Data Processing Agreement
GDPR-compliant data processing terms.
1. Controller and Processor Roles
In the context of this agreement, the Customer acts as the Data Controller — the entity that determines the purposes and means of processing personal data of candidates and employees. Proba Technologies, Inc. acts as the Data Processor, processing personal data solely on the documented instructions of the Controller and in accordance with GDPR Article 28. Proba will not process Controller data for any purpose other than providing the contracted services.
2. Processing Purposes and Scope
Proba processes personal data for the following purposes: conducting AI-assisted assessments, language tests, and structured interviews on behalf of the Controller; generating evaluation scores and reports; storing candidate responses and recordings as directed by the Controller; and providing analytics and usage reporting. Processing occurs only for the duration of the agreement and within the geographical regions specified in the Controller's account settings.
3. Sub-processors
Proba relies on a limited set of vetted sub-processors to deliver its services, including cloud infrastructure providers and AI model providers. A current list of sub-processors is maintained and made available to customers upon request. Proba will provide at least 30 days' notice before adding or replacing a sub-processor, giving Controllers the opportunity to object. All sub-processors are bound by data protection obligations equivalent to those set out in this DPA.
4. Data Subject Rights
Proba will assist the Controller in fulfilling its obligations to respond to data subject requests under GDPR Chapter III, including rights of access, rectification, erasure, portability, and objection. Where a data subject contacts Proba directly, Proba will promptly redirect the request to the Controller. Controllers may submit erasure or export requests via the platform settings or by emailing privacy@proba.ai.
Enterprise customers requiring a countersigned DPA should contact legal@proba.ai.