Privacy Policy

HireClarity, Inc. (“HireClarity”, “we”, “us”, or “our”) operates a one-way video interview platform used by organizations (“Tenants”) to screen job candidates. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information when you use our website, platform, and related services (collectively, the “Services”).

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our policies and practices, please do not use the Services.

For purposes of this Privacy Policy:

• “Tenant Data” means any information submitted to the Services by or on behalf of a Tenant, including job postings, interview questions, candidate responses, evaluations, and account information. • “Candidate Data” means personal information of individuals applying for positions through a Tenant’s use of the Services, including video recordings, resumes, contact details, and assessment results. • “User Data” means information about individuals who create or manage accounts on behalf of a Tenant, including recruiters, hiring managers, and administrators. • “Controller” means the natural or legal person who determines the purposes and means of processing personal data. For Candidate Data, the Tenant is typically the Controller and HireClarity acts as a Processor. • “Processor” means a natural or legal person who processes personal data on behalf of the Controller.

We collect information in the following categories:

A. Information You Provide Directly • Account Information: name, email address, company name, job title, phone number, and billing information when you register for a Tenant account. • Candidate Submissions: when Candidates participate in video interviews, we collect video recordings, audio, responses to questions, uploaded resumes, and contact information. Tenants control which questions are asked and what information is requested. • Communications: information you provide when contacting our support team, participating in surveys, or corresponding with us.

B. Information We Collect Automatically • Usage Data: IP address, browser type, device identifiers, operating system, access times, pages viewed, clicks, and navigation paths. • Log Data: error logs, performance data, and system activity related to your use of the Services. • Cookies and Similar Technologies: we use cookies, local storage, and similar technologies to maintain sessions, remember preferences, analyze usage, and improve the Services. See Section 10 (Cookies) for details.

C. Information from Third Parties • We may receive information from single sign-on (SSO) providers (e.g., Google Workspace, SAML identity providers) when you authenticate through them, limited to the name, email, and profile information you authorize. • We do not purchase personal information from data brokers or third-party data vendors.

We use the information we collect for the following purposes:

A. Providing and Operating the Services • Hosting, maintaining, and improving the platform. • Processing and storing video interviews and candidate responses on behalf of Tenants. • Generating AI-powered insights, summaries, and transcripts from video interviews as requested by Tenants. • Facilitating collaboration among Tenant users (sharing candidate reviews, comments, and ratings).

B. Billing and Administration • Processing payments and invoices. • Managing subscriptions, usage limits, and account access. • Sending service-related notices, including security alerts and administrative messages.

C. Security, Compliance, and Enforcement • Detecting, preventing, and responding to fraud, abuse, security risks, and technical issues. • Complying with legal obligations, court orders, and lawful requests from government authorities. • Enforcing our Terms of Service and other agreements.

D. Communications (with consent where required) • Sending product updates, marketing communications, and promotional offers (you may opt out at any time). • Conducting research and surveys to improve our Services.

E. Aggregated and De-Identified Data • We may aggregate or de-identify data so that it no longer identifies any individual. We may use and disclose such data for any lawful purpose, including product development, research, and industry benchmarking.

A. Tenant as Controller; HireClarity as Processor For Candidate Data and Tenant Data, the applicable Tenant is the Controller, and HireClarity acts as a Processor. We process such data only on documented instructions from the Tenant, as set forth in our Terms of Service and any applicable Data Processing Addendum (DPA). Tenants are responsible for providing appropriate privacy notices to Candidates and obtaining necessary consents.

B. Candidate Awareness If you are a Candidate, your relationship is primarily with the Tenant organization that invited you to interview. That organization controls: • The questions asked in the interview. • Who can view your responses. • How long your data is retained. • Whether AI analysis is applied to your video.

HireClarity processes Candidate Data according to the Tenant’s instructions and our contractual obligations. If you have questions about how a specific Tenant uses your data, please contact that organization directly.

C. Data Subject Rights Requests from Candidates If you are a Candidate and wish to exercise rights such as access, correction, or deletion, we will forward your request to the relevant Tenant. Because Tenants control the data, we cannot directly fulfill most Candidate requests without the Tenant’s instruction.

We do not sell, rent, or trade personal information. We disclose information only in the following limited circumstances:

A. With Your Consent or at Your Direction • We share Candidate Data and Tenant Data as directed by the applicable Tenant user (e.g., sharing a candidate profile with a hiring manager within the Tenant’s account).

B. Service Providers and Sub-Processors • We engage trusted third-party service providers to perform functions on our behalf, such as cloud hosting, payment processing, email delivery, analytics, and customer support. These providers have access to personal information only to perform these tasks and are contractually obligated to protect it. • A list of our sub-processors is available upon request and is updated periodically.

C. Legal Compliance and Protection • We may disclose information if required to do so by law, regulation, court order, or governmental request. • We may disclose information when we believe in good faith that disclosure is necessary to protect our rights, investigate fraud, respond to a safety emergency, or enforce our agreements.

D. Business Transfers • If HireClarity is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, information may be transferred or shared as part of that transaction. We will notify you of any change in ownership or use of your personal information.

A. Tenant-Controlled Retention Tenants control the retention period for Candidate Data and Tenant Data within their accounts. A Tenant may delete data at any time. Upon deletion by the Tenant, we remove the data from active systems within 30 days and from backups within 90 days, unless legal obligations require longer retention.

B. HireClarity-Determined Retention We retain account and billing information for as long as the Tenant’s account is active and for a reasonable period thereafter to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce agreements. Typically, this period is 7 years from the date of last account activity.

C. Deletion Requests When a Tenant terminates its account, we will delete or de-identify Tenant Data and Candidate Data within 90 days, except where we are required to retain it by law or for legitimate business purposes (such as fraud prevention or financial record-keeping).

We implement appropriate technical and organizational measures to protect personal information against unauthorized access, alteration, disclosure, or destruction:

• Encryption: All data is encrypted in transit using TLS 1.2 or higher. Stored video files and sensitive data are encrypted at rest using AES-256. • Access Controls: Role-based access controls restrict who can view, modify, or delete data within a Tenant account. • Infrastructure: Our platform is hosted on SOC 2 Type II certified cloud infrastructure with geographically distributed, redundant data centers. • Monitoring: We maintain intrusion detection, automated vulnerability scanning, and 24/7 security monitoring. • Incident Response: We have a documented incident response plan and will notify affected Tenants and relevant authorities of any data breach in accordance with applicable law.

No method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect personal information, we cannot guarantee absolute security.

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you. • Correction: Request that we correct inaccurate or incomplete information. • Deletion: Request deletion of your personal information, subject to legal exceptions. • Portability: Request transfer of your personal information to another service provider in a structured, machine-readable format. • Restriction: Request that we restrict processing of your personal information. • Objection: Object to processing based on legitimate interests or direct marketing. • Withdraw Consent: Where processing is based on consent, withdraw consent at any time.

If you are a Candidate, we may need to refer your request to the relevant Tenant, as they control the data. To exercise your rights, contact us at privacy@hireclarity.com. We will respond within the timeframes required by applicable law (typically 30 days).

We use cookies and similar tracking technologies to operate and improve the Services:

• Essential Cookies: Required for authentication, security, and core platform functionality. These cannot be disabled. • Analytics Cookies: Help us understand how visitors interact with the site (e.g., Google Analytics, Mixpanel). These are used in aggregated form. • Preference Cookies: Remember your settings and preferences (e.g., language, display options).

You can control cookies through your browser settings. Disabling certain cookies may limit functionality. We do not use tracking technologies to collect Candidate Data without the Tenant’s configuration.

HireClarity is headquartered in the United States. We and our service providers may process, transfer, and store information in the United States and other countries that may not have data protection laws equivalent to those in your jurisdiction.

When we transfer personal data from the European Economic Area (EEA), United Kingdom, or Switzerland to the United States, we rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by the European Commission, adequacy decisions, or other legally recognized transfer mechanisms. We ensure that our sub-processors provide the same level of protection.

The Services are not intended for children under the age of 16. We do not knowingly collect personal information from children under 16. If we learn that we have collected personal information from a child under 16, we will delete that information promptly. If you believe we may have information from a child under 16, please contact us at privacy@hireclarity.com.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or industry standards. We will post the revised policy on this page with an updated “Last Updated” date. For material changes, we will notify Tenants by email or through the platform at least 30 days before the changes take effect. Your continued use of the Services after the effective date constitutes acceptance of the revised policy.

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us:

HireClarity, Inc. Attn: Data Protection Officer Email: privacy@hireclarity.com Address: [Business Address]

For data protection inquiries from the EEA or UK, our representative may be contacted at the same email address.

We are committed to resolving complaints and will respond to all inquiries within the timeframes required by applicable law.