Privacy & Cookie Policy

Last updated: 4th October 2025

1. Who We Are

Phoenix Fortunes (SMC) Limited — Registration No. 80020003189771.
Plot 831, Block 181, Kira-Kiwologoma, Wakiso, Uganda.
Mail: 800826, Ntinda, Uganda.
Contact & Data Protection Officer: andeh@myjobconcierge.com

2. Scope

This policy covers all personal data collected through the My Job Concierge website, web and desktop apps, mobile apps, Career Coach, Job Search automation, and marketing communications.

3. Data We Collect

  • Account & contact data — name, email, phone number, and login credentials.
  • Job search materials — CVs, cover letters, and job descriptions you share with us.
  • Interview data — transcripts and session metadata from mock interview sessions.
  • Career Coach data — conversation history and career preferences.
  • Technical & usage data — IP addresses, device type, browser, and usage patterns.
  • Marketing preferences — your opt-in and communication history.

4. How We Use Data; Legal Bases

  • Provide and secure our services and automation pipelines.
  • Power the Career Coach and Job Search matching engine.
  • Improve reliability and service quality.
  • Send marketing communications where you have given consent.
  • Comply with applicable laws and regulations.

5. Model Providers; AI Processing

We send the minimum necessary data to AI model providers to carry out the service you have requested. Our model providers do not train their models on your data. Prompts are processed transiently and are not stored by providers beyond the API call.

6. Automated Decision Making & Profiling

Our matching engine scores your CV against job descriptions automatically. This score is advisory — it determines which jobs you are notified about, but all final application decisions rest with you.

7. Audio Capture and Speech-to-Text

7.1 Capture

Audio is captured only during Career Coach and Interview Prep sessions, and only with your active consent.

7.2 Raw Audio

Raw audio is processed in memory and is not stored permanently on our servers.

7.3 Transcripts

Transcripts are stored and retained until you request deletion.

7.4 Purpose Limitation

Audio data is used exclusively for the coaching or interview service you have initiated.

7.5 Testing

De-identified samples may be used internally to improve transcription accuracy.

7.6 Provider Safeguards

We use industry-standard speech-to-text providers with contractual data protection commitments.

7.7 International Transfers

Audio processing may occur outside Uganda. Where this happens, appropriate safeguards (Standard Contractual Clauses) are in place.

7.8 Provider Changes

We will update this policy if we change our audio processing provider.

7.9 Your Choices

You can disable audio capture at any time in your account settings or by ending the session.

8. "As Provided" Transmission; Restricted Data

You are responsible for not including sensitive categories of data (health, financial, biometric) in documents you upload unless strictly necessary for the service requested.

9. Local vs Cloud Processing

Where technically feasible, processing occurs on our own infrastructure. AI inference tasks are routed to cloud providers due to computational requirements.

10. International Transfers

Our primary infrastructure is EU-hosted. Where data is transferred internationally, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission.

11. Sharing

We do not sell your data. We share data only with:

  • Service providers who help us deliver the service (under data processing agreements).
  • Third-party platforms you explicitly connect to (e.g., job boards).
  • Competent authorities where required by law.

12. Cookies & Similar Technologies

We use essential cookies to keep you signed in and to maintain session state. Analytics cookies help us understand how the service is used. You can manage cookie preferences via your browser settings. See our Cookie Policy page for full details.

13. Marketing; Consent Records

We send marketing communications only where you have given explicit consent. Each separate marketing channel (email, SMS, WhatsApp) requires separate consent. You can withdraw consent at any time by clicking "unsubscribe" or contacting us.

14. Data Retention

  • Account data: retained for the life of your account.
  • Interview & coaching transcripts: retained until you request deletion.
  • Marketing mailbox: 3 months after your last payment or last consent date.
  • Backups: purged within +30 days after primary deletion.

15. Your Rights (UK/EEA)

If you are located in the UK or EEA, you have the following rights:

  • Access — request a copy of your personal data.
  • Correction — ask us to correct inaccurate data.
  • Deletion — request erasure of your data (see our Data Deletion Policy).
  • Restriction — ask us to limit how we process your data.
  • Objection — object to processing based on legitimate interests.
  • Portability — receive your data in a structured, machine-readable format.

To exercise any of these rights, contact andeh@myjobconcierge.com.

16. Security

We apply industry-standard technical and organisational measures to protect your data, including encryption in transit (TLS) and access controls on all data stores.

17. Children

My Job Concierge is not directed at users under the age of 18. We do not knowingly collect personal data from minors.

18. Complaints

If you believe your data rights have been violated, you may lodge a complaint with: National Information Technology Authority — Uganda (NITA-U). You may also contact us directly at andeh@myjobconcierge.com.

19. Changes to This Policy

We will post any updates to this policy on this page and update the "Last Updated" date. Continued use of the service after changes constitutes acceptance.

20. Third-Party Links

Our service may contain links to third-party websites. We are not responsible for their privacy practices and encourage you to read their policies.