1. Scope of this Policy

This Privacy Policy explains how HireFoundry (“HireFoundry,” “we,” “us”) collects, uses, discloses, and protects information in connection with the HireFoundry hiring platform (the “Services”), including our website, our software, and the interactions candidates have with our AI-assisted interview and screening tools.

This Policy describes our practices toward two different groups, and the rights and disclosures differ depending on which group applies to you:

• Customer Users: individuals who access the Services on behalf of an employer or staffing agency that has purchased a HireFoundry subscription (an “Authorized User”).
• Candidates: individuals who apply for or are considered for a role with a company that uses HireFoundry, and whose information is processed through the Services as part of that hiring process.

For Candidate information, our customer, the hiring employer, decides what information is collected and how it is used; we process it on their instructions as described in Section 3. If you are a Candidate and have a question about a specific hiring decision, [the employer you applied to] is generally the right first point of contact, though Section 8 below explains the rights you can also exercise directly with us.

2. Information We Collect

2.1 Information from Customer Users

• Account information: name, work email, job title, and company, provided when a Customer creates an Authorized User account.
• Usage data: how Authorized Users interact with the Services, including pages viewed, features used, and configuration choices such as custom scoring criteria.
• Billing information: for paid subscriptions, billing contact and payment details, processed through our payment processor.

2.2 Candidate Data

Candidate Data is submitted by or on behalf of a Candidate during the hiring process, or generated by the Services while assisting a human reviewer in evaluating a Candidate. It may include:

• Application materials: resume, cover letter, and answers to application questions.
• Interview data: audio, video, and transcripts of interviews conducted or assisted by the Interview Agent, and any notes a recruiter adds.
• Output generated by the Services: for example, a Candidate Shortlisting Agent score against a role’s custom criteria, a Pacing and Signal Agent note about interview coverage, or a Candidate Trust Agent flag comparing application and interview information.
• Identity and eligibility information, where the specific agent or feature requires it (for example, information used by an Identity and Profile Validation capability, where enabled by the employer).

We do not use Candidate Data for emotion recognition. The Services do not infer a Candidate’s emotional state from facial expression, tone, or similar biometric-adjacent signals, consistent with the EU AI Act’s prohibition on emotion recognition in the workplace, and we do not offer that capability regardless of jurisdiction.

2.3 Information Collected Automatically

• Device and log information: IP address, browser type, and access timestamps, collected for security and service reliability.
• Cookies and similar technologies, as described in our [Cookie Policy, if maintained separately].

3. How We Use Information

We use information to: provide and maintain the Services; support and troubleshoot; secure the platform against fraud and unauthorized access; improve the Services, including the accuracy of Output, in the aggregate and de-identified manner described in Section 3.4; comply with legal obligations; and communicate with Customer Users about their account.

3.1 Candidate Data Is Processed on the Employer’s Instructions. We process Candidate Data as a processor (or service provider, under applicable US state law) acting on the documented instructions of the employer that is our Customer. We do not sell Candidate Data, and we do not use Candidate Data to build profiles of a Candidate for any purpose unrelated to the hiring process for which it was submitted.

3.2 No Automated Final Decisions. HireFoundry’s Services are built so that Output, including any score, flag, or recommendation, is decision support for a human reviewer employed by our Customer. HireFoundry does not itself make hiring decisions, and the Services are not intended to be configured to auto-reject or auto-advance a Candidate without human review. See Section 4 for what this means in practice by jurisdiction.

3.3 Model Improvement. Where an employer permits it in their Order Form, we may use Candidate Data in aggregated, de-identified form to improve the accuracy and reliability of the Services. De-identified data used this way cannot reasonably be used to re-identify a Candidate, and is never shared across employers in a form that reveals one employer’s hiring activity to another.

3.4 Retention. We retain Candidate Data for the period specified by the employer, or [default retention period, e.g., 24 months from the close of the requisition] if the employer does not specify one, after which it is deleted or de-identified, except where a Candidate has exercised a deletion right under Section 8, or where longer retention is required by law (for example, recordkeeping obligations under Illinois HB 3773).

4. AI Use and Automated Processing Disclosures

Because HireFoundry’s Services use AI to support hiring decisions, this section explains, in plain terms, what that means and what rights it creates. Requirements vary by where a Candidate is located and where the role is based, and our customers, not HireFoundry, are generally responsible for delivering the candidate-facing notices below, since they are the employer of record. We provide this section so Candidates understand what the technology does, and so our customers have accurate language to build from.

4.1 What Our Agents Do

• Interview Agent generates and adjusts interview questions in real time and supports the interviewer with follow-up prompts.
• Candidate Shortlisting Agent evaluates applications against criteria the employer configures for a specific role and produces a shortlist recommendation.
• Pacing and Signal Agent tracks interview time and question coverage and surfaces what remains to be asked.
• Candidate Trust Agent compares information across resume, application, and interview and flags inconsistencies for human review, without producing a single combined score.

4.2 Notice Where Required by Law

If you are applying for a role based in New York City and an employer uses the Services in a way that qualifies as an automated employment decision tool under NYC Local Law 144, the employer is responsible for the annual independent bias audit, public summary, and advance candidate notice that law requires.

If you are applying for a role based in Illinois and are asked to complete a video interview that HireFoundry’s Interview Agent analyzes, the Illinois Artificial Intelligence Video Interview Act requires the employer to notify you before the interview, explain in general terms what the AI evaluates, and obtain your consent. You may request deletion of your interview video, and the employer (with our cooperation as their processor) must delete all copies, including any copies we hold, within 30 days of that request.

If you are applying for a role based in Colorado, California, or the European Union, additional disclosure, human-review, or automated-decision rights may apply under Colorado’s automated-decision employment law, the CCPA/CPRA’s automated decision-making technology rules, or the EU AI Act’s high-risk employment provisions, respectively. These frameworks are evolving; the EU AI Act’s employment deadline, for one example, has moved during 2026 and should be confirmed against its current status.

4.3 Your Right to Human Review

Regardless of jurisdiction, if a decision affecting you was informed by Output from the Services, you may ask the employer you applied to for human review of that decision. HireFoundry’s Services are designed to make that request straightforward to honor, since a human reviewer is always part of the process by design, not an exception to it.

5. How We Share Information

• With the Customer (employer): Candidate Data is shared with the employer who initiated the hiring process, and with Authorized Users at that employer involved in the relevant requisition.
• With service providers: vendors who help us operate the Services (for example, cloud hosting, and, where applicable, an independent AI bias auditor engaged by a Customer), bound by confidentiality and data protection obligations at least as protective as this Policy.
• For legal reasons: where required to comply with law, respond to a valid legal process, or protect the rights, property, or safety of HireFoundry, our Customers, or Candidates.
• In a business transfer: if HireFoundry is involved in a merger, acquisition, or asset sale, information may be transferred as part of that transaction, subject to this Policy or a successor policy of at least equivalent protection.

We do not sell Candidate Data, and we do not share Candidate Data across unrelated employers.

6. Data Security

We maintain administrative, technical, and physical safeguards designed to protect information against unauthorized access, disclosure, alteration, or destruction, described further in our [Security Overview / Trust Center]. No system is completely secure, and we encourage Customer Users to use strong, unique passwords and enable any available multi-factor authentication.

7. International Data Transfers

HireFoundry is based in [United States / jurisdiction]. Where we process personal information originating in the European Economic Area, United Kingdom, or other regions with data transfer restrictions, we rely on appropriate safeguards such as Standard Contractual Clauses, as described in our Data Processing Addendum.

8. Your Privacy Rights

Depending on where you live and your relationship to the Services, you may have some or all of the following rights. To exercise them, contact us using the information in Section 11, or contact the employer who initiated your application if your request relates specifically to a hiring decision.

8.1 General Rights

• Access: request a copy of the personal information we hold about you.
• Correction: request that we correct inaccurate information.
• Deletion: request deletion of your information, subject to legal retention requirements.
• Portability: request your information in a portable format, where applicable.

8.2 California (CCPA/CPRA)

California residents have the rights above, plus the right to know the categories of personal information collected and disclosed, the right to opt out of certain uses of automated decision-making technology for significant decisions such as employment, and the right to non-discrimination for exercising these rights. We do not sell or share personal information for cross-context behavioral advertising.

8.3 Illinois

If your video interview was analyzed by our Interview Agent, you have the right to request deletion of the interview video, and we will delete all copies, including those in our possession as the employer’s processor, within 30 days of a valid request.

8.4 European Economic Area, United Kingdom, and Similar Frameworks

If GDPR or a similar framework applies to you, you additionally have the right to object to certain processing, the right to restrict processing, and the right to lodge a complaint with your local supervisory authority. Where a decision is based solely on automated processing and produces a legal or similarly significant effect, you have the right not to be subject to that decision without human intervention; consistent with Section 4.3, HireFoundry’s Services are designed so this scenario should not arise, since human review is built into the process.

8.5 Other US States

[List additional applicable state privacy laws, e.g., Virginia, Colorado, Connecticut, and their specific opt-out or appeal rights, once the Customer base and hiring footprint are known.]

9. Children’s Privacy

The Services are intended for use by adults in a professional hiring context and are not directed to children. We do not knowingly collect personal information from children under 16.

10. Changes to this Policy

We may update this Policy from time to time. If we make a material change, we will provide notice as required by law, for example by posting an update with a new effective date, and, where required, by additional notice to affected Candidates or Customers.

11. Contact Us

If you have questions about this policy or want to exercise a privacy right, contact us at [privacy@hirefoundry.ai. If your question concerns a specific hiring decision, we may direct you to the relevant employer, who is best positioned to address it.

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