Fuzu Privacy Policy

Global Policy — to be read together with the applicable Country Addendum

Last updated
1 June 2026
Effective date
1 June 2026
Version
v2
Contents
  1. 1Introduction
  2. 2Definitions
  3. 3Who this Privacy Policy applies to
  4. 4What personal data we collect
  5. 5Why we process personal data and our lawful bases
  6. 6Sources of personal data
  7. 7AI Systems and automated processing
  8. 8Use of data for AI and machine-learning development
  9. 9How we share personal data
  10. 10International transfers of personal data
  11. 11How long we keep personal data
  12. 12How we protect personal data
  13. 13Your rights
  14. 14Cookies and similar technologies
  15. 15Children
  16. 16Changes to this Privacy Policy
  17. 17How to contact us and how to complain
  18. 18Country Addenda

1.Introduction

At Fuzu, we want you to be able to trust us with your personal data. This Privacy Policy explains how Fuzu Ltd and its affiliates (collectively, "Fuzu", "we", "us") collect, use, share, and protect personal data when you use our services. We comply with the General Data Protection Regulation (GDPR) and with the data-protection laws applicable in the other countries where we operate, and we always aim to act in accordance with good data-protection practice.

This Privacy Policy applies to Fuzu's websites (including www.fuzu.com), mobile applications, and the Fuzu career, recruitment, learning, talent-pool, and workforce platforms operated by Fuzu, including Fuzu Atlas (together, the "Service").

If you access the Service from Kenya, Uganda, or Nigeria, the applicable Country Addendum forms part of this Privacy Policy and prevails over the Global Policy to the extent of any conflict on matters specifically addressed in the Country Addendum.

Quick read: We collect the information you put into the Service (profile, CV, applications, learning activity), information that's generated when you use it (recommendations, search history, device and security data), and information we receive from other sources you connect (such as LinkedIn). We use this data to operate the Service, to match you with opportunities, to keep the platform safe, and to develop our products including our AI systems. We share it with Employers when you apply for or accept opportunities, with the Fuzu group, with our service providers, and where required by law. You have a range of rights described in Section 13.

Data controller

Fuzu Ltd, a company registered in Helsinki, Finland (business ID FI25462252, registered address: Lapinlahdenkatu 16, 00180 Helsinki, Finland), is the controller of personal data processed in connection with the Service, unless a different Fuzu group entity is specified as the controller in the applicable Country Addendum, in an order form, or in a separate agreement.

Fuzu Ltd is registered with the Office of the Data Protection Commissioner of Kenya as a data controller and data processor. Details of Fuzu's registration and local representative arrangements in each operating country are set out in the applicable Country Addendum.

Data Protection Officer and how to contact us

You can contact Fuzu about this Privacy Policy or about how we process your personal data at:

  • Email: privacy@fuzu.com
  • Post: Fuzu Ltd, Data Protection Officer, Lapinlahdenkatu 16, 00180 Helsinki, Finland
  • Through your account: www.fuzu.com/contact or the in-product support flow

Local contact details for Kenya, Uganda, and Nigeria are set out in the applicable Country Addendum.

2.Definitions

In this Privacy Policy, capitalised terms have the meanings given in the Fuzu Service Terms unless defined otherwise here. In particular:

  • "GDPR" means Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation).
  • "personal data" means any information relating to an identified or identifiable natural person.
  • "processing" means any operation performed on personal data, including collection, storage, use, sharing, and deletion.
  • "special-category data" means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data used for unique identification, data concerning health, or data concerning sex life or sexual orientation.
  • "AI System" has the meaning given in the Fuzu Service Terms.

3.Who this Privacy Policy applies to

This Privacy Policy applies to personal data processed by Fuzu about the following categories of individuals:

  • Candidates and Job Seekers: individuals who create a Fuzu account or otherwise interact with the Service to search for or take part in employment, workforce, learning, or career-related opportunities.
  • Business User contacts: individuals acting on behalf of Employers, recruiters, workforce clients, partners, or other organisations that use the Service.
  • Workforce participants: individuals engaged through Fuzu Atlas or comparable workforce services.
  • Visitors: individuals who visit Fuzu's websites or contact Fuzu without creating an account.

Where Fuzu processes personal data on behalf of an Employer or other Business User in the course of providing the Service (for example, where an Employer uses Fuzu's employer tools to manage a candidate pipeline that the Employer has sourced independently of Fuzu), Fuzu may act as a data processor in respect of that personal data. In those cases, the Business User is the controller, and Fuzu's processing is governed by Fuzu's Data Processing Addendum.

4.What personal data we collect

4.1 Information you provide

We collect personal data that you provide directly to us, including:

  • Account information (name, email, phone, password, country, date of birth).
  • Profile information (work history, education, skills, languages, certifications, salary expectations, work preferences, CV and supporting documents, optional photo).
  • Application and recruitment information (cover letters, application responses, test and assessment results, communications with Employers).
  • Links to external social networks or online resources (LinkedIn profile, GitHub account, Google Drive work samples, etc.)
  • Learning information (courses you enrol in, content you view, progress and completions).
  • Workforce engagement information (identity verification, payment account details, tax information, work authorisation evidence, engagement and task records).
  • Communications you send to us or through the Service.
  • Payment information for paid features (processed primarily by our payment-service providers).

4.2 Information generated by your use of the Service

We collect information generated automatically when you use the Service, including:

  • Activity and engagement data (pages and content viewed, opportunities searched and applied for, recommendations engaged with, time on platform).
  • Device and technical data (device type, operating system, browser, app version, IP address, language and locale settings, crash diagnostics).
  • Security and authentication data (login attempts, session tokens, multi-factor authentication signals).
  • Approximate location data based on IP address. Precise location is collected only with your permission.

4.3 Information from third parties

We may receive personal data about you from third parties, including:

  • Third-party login providers you choose to use (such as Google, Apple, LinkedIn, or Microsoft), which provide us with the basic profile information you have authorised them to share.
  • Employers or recruiters who add you to their pipelines, search you in our database with your visibility settings allowing it, or invite you to apply.
  • Public professional sources that you have made available.
  • Background-check or identity-verification providers engaged in connection with workforce opportunities, where you have authorised such checks.
  • Service providers operating on Fuzu's behalf for analytics, fraud prevention, and platform security.

4.4 Special-category data

We do not require you to provide special-category data to use the Service. Where you choose to share information that is or may constitute special-category data (such as information about a disability for the purpose of accessibility, or information about your trade-union or political activities included on your CV), you are providing that information voluntarily. To the extent processing of special-category data is necessary, we rely on your explicit consent or another lawful basis under Article 9 of the GDPR or the equivalent local provision.

5.Why we process personal data and our lawful bases

This section sets out, by category of data subject, the purposes for which Fuzu processes personal data, the lawful bases on which Fuzu relies, the types of personal data involved, and the periods for which Fuzu retains the data. Where Fuzu relies on legitimate interests, Fuzu has assessed those interests against the rights and freedoms of data subjects and considers that the processing is necessary and proportionate. You may request further information about that assessment via the contact details in Section 17.

5.1 Candidates and Job Seekers

Purpose of processingLegal basisTypes of personal dataRetention

Account creation and management

Contract (Art. 6(1)(b) GDPR); Legitimate interest in operating the Service as a long-term career platform

  • Name
  • Email address
  • Phone number
  • Account credentials
  • Login method (incl. third-party login identifier)
  • Country and city of residence
  • Date of birth

For as long as you maintain your Fuzu account. The Fuzu platform is designed for use over a multi-year career horizon, including periodic returns after extended gaps for new job searches, learning, and career coaching. Where you have not logged in or otherwise interacted with the Service for 10 years (the "Dormancy Threshold"), Fuzu will initiate the re-engagement flow described in Section 11; if you do not respond, the account and associated profile-level data will be deleted.

Building and managing the Candidate profile

Contract; Legitimate interest in operating the Service as a long-term career platform; Consent (where you proactively share special-category information such as health or disability)

  • Professional profile information (work history, education, skills, languages, certifications)
  • CV and supporting documents
  • Salary expectations and work preferences
  • Photo (optional)
  • Self-reported information you choose to add

For as long as you maintain your Fuzu account, subject to the 10-year Dormancy Threshold and re-engagement flow described in Section 11.

Headhunting visibility and discoverability

Legitimate interest in connecting Candidates with relevant opportunities; Consent for headhunting opt-in

  • Profile data made visible to Employers for sourcing
  • Discoverability preferences

Headhunting visibility is automatically switched off after 24 months of profile inactivity, at which point the profile is no longer surfaced in headhunting searches or included in recommended talents. Visibility can be reactivated by returning to the platform.

Processing job and opportunity applications (campaign-linked data)

Contract; Legitimate interest in operating the recruitment workflow

  • Profile snapshot taken at the moment of application (captured as a JSON record and stored with the application)
  • Application content (cover letter, screening question responses, attachments)
  • Assessment and test results submitted as part of the application
  • Communications between Candidate and Employer through the Service
  • Pipeline-stage information, status, and progression
  • Employer-authored evaluative content (assessor notes, interview records, ratings, comments, rejection rationale)
  • Hire outcomes

30 months from the Recruitment Process End Date (RPED) of each specific campaign. RPED is defined as the date on which the campaign is closed for applications by the Employer. Campaign-linked data is retained for the 30-month period regardless of profile activity, and is automatically deleted at the end of the period. Anonymised aggregated data derived from the campaign may be retained for analytics and benchmarking as described elsewhere in this Policy.

Dispute snapshot following a right-to-erasure request

Legitimate interest in establishing, exercising, or defending legal claims

  • Anonymised application record (Candidate identifier replaced with an anonymous identifier)
  • Profile snapshot taken at the moment of application
  • Application content and outcomes

24 months from the RPED of the relevant campaign. The dispute snapshot is accessible only through the specific campaign context (not via headhunting, search, or cross-campaign views) and is used solely for the establishment, exercise, or defence of legal claims relating to that campaign. Permanently deleted at the end of the 24-month period.

Recommendations, matching, and ranking of opportunities

Legitimate interest in personalising the Service

  • Profile data
  • Application and search history
  • Engagement and platform-activity signals
  • Location-related information

30 months from the Recruitment Process End Date (RPED).

Skill assessments, tests, and learning content

Contract; Consent (for aptitude or personality tests where applicable under local law)

  • Test responses
  • Test results and scores
  • Time-on-task data
  • Course enrolments, progress, and completions

Profile-level assessment results and learning history: for as long as you maintain your Fuzu account, subject to the 10-year Dormancy Threshold described in Section 11. Campaign-specific assessment results submitted as part of an application: 30 months from RPED of the relevant campaign.

Workforce opportunities, talent pools, and Fuzu Atlas

Contract; Consent for talent-pool inclusion; Legal obligation for identity, tax, and work-eligibility records

  • Profile data
  • Identity verification information
  • Bank or payment account information
  • Tax identification and residency information
  • Work authorisation evidence
  • Engagement and task-completion records

Duration of the engagement plus statutory retention under local tax, employment, and accounting law (typically 6 to 10 years).

Communications with Users and Employers

Contract; Legitimate interest in operating the Service

  • Messages sent or received through the Service
  • Communication metadata
  • Customer-support correspondence

Campaign-linked candidate–recruiter messages: 30 months from RPED of the relevant campaign. General customer-support correspondence: up to 24 months after last contact.

Account safety, fraud prevention, and platform security

Legitimate interest; Legal obligation (where applicable)

  • Login data and authentication events
  • Device and browser information
  • IP address
  • Behavioural and abuse-detection signals

Up to 24 months; longer where required to investigate or defend legal claims.

Service development, analytics, and AI/ML training

Legitimate interest in operating and improving the Service

  • Profile data
  • Application and learning activity
  • Behavioural data
  • Aggregated and anonymised data

Personal data: aligned with the retention periods for the underlying data category (profile-level data follows account retention with the 10-year Dormancy Threshold; campaign-linked data is retained for 30 months from RPED). You have the right to object to AI/ML training as described in Section 8. Anonymised or aggregated data: may be retained indefinitely.

Direct marketing and content recommendations

Consent for electronic direct marketing; Legitimate interest for on-platform recommendations

  • Contact details
  • Profile data
  • Preferences and behavioural signals

Until you withdraw consent or object, or up to 24 months from last activity, whichever is earlier.

Legal compliance, dispute resolution, and enforcement of Terms

Legal obligation; Legitimate interest in establishing, exercising, or defending legal claims

Information necessary to comply with a legal obligation or to establish, exercise, or defend a legal claim

As required by applicable law or until conclusion of relevant proceedings.

5.2 Business User contacts (Employers, recruiters, workforce clients)

Purpose of processingLegal basisTypes of personal dataRetention

Employer / Business User account management

Contract; Legitimate interest in operating the Service

  • Organisation details (name, registration number, address, sector)
  • Contact-person information (name, role, email, phone)
  • Account credentials

Duration of the contract plus 24 months

Posting opportunities, candidate sourcing, and pipeline management

Contract

  • Job advertisements and opportunity content
  • Candidate evaluation notes and pipeline status
  • Interactions with Candidates through the Service

30 months from the Recruitment Process End Date (RPED) of each specific campaign, in line with campaign-linked data retention. Longer where Employer instructions or local law require.

Subscription, billing, and payments

Contract; Legal obligation (accounting and tax records)

  • Billing contact details
  • Tax identification numbers
  • Bank account or card information (where relevant)
  • Transaction records

Statutory retention for accounting records (typically 6 to 10 years depending on jurisdiction)

Customer support, account management, and onboarding

Contract; Legitimate interest

  • Communications
  • Support tickets and notes
  • Account-usage information

Duration of the contract plus 24 months

Sales, business development, and B2B marketing

Legitimate interest; Consent where required by local marketing-communications law

  • Professional contact details (name, role, organisation, business email, business phone)
  • Engagement history
  • Profile information made publicly available by the contact

Up to 24 months from last meaningful contact; longer with consent

Service development and analytics

Legitimate interest

  • Usage data
  • Aggregated and anonymised activity

Up to 24 months for personal data; anonymised data may be retained indefinitely

Compliance, fraud and abuse prevention, and platform security

Legitimate interest; Legal obligation

  • Identity verification information
  • Behavioural and abuse-detection signals
  • Sanctions and screening information

Up to 24 months; longer where required to investigate or defend legal claims

Reference rights and case studies

Legitimate interest; Consent where required by local law

  • Organisation name and logo
  • Customer-testimonial content

Until consent is withdrawn or the reference is removed

5.3 Visitors and prospective users

Purpose of processingLegal basisTypes of personal dataRetention

Website analytics and improvement

Consent (where required for non-essential cookies); Legitimate interest for first-party analytics that does not require consent

  • IP address
  • Device and browser information
  • Pages viewed and on-site behaviour
  • Referring URL

Up to 14 months for analytics data; specific cookie lifetimes are set out in the Cookie Notice

Marketing communications to visitors and prospects

Consent

  • Email address provided through forms
  • Information you provide in your message

Until you withdraw consent or 24 months from last engagement, whichever is earlier

Responding to enquiries received through the website

Legitimate interest in responding to the enquiry

  • Contact details
  • Content of the enquiry

Up to 24 months from last contact

6.Sources of personal data

Personal data is mainly collected directly from you. We also collect personal data from the third-party sources described in Section 4.3, from your interactions with our Service, and (for Business User contacts) from public business sources and through introductions or referrals in the ordinary course of business.

7.AI Systems and automated processing

Fuzu uses AI Systems within the Service to support recommendations, candidate-employer matching, ranking and prioritisation of opportunities, personalisation, fraud and abuse detection, content moderation, and platform improvement. The way these AI Systems operate is described in Section 7 of the Fuzu Service Terms. Recommendations and rankings are produced primarily by rule-based, transparent, expert-defined logic, supplemented where appropriate by analytics.

Fuzu has assessed its AI Systems and considers that, in their current design and use, they perform preparatory and supportive tasks for recruitment and career-development decisions taken by human decision-makers. On that basis, having regard to Article 6(3) of the EU AI Act, Fuzu does not currently classify these AI Systems as high-risk AI systems under Annex III of the AI Act. Fuzu reviews this position on an ongoing basis.

7.1 No solely automated decisions with significant effects

Fuzu does not make decisions about you based solely on automated processing that produce legal effects concerning you or similarly significantly affect you, in the course of providing the core recruitment and career-platform functionality of the Service. Final hiring, engagement, promotion, performance, and termination decisions are made by Employers, recruiters, workforce clients, or other authorised parties, and not by Fuzu's AI Systems.

Where Fuzu itself uses an AI System to make or materially influence a platform-level decision about you (for example, account suspension, listing removal, or eligibility for a workforce opportunity), Fuzu provides human review of decisions that would significantly affect you, in line with Section 7.3 of the Service Terms.

7.2 Transparency and explanation

Where you interact with an AI System through the Service, Fuzu will inform you of that fact where required by applicable law, except where the AI nature of the interaction is obvious.

As a voluntary commitment, where a decision made through the Service significantly affects you and is based wholly or in part on the output of an AI System, you may request a clear and meaningful explanation of the role of the AI System and of the main parameters and types of input relied upon. Requests should be sent using the contact details in Section 17.

7.3 Your rights in relation to automated processing

Independently of the AI Act classification, you have the rights described in Section 13, including the right to object to processing carried out on the basis of legitimate interest (which includes the operation of Fuzu's recommendation and matching features) and the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects.

8.Use of data for AI and machine-learning development

Fuzu uses personal data and other platform data to develop, train, evaluate, and improve its AI Systems and analytics models within the Service and within Fuzu-operated or affiliated services (including Fuzu Atlas). The lawful basis for this processing is Fuzu's legitimate interest in operating, securing, and improving the Service and in developing new services and technologies.

You have the right to object to processing of your personal data for AI and machine-learning development purposes at any time, using the contact details in Section 17 or, where available, the relevant control in your account settings. Fuzu will respect your objection unless Fuzu can demonstrate compelling legitimate grounds that override your interests or where the processing is necessary for the establishment, exercise, or defence of legal claims. Objection does not affect the lawfulness of processing carried out before the objection.

Fuzu also uses anonymised, aggregated, or otherwise non-personal data derived from platform activity for analytics, benchmarking, research, service improvement, workforce intelligence, machine-learning development, and related commercial purposes, including in collaboration with affiliated services, service providers, technology partners, research organisations, or workforce and recruitment partners. Once data is fully anonymised so that you can no longer be identified, it ceases to be personal data and is not subject to the rights described in Section 13.

9.How we share personal data

9.1 With Employers and recruiters — applications submitted through the Service

When you apply for an opportunity posted on Fuzu by an Employer, your profile data, application content, and any assessment results submitted in connection with the application are shared with the relevant Employer. The Employer manages the resulting candidate pipeline, including communications with you, status updates, interview records, and assessor notes.

Fuzu and the Employer act as joint controllers in respect of this processing. This reflects the fact that the majority of Candidates applying to Employers through the Service originate from the Fuzu talent pool, that Fuzu retains access to the Employer-specific campaign data for specific platform purposes (described below), and that Fuzu and the Employer have overlapping purposes in operating the recruitment workflow. The allocation of responsibilities between Fuzu and the Employer is set out in the Joint Controller Arrangement ("JCA"), the essence of which is available on the joint controllers page.

At the moment you submit an application, Fuzu captures a snapshot of your profile and associates the snapshot with the application. The snapshot, together with all other campaign-linked data (your application content, communications with the Employer, assessor notes, interview records, and hire outcomes), is retained for thirty (30) months from the Recruitment Process End Date ("RPED") of the specific campaign. RPED is defined as the date on which the campaign is closed for applications by the Employer. The 30-month retention runs independently of your profile activity — campaign-linked data is retained for the full period regardless of whether you remain active on Fuzu.

Fuzu's access to the campaign-linked data during the 30-month retention period serves the following purposes:

  • Allowing the Employer to return to the shortlist if a preferred candidate does not accept or perform well, or to rerun the campaign within the retention window.
  • Supporting your experience continuity across applications (your progression record is preserved within the retention window).
  • Maintaining platform integrity and enforcing the anti-circumvention obligations described in Section 21 of the Service Terms.
  • Stewardship of Candidate data on behalf of the talent-pool community, including in support of future opportunities for which you may be relevant.
  • Establishing, exercising, or defending legal claims that may arise from the recruitment process.

At the end of the 30-month period, the campaign-linked data is automatically deleted. Anonymised aggregated data derived from the campaign may be retained for analytics and benchmarking purposes.

Where you exercise the right to erasure (described in Section 13), your profile and profile-level data are deleted in accordance with this Policy. Campaign-linked data relating to your applications is, however, retained for legal-defence purposes for twenty-four (24) months from the RPED of the relevant campaign, with your user identifier replaced by an anonymous identifier so that no direct personal data link remains. The dispute snapshot is accessible only through the specific campaign context and is used solely for the establishment, exercise, or defence of legal claims relating to that campaign. After the 24-month period, the dispute snapshot is permanently deleted.

Fuzu maintains role-based access controls governing which Fuzu personnel can see what campaign-linked data, including assessor notes and interview records. The Fuzu Internal Access Control Policy describes those controls; the policy is available to Customers and supervisory authorities on request under appropriate confidentiality.

Employers who receive your personal data are independent controllers (or, where applicable, joint controllers with Fuzu under the JCA) of the data they receive through the Service and are responsible for their own processing, including for providing you with their own privacy notice.

9.1.1 With Employers and recruiters — passive recommendations

Separately from applications, Fuzu may recommend your profile to Employers based on profile-fit with a job description. Recommendations are surfaced where you have opted in to be discoverable for opportunities matching your stated preferences. Recommendation does not, by itself, share your profile with the Employer for the Employer to retain — it surfaces your profile within the Employer's view of recommended candidates.

Where the Employer decides to add your profile to its pipeline or to contact you, the Employer makes that decision unilaterally; Fuzu does not determine which recommended candidates are added or contacted. Fuzu and the Employer act as independent controllers in respect of this processing. Each party is the sole controller in respect of its own step:

  • Fuzu is the controller of the recommendation step (which profiles are surfaced and on what basis).
  • The Employer is the controller of the add-to-pipeline-and-contact step (which recommended profiles are engaged with and how).

Where you subsequently apply to a Customer's vacancy (whether initiated by you or in response to the Customer reaching out), the application flow described in Section 9.1 applies and joint controllership begins from that point.

9.1.2 With Employers and recruiters — managed recruitment (Fuzu Elite)

Where the Employer has engaged Fuzu Elite (or an equivalent managed-recruitment service), Fuzu's recruitment consultants select candidates from the recommendation pool on the Employer's behalf and present a shortlist to the Employer. Fuzu and the Employer act as joint controllers in respect of the Elite processing activities, on a basis that is substantially the same as Section 9.1 above, with the additional element that Fuzu's consultants apply professional judgment when selecting candidates from the recommendation pool. The JCA describes the allocation of responsibilities.

9.1.3 With workforce clients — Fuzu Atlas engagements

Where you accept a workforce opportunity through Fuzu Atlas or a comparable service, the relevant workforce client or counterparty receives information necessary to engage you, including identity verification information, payment account details, tax-residency information, and work-authorisation evidence.

Fuzu and the workforce client (or the workforce-engagement entity engaging you on the client's behalf) act as joint controllers in respect of the engagement-formation phase, which covers the activities from initial sourcing through to commencement of substantive work delivery. The JCA describes the allocation of responsibilities. Once you begin delivering work, the workforce client (or workforce-engagement entity) becomes the sole controller in respect of performance management and ongoing engagement-related processing; Fuzu Atlas may continue to act as a processor on the client's behalf for platform-mediated tasks. Where the workforce involves sensitive content (such as content moderation, AI training and evaluation, or red-team work), Atlas applies additional consent, training, and welfare protections, which are described in the Atlas-specific terms made available to you.

9.1.4 Update to your visibility and what Employers see

Where you make your profile visible to Employers (for example, by joining a talent pool or by opting in to be discoverable for headhunting), the relevant Employers may view your profile in accordance with the visibility settings in your account. You can change your visibility settings at any time through your account.

9.2 Within the Fuzu group

Fuzu may share personal data within the Fuzu group of companies (including any local affiliates and Fuzu Atlas) for the purposes described in this Privacy Policy. Where required by applicable law, such sharing is governed by an intra-group data-sharing arrangement.

9.3 With service providers and processors

Fuzu uses service providers to operate and improve the Service, including:

  • Cloud-hosting and infrastructure providers
  • Communications providers (email, SMS, messaging)
  • Payment-service providers
  • Analytics, performance-monitoring, and product-improvement tools
  • Fraud-prevention and identity-verification services
  • Background-check providers (for workforce engagements where authorised)
  • Customer-support and ticketing systems
  • Marketing-automation and advertising-measurement services
  • AI/ML model providers and infrastructure

Service providers process personal data as data processors on Fuzu's behalf under contractual safeguards required by applicable data-protection law.

9.4 With business partners

Fuzu may share personal data with business partners including educational institutions, employer networks, government employment programmes, and workforce-development partners, where you have consented or where there is another lawful basis to do so. The applicable arrangement is described to you at the point of collection or in the relevant Service feature.

9.5 Mandatory disclosures, legal proceedings, and protection of rights

Fuzu may disclose personal data to law-enforcement authorities, regulators, courts, or other competent third parties where Fuzu is required to do so by law or where disclosure is necessary to comply with a legal obligation, to respond to a binding request from a competent authority, to enforce Fuzu's Terms, or to establish, exercise, or defend a legal claim.

9.6 Business transfers

If Fuzu is involved in a merger, acquisition, reorganisation, or sale of assets, personal data may be transferred as part of that transaction. We will notify you of any such transfer where required by applicable law.

9.7 Advertising and analytics partners

Fuzu may share information with advertising-measurement and analytics partners. We do not share information that directly identifies you (such as name or email address) with these partners for their own marketing purposes without your consent. We may share aggregated or pseudonymised information that does not directly identify you and may permit measurement partners to confirm that an advertisement was delivered.

10.International transfers of personal data

Fuzu operates globally and uses service providers located in various countries. Your personal data may therefore be transferred outside the country where you use the Service, including to Finland and other countries of the European Economic Area (EEA), the United States, the United Kingdom, and other countries where Fuzu, its affiliates, or its service providers operate.

Where personal data is transferred outside the EEA, Fuzu relies on one or more of the following lawful transfer mechanisms in accordance with Chapter V of the GDPR:

  • Transfers to countries that the European Commission has determined provide an adequate level of protection.
  • Standard contractual clauses approved by the European Commission, supplemented by additional safeguards where required following a transfer-impact assessment.
  • Binding corporate rules, where applicable.
  • Other mechanisms permitted under Articles 46 or 49 of the GDPR.

Where personal data is transferred outside Kenya, Uganda, or Nigeria, Fuzu relies on the transfer mechanisms permitted under the data-protection law of the relevant country, as further described in the applicable Country Addendum.

You may request further information about the transfer mechanisms applicable to your personal data using the contact details in Section 17.

11.How long we keep personal data

Fuzu retains personal data only for as long as necessary for the purposes for which it was collected, including for the purposes of complying with legal, regulatory, accounting, tax, and reporting obligations and for the establishment, exercise, or defence of legal claims. The retention framework operates on four principal timelines, reflecting the different purposes for which personal data is processed.

11.1 Profile-level data — account-driven retention with dormancy backstop

Fuzu is designed for use as a long-term career development platform. Many Users return to Fuzu after multi-year gaps for new job searches, learning, career coaching, or to reconnect with the platform's tools. Your profile is intended to remain available to you across that horizon, in the same way you would expect from a professional online identity (similar to LinkedIn, Xing, Indeed, and other career platforms).

Accordingly, profile-level data (your account, profile, work and education history, skills, learning records, and similar account-attached data) is retained for as long as you maintain your Fuzu account. The retention is not tied to a fixed activity-based clock.

Where you have not logged in or otherwise interacted with the Service for ten (10) years (the "Dormancy Threshold"), Fuzu will initiate a re-engagement flow to confirm your continued interest before deleting your data:

  • Fuzu sends an initial re-engagement notification at the Dormancy Threshold, informing you that your account is scheduled for deletion and inviting you to log in or otherwise interact with the Service to maintain your account.
  • Fuzu sends two further reminders at intervals of approximately sixty (60) days, providing a total re-engagement window of approximately six (6) months.
  • Where Fuzu has additional contact channels available (such as a registered phone number for SMS or in-app push notifications), Fuzu may use those channels in addition to email.
  • If you respond by logging in, updating your profile, or otherwise interacting with the Service, the Dormancy Threshold is reset and the account continues to be retained.
  • If you do not respond by the end of the re-engagement window, your account and profile-level data are deleted. Limited information may be retained where required by law or as described elsewhere in this Policy.

11.2 Campaign-linked data — 30 months from RPED

Campaign-linked data (the profile snapshot taken at the moment of application, your application content, communications with the Employer, pipeline-stage information, assessor notes, interview records, and hire outcomes) is retained for thirty (30) months from the Recruitment Process End Date (RPED) of each specific campaign. Campaign-linked data is retained for the full 30-month period regardless of whether you remain active on the Service. RPED is the date on which the relevant campaign is closed for applications by the Employer.

At the end of the 30-month period, the campaign-linked data is automatically deleted. Campaign-linked data retention is independent of your account retention; closing your account does not automatically delete campaign-linked data, but does trigger the anonymisation of your user identifier in the campaign records (see Section 11.3).

11.3 Dispute-snapshot data — 24 months from RPED, anonymised

Where you exercise the right to erasure (described in Section 13), your profile and profile-level data are deleted in accordance with this Policy. Campaign-linked data relating to your applications is, however, retained for legal-defence purposes for twenty-four (24) months from the RPED of the relevant campaign, with your user identifier replaced by an anonymous identifier so that no direct personal data link remains. The dispute snapshot is accessible only through the specific campaign context and is used solely for the establishment, exercise, or defence of legal claims relating to that campaign. After the 24-month period, the dispute snapshot is permanently deleted.

11.4 Headhunting visibility — automatic switch-off at 24 months of inactivity

Separate from profile retention, your headhunting visibility (whether your profile is surfaced to Employers in headhunting searches and recommended-talent lists) is automatically switched off after twenty-four (24) months of profile inactivity. At that point, your profile remains in your account but is no longer actively offered to Employers. Headhunting visibility is reactivated automatically when you next log in or update your profile.

11.5 Other exceptions and overrides

The framework above is subject to the following overrides:

  • Where Fuzu is required by law to retain certain information for longer (for example, accounting, tax, anti-money-laundering, or recruitment-licensing records).
  • Where Fuzu has shared information with Employers, recruiters, or workforce clients as part of an application, talent-pool participation, or workforce engagement, in which case those recipients hold the data as independent or joint controllers and apply their own retention periods.
  • Where Fuzu has a continuing legitimate interest in retaining the information for a limited period (for example, fraud prevention, dispute resolution, or anti-circumvention enforcement under the Service Terms).
  • Where the information has been fully anonymised, in which case it may be retained indefinitely as non-personal data.

11.6 Closing your account at any time

You may close your account at any time through your account settings or by contacting Fuzu at the details in Section 17. When you close your account, your profile and account data will generally cease to be visible to other Users within 48 hours, and profile-level data will be deleted within 30 days. Campaign-linked data relating to applications you have submitted is retained for the 30-month-from-RPED period described in Section 11.2, with your user identifier anonymised. The right of erasure under Section 13 applies in addition to your right to close your account.

12.How we protect personal data

Fuzu uses appropriate technical and organisational measures to protect personal data against loss, unauthorised access, alteration, disclosure, and other misuse. These measures include encryption of data in transit and at rest, access controls and authentication, security monitoring and logging, employee training, vendor due diligence, and incident-response procedures. Access to personal data within Fuzu is limited to those personnel who need it for their duties.

No security measure can guarantee absolute security. Where Fuzu becomes aware of a personal-data breach that is likely to result in a risk to your rights and freedoms, Fuzu will notify the relevant supervisory authority and, where required, affected individuals in accordance with applicable law.

13.Your rights

You have the following rights in relation to your personal data, subject to the conditions and exceptions set out in applicable data-protection law. The Country Addendum applicable to you may describe additional or modified rights under local law.

RightWhat it means

Right to be informed

You have the right to clear, transparent information about how Fuzu collects and uses your personal data. This Privacy Policy is intended to satisfy that right. You may request additional information using the contact details in Section 17.

Right of access

You have the right to obtain confirmation as to whether Fuzu processes your personal data, and where it does, to receive a copy of that personal data together with information about the processing.

Right to rectification

You have the right to ask Fuzu to correct inaccurate or incomplete personal data we hold about you. Many corrections can be made directly through your account settings.

Right to erasure (right to be forgotten)

You have the right to ask Fuzu to delete your personal data in certain circumstances, including where the data is no longer needed for the purposes for which it was collected, where you withdraw consent, or where you object to processing and Fuzu has no overriding legitimate grounds to continue. This right may be limited where Fuzu is required to retain data by law.

Right to restrict processing

You have the right to ask Fuzu to limit the processing of your personal data in certain circumstances, for example where you contest the accuracy of the data or where you have objected to processing pending verification of Fuzu's grounds.

Right to data portability

Where Fuzu processes your personal data on the basis of consent or contract and by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller.

Right to object

You have the right to object to the processing of your personal data where the processing is based on Fuzu's legitimate interests, including for AI/ML training, profile-based recommendations, and direct marketing. Fuzu will respect your objection unless we can demonstrate compelling legitimate grounds that override your interests or where processing is necessary for the establishment, exercise, or defence of legal claims. Objection to direct marketing is always honoured.

Rights related to automated decision-making

You have the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects. Fuzu does not make decisions based solely on automated processing that produce such effects in the course of the core recruitment and career-platform functionality of the Service. Where automated processing is used to support a decision, you have the right to obtain human intervention, to express your point of view, and to contest the decision.

Right to withdraw consent

Where Fuzu's processing of your personal data is based on consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal. Where you withdraw consent, Fuzu may no longer be able to provide some features of the Service to you.

Right to lodge a complaint

You have the right to lodge a complaint with the data protection supervisory authority in your country. The relevant authority for your country is identified in the applicable Country Addendum or in Section 17. You are encouraged to contact Fuzu first so that we can attempt to address the matter.

You may exercise these rights by contacting Fuzu using the details in Section 17. Many of the rights, including access, rectification, marketing objection, and download of profile data, can be exercised directly through your account settings.

Fuzu will respond to your request without undue delay and in any event within the time period required by applicable law (typically one month under the GDPR, extendable by a further two months for complex or numerous requests). Fuzu may request reasonable information to verify your identity before responding to a request.

If Fuzu does not act on your request, Fuzu will inform you of the reasons. You have the right to lodge a complaint with the data-protection supervisory authority in your country, as identified in the applicable Country Addendum.

14.Cookies and similar technologies

Fuzu uses cookies, pixels, web beacons, software development kits, and similar technologies to operate the Service, to remember your preferences, to keep you signed in, to analyse use of the Service, to provide personalised content and recommendations, and to deliver and measure advertising. Detailed information about the cookies and similar technologies used by Fuzu, their purposes, and how to control them, is set out in the Fuzu Cookie Notice.

Where required by applicable law, Fuzu obtains your consent before placing non-essential cookies or similar technologies on your device. You can change your cookie preferences at any time through the cookie preferences centre on the Service.

15.Children

The Service is designed for use by individuals aged sixteen (16) and above, or such higher minimum age as may be required by applicable law in your country of residence. The Country Addendum applicable to you may set out a different minimum age. Fuzu does not knowingly collect personal data from individuals below the applicable minimum age. If you believe that Fuzu has collected personal data from a person below the applicable minimum age without appropriate consent, please contact Fuzu using the details in Section 17, and Fuzu will take appropriate steps to delete the information.

16.Changes to this Privacy Policy

Fuzu may update this Privacy Policy from time to time to reflect changes to our practices, the Service, or applicable law. The current version of the Privacy Policy will always be available at www.fuzu.com/legal/privacy, with the effective date indicated at the top of the document.

Where changes are material, Fuzu will provide reasonable advance notice through the Service, by email, or by other appropriate means before the updated Privacy Policy takes effect. We encourage you to review this Privacy Policy from time to time.

17.How to contact us and how to complain

Questions about this Privacy Policy or about how Fuzu processes your personal data may be directed to:

  • Email: privacy@fuzu.com
  • Post: Fuzu Ltd, Data Protection Officer, Lapinlahdenkatu 16, 00180 Helsinki, Finland
  • Through your account: www.fuzu.com/contact or the in-product support flow

Country-specific contact details are set out in the applicable Country Addendum.

If you are not satisfied with Fuzu's response, you have the right to lodge a complaint with the data-protection supervisory authority in your country of residence, place of work, or place of the alleged infringement. The relevant supervisory authorities for the countries covered by Country Addenda are:

  • Finland and EU/EEA: the Office of the Data Protection Ombudsman of Finland (Tietosuojavaltuutetun toimisto), or another competent EEA supervisory authority where applicable.
  • Kenya: the Office of the Data Protection Commissioner (ODPC), www.odpc.go.ke.
  • Uganda: the Personal Data Protection Office (PDPO), www.pdpo.go.ug.
  • Nigeria: the Nigeria Data Protection Commission (NDPC), www.ndpc.gov.ng.

18.Country Addenda

The following Country Addenda form part of this Privacy Policy and apply in addition to the Global Policy:

Where there is a conflict between the Global Policy and a Country Addendum on a matter specifically addressed in the Country Addendum, the Country Addendum prevails for Users within its scope.