Privacy Policy

1. Data we collect

• Account data — name, email address, authentication identifier from your sign-in provider, and the public blockchain address generated for you.
• Billing data — purchase history, credit balance and transaction records. Card details are handled by our payment processor and are not stored by us.
• Assessment data — the code, text, answers and interaction telemetry you produce during a challenge, together with audio and video captured while it runs.
• Integrity signals — data derived from analysis of the assessment session, such as attention and presence indicators and identity verification outcomes.
• Profile data — anything you choose to publish on your public profile.
• Technical data — IP address, device and browser characteristics, and log data, used for security, fraud prevention and diagnostics.
• Regulatory identity data — only where a financial-compliance check is triggered, our wallet provider may collect a government-issued identity document, proof of address and a selfie. This is separate from the identity check described in Section 3, it is collected and held by that provider rather than by us, and in ordinary use of the Service it does not happen at all.

2. Why we process it, and on what legal basis

• To provide the Service and issue credentials — performance of our contract with you.
• To verify identity and detect fraud or impersonation — our legitimate interest in a credential that means something, and the legitimate interest of those relying on it.
• To take payment and keep accounting records — contract and legal obligation.
• To secure the Service and investigate abuse — legitimate interest.
• To process biometric data — your explicit consent (see Section 3).
• To meet anti-money-laundering and financial-compliance obligations, where a check of that kind is triggered — legal obligation. See Section 1.
• To comply with legal obligations, and to establish, exercise or defend legal claims.

3. Biometric and biometric-derived data

This section describes the most sensitive processing we do. Where the law requires separate, explicit, opt-in consent for it, we ask for that consent before an assessment begins, and you may refuse. Refusing means you cannot take a proctored assessment; it does not affect the rest of your account.

• Identity consistency. Before an assessment begins we run a short camera check. On your first one this creates a face enrolment; on later ones it confirms that a live person is present and that it is the same person. We do not ask for, collect or hold identity documents for this, and we do not attempt to establish your legal identity. The check is carried out by a specialist provider under contract.
• What is kept from that check is a numeric face template held by that provider, and a reference to it. The video is not recorded and the images captured during the check are not retained by us.
• Camera-based proctoring during an assessment — analysis of attention direction or of a second person in frame — is not in use. The integrity signals we currently collect are behavioural, not visual: whether the assessment window lost focus, and whether a large block of text was pasted rather than typed.
• We do not sell biometric data, do not use it for advertising, do not use it to train models for unrelated purposes, and do not disclose it except to the processors described in Section 5 or where compelled by law.
• Biometric identifiers and biometric-derived data are retained only as long as needed for the purpose collected, and in any event no longer than the shorter of the period permitted by applicable biometric privacy law or three (3) years from your last interaction with us, after which they are destroyed.
• You may withdraw biometric consent at any time from your profile settings. Withdrawing deletes the face template held for you and stops future processing. It cannot undo a credential already recorded (see Section 7), and you will not be able to take a spoken assessment again without enrolling anew.

4. Automated evaluation and automated decision-making

Assessments are scored by automated systems, including third-party machine-learning models. The output is a probabilistic estimate, not a determination of fact about you.

We do not use these systems to make decisions producing legal effects concerning you. Any hiring or engagement decision is made by the employer, not by us — employers are independent controllers for their own use of the results.

Where applicable law gives you a right to obtain human review of an automated result, to express your point of view, and to contest it, you may exercise that right by contacting us at the address in Section 14.

5. Who we share data with

We do not sell personal data. We share it with:

• Processors acting on our instructions — cloud hosting, authentication, payment processing, speech transcription, machine-learning inference, identity verification, wallet infrastructure and decentralised storage. Each is bound by contract to protect the data and to process it only for us. They are named individually at meritlink.pro/subprocessors, which is kept current.
• Employers and organisations, where you take an assessment they sent you, or where you choose to make a result visible to them.
• Anyone at all, in respect of what you publish on your public profile, and in respect of the on-chain record described in Section 7.
• Authorities and advisers, where required by law or necessary to establish, exercise or defend legal claims.
• A successor entity, in connection with a merger, acquisition or sale of assets, subject to this policy.

6. International transfers

Our providers operate in several countries, so your data may be transferred outside your country of residence. Where we transfer personal data out of the European Economic Area, the United Kingdom or Switzerland, we rely on an adequacy decision or on Standard Contractual Clauses together with any additional safeguards required.

7. Blockchain records — please read this

When you pass an assessment, a non-transferable token is recorded on a public blockchain and its metadata is pinned to a decentralised storage network. This has consequences that no privacy policy can soften and that we cannot reverse.

• The record is public, permanent and replicated across independent nodes worldwide. We cannot edit or delete it, and neither can you.
• A request to erase your personal data cannot remove an on-chain record. This is a limitation of the technology, not a decision by us. Where erasure is required and technically impossible, we erase what we hold off-chain and publish a revocation on-chain.
• What goes on-chain is limited by design: the skill, the format, the scores, the integrity index, a verification date, the evaluating model, and a link to metadata. Your name, email and identity documents are not written to the blockchain.
• Your blockchain address is pseudonymous, not anonymous. Anyone who links that address to your identity can see every credential attached to it, permanently.
• By taking an assessment you accept these consequences. If they are unacceptable to you, do not take one.

8. Retention

We keep account and billing data for as long as your account exists and thereafter as required for tax, accounting and limitation periods. Assessment media and integrity signals are retained for the period needed to support and defend the credential, subject to the biometric limits in Section 3. Technical logs are kept for a short period for security purposes. On-chain records persist indefinitely, as explained in Section 7.

9. Your rights

Depending on where you live, you may have the right to access your data, correct it, delete it, restrict or object to processing, obtain a portable copy, withdraw consent, and not be discriminated against for exercising these rights. Residents of the European Economic Area and the United Kingdom also have the right to lodge a complaint with a supervisory authority.

Residents of certain US states may have rights to know, delete, correct, and to opt out of sale or sharing of personal data. We do not sell or share personal data as those terms are defined.

To exercise any right, contact privacy@meritlink.pro. We will verify your identity before acting and will respond within the period required by applicable law. Section 7 explains the one limit we cannot overcome.

10. Security

We use encryption in transit, access controls, least-privilege practices and contractual protections with our processors. No system is perfectly secure, and we cannot guarantee absolute security. If a breach affects you and the law requires notification, we will notify you and the relevant authority within the required timeframe.

11. Cookies and similar technologies

We use cookies and local storage that are strictly necessary to sign you in, keep your session, and protect the Service. Where we use anything beyond strictly necessary technologies, we ask for consent first where the law requires it, and you can withdraw it at any time.

12. Children

The Service is not intended for anyone under 18 and we do not knowingly collect their data. If you believe a minor has given us personal data, contact us and we will delete it.

13. Changes to this policy

We may update this policy. Material changes take effect no sooner than thirty (30) days after we post them, and we will notify you where the law requires. The effective date above always reflects the current version.

14. Contact

Urbicode Services LLC — privacy@meritlink.pro for privacy matters, legal@meritlink.pro for legal notices.