This Privacy Policy explains how VisionBrain Inc., a Delaware corporation doing business as Daely (“Daely,” “we,” “us,” or “our”), collects, uses, shares, and protects personal data when you use the Daely website, applications, AI chat interface, AI interviews, and related services (the “Platform”). It applies to businesses and individuals hiring talent (“Clients”) and to professionals offering services (“Candidates,” and together with Clients, “Users” or “you”). Please read it together with our Terms of Service, Cookie Policy, and Daely Wallet Policy.

For personal data described in this Policy, Daely acts as the controller, except that for payment, escrow, wallet, and investment features our payment processor (“Payment Processor”) and our trusted third-party financial infrastructure partner (“Payment Partner”) and their partners act as controllers or processors for the data they handle under their own terms and privacy notices. Where required, references to our data protection contact are in Section 17.

1. Who We Are and Scope

Daely operates a hiring platform that helps Clients and Candidates connect, run AI interviews, enter into service contracts, and make and receive payments through our Payment Processor and Payment Partner. This Policy covers personal data we process through the Platform and in related interactions. It does not cover third-party websites or services that we do not control, or the independent processing carried out by the Payment Processor, the Payment Partner, and other providers, which is governed by their own privacy notices.

2. Personal Data We Collect

Information you provide to us

• Account and profile data — name, email, password, country/location, photograph, and, for Candidates, portfolio items, service descriptions, skills, work history, and other profile content.

• Verification data — information collected to verify identity and meet know-your-customer (KYC), anti-money-laundering (AML), and sanctions-screening obligations, which may include date of birth, government identifiers, and documents. This is typically collected and processed by our Payment Partner or other verification providers.

• Payment and financial data — information needed to fund, hold, transfer, and receive payments and to operate the Daely Wallet and any savings or investment features, including payment records from our Payment Processor and escrow and wallet records from our Payment Partner. Daely does not store full payment-card or bank-account numbers.

• Communications — messages you send through the Platform (including AI chat), and information you provide when you contact support or participate in surveys. Content you submit to AI features, including AI chat messages and AI interview responses, is processed by our AI service providers.

• Meeting recordings and transcripts. Where a Client enables recording for a scheduled meeting, the meeting's audio, video, and transcript may be captured and processed by our recording and transcription providers. Participants are shown an in-meeting notice when recording is active, and by remaining in or joining a meeting after that notice appears, you consent to being recorded. If you do not consent, you may leave the meeting or ask the meeting host to disable recording before continuing. Recordings and transcripts are shared with the Client and Candidate who participated in the meeting.

AI Interview data

• Audio and video recordings of your AI interviews, along with transcripts, responses, generated scores, and related assessment results (“AI Outputs”). AI interviews occur at signup and may also be requested by a Client for a specific job. This data is described further in Section 5.

Information we collect automatically

• Device and usage data — IP address, device and browser information, identifiers, pages viewed, and actions taken, collected through cookies and similar technologies as described in our Cookie Policy.

Information from other sources

• Data from our Payment Processor, our Payment Partner, and verification and hosting providers; internally-computed usage statistics and LLM logging, and analytics providers, and information other Users provide about you (for example, a Client's feedback or a referral).

• Data from our Payment Processor, our Payment Partner, and verification and hosting providers; internally-computed usage statistics and LLM logging as described in Section 8; and information other Users provide about you (for example, a Client's feedback or a referral). 

Categories of personal data

Category

Examples

Source

Identifiers

Name, email, account ID, IP address

You; automatic

Contact data

Email, phone, country/location

You

Profile / professional data

Portfolio, services, skills, work history, education

You

AI interview data

Audio, video, transcripts, scores, assessments (AI Outputs)

You (during interviews)

Financial data

Wallet activity, payout details, transaction records

You; Payment Processor; Payment Partner

Sensitive/biometric data

Interview audio/video and derived assessments; verification identifiers

You; providers

Usage & device data

Device, browser, IP, activity logs, cookies

Automatic

Inferences

Match and recommendation signals derived from the above

Daely

3. How We Use Your Data

We use personal data to operate and improve the Platform, including to:

• create and manage your account and profile, and verify your identity;

• conduct AI interviews, generate AI Outputs, and display Candidate profiles and results to Clients;

• match Clients and Candidates and power the AI chat and recommendations;

• provide support, send service communications, and maintain safety, security, and fraud prevention, including account-integrity, sanctions, and AML/KYC screening as described in Section 6;

• comply with legal, tax, KYC/AML, and regulatory obligations; and

• improve the Platform and develop new features.

• facilitate service contracts, payments, escrow, and the Daely Wallet through our Payment Processor and Payment Partner, including resolving disputes between Users and facilitating mediation as described in our Terms of Service;

Legal bases (where GDPR or similar laws apply)

We rely on: performance of a contract with you (to provide the Platform); our legitimate interests (to operate, secure, and improve the Platform, and to prevent fraud), balanced against your rights; your consent (for example, for AI interview capture and any biometric processing, and where otherwise required); and compliance with legal obligations. Where we rely on consent, you may withdraw it at any time as described in Section 10.

4. Payments, Escrow, Wallet, and Financial Data

When you fund a payment as a Client, the amount is processed by our Payment Processor and transmitted to an escrow account held through our Payment Partner. Once released under the applicable Service Contract, funds are credited to the Candidate's Daely Wallet, from which the Candidate may withdraw to a local bank account. Daely does not hold User funds in its own accounts at any point in this flow.

Our Payment Processor and Payment Partner process payment, escrow, wallet, and related financial data as controllers or processors under their own terms and privacy notices, including for fraud prevention, sanctions screening, and KYC/AML. Daely receives limited transaction information needed to operate the Platform (such as whether a payout occurred). Daely does not earn revenue from the Daely Wallet, savings, investments, payment transfers, or currency-conversion spreads; you are solely responsible for your own investment decisions and any resulting gains or losses, as described in our Daely Wallet Policy.

5. AI Interviews, AI Outputs, and Biometric Data

AI interviews are central to the Platform. During an AI interview, we capture audio and video and process them to generate a score and assessment (AI Outputs).

1. Purpose and display. We use AI interview data to assess and score Candidates, build Candidate profiles, and help match Candidates with Clients. Your AI interview results and score may be shown on your public Candidate profile and shared with Clients as part of the hiring process.

2. Consent. By starting an AI interview, you consent to the capture and processing of your audio, video, and responses for these purposes. Where audio, video, or derived assessments constitute biometric or other sensitive data under applicable law, we process them on the basis of your consent and only as needed to provide the Platform. You may decline, but you may then be unable to access features that require an AI interview.

3. No sale; limited sharing. We do not sell AI interview data, and we do not share it with third parties for their own profit. We store it in encrypted form and disclose it only to Clients as part of the hiring process and to service providers that help us operate the Platform under confidentiality obligations.

4. AI service providers. To generate AI Outputs and power the AI chat interface, your audio, video, and text responses are processed by our AI service providers, including providers of language-model, speech-to-text, and text-to-speech processing, and may be logged for debugging and quality purposes. As described in Section 8, this data is not used to train third parties' general-purpose AI models.

5. Informational only; no guarantee of outcome. AI Outputs are informational only and do not constitute a hiring decision, an endorsement, or a guarantee of a Candidate's skills, qualifications, suitability, or future performance. Clients make their own hiring decisions, and completion of an AI interview or vetting process does not guarantee engagement success.

6. Automated decisions and human review. If an automated assessment significantly affects you, you may request human review, contest the outcome, and ask for an explanation of how it was generated by contacting us in Section 17.

7. Biometric data retention and destruction. We retain AI interview audio, video, and derived AI Outputs only for as long as necessary to fulfill the purposes described in this Section. Such data will be retained while your account remains active, but in no event for longer than 3 years from your last activity, whichever occurs first. If you delete your account, we will permanently delete your biometric data within 14 days of the deletion request. The only exception is where the data is subject to an ongoing dispute, legal hold, investigation, or other legal obligation, in which case we will retain the data only until the matter is resolved or the legal hold is lifted, after which it will be permanently destroyed using deletion methods designed to prevent recovery. This retention and destruction schedule applies regardless of Daely's continued operation.  

6. Account Integrity, Fraud Prevention, and AML/KYC

To protect Users and the Platform, we and our Payment Processor and Payment Partner process personal data for account-integrity and compliance purposes, including:

• Fraud and abuse prevention — monitoring for fraud, identity misuse, suspicious or unauthorized payment activity, and other abuse of the Platform or the Daely Wallet, which may result in a hold, suspension, or termination of your account.

•  Sanctions and export-control screening — screening Users against applicable sanctions and restricted-party lists.

•  AML/KYC — verifying your identity and, where required, your source of funds, and delaying, suspending, or declining a payment or release of escrowed funds where necessary to complete verification or as required by law.

This processing is carried out on the basis of our legitimate interests in preventing fraud and abuse and complying with legal obligations, and, where required, on the basis of applicable law directly. This data may be shared with our Payment Processor, Payment Partner, and relevant regulators or law enforcement as required.

7. Your Profile and Public Information

Candidate profiles — including portfolio items, service descriptions, and AI Outputs — are visible to Clients and may be publicly accessible. You are responsible for the information you choose to include, and you should not post confidential, unlawful, or explicit content. We do not sell your profile, portfolio, or service data to third parties. Information you make public may be viewed, copied, or retained by others outside our control, and may remain cached or archived after you remove it.

8. How We Share Your Data

We share personal data only as described here:

• With other Users — Candidate profiles and AI Outputs are shared with Clients; relevant engagement details, including meeting recordings and transcripts where applicable, are shared between the Client and Candidate under a contract, including information exchanged to facilitate mediation or a dispute determination under our Terms of Service.

• With our Payment Processor and Payment Partner — to provide payments, escrow, the Daely Wallet, and any savings or investment features, including for fraud prevention and AML/KYC.

• With service providers — hosting, security, verification, AI processing, recording and transcription, and communications providers that process data on our behalf under confidentiality and data-protection obligations. We do not use third-party analytics trackers; the closest processing of this kind is LLM logging for debugging and quality, and usage statistics we compute ourselves internally. hosting, security, verification, and communications providers that process data on our behalf under confidentiality and data-protection obligations. 

• For legal and safety reasons — to comply with law, respond to lawful requests, enforce our terms, and protect the rights, safety, and property of Users, Daely, and others.

• In a business transfer — in connection with a merger, financing, acquisition, or sale of assets, subject to applicable law.

We do not sell your personal data for money, and we do not use AI interview or profile data for third-party advertising or general-purpose AI model training. Where “sale” or “sharing” has a broad meaning under laws such as the CCPA/CPRA, see Section 15 for the applicable disclosures and your opt-out rights.

Google API Services. Daely uses Google in two separate ways, and they request different data.
Signing in with Google. If you sign in with Google, Daely receives only your basic account identity — your email address and basic profile. Signing in gives Daely no access to your Google Calendar, and no calendar data is read or stored.

Connecting your calendar (optional). Separately, you may choose to connect your Google Calendar from Daely's settings or when scheduling an interview. This is a distinct, explicit step with its own Google consent screen, and only then does Daely request the calendar.events scope. Once connected, Daely uses it to create interview events with Google Meet links on your primary calendar, to display your upcoming and past events in the in-app Meetings view, and to work out when you are busy so it does not offer an interview slot that clashes with an existing commitment. You can disconnect at any time, which deletes the stored tokens.

Daely's use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Google Calendar data is never sold, used for advertising, or used to train generalized AI models. OAuth tokens are stored encrypted at rest and are deleted when you disconnect your Google account or delete your Daely account. 

9. Cookies and Similar Technologies

We use a limited set of cookies and similar technologies on the Platform, including to remember certain preferences during video-based features and to support fraud prevention on payment pages. We do not currently use cookies to measure performance, conduct analytics, or serve advertising. You can control cookies through your browser and, where offered, our cookie settings. For details on the cookies we use and your choices, see our Cookie Policy.

10. Your Privacy Rights

Depending on where you live, you may have some or all of the following rights, subject to legal limits:

•  access the personal data we hold about you and obtain a copy; 

• correct inaccurate or incomplete data;

• delete your data (see Section 11) and, where applicable, restrict or object to processing;

• receive your data in a portable format;

• withdraw consent where processing is based on consent (including for AI interviews and biometric data);

• request human review of, contest, and obtain an explanation about significant automated decisions; and

• not be discriminated against for exercising your rights.

To exercise your rights, contact us as set out in Section 17. We may need to verify your identity, and you may use an authorized agent where the law allows. If we decline a request, you may appeal by replying to our response. You may also lodge a complaint with your local data protection authority.

11. Account Deletion and Data Retention

1. You may delete your account at any time through the Platform or by contacting support@daely.ai.

2. If your Daely Wallet has no balance, your account and associated data are deleted, subject to any data we must retain by law or that our Payment Partner retains for its records.

3. If your Daely Wallet holds a balance, you must first withdraw or transfer all funds so the balance is US$0 before deletion can be completed. Our team can help at support@daely.ai.

4. We keep personal data only as long as needed for the purposes in this Policy or as required by law (for example, tax, accounting, KYC/AML, and fraud-prevention records).

See Section 5(g) for the retention schedule specific to AI interview and biometric data. 

12. International Data Transfers

We and our providers may process and store personal data in the United States and other countries whose laws may differ from yours. Where we transfer personal data internationally, we use appropriate safeguards required by applicable law, such as the European Commission's Standard Contractual Clauses (and the UK Addendum) or a valid adequacy or transfer mechanism. Contact us for more information about these safeguards.

13. Security

We use technical and organizational measures designed to protect personal data, including encryption of AI interview data and access controls. No system is completely secure, however, and we cannot guarantee absolute security. If we become aware of a breach affecting your data, we will notify you and regulators as required by law.

14. Children

The Platform is intended for users who are at least 18 years old. We do not knowingly collect personal data from anyone under 18. If you believe a minor has provided us personal data, contact us and we will take appropriate steps to delete it.

15. Region-Specific Disclosures

European Economic Area, United Kingdom, and similar regimes

If you are in these regions, Daely processes your data on the legal bases in Section 3, you have the rights in Section 10, and you may contact our data protection representative (Section 17) or your supervisory authority.

United States (including California)

Depending on your state, you may have rights to know, access, correct, delete, and opt out of “sale” or “sharing” or targeted advertising, and to limit the use of sensitive personal information. Daely does not sell personal data for money. 

16. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will post the updated Policy and update the “Last updated” date, and provide additional notice where required. Your continued use of the Platform after the changes take effect means you accept the updated Policy.

17. Contact Us and Complaints

VisionBrain Inc. (dba Daely)

Privacy contact: support@daely.ai [or a dedicated privacy@daely.ai address]

Address: [Daely mailing/notice address —  8 The Green, Ste R, in the City

of Dover County of Kent Zip Code 19901]