Privacy Notice

Introduction

Willo Technologies Limited recognises that our official Willo websites, https://www.willotalent.com, https://willo.video and any related services we offer, including mobile applications (collectively, the "Platform"), can only work if we build a relationship of trust with our users.

For information on how our customers use your data please contact them directly. If you would like to contact us about how we process your data please contact us using the details set out at the end of this privacy notice ("Privacy Notice").

As a user of the Willo platform, we may in certain circumstances collect and process your personal data in the course of our business with you. Under the General Data Protection Regulation EU 2016 / 679 (GDPR) you are entitled to be informed of what data we will hold and how we intend to use that data. This Privacy Notice informs you of what data we collect, why we collect it and the lawful conditions we consider appropriate for the processing of your personal data.

‘Personal data’ means any information relating to an identified or identifiable natural person, most common data being name, email, telephone number or IP address.

We may collect, store and process the following types of personal data relating to you through our website, application, by telephone, email or on live chat:

• Information that you provide to us when interviewing which includes Name, Email address, Phone number, IP address and recorded video, audio answers and files uploaded to questions. 
• Information that you provide to us when signing up and/or paying for the platform as a customer, including Name, Email address, Organisation name, Phone number, IP address, Language preferences.

Whilst we do not request special category data, it may be incidentally present in content you provide during your assessment. Where this occurs, it is processed as part of your assessment on behalf of the hiring organisation. Willo monitors assessment questions and may flag for review any questions we consider inappropriate or designed to elicit special category data unlawfully.

Why We Need this Information 

Personal data we collect from you will be used for the purposes it was provided, including the following:

• In order for us to capture and store your video interview answers.
• In order for us to provide you with video interviewing services.
• In order to analyse and improve our product and service for users.
• To provide AI-enhanced features where specifically enabled by the hiring organisation, including automated transcription, summaries, and AI-assisted analysis of your responses to support their review process..

AI-Assisted Features

Where enabled by your hiring organisation, your interview responses may be processed using AI-assisted features. These include automated transcription of your responses, AI-generated summaries of that transcription, and - where your hiring organisation has enabled Willo Insights - AI-assisted analysis of your responses, including candidate fit scoring and related insights to support their structured review process.

All AI-assisted features are performed on behalf of, and under the instructions of, the hiring organisation, who remains responsible for all hiring decisions. Any AI-generated outputs are intended to assist, not replace, human review. If you have questions about which AI features were used in your assessment, you should contact the hiring organisation directly.

Lawful Bases for Processing

Where Willo acts as a data controller, we rely on the following lawful bases under UK GDPR and EU GDPR, depending on the context of the processing: 

• Performance of a contract - where processing is necessary to provide the Platform, manage customer accounts, process payments, or respond to service-related enquiries. 
• Legitimate interests - where processing is necessary for the operation, security, and improvement of the Platform, including fraud prevention, network security, service optimisation, and internal administrative purposes. We ensure that such interests are balanced against your rights and freedoms. 
• Legal obligation - where processing is required to comply with applicable legal or regulatory requirements (for example, accounting or tax obligations). 
• Consent - where required by law, such as for the placement of non-essential cookies or certain marketing communications. You may withdraw your consent at any time. 

Where Willo acts as a data processor on behalf of a customer (for example, in relation to interview recordings and candidate data), the customer determines the lawful basis for that processing.

Where data will be stored

Willo production data is processed and stored using Amazon Web Services (AWS), which implements multilayer security controls including access management, monitoring, alerting, and auditing. All persistent data is encrypted at rest using industry-standard AES-256 encryption.

Personal data is primarily hosted within the European Union. Depending on service configuration and the use of certain third-party service providers, limited processing or access may occur in the United States.

Where personal data is transferred outside the UK or EU, appropriate safeguards are in place to ensure an adequate level of protection, including reliance on the EU–U.S. Data Privacy Framework (and the UK Extension where applicable) and/or Standard Contractual Clauses with the UK Addendum, or the UK International Data Transfer Agreement (IDTA) as appropriate.

Information Security

We have appropriate security measures to prevent Personal Information from being accidentally lost, used or accessed unlawfully. We limit access to your Personal Information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. 

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Detailed Information Security documentation can be found here.

Cookies and similar technologies 

We use cookies and similar technologies to operate and improve the Platform, understand how users interact with our website, and support marketing activities.

When you first visit our website, you will be presented with a cookie banner that allows you to accept or decline non-essential cookies. If you accept, we may place analytics and marketing cookies on your device. If you decline, we will not track your activity for these purposes and will place a single cookie to remember your preference.

Candidates accessing an assessment via an invite link are not subject to non-essential cookies. Only essential platform security cookies operate in that context.

Essential cookies necessary for the secure operation of the platform may be set regardless of your choice. These include cookies used for payment fraud prevention and platform security, and are not used for analytics or marketing purposes.

You can update your cookie preferences at any time by clearing your browser cookies, which will cause the cookie banner to reappear on your next visit. Alternatively, most browsers allow you to block or delete cookies directly via their settings.

Third Party Websites and Services

The Platform may contain links to websites, services, or integrations operated by third parties that are not controlled by Willo (“Third-Party Websites”). Where you choose to interact with or export information to such Third-Party Websites, any personal data you provide will be processed in accordance with that third party’s own privacy notice and practices. Willo is not responsible for the content, security, or privacy practices of Third-Party Websites.

Separately, Willo uses certain trusted third-party service providers (sub-processors) to help deliver and support the Platform (for example, hosting, analytics, customer support, or identity verification). These sub-processors process personal data on Willo’s behalf and only in accordance with our instructions and contractual obligations.

We do not permit our sub-processors to use personal data for their own purposes. A list of our current sub-processors is available at: https://support.willo.video/article/110-platform-subprocessors

Where personal data is shared with third parties at your direction (for example, through integrations you enable or external services you choose to use), such sharing is initiated by you, and Willo does not control how those third parties process your data. You can stop sharing your personal information with third-party services by disabling the relevant integration or referring to https://support.willo.video 

Retention Period 

Willo retains personal data only for as long as necessary to provide the Platform, fulfil contractual obligations, comply with legal requirements, and resolve any issues arising from the use of the Platform. The exact retention period will depend on the nature of the data and the purpose for which it is processed.

Where Willo acts as a data processor on behalf of a customer (for example, in relation to interview recordings and candidate data), personal data is retained in accordance with the customer’s instructions and applicable retention settings within the Platform. Customers, as data controllers, are responsible for determining appropriate retention periods for such data. 

Retention is aligned to the customer's contracted service period:

• Fixed-term contracts: candidate data is purged at expiry plus a 30-day grace period. 
• Indefinite or rolling contracts: candidate data is retained for a maximum of 12 months from submission.

Where Willo acts as a data controller (for example, in relation to account management, billing, security, and platform administration), personal data is retained for as long as required to meet those purposes and applicable legal or regulatory obligations.

Upon termination or expiry of a customer account, personal data processed on behalf of that customer will be deleted or anonymised in accordance with the customer’s instructions and the terms of the applicable agreement, subject to any legal obligations requiring continued retention.

Further details regarding retention periods or data deletion requests can be obtained by contacting us at https://support.willo.video.

Your Data Protection Rights

Where Willo acts as a data controller, you have the following rights under applicable data protection laws:

• The right of access to the personal data we hold about you.
• The right to rectification of inaccurate or incomplete data.
• The right to erasure in certain circumstances.
• The right to restriction of processing in certain circumstances.
• The right to object to processing based on legitimate interests.
• The right to data portability where processing is based on contract or consent and carried out by automated means.
• The right to lodge a data protection complaint direct to us.
• Where processing is based on consent, the right to withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

You may exercise your rights by contacting us using the contact details set out in this Privacy Notice. You also have the right to lodge a complaint via your local supervisory authority. In the United Kingdom, this is the Information Commissioner’s Office (ICO).

Where Willo processes interview data on behalf of a hiring organisation (including recordings, transcripts or AI-generated summaries), that organisation acts as the Data Controller and is responsible for responding to Data Protection Rights Requests. You should direct any request to the relevant hiring organisation, as set out in its privacy notice.

If you contact Willo directly about interview data, we will forward your request to the appropriate organisation and assist them in responding. If you are unsure which organisation is responsible, you may contact us and we will help identify them.

Sharing of data

Willo may share limited personal data with trusted third parties where necessary to operate, support, and improve the Platform. Such sharing falls into the following categories:

Service providers and sub-processors

We use carefully selected third-party service providers (such as hosting providers, customer support tools, analytics services, and identity verification providers) to process personal data on our behalf. These parties act as sub-processors and are contractually required to process personal data only in accordance with our instructions and applicable data protection laws.

Resellers and commercial partners

In certain circumstances, we may share limited business contact information with authorised resellers or commercial partners for the purposes of sales support, onboarding, or account management. This sharing is restricted to what is necessary for those purposes and does not include the disclosure of interview content or candidate personal data. We do not share personal data with third parties for their own direct marketing purposes.

In connection with our commercial partnerships, we may share limited business account information with partners where necessary to support collaboration or account management. This does not include the sharing of individual contact details or candidate interview content.

A list of our current sub-processors is available at https://support.willo.video/article/110-platform-subprocessors. 

Partner Account Matching

Willo may use secure partner-matching platforms to identify overlapping business customers with authorised commercial partners. This activity is limited to company-level information (such as company name or domain) and does not involve the sharing of personal data relating to individuals or candidate interview content.

Further information about our data-sharing practices can be obtained by visiting https://support.willo.video 

Children (Under 16 years of age)

The Platform is intended for use by businesses and adult individuals only. It is not designed for, directed at, or intended to be used by children, and children must not use the Platform.

Registration

Willo Technologies Limited is registered with the Information Commissioner’s Office (ICO) in the United Kingdom. Depending on the context of the processing, Willo may act as a data controller (for example, in relation to account management, billing, security, and platform administration) or as a data processor on behalf of its customers.

Our ICO registration number is: ZA558632.

Changes to this Privacy Notice

We may update this Privacy Notice from time to time to reflect changes to our services, practices, or legal obligations. Any updates will be posted on this page. We encourage you to review it periodically.

How to contact us

If you have questions or comments about this Privacy Notice please contact us at the address below:

DPO

Willo Technologies Limited, 

20-23 Woodside Place, 

Glasgow,

G3 7QF, 

United Kingdom.

If you are dissatisfied with any aspect of our handling of your personal data, you can complain to the Information Commissioner’s Office via the following:

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

www.ico.org.uk