Privacy Policy

1. Introduction

Thank you for choosing to be part of our community at Progreso AI Limited (trading as Lily AI) (“Lily”, “we”, “us”, or “our”).

We are committed to protecting your personal data and respecting your privacy rights.
This Privacy Policy explains how we collect, use, disclose, and safeguard personal data when you:

• Visit our website teamilily.ai (the “Website”),

• Interact with our AI recruitment services (the “Services”),

• Or engage with us directly.

If you have any questions about this Privacy Policy or our practices, please contact us at privacy@teamlily.ai.

2. Who We Are and Roles Under Data Protection Law

When You Apply for a Job Through Lily

• Customer (employer) – the company you are applying to is the data controller, meaning they determine why and how your data is processed for recruitment purposes.

• Lily – acts as the data processor, providing technology and services to the employer to support their hiring process.

We process your personal data only on the employer’s documented instructions, as set out in our Data Processing Agreement (DPA) with them.

⚠️ If you want to access or exercise your privacy rights (e.g., obtain a copy of your interview transcript), you should contact the employer directly, as they are responsible for handling Data Subject Access Requests (DSARs).
Lily will support the employer in fulfilling those requests.

When We Use Aggregated or Anonymous Data

Lily may act as independent controller for:

• Data that has been anonymised and aggregated,

• Used to improve our services, train AI models, and create benchmarking insights.

Aggregated data cannot identify you and is outside the scope of UK GDPR.

3. What Data We Collect

We collect three main types of data:

A. Personal Data You Provide

This includes information you directly give us, such as:

• Contact details: name, email, phone number.

• Application details: CV/resume, employment history, skills.

• Interview data: call recordings and transcripts.

• Account details: usernames and passwords if you create an account.

Example:
When you apply for a role, you might submit your CV, and during your screening call with Lily, we process your responses and store the transcript securely.

B. Information Automatically Collected

When you visit our Website or use our Services, we may collect:

• Technical Data: IP address, browser type, operating system, device identifiers.

• Usage Data: pages visited, actions taken, date and time of access.

This data is primarily used to ensure security and improve our services.

C. Information from Employers and Partners

Employers using Lily may provide us with candidate data they have collected, such as:

• Candidate lists,

• Historical hiring decisions,

• Scheduling or recruitment platform data.

We process this data solely to provide the agreed recruitment services.

4. How We Use Your Information

We process personal data for the following purposes:

We only process personal data when we have a lawful basis, such as:

• Contractual necessity – to deliver recruitment services to employers,

• Legitimate interests – improving our platform and ensuring security,

• Consent – for marketing communications,

• Legal obligations – for compliance purposes.

5. How We Share Your Information

We may share data with:

We never sell personal data to third parties.

6. International Data Transfers

If we transfer personal data outside the UK or EEA, we will:

• Use lawful transfer mechanisms, such as the UK Addendum to EU Standard Contractual Clauses (SCCs),

• Ensure equivalent protection for your data wherever it is processed.

Our current SCCs are published at:
https://teamlily.ai/legal/sccs

7. Data Retention

We retain personal data only as long as necessary to:

• Fulfil the purposes for which it was collected,

• Meet legal or regulatory requirements,

• Support employer compliance needs.

Once data is no longer needed, it is securely deleted or anonymised.
If you are a candidate, your data is retained according to the employer’s retention policy, which Lily follows strictly.

On termination of our agreement with an employer:

• Data is securely deleted within 30 days, or

• Returned to the employer if requested.

8. Your Privacy Rights

Under UK GDPR, you have rights including:

Important:
If you are a candidate, you must contact the employer directly to exercise your rights, as they are the Controller.
Lily will assist the employer in fulfilling your request but cannot act on its own.

9. Security of Your Data

We implement strict technical and organisational measures to protect data, including:

• Encryption at rest and in transit,

• Role-based access controls,

• Regular penetration testing,

• Monitoring and anomaly detection.

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10. Children’s Privacy

Our Services are not intended for individuals under 18.
If we learn that we have collected data about a child under 18 without parental consent, we will delete it immediately.

11. Updates to This Privacy Policy

We may update this Privacy Policy to reflect:

• Changes in laws,

• Changes in our practices or services,

• Other operational or regulatory needs.

The “Last Updated” date at the top indicates the latest version.
We encourage you to review this Privacy Policy regularly.

12. Contact Us

For privacy-related questions or concerns:

Progreso AI Limited
Email: privacy@teamlily.ai

13. How This Privacy Policy Works With Other Documents

This Privacy Policy works alongside:

• The Master Services Agreement (MSA) – sets out commercial terms between Lily and employers,

• The Data Processing Agreement (DPA) – governs how we process data on behalf of employers.

If there is any conflict:

• The DPA takes precedence over this Privacy Policy for data processing matters,

• The MSA governs overall contractual terms.

14. Summary for Candidates

To make this clear for candidates using Lily:

1. You are applying to a company (employer). They are responsible for your data.

2. Lily provides technology to help that company manage recruitment.

3. If you want to:

   • Access your interview transcript,

   • Correct your data,

   • Or request deletion,
     contact the employer directly.

4. Lily will assist the employer behind the scenes but cannot respond to you directly.