Data processing addendum
This addendum is part of Panelio's terms and applies whenever Panelio processes personal information for you. Where it and the terms differ about personal information, this addendum wins. An employer that needs a signed copy writes to support@panelio.ai.
Roles
You are the controller of the personal information you and your candidates put into Panelio, and the business under California law. Panelio is your processor and service provider: it processes that information only for you, only to provide Panelio, and only as this addendum says. "Personal information" here is any information about an identified or identifiable person that Panelio processes for you.
The processing
| Subject matter | Running technical interviews in Zoom meetings: reading resumes against a job description, the rounds, the transcript, the code timeline and the whiteboard, the evidence pack, the debrief and the record of decisions. |
|---|---|
| Duration | The term of the terms, then until the information is erased under Deletion and return. |
| Nature | Collecting through Zoom and the app, storing, organizing, transcribing the meeting's audio as it arrives, reading with AI models, suggesting grades and questions, sending mail you ask Panelio to send, and erasing. |
| Purpose | To provide Panelio to you as the terms and the documentation describe, to keep it secure, and to bill you through the Zoom Marketplace. Never to train a model, never for advertising, never sold. |
| People it is about | Your candidates and applicants; your members (admins, hiring managers, interviewers and reviewers); others in a round's meeting. |
| Kinds of information | Names, emails and Zoom identifiers; resumes and job descriptions; the transcript of each round, the code timeline, the whiteboard and the coding assistant's record; notes, ratings, suggested and confirmed grades and decisions; who joined a meeting and when; a link to a candidate's own public code and the files read from it, when they agree; a voiceprint, with the candidate's written consent. |
| Sensitive information | A voiceprint is biometric information, processed only with the candidate's written consent and only to confirm that the same person joins every round. Panelio asks for no protected attributes and records no audio or video. |
| How long | A candidate's record for the period you set after your decision, from 30 days to one year, 90 days unless you change it; a voiceprint until your hiring decision for the role, and never more than a year after the candidate's last round of it; each decision for your audit while your workspace exists. |
Your instructions
The terms, this addendum, your settings and what your members do in Panelio are your instructions. Panelio follows them, and tells you if it believes an instruction breaks the law. Panelio processes personal information outside your instructions only where the law requires it, and then tells you first unless the law forbids it.
What Panelio does
- Processes personal information only for you and as this addendum says.
- Lets only the people who need it to run the service reach it, each bound to keep it confidential.
- Never uses it, or lets anyone use it, to train or improve an artificial intelligence or machine learning model.
- Keeps each workspace's information apart from every other's.
- Helps you with the assessments and consultations the law asks of you, with what it knows about the processing.
Subprocessors
You authorize Panelio to use the subprocessors below. Each is bound by a written agreement that protects personal information at least as well as this addendum. Panelio emails your workspace admins 30 days before adding or replacing one; if you object for a reason about data protection before then, Panelio works with you on it, and if it cannot meet the objection you may end the terms and have your information erased. Panelio stays responsible for its subprocessors.
| Subprocessor | What it does | Region | When |
|---|---|---|---|
| Vercel | hosts the app and the API, and Panelio's seat in each live meeting | United States and EU edge | always |
| Supabase | the database, stored resume files and realtime channels | United States (Ohio) | always |
| OpenAI | the model behind grading, the coach, the AI interviewer and the agent, on Panelio's account; no training on the data | United States | always |
| Resend | transactional email: invitations, the candidate's note, reviewer nudges | United States | when a workspace sends email |
| Vultr | the execution box that runs the candidate's code, in a container with no network; nothing is kept there after a run | United States (New Jersey) | when a round runs code |
Zoom, and an applicant tracking system you connect, are your own vendors under your own agreements with them, not Panelio's subprocessors.
Security
Panelio keeps the measures on its security page in place and does not weaken them while it processes your information: TLS on every connection, each workspace's sensitive records encrypted with its own key, access by role, every database query scoped to the workspace, code run with no network, and secrets kept out of the code.
Requests from people
Panelio passes on to you any request it receives from a person about their information in your workspace, and does not answer it itself unless you ask. It helps you answer, and makes a copy, a correction or an erasure of a candidate's information within 30 days of your request.
Incidents
If a security incident reaches personal information Panelio processes for you, Panelio tells your workspace admins within 72 hours of confirming it, with what was reached, what is known of the cause and what was done, and keeps you told as it learns more. It helps you tell the people affected and any authority, as the law requires.
Deletion and return
While the terms run, your admins can open every evidence pack and export each role's decisions. Panelio erases a candidate's record at the end of your retention period, and a candidate within 30 days of your request. One of your admins can delete your whole workspace in Settings, Data: Panelio deletes it 7 days after the request, unless one of your admins cancels before then, and emails your admins when it is asked for and when it is done; deleting a workspace deletes its key, so nothing it held can be read again. The count of interview rounds and resumes it used stays with your Zoom account, by month under the account's id and nothing else, since the plan is the account's. When one of your members removes Panelio from their Zoom account, Panelio tells Zoom to revoke its access and erases that member's name, email and Zoom login at once; what they recorded stays in your records under "A former member". When the terms end, an admin deletes your workspace the same way, or Panelio erases it within 30 days of your request, and otherwise as your retention period runs; the database provider's backups expire on their own schedule. Panelio keeps nothing past that but those counts, unless the law requires it.
Audits
Once a year, or after an incident, Panelio answers your reasonable written questions about how it protects your information, and shares its trust packet: the security page, the technical design document from the Zoom Marketplace review and the current dependency audit. Where the law gives you more, Panelio agrees with you a reasonable audit, with notice, at your cost, that keeps other customers' information safe.
United States privacy laws
Under the California Consumer Privacy Act, as amended, and the other state privacy laws that apply to the processing, Panelio:
- does not sell or share personal information, and does not use it for advertising across sites;
- does not keep, use or disclose it for any purpose but the business purposes in this addendum, or outside the direct business relationship with you;
- does not combine it with personal information from anyone else, except as those laws allow a service provider;
- gives it the protection those laws require, and tells you if it can no longer meet them;
- lets you take reasonable steps to make sure it is used as this addendum says, and to stop and fix any use that is not.
Panelio understands these limits and keeps to them.
Biometric information
- You choose whether to offer the voice check, in Settings, Data. Where you do, Panelio gives the candidate the notice in full and takes their written consent, by a tick and I agree on their screen in Zoom, before it captures anything, and keeps the record of that consent for you.
- Panelio publishes its retention schedule and destruction guidelines on its privacy policy, and keeps to them: a voiceprint is deleted at your hiring decision for the role, and never more than a year after the candidate's last round of it.
- Panelio never sells, leases, trades or otherwise profits from a voiceprint, discloses it only to the subprocessors that host it, and protects it at least as well as other confidential information.
- A voiceprint is never used to grade, to infer emotion or anything else about a person, or for any other purpose, role or employer.
Where the data is
Panelio stores and processes personal information in the United States. Panelio is offered to employers in the United States; an employer whose processing falls under the GDPR, the UK GDPR or another country's data protection law writes to Panelio before it puts anyone's information into Panelio.
What is yours to do
You have a lawful basis for the processing and give the people concerned the notices the law requires, including your own privacy notice to applicants and the notices of an automated employment decision tool where you hire. You put into Panelio only information you may share with it, and no protected attributes. You answer the requests of the people your information is about.
Term
This addendum runs for as long as Panelio processes personal information for you. The terms' limits on liability apply to it, as far as the law allows.