relay only the encrypted form and cannot decrypt it. If your browser cannot perform this encryption, the dashboard refuses to send the credential and asks you to enter it in the Local Agent instead.

5. AI document generation

If you use AI resume or cover-letter generation, your Local Agent sends Google's Gemini service the job description and a limited set of your professional information: verified skills, job titles, employers, employment dates, experience bullet points, degrees and institutions, and certifications. This is used only to draft your documents.

We never send Gemini your passwords, security codes, cookies, CAPTCHA data, contact details, demographic or equal-opportunity answers (such as race, ethnicity, gender, disability or veteran status), age or date of birth, government identifiers, immigration document numbers, criminal-history or background-check answers, legal attestations, or salary information.

For customer data we use only a paid Google Gemini service. We do not use a free tier for customer data and we do not switch to another AI provider. AI is never used to fill in or submit applications.

We explain this and ask for your acknowledgement before the first AI generation.

Counsel review note: Whether AI processing needs notice or consent per jurisdiction is COUNSEL_REQUIRED (see config/compliance/countries.yaml ai_processing_basis).

6. Employers and applicant-tracking websites

When you apply for a job, the information in that application goes to the employer and to the applicant-tracking system the employer uses. Their own privacy policies apply to what they do with it.

7. Your email account

If you connect an application email account, the Local Agent signs in to it from your computer to read application and account-verification messages for the applications it is handling. Security codes for sign-in to employer websites are not read automatically by default; you complete those yourself.

8. Why we use your information

To provide the service you signed up for: running your account, pairing your devices, relaying commands to your Local Agent, preparing and submitting applications as you configure, and pausing for verification.

To keep the service secure: detecting misuse, investigating incidents and protecting accounts.

To bill you, if you subscribe, and to keep financial records.

To send service messages you need, such as email verification and password changes.

To send product news and offers only if you opted in. You can withdraw at any time.

To meet legal obligations and respond to privacy requests.

Counsel review note: Lawful-basis mapping per purpose and per jurisdiction (GDPR/UK GDPR Article 6, DPDP, PIPEDA) is COUNSEL_REQUIRED.

9. Service providers

We use service providers only for the purposes above. The current list, with what each one receives and where, is on our Subprocessors page. We update it before a new provider starts receiving personal information.

10. International transfers

Some providers process information in countries other than yours, including the United States. Where the law requires a transfer mechanism, we will name it here before offering ApplyPilot in that country.

Counsel review note: Transfer mechanisms (SCCs, UK IDTA/Addendum, DPDP restrictions) are COUNSEL_REQUIRED.

11. Cookies and similar storage

We use only storage that is needed for the service: a sign-in session cookie, a security cookie that prevents cross-site request forgery, and small browser preferences. We do not use advertising or cross-site tracking. See the Cookies page for details.

12. How long we keep information

Account information is kept while your account exists. Expired sessions, sign-in tokens and pairing codes are deleted after short fixed periods, and verification events after 30 days. Billing, security, legal-acceptance, consent and privacy-request records are kept for periods that are being confirmed with legal counsel; we will state them here before launch. Your Privacy Center shows the current schedule.

Counsel review note: Statutory retention periods are COUNSEL_REQUIRED (config/compliance/retention.yaml).

13. Deleting your account

You can delete your cloud account from the Privacy Center. Deletion signs you out everywhere, disconnects your devices, and removes your name and email from your account record immediately.

Some records are kept after deletion for the reasons and periods shown at the time of deletion: billing records for accounting and tax, and security records for investigating abuse. We do not say that everything is deleted immediately, because that would not be true.

Files on your computer are not deleted by deleting your cloud account. You can delete them yourself, or ask the Local Agent to delete your workspace; it asks you to confirm on your computer before deleting anything.

14. Your rights

Depending on where you live, you may have rights to access, correct, delete or receive a copy of your information, to withdraw consent, to object to or restrict some processing, and to opt out of marketing. You can use most of these directly in the Privacy Center, or send a request there or to {{PRIVACY_EMAIL}}. We may need to confirm your identity first. We do not refuse requests automatically; a person reviews every request.

15. Questions and complaints

Contact {{PRIVACY_EMAIL}} with any question or complaint. You may also complain to the data protection authority where you live.

Counsel review note: Regulator references and grievance timelines per jurisdiction are COUNSEL_REQUIRED.

16. Children

ApplyPilot is only for people aged 18 or over. We do not knowingly collect information from anyone under 18. If you believe a person under 18 has created an account, contact {{PRIVACY_EMAIL}}.

17. Security

Our Security page describes the controls we actually use. No system is perfectly secure. Report a suspected security issue to {{SECURITY_EMAIL}}.

18. Changes

We publish each version of this notice with a version number. If a change matters, we tell you before it takes effect.

Related: Subprocessors / Cookies / Make a privacy request