Last updated: July 2026
This Data Processing Addendum (“DPA”) forms part of the Aigis Terms of Service and applies whenever you (a hiring manager or recruiter, the “Controller”) use Aigis's hiring features to process personal data of candidates — principally CVs you upload for AI-assisted screening. Aigis acts as your “Processor” within the meaning of Article 28 GDPR.
Aigis processes candidate personal data solely to provide the hiring features you invoke — text extraction, structuring, AI-assisted scoring against your job criteria, pipeline management, and Twin invitations — and only on your documented instructions, which you give through your use of the product. Aigis will not process candidate data for its own purposes: Aigis never uses candidate data to train AI models, and AI inference runs on API terms under which our AI sub-processor does not use your data for model training.
Data subjects: job candidates whose CVs you upload. Categories: identification and contact data, education and employment history, skills and qualifications, and any other personal data contained in the documents you upload. You agree not to upload special-category data unless it is incidental to a CV's content and you have a lawful basis for it.
Candidate CV data is retained for 28 days after last activity on the record, with a hard maximum of 180 days, after which it is automatically and permanently deleted (file, extracted text, AI scores, and search-index entries). You can delete any candidate at any time, with immediate effect across all live systems. Deleting your account deletes all candidate data you control. Short-lived encrypted infrastructure backups exist for disaster recovery only: deleted data ages out of them automatically (daily backups within days; the longest-lived within three months) and backups are never used to restore deleted candidate data.
Aigis applies the measures described in our Privacy Policy: encryption at rest for candidate content and files (Fernet, AES-128-CBC), hashed lookups for personal identifiers, TLS in transit, application-layer key management, and access restricted to the hiring account that uploaded the data.
You authorise the following sub-processors. Aigis will update this page before adding or replacing sub-processors; continued use after an update constitutes acceptance.
| Sub-processor | Purpose | Location |
|---|---|---|
| Railway Corp. | Infrastructure hosting (application, database, file storage) | United States (EU data residency dependent on service configuration) |
| Google LLC (Gemini API) | AI model inference for scoring, summaries, and Twin responses | United States / global (queries are not used for model training) |
| Resend, Inc. | Transactional email delivery | United States |
| Functional Software, Inc. (Sentry) | Error monitoring (exception reports may reference record identifiers; PII sending is disabled and events are scrubbed) | United States |
| Grafana Labs (Grafana Cloud) | Performance telemetry (request traces carry record identifiers, not candidate content) | European Union / United States |
Taking into account the nature of the processing, Aigis will assist you in responding to candidate data-subject requests (access, rectification, erasure, objection) — in most cases you can action these yourself in-product by viewing or deleting the candidate record. Aigis will notify you without undue delay after becoming aware of a personal data breach affecting candidate data you control, and will make available the information reasonably necessary for your Article 33/34 obligations and DPIAs (see our AI transparency page for a description of the processing logic).
On written request (no more than once per year), Aigis will make available information reasonably necessary to demonstrate compliance with this DPA. Where processing involves transfers outside the EEA/UK, the parties rely on the sub-processors' applicable transfer mechanisms (including Standard Contractual Clauses and, where applicable, the EU–US Data Privacy Framework).
You remain responsible for the lawfulness of the processing: a lawful basis for uploading candidate data, notice to candidates (GDPR Articles 13/14 — including that AI-assisted screening is used), meaningful human review of every candidate outcome, and compliance with employment and AI laws in your jurisdiction. See our Responsible AI Screening guide for a practical checklist and notice template.
Questions about this DPA or data processing? Contact hello@aigis.bio