Mokka | Privacy Policy for Customers

Last Updated: January 27, 2026

Introduction

Welcome to Mokka. "Mokka," "we," "our," or "us" refers to Mokka Labs Ltd. and its affiliates. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information provided by recruiters, hiring managers, and other representatives of our customers ("you" or "your") who use our services. It is distinct from our Candidate Privacy Policy, which addresses the handling of personal data for job applicants. By using our services or interacting with us, you agree to the practices described in this Privacy Policy.

1. Information We Collect We collect and process the following personal information from customer representatives:

• Personal Identification Information: Name, email address, job title, and company affiliation.
• Account Information: Username, password, and other authentication credentials.
• Technical Data: IP address, device information, browser type, operating system, and usage logs.
• Communication Data: Records of communications with Mokka, including emails, support inquiries, and feedback.
• Marketing Preferences: Information on your preferences for receiving marketing communications.
• Cookies and Tracking Technologies: Data collected through cookies and similar technologies, as described in our Cookie Policy.

2. How We Use Your Information We use your personal information for the following purposes:

• To Provide Services: Facilitate access to and use of our platform, including account creation, user authentication, and service functionality.
• To Communicate with You: Send system-related communications, such as account notifications, updates, and customer support responses.
• To Improve Our Services: Analyze usage data to enhance service features, functionality, and performance.
• To Market Our Services: Send you promotional materials or newsletters about our services, where permitted by law and based on your preferences.
• To Ensure Compliance and Security: Monitor platform activity to detect fraud, unauthorized access, or violations of our Terms and Conditions.

3. Legal Basis for Processing For users in the European Economic Area (EEA), we process your personal data based on the following legal grounds:

• Contractual Necessity: To provide and manage your access to our services.
• Legitimate Interests: For service improvement, marketing communications, and security purposes.
• Consent: For marketing activities requiring explicit consent under applicable laws.
• Compliance with Legal Obligations: To meet regulatory or legal requirements.

4. Sharing Your Information We do not sell or share your personal information with third parties, except as described below:

• Service Providers: Trusted third parties who provide infrastructure, analytics, communication, or other operational support for our platform. We do not share your personal information with AI model providers for training their models.
• Compliance with Laws: When required by law, court order, or regulatory obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

5. Data Retention We retain your personal information as long as necessary to fulfill the purposes outlined in this Privacy Policy, including:

• Account Data: Retained for the duration of your account with Mokka.
• Communication Records: Retained for the duration necessary for customer support, service improvement, and legal compliance purposes, typically aligned with your account retention.
• Technical Data: Retained for the duration necessary for service security, functionality, and compliance purposes, typically aligned with your account retention.

Zero Data Retention (ZDR): Mokka does not store any customer data on any external AI model provider's servers after processing. Any data processed by third-party AI model services is used strictly for real-time inference and is not retained by those services.

Upon termination of the retention period, we securely delete or anonymize your data. If you request deletion of your data, we will honor the request in compliance with applicable laws.

6. Cookies and Tracking Technologies We use cookies and similar technologies to enhance your experience and analyze usage of our platform. For more information, please review our Cookie Policy.

7. Data Security We implement industry-standard security measures to protect your personal information from unauthorized access, use, or disclosure. This includes encryption, access controls, and regular security audits. While we strive to protect your data, no system can guarantee absolute security.

8. Your Rights Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Access: Request access to the personal data we hold about you.
• Correction: Request correction of inaccurate or incomplete data.
• Deletion: Request deletion of your personal data, subject to legal or contractual obligations.
• Objection: Object to the processing of your personal data for certain purposes.
• Data Portability: Request a copy of your data in a structured, machine-readable format.
• Withdrawal of Consent: Withdraw consent for marketing communications or other activities based on consent.

To exercise your rights, you can contact us via:

• Email: privacy@gomokka.com
• In-app chat support: Available via the chat widget on our website or within the application

We will respond within the timeframes required by applicable laws.

9. International Data Transfers For users outside Cyprus, your data may be transferred to and processed in jurisdictions with different data protection laws. In such cases, we ensure appropriate safeguards, such as Standard Contractual Clauses, are in place to protect your information.

10. Changes to This Privacy Policy We may update this Privacy Policy periodically to reflect changes in our practices or legal obligations. Significant changes will be communicated through email or platform notifications. The "Last Updated" date will indicate the most recent revisions.

11. Contact Us For questions or concerns about this Privacy Policy, or to exercise your rights, please contact us:

Mokka Labs Ltd Email: privacy@gomokka.com Address: 28 October Avenue 367, Mediterranean Court, 1st Floor, Office A5, Limassol, Cyprus, 3107

Appendix: Amendment Template for Customer Policies

Last Updated: December 13, 2024

To ensure transparency and compliance with data protection laws, the following text can be incorporated into your company's Privacy Policy, Terms and Conditions, and Subprocessor List to reflect Mokka's role as a data processor.

1. Privacy Policy Clause

Use of Mokka for Candidate Assessments

We use Mokka Labs Ltd and its affiliates ("Mokka"), an AI-powered talent assessment provider, to process candidate applications and evaluate suitability for roles. Mokka acts as a data processor on our behalf and processes candidate data strictly in accordance with our instructions and applicable data protection laws, including GDPR. Mokka does not use candidate data for any purposes beyond the assessment services provided to us. For more details on Mokka's processing practices, please contact us or refer to their Privacy Policy at https://gomokka.com/privacy-policy.html.

2. Terms and Conditions Clause

Third-Party Assessment Services

We partner with Mokka Labs Ltd ("Mokka") to facilitate AI-powered assessments for candidates. By applying for a role with us, you acknowledge that your assessment data may be processed by Mokka on our behalf. Mokka operates as a data processor under GDPR and adheres to strict security and compliance standards. Any requests regarding your personal data should be directed to us, as we remain the primary data controller.

3. Subprocessor List Entry

For any questions regarding these clauses or how Mokka processes candidate data, please contact us at privacy@gomokka.com.