Privacy Policy

1. Who we are

Franke Personal ("we", "us") operates frankeApply, a job-application tracking and AI cover-letter workspace tailored to the German market. Franke Personal is the data controller for personal data processed through this service under the EU General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG).

Privacy contact: tran@frankepersonal.de. We respond to privacy requests within 30 days as required by Art. 12(3) GDPR.

2. What data we collect

We process personal data in accordance with the principle of data minimization. You have the right to choose whether or not to upload your CV/résumé to the system. Uploading or inputting your CV is entirely optional.

• Account data: email address, full name.
• Profile data: phone number, postal address (used solely to generate your applications if you choose to input them).
• Application data: jobs you add, ATS scores. Uploaded résumés and cover letters are only saved if you explicitly choose to save them in your profile (e.g. for CV translation or auto-fill).
• ATS Checking Data (Ephemeral): For ATS score checking, the system does not save or store your uploaded résumé or cover letter. This data is held temporarily in memory for the duration of the analysis. When you navigate away from the page, switch to another tab, or close the browser tab, the résumé and cover letter will immediately disappear and are not retained on our servers.
• Technical data: minimal session storage required to keep you signed in; IP address and device/browser metadata for security.
• Billing data: for paid subscriptions, billing details (name, email, country, payment details where applicable) are collected and processed by our payment provider, PayPal (see Section 8).

3. Legal basis & purpose

We process your data on the basis of Art. 6(1)(b) GDPR (performance of contract, providing the service you signed up for), Art. 6(1)(a) GDPR (your explicit consent during signup) for optional features such as AI optimization, Art. 6(1)(c) GDPR (legal obligation - e.g. tax and invoicing requirements relating to subscription purchases) and Art. 6(1)(f) GDPR (legitimate interest in service security and fraud prevention).

4. Data isolation & security

• Your saved résumés, cover letters and contact details are stored in a private database / bucket protected by row-level security, meaning only you can access them.
• Documents uploaded specifically for ATS score analysis are processed ephemerally in memory and are never saved or stored in any database or file bucket. They disappear completely when you navigate away, switch tabs, or close the page.
• We do not aggregate user-uploaded documents into any shared dataset.
• Communication with our servers is encrypted in transit (TLS).

5. Interviewer / third-party contact data

When you research a job, the system may surface publicly listed names of hiring managers. This information is processed ephemerally and attached only to your individual job entry. We do not build a shared database of recruiter contacts and we do not send any email on your behalf without an explicit click. This protects against unsolicited commercial communication under the German UWG (§ 7 UWG).

6. Your rights (Art. 15–22 GDPR)

• Right of access, rectification, restriction and objection.
• Right to data portability.
• Right to erasure ("right to be forgotten"): at any time you can permanently delete your account and all associated data from Settings → Delete account.
• Right to lodge a complaint with a supervisory authority (e.g. your state's data-protection commissioner).

7. Retention

We retain your data only as long as your account exists. Deleting your account purges your profile, jobs and uploaded files immediately and irreversibly. Billing records may be retained by PayPal and by us for the period required by applicable tax and commercial law (typically up to 10 years under German HGB / AO).

8. Subprocessors & data sharing

We share personal data only with the following categories of recipients:

• PayPal (PayPal (Europe) S.à r.l. et Cie, S.C.A., Luxembourg) - our payment processor. When you purchase a subscription, PayPal processes the payment, handles transaction details, and manages recurring billing profile data. See PayPal's privacy statement at paypal.com/webapps/mpp/ua/privacy-full.
• Hosting & database infrastructure providers (EU region).
• AI inference: We utilize Google Gemini and open-source models from Mistral AI for AI-generated features, such as cover letter generation/optimization, CV translation, and ATS score checking. These AI features are completely optional and are only used if you explicitly agree to use them by initiating an AI action (e.g., clicking "Generate Cover Letter", "Translate CV", or "Analyze Your CV"). Your uploaded documents are only processed by these models for the duration of the request and are not used to train the AI models.
• Authorities where required by law.

An up-to-date list of subprocessors is available on request.

9. Cookies

We use only strictly necessary cookies / local storage required to keep you signed in and to remember your preferences. We do not use third-party advertising or cross-site tracking cookies.

10. Contact

For any privacy request, write to tran@frankepersonal.de.