PRIVACY POLICY

1. Controller

Steven Lucchesi
Rheinweg 5, 8200 Schaffhausen, Switzerland
Email: Neuralw1@gmail.com

This privacy policy applies to the NeuralWorker.one platform and complies with the Swiss Federal Act on Data Protection (revDSG) and, where applicable, the EU General Data Protection Regulation (GDPR).

Referral program data

If you participate in the referral program, we process only the data needed to verify reward eligibility and make payouts, such as invite linkage, approved project hours, project completion confirmation, provider payment confirmation, payout method, payout identifier, and reward status.

2. Data We Collect

• Account data: Email address used for login and profile fields you add manually
• CV processing data: CV files or pasted text used temporarily to extract text for your review
• Profile data: Skills, experience, languages, and other professional attributes that you confirm for storage
• Usage data: Job views and interactions within the platform (for matching improvement)
• Operational metadata: Metadata-only processing and audit events needed to operate, secure, and troubleshoot the service without storing CV content
• Project workflow data: Company applications, project participation status, agreement acceptance records, and completion confirmations needed to run project infrastructure features
• Technical data: Session cookies required for authentication

3. Legal Basis for Processing

We process your personal data on the following legal grounds:

• Contractual necessity (Art. 6(1)(b) GDPR / Art. 31(2)(a) revDSG): Account data and profile data are processed to provide the job-matching service you have requested.
• Consent (Art. 6(1)(a) GDPR / Art. 31(1) revDSG): Cleaned CV text is processed only after your explicit review and consent in the CV flow.
• Legitimate interests (Art. 6(1)(f) GDPR): Usage analytics are processed for platform improvement, provided these interests are not overridden by your rights.

4. AI Processing of CV Data

NeuralWorker first extracts CV text and shows it to you for review. Possible personal information is highlighted, and you can remove or manually mark text before any AI-assisted analysis occurs. Only the cleaned text you explicitly confirm is sent for professional skill extraction. The original CV file is not permanently stored, and AI suggestions are not saved as your profile until you review and confirm them.

5. Data Processors (Third Parties)

We use external service providers where needed to operate the platform:

• Supabase - Database and authentication infrastructure.
• OpenRouter - AI API gateway used for AI-assisted CV extraction when the user has explicitly consented.
• Selected AI model providers - Provide the model used for AI-assisted extraction through the configured provider path.
• Google - Used for Google Sign-In where that login option is selected.

6. International Data Transfers

Some service providers may process personal data outside Switzerland, the EU, or the EEA. Where required, such transfers are handled using an applicable legal transfer mechanism, such as an adequacy decision, standard contractual clauses, or other permitted safeguards.

7. Data Retention

Original CV files are not permanently stored. Raw extracted text and cleaned text are used only during the active CV processing flow and are not stored as profile content. Confirmed profile data is retained while your account remains active. You can delete your account from Settings. After deletion, account-related data is removed unless a legal retention duty applies. Operational metadata is kept only as long as needed for service operation, security, abuse prevention, or legal obligations.

8. Cookies

We use only technically necessary cookies for authentication (session management via Supabase Auth). No marketing, advertising, or tracking cookies are used. No cookie consent banner is required because no non-essential cookies are set.

9. Your Rights

Under the GDPR and revDSG, you have the following rights:

• Access: Request a copy of the personal data we hold about you
• Rectification: Request correction of inaccurate data
• Erasure:Request deletion of your data ("right to be forgotten")
• Restriction: Request that we restrict processing of your data
• Data portability: Receive your data in a structured, machine-readable format
• Objection: Object to processing based on legitimate interests
• Withdrawal of consent: Withdraw consent at any time without affecting prior processing

To exercise any of these rights, please contact: Neuralw1@gmail.com. We will respond within the period required by applicable law.

10. Security and Abuse Prevention

We use technical safeguards such as authentication, row-level database access rules, rate limits, CAPTCHA checks for public contact forms, and server-side controls for CV analysis capacity. These measures help protect user data and prevent misuse of the platform and third-party AI services.

11. Right to Lodge a Complaint

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the competent supervisory authority:

• Switzerland: Federal Data Protection and Information Commissioner (FDPIC / EDOB) - www.edoeb.admin.ch
• EU users: The supervisory authority of your EU member state of residence.

12. Changes to this Policy

We may update this privacy policy from time to time. Material changes will be communicated by email. The current version is always available at neuralworker.one/datenschutz.