Privacy Notice
Version 4.0
Effective Date: September 10, 2026
aiAvenu, Inc. (“aiAvenu,” “we,” “us,” or “our”) respects your privacy and is committed to protecting personal information.
This Privacy Notice explains how aiAvenu collects, uses, discloses, retains, and protects personal information in connection with our websites, applications, applicant tracking system (“ATS”), onboarding services, AI-assisted recruiting and interviewing tools, including Eva, integrations, and related services (collectively, the “Services”).
This Privacy Notice applies to individuals who visit or use our websites, Customers and their personnel, job applicants and candidates (“Candidates”), and other individuals whose personal information is processed through the Services.
When aiAvenu processes personal information on behalf of a Customer, the Customer may determine the purposes and means of processing and may be the applicable business, controller, employer, or other covered entity, while aiAvenu may act as a service provider, processor, contractor, or other service provider depending on applicable law and the nature of the processing.
Where applicable, the Customer’s agreement with aiAvenu, including any applicable data processing agreement (“DPA”), governs the processing of Customer-controlled data. If there is a conflict between this Privacy Notice and a Customer agreement or DPA, the applicable Customer agreement or DPA will control with respect to Customer-controlled data.
1. Personal Information and Privacy Rights
“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an identified or reasonably identifiable individual, or as otherwise defined by applicable privacy law.
Depending on where you reside and how you interact with the Services, you may have rights concerning your personal information, including rights to access, correct, delete, restrict, object to, or obtain a copy of certain information, as well as rights relating to automated decisionmaking, targeted advertising, or other processing.
The availability and scope of these rights depend on applicable law and the role aiAvenu has with respect to the information.
If you are a Candidate using the Services in connection with an employer or other organization, that organization may be the party responsible for responding to certain privacy requests concerning your Candidate information. You may contact the organization directly or contact aiAvenu as described below.
2. Information We Collect
We may collect the following categories of information.
(a) Information You Provide Directly
Depending on your relationship with aiAvenu and your use of the Services, this may include:
• first and last name;
• email address;
• telephone or mobile number;
• mailing or physical address;
• username and password;
• employment history and work experience;
• education and professional qualifications;
• work availability;
• preferred work locations;
• job application information;
• resume or curriculum vitae;
• information contained in application forms;
• responses to application questions;
• information voluntarily provided through communications with us;
• account, billing, and payment information;
• information provided when requesting support; and
• other information you choose to provide.
(b) Candidate Information
When the Services are used for recruiting or hiring, we may process information submitted by or about Candidates, including:
• application information;
• resume and employment history;
• education and qualifications;
• job-related responses;
• scheduling information;
• interview responses;
• communications between Candidates and Customers;
• employment eligibility information where applicable;
• information contained in forms or onboarding documents; and
• information necessary to facilitate background screening, work authorization, or other Customer-requested employment processes.
(c) Information Collected Through the Services
We may automatically collect information concerning use of the Services, such as:
• IP address;
• browser type;
• operating system;
• device information;
• approximate geographic information derived from IP address;
• referring and exit pages;
• pages or features viewed;
• dates and times of access;
• system logs;
• authentication and security information;
• cookies and similar technologies; and
• other technical information reasonably necessary to operate, secure, and improve the Services.
(d) AI Interview Data
When a Customer uses Eva or another AI-assisted interviewing feature, the Services may process:
• interview questions presented to the Candidate;
• Candidate responses;
• written transcripts;
• audio and/or video recordings where the interview configuration uses audio or video;
• interview timestamps and related technical metadata;
• job-related information contained in Candidate responses; and
• summaries, assessments, scores, rankings, or other decision-support information generated from the transcript.
Eva’s substantive Candidate evaluation is based solely on the content of the written transcript and the job-related criteria configured for the applicable position.
Eva does not score, rank, evaluate, or make Candidate assessments based on:
• facial expressions;
• physical appearance;
• gestures;
• eye contact;
• body language;
• voice characteristics;
• vocal tone;
• accent;
• acoustic characteristics;
• speech characteristics as an independent signal;
• visual characteristics;
• biometric characteristics; or
• other non-transcript audio or visual signals.
Where audio or video is used, such audio or video may be processed to facilitate the interview and generate or maintain a transcript. The audio or video itself is not used as a substantive evaluation signal by Eva.
3. Cookies and Similar Technologies
We may use cookies, pixels, tags, local storage, log files, and similar technologies to operate the Services, remember preferences, authenticate users, maintain security, understand usage, and improve our websites and Services.
Where required by applicable law, we will obtain consent before using non-essential cookies or similar technologies.
You may be able to control cookies through your browser or device settings. Disabling certain cookies may affect the functionality of the Services.
We do not use facial recognition, voice recognition, or similar biometric identification technologies as part of Eva's Candidate evaluation.
4. How We Use Personal Information
We may use personal information for the following purposes:
1. to provide, operate, maintain, and secure the Services;
2. to create and administer accounts;
3. to process job applications and recruiting workflows;
4. to facilitate interviews and onboarding;
5. to provide AI-assisted recruiting and interviewing functionality;
6. to generate transcripts, summaries, assessments, and other requested outputs;
7. to communicate with users and Customers;
8. to provide customer support;
9. to process payments and maintain billing records;
10. to authenticate users and prevent fraud or unauthorized access;
11. to monitor, troubleshoot, and improve the Services;
12. to conduct quality assurance and testing;
13. to comply with applicable law and legal obligations;
14. to enforce agreements and protect our rights and property;
15. to investigate security incidents;
16. to develop aggregated or deidentified analytics and insights; and
17. for other purposes disclosed at or before the time information is collected or otherwise permitted by applicable law.
We do not use Candidate interview data to make employment decisions on behalf of Customers.
Eva provides decision-support information. The Customer or employer remains responsible for reviewing the information and making employment decisions.
5. How We Share Personal Information
We may disclose personal information to the following categories of recipients, depending on the Services being used:
(a) Customers and Employers
Candidate information may be made available to the Customer or employer responsible for the applicable recruiting or employment process.
(b) Service Providers
We may disclose information to vendors and service providers that help us operate the Services, including providers supporting:
• hosting and cloud infrastructure;
• communications;
• email and SMS;
• transcription;
• AI services;
• security;
• analytics;
• payment processing;
• background screening;
• work authorization;
• tax-credit services;
• customer support; and
• other business operations.
Service providers are permitted to process information only as necessary to provide services to aiAvenu or its Customers and as otherwise permitted by applicable agreements and law.
(c) Integrations
If a Customer enables an integration with a third-party service, information may be transmitted to that third party as directed by the Customer.
(d) Business Transactions
We may disclose information in connection with a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar transaction, subject to applicable law.
(e) Legal and Safety Purposes
We may disclose information when reasonably necessary to:
• comply with law;
• respond to lawful requests;
• enforce agreements;
• protect our rights or property;
• investigate fraud or abuse;
• protect users or the public; or
• address security threats.
We do not sell personal information for monetary consideration.
6. Public Information
Some areas of the Services may permit users to voluntarily post information that is visible to other users or the public.
You should not submit personal information to a public area of the Services that you do not want others to see.
Candidate application and interview information is not intended to be publicly accessible.
7. Communications and Marketing
We may use contact information to provide:
• account communications;
• service notices;
• security notifications;
• transactional communications;
• support communications;
• information concerning Services; and
• marketing communications where permitted by law.
You may opt out of marketing communications by following the unsubscribe instructions in the communication or contacting us.
You may continue to receive transactional or service-related communications even after opting out of marketing communications.
8. SMS and Text Messaging
Where SMS functionality is enabled, aiAvenu or a Customer may send text messages relating to recruiting, scheduling, onboarding, account activity, or other authorized communications.
The Customer is responsible for obtaining any consent required by applicable telecommunications, privacy, and employment laws before sending SMS messages to Candidates or employees.
Message frequency and applicable carrier charges may vary.
Recipients may opt out of SMS communications by following the instructions provided in the applicable message, including replying “STOP” where supported.
9. Third-Party Services
The Services may contain links to or integrate with third-party services.
Third-party services operate under their own privacy policies and terms. aiAvenu is not responsible for the privacy practices of third parties except to the extent required by applicable law or contractual obligations.
Where a Customer directs aiAvenu to transmit information to a third-party service, the Customer is responsible for ensuring that the integration and resulting processing are authorized and lawful.
10. Customer-Directed Integrations and Data Roles
The Services may integrate with third-party systems, including payroll, HR, background screening, work authorization, tax-credit, communications, and recruiting platforms.
The applicable privacy role of aiAvenu, the Customer, and a third-party provider depends on the nature of the processing and applicable law.
Where aiAvenu processes personal information on behalf of a Customer, aiAvenu will process that information in accordance with the Customer's instructions, applicable agreement or DPA, and applicable law.
We do not represent that aiAvenu is always a processor, service provider, contractor, controller, or business for every category of information. Our role is determined by the actual processing activity and applicable law.
11. Retention and Deletion
We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Notice, including to:
• provide the Services;
• maintain business and financial records;
• comply with legal obligations;
• resolve disputes;
• enforce agreements;
• maintain security;
• prevent fraud; and
• satisfy applicable employment or record-retention requirements.
Retention periods may vary depending on the type of information, the purpose of processing, Customer instructions, applicable law, and whether information is subject to a legal hold or other legitimate retention requirement.
For Candidate information processed on behalf of a Customer, the Customer generally determines the applicable retention period, subject to applicable law and contractual obligations.
Where applicable employment law requires retention of automated-decision or employment records, those records may be retained for the legally required period.
For example, California employment regulations address retention of employment records relating to automated-decision systems for a minimum of four years in covered circumstances.
Where a deletion request is legally valid and no exception applies, we will delete, deidentify, or otherwise dispose of information as required by applicable law and our contractual obligations.
12. Security
aiAvenu maintains administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, or disclosure.
aiAvenu maintains a SOC 2 Type II program and employs security controls appropriate to the nature of the information and Services.
No security system can guarantee absolute security. Accordingly, we cannot guarantee that information will never be accessed, disclosed, altered, or destroyed through unauthorized means.
13. Children
The Services are intended for adults and employment-related users.
We do not knowingly collect personal information from children under the age required by applicable law except where necessary and legally permitted in connection with a Customer's legitimate employment or workforce process.
If you believe that a child has provided personal information to aiAvenu in violation of applicable law, please contact us.
14. European Economic Area, United Kingdom, and Switzerland
If you are located in the European Economic Area (“EEA”), United Kingdom, or Switzerland, applicable data protection laws may provide you with additional rights.
Depending on the circumstances, aiAvenu may rely on one or more lawful bases for processing, including:
• performance of a contract;
• compliance with legal obligations;
• legitimate interests;
• consent; or
• another lawful basis recognized by applicable law.
Depending on applicable law, you may have the right to:
• access your personal information;
• correct inaccurate information;
• request deletion;
• restrict processing;
• object to processing;
• request data portability;
• withdraw consent where processing is based on consent; and
• lodge a complaint with a supervisory authority.
International Transfers
Personal information may be processed in countries other than the country in which it was collected.
Where required, we use appropriate legal mechanisms for international transfers, which may include adequacy decisions, standard contractual clauses, or other lawful transfer mechanisms.
15. Automated Decisionmaking Under GDPR
Where GDPR or similar laws apply, individuals may have rights concerning decisions based solely on automated processing that produce legal or similarly significant effects.
aiAvenu's Services may generate automated assessments, summaries, scores, rankings, or other decision-support information.
Eva does not make the final employment decision. Eva's substantive Candidate evaluation is based solely on the written transcript of the Candidate's responses and applicable job-related criteria.
The Customer or employer is responsible for reviewing the applicable output and making the final employment decision.
Where applicable law requires human intervention, an opportunity to contest a decision, an alternative process, or other rights, the Customer is responsible for providing those rights, with reasonable technical or contractual assistance from aiAvenu where applicable.
Candidates should generally direct requests concerning an employment decision to the employer or organization responsible for the hiring process.
16. California Privacy Rights
If you are a California resident and the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), applies to aiAvenu’s processing of your personal information, you may have certain rights, subject to applicable exceptions.
These rights may include:
• the right to know or access personal information;
• the right to correct inaccurate personal information;
• the right to request deletion;
• the right to opt out of certain sales or sharing;
• the right to limit certain uses of sensitive personal information;
• the right not to receive discriminatory treatment for exercising applicable privacy rights; and
• other rights provided by California law.
The scope of these rights depends on the nature of the information and aiAvenu's role with respect to that information.
Where aiAvenu processes personal information solely on behalf of a Customer, certain requests may need to be directed to the Customer.
aiAvenu will provide assistance as required by applicable law and our contractual obligations.
17. California Automated Decisionmaking Technology
California law imposes requirements concerning the use of automated decisionmaking technology (“ADMT”) in certain circumstances.
The California Privacy Protection Agency's ADMT regulations became effective January 1, 2026, with certain requirements concerning significant decisions applying to ADMT use no later than January 1, 2027.
The availability and scope of any CCPA rights relating to ADMT depend on factors including:
• whether the CCPA applies;
• whether aiAvenu is acting as a business, service provider, contractor, or other covered entity;
• the nature and purpose of the processing;
• whether the processing involves a covered significant decision;
• whether an applicable exception applies; and
• the law in effect when the processing occurs.
aiAvenu does not represent that every use of AI or automated processing within the Services constitutes ADMT subject to every CCPA requirement.
Where aiAvenu processes Candidate information on behalf of an employer or Customer, the employer or Customer remains responsible for complying with applicable employment and privacy requirements governing its use of automated decisionmaking technology, including applicable notice, human-review, accommodation, nondiscrimination, and recordkeeping obligations.
Nothing in this Privacy Notice limits or waives any right that cannot lawfully be limited or waived.
18. AI-Assisted Interviewing and Eva
18.1 What Eva Does
Eva is aiAvenu's conversational AI interviewing system.
Depending on the Customer's configuration, Eva may conduct interviews through text, audio, or video.
Eva may ask structured, job-related questions and receive Candidate responses.
Where an audio or video interface is used, aiAvenu may process the audio or video to facilitate the interview and generate a written transcript.
Eva’s substantive evaluation is transcript-only.
Eva's substantive evaluation of a Candidate is based solely on the written transcript of the Candidate's responses and the job-related criteria configured for the applicable position.
Eva does not evaluate or score Candidates based on:
• facial expressions;
• physical appearance;
• gestures;
• eye contact;
• body language;
• voice characteristics;
• vocal tone;
• accent;
• acoustic characteristics;
• visual characteristics;
• biometric characteristics;
• speech characteristics as an independent signal; or
• other non-transcript audio or visual signals.
Accordingly, the presence of audio or video in an Eva interview does not mean that Eva evaluates the Candidate using the Candidate's appearance, voice, facial expressions, or other visual or acoustic characteristics.
Audio or video may be processed to facilitate the interview and transcription, but the substantive Candidate evaluation is performed from the transcript content, not from the underlying audio or video signal.
18.2 AI-Generated Outputs
Depending on configuration, Eva may generate:
• interview summaries;
• assessments;
• scores;
• rankings;
• recommendations;
• structured responses;
• reports; or
• other decision-support information.
These outputs are intended to assist authorized personnel.
AI-generated outputs may contain errors, omissions, or inaccuracies and should not be treated as independently determinative of a Candidate's qualifications.
18.3 Human Decisionmaking
aiAvenu does not make final employment decisions for Customers.
Customers and employers remain responsible for:
• establishing lawful job-related criteria;
• reviewing Candidate information;
• evaluating AI-generated outputs;
• making hiring and employment decisions;
• providing required notices;
• providing required human review;
• providing reasonable accommodations;
• complying with applicable nondiscrimination laws; and
• maintaining required employment records.
Where applicable law requires human review or an alternative process, Customers are responsible for implementing that process.
19. Jurisdiction-Specific AI Requirements
AI and automated employment decision laws vary by jurisdiction.
Customers are responsible for determining which requirements apply to their particular hiring process and Candidates.
New York City
New York City's Local Law 144 regulates covered automated employment decision tools. Among other requirements, covered employers and employment agencies must satisfy applicable bias-audit and notice requirements.
Customers using Eva in New York City are responsible for complying with applicable requirements, including required notices, bias-audit obligations, reasonable accommodation procedures, and other applicable requirements.
aiAvenu may provide documentation and reasonable technical assistance as required under the applicable Customer agreement.
Illinois
Illinois law regulates certain employer use of AI analysis in video interviews, including disclosure and consent requirements.
Because Eva's substantive Candidate evaluation is based solely on the written transcript and not on facial, visual, vocal, acoustic, or other non-transcript characteristics, Customers should nevertheless evaluate whether the particular interview configuration and processing triggers any applicable Illinois requirement.
Customers remain responsible for providing any legally required notice or obtaining any legally required consent.
Other Jurisdictions
Other states, cities, and countries may impose additional requirements relating to AI, automated employment decisionmaking, privacy, biometric information, discrimination, accessibility, or candidate notice and consent.
Customers are responsible for complying with requirements applicable to their hiring activities.
20. AI Interview Data
AI interview data may include:
• interview questions;
• Candidate responses;
• written transcripts;
• audio or video recordings where enabled;
• interview timestamps;
• technical metadata;
• job-related information contained in responses; and
• AI-generated summaries, assessments, scores, rankings, or reports.
Where audio or video is collected, it is used to facilitate the interview and/or create or maintain the transcript.
Eva does not use audio, video, facial expression, appearance, voice, acoustic characteristics, vocal tone, accent, body language, gestures, eye contact, or other non-transcript signals as evaluation or scoring inputs.
The substantive evaluation is based solely on the written transcript and applicable job-related criteria.
21. AI Training and Model Development
aiAvenu does not use Customer Content or Candidate interview data to train general-purpose AI models for unrelated customers or third parties.
aiAvenu may process information as necessary to:
• provide the Services;
• operate and secure the Services;
• troubleshoot and maintain the Services;
• perform quality assurance;
• detect and prevent abuse;
• improve the functionality and reliability of the Services;
• comply with law; and
• fulfill contractual obligations.
Where permitted by applicable law and agreements, aiAvenu may use aggregated or deidentified information for analytics, product improvement, benchmarking, or similar purposes.
aiAvenu will not use Candidate interview data for a materially different AI training or model-development purpose except as permitted by applicable law, contractual terms, and any required authorization.
22. AI Transparency and Explainability
aiAvenu seeks to provide Customers with information reasonably necessary to understand the AI-assisted features they use.
Depending on the applicable Service and configuration, this may include information concerning:
• the purpose of the AI feature;
• the types of information processed;
• the role of AI in the workflow;
• the nature of AI-generated outputs;
• applicable human review processes; and
• applicable limitations.
Because Eva's substantive evaluation is transcript-based, descriptions of Eva's evaluation process refer to the content of Candidate responses and applicable job-related criteria rather than analysis of facial, visual, vocal, acoustic, or other non-transcript characteristics.
AI outputs are probabilistic and may not accurately reflect a Candidate's qualifications. Customers should independently review AI-generated information before making employment decisions.
23. Bias, Fairness, and Nondiscrimination
aiAvenu is committed to developing and operating its Services in a manner designed to support lawful, fair, and nondiscriminatory employment practices.
aiAvenu may conduct testing, monitoring, validation, quality assurance, or bias-related assessments of its Services.
Because Eva's substantive Candidate evaluation is based solely on transcript content and job-related criteria, aiAvenu does not intentionally use facial expressions, physical appearance, voice characteristics, acoustic characteristics, vocal tone, accent, body language, gestures, eye contact, or other visual or vocal characteristics as evaluation signals.
Customers remain responsible for:
• selecting lawful job-related criteria;
• ensuring that interview questions are appropriate;
• avoiding discriminatory selection practices;
• avoiding unlawful use of protected characteristics or proxies;
• reviewing AI outputs;
• providing reasonable accommodations; and
• complying with applicable employment discrimination laws.
Automated systems can nevertheless produce disparate outcomes depending on the underlying data, job criteria, configuration, implementation, or other factors. Customers should monitor their employment processes and take corrective action where required.
24. Data Subject Requests
Depending on applicable law, you may have the right to request access to, correction of, deletion of, restriction of, or portability of certain personal information.
You may submit a request by contacting us at:
Email:legal@avenu.ai
If your request concerns Candidate information processed on behalf of an employer or Customer, we may refer your request to the applicable Customer where required or permitted by law.
We may need to verify your identity before processing certain requests.
We will not discriminate against you for exercising a privacy right available to you under applicable law.
25. Consent and Withdrawal
Where processing is based on consent, you may have the right to withdraw consent.
Withdrawal of consent does not affect the lawfulness of processing that occurred before withdrawal.
For Candidate interviews, any consent required by applicable law may be obtained through the applicable Customer's candidate-facing workflow, interview interface, or other notice and consent mechanism.
Participation in an AI-assisted interview does not constitute a waiver of rights that cannot legally be waived.
26. Privacy Requests and Contact
For privacy questions or requests, contact:
aiAvenu, Inc.
Email: legal@avenu.ai
Please include sufficient information to allow us to understand and respond to your request.
If your request concerns information controlled by one of our Customers, we may direct you to that Customer.
27. California Privacy Requests
California residents may submit applicable CCPA requests by contacting:
Where required, aiAvenu will honor applicable California privacy rights and provide appropriate assistance to Customers where aiAvenu processes personal information on their behalf.
Where a Customer is the business responsible for the applicable processing, the Customer may be the appropriate party to respond to the request.
California residents may also use a browser-based opt-out preference signal, such as Global Privacy Control (“GPC”), where required by applicable law and where technically supported by the relevant Service.
The availability of an opt-out right depends on the type of processing and aiAvenu's applicable legal role.
28. Changes to This Privacy Notice
We may update this Privacy Notice from time to time to reflect changes in:
• our Services;
• our data practices;
• applicable law;
• technology; or
• business operations.
When we make material changes, we may provide additional notice where required by law.
The “Effective Date” at the beginning of this Privacy Notice indicates when the current version became effective.
29. Contact Us
If you have questions about this Privacy Notice or our privacy practices, please contact:
aiAvenu, Inc.
Email: legal@avenu.ai
Effective Date: September 10, 2026
Version: 4.0