RECRUITMENT · PRIVACY
Recruitment
Privacy Policy
Recruitment and Recorded Interviews
VERSION · 19 SEPTEMBER 2026
This policy explains how Novo AI uses information for recruitment and interviews, the choices available to you and how to exercise your rights. Participation is also governed by our Interview Participation Terms & Conditions.
1. Who is responsible?
Novo AI GmbH, Hollerithallee 21, 30419 Hannover, Germany, is responsible for the recruitment processing described here. The company is registered in the commercial register in Hannover under HRB 221489.
Recruitment and privacy contact: [email protected].
This notice covers applications and interviews conducted for Novo AI through interview.novoai.de. It does not replace notices for unrelated visits to our corporate website.
2. What information we use
We process your name, email address, application information you provide, answers to interview questions, communications with us, and our reviewers’ job-related notes and evaluations. If you choose a recorded interview, this includes your image, voice and recorded answers. The platform also processes technical information necessary for delivery and security, including IP address, browser/device information, timestamps and error logs. We keep evidence of your recording consent and any withdrawal.
Please use anonymised examples and avoid sharing former employers’ confidential information or unnecessary information about health, religion, political beliefs or other sensitive matters. If you need an adjustment, contact us privately and provide only what is necessary to arrange it.
Sources of information
We receive information directly from you and create recruitment notes during our review. If you apply through Indeed or another recruitment service, we may receive the application and recruitment messages you choose to share with Novo AI through that service. We will identify the source in our recruitment communication if it is not already clear to you. The service's own privacy notice governs its separate processing. We do not routinely obtain private social-media information or contact your current employer. Any proposed reference check will be explained to you before it takes place.
Recording boundaries
Recording covers the question-and-answer periods disclosed in the interview interface, including pauses within those periods. We do not intentionally record you before recording consent or outside the disclosed recording periods. We do not use screen capture or biometric templates to identify you. An ordinary video contains personal information; we do not use it for technical biometric identification. Please keep other people out of the recording and choose a background that does not reveal unnecessary personal information.
3. Why we process information and our legal bases
We use necessary application information and job-related evaluations to assess your suitability, communicate with you and decide whether to offer employment. The legal basis is section 26(1), read with section 26(8), of the German Federal Data Protection Act (BDSG).
Recording, storing and reviewing your optional video interview is based on your consent under Article 6(1)(a) GDPR and section 26(2) BDSG. You may instead request an equivalent non-recorded interview using the same job-related assessment criteria, without disadvantage. Contact us before starting if you prefer this option.
We process limited security logs to protect the interview service against misuse and resolve technical problems, and retain necessary evidence to establish or defend legal claims. The basis is Article 6(1)(f) GDPR; our interests are secure operation and the protection of legal rights. Where a specific legal obligation requires processing, Article 6(1)(c) applies and we will explain the relevant obligation where applicable.
If you request an adjustment involving health or disability information, we handle necessary information separately and confidentially under the applicable employment-law basis, including section 26(3) BDSG and Article 9(2)(b) GDPR where their conditions are met. We do not request such information in recorded answers.
4. Your choice about recording
By accepting the interview invitation and proceeding after the participation terms have been presented, you agree to the Interview Participation Terms & Conditions and acknowledge that this Privacy Policy explains how your information is handled. This acknowledgement is not blanket consent to every use of your data. Providing relevant information about your suitability is necessary to assess your application; recording is optional and requires a separate, specific choice. Declining recording or withdrawing consent does not itself count against you.
You can withdraw recording consent at any time by emailing the contact above, as easily as you gave it. We will stop further consent-based use and delete the recording without undue delay, unless a specific lawful exception requires limited retention. Withdrawal does not affect processing already carried out lawfully. Necessary application information and job-related assessment records may continue to be processed on their separate legal bases. We will arrange a non-recorded alternative if further assessment is needed.
5. Who can access information?
Access is limited to authorised Novo AI founders and recruitment reviewers who need it for this vacancy, and service providers supporting the process under appropriate contractual arrangements. Professional advisers or authorities receive information only when necessary for a legal matter or legal obligation.
XInterview provides the video-interview platform. Its published privacy notice names Amazon Web Services (AWS) for hosting and Cloudflare for content delivery. Relevant recipient categories also include providers of business email, secure record storage and technical support acting for Novo AI. Provider information is available in the XInterview Privacy Policy; questions about recipients can be sent to [email protected].
Novo AI uses interview information only for recruitment, related communications, service security and the handling of legal rights described in this notice. We do not sell your answers or use your recording for advertising, public promotion or general-purpose AI training. XInterview’s public notice also describes provider purposes such as product improvement and marketing. Those purposes are distinct from Novo AI’s interview use; acceptance of this interview does not itself authorise them. Any optional additional purpose requiring consent must be explained and agreed separately.
6. Processing locations and international transfers
Novo AI is based in Germany. XInterview’s published hosting statement, dated 1 April 2025, identifies Frankfurt, Germany, for its servers and data processing. That statement does not establish the location of every backup, support operation or subprocessor, and this notice does not promise that all processing remains in the European Economic Area (EEA). Novo AI’s policy requires a valid GDPR transfer mechanism before authorising transfers outside the EEA. For information about the locations and safeguards applicable to your data, including how to obtain a copy of relevant safeguards, contact [email protected].
7. How long we keep information
We keep application records while the recruitment process is active. Our maximum retention period for recorded answers is six months after we communicate the final outcome of your application or receive your application withdrawal. Recordings are deleted sooner when no longer needed or when you withdraw recording consent, unless a specific lawful exception requires limited retention. The six-month period is a maximum, not a requirement to keep every recording for that long.
For unsuccessful or withdrawn applications, the maximum retention period for application records, correspondence and assessment notes is six months after communicating the final decision or receiving the application withdrawal. Earlier deletion applies when the information is no longer necessary. Six months is Novo AI’s chosen maximum for this process; it is not a universal statutory retention period.
If you join us, we transfer only information necessary for your employment into your personnel records and provide the applicable employee privacy notice. We do not retain interview recordings as routine personnel records.
Consent records: retained for no longer than six months after the final application outcome or application withdrawal, including necessary evidence of any recording-consent withdrawal.
Technical and security logs: retained for no longer than six months from creation and deleted earlier when no longer needed.
Backups: residual copies are restricted from ordinary use and must be erased or overwritten within a maximum of six months after deletion from active systems. Deletions must be reapplied if a backup is restored. This does not authorise continued recruitment use of deleted data.
Where a specific dispute or legal obligation requires longer retention, only the necessary information is kept with restricted access, for the duration of that need. The reason and applicable retention criteria will be explained where required. A shorter provider retention period may result in earlier deletion.
We do not add you to a talent pool without a separate optional arrangement and notice.
8. How hiring decisions are made
People assess your relevant experience, reasoning, working methods and job-related answers. Novo AI’s interview policy requires human hiring decisions and does not permit solely automated acceptance or rejection, personality or emotion inference, facial recognition, or automated deception detection. We do not assess suitability from appearance, accent, eye contact or nervousness. The mere availability of an AI feature within the platform does not mean it is authorised for this recruitment process.
Any use of automated transcription, AI scoring or ranking requires a specific assessment and clear information to affected applicants about the purpose, data involved and role of human review before it begins. Accepting the interview or these policies is not blanket permission to introduce such processing or to train general-purpose AI models.
9. Cookies and similar technologies
The platform may use cookies and similar technologies for service delivery and security. XInterview’s public notice describes session and persistent cookies and names Microsoft Clarity, Google Analytics and Facebook Pixel. This is provider-published information, not a claim that every listed tool operates in this interview. Novo AI’s policy requires a separate informed choice before non-essential storage or access that requires consent. Interview acceptance does not provide that consent. See the XInterview Privacy Policy and any technology information and choices displayed in the interview interface. Privacy enquiries can be sent to [email protected].
10. Your rights
Subject to the applicable legal conditions, you can request access to your data, correction, deletion, restriction of processing and data portability. You can withdraw consent as described above. Where processing relies on legitimate interests, you may object on grounds relating to your particular situation.
Contact us using the details in section 1. We normally respond within one month; if a lawful extension is necessary, we will explain it within that month. We may request proportionate information to verify your identity.
You may complain to a supervisory authority, including the authority where you live or work or where an alleged infringement occurred. Our local authority is the Landesbeauftragte für den Datenschutz Niedersachsen: https://www.lfd.niedersachsen.de/.
11. Security and handling requests
We apply technical and organisational safeguards appropriate to the risks of applicant information. These include restricted reviewer access, confidential handling, protection during transmission and storage, and controlled deletion. Our service providers must support our documented instructions and relevant data-rights requests. No internet service can promise absolute security; this does not reduce our legal responsibilities.
Please report a suspected privacy incident to [email protected]. We investigate incidents and notify the competent authority and affected people where legally required. Please do not include passwords or identity documents in an initial report.
We do not require you to give up a complaint, access request or other statutory right as a condition of participating. Requests are normally handled free of charge. Any lawful refusal, restriction or fee will be explained together with the available complaint options. Information about other people and legally protected material may need to be redacted, without preventing access to your own data where the law requires it.
12. Updates
The date above identifies this version. We will make relevant changes available and notify affected applicants where required. Publishing a revised notice does not itself authorise a new use of previously collected information.