Privacy Policy

1. Scope and who is responsible

This policy covers www.recruitfractional.com and the RecruitFractional platform. Cobalt Glacier LLC is the controller of the personal information described here and is based in North Carolina, United States.

For candidate information a recruiter or a company uploads into its own workspace, that customer is the controller and we act as a processor on its instructions. Those arrangements are covered by our Data Processing Addendum.

Privacy contact: privacy@recruitfractional.com.

2. Information we collect

We do not intentionally collect government identification numbers, precise geolocation, health data, biometric data, or payment card numbers. Do not upload sensitive information that is not needed for a hiring conversation.

3. Where the data comes from

• Directly from you, when you register, build a profile, publish a role, message another user, subscribe, or contact us.
• From your organization's other workspace members, when they add you to a team or record notes about a search.
• From recruiters, when a recruiter submits a candidate. Recruiters must have the candidate's informed consent before submitting information, and are responsible for having that consent.
• Automatically from your device and browser as you use the platform.
• From our service providers, for example payment status from Stripe and delivery or bounce status from our email provider.

4. How we use information, and our legal bases

We do not sell personal information and we do not share it for cross-context behavioral advertising.

5. Who can see what

Visibility on the platform is deliberately tiered.

6. Sharing and service providers

We share personal information only as follows:

• With other users, as described in the visibility table above.
• With service providers who process data on our behalf under contract, listed on our subprocessor page: application hosting, database and authentication, file storage, payment processing, transactional email delivery, AI inference for matching, and search performance reporting.
• With professional advisers such as accountants and lawyers, where needed and under confidentiality.
• In a merger, financing, acquisition, or asset sale, subject to this policy continuing to apply to the transferred data.
• When required by law, subpoena, or court order, or to protect the rights, safety, and property of users, the public, or us.
• In aggregated or de-identified form that cannot reasonably identify you, for market reporting and product research.

7. AI features and automated decisions

Our matching features send role requirements and relevant profile text to an AI model to produce a ranked shortlist and a written rationale. The output is advisory. It does not automatically accept, reject, or rank you for a decision with legal effect, and a person always makes the hiring decision. We do not use your private workspace content to train third-party foundation models. You may ask us to review any match result you believe is wrong by emailing privacy@recruitfractional.com.

8. Cookies and analytics

We use strictly necessary cookies and local storage for sign-in, security, and preferences, and optional functional and analytics storage that only runs if you consent. You can accept, reject, or change your choice at any time from the cookie preferences link in the footer. Details are in our Cookie Policy.

9. Email and marketing

• Transactional email (sign-in, notifications, invoices, placement and dispute notices, support replies) is part of the service and cannot be unsubscribed while your account is open.
• The newsletter and marketing email require double opt-in: you confirm through a link we email you. Every marketing message includes an unsubscribe link, and unsubscribing is honored immediately.
• We keep a suppression list of unsubscribed and bounced addresses so we do not email them again. That is the only reason those addresses are retained.

10. Retention

When you close your account we delete or anonymize your personal information except where we must keep it for the reasons above, or where an unpaid balance or open dispute remains.

11. Security and breach notification

• Data is encrypted in transit with TLS and at rest by our hosting and database providers.
• Access to platform data is restricted by row-level database policies so that users reach only their own records, and administrative access is limited and audit-logged.
• Uploaded photos, videos, and documents are stored in private buckets and served through access-checked URLs.
• Payment card data never touches our systems; it is handled by Stripe.
• No system is perfectly secure. If a breach affects your personal information, we will notify you and any required regulator without undue delay and describe what happened and what to do.

12. International transfers

We are based in the United States and our providers process data primarily in the United States. If you are in the European Economic Area, the United Kingdom, or Switzerland, your information is transferred to the United States. Where required, we rely on the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, and supplementary technical measures such as encryption and access controls. You can request a copy of the relevant transfer terms by emailing privacy@recruitfractional.com.

13. Your rights and choices

• Access a copy of the personal information we hold about you.
• Correct inaccurate information, most of which you can edit yourself in settings.
• Delete your profile and account, subject to the retention exceptions above.
• Export your data in a portable format.
• Object to or ask us to restrict processing based on legitimate interests.
• Withdraw consent for analytics storage or marketing email at any time, without affecting the service.
• Complain to us or to your data protection authority.

Email privacy@recruitfractional.com from your account address, or tell us how to verify you. We respond within 30 days, or 45 days for California requests where an extension applies, and we will tell you if we need more time. We will not discriminate against you for exercising a right.

14. California notice (CCPA and CPRA)

Categories we collect and disclose

In the last twelve months we collected identifiers, professional and employment information, commercial information (subscriptions and invoices), internet and network activity, audio and visual information where you upload a photo or intro video, and inferences drawn from matching. We disclosed these categories to service providers for the business purposes described in section 4, and to other users as described in section 5.

No sale, no sharing, no financial incentives

We do not sell personal information and do not share it for cross-context behavioral advertising. We do not offer financial incentives in exchange for personal information. We do not knowingly process sensitive personal information for purposes requiring a right to limit.

Your California rights

• Know what we collect, use, disclose, and the sources and purposes involved.
• Access the specific pieces of personal information we hold about you.
• Delete personal information, subject to legal exceptions.
• Correct inaccurate personal information.
• Non-discrimination for exercising these rights.
• Use an authorized agent, who must provide written permission and whose authority we may verify with you directly.

Submit requests to privacy@recruitfractional.com.

15. EU and UK notice (GDPR)

• Legal bases for each purpose are listed in section 4.
• You have the rights of access, rectification, erasure, restriction, portability, objection, and withdrawal of consent, and you may lodge a complaint with your supervisory authority.
• Where you object to processing based on legitimate interests, we will stop unless we have compelling grounds or a legal obligation.
• Business customers acting as controllers can enter our Data Processing Addendum, which incorporates the Standard Contractual Clauses and lists our subprocessors.
• We have not appointed an EU or UK representative because our processing of EEA and UK data is limited and incidental to a US-focused marketplace. Direct all requests to our privacy contact and we will handle them under this policy.

16. Children

The platform is for business use by adults. It is not directed to anyone under 18 and we do not knowingly collect information from minors. If we learn we have, we delete it. We honor Global Privacy Control and do-not-track signals for optional analytics storage.

17. Changes and contact

We may update this policy. Material changes will be announced by email or in-product notice and the last-updated date above will change. Questions, requests, or complaints: privacy@recruitfractional.com. For contractual matters, see our Terms of Service.