Privacy Policy

Lemonly Technologies Inc., trading as lemonly ("lemonly," "we," "our," or "us") values your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use any of our products or services, including the lemonly hiring platform, Interview Copilot, and related features.

1. Who We Are and What We Do

lemonly is a hiring and career application platform that helps employers evaluate candidates fairly and efficiently through AI-assisted screening, interview analysis, and role matching.

Depending on context:

• We act as Data Controller for personal data collected directly from candidates when they apply to roles or otherwise interact with lemonly.
• We act as Data Processor for hiring managers and organizations that use lemonly to manage recruitment, including when data is synced from integrated systems.

2. Information We Collect

2.1 Candidates

When you apply for a role, participate in an interview, or otherwise use lemonly, we may collect:

• Contact details (name, email address, phone number)
• Resume, cover letter, and other application materials
• Interview audio or video recordings, transcripts, and notes (via Interview Copilot)
• AI-generated summaries, scores, and assessments
• Prior application context within lemonly (e.g. past evaluations or outcomes)
• Any additional information you voluntarily provide (e.g. messages or feedback)

If a hiring manager uploads or syncs your information (including via an ATS), they are responsible for ensuring they have a lawful basis to do so.

2.2 Hiring Managers

When you create an account or use lemonly, we may collect:

• Business contact details and login credentials
• Job descriptions, interview criteria, and internal notes
• Candidate evaluation data generated within the platform
• Billing and payment information (for paid features)

2.3 ATS and Third-Party Integrations

At the direction of hiring managers, lemonly may integrate with third-party systems such as applicant tracking systems (ATSs) (e.g. Ashby, BambooHR or similar platforms).

Through these integrations, lemonly may receive candidate data already held by the hiring organization in order to provide assessment, evaluation, and hiring support services.

2.4 Automatically Collected Data (All Users)

• Device and browser information
• IP address and approximate location
• Usage data such as pages visited, features used, and timestamps

2.5 Advertising and Marketing Platform Data

When we run advertising campaigns, we access data from third-party advertising platforms to manage and measure our own marketing. This may include:

• Campaign, ad group, and creative performance metrics (impressions, clicks, spend, conversions)
• Aggregated, non-identifying audience demographics (e.g. job function, industry, seniority)
• Contact details voluntarily submitted by individuals through lead-generation forms on these platforms (e.g. name, email, company), where we use such forms

We access this data only for our own owned-and-operated advertising accounts. We do not collect or process platform member profile data beyond what is necessary to manage our own advertising.

3. How We Use Your Information

We use personal data to:

• Provide, operate, and improve the lemonly platform and Interview Copilot
• Evaluate applications and interview data using AI-assisted tools
• Reuse application data within lemonly to support future applications and role matching
• Generate transcripts, summaries, and structured assessments for hiring managers
• Maintain consent records and audit logs
• Provide customer support and respond to inquiries
• Manage, measure, and optimize our own advertising campaigns across third-party advertising platforms
• Prevent misuse and comply with legal obligations

Reuse of candidate application data within lemonly is a core and inherent part of the service.

Where we access data through third-party advertising-platform APIs, we use it solely to manage and analyze our own owned-and-operated advertising accounts. We do not sell this data, share it with third parties, or use it to build or enrich any external database or product. Such data is retained and deleted in accordance with Section 8, and our use complies with the applicable terms of each advertising platform.

4. Lawful Bases for Processing (GDPR Article 6)

lemonly processes personal data only where permitted by applicable data-protection laws. Depending on the context, we rely on the following lawful bases:

• Performance of a contract — We process candidate application data and related context where necessary to deliver the lemonly service. This includes evaluating applications, reusing application data across roles, and matching candidates to relevant opportunities within the platform.
• Consent — We rely on consent for certain processing activities, including interview recording, transcription, and AI-assisted interview analysis. You may withdraw consent for these activities at any time by contacting hello@lemonly.ai.
• Legitimate interests — We process data where necessary to operate and secure the platform, prevent misuse, improve service quality, and support internal analytics, provided these interests are not overridden by your rights and freedoms.
• Legal obligations — We may process personal data to comply with applicable legal, regulatory, or accounting obligations.

Withdrawal of consent does not affect processing already carried out under a valid lawful basis.

5. AI Processing and Interview Copilot

When enabled, the Interview Copilot may automatically record and transcribe interviews conducted via integrated calendar or meeting platforms (e.g. through Nylas).

• Participants are informed in advance and again when recording begins.
• Transcripts are analyzed using AI to generate summaries and assessments aligned with role criteria.
• AI outputs are informational and support human decision-making only.
• Hiring decisions are made solely by hiring managers or their organizations.

We may use anonymized and aggregated data to improve model performance and service quality.

6. Sub-Processors and International Data Transfers

lemonly uses trusted sub-processors, including:

• Nylas, Inc. (calendar, scheduling, meeting, and transcription infrastructure)
• OpenAI LLC (AI text analysis)
• Mistral AI SAS (language-model processing)

These providers may process data in the United States or other jurisdictions.

Where required, lemonly relies on the European Commission's Standard Contractual Clauses (SCCs) and equivalent safeguards to ensure lawful cross-border data transfers under GDPR Chapter V.

7. How We Share Your Information

We do not sell personal data.

We may share information only:

• With the hiring manager or organization responsible for the role;
• With approved sub-processors bound by confidentiality and data-protection obligations;
• Where required by law or to protect the rights, safety, or integrity of lemonly and its users.

8. Data Retention

We retain personal data until a deletion request is received or the data is no longer required for legitimate business or legal purposes.

Data may be retained to:

• Support ongoing or future applications within lemonly
• Maintain audit and compliance records
• Improve platform functionality (in anonymized or aggregated form)

This includes any data obtained through third-party advertising-platform APIs, which is deleted upon request or when no longer required to manage our advertising.

You may request deletion at any time by contacting hello@lemonly.ai.

9. Consent Logging and Audit Trail

To comply with GDPR Articles 5(2) and 7(1), lemonly maintains records showing:

• When and how consent was obtained
• What notice or policy version was presented
• The source of consent (e.g. form submission, email, interview notice)

These records are retained alongside related processing data for accountability purposes.

10. Your Rights

Depending on your location, you may have the right to:

• Access, correct, or delete your personal data
• Withdraw consent
• Request a copy of your data (data portability)
• Object to processing based on legitimate interest
• Lodge a complaint with a data-protection authority

Requests can be made to hello@lemonly.ai. We aim to respond within one month.

11. Security

We use industry-standard technical and organizational measures, including encryption, access controls, and secure infrastructure, to protect personal data, transcripts, and AI outputs.

12. International Users

If you are located in the EEA, UK, or Switzerland, your data may be processed outside your country of residence. We ensure appropriate safeguards are in place in accordance with applicable law.

13. Children's Privacy

lemonly is not intended for individuals under 18. We do not knowingly collect personal data from minors.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be announced via email or posted at https://www.lemonly.ai/privacy-policy.

Continued use of lemonly after updates constitutes acceptance of the revised policy.

15. Contact Us

Lemonly Technologies Inc., trading as lemonly
3106-128 W Cordova Street
Vancouver, BC V6B 0E6
Canada
Email: hello@lemonly.ai