Privacy Policy

Last Updated: Dec 16, 2025

Neuround, Inc. ("Neuround," "we," "us," or "our") operates Lumen, an AI-powered interview platform. This Privacy Policy explains how we collect, use, disclose, and
safeguard your information when you use our platform, website, and services (collectively, the "Services").

By using our Services, you agree to the collection and use of information in accordance with this Privacy Policy.

1. Information We Collect

Information You Provide

Account Information: When you create an account, we collect your name, email address, company name, and password.

Company and Job Information: If you are an employer or recruiter, we collect information about your company, job descriptions, required skills, interview criteria,
and hiring preferences.

Candidate Information: We collect candidate names, email addresses, phone numbers, resumes, and any information provided during the interview process. This data may
be provided directly by candidates or by employers/recruiters using our platform.

Interview Recordings: We record audio from AI-conducted interviews. These recordings are processed to generate transcripts and structured feedback.

Payment Information: If you purchase a subscription, we collect billing information. Payment processing is handled by third-party providers who maintain their own
privacy policies.

Communications: We collect information when you contact us for support or communicate with us through any channel.

Information Collected Automatically

Usage Data: We collect information about how you interact with our Services, including pages visited, features used, and actions taken.

Device Information: We collect device type, operating system, browser type, IP address, and unique device identifiers.

Cookies and Tracking Technologies: We use cookies, pixels, and similar technologies to collect information about your browsing activities. See Section 7 for more
details.

Information from Third Parties

ATS Integrations: If you connect your Applicant Tracking System, we receive candidate and job data as authorized by you.

Single Sign-On: If you authenticate using a third-party service (e.g., Google), we receive basic profile information from that provider.

2. How We Use Your Information

We use the information we collect to:

  • Provide, maintain, and improve our Services

  • Conduct AI-powered interviews and generate structured feedback

  • Process and transcribe interview recordings

  • Facilitate communication between employers and candidates

  • Process transactions and send related information

  • Send administrative messages, updates, and security alerts

  • Respond to your inquiries and provide customer support

  • Analyze usage patterns to improve our platform

  • Detect, prevent, and address fraud, abuse, and security issues

  • Comply with legal obligations

AI Processing

Our AI systems analyze interview recordings to:

  • Transcribe spoken responses

  • Evaluate candidate responses against job criteria

  • Generate structured feedback and summaries

  • Provide insights to help employers make informed hiring decisions

We do not use your interview data to train our AI models without explicit consent.

3. How We Share Your Information

We do not sell your personal information. We share information only in the following circumstances:

With Employers: Candidate interview data, recordings, transcripts, and AI-generated feedback are shared with the employer or recruiter who initiated the interview.

Service Providers: We share information with third-party vendors who perform services on our behalf, including cloud hosting, payment processing, analytics, and
customer support. These providers are contractually obligated to protect your information.

Business Transfers: If we are involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

Legal Requirements: We may disclose information if required by law, subpoena, or other legal process, or if we believe disclosure is necessary to protect our rights,
your safety, or the safety of others.

With Your Consent: We may share information for other purposes with your explicit consent.

4. Data Retention

We retain your information for as long as necessary to provide our Services and fulfill the purposes described in this Privacy Policy. Specifically:

  • Account data is retained while your account is active and for a reasonable period thereafter

  • Interview recordings and transcripts are retained according to your subscription plan settings or as required by applicable law

  • Usage data is retained for analytics purposes and typically anonymized after 24 months

You may request deletion of your data as described in Section 6.

5. Data Security

We implement appropriate technical and organizational measures to protect your information, including:

  • Encryption of data in transit and at rest

  • Regular security assessments and penetration testing

  • Access controls and authentication requirements

  • Employee training on data protection practices

  • Incident response procedures

However, no method of transmission or storage is completely secure. We cannot guarantee absolute security of your information.

6. Your Rights and Choices

Depending on your location, you may have the following rights:

Access: Request a copy of the personal information we hold about you.

Correction: Request correction of inaccurate or incomplete information.

Deletion: Request deletion of your personal information, subject to certain exceptions.

Portability: Request a copy of your data in a portable format.

Objection: Object to certain processing of your information.

Withdrawal of Consent: Withdraw consent where processing is based on consent.

Opt-Out of Marketing: Unsubscribe from marketing communications at any time.

To exercise these rights, contact us at privacy@trylumen.ai. We will respond within the timeframe required by applicable law.

For Candidates

If you participated in an interview through Lumen, please note that the employer who initiated your interview is the data controller for your interview data. To exercise
your rights regarding interview recordings or feedback, please contact the employer directly. For requests related to your Lumen account (if you created one), contact
us.

7. Cookies and Tracking Technologies

We use cookies and similar technologies for:

  • Essential Functions: Authentication, security, and core functionality

  • Analytics: Understanding how users interact with our Services

  • Preferences: Remembering your settings and preferences

You can control cookies through your browser settings. Disabling certain cookies may affect the functionality of our Services.

8. International Data Transfers

We are based in the United States and process information in the US. If you are located outside the US, your information will be transferred to and processed in the US.
We implement appropriate safeguards for international transfers, including Standard Contractual Clauses where required.

9. Children's Privacy

Our Services are not directed to individuals under 16 years of age. We do not knowingly collect personal information from children. If we become aware that we have
collected information from a child, we will take steps to delete it promptly.

10. California Privacy Rights

California residents have additional rights under the California Consumer Privacy Act (CCPA):

  • Right to Know: Request information about the categories and specific pieces of personal information we have collected

  • Right to Delete: Request deletion of personal information

  • Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights

  • Right to Opt-Out: We do not sell personal information

To exercise these rights, contact us at privacy@trylumen.ai.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website and updating the "Last Updated"
date. We encourage you to review this Privacy Policy periodically.

12. Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us:

Neuround, Inc.

Email: privacy@trylumen.ai

You may also contact our Data Protection Officer at dpo@trylumen.ai.

If you are not satisfied with our response, you may have the right to lodge a complaint with your local data protection authority.