Applies to: business.talentygo.com (the "Business Portal") and business users' interactions with TalentyGo

Effective date: August 22, 2026

Last updated: August 22, 2026

1. Scope of This Policy

1.1 This Privacy Policy explains how TalentyGo LLC, a a Wyoming limited liability company located at 30 N Gould St Ste N, Sheridan, WY 82801, USA ("TalentyGo," "we," "us," "our"), collects, uses, discloses, and protects personal information of business users — the individuals who register for, administer, or use the Business Portal on behalf of an employer (recruiters, hiring managers, administrators, and other authorized users) ("you").

1.2 What this policy does and does not cover. This policy addresses personal information about business users. It is not the candidate-facing privacy notice; personal information about candidates is addressed in the candidate privacy notice and in Section 8 below (which describes the roles of TalentyGo and employers with respect to candidate data). It also does not cover third-party websites or services (such as Stripe) that have their own privacy policies.

1.3 This policy incorporates disclosures required under the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), the California Online Privacy Protection Act ("CalOPPA"), and other applicable U.S. state privacy laws.

2. Personal Information We Collect

We collect the following categories of personal information about business users:

2.1 Information you provide:

Identifiers and account data: name, business email address, phone number, job title, employer/company name, username, and password.
Company/professional information: company details, department, role, hiring needs, job descriptions, and search criteria you enter.
Communications: messages you send through the platform, support requests, and correspondence with us.
Billing information (for paid Services): billing name, business address, and transaction records. Payment-card details are collected and processed directly by our payment processor, Stripe; we do not store full card numbers.

2.2 Information collected automatically:

Usage and device data: IP address, browser and device type, operating system, pages viewed, searches run, features used, referring/exit pages, timestamps, and log data.
Cookies and similar technologies: see Section 11.

2.3 Information from third parties:

Information from your employer (for example, when an administrator adds you as an authorized user), from identity/verification providers, from fraud-prevention tools, and from analytics providers.

2.4 Sensitive personal information. We do not intentionally collect "sensitive personal information" (as defined under CCPA/CPRA) about business users beyond account credentials. We do not use or disclose any sensitive personal information for purposes that would require an opt-out right under CCPA/CPRA.

3. How We Use Personal Information

We use business-user personal information to:

create, authenticate, and administer Accounts, and verify eligibility;
provide, operate, maintain, and improve the Services, including the Roster search and the AI Matching Engine features you use;
process payments, subscriptions, and one-time purchases, and manage billing (via Stripe);
communicate with you about your Account, transactions, security, and service-related and (where permitted) marketing messages;
personalize and analyze use of the Services and develop new features;
ensure security, prevent fraud and abuse, detect and stop scraping or unauthorized access, and enforce our Terms;
comply with legal obligations and respond to lawful requests; and
establish, exercise, or defend legal claims.

We use personal information consistent with the purposes described here and, where required, will obtain consent or provide additional notice.

4. How We Disclose Personal Information

We may disclose business-user personal information to:

Service providers / processors who perform services on our behalf (for example, cloud hosting, payment processing via Stripe, analytics, customer support, email delivery, security, and fraud prevention), bound by contract to use it only for our purposes;
Candidates, to the limited extent necessary to facilitate a consented interaction (for example, revealing that a named employer or recruiter has expressed interest);
Corporate transactions, in connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to this policy;
Legal and safety recipients, where necessary to comply with law, enforce our Terms, protect rights, safety, and property, or respond to lawful requests; and
Affiliates and advisors (auditors, lawyers, insurers) under confidentiality obligations.

We do not disclose business-user personal information to third parties for their own independent marketing without your consent.

5.1 Do Not Sell or Share My Personal Information. Under CCPA/CPRA, "sale" means disclosing personal information for monetary or other valuable consideration, and "sharing" means disclosing personal information for cross-context behavioral advertising.

5.2 Our practice. TalentyGo does not sell business users' personal information for money. (Whether any cookie-based advertising or analytics constitutes a sale or a share under applicable law is to be confirmed with counsel.) To the extent any use of advertising or analytics cookies is deemed a "sale" or "share" under applicable law, you may opt out.

5.3 How to opt out. You may exercise a "Do Not Sell or Share My Personal Information" request by emailing [email protected], and we honor recognized opt-out preference signals (such as the Global Privacy Control) where required. We do not knowingly sell or share personal information of individuals under 16.

6. Your Privacy Rights and How to Exercise Them

6.1 Rights. Depending on your state of residence, you may have the right to:

Know / access the categories and specific pieces of personal information we have collected;
Correct inaccurate personal information;
Delete personal information, subject to legal exceptions;
Opt out of "sale," "sharing," or targeted advertising (see Section 5);
Limit the use of sensitive personal information (we do not use it in ways triggering this right);
Data portability; and
Non-discrimination for exercising your rights.

6.2 How to submit a request. Submit requests to [email protected] (an online privacy request form is in the process of being made available). We will verify your identity before responding and will respond within the timeframes required by applicable law (generally 45 days under CCPA/CPRA, extendable as permitted).

6.3 Authorized agents. You may use an authorized agent to submit a request, subject to verification and proof of authorization.

6.4 Appeals. Where required (for example, under Virginia and Colorado law), if we decline your request you may appeal by contacting [email protected]; we will respond within the statutory period.

6.5 Business-context note. Some rights and disclosures apply differently to information processed in a business-to-business or employment context; we handle each request in accordance with applicable law.

7. Data Retention

7.1 We retain personal information for as long as needed to provide the Services, maintain your Account, comply with legal, tax, and accounting obligations, resolve disputes, and enforce our agreements. Retention periods vary by data type and purpose. When information is no longer needed, we delete, de-identify, or anonymize it. Upon deletion of your Account, we remove business-user personal information within 30 days, except where longer retention is required for legal, tax, or billing purposes. (A detailed retention schedule is to be confirmed with counsel.)

8. Employer Responsibilities and the Roles of the Parties Regarding Candidate Data

8.1 Distinct roles. TalentyGo operates the platform and maintains the anonymized Roster. When an employer accesses, receives, or uses candidate personal information through the Business Portal, the employer acts as an independent business/third party (and, where applicable, a separate controller/business under applicable privacy law) and is solely responsible for its own lawful handling of that candidate data. TalentyGo is not responsible for an employer's independent use of candidate data.

8.2 Consent-gated candidate contact. Candidate profiles are displayed in anonymized form (names and employers masked) until the candidate consents. Employers may unmask and contact a candidate only where the candidate has consented through the platform, and must not attempt to de-anonymize or contact candidates outside that workflow.

8.3 Employer obligations. Employers must, among other things: use candidate data only for legitimate recruiting purposes; comply with all applicable privacy laws (including CCPA/CPRA and other state laws); provide their own required notices and honor candidate rights; maintain reasonable security safeguards; not sell/share candidate data or use it for advertising or model training; not retain candidate data longer than necessary; and comply with EEO/anti-discrimination and FCRA obligations. These obligations are detailed in the Terms of Service (Sections 5–6).

8.4 Data Processing Addendum (DPA). Where TalentyGo processes personal data on an employer's behalf, or where otherwise required by applicable law, the parties' respective data-protection roles and safeguards are set out in the Data Processing Addendum (available on request at [email protected]), incorporated by reference into the Terms of Service. Employers that require a signed DPA may contact [email protected].

9. Security

9.1 We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information (for example, encryption in transit, access controls, and monitoring). However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for safeguarding your credentials and for the security of data you export from the Services. We will notify affected parties and authorities of security incidents as required by applicable law.

10. International Users

10.1 The Services are intended for the U.S. market and are operated from the United States (data-hosting location(s) to be confirmed). If you access the Services from outside the United States, you understand that your information will be processed in the United States and other jurisdictions that may not provide the same level of data protection as your home jurisdiction. The operator, TalentyGo LLC, is a U.S. (Wyoming) company; its representative in the EU/EEA under Article 27 GDPR is in the process of being appointed (contact [email protected]). If you are subject to EU/EEA or other non-U.S. law, additional terms and transfer mechanisms may apply; contact [email protected].

11. Cookies and Tracking Technologies

11.1 We and our providers use cookies and similar technologies to operate the Services, remember preferences, provide security, and analyze usage. You can manage cookies through your browser settings and, where offered, through our cookie controls. For details, see our cookie policy (in the process of being published). Where required, we present a cookie consent/preference tool and honor opt-out preference signals. Certain cookies are strictly necessary and cannot be disabled without affecting functionality.

12. Children's Data

12.1 The Business Portal is intended solely for businesses and their adult authorized personnel and is not directed to children. We do not knowingly collect personal information from individuals under 18. If we learn we have collected such information without appropriate authority, we will delete it. Candidate-side eligibility (minimum age for candidates) is addressed in the candidate terms and notice.

13. State-Specific Disclosures

13.1 The 50-state patchwork. U.S. privacy obligations vary by state, and the number of comprehensive state privacy laws continues to grow. The disclosures below highlight key regimes; other states (for example, Connecticut, Utah, Texas, Oregon, Montana, and others) have or are enacting comparable laws, and we honor rights required by the law applicable to you.

13.2 California (CCPA/CPRA and CalOPPA).

Categories collected/disclosed: identifiers, commercial information, internet/network activity, professional/employment information, and inferences (see Sections 2 and 4). We disclose these categories to service providers for business purposes as described above.
Sources, purposes, and disclosures: as described in Sections 2–4.
Sale/Share: see Section 5.
Rights: to know, delete, correct, opt out of sale/sharing, limit sensitive PI, and non-discrimination (Section 6).
CalOPPA: we disclose how we respond to browser Do-Not-Track signals — we do not currently respond to DNT signals but honor recognized opt-out preference signals such as the Global Privacy Control. Third parties may collect information over time and across sites as described in Section 11.
Shine the Light: California residents may request information about disclosures to third parties for their direct marketing; we do not make such disclosures.

13.3 Virginia (VCDPA). Virginia residents have rights to access, correct, delete, obtain a copy of, and opt out of targeted advertising, sale, and certain profiling; and to appeal (Section 6.4).

13.4 Colorado (CPA). Colorado residents have rights to access, correct, delete, data portability, and to opt out of targeted advertising, sale, and certain profiling; we honor universal opt-out mechanisms as required and provide an appeal process (Section 6.4).

13.5 Other states. Residents of other states with comprehensive privacy laws have rights consistent with those laws; contact us at [email protected] to exercise them.

14. Changes to This Policy

14.1 We may update this Privacy Policy from time to time. Material changes will be communicated (for example, by email or in-portal notice), and we will update the "Last updated" date. Your continued use of the Services after the effective date constitutes acceptance of the updated policy.

15. Contact Us

For privacy questions or to exercise your rights:

TalentyGo LLC — Privacy Team

30 N Gould St Ste N, Sheridan, WY 82801, USA

Privacy inquiries: [email protected]

General/legal inquiries: [email protected]

Privacy request form: in the process of being made available