Privacy Policy and Data Protection
Effective Date: December 16, 2025
Last Update: December 16, 2025
1. Introduction and Scope
DafonCV ("Service") is operated by Dafon LLC ("Company", "we", "our" or "us") and respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, process, and protect information when you use the DafonCV service ("Service").
Regulatory Compliance: This policy complies with the Brazilian General Data Protection Law (LGPD), European GDPR, US state privacy laws including the California Consumer Privacy Act (CCPA), Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), the UK's Personal Information Protection and Electronic Documents Act, and applicable international data protection regulations.
Service Overview: Our Service provides automated discovery of charts and European job market levels through AI-powered analysis of publicly available job listings from European sources, delivered via available format models.
2. Data Controller Information and Contact Details
Data Controller: Dafon LLC
Privacy Inquiries: dafondeveloper@gmail.com
Customer Support: dafondeveloper@gmail.com
3. Categories of Personal Information We Collect
Information You Provide Directly:
- Account Information: Email address, notification preference settings, user preferences
- Payment Information: Billing details processed through Stripe (we do not store complete payment card information)
- Communication Data: Support inquiries, feedback, and correspondence
Information Collected Automatically:
- Usage Data: Service interaction patterns, feature usage, search queries, and preferences
- Technical Information: IP addresses, device information, browser type, access times
- Bot Interaction Data: Commands used, response patterns, service configuration choices
- Session Information: Login timestamps, session duration
- Profile Data: Name, email, phone, career information, gender (when voluntarily provided by the user)
Marketing and Analytics Data:
- Site Analytics: Google Analytics, Facebook Pixel, Yahoo marketing pixels for site optimization
- Marketing Attribution: Campaign effectiveness, referral sources, user acquisition metrics
- Cookie Data: Session management cookies, preference settings, authentication tokens
4. Legal Basis for Processing and Purposes of Use
LGPD Legal Bases:
- Consent: For marketing communications, analytics, and optional features, and processing of sensitive data (when applicable)
- Contract Performance: For service delivery, payment processing, and account management
- Legitimate Interest: For service improvement, fraud prevention, and customer support
- Legal Compliance: For tax obligations, regulatory reporting, and law enforcement requests
GDPR Legal Bases (for EU users):
- Consent (Article 6(1)(a)): Marketing, analytics, and optional data processing
- Contract Performance (Article 6(1)(b)): Service delivery and payment processing
- Legitimate Interests (Article 6(1)(f)): Service improvement, security, and fraud prevention
- Legal Obligation (Article 6(1)(c)): Regulatory compliance and legal requirements
- Sensitive Data (Article 9): When sensitive data such as gender is processed, we base it on explicit consent from the data subject
Processing Purposes:
- Service Delivery: Providing job opportunity notifications and personalized recommendations
- AI Processing: Use of Claude AI and ChatGPT for content analysis, filtering, and document generation
- Payment Processing: Subscription management and billing through Stripe
- Customer Support: Responding to inquiries, troubleshooting, and service assistance
- Service Improvement: Analyzing usage patterns to enhance features and functionality
- Marketing and Analytics: Understanding user behavior and promoting relevant services
- Legal Compliance: Meeting tax, regulatory, and law enforcement obligations
5. AI Processing and Automated Decision Making
AI Systems Used:
- Content Analysis: Processing resume information for relevance and quality
- Job Scoring: Algorithmic evaluation of listing value and user relevance
- Automatic Context Expansion: Enhancing resume information with additional relevant details
- Recommendation Generation: Personalizing job suggestions based on user preferences
Automated Decision Making Rights:
- Request human review of AI-driven recommendations
- Understand the logic behind automated processing that affects your service experience
- Opt out of using certain AI-powered features while maintaining access to the main service
- Access information about how AI systems process your data
AI Transparency: AI processing involves analysis of user preferences, search history, and interaction patterns to improve recommendation accuracy. Users may request detailed explanations of AI decision-making processes that affect their service experience.
6. Data Sharing and Third-Party Processors
Payment Processing:
Stripe: Processes all payment transactions. Shared data includes billing information and transaction details. Stripe maintains independent privacy practices described in its privacy policy.
Service Infrastructure:
Cloud Hosting Providers: Service technical data and user information stored in secure cloud infrastructure
AI Processing Partners:
Anthropic (Claude AI): User queries and job market data processed for analysis and recommendations. OpenAI (ChatGPT): Similar processing for content enhancement and user assistance.
Marketing and Analytics:
- Google Analytics: Site usage analysis for service improvement
- Facebook Pixel: Marketing attribution and campaign optimization
- Yahoo Analytics: Additional marketing performance analysis
No Data Sale: We do not sell personal information to third parties for their direct marketing purposes.
7. International Data Transfers
Transfer Locations:
- United States: For AI processing (Anthropic, OpenAI) and payment processing (Stripe)
- European Union: For cloud infrastructure and service delivery
- Other Countries: As necessary for service operation and third-party processing
Transfer Safeguards:
- Standard Contractual Clauses (SCCs): We use Standard Contractual Clauses approved by the European Commission for EU data transfers, and clauses approved by ANPD for transfers from Brazil
- Data Processing Agreements: Comprehensive agreements with all international processors that include data protection obligations
- Privacy Shield Successors: Appropriate frameworks for US data transfers when available
- Adequate Protection: Ensuring that recipient countries provide adequate levels of data protection equivalent to EU and Brazil standards
User Rights Regarding Transfers: Users may request information about international transfers affecting their data and the safeguards protecting their information in foreign jurisdictions.
8. Data Retention and Deletion
Retention Periods:
- Account Data: Retained while the account is active plus 30 days after closure
- Payment Information: 7 years for tax and financial record keeping (European/international requirements)
- Usage Analysis: 24 months for service improvement analysis
- Marketing Data: Until consent is withdrawn or maximum 3 years
- Legal Compliance Data: As required by applicable laws and regulations
Automatic Deletion:
We implement automated deletion processes to remove data after retention periods end. Users receive notification before automatic deletion when required by law. We collect and retain only data necessary for specified purposes and regularly review retention practices to minimize storage duration.
9. Comprehensive User Rights Framework
Universal Rights (Available to All Users):
- Right to be Informed: Clear information about data processing at collection
- Right of Access: Obtain copies of personal data and processing information
- Right of Rectification: Correct inaccurate or incomplete information
- Right of Deletion: Request erasure of personal data ("right to be forgotten")
- Right to Data Portability: Export data in machine-readable format
- Right of Opposition: Object to processing for direct marketing and legitimate interests
Brazilian Users (LGPD Rights):
- Right of Confirmation: Confirm existence of data processing
- Right of Information: Detailed information about processing activities
- Right of Anonymization: Request anonymization of unnecessary data
- Right to Withdraw Consent: Easy mechanism for consent withdrawal
- Right of Explanation: Understand automated decision-making processes
US State Law Rights (California, Virginia, Colorado, etc.):
- Right to Know: Categories of personal information collected and processed
- Right to Delete: Request deletion of personal information
- Right to Opt-Out: Opt out of sale/sharing and targeted advertising
- Right to Non-Discrimination: Equal service regardless of privacy choices
- Right to Correct: Rectify inaccurate personal information
Canadian Users (PIPEDA Rights):
- Right of Access: Access personal information maintained by the organization
- Right to Contest: Contest accuracy and completeness of information
- Right to Withdraw Consent: Withdraw consent subject to contractual restrictions
- Right to Complain: File complaints with the Privacy Commissioner
10. Exercising Your Rights
How to Submit Requests:
Email: dafondeveloper@gmail.com with "Privacy Request" in the subject line
Request Processing:
- Response Time: 15 days (LGPD), 30 days (GDPR), 45 days (CCPA)
- Identity Verification: Reasonable measures to confirm requester identity
- No Fee: Generally free unless requests are excessive or repetitive
- Status Updates: Regular communication about request processing status
Request Fulfillment:
- Data Access: Comprehensive information about data processing
- Data Deletion: Complete erasure subject to legal retention requirements
- Data Portability: Machine-readable format (JSON, CSV, XML)
- Consent Withdrawal: Immediate cessation of consent-based processing
11. Cookies and Tracking Technologies
Types of Cookies Used:
- Essential Cookies: Necessary for basic service functionality and security
- Analytics Cookies: Google Analytics for site performance analysis
- Marketing Cookies: Facebook Pixel, Yahoo marketing pixels for campaign optimization
- Preference Cookies: Remember user settings and preferences
Cookie Consent:
- Granular Control: Users can accept/reject specific cookie categories
- Consent Management: Easy-to-use cookie preferences center
- Withdrawal Rights: Simple mechanism to withdraw cookie consent
- Equal Prominence: Accept and reject options receive equal emphasis
Opt-Out Mechanisms:
- Global Privacy Control (GPC): Respect browser-based opt-out signals
- Cookie Settings: Preference management accessible on all pages
- Marketing Opt-Out: Direct opt-out links in marketing communications
- Analytics Opt-Out: Support for Google Analytics browser opt-out plugin
12. Data Security and Breach Procedures
Security Measures:
- Encryption: AES-256 encryption for data at rest, TLS 1.3 for data in transit
- Access Controls: Role-based access permissions and multi-factor authentication
- Regular Audits: Periodic security assessments and penetration testing
- Employee Training: Comprehensive privacy and security training programs
Breach Response:
- Detection: 24/7 monitoring and incident detection systems
- Assessment: Rapid risk assessment and impact analysis
- Notification: Regulatory notification within 72 hours (GDPR), 3 business days (LGPD)
- User Communication: Immediate notification if breach likely to cause harm
- Remediation: Immediate measures to contain and remediate security incidents
Data Protection Measures:
- Privacy by Design: Privacy protections integrated into system architecture
- Data Minimization: Collect only information necessary for specified purposes
- Regular Deletion: Automated removal of data after retention periods
- Vendor Security: Comprehensive security requirements for all data processors
13. Children's Privacy
Although our Service is available to all users, we do not knowingly collect personal information from children under 13 years of age without parental consent in compliance with COPPA (Children's Online Privacy Protection Act).
If we become aware that we have collected information from children under 13, parents may:
- Request access to their children's information
- Request deletion of their children's personal information
- Refuse additional collection of their children's information
Enhanced Protections: Users aged 13 to 16 in EU jurisdictions receive enhanced privacy protections under GDPR requirements.
14. Marketing and Communication Preferences
Marketing Communications:
- Explicit Consent: Opt-in for marketing communications
- Service Relationship: Transactional messages related to service use
- Legitimate Interest: Service improvement communications when permitted
Communication Controls:
- Subscription Management: Easy unsubscribe links in all marketing emails
- Granular Preferences: Choose specific types of communications to receive
- Immediate Effect: Opt-out requests processed within 10 business days
15. Updates to this Privacy Policy
- Site Notice: Prominent publication of updated policy with effective date
- Email Notification: Direct communication to registered users
- Service Notification: In-app notices for significant changes
Users have 30 days to review changes before they take effect. Continued use after the effective date constitutes acceptance of updated terms.
16. Contact Information and Complaints
Privacy Inquiries:
Email: dafondeveloper@gmail.com with "Privacy Request" in the subject line
Response Time: 15 business days for general inquiries
Regulatory Complaints:
- Brazil (LGPD): National Data Protection Authority (ANPD) - www.gov.br/anpd
- EU (GDPR): Relevant EU supervisory authority in your member state
- California: California Attorney General - oag.ca.gov
- Canada (PIPEDA): Office of the Privacy Commissioner of Canada - priv.gc.ca
We are committed to resolving privacy concerns promptly and encourage users to contact us directly before filing regulatory complaints. We maintain detailed records of complaint resolution efforts to demonstrate compliance with applicable privacy laws.
This Privacy Policy complies with Brazilian LGPD, US state privacy laws, Canadian PIPEDA, EU GDPR, and international data protection standards. Regular updates ensure ongoing compliance with evolving regulatory requirements.
