Privacy Policy

Version 2.0.0 · Effective September 24, 2026

AceUnlock AI Inc. ("AceUnlock," "we," "us") is incorporated in Ontario, Canada, and headquartered in Oakville, Ontario. This Privacy Policy explains how we collect, use, retain, and disclose personal information through our website (aceunlock.com) and our AI interview platform (the "Platform").


  1. Our Role

Platform data. When an organization such as a university or employer (a "Customer") uses the Platform, we process personal information on the Customer's behalf and according to its instructions. The Customer owns this data ("Customer Data"). If you use the Platform through a Customer, such as a student invited to a practice interview, the Customer's own privacy policy also applies, and you may direct requests to the Customer or to us.

Educational institutions. When we provide services to an educational institution, we act as a "school official" under the Family Educational Rights and Privacy Act (FERPA), under the institution's direct control, and use student records only to provide the services.

Website data. For visitors to our website and people who contact us, AceUnlock is responsible for the personal information we collect.


  1. Information We Collect

Account information: names, email addresses, and roles of Customer administrators and recruiters, and the names and email addresses of candidates or students invited to interviews.

Interview data: video and audio recordings of interview responses, transcripts, and AI-generated analysis, evaluations, and feedback.

Customer content: job postings, interview questions, evaluation rubrics, and email templates provided by Customers.

Technical information: IP addresses, browser and operating system type, and approximate city-level location derived from IP addresses. We do not collect MAC addresses or other hardware identifiers.

Website information: information you provide when you contact us, book a demo, or subscribe to updates, along with basic website usage information.

Information we do not collect: We do not request government identification numbers, financial information, health information, or demographic information such as age, gender, race, or ethnicity. We do not use facial recognition, create voiceprints, or otherwise create biometric identifiers. Please avoid sharing sensitive personal information during interviews.


  1. How We Use Information

We use Customer Data only to provide the Platform to the Customer, including:

conducting interviews and recording responses;
generating interview questions from job postings;
analyzing interviews and providing evaluations and feedback;
operating, securing, and supporting the Platform, including detecting fraud and abuse; and
producing aggregated usage statistics that do not identify individuals.

We do not sell personal information, share it for advertising, or use Customer Data for marketing. Marketing communications are sent only to website visitors and business contacts who have consented to receive them, and you can unsubscribe at any time.


  1. Artificial Intelligence

The Platform uses AI services from third-party providers:

Amazon Bedrock (including Anthropic's Claude models) to analyze job postings and evaluate interview responses;
Google Gemini to analyze interview video and transcripts; and
ElevenLabs to provide the AI interviewer's voice and transcribe responses.

No training on your data. AceUnlock does not train or fine-tune AI models, and our agreements with these providers prohibit them from using Customer Data to train their models.

Human review. AI-generated evaluations support human judgment. They are reviewed by Customer recruiters, and AI does not make hiring, admissions, or other significant decisions about individuals. You may request human review of an AI-generated evaluation (see Section 9).

Data minimization. We send AI providers only the content needed for each task. Names, email addresses, and account identifiers are excluded from AI requests.


  1. How We Share Information

We share personal information only as follows:

Service providers (subprocessors): Amazon Web Services (hosting and AI), Auth0 (authentication), Google (AI analysis), ElevenLabs (voice processing), and Sentry (error monitoring). Each is bound by a data processing agreement requiring it to protect the information and use it only to provide services to us. We notify Customers at least 30 days before adding a new subprocessor.
Legal requirements: We disclose information to law enforcement or government authorities only in response to valid legal process, such as a warrant, subpoena, or court order. We disclose only the minimum information required and notify the affected Customer beforehand unless legally prohibited. We may also disclose information in an emergency involving imminent risk of death or serious physical harm, where permitted by law.
Business transfers: If AceUnlock is involved in a merger or acquisition, our obligations regarding personal information would transfer to the acquiring entity, and affected Customers would be notified.


6. Where Information Is Stored

Customer Data is stored in the United States, in Amazon Web Services' US East (N. Virginia) region, and backups remain in that region. Our subprocessors process data primarily in the United States. Because AceUnlock is based in Canada, authorized staff may access information from Canada to support and maintain the Platform.


  1. Retention and Deletion


    Customer Data is retained for the duration of the Customer's agreement, unless the Customer deletes it earlier.
    At the end of an agreement, Customer Data remains available for export for 30 days (extendable by agreement). It is then permanently deleted, and backup copies expire within 7 days. We will confirm deletion in writing on request.
    AI providers process data only to generate responses and retain it only temporarily under their terms, for example for abuse monitoring.
    Website information is retained as long as needed for the purpose it was collected, or until you ask us to delete it.


  2. Security

We protect personal information with measures including encryption in transit (TLS 1.2 or higher) and at rest (AES-256), separation of each Customer's data, role-based access controls with multi-factor authentication, logging and monitoring, employee background checks and training, and regular independent security testing. We notify affected Customers within 72 hours of confirming a breach affecting their data, and comply with applicable breach notification laws. No method of transmission or storage is completely secure, but we work to protect your information.

  1. Your Rights

Depending on where you live, you may have the right to access, correct, or delete your personal information, and to withdraw consent for marketing communications. You may also ask for human review of an AI-generated evaluation. If you used the Platform through a Customer, such as your university, you may contact the Customer or us; we will work with the Customer to respond. We respond to requests within 30 days.

  1. Cookies

We use strictly necessary cookies and browser storage to keep you signed in and to secure the Platform. We do not use third-party advertising cookies, tracking pixels, or cross-site tracking on the Platform.

  1. Children's Privacy

Our website and Platform are not directed to children under 13, and we do not knowingly collect personal information from them. If you believe we have collected such information, please contact us.

  1. Changes to This Policy

We may update this Privacy Policy from time to time. We will post changes on this page with a new effective date, and notify Customers of material changes.

  1. Contact Us

Our Privacy Officer is responsible for our compliance with this Privacy Policy:

Sam Surkhang, CTO and Privacy Officer
AceUnlock AI Inc., Oakville, Ontario, Canada
support@aceunlock.com