At Cammio, we are committed to protecting your privacy and ensuring that your Personal Data is handled securely and responsibly. With this Privacy Policy, we inform you about the Processing and protection of personal data when using the Cammio Video Recruitment Platform (hereinafter also referred to as the “Platform”).
1. Definitions
This Privacy Policy is based on the definitions provided in Article 4 of the EU General Data Protection Regulation (“GDPR”):
Personal Data: refers to any information relating to an identified or identifiable natural person (“Data Subject”). This includes information such as your name, email address, or IP address. Information that is not directly or indirectly associated with your identity, e.g. the number of visitors of an website, does not fall within this scope.
Processing: encompasses any operation or set of operations which is performed on Personal Data, whether or not by automated means. This includes collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment, restriction, erasure, or destruction of Personal Data, as well as any changes to the purpose or Processing methods originally intended.
Data Controller: a natural or legal person, authority, body, or agency that, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.
Data Processor: a natural or legal person, public authority, agency, or other body that Processes Personal Data on behalf of the Data Controller, especially in accordance with their instructions (e.g., IT service providers). In data protection terms, a Data Processor is not considered a Third Party.
Data Protection Officer: a data protection expert who advises on data protection compliance within an organization in the sense of Art 37 GDPR.
Third Party: means any natural or legal person, public authority, agency, or body other than the Data Subject, the Data Controller, the Data Processor, and the persons who, under the direct authority of the Data Controller or the Data Processor, are authorized to Process Personal Data; this includes other legal entities within the same group.
Consent: given by the Data Subject means any freely given, specific, informed, and unambiguous indication of the Data Subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the Processing of Personal Data relating to them.
Further defined terms for this Privacy Policy are
Cammio Applicant: each natural person who uses the Platform as part of their application to Cammio, to conduct one or several video interviews and transmit them to Cammio.
Client: Every natural or legal person who is a contractually authorized end user of the Platform and who is granted access to the Platform by Cammio or by a Third Party authorized by Cammio, and uses the Platform for recruitment activities.
Client End User: each natural person that can access the Platform using a username and password or in another way and makes use of the Platform by or on behalf of Client.
Client Applicant: each natural person who uses the Platform as part of their application to a Client, to conduct one or several video interviews and transmit them to such Client.
For the sake of readability, this Privacy Policy refrains from gender-specific differentiation. Corresponding terms apply equally to all genders.
2. The Data Controller
Client Applicants and Client End Users
Unless otherwise stated the Data Controller is the company who
invited you to conduct a video interview (Automated or Live),
sent a personal video message (Clip) or video job description (Story) to you, or
invited you to use the Cammio Platform as a user
In these cases, Cammio Processes Personal Data solely on behalf of the Client and in accordance with Client’s instructions within the meaning of Art. 28 GDPR in conjunction with the use of the Platform or the Client account. Data Controller is and remains the Client as the responsible entity for the Personal Data transmitted to Cammio as the Data Processor, and of all Personal Data resulting and derived therefrom (e.g.: reviews). The Client is therefore the Data Controller within the meaning of Art. 4 point 7 GDPR. A corresponding data processing agreement is in place between the Client and Cammio.
Cammio Applicants
If you are applying for a role at Cammio, the Data Controller is either Cammio B.V., if you are applying for our international office in The Hague, or Cammio GmbH, if you are applying for our German office in Düsseldorf.
International office | German office |
|---|---|
Cammio B.V. | Cammio GmbH |
3. The Data Processor
Client Applicants and Client End Users
Unless otherwise stated in this Privacy Policy, the Data Processor in accordance with Art. 6 GDPR is either Cammio B.V. or Cammio GmbH:
Client has a contract with Cammio B.V. | Client has a contract with Cammio GmbH |
|---|---|
Cammio B.V. | Cammio GmbH |
With respect to Client’s Personal Data to be processed, we are responsible for complying with the relevant data protection laws applying to us. We collect, store, process and use Client’s Personal Data only within the scope of the concluded agreements, for the defined purposes and in accordance with Client’s instructions. We do process or use Personal Data to fulfill our obligations as Processor under the agreements between the Client and us. We further process Personal Data for own business purposes, particularly, by creating aggregated statistical data about your use of the Platform in order to improve the Platform and develop product and business strategies. Data for statistical purposes is completely anonymized.
Cammio Applicant
If you are applying for a position at Cammio, the Data Controller is either Cammio B.V., if you are applying for our international office in The Hague, or Cammio GmbH, if you are applying for our German office in Düsseldorf (see “2. The Data Controller”).
4. Contact Details of Data Protection Officer
Client Applicants and Client End Users
For disclosure of the Data Protection Officer contact details, the responsible party is our Client.
Cammio Applicant
The contact details of our Data Protection Officer, for Cammio B.V. as well as for Cammio GmbH, are as follows:
Cammio B.V, Spui 1, 2511 BL The Hague, reachable per phone: +31 (0) 85 401 3118 and email: info@cammio.com.
5. Purpose and Legal Basis of Data Processing
Client Applicants and Client End Users
We Process your Personal Data solely on behalf and in accordance to Client’s instruction and the Data Controller is and remains the Client as the responsible entity for the Processing of the Personal Data and is therefore also defining the purpose of Personal Data Processing. The Client is responsible to inform you about the explicit purpose for the Processing, e.g. within Consent forms or privacy statements made available to you.
Cammio Applicant
We Process your Personal Data exclusively for the purpose of the Platform to you in regards to your application for an employment relationship with us. Your Consent is our legal basis for the Processing of your Personal Data (Art. 6(i)(a) GDPR).
6. Accessing and Using the Platform
When accessing and using the Platform, we will Process the Personal Data set forth in this section either as a Data Controller or as a Data Processor (see Sections 2 and 3 of this Privacy Policy).
As a Cammio or Client Applicant
For you using the Platform as a Cammio or Client Applicant, creating a user account is not required. If you are invited to use the Platform the following Personal Data about you will be processed:
Your complete name (or pseudonym)
Your chosen form of address (only within German-based processes)
Your e-mail address (or pseudonym)
Information about your end device and browser user agent
Date and time of your access
Your recorded and submitted video and/or audio files
Your feedback after completing the interview process (optional)
Any other information you freely choose to provide during the recruitment process
We do not directly collect IP addresses, except as part of our log files for security and technical diagnostics. This IP address must be stored for technical reasons, even if only temporarily, in order to provide the Platform.
Depending on the selected settings and use case, the following additional Personal Data may be Processed when provided by you:
Your phone number
Your address
Your date of birth
Your CV
Your motivation statement
An individual link for you is created within the Platform, granting you access to your interview (Automated or Live). A user account is not created for you.
As a Client End User
The Personal Data collected on user account creation is Processed in order to perform the contract between us and the Client. For you using the Platform as an End User, a specific user account is created for you. If you are using the Platform as an End User the following Personal Data about you will be processed:
Your chosen form of address
Your complete name (or pseudonym)
Your e-mail address
Your phone number (optional)
Date and time of your access(es)
IP address (in case of Live Interviews)
Your recorded and/or uploaded video and/or audio files (optional)
When the Live Chat is enabled, the following Personal Data of Client End Users (not Applicants) gets additionally Processed:
Message exchanges
Activity status (online / offline)
Activity date and time
IP Address
Device type (operating system and browser)
Geographic location, city, country (derived from the IP address)
Preferred language
Time zone
Website pages that were accessed
Professional life data (Position, Employer, Business Address), if e-mail address provided by end-user
Data guessed from public information on Google (Avatar, Twitter/Facebook handle)
If conversations are inactive or resolved, all chat data gets deleted after 7 days.
7. Personal Data Deletion and Storage Duration
As a Client Applicant and Client End User
Deletion and storage duration of your Personal Data is defined by the Client as Data Controller. The Client is responsible to inform you about the Data deletion and Data storage duration, e.g. within Consent forms or privacy statements made available to you.
Cammio Applicant
For video interviews (Automated and Live), you submitted during your hiring process at Cammio, a data retention period of 180 days applies. At the end of this Personal Data retention period, the video files are automatically and irrevocably destroyed. During this period, the video files can be used for hiring processes.
8. Cooperation with Sub-Processors and Disclosure to Third Parties
Some of our the Processing of your Personal Data may be carried out by a Third Party. If the processing of personal data is carried out on our behalf, we conclude a separate data processing agreement with the respective Third Party in accordance with Art. 28 GDPR.
We use such Personal Data Processors as listed below to provide the Platform:
8.1 Hosting
For the purposes of hosting the Platform, we use the following Data Processors:
# | Name | Purpose |
|---|---|---|
1 | Amazon Webservices EMEA SARL | Hosting of Cammio platform (Personal Data Processing and storage in Frankfurt am Main, Germany) |
2 | Cammio B.V. | Holds the data processing agreement with Amazon Web Services EMEA SARL and provides the service through an intercompany data processing agreement to Cammio GmbH. |
8.2 Additional Sub-Processors
To further enhance and facilitate recruiting processes, our Clients can optionally use a transcription service to generate transcripts of completed automated interviews and a Live Chat functionality for Client End Users (not Applicants).
# | Name | Purpose |
|---|---|---|
1 | Amberscript BV | Transcription service (optional) |
2 | Crisp IM SAS | Live-Chat within the Platform (optional) |
3 | Cammio B.V. | Holds the data processing agreement with Amberscript BV and Crisp IM SAS and provides the services through an intercompany data processing agreement to Cammio GmbH |
8.3 Disclosure to Third Parties
Only groups and individuals within Cammio who need to know your Personal Data to carry out their activities or to fulfil contractual and legal obligations will have access to such data. We may in some cases make your Personal Data available to service providers who contract with us to Process your Personal Data on our behalf and as instructed by us. These service providers acting as Data Processors are mentioned above.
In some cases, the recipients will be independently responsible as Data Controllers and therefore also be required to comply with the requirements of applicable data protection laws, in particular the GDPR. In any case where we engage a service provider to Process your Personal Data, we will have entered into a separate binding agreement with such provider for such Processing in accordance with Art. 28 GDPR.
To the extent necessary, we may in individual cases disclose personal data to our legal or tax advisors. In all such cases, such recipients will be bound their respective professional rules of confidentiality and secrecy.
9. Use of Cookies
The platform uses cookies. Cookies are small text files that are stored on your end device. These text files can be read by the platform and help to identify you when you visit the platform again. Some cookies are used to store preferences and are deleted after the end of the browser session, i.e. after closing the browser, so-called session cookies. Within our Cammio Platform we use technical and functional cookies. They ensure that the Platform works properly.
Cammio or Client Applicants
We always use the following cookies, which are absolutely necessary to make our platform available to you:
Host | Cookie | Provider | Retention |
|---|---|---|---|
https://tool.cammio.me | AWSALB/AWSALBCORS | Third Party | 7 days |
We use the following technically necessary cookie if the candidate support chatbot is enabled for the Cammio Client’s account:
Host | Cookie | Provider | Retention |
|---|---|---|---|
https://tool.cammio.me | IBM_WAC_ANONYMOUS_USER_ID | Third Party | 14 days |
The legal basis for the use of these cookies is Art. 6 (1) sentence 1 lit. f GDPR.
End Users
We always use the following cookies, which are absolutely necessary to make our platform available to you:
Host | Cookie | Provider | Retention |
|---|---|---|---|
https://tool.cammio.me | AWSALB/AWSALBCORS | Third Party | 7 days |
https://tool.cammio.me | _vss_admin | First Party | After session |
The following additional functional cookies are used if the Live Chat functionality for End Users (not candidates) is enabled for the Client’s account:
Host | Cookie | Provider | Retention |
|---|---|---|---|
https://tool.cammio.me | crisp client session | Third Party | 180 days |
https://tool.cammio.me | crisp client socket | Third Party | 3 days |
10. Contacting Cammio and Getting Assistance
When you contact us, for example using one of our contact forms or e-mail addresses, the Personal Data that you provide (your e-mail address, possibly your name and your telephone number) will be Processed by us for the solely purpose of responding to your enquiry. We will delete such Personal Data collected in this connection once it is no longer required for the aforementioned purpose, unless the deletion of this Personal Data would contravene statutory retention obligations. The legal basis for data processing is provided by Art. 6(1)(f) GDPR.
11. Data Security
We use appropriate Technical and Organizational Measures (TOM) to protect your Personal Data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorized access by third parties (e.g. TLS encryption for communication with the platform), taking into account the state of the art, the implementation costs and the nature, scope, context and purpose of the processing as well as the existing risks of a data breach (including its probability and impact) for you. Our security measures are continuously improved in line with technological developments. We will be happy to provide you with more detailed information on request. Please contact our data protection officer (info@cammio.com).
12. Your Rights as Data Subject
Should you have any queries or comments on data protection and privacy or wish to exercise your rights as a Data Subject, please contact the Data Controller of
the Client, if you are part of a hiring process with a company using the Platform
or
Cammio, if you apply to Cammio itself
(See Section “2. The Data Controller”)
12.1 Your Rights
You, as a Data Subject, have the following rights in regard to your Personal Data:
Right | Explanation |
|---|---|
Right to access and rectification | You can receive information at any time and at no charge about whether Personal Data related to you is processed and, if this is the case, which Personal Data is specifically stored about you. You are also entitled to receive a copy of the stored Personal Data. You can also have errors in your Personal Data corrected and missing information completed. |
Right to erasure | You can request the erasure and restriction of your Personal Data. If deletion of your Personal Data conflicts with statutory retention obligations, your Personal Data will be marked with the aim of restricting its future Processing. |
Right to data portability | You generally have the right to have the Personal Data concerning you transmitted to you or to another Data Controller in a structured, commonly used and machine-readable format, provided that the Processing is based on Consent or on a contract and is carried out by automated means. You also have the right to have the Personal Data transmitted directly from one Data Controller to another, where technically feasible and if this does not adversely affect the rights and freedoms of others. |
Right to withdraw consent and right to object | Where the Processing of your Personal Data is based on your Consent, you can withdraw your Consent at any time. The withdrawal of your Consent does not affect the legitimacy of the processing that occurred based on your Consent until the withdrawal. |
Right of Complaint (Art. 77 DSGVO) | You also have the right to lodge a complaint with the competent supervisory authority and to seek legal remedies. The supervisory authority to which the complaint has been submitted will inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy. |
12.2 Assistance from Cammio
If you are unsure who the Data Controller is or how to contact them, please reach out to us: info@cammio.com.
While Cammio cannot directly fulfill requests to exercise your rights over Personal Data the Clients are responsible for, we are committed to assisting you by providing necessary information on how to reach out to the relevant Data Controller.
Cammio will also support its Clients in fulfilling their obligations under the GDPR, including facilitating the process of responding to your requests as required by law.
13. Adjustments to this Data Privacy
We reserve the right to amend this Privacy Policy in accordance with updates to our Platform, services, or regulatory developments. This Privacy Policy was last updated on 07.01.2025.
