TeamFill Privacy Policy

Last Updated 2025-11-17

Version 1.0

Notice for U.S. Users
This Privacy Policy applies only to individuals and organizations located in the European Economic Area (EEA), the United Kingdom, and Switzerland.

If you are located in the United States, please review our U.S. Privacy Notice, which explains how TeamFill processes personal data in accordance with applicable U.S. privacy laws, including state-level laws such as the California Consumer Privacy Act (CCPA/CPRA).

1. Who is this Privacy Policy for?

This privacy policy (hereinafter referred to as the "Privacy Policy") is intended to inform data subjects, including TeamFill Clients, Users, suppliers, partners, and Applicants, about the processing and protecting of personal data by TeamFill UAB (“we,” “us,”, “our”, “Company”), the operator of the TeamFill platform. The Policy provides a detailed overview of how we handle data within the TeamFill platform and outlines the responsibilities of all parties involved, including TeamFill UAB, Clients, and Users, in compliance with applicable privacy laws. Any person whose personal data we process is referred to in this Privacy Policy as a Data Subject.

The TeamFill platform is intended for individuals aged 18 years or older. We do not knowingly collect data from anyone under 18.

Our primary role is as a data processor, handling data solely on behalf of our Clients, who serve as data controllers. This means that our Clients determine the purposes and means of processing personal data within TeamFill. We, as a processor, operate under the instructions of our Clients and do not independently access, control, or use Client data beyond the requirements necessary to deliver our service.

Our role as a data controller applies to specific activities, such as managing user accounts, providing technical support, and enhancing platform functionality. In these cases, we determine the purposes and means of processing personal data independently to ensure secure and efficient service delivery. As the data controller, we are responsible for safeguarding this data in compliance with applicable privacy laws and ensuring transparency in how we process and use user information.

When processing personal data, the Company is guided by Regulation (EU) No 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (GDPR), the Law on Legal Protection of Personal Data of the Republic of Lithuania, the Law on Electronic Communications of the Republic of Lithuania, and other legal acts regulating personal data protection.

Below you can find out how we process your personal data: what personal data we process, what are the purposes for such processing, how long we keep it and what rights Data Subjects have.

2. About the Company

TeamFill, UAB (the “Company”), operates the TeamFill SaaS platform, specializing in recruitment services. Our legal entity code is 304522511, with a registered office at Partizanų g. 61-806, Kaunas, Republic of Lithuania. For any inquiries related to data protection, including exercising your rights as outlined in this Privacy Policy, please contact us via email at legal@teamfill.net.

3. Definitions

"Personal Data" refers to any information about a Data Subject that can identify them directly or indirectly and that is collected, stored, or otherwise processed electronically or in other formats. Examples of Personal Data include, but are not limited to, a Data Subject’s name, surname, address, email address, contact information, and other identifiers that may be collected to fulfill the purposes outlined in this Privacy Policy or in the Data Subject's specific consent or agreement with the Company.

“Applicant” means an individual who applies for a position through the provider platform and participates in the video interview process.

“AI / Artificial Intelligence” means a computer system designed to simulate human reasoning and generate output based on input data, such as converting audio (speech) to text for human review.

“User” means any person who accesses or interacts with the provider Platform, including Clients and their representatives.

“Client” means an organization that uses the provider Platform to screen, evaluate, or manage Applicants.

4. Processing Applicant Data through the TeamFill Platform

The Company has developed a smart video interview platform for Applicant screening and shortlisting. When interviewing is conducted by our Clients using the TeamFill platform, TeamFill UABacts solely as a data processor. In these cases, Clients are responsible for providing adequate information to Applicants regarding the processing of their personal data, as they function as the data controllers.

When the initial job interview is conducted via the TeamFill platform, TeamFill can act as AI Notetaker or as AI Interviewer. If TeamFill acts as a AI Interviewer, no human recruiters are involved in the job interview. 

The TeamFill platform uses artificial intelligence (AI), specifically OpenAI’s GPT model, to analyse the text transcript of your answers. The AI provides transcription citations and summaries; and every interview is reviewed by a human recruiter, who makes all hiring decisions. Due to this, TeamFill Platform is not classified as a ‘high‑risk AI system’ under the EU AI Act (Reg. 2024/1689, Annex III).

By clicking ‘Start Interview,’ you give your consent (GDPR Art. 6(1)(a)) for the recording and transcription (speech-to-text) of your interview for human review. If you do not wish to provide this consent, please close the interview window; no recording will begin.

Here you can find a simplified explanation on how TeamFill works: 

• the Applicant answers the questions during the video interview;

• the Applicant's video job interview is recorded

• the audio is converted into text using the OpenAI API;

• Interview text is summarized and citations from the text are extracted to help a human recruitment specialist to make a decision

• the interview is reviewed and evaluated by the recruitment specialist.

Please note that we use AI to convert audio (speech) to text, therefore, we recommend that you speak as clearly as possible during the job interview. This will help you avoid situations where unclear speech leads to inaccurate speech-to-text conversion.

The table below provides detailed information on the processing of Applicants' personal data on the TeamFill platform:

1. Purpose: to remind Applicants that they started but haven't completed an interview on the TeamFill platform

2. Purpose: screening of Applicants via the TeamFill platform

5. International Transfers

Some personal data is transferred to service providers in the United States (e.g., OpenAI, Amazon Web Services, SendGrid). All such transfers are under (i) the EU–U.S. Data Privacy Framework certification of the recipient or (ii) the European Commission’s 2021 Standard Contractual Clauses (SCCs), plus a transfer‑impact assessment. A live list of subprocessors and their transfer mechanisms is available at TeamFill Data Processing Agreement's Annex III.

6. Personal data of the Clients of TeamFill

When you create a Client account on the TeamFill platform, we, as the data controller, process your personal data as described in the table below. We also collect certain information about your use of the platform for the purposes of ensuring and improving the functionality of the platform. For more information on this, please refer to the Cookies and other tracking technologies section of the Privacy Policy.

We are not the controller of the personal data that you yourself process through the TeamFill platform (personal data of Applicants participating in the selection process, etc.). You are the controller of this personal data and we act as your data processor. If you wish to enter into an agreement with us regarding the processing of your personal data, please contact us at the email address indicated in the Section 2.

Purpose: creating and managing a TeamFill account

7. Processing related to conclusion and performance of contracts 

Purpose: to conclude and perform contracts with Clients, suppliers, partners and other individuals

Purpose: to conclude and perform contracts with Clients, suppliers, partners and other legal entities

Purpose: protecting rights and legitimate interests of the Company

8. Direct marketing (sales promotion)

We send direct marketing communications to recipients who have given their consent to direct marketing. For the purpose of sending direct marketing communications, we process the following personal data: name of the organization, position, email address, telephone number, content and dates of the messages sent. Your data will be processed for the purpose of sending direct marketing communications for 2 years from the date of consent. Direct marketing communications are sent (your contact details are processed) on the basis of consent.

If you are our client and you did not object to direct marketing of our goods or services similar to the services you have purchased at the time of ordering the services (at the time of entering into the contract), we may send direct marketing communications to the email address specified in the contract on the basis of our legitimate interest. In this case, direct marketing communications will be sent to the email address specified in the contract for the duration of the contract and for 1 year after its termination, unless you object to the further processing of the data for the purpose of direct marketing before that time. In this case, we will immediately stop sending you direct marketing communications.

Personal data processed for the purpose of direct marketing shall be transferred to the processors necessary to carry out direct marketing.

You have the right to opt-out of receiving direct marketing communications at any time by contacting us at the email address support@teamfill.net.

9. Protecting confidential information of the Company and ensuring business continuity

The Company may review its employees' correspondence with contractors in order to protect the Company's confidential information and ensuring the continuity of the Company's business in its legitimate interest. For these purposes, the Company processes the following personal data of its employees and of persons who send or receive employee communications: e-mail address, name of the sender or recipient, date, and content of information contained in electronic work tools. Such data shall be kept for 4 years.

10. Defending our rights and legitimate interests

The Company will, on the basis of its legitimate interest to defend its rights, including in the event of civil disputes, process the names, surnames, personal identification numbers, case background, other information related to the case, and publicly available information of the persons involved in the case or of their employees. The data may be communicated to law enforcement authorities, lawyers or bailiffs for the purpose of debt collection. The data shall be destroyed 1 year after the final settlement of the case and the full satisfaction of the Company's claims (if satisfied).

11. Archiving

We continue to store contracts for goods, works, services, and acts of acceptance of goods, works and services for archiving purposes (10 years after the end of the contract), when they are no longer needed for the original purpose (in the general sense of concluding and performing the contract). We process personal data for this purpose in order to comply with a legal obligation (Article 6(1)(c) GDPR), as set out in point 10.37 of the General Index of Document Retention Periods approved by Order No V-100 of the Archivist of the Republic of Lithuania dated 9 March 2011.

12. Contact us

There are several ways you can contact the Company: by phone, email, social media accounts or by sending a letter to the Company's registered office address. All communications are received, reviewed and responded to by us. If you contact us, we may process the data you provide to us, i.e. email address, name (if provided), username (if the request is sent via a social networking account), workplace (if provided), date, time, recipient, sender (if the message is addressed to you), content of the messages sent and received.

Such data will be processed in order to answer your questions and process your suggestions. If you do not provide your contact details, it will not be possible to contact you.

Correspondence is stored for 1 year from the date of receipt of the message, except for information for which other time limits are specified in the Privacy Policy or in legal acts.

Any personal data you provide when you interact with us is only used for the purposes set out above and to view messages and administer and manage communication flows. We undertake not to use your personal data in any publications in a way that could identify you without your explicit consent.

Please note that we may need to contact you by post, email or telephone. Please notify us of any changes to your personal data.

13. Cookies and other tracking technologies

Our websites use cookies and other tracking technologies. A cookie is a small file made up of letters and numbers that we place on your browser or on the hard drive of your computer with your consent. We use different cookies for different purposes.

Cookies also help us to distinguish you from other users of the Website, thus ensuring a more pleasant experience and enabling us to improve the Website.

Most browsers allow you to reject all cookies, and some browsers only allow you to reject third party cookies. You can therefore take advantage of these options. However, please note that blocking all cookies will have a negative impact on the use of the Website and without cookies you will not be able to use all the services provided on the Website. Further information is available at AllAboutCookies.org or www.google.com/privacy_ads.html.

We may use the types of cookies described below, but for a detailed and up-to-date list of the cookies used on this website, please visit "Cookie list" paragraph in this section.

Strictly Necessary Cookies. These cookies are absolutely necessary for our website to work. The basis for the use of such cookies is Article 73(4) of the Law on Electronic Communications of the Republic of Lithuania. These cookies are necessary for the operation of the website and cannot be disabled on our systems. They are usually used in response to what you do on the website, such as starting to browse or selecting your privacy settings. These cookies do not store any personally identifiable information about you and are deleted as soon as you turn off the website.

Analytics and/or Performance Cookies. These cookies allow us to count the number of visits to the website and to monitor the flow of visitors so that we can improve the website. They allow us to know which pages of the website are the most or least visited and to monitor how visitors navigate through the website. The data collected is not accessible to any other party. The information collected by cookies is anonymous and is not intended to identify you or to influence your browsing experience while you are on the website. If you do not consent to the use of these cookies, you will not be recorded in the visit statistics. The processing of data collected by these cookies is based on your consent.

Commercial / Advertising Cookies. These cookies, used by us and third parties, are designed to show you offers or other promotional information that may be of interest to you. We use cookies that collect data about your browsing history and identify your areas of interest so that we can show you relevant marketing information. The processing of data collected by these cookies is based on your consent.

Cookie list

14. Managing our social media accounts

The information you provide to us via social media (including messages, the use of the "Like" and "Follow" buttons, and other communications) is controlled by the operator of the social network.

Our websites may provide links to our social media accounts ("Social Accounts"). We currently administer the following Social Accounts:

• TeamFill account on LinkedIn;

We process the information contained in social accounts for the purpose of administering the accounts on the basis of your consent. We do not separately store the information contained in the Social Accounts (where the data is processed for the purpose of administering the Social Accounts, but the data may be stored if it is necessary to process the data for another purpose, such as for the purpose of enforcing rights).

When you visit Social Accounts, social network administrators place cookies on your device that collect personal data. Cookies are stored both if you are a registered user of a social network and if you do not have an account with the relevant social network. We do not have access to the personal data collected about you and can only obtain statistical information from the administrators of the social networks about the traffic of the Social Accounts.

We recommend that you read the privacy notices of third parties and contact the service providers directly if you have any questions about how they use your personal data.

15. Receipt and disclosure of data

We receive your data from you, our employees and service providers, our contractors or generate it from software (for example, Applicant assessments provided by TeamFill).

Your personal data may be transferred to our data processors, such as IT or cloud service companies (e.g. when we rent servers from an IT company, your personal data will be physically hosted (stored) with that IT company). We require our data processors to ensure adequate protection of your data and ensure that they process your personal data only for the purposes for which we have instructed them to do so and only under our written instructions.

Personal data may also be transferred to recipients who act as data controllers (separately or jointly with us). For example, social network operators, banks, payment service providerss (for payments for paid services), etc.

If you have any questions about our service providers, please contact us at the email address listed in Section 2.

In addition to the specific recipients of the data identified in this Privacy Policy, we may also disclose information about you:

• if we are required to do so by law (e.g. by a court or law enforcement authority);

• when we intend to sell the business or part of its assets by disclosing your personal data to a potential buyer of the business or part of the business;

• the sale of the Company's business or a substantial part of its assets to a third party.

• where necessary to protect our rights and legitimate interests.

Except as provided in this Privacy Policy, we do not provide your personal data to any third parties.

16. Security of your personal data

Your personal data will be processed in accordance with the General Data Protection Regulation, the Law on Legal Protection of Personal Data of the Republic of Lithuania and other legal requirements. When processing your personal data, we implement organisational and technical measures to ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure, as well as against any other unlawful processing.

17. Your rights

In this section, we provide information about your rights in relation to our processing of your personal data and when you can exercise these rights. If you would like more information about your rights or to exercise them, please contact us at the email address listed in Section 2.

The Company will provide you with information on the action taken following your request for the exercise of your rights without undue delay, but at the latest within one (1) month of receipt of the request. Depending on the complexity of the request and the number of requests received, the aforementioned time limit may be extended for a further 2 (two) months. In this case, we will inform you within 1 (one) month of receipt of the request of such extension and the reasons for it. The company will only refuse to exercise your rights in cases provided for by law.

For candidate interviews, you may also request a human re‑assessment of any AI‑assisted outcome.

18. Right of access to your personal data

We want you to fully understand how we use your personal data so that you do not experience any inconvenience. You can contact us at any time to enquire whether we are processing any of your personal data. If we store or use your personal data in any way, you have the right to access it. To do so, please submit a written request to us at the email address listed in Section2, confirm your identity; and observe the principles of fairness and reasonableness when making such a request.

18.1 Right to withdraw consent. If you have given us your explicit consent to the processing of your data, you can withdraw it at any time. Withdrawal of consent does not affect the lawfulness of consent-based processing carried out before the withdrawal of consent.

18.2 Additional rights. Below you will find information about additional rights that you may have, which you can exercise by following the procedures described below:

1. You have the right to ask us to correct any inaccuracies in the data we hold. In this case, we may ask you to confirm the corrected information.

2. You have the right to ask us to delete your personal data. This right shall be exercised in the cases provided for in Article 17 of the General Data Protection Regulation (EU) 2016/679.

3. You have the right to ask us to restrict or not to process your personal data:

• the period of time necessary to verify the accuracy of your personal data when you make a complaint about the accuracy of the data;

• where our collection, storage or use of your personal data is unlawful, but you choose not to request erasure;

• where we no longer need your personal data, but you need it to establish, exercise or defend a legal claim;

• the period necessary to determine whether we have an overriding legal basis to continue processing your personal data if you have exercised your right to object to the processing of personal data.

4. You have the right to the transfer of data processed by automated means which we have received from you in a structured, commonly used and computer-readable format with your consent or for the purposes of concluding a contract (right to data portability). If you exercise this right, we will, at your request, transfer a copy of the data provided by you to you or to a data controller of your choice.

5. You have the right to object to our use of your personal data in accordance with Article 21 of the GDPR. You have the right to object when your personal data is processed on the basis of legitimate interest (for each of the above purposes of processing, it is indicated on which basis the data is processed) or for direct marketing purposes.

18.3 Right to request more information. We hope that you will understand that it is very difficult to discuss all possible ways of collecting and using personal data. We do our best to provide as clear and complete information as possible and we undertake to update this Privacy Policy if the process of using personal data changes. However, if you have any questions about our use of your personal data, we will be happy to answer them or provide you with any additional information we may disclose. If you have any specific questions or do not understand the information provided, please contact us at email listed in Section 2.

19. Complaints

If you believe that your rights as a data subject have been and/or may be violated, please contact us immediately at the email address listed in Section 2. We ensure that only upon receipt of your complaint, we will contact you within a reasonable period of time to inform you of the progress of the investigation and, subsequently, the outcome of the complaint.

If you are not satisfied with the results of the investigation, you can lodge a complaint with the supervisory authority, the State Data Protection Inspectorate: https://vdai.lrv.lt/.

20. Responsibility

You are responsible for maintaining the confidentiality of the data you provide to us and for ensuring that the data you provide to us is accurate, correct and complete. If there is any change in the data you have provided, you must inform us immediately by e-mail. In no event shall we be liable for any damage caused to you as a result of your providing incorrect or incomplete personal data or your failure to inform us of any change in the data.

21. Changes to the Privacy Policy

We may update or change this Privacy Policy at any time. If you would like to receive an updated Privacy Policy, please notify us at the email address listed in Section 2.