PRIVACY POLICY

MILYONUS A.Ş. — Privacy Policy

Effective Date: [30.06.2026] | Last Updated: [30.06.2026] |

Version 1.0

This Privacy Policy explains how Milyonus A.Ş., a company registered in Ankara, Türkiye ("Milyonus," "we," "us," or "the Company"), collects, uses, discloses, stores, and protects personal data in connection with the Milyonus Interviewer AI Agent platform and related services (collectively, the "Service").

Milyonus acts as the data controller for personal data processed through the Service, in accordance with the Turkish Personal Data Protection Law No. 6698 ("KVKK") and, where applicable to data subjects located in the European Economic Area, the General Data Protection Regulation ("GDPR").

1. Data Controller Identity
Company Name: Milyonus A.Ş.

Tax Identification Number: 1090917289

MERSİS Number: 8240203032032324

Registered Address: 153/8 Koza Street, Sev Apartment, Gaziosmanpaşa, Büyükesat District, Çankaya/Ankara, 06640, Türkiye

Email: ayaz@milyonus.com

Phone: +90 530 747 4715

2. Scope
Milyonus provides the Service exclusively to corporate clients ("Client(s)," "Employer(s)") on a business-to-business basis. In providing the Service, Milyonus processes personal data belonging to two categories of individuals:

• Client Users — HR personnel, hiring managers, and other authorized representatives of a Client who access the Milyonus dashboard to plan and review interviews; and

• Candidates — individuals who are invited to, and participate in, an AI-conducted interview through the Service on behalf of a Client.
  
  

3. Personal Data We Collect

3.1 Candidate Data

• Identity and contact information (full name, email address, phone number, and any application/CV information the Client or candidate provides to the platform);

• Application and role information (position applied for, application source, screening answers);

• Interview content: real-time audio and/or video of the interview session, machine-generated transcripts of the conversation;

• AI-generated evaluation data: skill assessments, competency scores, confidence and tone analysis, personality/behavioral insights, and hiring recommendation notes generated by the Milyonus AI Agent;

• Technical data: device/browser information, IP address, and session logs necessary to conduct the online interview;

• Consent records: the timestamped confirmation of the candidate's explicit consent checkbox obtained immediately before each interview session.

3.2 Client User Data

• Account information (name, business email, role, phone number);

• Company information (legal name, address, tax/registration details, billing contact);

• Usage data related to the Client's use of the dashboard and reporting tools;

• Communications with Milyonus, including demo requests and Demo Tracking and Approval Board correspondence.
  
  

4. How We Collect Data
Personal data is collected directly from Candidates (during interview registration and the interview session itself), directly from Client Users (during account setup and platform use), and from Clients who upload candidate contact/application details to schedule interviews.

5. Purposes and Legal Basis for Processing

PurposeLegal Basis (KVKK Art. 5 / GDPR Art. 6)Conducting the AI-driven interview and generating evaluation reports for the ClientExplicit consent of the candidate; performance of the Client's contract with MilyonusDelivering interview results and analytics to the ClientLegitimate interest of the Client in its recruitment process; explicit consentClient account management and billingPerformance of contract with the ClientPlatform security, fraud prevention, and abuse monitoringLegitimate interest of MilyonusCompliance with legal obligationsLegal obligationImproving and training the reliability of AI evaluation modelsExplicit consent (see Section 9)

6. Explicit Consent Mechanism
Before any interview session begins, the candidate must affirmatively check a consent checkbox confirming that they understand and agree the session will be recorded, transcribed, and analyzed by an AI system, and that the resulting data will be shared with the hiring Client. If consent is not given, the interview session will not commence. Milyonus retains a timestamped record of this consent.

7. Recipients and Third-Party Processors
Milyonus shares personal data only to the extent necessary to operate the Service, with the following categories of recipients:

• The hiring Client — receives candidate interview recordings, transcripts, scores, and reports for the role the candidate applied to;

• Sub-processors engaged to operate the technical infrastructure of the Service, currently including:

Sub-processorFunctionOpenAIAI language model processing supporting interview conduct and analysisAnthropicAI language model processing supporting interview conduct and analysisDaily.coReal-time audio/video communication infrastructure for interview sessionsRetell AIVoice AI / conversational infrastructure supporting the interview agentNeon (Neon Database)Managed PostgreSQL database hostingSupabaseBackend-as-a-service platform (database/authentication infrastructure)Amazon Web Services (AWS), United StatesCloud hosting infrastructure

Milyonus requires each sub-processor to maintain appropriate technical and organizational security measures. We do not sell personal data to third parties, and we do not share candidate data with any party other than the relevant hiring Client and the sub-processors listed above.

8. International Data Transfers
Certain sub-processors listed in Section 7 store or process data in the United States, outside of Türkiye and the European Economic Area. Where personal data is transferred abroad, Milyonus relies on the explicit consent of the data subject and/or the appropriate safeguards recognized under KVKK Article 9 and, where applicable, GDPR Chapter V (such as standard contractual clauses maintained by our sub-processors). By using the Service, Candidates and Client Users acknowledge that their data may be processed on servers located outside Türkiye.

9. AI Processing and Automated Decision-Making
The Service uses artificial intelligence to conduct interviews and to generate skill, competency, and behavioral assessments. These AI-generated outputs are provided to the Client as a decision-support tool. Milyonus does not itself make final hiring decisions; hiring decisions remain the sole responsibility of the Client. Candidates may contact the Client or Milyonus to request information about the logic involved in an AI-generated assessment, subject to applicable law.

10. Data Retention
Milyonus retains candidate interview data (recordings, transcripts, and AI-generated reports) for a period of eighteen (18) months from the date of the interview, after which the data is deleted or irreversibly anonymized, unless a longer retention period is required by law, requested by the Client for an active legal or compliance need, or necessary to resolve a dispute. Client User account data is retained for the duration of the commercial relationship and for a reasonable period thereafter as required for legal, accounting, or audit purposes.

11. Data Security
Milyonus implements administrative, technical, and physical safeguards designed to protect personal data against unauthorized access, alteration, disclosure, or destruction, including encrypted data transmission and storage, access controls limiting data access to authorized personnel, and contractual security obligations imposed on sub-processors. No system is completely secure, and Milyonus cannot guarantee absolute security of data transmitted over the internet.

12. Data Subject Rights
Subject to applicable law (including KVKK Article 11 and, where applicable, GDPR Articles 15–22), data subjects have the right to: (a) learn whether their personal data is being processed; (b) request information about such processing; (c) learn the purpose of processing and whether data is used consistently with that purpose; (d) know the third parties to whom data is transferred; (e) request correction of incomplete or inaccurate data; (f) request deletion or destruction of data; (g) object to a result arising solely from automated analysis; and (h) request compensation for damages arising from unlawful processing. Requests may be submitted to ayaz@milyonus.com. We will respond within the timeframes required by applicable law.

13. Children's Data
The Service is intended for use by individuals who are at least the minimum legal working age in their jurisdiction and are participating in a bona fide employment recruitment process. Milyonus does not knowingly process data relating to children unrelated to a legitimate job application.

14. Changes to This Policy
Milyonus may update this Privacy Policy from time to time to reflect changes to the Service, our data practices, or applicable law. Material changes will be communicated to Clients and, where feasible, to Candidates prior to their next use of the Service. The "Last Updated" date above indicates when this policy was last revised.

15. Contact


Milyonus A.Ş.
153/8 Koza Street, Sev Apartment, Gaziosmanpaşa, Büyükesat District, Çankaya/Ankara, 06640, Türkiye

Email: ayaz@milyonus.com

Phone: +90 530 747 4715