Privacy Policy
Who We Are and What This Policy Covers
This Privacy Policy explains how Athyna, Inc. (“Athyna,” “we,” “us,” or “our”) collects, uses, shares, and protects personal data when you use our Website, Platform, and Global Job Board (collectively, the “Services”).
It also explains your privacy rights and how to exercise them under applicable data protection laws. This Policy complements our Terms and Conditions of Use and the user-specific Annexes (Talent / Client). It governs digital use only and does not replace any Master Services Agreement or other contract that may be executed if a commercial relationship is established.
Roles in Data Processing
- Controller: Athyna acts as a data controller for personal data collected directly through the Services (e.g., account creation, profile management, platform usage).
- Processor: Athyna may act as a data processor when processing personal data on behalf of a Client under a separate agreement.
- Independent Controllers: When you apply to Third-Party Opportunities via external links on the Global Job Board, that third party acts as an independent controller of your data, and its own privacy policy applies.
Categories and Sources of Personal Data
We collect and process personal data as relevant to each user type:
For Talents:
- Identification and contact information (name, email, phone, location).
- Professional information (experience, education, skills, certifications, languages, assessments, interview notes).
- Account and technical data (login information, activity logs, IP address, device information).
For Clients:
- Company details, contact information, and user credentials.
- Role descriptions, requirements, feedback, and communications regarding Talent candidates.
Sources:
Data is obtained directly from users, through our Clients (for example, when they post a role), through legitimate third-party integrations (video, analytics, communications), and from publicly available professional data (e.g., LinkedIn, portfolio sites).
Purposes and Legal Bases of Processing
Athyna does not use automated decision-making that produces legal or similar effects.
All evaluations and matching processes include human review and oversight.
Sensitive Personal Data
Athyna does not request, require, or process sensitive personal data (such as health information, biometric data, sexual orientation, political opinions, religious or philosophical beliefs, or trade union membership) as part of its Website, Platform, or Global Job Board. Such data is not necessary nor relevant to our operations, and users should not include it in their profiles or any materials uploaded to our Services. Athyna will delete or anonymize any sensitive data it becomes aware of that was inadvertently submitted. Athyna is not responsible for any sensitive or special-category data requested or processed by third-party organizations offering opportunities through the Global Job Board or via external application processes. In those cases, the third party’s privacy policy applies.
Use of Artificial Intelligence Tools
Athyna uses internal artificial intelligence (AI) tools to assist its recruitment and evaluation processes. These tools help our recruiting team analyze and organize information efficiently and fairly, using objective criteria such as validated skills, professional experience, education, certifications, language level, and relevant keywords.
AI tools are used solely to support Athyna’s recruiters in identifying and presenting qualified professionals to Clients.
These tools do not make or replace human decisions. All evaluations and recommendations involving candidates are reviewed by Athyna’s human staff, and the final hiring decision always rests with Athyna’s Clients.
AI processing is applied only to enhance the quality, accuracy, and efficiency of Athyna’s recruitment operations and is not used for automated decision-making that could produce legal or similar effects for any individual.
Sharing of Personal Data
We do not sell personal data and do not “share” it for cross-context behavioral advertising.
We share data only as necessary for legitimate operational purposes:
- Clients of Athyna: Talent profiles shared exclusively for hiring evaluations, always mediated by Athyna.
- Service Providers / Processors: Hosting, cloud storage, analytics, video, or communication tools, bound by contractual confidentiality and data protection clauses.
- Affiliates: When necessary for operations, under equivalent safeguards.
- Legal Compliance: When required by law, court order, or to protect rights or safety.
- Business Transactions: In the context of mergers or acquisitions, with appropriate safeguards and notice.
Athyna does not disclose Talent data to external agencies or companies offering roles through the Global Job Board.
Public Profiles and Data Sharing Controls
Athyna does not create or publish public profiles of users.
Talent profiles are shared exclusively with verified Clients for legitimate hiring evaluations and never with unrelated third parties, agencies, or external job boards.
Clients receiving such profiles are bound by confidentiality and may not disclose, copy, or reuse them for any other purpose.
International Data Transfers
Personal data may be processed in the United States and other countries where Athyna or its service providers operate. We use appropriate safeguards for international transfers, including EU Standard Contractual Clauses (SCCs), UK IDTA/Addendum, adequacy decisions (where applicable), and LGPD-compatible contractual clauses.
Our sub-processors are periodically reviewed and bound by equivalent data protection obligations.
Data Retention
Athyna retains personal data only as long as necessary for the purposes described in this Policy:
After expiration, data is securely deleted or anonymized.
Security and Data Breach Notification
Athyna applies SOC 2–aligned technical and organizational measures to protect information, including:
- Encryption in transit and at rest
- Access controls and least-privilege principles
- Secure development lifecycle and vulnerability management
- Backups, monitoring, and incident detection
- Vendor due diligence and confidentiality
- Employee training and role-based access reviews
In the unlikely event of a personal data breach, Athyna will notify affected users and, where required, the relevant authorities without undue delay in accordance with applicable law, including EU, US, Brazil, and Argentina regulations. Such notifications will include the nature of the incident, possible consequences, mitigation measures, and contact information for further assistance.
Cookies and Tracking Technologies
We use cookies and similar technologies to ensure proper functionality and improve performance. Certain analytical cookies may be provided by trusted third-party service providers (for example, to measure performance or usage patterns). These providers act under Athyna’s instructions and cannot use the information for their own advertising or profiling. Athyna does not use advertising cookies, does not sell or “share” personal data for behavioral advertising, and does not allow ad networks to track users across sites.
Users can disable or control cookies via their browser settings or through the cookie preferences available on our Website.
Consent and Acceptance
By accessing or using the Website, Platform, or Global Job Board, or by creating an account on the Platform, you acknowledge and accept this Privacy Policy, the Terms and Conditions of Use, and the relevant Annex (Talent or Client).
Athyna relies on this acceptance, together with the performance of our services, as the lawful basis for processing where consent is required. You may withdraw your acceptance or request deletion of your data at any time by contacting privacy@athyna.com.
Your Rights
Depending on your location and applicable law, you may have the right to:
- access, correct, or delete your personal data
- Restrict or object to processing
- Request data portability
- Withdraw consent where applicable
- File a complaint with a supervisory authority
For California (CPRA/CCPA) residents, you may also:
Request to know, delete, or correct personal information.
Opt-out of sale or sharing (Athyna does not sell/share)Limit use of sensitive personal information (not applicable).
- Use Global Privacy Control (GPC) signals
- Exercise your rights without discrimination
To exercise any of these rights, contact privacy@athyna.com.
We will verify your identity and respond within the timeframes required by law.
Children
The Services are intended for users 18 years and older.
Athyna does not knowingly collect data from minors. If we become aware that a minor has provided personal data, we will promptly delete it.
Contacts and Representatives
For all privacy-related matters, please contact:
If applicable, Athyna will appoint a Data Protection Officer (DPO/Encarregado) and EU/UK Representatives, whose contact details will be published here once designated.
You may also contact your local data protection authority (e.g., AAIP in Argentina, ANPD in Brazil, your EU Data Protection Authority, or the California Privacy Protection Agency).
Anti-Spam Policy
Athyna, Inc. is firmly opposed to the sending of unsolicited commercial email (spam). We do not send, and do not authorize any third party to send, unsolicited email messages that advertise, reference, or link to our website (athyna.com) or any of our services.
Our email communications are limited to:
- Newsletters and updates sent to individuals who have opted in to receive them.
- Transactional and operational messages sent to current clients or candidates in the context of an active business relationship.
We do not permit affiliates, partners, or any other third parties to advertise athyna.com through unsolicited messages.
If you believe you have received an unsolicited message that references athyna.com, please report it to hello@athyna.com so we can investigate and take appropriate action. This policy applies to all forms of electronic messaging, including email and newsletters.
Updates to This Policy
We may update this Privacy Policy periodically.Changes will be published with the updated “Last Updated” date and, where required, we will provide prominent notice or request renewed consent for material modifications.
At-a-Glance Summary (Non-Legal)
We operate a Website, Platform, and Global Job Board.
We do not request or process sensitive data. Our recruiting team uses AI-based tools to assist in analyzing profiles and role descriptions, relying on objective criteria such as validated skills, experience, education, certifications, and language level.
All decisions are made by people — the final hiring decision always belongs to our Clients. We do not use advertising cookies and we never sell or share personal data for cross-context behavioral advertising.
We do not create public profiles.
Talent data is shared only with Athyna’s verified Clients and never with third parties or external job boards.
You may access, correct, or delete your information at any time by contacting privacy@athyna.com.
We apply SOC 2-aligned technical and organizational security controls and comply with global privacy laws.
Glossary (Key Terms)
• Personal Data:
Information that identifies or can reasonably identify an individual.
• Sensitive Personal Data:
Data revealing health, biometric, political, religious, or sexual information, or other information classified as sensitive under applicable law.
• Artificial Intelligence (AI) Tools:
Internal systems that assist Athyna’s recruiters in analyzing professional profiles and role descriptions using objective criteria such as skills, experience, education, certifications, and language proficiency. These tools do not make automated decisions and are used solely to support human evaluation.
• Cookies:
Small files stored on a user’s device to enable essential website functionality and improve experience.
• Controller / Processor:
Legal roles defining who determines or executes personal data processing activities.
• Global Job Board:
Section of the Website displaying Athyna and third-party job opportunities.
• Third-Party Opportunities:
Job openings managed by external organizations, which process data independently under their own privacy policies.
