Privacy Policy

1. Introduction

This Privacy Policy explains how FirstLook ("we", "us", or "our") collects, uses, stores, and protects your personal data when you use our website and services. We are committed to protecting your privacy and handling your data in an open and transparent manner.

FirstLook is the data controller for the personal data we process, unless otherwise stated.

2. Information We Collect

For Employers

When you create an employer account, we collect:

• Name and email address
• Company name and details
• Payment information (processed securely via Stripe)
• Usage data and preferences

For Candidates

When you apply for a role through FirstLook, we collect:

• Email address and name
• Assessment responses (written, audio, video, or code)
• CV and cover letter (if uploaded)
• Behavioural data during assessments (see Section 3)

3. Behavioural Data Collection

To verify the authenticity of candidate responses, we collect behavioural signals during assessments. This includes:

• Time spent on the assessment
• Typing patterns and keystroke timing
• Edit and revision activity
• Paste events
• Tab focus changes

This data is used to calculate an authenticity score that helps employers identify genuine, engaged candidates. Candidates are informed that this data is collected before they begin an assessment.

4. How We Use Your Data

We use your personal data to:

• Provide and operate our services
• Process and display candidate applications to employers
• Calculate authenticity scores for candidate submissions
• Send service-related notifications and updates
• Process payments and manage subscriptions
• Improve our services and develop new features
• Comply with legal obligations

5. Legal Basis for Processing

We process personal data on the following legal bases:

• Contract: To provide our services to employers under our terms of service
• Legitimate Interest: To facilitate job applications and improve our services
• Consent: For candidates, where consent is provided before submitting an application
• Legal Obligation: To comply with applicable laws and regulations

6. Data Sharing

We share candidate data with the employers they apply to. This includes assessment responses, authenticity metrics, and CV/cover letter data when revealed by the employer.

We may also share data with:

• Payment processors (Stripe) to handle transactions
• Cloud hosting providers to store data securely
• Analytics providers to improve our services
• Law enforcement when required by law

We do not sell your personal data to third parties.

7. Data Retention

We retain personal data as follows:

• Candidate submissions are deleted within 30 days of a role being closed or the candidate being rejected
• Candidate data is deleted within 7 days upon request
• Employer account data is retained for the duration of the account and deleted within 30 days of account closure

8. Data Security

We implement appropriate technical and organisational measures to protect your personal data, including:

• Encryption of data in transit and at rest
• Secure data centres located in the UK/EU
• Access controls and authentication
• Regular security assessments

9. Your Rights

Under UK GDPR, you have the right to:

• Access: Request a copy of your personal data
• Rectification: Request correction of inaccurate data
• Erasure: Request deletion of your data
• Restriction: Request limitation of processing
• Portability: Request your data in a machine-readable format
• Object: Object to processing based on legitimate interests

To exercise these rights, please contact us at privacy@firstlooknow.com. We will respond within 30 days.

10. Cookies

We use cookies and similar technologies to operate our services and improve your experience. For more information, see our cookie settings when you first visit our site.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by posting a notice on our website or sending you an email.

12. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us:

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) if you believe your data has been mishandled.