Privacy Notice – AI-Supported Member Interviews

Last updated: 7. October 2026

1. An Overview

General Information

This notice explains how we process your personal data when you, as a member of the XMGlobal Collaborative, take part in an interview with our AI interviewer and receive a personal growth plan. It supplements our general Privacy Policy and provides the information required under Articles 13 and 14 of the General Data Protection Regulation (GDPR).

Information About the Responsible Party ("Controller" in the GDPR)

The controller responsible for this data processing is:

Joint Controllers

For inviting you, conducting the interview and creating, reviewing and delivering your growth plan, unipro solutions and the XMGlobal Collaborative ([● address], USA) are joint controllers (Art. 26 GDPR). unipro solutions alone is responsible for analysing and pseudonymising your interview and for storing the results in its knowledge database.

Essence of our arrangement: The XMGlobal Collaborative invites you, provides the interview in its members area, reviews your growth plan and sends it to you. unipro solutions runs the AI interviewer, asks for your consent and drafts your growth plan. You can exercise your rights with either party. The central contact point is unipro solutions at info@unipro-solutions.com.

2. The Interview and Your Growth Plan

What the Interview Is

The interview is conducted by an AI interviewer – not a human. The AI interviewer asks about your professional situation, how you came to join the XMGlobal Collaborative and what you want to achieve. From your answers we create a personal growth plan that recommends suitable XMGlobal Collaborative resources. Participation is voluntary and is not a condition of your membership.

Purposes and Legal Basis

You give your consent by clicking “Agree” before the interview starts. We do not deliberately collect special categories of personal data (Art. 9 GDPR), such as health data or political or religious views. Please do not share them. If you mention them anyway, we do not use them for your growth plan.

Data We Process

• Identification: your first and last name, which you type into the chat at the start of the interview, and your country of residence.
• Professional context: role, career history, goals and challenges.
• Your experience with the XMGlobal Collaborative: reasons for joining, expectations, resources used, feedback.
• Technical data: conversation ID, date, time, duration and language of the interview.
• Derived data: interview summary, structured analysis and the recommendations in your growth plan.

Your spoken answers are converted to text during the conversation. No audio recording is stored, and your voice is not used to identify you.

How Your Data Is Processed

1. Interview: A voice AI platform conducts the conversation and creates a text transcript. AI language models generate the interview questions and a summary of the conversation.
2. Analysis: The transcript is transferred to our systems and analysed with the support of AI language models and a specialised analysis partner.
3. Pseudonymisation: Before the results are stored, your name is replaced by a pseudonym. Other details that could identify you – for example names of people or organisations, specific places or unique events – are removed or generalised.
4. Knowledge database: The pseudonymised results are stored in our knowledge database, hosted in Germany. The table that links your name to your pseudonym is kept separately and is accessible to two named persons at unipro solutions only.
5. Growth plan: We draft your growth plan with AI support from your own pseudonymised results and general patterns across interviews. Your name is added only to the final version. The XMGlobal Collaborative reviews every growth plan and sends it to you.

3. Recipients and Service Providers

Service Providers

We use service providers in the following categories. Model training on your data is disabled with every AI provider we use.

On request, we will tell you the specific providers that process your data (Art. 15 GDPR).

Data processing agreements

Our voice AI platform and our cloud database provider process your data on our behalf under a data processing agreement (Art. 28 GDPR). For the other providers, we are moving to business plans or contracts that include such an agreement.

XMGlobal Collaborative

The XMGlobal Collaborative, a non-profit organisation based in the USA, receives your growth plan to review it, sends it to you by e-mail and supports you with suitable programme resources. It has no access to your transcript, to the table linking your name to your pseudonym or to our knowledge database. We do not share your data with any other third parties, we do not use it in projects for other clients and we never use it for advertising.

Information on Data Transfer to the USA

Some providers process data in the USA. Where the recipient is certified under the EU-U.S. Data Privacy Framework, the transfer is based on the European Commission’s adequacy decision (Art. 45 GDPR). Otherwise it is based on the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR). You can request a copy of these safeguards at info@unipro-solutions.com.

The transfer of your growth plan to the XMGlobal Collaborative in the USA is based on your explicit consent (Art. 49(1)(a) GDPR), which you give by clicking “Agree” before the interview. Please note the risks of this transfer: the USA does not offer a level of data protection equivalent to the EU. US authorities may be able to access your data, and you may have fewer ways to enforce your rights there. You can withdraw this consent at any time with effect for the future.

4. Storage Duration and Security

Storage Duration

While your membership is active, the pseudonymised data can only be linked back to you with the separate table described above, which we protect by technical and organisational measures.

Security

• Our voice AI platform and our cloud database provider are certified to ISO/IEC 27001 and have SOC 2 Type II reports.
• Model training on your data is disabled with all AI providers we use.
• Your name is replaced by a pseudonym, and other identifying details are removed or generalised, before data is stored in the knowledge database.
• Access to transcripts, growth plans and the table linking names to pseudonyms is limited to the people who need it for the purposes described above.

5. Your Rights

Revocation of Your Consent to the Processing of Data

You can withdraw your consent at any time with effect for the future (Art. 7(3) GDPR), for example by writing to info@unipro-solutions.com. This shall be without prejudice to the lawfulness of any data processing that occurred prior to your revocation.

Your Rights as a Data Subject

Within the scope of the applicable statutory provisions, you have the right to:

• access your data (Art. 15 GDPR);
• have it rectified (Art. 16 GDPR);
• have it erased (Art. 17 GDPR);
• restrict its processing (Art. 18 GDPR);
• receive it in a portable format (Art. 20 GDPR);
• object to its processing (Art. 21 GDPR).

Please do not hesitate to contact us at any time at info@unipro-solutions.com if you want to exercise these rights or have questions about data protection.

Right to Log a Complaint with the Competent Supervisory Agency

You have the right to log a complaint with a data protection supervisory agency. The agency responsible for us is:

Use of AI and Automated Decisions

The interview is conducted by an AI system, and AI supports the analysis and the drafting of your growth plan. No decisions with legal or similarly significant effects are made about you solely by automated means (Art. 22 GDPR). A person at the XMGlobal Collaborative reviews every growth plan.

6. Changes to This Notice

We update this notice when our processing or service providers change. The current version is always available on this page.