Privacy Policy

Version 2026-10

This policy shares its version with our Data processing agreement and our Sub-processors list. See section 2.

Your privacy matters to us. Here’s how we handle your information:

What we collect

Account details (name, email)
CV content you create or upload
Video introductions (if you record one)
AI inputs and generated content
Usage and technical data, including recordings of how you use our app
Payment info (processed securely by providers like Stripe)
CV information provided by a career professional acting on your behalf, where you have consented to that
Identity verification data, only if you choose to verify: an ID document photo and a short face video, used for the check and then discarded (see section 17)
If you apply for a job through Orbit: your application, and what the employer records about it (see section 18)
If an employer imports your CV into Orbit, or you apply with a PDF: a draft Virtual CV made from it (see section 16)

Why we collect it

To run the platform and your account
To create and display your Virtual CV
To provide AI-assisted features
To match Virtual CVs with jobs, and public Virtual CVs with employers’ roles in Orbit (section 20)
To send you marketing emails about Wipperoz, only if you agree to them
To improve security, performance, and support

AI & your data

We do NOT use your data to train AI models
AI providers only process data to run our features, and do not train on it
You stay in control of what’s published

If you make your Virtual CV public:
- Anyone with the link can view it, and, unless you protect the link, search engines can list it
- Employers using Orbit can be shown it as a match for their roles, without your email address or phone number
- Others may copy or share it
You can add a password, a view limit or an expiry date, change visibility, or unpublish at any time

If someone created a CV for you

A career coach or CV writer can prepare a draft Virtual CV for you, but only with your consent
An employer using Orbit can import your CV, and we make a draft Virtual CV from a PDF you send with an application
It stays private — it is never public before you claim it
We email you a link to claim it
If you do nothing, it is deleted automatically after 90 days
You can ask for it to be deleted sooner (section 16)

The service providers listed on our Sub-processors page (hosting, AI, analytics, payments, email)
Employers you apply to or give access to your Virtual CV
Employers using Orbit, when your public Virtual CV matches one of their roles
Legal authorities if required by law
We do not sell or share personal information

Where your data is stored

Our systems run on Amazon Web Services in the United States (us-east-1, Northern Virginia)
Some providers operate in other countries; each one, and where it is, is listed on our Sub-processors page

How long we keep it

Only as long as each kind of data needs, with fixed periods for each (section 12)
An account nobody has signed in to for 3 years is deleted, after a warning email 30 days before

Your rights

Download a copy of your data yourself, correct it, and delete it
Withdraw any consent you have given, and turn off marketing emails
Ask for a person to review a decision made automatically (section 20)
Complain to us, and to the regulator where you live
The same rights for everyone, wherever you are, free of charge

Bottom line

Your data is used to run Wipperoz — your Virtual CV, job matching and Orbit — and, if you agree, to tell you about Wipperoz. We never sell it
You control what’s public
We follow Australian privacy law, and give everyone the rights of the GDPR and Brazil’s LGPD

👉 For full details, read the complete Privacy Policy below.

1. Introduction

This Privacy Policy applies to all personal information collected by Wipperoz Pty Ltd (ACN 623 500 603) (“Wipperoz”, “we”, “us”, “our”).

This policy explains how we collect, hold, use, disclose, and protect your personal information when you access or use the Wipperoz Virtual CV platform, the Orbit hiring platform, and related services (the “Services”), available at wipperoz.

For most of the personal information described here, Wipperoz decides why and how it is used, and is responsible for it (the “controller” under the GDPR and Brazil’s LGPD). The exception is information an employer adds about job applicants in Orbit: there, the employer is responsible and Wipperoz acts on its instructions. Section 18 explains this.

Wipperoz allows users to sign in using Google Sign-In (OAuth). Where users choose to sign in with Google, Wipperoz may receive limited Google user data such as your email address, profile name, profile picture, and a Google account identifier, strictly for authentication and account creation purposes. Wipperoz does not access Google Drive files, Gmail content, Google Calendar data, Google Contacts, or any other Google services unless explicitly stated in this Privacy Policy and authorised by the user.

Wipperoz’s use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. We do not use Google user data to develop, improve, or train generalized AI and/or machine learning models.

By using our Services, you agree to this Privacy Policy and the Wipperoz Terms & Conditions.

Wipperoz is committed to complying with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

A copy of the APPs is available at: Office of the Australian Information Commissioner

1.1 One standard for everyone

We apply one set of privacy rights to everyone, wherever they live: those of the Australian Privacy Act, the EU and UK GDPR, and Brazil’s LGPD. We do not ask where you are or offer fewer rights in some countries. Residents of US states with privacy laws, such as California, have the rights in section 21.

2. Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

2.1 Version

Each version of this policy has a version number, shown at the top. When you sign up for Virtual CV or Orbit, you tick a box to agree to the Terms and Conditions and this policy before your account can be created.

This Privacy Policy, our Data processing agreement and our Sub-processors list share one version number:

Any change that alters the meaning of any of the three documents, in any language, publishes a new version of all three at the same time, with the same version number, in all four languages
Corrections that do not change meaning — a typo, formatting, a broken link — do not change the version
A version number is the year and month the version takes effect (for example, 2026-11). A second version in the same month adds a number (for example, 2026-11.2)

2.2 How we tell you

If we make material changes that affect how we use or disclose your personal information, we will notify you via your registered email address or through the platform before the new version takes effect. You should review this policy periodically.

Orbit customers are also told about new sub-processors in advance, as their data processing agreement sets out.

3. What personal information we collect

The types of personal information we may collect include:

3.1 Identity & account information

Full name
Email address
Phone number (optional)
Username and password (stored securely)
Profile settings and preferences
The date you last signed in
When you sign up: your IP address, the country and currency it points to, and your browser’s language
If someone referred you: the account that referred you, and an identifier of your device (a “device fingerprint”), which we use to stop referral rewards being abused

3.2 Career & profile content

Resume / CV information (work history, education, skills)
Portfolio links and descriptions
Cover letter content
Career goals and preferences
Your job preferences, the jobs you save or dismiss, and the jobs you tell us you applied to
Endorsements you ask for: the name and email address of the person you ask, and what they say about you, including their relationship to you
Certifications you add, which we check with the issuer (Credly or Microsoft Learn) using the link to the badge
Any information you choose to include in your Virtual CV

3.3 Uploaded content

PDF resumes or other documents you upload. We read the file to build your Virtual CV, then delete it: straight away when it works, and within 7 days when it does not. We keep the text we read from it, and the IP address it was uploaded from, with your account
A CV you try out on our website before signing up, with the email address you give and your IP address. The file is deleted once it is read, and the draft after 14 days
Images or media you choose to attach

3.4 Video & audio content

Recorded video introductions
Basic metadata (duration, upload time)
How people view your Virtual CV: when, from which country and city, the kind of device and browser, which sections they looked at and for how long, and how much of your video they watched. If a recruiter is signed in when viewing it, their name, email address and company

3.5 AI interaction data

Text you input into AI-assisted features
Prompts, edits, feedback, and preferences
AI-generated outputs such as rewritten content, summaries, or suggestions

Important: We do not use your personal information, uploads, or AI interactions to train artificial intelligence models.

3.6 Payment & billing information

Payment method details (processed securely by third-party providers such as Stripe)
Your billing name and email address, and the reference Stripe gives your account
The country we charge tax for, which Stripe may work out from your IP address
Transaction records and credit usage

3.7 Usage & technical data

IP address
Browser and device type
Operating system
Log files, error reports, and performance metrics
Pages or features used within the Services
Recordings of how you use our app (section 10)

Wipperoz allows users to sign in using Google Sign-In (OAuth).

When you choose to sign in with Google, we may collect and process limited Google user data including:

Your Google account email address
Your Google profile name
Your Google profile picture (if available)
A Google account identifier (OAuth subject ID)

We use this information strictly for the purposes of:

authenticating your identity
creating or logging you into your Wipperoz account
displaying basic profile information within the platform

Signing in with Google does not give us access to Google user data from other Google services such as:

Google Drive files
Gmail content
Google Calendar data
Google Contacts
Google Photos
or any other Google services

The one exception is a calendar you choose to connect to schedule interviews, separately from signing in, which is described in section 3.12.

Wipperoz does not sell Google user data and does not share Google user data with advertisers.

Google user data may be stored and processed only as required to operate the Services and may be handled by trusted infrastructure providers (such as hosting services) strictly for the purpose of operating Wipperoz.

Wipperoz’s use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

We do not use Google user data to develop, improve, or train generalized AI and/or machine learning models.

3.9 Information provided by a career professional on your behalf

Where a career coach, CV writer, or other career professional prepares a Virtual CV on your behalf, we may receive your name, email address, career information, and uploaded documents from that professional rather than directly from you. An employer using Orbit can likewise import your name, email address and CV file. See section 16.

3.10 Identity verification (optional)

If you choose to verify your identity, we collect a photo of a government-issued ID document and a short live video of your face, which includes biometric information. These are used only for the check and are not stored. We keep the result, and a record of each attempt that holds no images, face measurements or scores. See section 17.

3.11 Orbit accounts and job applications

If you use Orbit to hire, we collect your name, work email address, your organisation’s details, your role in the account (Admin, Recruiter or Viewer), what you do in Orbit (roles you post, candidates you review, notes you write, offers you make), and the email addresses of colleagues you invite.

If you apply for a role through Orbit, or an employer invites you to, we collect your application: the CV or Virtual CV you send, your answers, your contact details, and the consent you gave and when. When you apply on an employer’s careers page, we also record your IP address and browser details with that consent. The employer may add its own notes, decisions, offers and hiring stage to your application, and we record how often its team viewed it. We also give the employer an AI assessment of how well you fit the role (section 20). See section 18.

If an employer schedules an interview with you, we keep its times, format and notes, and the names and email addresses of the people taking part, including people from outside the employer.

If an employer asks you to take an AI screening interview, we collect your answers, a transcript of the interview, and how each answer was typed. See section 19.

3.12 Calendars you connect (optional)

An Orbit or Virtual CV user can choose to connect a Google, Microsoft or Apple iCloud calendar to schedule interviews. For Google and Microsoft we store the access keys the provider gives us; for Apple, your Apple ID and an app-specific password you create for us. We store these encrypted, together with the working hours you set. We read only when that calendar is free or busy, and the email address of the connected account. We do not read event titles, attendees, or other calendar content. Microsoft’s permission screen asks you to let us read your calendars, because Microsoft has no narrower permission for free/busy times; we still read only free/busy times. You can disconnect the calendar at any time.

3.13 Community Board location (optional)

If you post on the Community Board, we store the suburb and the exact coordinates of your post. They come from an address you search for, or, if you allow it, from your browser’s location. Your browser keeps that location for 24 hours. Other people see the suburb and how far away the post is, never the exact coordinates.

3.14 Wallet passes and mobile notifications (optional)

If you add your Virtual CV to Apple Wallet, we store an identifier of your device and a push token from Apple, so that we can update the pass. If you allow notifications in our mobile app, we store a push token and basic details of your device.

4. Why we collect personal information

We collect and use personal information to:

Create and manage user accounts
Provide and operate the Services
Create, edit, publish, and host Virtual CVs
Enable video introductions and profile sharing
Provide AI-assisted features (such as CV generation, rewriting, and feedback)
Process uploaded documents (e.g. PDF to Virtual CV conversion)
Process payments, credits, and billing
Match your Virtual CV with jobs, and keep track of the jobs you apply to
Match public Virtual CVs with employers’ roles in Orbit, score applicants’ fit for a role, and assess it with AI when the employer asks or has turned on role automations (section 20)
Check endorsements and certifications you add
Communicate with you about your account and the Services, and, if you agree, send you marketing emails about Wipperoz (section 4.2)
Provide customer support
Improve platform performance, usability, and security
Detect and prevent fraud, misuse, or security incidents, including abuse of free credits and referral rewards
Comply with legal and regulatory obligations
Verify your identity and show an “Identity verified” badge, where you choose to (see section 17)
Let employers using Orbit receive and manage job applications (see section 18)

4.1 Legal bases

Where the GDPR or the LGPD applies, we rely on:

Contract — to provide the Services you signed up for
Consent — for marketing emails (section 4.2), identity verification, AI screening interviews, your browser’s location on the Community Board, analytics on our marketing website, and anything else where we ask you first. You can withdraw consent at any time (section 13.4)
Legitimate interests — to keep the Services secure, prevent fraud, understand how the Services are used, and show public Virtual CVs to employers as matches for their roles, where those interests are not outweighed by yours. You can object at any time (section 13.5)
Legal obligation — to keep financial records and respond to lawful requests

4.2 Marketing emails

We send marketing emails — product news and tips about Wipperoz — only to people who agree to receive them. The sign-up forms for Virtual CV and Orbit have a box, not ticked, that says “Send me product news and tips by email”. Only if you tick it do we send you marketing emails and add you to the marketing list in our email provider, Brevo. If you sign up with Google, marketing emails start turned off.

You can turn them on or off at any time with Marketing emails in Settings → You → Your notifications, or with the unsubscribe link in any marketing email. Signing up again never undoes an unsubscribe.

Accounts created before 5 October 2026 were subscribed by default, and keep that setting until it is changed.

5. AI features and data use

Wipperoz offers AI-assisted features to help Users improve and present their career information.

You acknowledge that:

AI-generated outputs are assistance only, not professional or legal advice
AI outputs may be incomplete, generic, or inaccurate
You are responsible for reviewing and deciding what content to use or publish

AI training

We do not use your personal information, uploads, or AI interactions to train AI models.
AI service providers process your data only to generate outputs and to operate the Services. They are listed, with their location, on our Sub-processors list.
Our AI provider, OpenAI, keeps what we send it and what it returns for up to 30 days, to detect abuse and to complete answers that take more than one step, and then deletes it. Files we send it to match Virtual CVs with jobs in bulk stay with OpenAI until they are deleted.

You may choose to:

Keep your Virtual CV private
Publish it publicly, with a link you can protect with a password, a view limit or an expiry date

If you publish or share your Virtual CV:

The information you include (including video introductions) may be accessible by third parties
Third parties may copy, share, screenshot, or store your content
Search engines can list it, unless the link has a password, a view limit or an expiry date
Employers using Orbit can be shown it as a match for their roles (section 20)
You can change visibility settings or unpublish your Virtual CV at any time, subject to technical limitations and third-party caching beyond our control

7. How we collect personal information

We collect personal information:

Directly from you when you sign up, edit your profile, upload content, or use features
Automatically through your device or browser when you use the Services
Through cookies, analytics tools, and similar technologies
From payment providers in relation to transactions
From ipapi.co, which tells us the country and currency of your IP address when you sign up
From people you ask to endorse you, and from the issuers of certifications you add
From a career professional acting on your behalf with your consent, as described in section 16
From an employer using Orbit, when it invites you to apply, imports your CV or records information about your application, as described in sections 16 and 18

8. Disclosure of personal information

We may disclose personal information to:

8.1 Sub-processors

Third-party providers who process personal information for us, to help us operate the Services. Each one, what it does and where it processes data, is listed on our Sub-processors list, which is versioned with this policy. In summary:

Amazon Web Services (AWS) — United States (us-east-1). Cloud hosting, databases, backups, file storage, sign-in, and transactional email delivery; also the face and document checks used for identity verification (see section 17). Public images are resized at AWS edge locations around the world (section 9)
OpenAI — United States. The AI model provider behind CV writing, rewriting and checks, reading uploaded CVs, cover letters, chat and interview practice, job matching, Orbit matching and fit assessments, reading imported CVs, AI screening interviews, and the CV you try out on our website
Stripe — United States. Payment processing
PostHog — United States. Product analytics and session recordings
Sentry — United States. Error monitoring, including recordings of a sample of app sessions
Vercel — United States, with edge locations around the world. Hosting of our websites and web apps, including caching public Virtual CV pages and receiving CVs you try out on our website
Google — United States. Website analytics (Google Analytics) and advertising conversion measurement on our marketing website only
Carbone — European Union (France). Turning a CV into a Word or PDF document when you download one
Brevo — European Union (France, Germany and Belgium). Welcome emails, and marketing emails to people who have agreed to receive them
Xero — United States. Accounting records for invoices
Slack — United States. Internal alerts to our team. Alerts about possible sign-up fraud include an email address and an IP address
ipapi.co — United States. Looking up the country and currency of your IP address when you sign up
OpenCage — European Union (Germany). Finding addresses you type, such as a location for a Community Board post or a job
Intercom — United States. In-app support chat (being removed)

These providers are authorised to use personal information only as necessary to provide services to us, and are not permitted to use it for their own purposes.

Where a Virtual CV is created on your behalf by a career professional (see section 16), we limit what is shared with analytics providers: the analytics events our servers record contain the email domain only, and do not include the name or email address of the person the Virtual CV is about. Session recordings in our app can still show what is on screen (section 10).

8.2 Services you choose to connect

Some services are used only if you choose to: Google Sign-In (section 3.8), a Google, Microsoft or Apple iCloud calendar (section 3.12), and adding your Virtual CV to Apple Wallet or Google Wallet, which sends the pass details to Apple or Google. When you add a certification, we ask its issuer (Credly or Microsoft Learn) to confirm it, sending only the identifier in the badge link. Those companies handle that data under their own privacy policies.

8.3 Payment providers

Payments are processed by third-party providers. Wipperoz does not store full payment card details.

8.4 Employers

When you apply for a role through Orbit, accept an invitation, or give an employer access to your Virtual CV, that employer receives what you send and can see your Virtual CV for as long as its access lasts (section 12.3). See section 18.

If your Virtual CV is public, employers using Orbit can also see it when it matches one of their roles, without your email address or phone number. See section 20.

8.5 Legal and regulatory authorities

Where required by law, court order, or regulator, or where reasonably necessary to protect rights, safety, or prevent unlawful activity.

Where you explicitly authorise us to do so.

9. Where your data is stored, and overseas disclosure

Wipperoz is based in Australia. Our systems, and the personal information they hold, are hosted by Amazon Web Services in the United States, in the us-east-1 region (Northern Virginia). Public images and media on Virtual CVs are delivered through AWS’s global content delivery network, which keeps temporary copies close to the people viewing them. Images are resized at the AWS edge location nearest the viewer, and the logs of that work are kept for 30 days in that AWS region. Vercel, which hosts our websites, also keeps short-lived copies of public Virtual CV pages at its edge locations around the world.

This means we disclose personal information outside Australia. The countries are:

United States — AWS, OpenAI, Stripe, PostHog, Sentry, Vercel, Google, Xero, Slack, ipapi.co and Intercom
European Union — Carbone (France), Brevo (France, Germany and Belgium) and OpenCage (Germany)
AWS and Vercel edge locations worldwide — short-lived copies of public images and pages, and image-resizing logs

Before we disclose personal information to an overseas recipient, we take reasonable steps to ensure it handles that information in accordance with the Australian Privacy Principles (APP 8), including through written contracts that limit what the recipient may do with it and require it to keep it secure. The current list of recipients, and where each one is, is on our Sub-processors list.

Where the GDPR or the LGPD applies, transfers out of the European Economic Area, the United Kingdom or Brazil rely on the European Commission’s Standard Contractual Clauses (with the UK Addendum) or the equivalent mechanism under the LGPD, or on an adequacy decision where one exists.

10. Cookies and analytics

We use cookies and similar technologies, such as your browser’s local storage, to:

Keep you signed in, and remember your preferences
Operate and improve the Services
Understand user behaviour
Measure performance and usage
Measure whether our advertising leads people to sign up, on our marketing website

10.1 In the Virtual CV app

The Virtual CV app does not ask for your choice before these tools run:

PostHog — product analytics, and recordings of your sessions in the app, which are kept for 30 days. Recordings hide what you type into standard form fields, but capture other text on the screen, including your CV. PostHog receives your account identifier and email address, and keeps your IP address. We remove secret codes, such as sign-in and password-reset codes, from the page addresses it records
Sentry — error reports, and recordings of about 1 in 10 sessions and of the moments before an error. These recordings hide all text and media. Sentry receives your account identifier and email address
Intercom — in-app support chat, once you are signed in on a larger screen. Intercom receives your name, email address and account identifier (being removed)
Vercel — page speed measurements

Orbit does not use analytics or session recordings.

10.2 On our website

When you first visit our marketing website, we ask whether you accept analytics, with Accept and No thanks. Until you choose, and if you choose No thanks, PostHog, Google Analytics and Google Ads do not load. Vercel page speed measurements run either way. Your choice is kept in your browser; to change it, clear our website’s data in your browser settings.

PostHog — website analytics
Google Analytics — website analytics
Google Ads — to count sign-ups that came from our ads. We have turned off personalised advertising and Google signals, and use Google’s restricted data processing, so Google does not use this to build advertising profiles or show you personalised ads

10.3 What is kept in your browser

Signing in — the sign-in tokens from our sign-in service (Amazon Cognito), in your browser’s local storage
Preferences — your language, your theme, and your choice about analytics on our website
PostHog — a cookie and a local storage entry whose names start with “ph”, shared across wipperoz.com sites
Google — the _ga and _gcl_au cookies, on our website, after you accept
Intercom — cookies whose names start with “intercom”, in the Virtual CV app
Stripe — cookies set by Stripe’s payment form when you pay, to prevent fraud
Trying out a CV on our website — the wz_sandbox_resume cookie, for 24 hours, so you can come back to it
Community Board — your location, for 24 hours, if you allow it

You can also block or delete cookies through your browser. Parts of the Services may stop working if you do.

11. Security of personal information

We take reasonable technical and organisational measures to protect personal information from misuse, loss, unauthorised access, modification, or disclosure.

However, no system is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your login credentials.

If a data breach is likely to result in serious harm to you, we will tell you and the regulator as the law requires.

12. Data retention

12.1 General

We retain personal information only for as long as necessary to:

Provide the Services
Meet legal and regulatory requirements
Resolve disputes and enforce agreements

When information is no longer required, we take reasonable steps to delete or de-identify it, unless retention is required by law. The periods below are how long we keep each kind of information.

Deleted information stays in our database backups for up to 35 days, and in our system logs for up to 30 days, before it is overwritten.

12.2 Retention schedule — Virtual CV

Original CV file you upload — deleted once we have read it, or within 7 days if reading it fails. The text we read from it, and the IP address it was uploaded from, are kept with your account
Draft and try-it-out CVs that were never saved — until they expire, then deleted automatically. A CV you try out on our website expires after 14 days
Views of your Virtual CV — for the life of your account
Community Board posts — 14 days, or 1 day after you close the post
Endorsement requests nobody answers — 30 days
AI screening interview transcript — 90 days
AI screening interview findings — until the employer closes its Orbit account. Removing your screening data, or deleting your account, removes your answers and quotes from them (section 19)
ID document photos and face videos — never stored (section 17)
Identity verification result — until you remove it or delete your account. The badge stops showing when your ID document expires, or 3 years after you verified, whichever comes first
Identity verification attempt records — 400 days after each attempt, to apply the attempt limit and for audit. They hold no images, face measurements or scores. If you remove your verification, they are reduced to the date, the credits charged or refunded and the fact that they were erased
Data export download — 7 days after it is ready
Record that your account was deleted, and of data exports you asked for — kept indefinitely. It contains your email address, so that we can show what we did if we are asked
A one-way hash of the email address of a closed account — kept indefinitely, so that closing an account and signing up again cannot be used to claim free credits again. The hash cannot be turned back into the email address
Credit and usage records — kept after your account is deleted, as financial records. They can include the email address of the person who used or granted credits
Referral records — if you were referred, the record of the referral (the referring account, a masked copy and a hash of your email address, your IP address, device fingerprint and country) is kept after your account is deleted, to prevent referral fraud
Your contact in our email provider (Brevo), and your analytics history (PostHog) — not deleted automatically when you close your account. Email privacy@wipperoz.com and we will delete them
Invoices and payment records — as long as Australian record-keeping law requires. These are held by Stripe and Xero and are not removed when you delete your account
Inactive accounts — see section 12.4

12.3 Retention schedule — Orbit

Applicants to a role that has closed — 12 months after the role closes, then de-identified so that nothing in them identifies the applicant. An admin of the employer’s account can change this to anything between 6 and 24 months (section 18.4)
An employer’s access to your Virtual CV — while the role is open and for 90 days after it closes, unless you end it sooner
Matches of public Virtual CVs with a role — 90 days
Invitations to apply that are never answered — 90 days
Links a recruitment agency sends its clients to review candidates — until the link expires, at most 90 days, and never longer than the agency’s access to the Virtual CV
AI screening interviews an employer asks for — transcript 90 days; findings until the employer closes its account (section 19)
Interview records — until the employer closes its account. The candidate’s own copy is kept until they delete their account
Candidates an employer keeps in its My candidates list — until the candidate ends the employer’s access, the employer removes them, or the employer closes its account
CVs an employer imports — the import record 90 days; the draft Virtual CV as in section 12.5
A closed Orbit account — deleted straight away, with its hiring records. A record of the deletion, with the team’s email addresses, is kept for 90 days
Inactive Orbit accounts — the same rule as section 12.4. The account’s admins are warned, and an account with open roles is never deleted for inactivity

12.4 Inactive accounts

If nobody signs in to an account for 3 years, counted from the last time anyone signed in to it, we delete it. We email the account’s admins 30 days before, and signing in during those 30 days keeps the account. The deletion is the same as when you close your account yourself.

We do not delete an account for inactivity while it has a paid balance or an active subscription (including a trial, or a subscription with a payment overdue), or, for Orbit, while it has open roles.

12.5 Virtual CVs created on your behalf (unclaimed)

Where a career professional creates a Virtual CV on your behalf, an employer imports your CV into Orbit, or you apply for a role in Orbit with a PDF, we hold a draft Virtual CV for you for a maximum of 90 days from the date it is created, until you claim it.

7 days before a draft a career professional created is due to be deleted, we remind that professional, not you
The link to claim it works for 30 days, and a new one can be sent
If it is not claimed within 90 days, it is permanently deleted, including the CV content and any uploaded documents
You can have it deleted sooner at any time: for a CV an employer imported, with the decline link in the email we send you; otherwise by asking the professional who created it, or by contacting us

After the deletion, we keep:

The professional’s record of the Virtual CV they created, with your name and email address, for 90 days
If you declined, your email address on a list that stops a draft being created for you again. We keep it until you ask us to remove it, at privacy@wipperoz.com

Once you claim a Virtual CV and create an account, the information becomes part of your account and is retained under section 12.1.

12.6 Identity verification

The ID photo and face video are discarded as soon as the check is complete. The verification result is kept until you remove it or delete your account; the badge stops showing when your ID document expires, or 3 years after you verified, whichever comes first. Attempt records hold no images, face measurements or scores, and are deleted 400 days after each attempt; if you remove your verification, they are reduced until then to the date, the credits charged or refunded and the fact that they were erased. See section 17.

13. Your rights, and how to use them

You have the rights below wherever you live. Using them is free. We respond within 30 days, and may ask you to confirm your identity first. For anything you cannot do yourself in the Services, email privacy@wipperoz.com and we will do it for you.

13.1 Get a copy of your data

You can request a copy of your data yourself. In Virtual CV, go to Settings → You → Privacy → Download my data, choose “Request my data”, then “Download” when it is ready. In Orbit, to get your own data, choose “Request my data” in Settings → You → Privacy → Download my data. We prepare a file of everything you have given us and every access you have granted to employers, and email you when it is ready. You can download it from that screen for 7 days, from any device where you are signed in, and you can make one request every 24 hours. You can also email privacy@wipperoz.com instead.

An admin of an Orbit account can export the company’s data in Settings → Account → Data & privacy → Export the company’s data, by choosing “Request the company’s data”. The same rules apply.

13.2 Correct your data

You can edit your profile, your Virtual CVs and your account details directly in the Services. For anything you cannot edit yourself, contact us.

13.3 Delete your data

You can close your account in Settings → Account → Overview. This deletes your account and the personal information it holds across all our systems, for every user on the account. Only an admin can close an Orbit account. We keep only what section 12.2 lists: the record of the deletion, the hash of your email address, credit and usage records, referral records, and invoices and payment records; your Brevo contact and PostHog history are deleted when you ask. You can also remove individual items: a Virtual CV, your identity verification, or your screening interview data.

Where we rely on your consent, you can withdraw it at any time, and it is as easy as giving it:

Marketing emails — the unsubscribe link in our marketing emails, or Marketing emails in Settings → You → Your notifications (section 4.2). Unsubscribe links in our other emails work for 30 days after the email is sent
Identity verification — remove your verification (section 17.7)
AI screening interviews — remove your screening data from the screening page
Employer access to your Virtual CV — end it from the Virtual CV’s Public settings
Your browser’s location — turn it off for our site in your browser settings
Analytics on our website — clear our website’s data in your browser, and choose No thanks

Withdrawing consent does not affect what we did before you withdrew it.

13.5 Object, restrict, and move your data

You can ask us to stop or limit a use of your data, or to send your data to you in a format another service can read. The copy you can download yourself (section 13.1) is in that format.

13.6 Decisions made automatically

To ask for a person to review a decision made automatically, see section 20.3.

13.7 Applications to an employer

For information an employer recorded about your application in Orbit, see section 18.3.

14. Complaints

If you believe we have mishandled your personal information, contact us at: privacy@wipperoz.com

We will investigate and respond within 30 days.

If you are not satisfied, you may complain to the privacy regulator where you live:

Australia — the Office of the Australian Information Commissioner (OAIC), at oaic.gov.au
European Union — the data protection supervisory authority in the country where you live or work
United Kingdom — the Information Commissioner’s Office (ICO)
Brazil — the Autoridade Nacional de Proteção de Dados (ANPD)

15. Contact us

For questions about this Privacy Policy: privacy@wipperoz.com

16. Personal information collected from a third party (Virtual CVs created on your behalf)

In some cases we receive personal information about you from someone other than you — specifically from a career coach, CV writer, or other career professional (a “Partner”) who uses Wipperoz to prepare a Virtual CV on your behalf. This section explains what happens in that case, and is provided to meet our obligations under Australian Privacy Principle 5.

16.1 What we receive, and from whom

A Partner may provide us with your name, email address, and career information (work history, education, skills, and similar), together with any documents they upload. We then generate draft Virtual CV content from that information using the AI features described in section 5.

16.2 The basis on which we hold it

A Partner may only do this where they have a genuine professional engagement with you and have obtained your informed consent. Partners give us a contractual warranty to that effect under our Partner Terms, and confirm it each time they create a Virtual CV. We record that they confirmed it, and the date and time.

If you believe a Virtual CV has been created for you without your consent, contact us at privacy@wipperoz.com and we will delete it.

16.3 What we do with it before you claim it

Before you claim the Virtual CV:

It is never public. It is not published, not shared by link, and not indexed by search engines.
It is visible only to the Partner who created it, and to authorised Wipperoz personnel where necessary for support, security, or investigating misuse.
It is not used to train AI models (see section 5).
We do not use your details for marketing. The only message we send you is the invitation to claim the Virtual CV, when the Partner chooses to send it, and again if they resend it.

16.4 How long we keep it

A maximum of 90 days. We remind the Partner 7 days before it is deleted. See section 12.5.

16.5 Your choices

You may:

Claim the Virtual CV, by creating a Wipperoz account
Have it deleted, by asking the Partner, who can delete it at any time
Contact us at privacy@wipperoz.com to ask what we hold, to correct it, or to have it removed

Your rights under section 13, and to complain under section 14, apply to this information in the same way as to any other personal information we hold.

16.6 If you claim it

When you claim a Virtual CV you create your own Wipperoz account and accept the Wipperoz Terms and Conditions directly. From that point the information is held under your account, you control it, and the Partner’s access to it ends unless you choose to grant it again.

16.7 If you take no action

The draft is deleted as described in section 12.5, and the Partner’s access to it ends at the same time.

16.8 CVs an employer imports, and applications with a PDF

An employer using Orbit can import CVs of people it is considering, including people who have not applied: their name, email address and CV file. The employer confirms that it has a lawful reason to do so, and we record what it confirmed, the version of that wording, who confirmed it and when. Then:

If you do not have a Wipperoz account, we make a private draft Virtual CV from the file and delete the file. We email you a link to claim it or decline it, unless the employer turns that email off. We send at most one such email in 30 days, whichever employer imports you
If you already have a Wipperoz account, we do not make a draft. We delete the file and email you that the employer added you
The employer keeps you in its My candidates list until you end its access or it removes you

When you apply for a role in Orbit with a PDF, we also make a private draft Virtual CV from it, and email you a link to claim it.

These drafts follow section 12.5: they are never public, and are deleted after 90 days if you do not claim them.

17. Identity verification and biometric data

Identity verification is optional. You can use Wipperoz without it. If you verify, your Virtual CV can show an “Identity verified” badge.

17.1 What we collect

When you start a verification, we ask for:

A photo of a government-issued ID document (such as a passport, national ID card or driver’s licence)
A short live video of your face, used to confirm that a real person is present (a “liveness” check). A still image of your face is taken from this video

From the ID photo we read your name, date of birth, the document’s expiry date, the document type and the issuing country. We compare your face in the video with the photo on the ID, and the name on the ID with the name on your account.

17.2 Why we collect it

Only to confirm that you are the person named on your account, so that your Virtual CV can show the “Identity verified” badge. We do not use it for anything else.

Your face video, the image taken from it and the comparison of your face with your ID photo are biometric information. Together with your ID document, this is sensitive information under the Privacy Act 1988 (Cth), special-category data under the GDPR, sensitive personal data under Brazil’s LGPD, and biometric information under US state laws such as the Illinois Biometric Information Privacy Act.

We only collect it with your explicit consent, which we ask for before any capture begins. A verification cannot start until you have given it. We record when you gave it and which version of the consent wording you saw, in the attempt record (section 17.6). You can withdraw your consent at any time by removing your verification (section 17.7).

17.4 Who processes it

Amazon Web Services (AWS) performs the face and document checks for us, as our service provider, in the United States (us-east-1). AWS processes this data only to perform the check. It does not keep the images or use them to improve its services.

17.5 What we keep

The ID photo, the face video, the image taken from it and any face measurements are used only during the check and then discarded. Neither Wipperoz nor AWS stores them. We also do not store the name, date of birth or document number read from your ID.

We keep the result, and the attempt records described in section 17.6:

Whether the verification succeeded, did not succeed, or you were asked to try again, and the reason
The document type and issuing country
The date the verification was completed and the date it expires

A verification expires when your ID document expires, or 3 years after it was completed, whichever comes first. The badge then stops showing. The result stays in your account, marked as expired, until you remove it or delete your account.

Only you can see the expiry date, in your account settings. Recruiters and anyone viewing your Virtual CV see only that your identity is verified.

17.6 Attempt records

Each attempt creates a record that keeps: the outcome (verified, not verified, or asked to try again) and the category of reason; the document type and issuing country; which reader checked the document (the ID reader or the machine-readable zone); when you gave your consent and the version of the consent wording; the credits charged and any refund; the dates; and the identifier of the AWS liveness session. It contains no images, no face measurements and no scores: not how confident the liveness check was, how similar your face was to your ID photo, or how closely the names matched. We use these records to apply the attempt limit, to refund credits when a check fails because of a problem on our side, and for audit, including looking into a check if you or we question it. We keep each one for 400 days after the attempt. If you remove your verification, they are reduced to the date, the credits charged or refunded and the fact that they were erased, until their 400 days end.

17.7 Removing your verification

You can remove your verification at any time in Settings → You → Identity. This withdraws your consent, deletes the verification result straight away, reduces your attempt records as section 17.6 describes, and removes the badge from your Virtual CV. You can also ask us to remove it by contacting privacy@wipperoz.com.

Deleting your account deletes your verification result and your attempt records.

17.8 No sale of biometric information

We never sell, rent, trade or otherwise profit from biometric information. We do not disclose verification results to anyone beyond the badge described in section 17.5, except where required by law (section 8.5).

18. Orbit: employers, applicants, and who is responsible

Orbit is the part of Wipperoz that employers and recruiters use to post roles, receive applications, and review candidates.

18.1 Who is responsible for what

What you provide when you apply — your application, CV, answers, and any access you grant to your Virtual CV. Wipperoz is responsible for this information as a controller, and this policy applies to it
What the employer adds — its notes, decisions, offers, hiring stage, and the history of your application in its hiring process, and the AI fit assessments, AI screening interviews and interviews it asks for. The employer’s Orbit account is responsible for this information as the controller. Wipperoz stores and processes it only on the employer’s instructions, as its processor, under our Data processing agreement

18.2 What Wipperoz does as a processor

For the employer, we store its hiring records, show them to its team, score applicants’ fit and assess it with AI when it asks or has turned on role automations, run the role automations it turns on and the AI screening interviews it asks for, apply its retention setting, and help it answer requests from applicants. We do not use the employer’s notes about you for any other purpose, and we do not share them with other employers.

18.3 Requests about what an employer recorded

To see, correct, or delete what an employer recorded about your application, contact that employer: it decides what happens to that information. If you contact us instead, we will pass your request to the employer and help it respond. The copy of your data from section 13.1 contains everything you provided and every access you granted, but not the employer’s own notes.

18.4 How long employers keep applications

When a role closes, its applications are kept for 12 months and then de-identified, so that nothing in them identifies you. An admin of the employer’s account can set this period to anything from 6 to 24 months in Settings → Account → Data & privacy. A shorter period applies only from the date it is changed, never all at once to applications already past it.

This covers your application and the employer’s records about it. It does not cover AI screening findings (section 19), interview records, or the employer’s My candidates list, where it keeps candidates it wants to stay in touch with. Those are kept as section 12.3 sets out, at the longest until the employer closes its account. The rest of the Orbit schedule is in section 12.3.

18.5 When an employer closes its account

Only an admin can close an Orbit account. It is deleted straight away, together with its hiring records, and cannot be reopened. Your own Wipperoz account and Virtual CVs are not affected.

19. AI screening interviews

An employer using Orbit can ask you to take a short interview with an AI interviewer. It is your choice.

Before it starts, we explain what is recorded and ask for your consent, and record that you gave it and when. If you say no, nothing is recorded, and the employer is told that you declined
While you answer, we record how each answer was written: when the question was shown, when you started typing, how many keys you pressed, how many times you pasted and how many characters (never what you pasted), and how long you were away from the page. We never see your clipboard or your screen
The AI writes findings for the employer: a summary of each part, any concerns, with short quotes from your answers, checks of your answers against your CV, and notes on how answers were written, such as an answer that was mostly pasted. These are observations for the employer, not a score or a decision (section 20)
We keep the transcript for 90 days and then delete it
The findings are kept until the employer closes its Orbit account. The employer’s retention period (section 18.4) does not remove them
You can remove your screening data from the screening page once the screening has ended. This deletes your answers, the transcript, the quotes, the checks against your CV and the record of how each answer was typed, takes your name and email address off the screening, and withdraws your consent. The employer keeps the summary of each part and the concerns, without quotes. Deleting your account does the same
The AI model provider that runs the interview is listed on our Sub-processors list, and does not use your answers to train its models

20. Automated decisions and profiling

Some of our features use AI to evaluate people. This section explains where, and what you can do about it.

20.1 Matching public Virtual CVs with employers

If your Virtual CV is public, we use AI to compare it with the roles employers post in Orbit, even if you have not applied. When it matches, the employer can see your name, headline, photo, skills, experience and the other sections you show publicly, a match percentage, and the AI’s reasons for the match. The employer never sees your email address or phone number. It can only reach you through an invitation to apply, which we send you, and which you can turn off from the link in the invitation email. We do not email you about a match in any other way.

To stop this matching, make your Virtual CV private, or ask us at privacy@wipperoz.com.

We also use AI to match your Virtual CV with jobs for you. This only shows you jobs; it does not decide anything about you.

20.2 Decisions in Orbit

When you apply for a role, we score how well your CV fits it, by comparing the skills it lists with the skills the role requires. The employer sees the score, and can also ask our AI to assess your application, with reasons. The employer can also turn on automations for a role. When it does, our AI assesses every new application to that role against the role’s requirements, and the automations act on where the AI’s score falls between two cutoffs the employer chooses, for that role or for all its roles (75 and 50 out of 100 unless it changes them):

Send an AI screening interview to applicants whose AI score reaches the higher cutoff (a strong fit)
Reject applicants whose AI score is below the lower cutoff (a partial fit)
Move applicants whose screening findings raise no concerns to the shortlist

These automations act without a person looking at your application at that moment. When an automation or a person moves your application to a new stage, we tell you by email and in the app, up to 3 times a day and 8 times a week for one employer. When an automation rejects your application, the email and the notification in the app say that the decision was made automatically, by an AI review of your CV against the role’s requirements that scored it below the level the employer set, and that you can write to privacy@wipperoz.com to have a person at the employer review it or to learn more; we pass your request on to the employer. Other changes of stage, such as a person moving your application or an automation moving it to the shortlist, do not say whether a person or an automation made them.

20.3 Asking for a person to review a decision

Under the GDPR (Article 22) and the LGPD (Article 20), you can ask for a person to review a decision that was made only by automated means and affects you significantly, such as an application rejected by an automation. You can also ask how the decision was made, and give your point of view.

Contact the employer, which decides about your application. Or email privacy@wipperoz.com, and we will pass your request to the employer and help it respond (section 18.3).

21. Privacy rights in US states, including California

We do not sell or share personal information. We do not sell it for money or anything else, and we do not share it for cross-context behavioural advertising, as the California Consumer Privacy Act (CCPA) defines those terms.

The categories of personal information we collect, where they come from, why we use them and who we disclose them to are set out in sections 3, 7, 4 and 8. We use sensitive personal information — your ID document and biometric information — only to verify your identity, as described in section 17, and your precise location, if you share it on the Community Board, only to place your post (section 3.13).

You have the right to know what we collect, to access it, to correct it, to delete it, and to not be treated differently for using these rights. To use them, follow section 13 — you can download a copy of your data yourself (section 13.1) — or email privacy@wipperoz.com. An authorised agent can make a request for you; we may ask for proof that you authorised them.