Mokka | Privacy Policy for Applicants

Last Updated: January 27, 2026

Introduction

Welcome to Mokka. "Mokka," "we," "our," or "us" refers to Mokka Labs Ltd. and its affiliates. We are committed to protecting your personal information and your right to privacy. This Privacy Policy outlines how we collect, use, disclose, and safeguard your information in compliance with applicable data protection regulations, including the General Data Protection Regulation (GDPR) for users in the European Economic Area (EEA) and relevant privacy laws for users in other jurisdictions, such as the United States. By using our services and accepting this Privacy Policy, you agree to the collection and use of information as described in this Privacy Policy. Users in certain jurisdictions may have specific rights and protections, as detailed below.

1. Information We Collect and Lawful Basis for Processing

• Personal Identification Information (e.g., name, email, social media profiles): Processed based on consent, contractual necessity, or legitimate interest, as required under applicable law.
• Employment-Related Information (e.g., employment history, CVs, qualifications): Processed with your consent and/or legitimate interest to assess candidates on behalf of hiring companies. Candidates are advised not to include sensitive data as defined under GDPR Article 9 (e.g., data revealing racial or ethnic origin, political opinions, religious beliefs, health data, etc.) unless required for legal or hiring purposes. By accepting this Privacy Policy, you explicitly consent to the processing of any special category data you may provide inadvertently.
• Technical Data (e.g., IP address, browser type): Processed to maintain service security and functionality. If you are in the EEA, we process this data under our legitimate interest in providing secure services.
• Video and Audio Recordings: Collected and processed with your explicit consent, particularly if you use our voice or video recording features. Audio is converted to text for assessment and not stored in its original form. Video is retained as per business needs or legal requirements.
• Cookies and Tracking Technologies: We use cookies to track your activity on our service. For users in the EEA, non-essential cookies are only used with your consent.

2. How We Use Your Information

• For Candidate Assessment: Information is used to support recruitment decisions by hiring companies. Any special category data inadvertently provided will be disregarded unless necessary for the hiring process, as determined by hiring companies, and subject to your explicit consent.
• To Provide and Operate Services: Information is used for user authentication and service access.
• To Improve and Personalize Services: We analyze data to improve service quality and personalization.
• To Communicate with You: We may send you system-related emails, such as invitations to complete assessments and reminders to finish assessments. By using our services, you consent to these emails. You can manage communication preferences by contacting us or using opt-out instructions in emails.

3. Sharing Your Information We do not share your personal information with third parties except as described here:

• Third-Party Vendors and Subprocessors: We may share your information with trusted vendors, service providers, and subprocessors who assist in providing and improving our services. These parties are contractually obligated to adhere to data protection laws and standards. We do not share your personal information with AI model providers for training their models. The full list of sub-processors is available via our Trust Center: https://trust.gomokka.com/subprocessors
• Legal Compliance: We may share your information where required by law or to protect our legal rights.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred as part of that process.
• International Data Transfers: We process and store data in jurisdictions that may have different data protection standards. For transfers outside the EEA, we use Standard Contractual Clauses or other legally recognized safeguards to protect your information.

4. User Rights and Controls Depending on your location, you may have certain rights regarding your personal information:

• Access, Correction, and Deletion: You may request access to, correction, or deletion of your data.
• Data Portability (GDPR): If you are in the EEA, you may request your data in a structured format for transfer.
• Withdrawal of Consent: You may withdraw consent at any time without affecting prior lawful processing.
• Objection and Restriction (GDPR): EEA users may object to or restrict certain processing activities. To exercise these rights, you can contact us via:
• Email: privacy@gomokka.com
• In-app chat support: Available via the chat widget on our website or within the application

We respond within timeframes required by your jurisdiction's regulations.

5. Data Retention

Mokka acts as a data processor on behalf of hiring companies (data controllers) who use our platform to evaluate candidates. As a processor, we retain your data in accordance with our customers' instructions and their configured retention settings.

Retention principles:

• Employment-Related Data: Retained for as long as the hiring company maintains an active account with us and in accordance with their retention policies. When our relationship with a customer ends, associated candidate data is handled in accordance with our agreement with them.
• Technical Data: Retained for the duration necessary for service security, functionality, and legal compliance purposes, typically aligned with your account retention.
• Video and Audio Data: Retained according to customer settings and applicable business or legal requirements.

Your rights: If you wish to have your data deleted, you may:

• Contact the hiring company directly (as the data controller, they can instruct us to delete your data)
• Contact us at privacy@gomokka.com, and we will coordinate with the relevant customer

Upon receiving a valid deletion request, we will delete or anonymize your data within 30 days in accordance with GDPR Article 17.

• Zero Data Retention (ZDR): Mokka does not store your data on any external AI model provider's servers after processing. Any data processed by third-party AI model services is used strictly for real-time inference and is not retained by those services.

6. Mokka Talent Network

The Mokka Talent Network is a service where we retain your profile and may recommend you for suitable opportunities at other companies using our platform.

What is the Talent Network? When you join the Talent Network, we may share your profile with hiring companies using Mokka when we identify a potential match. This allows you to be considered for opportunities beyond your initial application.

How you may join the Talent Network:

• When applying to a specific company's role: If you apply to a role posted by a hiring company, joining the Talent Network is optional. You may be offered a separate checkbox to opt in. You can apply for the role without joining the network.

• When applying through Mokka's sourcing service: If Mokka identified you as a potential candidate (e.g., through job boards or talent databases) and invited you to apply, joining the Talent Network is part of the service. By applying through Mokka's sourcing service, you agree to join the Talent Network as described in this policy.

Our role: For Talent Network data, Mokka acts as a data controller (not just a processor). This means we independently determine how your data is used within the Talent Network.

Your control:

• Opt out anytime: You can withdraw from the Talent Network at any time by contacting us at privacy@gomokka.com or via in-app chat support.
• Deletion: Upon withdrawal, your Talent Network profile will be deleted within 30 days. This does not affect any active applications you have with specific hiring companies.

Data retention for Talent Network: Your Talent Network profile is retained until you withdraw consent or request deletion. We may periodically contact you to confirm you wish to remain in the network.

7. Cookies and Similar Technologies We use cookies to monitor activity and enhance user experience. Types include:

• Essential Cookies: Necessary for basic service functionality.
• Analytical Cookies: Help us improve performance based on user behavior. For EEA users, non-essential cookies are used only with your consent. You can manage cookie preferences via your browser settings or, if applicable, an opt-in mechanism on our website.

8. Security of Your Information We implement appropriate technical and organizational security measures, such as encryption and access controls, to protect personal information from unauthorized access, use, or disclosure. Security practices are aligned with industry standards but may differ based on regional requirements.

9. Automated Decision-Making and Profiling Our candidate assessment services use artificial intelligence (AI), including third-party large language models (LLMs), to assist in evaluating candidate-provided responses and structured data. These systems may perform automated processing or profiling based on your skills, qualifications, job responsibilities, and past performance indicators. This processing is designed to support recruiters in making more consistent and fair hiring decisions. All AI outputs are used as decision support only – final hiring decisions remain with human reviewers. For users in the European Economic Area (EEA), you have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects. Where applicable, a human reviewer will always be involved in reviewing AI-generated insights. Please note: While we may support video or audio input during assessments, only transcribed text is analyzed. We do not process biometric, facial, or emotional data.

10. Minimum Age Requirement Our services are intended for users who are of legal working age in their jurisdiction. We do not knowingly collect personal information from individuals below the legal working age applicable in their region. If we learn we have inadvertently collected such information, we will delete it.

11. Changes to This Privacy Policy We may update this policy periodically. Any changes will be posted here with an updated effective date. Where appropriate, we will notify you of significant changes via email or a service notification.

12. Additional Information for US Users

Data Sources for Active Applicants When you apply for a role, submit your resume, or complete a pre-screening interview, we evaluate you based on information you provide—including your resume, application answers, interview responses, and any professional profile URLs you include (such as LinkedIn, GitHub, or portfolio sites). When you provide profile URLs, we may use third-party services to access and parse that profile data on your behalf.

Data Sources for Sourced Candidates We partner with third-party talent database providers to identify potential candidates for open roles. These providers supply candidate information which may include contact details, work history, and professional profile links. We may evaluate this information to determine fit before reaching out to you.

Company Research We use public business data (company size, funding stage, industry) from sources like Crunchbase and LinkedIn company pages to understand the context of your work history. This is company information, not personal profile data.

What We Don't Do We do not independently scrape or compile personal profiles from the web. For active applicants, we use information you provide (including profile URLs you share). For sourced candidates, we use information provided by established talent database providers.

Accuracy and Disputes If you believe any information about you is inaccurate, or wish to understand what data we have about you, contact us at privacy@gomokka.com.

Contact Us If you have questions about this Privacy Policy or wish to exercise privacy rights, please contact us at:Email: privacy@gomokka.com Company Details Mokka Labs LimitedAddress: 28 October Avenue 367, Mediterranean Court, 1st Floor, Office A5, Limassol, Cyprus, 3107