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Effective Date: 1st March 2025
Last Updated: 1st May 2025
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request.
We collect, use, and are responsible for certain personal information about you. When we offer goods and services to individuals in the European Economic Area (EEA), we are subject to the EU General Data Protection Regulation (EU GDPR), which applies across the entire European Union. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We are responsible as a “controller” of that personal information for the purposes of the GDPR. We are responsible for your personal information as a “business” under the CCPA/CPRA.
Privacy Policy Overview: What You Need to Know
What we collect: We collect information you provide (like your name and email), data related to your hiring activities, and necessary technical data to perform our AI-powered services.
Why we collect it: To provide our recruiting automation services, enhance AI recommendations, and comply with legal requirements.
Who we share it with: We only share data with trusted service providers for essential business functions (e.g., payment processing, compliance). We never sell your personal data.
Your rights: You can access, correct, or delete your data, and opt-out of marketing anytime.
Data security: We store your data securely in the EU and in the US and use strict safeguards to protect it.
You can read the full policy below for detailed information. If you have any questions, contact us at legal@ogment.ai.
It would be helpful to start by explaining some key terms used in this policy:
We, us, our:
Ogment Inc.
Our Data Protection Officer:
Teo Borschberg. legal@ogment.ai
Personal information:
Any information relating to an identified or identifiable individual
Special category personal information:
Ogment does not collect special category personal data by default. However, if customers input such data into our AI-driven hiring platform, we process it solely for employment-related purposes.
If applicable, special category data may include:
Diversity and Inclusion Data: Race, ethnic origin (for EEO compliance)
Union Membership: If shared by candidates for compliance with labor laws
Work Authorization & Immigration Status: For employment eligibility verification.
Ogment does not collect biometric data, genetic data, or sexual orientation unless explicitly provided by users in a hiring context.
Sensitive Personal Information:
Identifiers: Name, email, phone number, LinkedIn profile URL, work history
Professional or Employment Information: Job titles, employer, work experience, skills, certifications
Commercial Information: Hiring preferences, role preferences, company hiring history
Digital data: IP address, session cookies, usage analytics
Candidate scoring, role-fit predictions, talent insights, Internet & Device Data
Candidate Messaging Data: AI-generated outreach messages, recruiter-candidate interactions
Payment Data (for customers only): Credit card details (via Stripe), billing address
Third-Party Data: Public profiles from job boards, professional networks, and data enrichment tools
Biometric Information:
N/A
We may collect and use the following personal information, including sensitive personal information, that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
The sections below outline the categories of personal information we collect, along with specific examples of the types of data that may fall within each category:
Identifiers:
Name, email, phone number, LinkedIn profile URL, work history
Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account:
Only collected for customers subscribing to paid plans, handled via Stripe
Characteristics of protected classifications under California or federal law:
(If provided by users) Gender, age, veteran status, disability status (for Equal Employment Opportunity compliance)
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies):
Subscription history, service usage history (e.g., number of searches, job postings, AI evaluations used)
Biometric information:
None (Ogment does not process biometric data such as facial recognition, fingerprints, or voiceprints). Except if users opt-in for AI-Powered Interview and / or screening.
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement):
IP address, device type, browser type, operating system, user behavior analytics (e.g., time spent on platform, clicked links)
Geolocation data:
N/A
Audio, electronic, visual, thermal, olfactory, or similar information:
Audio recordings of customer support calls (for quality assurance and legal compliance)
Professional or employment-related information:
Job titles, company affiliations, work history, job preferences, skills, endorsements
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA):
Degrees, certifications, universities attended (if included in candidate profile)
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes:
AI-generated candidate rankings, job match scores, engagement likelihood predictions
Racial or ethnic origin, religious or philosophical beliefs, union membership, or citizenship or immigration status:
Only collected if voluntarily provided by users for compliance (e.g., diversity hiring goals, work authorization status)
Contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication:
Ogment does not process personal communications unless as part of the AI-driven candidate outreach initiated by the user through Email and / or LinkedIn
Genetic data:
N/A
Processing of biometric information to uniquely identifying a consumer:
N/A
Health information:
Only if provided by users in the context of reasonable hiring accommodations (e.g., disability status)
Sex life or sexual orientation:
N/A
If you do not provide personal information required to provide our services to you, it may delay or prevent us from providing services to you.
We collect personal information from the following categories of sources:
Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The sections below explains what we use (process) your personal information for and our reasons for doing so:
To provide services to you:
For the performance of our contract with you or to take steps at your request before entering into a contract
Conducting checks to identify our customers and verify their identity. Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator:
To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies:
To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g., policies covering security and internet use:
For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training, and quality control:
For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information:
For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures:
For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems:
For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
Updating customer records:
For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns:
To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments:
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services and those of selected third parties to:
For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers, otherwise, we will request your consent.
External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts:
For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards
To comply with our legal and regulatory obligations
For EEA Data Subjects: The above table does not apply to special category personal information, which we will only process with your explicit consent.
We may use your personal information to send you updates (by email, text message, telephone, or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
You have the right to opt-out of receiving promotional communications at any time by contacting us at legal@ogment.ai.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We routinely share personal information with:
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., in relation to ISO accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:
We will keep your personal information while you have an account with us or while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
When it is no longer necessary to retain your personal information, we will delete or anonymize it.
You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:
Disclosure of Personal Information We Collect About You:
You have the right to know, and request disclosure of:
Please note that we are not required to:
Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose:
In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:
You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information.
To opt-out of the sale or sharing of your personal information, email us at legal@ogment.ai.
Right to Limit Use of Sensitive Personal Information:
You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:
You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes.
To limit the use of your sensitive personal information, email us at [EMAIL].
Right to Deletion:
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
Please note that we may not delete your personal information if it is reasonably necessary to:
Right of Correction:
If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
Protection Against Retaliation:
You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:
Please note that we may charge a different price or rate or provide a different level or quality of goods and services to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information.
Right to Be Informed:
The right to know or be notified about the collection and use of your personal information
Right to Access:
The right to be provided with a copy of your personal information (the right of access)
Right to Rectification:
The right to require us to correct any mistakes in your personal information
Right to be Forgotten:
The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing:
The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data
Right to Data Portability:
The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object:
The right to object:
Right Not to be Subject to Automated Individual Decision-Making:
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the EU General Data Protection Regulation.
If you would like to exercise any of your rights as described in this Privacy Policy, you can do so here legal@ogment.ai.
Information may be held at our offices, third-party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).
Some of these third parties may be based outside the EEA. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA.”
To deliver services to you, it is sometimes necessary for us to share your personal information outside the EEA, e.g.:
These transfers are subject to special rules under European and UK data protection law.
These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission.
If you would like further information, please contact us at [EMAIL] (see “How To Contact Us” below).
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We continually test our systems and are ISO 27001 certified, which means we follow top industry standards for information security. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses, and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
We hope that we can resolve any query or concern you raise about our use of your information.
The GDPR also gives you right to lodge a complaint with a supervisory authority, in the European Union (or EEA) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
We may change this privacy notice from time to time–when we do, we will inform you via our website.
How to Contact Us.
Please contact us by email (legal@ogment.ai) if you have any questions about this privacy policy or the information we hold about you.
If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).
