Mokka | Privacy Policy for Applicants

Last Updated: March 1, 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, phone number, 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 and SMS/text messages, such as invitations to complete assessments and reminders to finish assessments. By using our services, you consent to these communications. SMS/text messages are delivered by Mokka on behalf of the hiring company to the phone number you provided during your application. By voluntarily providing your phone number during the application process, you consent to receive assessment-related SMS notifications from the hiring company via Mokka. Message frequency varies; typically 1-3 messages per assessment. You can opt out of SMS communications at any time by replying STOP to any text message, or by contacting us at privacy@gomokka.com. Standard message and data rates may apply. You can manage other 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, including SMS/text message delivery providers for sending assessment-related notifications on behalf of hiring companies. 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.

• AI Decision Records: Mokka retains system-level documentation — including bias audit methodology, aggregate scoring statistics, and technical system documentation — to support regulatory compliance and bias auditing. This system-level documentation does not contain individual candidate personal data. Individual candidate scoring records are retained in accordance with the hiring company's instructions and retention settings. When a hiring company requests deletion of candidate data (or upon termination of our agreement), Mokka deletes candidate-level records in accordance with our data processing agreement. Hiring companies are responsible for independently retaining any AI decision records required by their jurisdiction (such as the four-year minimum under California FEHA) by exporting data before deletion.

• SMS Delivery Records: Records of SMS communications (phone number, delivery status, timestamps) are retained for the duration of the associated application record and deleted in accordance with the hiring company's retention settings.

• 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

9.1 How Our AI Assessment Works

Our candidate assessment services use artificial intelligence (AI), including third-party large language models (LLMs), to evaluate candidate-provided responses and structured data. This section describes how these systems work, what they assess, and your rights.

What the AI evaluates: The AI system scores your fit against job requirements by analyzing: (a) your resume, work history, and qualifications; (b) written responses to job-specific questions; (c) transcribed text from video or audio interviews, if applicable; (d) professional profile URLs you provide (e.g., LinkedIn, GitHub, portfolio sites); and (e) public company information (size, industry, funding stage) to contextualize your work history. The system assesses skills, qualifications, relevant experience, accomplishments, cultural alignment based on your professional background, and alignment with the role's requirements. Hiring companies may also configure custom interview segments to assess role-relevant competencies.

What the AI does not evaluate: The AI does not assess physical appearance, tone of voice, facial expressions, or other behavioral or biometric indicators. It does not use biometric data, emotion detection, or facial recognition. When video or audio input is used during assessments, only the transcribed text is analyzed.

How scores are used: The AI generates a compatibility score that helps recruiters prioritize candidates for review. This score is one input among many. A human recruiter reviews your full profile before any hiring decision is made. AI scores alone do not determine your candidacy.

9.2 Human Oversight

All AI outputs are used as decision support only — final hiring decisions remain with human reviewers. Human reviewers examine the AI's scoring alongside your original application materials and exercise independent judgment. Reviewers retain full authority to accept candidates with lower AI scores or advance candidates the AI did not prioritize, based on role requirements and professional judgment.

9.3 Your Rights Regarding AI Decisions

Depending on your location, you have the following rights regarding automated processing of your application. Because Mokka acts as a data processor on behalf of hiring companies, the hiring company that posted the role is the primary point of contact for most candidate rights requests.

If you applied to a role posted by a hiring company:

• Right to explanation: You may request an explanation of the AI assessment from the hiring company that posted the role. The hiring company, as the data controller, is responsible for providing this information. Mokka provides technical support to hiring companies so they can explain how our AI scoring methodology works.

• Right to human review: You may request that the hiring company arrange for a human reviewer to manually assess your application. Direct this request to the hiring company.

• Right to an alternative selection process: If you prefer not to be evaluated by an automated employment decision tool, you may request an alternative selection process from the hiring company before completing your application.

• Right not to be subject to solely automated decisions (EEA): For users in the European Economic Area, 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. A human reviewer is always involved in reviewing AI-generated insights before consequential decisions are made.

If you are unsure how to contact the hiring company, or if the hiring company does not respond, email privacy@gomokka.com and we will coordinate with them on your behalf.

If you were sourced by Mokka (Talent Network or recruitment services):

For candidates identified and pre-screened by Mokka directly, Mokka acts as a data controller. You may direct requests for explanation, human review, or alternative selection processes to privacy@gomokka.com. We will respond within the timeframes required by your jurisdiction's regulations.

9.4 Bias Auditing and Fairness

Mokka is independently audited for bias by Fair AI and Business Certification (FABC). We conduct regular audits to identify and mitigate potential disparate impact based on protected characteristics. Bias audit summary results are available through our Trust Center at https://trust.gomokka.com/. We do not use zip codes, postal codes, or geographic residence as variables in AI scoring decisions, and we do not use any proxy variables that correlate with protected characteristics such as race, gender, age, or disability.

9.5 Video and Audio Interview Processing

If you participate in a video or audio interview:

• What is analyzed: Only the transcribed text of your spoken responses is analyzed by the AI system. The AI evaluates the content of your answers against job requirements.
• What is not analyzed: We do not analyze tone of voice, facial expressions, eye contact, body language, or other behavioral or biometric indicators.
• Accessibility: If you have a disability or condition that makes video or audio assessment difficult, you may request an alternative assessment format. For roles posted by a hiring company, contact the hiring company directly. If you are unsure how to reach them, email privacy@gomokka.com and we will coordinate with the hiring company on your behalf. For candidates sourced by Mokka directly, email privacy@gomokka.com with "Accessibility Request."

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.

California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:

• Right to know: You may request the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collection, and the categories of third parties with whom we share your information.
• Right to delete: You may request deletion of your personal information, subject to certain exceptions.
• Right to correct: You may request correction of inaccurate personal information.
• Right to opt-out of sale/sharing: We do not sell your personal information or share it for cross-context behavioral advertising.
• Right to limit use of sensitive personal information: We use employment-related information only for the purposes disclosed in this Privacy Policy and do not use or disclose it beyond what is necessary to provide the service.
• Non-discrimination: We will not discriminate against you for exercising your privacy rights.

The categories of personal information we collect, the purposes for collection, and the categories of third parties with whom we share information are described in Sections 1, 2, and 3 of this Privacy Policy. To exercise your rights, contact us at privacy@gomokka.com. You may also designate an authorized agent to make requests on your behalf.

13. Jurisdiction-Specific AI Notices

The following notices apply based on your location and supplement Section 9 above.

New York City Residents — Automated Employment Decision Tool (AEDT) Notice

Mokka uses an automated employment decision tool (AEDT) to assist in evaluating candidates for employment opportunities. This tool analyzes your resume, application responses, and interview transcripts to score your fit against job requirements. It assesses qualifications, relevant experience, skills, accomplishments, and cultural alignment. The data sources for this evaluation include information you provide during the application process and any professional profile URLs you submit. Mokka retains AEDT data in accordance with Section 5 of this Privacy Policy. An independent bias audit of this tool has been conducted by Fair AI and Business Certification (FABC), and summary results are available at https://trust.gomokka.com/. If you would like to request an alternative selection process not reliant on the AEDT, contact the hiring company directly. If you are unsure how to reach them, email privacy@gomokka.com and we will coordinate on your behalf.

Illinois Residents — AI Video Interview Act (AIVIA), as amended by HB 3773

Mokka uses AI to assist in evaluating candidates for employment opportunities, including analyzing your resume, application responses, and interview transcripts. If you participate in a video interview, the AI analyzes only the transcribed text of your responses — it does not analyze facial expressions, emotional states, tone of voice, or biometric data. Before your application is evaluated by AI, you will be informed and your continued participation constitutes consent. If you prefer not to be evaluated by AI, contact the hiring company to request an alternative assessment method. Mokka does not use zip codes or geographic residence as scoring variables, and we regularly audit our AI systems to ensure no proxy variables create disparate impact based on protected characteristics.

Colorado Residents — Colorado AI Act (SB 24-205)

In addition to the rights described in Section 9.3 above, Mokka uses AI systems to make or support consequential decisions related to your employment opportunities. You have the right to appeal or contest an AI-assisted employment decision. To exercise this right, contact the hiring company directly. If you need assistance, email privacy@gomokka.com and we will coordinate with them. Mokka maintains documented standards of reasonable care for its AI systems, including regular bias testing and performance monitoring.

California Residents — Fair Employment and Housing Act (FEHA) Automated Decision Systems

In addition to the rights described in Section 9.3 above, you have the right to correct inaccurate data used in your evaluation. To exercise this right, contact the hiring company. Under California law, the hiring company is required to retain AI decision records for a minimum of four (4) years. Mokka provides data export capabilities to support hiring companies in meeting this obligation. Mokka retains system-level documentation (bias audit results, technical documentation) independently of individual candidate data (see Section 5).

Utah Residents — Utah AI Policy Act

When AI assists in screening or evaluating your application, you are entitled to know that an AI system is being used and how it contributed to the evaluation of your candidacy. Mokka's AI assessment systems evaluate your qualifications, experience, and skills against job requirements as described in Section 9.1 above. To request additional information about how AI was used in your evaluation, contact the hiring company or email privacy@gomokka.com with "Utah AI Inquiry" and your application details.

European Economic Area, United Kingdom, and Switzerland — EU AI Act and GDPR

Mokka's AI assessment system is classified as high-risk under the EU AI Act because it is used in employment-related decisions. In addition to your rights under Section 9.3 above: (a) you have the right to receive a meaningful explanation of how the AI system contributed to any decision about your candidacy, including the main factors considered and how your qualifications were weighed; (b) you have the right to contest any AI-assisted decision and request that the hiring company arrange for a human reviewer to evaluate your application independently; and (c) Mokka conducts fundamental rights impact assessments and regular bias audits to identify and mitigate risks of discrimination. For further information about our AI governance practices, bias audit results, and compliance documentation, visit our Trust Center at https://trust.gomokka.com/ or email 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 Ltd

Address: 28 October Avenue 367, Mediterranean Court, 1st Floor, Office A5, Limassol, Cyprus, 3107