1. Who we are, and who is responsible for your data
InstaTalent is operated by BrightSpheres LLC, an Arizona limited liability company, 2840 E Germann Rd #1157, Chandler, AZ 85286, United States ("InstaTalent", "we", "us"). Whether we are the "controller" (the party that decides why and how data is used) or a "processor" (acting on someone else's instructions) depends on the data:
- We are the controller for account data (employers and job seekers), the public job board, job seeker profiles, billing, website security, and visit statistics. We are also the controller for the InstaTalent Talent Network (profiles and interviews of job seekers who join it), and when a candidate opts in to let us show their interview to other employers they apply to.
- The employer is the controller for candidate data used in its own hiring: applications to its jobs, the AI interviews it sends, recordings, transcripts, AI reports, notes and hiring decisions. We process that data as the employer's processor, only to provide the service, under our Data Processing Agreement. If you are a candidate and want to exercise your rights over that data, you can contact the employer directly or contact us and we will pass your request on and help them respond.
2. What we collect
2.1 Accounts and the job board
- Name, email address, password (never stored in readable form), and your Google account identifier if you sign in with Google
- Employer details: company name, profile, logo, team members, job postings
- Job seeker profile: CV/resume, skills, experience, portfolio and social links you add
- Applications, application status, and messages exchanged through the platform
- Consent records: when you accepted our terms or gave interview consent, with timestamp, IP address, browser and document version
2.2 AI interviews
- Recording: your voice, your camera video, and, only if the interview asks for it, the window or tab you choose to share
- Transcript: a word-by-word transcript of the conversation, with timings
- Screen notes: short AI-written descriptions of what was visible on a shared screen, used to understand what you were presenting (never of people or faces)
- Report: AI-generated scores against the employer's rubric, each backed by quotes from what you said, plus a summary, strengths, open questions, short evidence clips and still images, and simple speaking measures (such as pace and pauses) for English assessments
- Employer actions: notes, stage changes, the hiring decision and the reason recorded for it
- Your choices: interview consent, optional consent to share with other employers, and any request for a human-led interview
We do not use facial recognition, facial analysis or emotion recognition. Your camera video is recorded so a person can watch the interview; no AI analyses it.
2.3 Talent Network (job seekers who join it)
- Profile: name, role, headline, skills, years of experience, country, time zone, work preferences, salary expectations, availability, LinkedIn and portfolio links, phone number and CV
- Interview: the same recording, transcript and AI report described in 2.2. The interview is run by InstaTalent itself, and its questions are drawn at random from a question bank for your role
- Review: our team's outcome (approved, not added, or a retake request) and the reason given to you
- Your choices: your directory consent (with its date and wording version), whether your profile is published, and your availability confirmations
We use your phone number, links and CV only to verify your profile and to detect duplicate accounts. Your phone number is not shown to companies unless you accept their introduction.
2.4 Billing (employers)
Plan, usage, invoices and billing contact. Card details are collected and held by our payment provider; we never see the full card number.
2.5 Company waitlist and business contacts
If you join the company waitlist: your name, work email, company, website, the roles you are hiring for and anything you write to us. We also keep business contact details of people at companies we contact about InstaTalent: name, work email, company, job title and public links such as a company website, together with a record of the emails we send and your replies. Our outreach emails contain a small image that tells us whether an email was opened, and every outreach email has a one-click unsubscribe link.
2.6 Technical and visit data
IP address, browser and device type, pages visited, referrer and time on page. For visitors who are not signed in, we keep a random visit identifier in your browser and derive an approximate country and city from your IP address, to count visits and improve the site. We also keep security and audit logs.
3. Why we use it, and our legal basis
Under the GDPR (and similar laws), we must have a legal basis for each use. Where we act as a processor, the employer determines the basis.
- Running your account, the job board, applications and messages: performance of our contract with you (Art. 6(1)(b))
- Conducting, recording, transcribing and scoring AI interviews for an employer: on the employer's instructions. Employers typically rely on steps taken at the candidate's request before entering a contract (Art. 6(1)(b)) or legitimate interests (Art. 6(1)(f)); we also ask every candidate for explicit consent before the interview starts, because some laws require it
- Showing an interview to other employers you apply to: your consent (Art. 6(1)(a)), which you can withdraw at any time
- Running your Talent Network profile, interview and review: performance of our contract with you (Art. 6(1)(b)); showing your anonymised profile to companies: your consent (Art. 6(1)(a)), which you can withdraw at any time by unpublishing your profile or unticking the directory consent
- Your waitlist request: steps taken at your request (Art. 6(1)(b)), to give you access and email you about it; emailing business contacts about InstaTalent: our legitimate interests (Art. 6(1)(f)), where the law allows it. You can object or unsubscribe at any time
- Billing, tax and accounting: contract and legal obligation (Art. 6(1)(b) and (c))
- Security, fraud prevention, audit logs, visit statistics and improving the product: our legitimate interests (Art. 6(1)(f))
- Service and transactional emails: contract; marketing emails: with your consent or, for business contacts, our legitimate interests as described above; you can unsubscribe at any time
- Complying with law and defending legal claims: legal obligation and legitimate interests
We do not ask for special category data (such as health, ethnicity, religion or sexual orientation), and our AI is designed not to infer it. If you mention it in an interview or ask for an accommodation, it is used only to handle your request.
4. AI and automated decisions
AI conducts the interview and drafts an assessment. No hiring decision is made solely by automated means. A person at the employer reviews the report, which quotes your own words and links each score to the moment in the recording, and that person makes every decision. Scores are evidence for a human reviewer, not a decision, so Article 22 GDPR "solely automated decisions" do not apply. You can still ask for a human review of your assessment, contest it, or ask for an interview with a person instead of the AI (see AI Interview Notice).
We do not use your data to train AI models, and our AI providers do not use it to train theirs.
5. Who we share it with
- The employer you apply to or interview with, including its team members who have access to that job
- Other employers you apply to, only if you opted in on the interview consent screen
- Companies using the Talent Network, if you joined it, gave directory consent and published your profile, and our team approved it. They see an anonymised profile: your role, interview results, salary range, availability, country and time zone. Your name, contact details, CV and full recording go only to a company whose introduction you accept
- Our sub-processors, who host, run or support the service under contracts that limit their use of the data. The current list is on our Sub-processors page
- Authorities or courts when the law requires it, and professional advisers bound by confidentiality
- A buyer or successor if our business is merged or sold, under the same protections
We do not sell personal data and we do not share it for advertising.
6. International transfers
InstaTalent is operated from the United States, and our servers and most of our service providers are located there. When data leaves the EU/EEA, the UK or another country that restricts transfers, we rely on the European Commission's Standard Contractual Clauses (with the UK Addendum) or an applicable adequacy framework, together with additional safeguards such as encryption in transit. You can ask us for a copy of the relevant safeguards.
7. How long we keep it
- Full interview recordings (audio, video, screen share): deleted automatically 180 days after the interview by default. An employer can ask us to apply a shorter or longer period.
- Transcripts, reports, evidence clips and decision records: until the employer deletes them or closes its account, or we act on a valid deletion request. Employers should delete them once they no longer need them for the hiring process or legal claims.
- Accounts and profiles: until you delete your account; we then delete or anonymise the data within 30 days.
- Billing records: as long as tax and accounting law requires.
- Backups: overwritten on a rolling 30-day cycle, so deleted data disappears from backups within 30 days.
- Consent records and audit logs: as long as the related record exists, and longer only where needed to prove compliance or defend legal claims.
- Visit statistics: up to 13 months, after which they are deleted or kept only in aggregate form.
- Waitlist and business contacts: until you ask us to delete them, and no longer than 24 months after our last contact with you. If you unsubscribe, we keep your email address on a suppression list so we don't email you again.
- Talent Network profiles: until you delete your profile or account, or ask us to. The full interview recording is deleted 180 days after the interview; the report stays with your profile. A profile whose availability you don't confirm is hidden from companies until you do.
8. Your rights
Depending on where you live, you have the right to:
- Access your data and get a copy of it
- Correct inaccurate data
- Delete your data, including your interview recording, transcript and report
- Restrict or object to processing, including processing based on legitimate interests
- Data portability, for data you gave us under contract or consent
- Withdraw consent at any time (this does not affect processing before the withdrawal)
- Ask for a human to review an AI-assisted assessment, express your point of view and contest it
- Ask for an interview with a person instead of the AI, or for an accommodation
- Complain to your data protection authority
Email privacy@instatalent.dev. We answer within one month (we may need to confirm your identity). For interview data we hold for an employer, we will forward your request to that employer and help them respond; deletion requests for AI interviews are completed within 30 days.
9. Security
We use administrative, technical and organisational measures designed to protect personal data, including encryption in transit, access controls that limit each employer to its own jobs, candidates and interviews, time-limited access to recordings, audit logs of sensitive actions, automatic deletion of recordings after the retention period, regular backups, and written data protection terms with our service providers.
No system is perfectly secure. If a breach affects your data, we will notify the employer (where we act as processor), the authorities and you where the law requires.
10. Cookies and browser storage
We do not use advertising or third-party tracking cookies. We use only:
- Essential cookies and storage to keep you signed in, remember where to return after signing in, and secure your session
- Preferences such as light/dark theme and whether the sidebar is open
- A first-party visit identifier (random, stored in your browser) used only for our own visit statistics
You can clear these in your browser settings at any time; signing in will then require logging in again.
11. Children
InstaTalent is for people of legal working age and at least 16 years old. We do not knowingly collect data from children. If you believe a child has given us data, contact us and we will delete it.
12. Contact
BrightSpheres LLC (doing business as InstaTalent), 2840 E Germann Rd #1157, Chandler, AZ 85286, United States. Privacy questions: privacy@instatalent.dev.
13. Changes
We will update this policy when our practices change and change the date at the top. If a change is significant, we will tell account holders by email or in the product before it takes effect, and we will tell employers in advance of any new sub-processor.