Applies to residents of the United States, including California (CCPA as amended by the CPRA), Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Delaware, New Jersey, New Hampshire, Kentucky, Rhode Island, Minnesota, Maryland, Indiana and Tennessee, in addition to the Privacy Policy.
Most of what HR Assist processes about a candidate is processed as a service provider on a customer's instructions; the customer is the business that decides why the data is collected. Where a candidate exercises a right, we forward the request to the customer within five business days and help it respond. The disclosures below cover both the data we collect as a business (about workspace users) and the data we process as a service provider (about candidates).
1. Notice at collection (Cal. Civ. Code §1798.100(b))
| Category (§1798.140(v)) | Examples | Source | Purpose | Retention |
|---|---|---|---|---|
| Identifiers | Name, email, phone, account ID, IP address | You, your administrator, the recruiting customer | Operate the account; deliver messages; security | Life of the account plus 30 days; candidates, under the customer's control |
| Personal records (§1798.80(e)) | Résumé, employment and education history | The candidate or the customer | Match to a role; AI-assisted scoring reviewed by a person | Under the customer's control |
| Professional or employment information | Job title, organisation, interview outcomes, notes | You, the customer | Recruitment | Under the customer's control |
| Internet or network activity | Sign-in events, user agent, activity in the test room (tab switches, pastes) | Your device | Security; integrity of the test | Security logs 12 months; test activity with the test record |
| Audio, electronic or visual information | Interview recordings and transcripts; webcam still frames, audio clips and screenshots at flagged moments in a proctored test | The customer's meeting; the candidate's device after explicit consent | Interview write-up; evidence for a human reviewer | With the interview or test record; deletable by the customer |
| Sensitive personal information (§1798.140(ae)) | Biometric processing of the face on the candidate's own device; account credentials | The candidate; you | Presence and attention checks during a proctored test only; authentication | Face analysis is discarded at the end of the sitting; no template is stored |
| Inferences | Fitment score, interview score, proctoring risk signal, joining-risk score | Derived | Decision support for a person | With the candidate record |
| Commercial information | Plan, invoices | The customer's administrator | Billing | As tax law requires |
We do not collect precise geolocation, and we do not collect any category not listed above.
2. We do not sell or share personal information
We do not sell personal information and do not share it for cross-context behavioural advertising, and have not done so in the preceding twelve months. We do not use or disclose sensitive personal information for any purpose other than those permitted by §7027(m) of the CCPA regulations (providing the Service, security, integrity). Because there is no sale or sharing, a "Do Not Sell or Share My Personal Information" request changes nothing, but we accept it at privacy@axionconnect.com and record it against your account.
3. Limit the use of my sensitive personal information
We use sensitive personal information only as necessary to provide the Service a candidate or customer asks for. You may still submit a "Limit the Use of My Sensitive Personal Information" request to privacy@axionconnect.com; we record it and confirm that no further limitation is needed.
4. Global Privacy Control
Our servers read the Sec-GPC request header on every request and treat it as a valid opt-out of sale, sharing and targeted advertising under the California regulations (§7025), Colorado and Connecticut law. Since we do none of those, the signal is honoured by recording it.
5. Your rights
- Know the categories and specific pieces of personal information collected, the sources, purposes and recipients.
- Delete personal information we collected from you, subject to the exceptions in §1798.105(d).
- Correct inaccurate personal information.
- Opt out of sale, sharing and targeted advertising (we do none; the right is acknowledged).
- Limit the use of sensitive personal information.
- Portability — receive your information in a portable, machine-readable format.
- Opt out of profiling in furtherance of decisions with legal or similarly significant effects (Colorado, Connecticut, Virginia and others). The Service makes no such decision by itself; a person reviews every score.
- Non-discrimination — we will not deny service, charge differently or provide a lesser service because you exercised a right.
- Appeal a refusal, where your state provides for it, by replying to our decision; we answer the appeal within the period your state's law sets and tell you how to contact your attorney general.
Send a request to privacy@axionconnect.com. We verify it against the contact details on the account or, for a candidate, through the recruiting customer; an authorised agent must provide signed authority and we may ask the person to confirm. We respond within 45 days, extendable once by 45 days with notice. Candidates' requests go to the customer, which controls the data.
6. Automated decision-making technology
AI-assisted scores, transcripts and proctoring signals are decision support. The Service is built so that a person reviews them and makes the hiring decision, and it does not reject a candidate on its own. Where the CPPA's automated decision-making technology regulations, New York City Local Law 144, the Illinois Artificial Intelligence Video Interview Act, Colorado SB 24-205 or a similar law requires notice, a bias audit or an opt-out before an automated tool is used in hiring, the recruiting customer is responsible for providing it, and we supply the model, prompt-version and score-provenance information a bias audit or explanation needs.
7. Biometric laws (Illinois BIPA, Texas CUBI, Washington)
Webcam proctoring analyses face geometry on the candidate's own device to check presence and attention. No face template is stored, no identification against a database is performed, and nothing is captured until the candidate ticks each statement on the consent screen. Whether that processing is a biometric identifier under Illinois, Texas or Washington law depends on facts the customer controls; the customer must not enable proctoring for candidates in those states unless it has established the written notice and consent those laws require.
8. Children (COPPA)
The Service is for adults in a hiring context. We do not knowingly collect personal information from children under 13; contact privacy@axionconnect.com if you believe we have and we will delete it.
9. Other state notes
- California "Shine the Light" (§1798.83). We do not disclose personal information to third parties for their direct marketing.
- Nevada (NRS 603A). We do not sell covered information; an opt-out request may still be sent to privacy@axionconnect.com.
- Other states. Residents of the states listed at the top have the rights in section 5 under the same process.
10. Cookies
The only cookies are strictly necessary session cookies; there are no advertising, analytics or social-media cookies. See the Cookie Policy.
11. Contact and complaints
Requests, appeals and authorised-agent submissions: privacy@axionconnect.com, or by post to Axion Connect, Registered office address — to be confirmed. You may complain to the California Privacy Protection Agency (https://cppa.ca.gov (opens in a new tab)), the California Attorney General (https://oag.ca.gov/privacy (opens in a new tab)) or your state's attorney general.
Questions about this document?
Write to privacy@axionconnect.com for anything about data and privacy, or support@axionconnect.com for the agreement itself. We reply within one working day.