Privacy Policy

1. Introduction

PRO PROFILE (Pty) Ltd ("ProProfile", "we", "us", "our") is committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you use the ProProfile platform ("Platform"), including our website and all associated services.

This policy is drafted in compliance with:

• POPIA -- Protection of Personal Information Act, 2013 (Act No. 4 of 2013)
• PAIA -- Promotion of Access to Information Act, 2000 (Act No. 2 of 2000)
• GDPR -- General Data Protection Regulation (EU) 2016/679, for users in the European Economic Area

By creating an account or using our Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use our Platform.

2. Who We Are

ProProfile is a video-first professional identity platform that enables candidates to create verified video CVs and employers to search, view, and engage with candidates for hiring purposes.

3. Definitions

Candidate

An individual who has created an account to build a professional profile and seek employment.

Data Subject

The natural person to whom personal information relates (POPIA) or the identified/identifiable natural person (GDPR).

Employer

An individual or company that has created an account to search for and engage with candidates.

Information Officer

The person designated under POPIA Section 55 responsible for compliance.

Operator

A third-party service provider that processes personal information on our behalf (equivalent to "Processor" under GDPR).

Personal Information

Information relating to an identifiable, living natural person as defined in POPIA Section 1.

Processing

Any operation concerning personal information, including collection, storage, use, and destruction.

4. Information We Collect

4.1 Account Information

• Full name, email address, and password (encrypted by AWS Cognito)
• Company name and contact name (employer accounts)
• Account type (candidate, employer, admin, or auditor)

4.2 Candidate Profile Data

• Professional headline, biography, and career information
• Work experience, education, certifications, and professional memberships
• Skills, salary expectations, notice period, and location preferences
• References (name, relationship, company, position, email, phone number)
• External links (LinkedIn, GitHub, portfolio)
• Uploaded documents (certification documents, skill evidence)

4.3 Employer Profile Data

• Company registration number, industry, size, and description
• Website, city, province, and office address
• Meeting link and scheduling preferences
• Team member names and emails (Pro plan)

4.4 Video and Audio Content

• Video recordings (culture videos, project walkthroughs)
• Voice recordings from scenario-based assessments
• Auto-generated transcripts from walkthrough videos
• AI-extracted skills and confidence scores (only when explicitly requested and paid for)

4.5 Transaction Data

• Subscription plan selection and payment history
• Interview credit and walkthrough AI payment records
• Donation records

We do not store payment card numbers. All card data is handled directly by Yoco.

4.6 Usage Data

• Search queries and filter selections (employer accounts)
• Profile and video view activity
• Shortlist and interview request history
• Authentication timestamps and session data
• Page-load performance and JavaScript error telemetry from your browser (see section 14)

5. How We Collect Information

Directly from you

When you register, complete your profile, upload videos or documents, make payments, or use platform features.

From third parties

Mux (video processing status, transcripts), Yoco (payment confirmations), AWS Cognito (authentication events), Cloudflare (the result of the human-verification check), referees (reference confirmations), and -- only if you or an employer use them -- Telegram (messages you send us) and Calendly (interview booking confirmations).

Automatically generated

Authentication logs, API access logs, video transcripts, AI skill extractions (when requested), and audit logs.

6. Purposes of Processing

• Service delivery: Account management, profile hosting, video hosting, search and discovery, interview facilitation, payment processing, and transactional emails
• Verification and trust: Admin credential verification, peer verification, AI skill extraction, reference confirmation, and digital credential issuance
• Compliance: POPIA compliance monitoring (auditor portal), audit trails, financial record-keeping, and regulatory reporting
• Security: Fraud detection, abuse prevention, rate limiting, and platform integrity
• Improvement: Monitoring platform health, identifying bugs, and understanding usage patterns

• Commercial data products: aggregate statistics and de-identified records sold to buyers such as research and workforce-analysis organisations, under the consent tiers described in section 8

We do not process personal information for targeted advertising or advertising profiles. We do sell the data products described in section 8; that section sets out exactly what they contain and what is removed first.

7. Legal Basis for Processing

Under POPIA, we process your personal information based on:

• Consent (Section 11(1)(a)): Account registration, video uploads, AI skill extraction
• Contract (Section 11(1)(b)): Service delivery, subscriptions, interview facilitation
• Legal obligation (Section 11(1)(c)): Tax records, POPIA compliance, breach notification
• Legitimate interest (Section 11(1)(f)): Security, fraud prevention, platform improvement

For GDPR (EEA users), equivalent bases apply under Articles 6(1)(a) through 6(1)(f).

8. How We Share Your Information

Within the Platform

Employers can view candidate professional profiles and video content. Candidate email addresses, phone numbers, Cognito identifiers, and reference contact details are stripped from all employer-facing API responses and are never visible to employers.

With Operators (Third-Party Processors)

Below is the full list of operators that process personal information on our behalf, or that receive it because you or your employer switched a connection on. Operators marked employer-connected receive nothing unless an employer connects them to their own account; operators marked optional receive nothing unless you choose to use that feature.

Data Products We Sell

We sell data products, and this section says exactly what they contain. It replaces an earlier statement that we sold no data at all, which was not accurate.

• Aggregate statistics. Counts and trends by province, industry and role level. No individual records, and a group too small to be anonymous is reported as a range rather than an exact number.
• De-identified records. Row-level work-status data with your name, contact details and account identifiers removed, every internal reference replaced by a one-way pseudonym, dates reduced to the day, and a row released only where at least five records share the same combination of characteristics.
• Your identified profile, only by your choice. An employer receives a profile that identifies you only where you have given consent for that specific opportunity, and each such disclosure is recorded. Identified profiles are never sold in bulk.
• Research datasets. Available to academic or clinical partners under a data-use agreement, and only for people who have specifically opted in.

We never sell your name, contact details, cellphone number, video or documents. We do not use your personal information for targeted advertising or advertising profiles, and we do not rent or trade it for marketing.

Current status, stated plainly: buyer access to the de-identified record feed, and the nightly build of that dataset, are both switched off while we confirm the de-identification against real output. There is no public sign-up for these products at present. We will not describe a safeguard as being in force while the process it protects is suspended.

We may disclose information when required by law, regulation, or legal process.

9. Cross-Border Data Transfers

Our primary infrastructure is hosted in the AWS af-south-1 (Cape Town, South Africa) region. Most personal information remains within South Africa.

The following processing takes place outside South Africa:

• AWS SES (United States) -- transactional email delivery
• AWS SNS (United States) -- the one-time verification code sent to your cellphone, which means your cellphone number leaves South Africa for delivery
• AWS Bedrock (United States) -- AI skill extraction, scenario generation, and walkthrough scoring
• Anthropic (United States) -- AI skill suggestions and video safety screening called directly
• Mux (United States) -- video encoding, storage, and playback
• Cloudflare (global network) -- the human-verification check on public pages
• Adzuna (United Kingdom) -- the search words you type when browsing external job adverts
• Telegram (outside South Africa) -- only if you use our chat channel
• Calendly, Slack, Microsoft Teams, Greenhouse, Lever -- only where an employer has connected that service to their own account

Automated video safety screening and our monitoring telemetry stay inside the Cape Town region.

All cross-border transfers comply with POPIA Section 72 and are protected by Data Processing Addenda, Standard Contractual Clauses, and encryption in transit and at rest.

10. Data Retention

• Active accounts: Data retained for the duration of the account
• Deleted accounts: Profile data, videos, and documents deleted promptly. Audit logs retained 90 days. Financial records retained 7 years.
• Inactive accounts: Accounts with no activity for 24 months may be deleted after notification
• Reference tokens: Expire after 14 days
• API logs: 30-day retention

11. Data Security

We implement appropriate technical and organisational measures:

• AES-256 encryption at rest for all stored data
• TLS 1.2+ encryption for all data in transit
• Private VPC network isolation for database infrastructure
• AWS Cognito authentication with JWT-based API authorisation
• Role-based access controls (candidates, employers, admins, auditors)
• Signed and time-limited URLs for video playback and document access
• All credentials stored in AWS Secrets Manager (never in code)
• Parameterised database queries (preventing SQL injection)
• Automated daily backups with 7-day retention
• Multi-AZ database deployment in production

12. Your Rights

As a data subject under POPIA, you have the right to:

• Access (Section 23): Request a copy of all personal information we hold about you
• Correction (Section 24): Request correction of inaccurate or incomplete information
• Deletion (Section 24): Request deletion via account deletion in Settings
• Portability: Download everything we hold about you, as a file, from your Settings page. Anything deliberately left out is named in that file with the reason, and the file says plainly whether you have all of it. Each download is recorded.
• Objection (Section 11(3)): Object to processing on reasonable grounds
• Withdraw consent: Withdraw consent at any time by deleting your account
• Complain (Section 74): Lodge a complaint with the Information Regulator

To exercise any of these rights, email nkosinathi.dhliso@gmail.com. We will respond within 30 days.

13. Automated Decision-Making

ProProfile uses AI (Anthropic's Claude models, reached both through AWS Bedrock and directly from Anthropic) to extract skills from project walkthrough video transcripts. This processing:

• Is only triggered when explicitly requested and paid for by the candidate
• Uses only the text transcript (not video or audio)
• Produces suggested skills that the candidate must manually review and confirm
• Does not make decisions with legal or similarly significant effects

Uploaded video is also screened automatically for safety and authenticity concerns. That screening only raises a flag for a human administrator to look at; it does not itself approve, reject or hide anything.

We do not make automated hiring decisions. All candidate-employer interactions are initiated by human users. Verification decisions are made by human administrators.

14. Cookies, Local Storage and Analytics

ProProfile uses your browser's local storage for essential things only: keeping you signed in, remembering your theme, remembering which portal you last used, and recording your cookie choice. We set no advertising cookies and no social-media tracking.

We do use two third-party services that run in your browser, and neither is advertising:

• Human verification (Cloudflare) on public pages, which processes your IP address and browser characteristics to tell a person from a bot.
• Performance and error monitoring (AWS CloudWatch RUM), which records how quickly pages load and which JavaScript errors occur. It sets no cookies, and identifiers and one-time links are removed from page addresses before anything is sent. It exists so we can find faults, not to profile you.

An earlier version of this policy said we used no analytics services of any kind. That was not accurate, and this section replaces it.

No advertising or marketing analytics tag is loaded on this site today. If we ever add one, it will run only if you choose "Accept all" below.

15. Children's Privacy

We do serve people under 18, and only for learning. ProProfile runs a portal for school learners, most of whom are under 18. A learner may hold a learning account. They are never treated as a product.

The legal ground we rely on. Section 34 of POPIA prohibits processing the personal information of a child unless a section 35 ground applies. Ours is section 35(1)(a): the prior consent of a competent person, which means the learner's parent or legal guardian. We ask for that consent by emailing the guardian a link they click to give it, and the learner's sessions do not run until they have. If we do not know a learner's age, we treat them as a child and ask anyway. We hold no identity document and no identity number for anybody, of any age.

What we do with a learner's information while they are under 18. We use it to run the learning product and to show their progress to them and to their guardian. Nothing else.

What we never do. We do not publish a learner's profile publicly. We do not show them to employers or to sporting scouts. We do not include them in any data product we sell, including the ones we have stripped of names and the ones that are only totals: adding a child up into an average does not make it acceptable to sell. We do not send them marketing. We do not pass their details to a school, a bursary provider or an employer, and there is no setting that lets anybody agree to that on their behalf.

Withdrawing consent deletes things. A guardian can withdraw at any time using the link in the email we sent them, which does not expire. Withdrawing stops further sessions and deletes the sessions already taken, the results from them, and the work submitted for marking. The account itself stays, so consent can be given again later. We keep the record of the consent and of its withdrawal, because that record is how we can show we honoured it.

Rights. A guardian may exercise the rights in section 12 of this policy on their child's behalf, including access, correction and erasure. When a learner turns 18 they consent for themselves and the guardian's consent is no longer the ground we rely on.

16. Data Breach Notification

In the event of a security compromise that affects your personal information, we will notify the Information Regulator and affected data subjects within 72 hours of becoming aware of the breach, as required by POPIA Section 22.

Notification will include a description of the breach, the data affected, measures taken, and recommendations for protecting yourself.

17. Platform-Specific Processing Details

Video Pipeline

Videos are uploaded directly to Mux (they do not pass through our servers). Videos are reviewed by human administrators before becoming visible to employers. Signed, time-limited playback URLs ensure only authorised viewers can watch. All video assets are deleted when you delete your account.

Reference Verification

When you add a reference, an email with a time-limited confirmation link (14-day expiry) is sent to the referee via AWS SES. Referee contact details are never shared with employers.

Payment Processing

All payments are processed by Yoco. Card details are entered on Yoco's page and never touch our servers. We record transaction outcomes but never card details.

Credential Verification

Admins verify credentials through document review, reference confirmation, manual verification, and voice scenario assessment. Verified credentials receive cryptographically signed digital credentials. If you edit a verified credential, its verification status resets.

18. GDPR Provisions (International Users)

If you are located in the European Economic Area:

• PRO PROFILE (Pty) Ltd acts as the data controller
• International data transfers are protected by Standard Contractual Clauses
• You have additional rights under GDPR Articles 15-22 (restriction, portability, erasure)
• You may lodge a complaint with your local supervisory authority under GDPR Article 77

19. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify registered users of material changes via email. The "Last updated" date at the top indicates when this policy was last revised.

20. Contact Information

For privacy-related enquiries or to exercise your rights:

21. Complaints

If you are dissatisfied with how we handle your personal information, please contact our Information Officer first. We will investigate and respond within 30 days.

If you are not satisfied with our response, you may lodge a complaint with the Information Regulator of South Africa: