Introduction

At Talentropy, protecting your privacy is our top priority. Our platform leverages generative AI to revolutionize the recruitment experience for both candidates and businesses. For candidates, the process is entirely conversational and seamless—from submitting their CV and personal information to receiving updates, undergoing evaluations, and scheduling interviews. For businesses, Talentropy focuses on operational efficiency through an intuitive dashboard, visual management tools, and AI-driven candidate matching that optimizes recruitment timelines and enhances selection accuracy.

This Privacy Policy outlines how we collect, use, share, and safeguard your personal information in compliance with applicable U.S. laws, including the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), Florida Information Protection Act (FIPA), and Texas Privacy Protection Act (TPPA). By accessing or using our platform, you agree to the practices described in this Privacy Policy. The parent company responsible for this platform is Umany Holdings Limited.

This Privacy Policy also describes the data protection practices of Talentropy and its affiliated companies (collectively referred to as “Talentropy,” “we,” “us,” or “our”). It applies to all websites, mobile applications, digital properties, and communications owned, operated, or utilized by us that link to this Privacy Policy, as well as related online and offline services (collectively, the “Services”).

When handling information about job seekers (“Seekers”) who use our Services to complete job applications, provide onboarding documents/forms, or communicate directly with employers (“Employer Direct Engagements”), Talentropy acts as a service provider or processor on behalf of employers. In these cases, the employers determine how the data is processed and used. We encourage Seekers to carefully review the privacy policies of the employers they interact with, as Talentropy is not responsible for those practices.

However, when Seekers create profiles, apply for roles, or use Talentropy’s platform more broadly, Talentropy acts as a business and independently determines how data is handled and processed.

PLEASE READ THIS PRIVACY POLICY CAREFULLY to understand how we manage your personal data. By using Talentropy Services, you expressly and voluntarily agree to the terms of this Privacy Policy and our Terms of Use, which authorize us to process information about you.

For questions or concerns, contact us at:

Email: support@talentropy.ai

   1. Information We Collect

1.1 Data You Provide:

• • Personal Information: Name, email address, phone number, resume, and other application materials.
  • Sensitive Information: Only collected with explicit consent or as required by law.

1.2 Data Collected Automatically:

• • Usage Information: IP addresses, device data, and usage analytics.
  • Cookies: To enhance user experience and analyze platform traffic.

1.3 Aggregated and Anonymized Data:

• • Used for analytics and to improve platform functionality without identifying specific users.
    

   2. Who is responsible for your information

This section explains when Talentropy is a controller or a processor of your Personal Information, and which entity is responsible for your Personal Data.

For Job Seekers

Talentropy operates as both a processor and a controller of personal data, depending on the context of your interaction with our platform:

• Processor: Talentropy processes application data submitted by candidates, including resumes, responses to screener questions, assessments set by employers, and interview information managed through the platform. In these instances, the employer to whom you are applying is the controller of your data and determines its use.

• Controller: Talentropy acts as a controller for all other information you provide during your use of our platform. This includes data collected to create candidate profiles, optimize user experience, and improve platform functionality using aggregated and anonymized insights.

For Employers

For employers utilizing Talentropy’s recruitment tools, we assume the following roles:

• Processor: Talentropy processes candidate data submitted through the platform, including application materials and interview data, as part of the recruitment process. Employers retain control over these data and determine their use through their Talentropy dashboards.

• Controller: Talentropy is the controller of the information employers provide directly to the platform, such as account details, job postings, and platform usage data. This information is used to personalize the employer’s experience, ensure operational efficiency, and continuously improve our services.

Data Processing Agreements (DPAs)

Employers must agree to a Data Processing Agreement (DPA) with Talentropy. This agreement outlines our shared responsibilities regarding data protection and ensures compliance with applicable laws, including but not limited to the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), Texas Privacy Protection Act (TPPA), and Florida Information Protection Act (FIPA). The DPA formalizes secure processing practices, retention policies, and adherence to applicable data privacy regulations.

This section reflects Talentropy’s dual roles as a controller and processor, ensuring transparency and compliance with U.S. data privacy laws across states, while emphasizing the platform’s AI-driven recruitment capabilities.

     3. Definitions 

    4. How we use your information

Talentropy collects and processes different types of personal data to deliver our platform’s services, products, and features in compliance with U.S. data privacy laws, including the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), the Florida Information Protection Act (FIPA), and the Texas Privacy Protection Act (TPPA). The specific data we collect and process may vary depending on your interaction with our platform.

Collection and Use of Personal Data

• Data Required for Services: Certain personal data is necessary to use specific features of the platform, such as creating a candidate profile, applying for a job, or using our AI-driven job-matching tools. If you choose not to provide this required data, the associated features may not be available to you.
• Transparency at Collection: When personal data is essential for a feature or service, we will clearly indicate it at the time of collection.

Legal Basis for Processing Personal Data

In compliance with U.S. laws, we rely on the following legal bases to process personal data:

• Consent: For optional features, such as receiving notifications or marketing updates.
• Contractual Necessity: To provide core platform functionalities, including job applications and communication between candidates and employers.
• Legitimate Interests: For improving platform features, conducting analytics, and maintaining security while ensuring user rights are respected.
• Legal Compliance: For meeting regulatory requirements, such as fraud prevention or responding to legal obligations.

Retention of Personal Data

Controller Role:
When Talentropy acts as the controller of your personal data, we retain it only for as long as necessary to:

• Fulfill the purposes outlined in this Privacy Policy.
• Comply with legal and regulatory requirements.
• Maintain your account’s functionality throughout its lifetime, or until you remove your profile data.

If you request deletion of your data, we will securely erase it unless its retention is required to meet legal obligations, resolve disputes, or enforce our agreements.

Retention Considerations:
The duration of data retention is determined based on:

• The nature, sensitivity, and scope of the personal data.
• The purpose for which the data is being processed.
• The feasibility of achieving the same purpose through anonymization or aggregation.

Anonymized Data:
Where appropriate, Talentropy anonymizes or aggregates personal data to ensure it can no longer be linked to specific individuals. Anonymized data may be used to:

• Train and validate AI models, enhancing their performance and accuracy.
• Improve platform features and generate insights to optimize recruitment processes.

Processor Role:
When Talentropy processes data on behalf of employers, we act as a processor. In this role, we retain the data only as long as instructed by the employer (the controller), adhering to their retention policies and legal obligations.

Full details of the types of personal data we collect from you and the purpose of processing it are detailed below.

Data from All Users

Data from Job Seekers

Data from Employers

Any Personal Data that Talentropy obtains from other third-party sources will be processed in accordance with this Privacy Policy and all applicable laws.

Additional Purposes and Disclosures of Information

Profile Data

By creating a searchable profile on Talentropy, including uploading your resume and other details, you authorize Talentropy to share your profile data with employers in accordance with this Privacy Policy. Profiles are set to searchable visibility by default, meaning employers can view your profile and resume to assess job fit.

• Sharing of Data by Employers: Employers or their representatives who access your profile while it is searchable, or when you apply to a job using a private (not searchable) profile, may choose to share your profile with other parties. Talentropy is not responsible for such sharing.
• Shared Links: When you share your profile via a personalized link, Talentropy cannot control how it is subsequently shared or who gains access.

Employer Accounts

Talentropy offers the option to link employer accounts. Linked accounts provide varying levels of access to candidate data based on assigned roles.

• Shared Access: By linking accounts, you agree that linked users can access candidate data, including resumes, application details, and communications.
• Delinking Accounts: If an account is delinked, either by the user or an administrator, access to shared candidate data is revoked immediately.

Resume Review Services

Talentropy may offer resume review services to help job seekers optimize their resumes for better alignment with employer expectations. This includes:

• Feedback on resume formatting and relevance for applicant tracking systems (ATS).
• Suggestions for improving content, structure, and overall effectiveness.
• Feedback is provided directly to job seekers and is not shared with employers.

Automated Processing of Personal Data

Talentropy uses automated processing and artificial intelligence (AI) to evaluate and predict user preferences, streamline recruitment, and improve platform performance.

• Purposes of Automated Processing:
  • Match job seekers with relevant vacancies.
  • Send job alerts, application updates, and personalized job recommendations.
  • Perform spam and fraud detection to safeguard users.
• Safeguards: All automated decisions are subject to the privacy protections outlined in this Privacy Policy. You may contact support@talentropy.ai to contest any decision generated by automated processes.

    5. How We Use Artificial Intelligence (AI)

Talentropy uses AI to:

• Provide insights to employers through summarized candidate highlights.
• Personalize outreach messages to candidates.
• Identify job seekers with the highest compatibility for job openings.

Data Sources: Talentropy leverages user activity, profile data, and anonymized usage patterns to enhance AI-generated recommendations and outreach. AI features help job seekers and employers connect more efficiently, reducing time-to-hire and improving job matching accuracy.

Chatbots: Talentropy enables conversational interactions through AI-driven chatbots, allowing job seekers to:

• Submit resumes.
• Schedule interviews.
• Receive application updates.

Site Activity Recording

Talentropy records all interactions with the platform, including:

• Pages visited, content viewed, clicks, scrolls, and input details.
• Timing and duration of activities.

Purpose of Recording:
This data helps us:

• Understand user behavior to improve platform functionality.
• Protect users from fraudulent activity.
• Optimize services and job-matching algorithms.

Research and User Experience Data

Talentropy collects personal data for research to enhance platform features, understand user behavior, and improve recruitment outcomes.

• Types of Data: Name, contact details, account activity, and preferences.
• Retention: Data is retained only as long as necessary to fulfill the objectives of the study. Once completed, data is anonymized or securely deleted.

This approach aligns with U.S. privacy laws, ensuring data security, transparency, and compliance while leveraging Talentropy’s AI-driven capabilities to improve recruitment experiences for job seekers and employers.

   6. Transfer of data to third parties 

At Talentropy, we are committed to sharing your personal data only when necessary and in a secure manner. We pass data exclusively to employers and trusted service providers that support our platform’s operations, such as messaging services. Additionally, as part of a holding group, we may transfer data to other entities within our corporate structure for product improvement and operational purposes. Below, we outline the specific purposes and conditions for data sharing:

Transfers of Information to Employers

Talentropy shares job seeker personal data with employers in the context of job applications, interview scheduling, and other recruitment-related activities.

• Purpose of Sharing:
  • To enable employers to evaluate candidates and facilitate the recruitment process.
  • To support employers in managing applications via their preferred systems, such as Applicant Tracking Systems (ATS) or scheduling platforms.
• Responsibilities of Employers:
  Employers are required to comply with all applicable data protection regulations when processing, storing, or sharing personal data received from Talentropy. Employers must ensure adequate protection of all data subject rights under U.S. data privacy laws, such as the California Consumer Privacy Act (CCPA) and other relevant statutes.

Transfers of Information to Service Providers

We work with trusted third-party service providers to help us deliver our services and improve the Talentropy platform.

• Examples of Providers:
  • Messaging platforms for communication with job seekers and employers.
  • Cloud storage services for secure data hosting.
  • Analytics tools to optimize platform performance and user experience.
• Legal and Security Safeguards:
  All transfers to service providers are governed by robust data processing agreements to ensure compliance with U.S. and international privacy standards. If data is transferred across borders, legal mechanisms such as standard contractual clauses are implemented to protect user privacy.

Transfers Within the Talentropy Group

As part of a holding company, Talentropy may transfer data to affiliated entities within our corporate group for product improvement, analysis, and internal research purposes.

• Purpose of Sharing:
  • To enhance Talentropy’s AI capabilities and improve platform performance.
  • To conduct internal audits and develop new features tailored to user needs.
• Data Protection Standards:
  Transfers within the corporate group are limited to what is strictly necessary and are protected by intra-group agreements that align with data privacy laws.

Additional Transparency Measures

1. Limited Data Sharing: Talentropy only shares essential data required for specific purposes, such as facilitating employer-candidate interactions or improving platform features.
2. No Sale of Data: Talentropy does not sell or rent personal data to third parties for marketing purposes.

By ensuring strict compliance with data protection laws and implementing robust safeguards, Talentropy remains committed to protecting user data while enabling seamless recruitment experiences.

     7. Your Personal Data rights

Talentropy respects your rights under applicable U.S. data protection laws, including the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), Florida Information Protection Act (FIPA), and Texas Privacy Protection Act (TPPA). Below is a summary of your rights and how to exercise them:

 Right to Access and Data Portability

• Description: You can request access to the personal data Talentropy has collected, used, and shared about you. This includes a summary of the categories of data and the purposes of processing.
• Portability: You can request your data in a portable format for transfer to another platform.
• How to Exercise: Submit a request by contacting us at  support@talentropy.ai  using the email address associated with your account.

 Right to Rectification (Correction)

• Description: You have the right to correct inaccurate or incomplete personal data. You may update much of your data directlysubmit a formal request via  support@talentropy.ai 
• How to Exercise: If further corrections are needed, submit a formal request via  support@talentropy.ai 

 Right to Deletion (Erasure)

• Description: You may request the deletion of your personal data, including closing your account. Note that deletion may limit your ability to use certain features or services.
• Exceptions: Talentropy may retain data where required by law, to resolve disputes, or to enforce agreements.
• How to Exercise: Submit a request via support@talentropy.ai.

Right to Restrict or Object to Processing

• Description: You can restrict or object to Talentropy’s processing of your data, particularly when processing is based on legitimate interests.
• How to Exercise: Contact us at support@talentropy.ai to submit your request.

Right to Opt-Out of Data Sharing 

• Description: You may opt-out of data sharing with third parties, except for service providers acting on our behalf.
• How to Exercise: Submit your request at support@talentropy.ai.

Right to Withdraw Consent

• Description: If Talentropy processes your data based on your consent, you may withdraw this consent at any time. For example, you can turn off location tracking in your device settings.
• How to Exercise: Contact us at support@talentropy.ai to withdraw your consent.

Right to Non-Discrimination

• Description: Exercising your privacy rights will not result in denial of service or discriminatory treatment.

Verification Process

All requests are verified via the email address associated with your account. If you are making a request on behalf of someone else, additional documentation may be required to confirm your authorization.

Limitations and Response Time

• Talentropy will process requests within the timeframes set by applicable laws.
• Certain rights may have limitations based on legal or operational requirements.

If you have any questions or wish to exercise any of these rights, please contact us at support@talentropy.ai.

    8. Security:

At Talentropy, we prioritize the security of your personal information and have implemented robust measures to ensure its protection:

• Encryption: All personal data is encrypted both in transit and at rest using industry-standard encryption protocols, preventing unauthorized access.
• Secure data access: Users can only access their data through a unique, one-time authentication key generated each time they log in, ensuring maximum security and preventing unauthorized access.
• Regular backups: We perform daily backups of all data to safeguard against accidental loss or technical failures. These backups are stored securely and can be quickly restored if necessary.
• Advanced security technology: Our platform employs state-of-the-art security technologies, including firewalls, intrusion detection systems and continuous monitoring to detect and prevent potential threats.
• Access control: Access to personal data is restricted to authorized personnel only  and all access is logged and regularly audited to ensure compliance with our security policies.
• Ongoing risk assessment: We continuously review and update our security practices to address emerging threats and ensure alignment with the latest industry standards.

If you suspect any unauthorized access or security issue, please contact us immediately at support@talentropy.ai

     9. Use of cookies

You can manage your cookie preferences through your browser settings or contact us for more details.

    10. Changes to this Policy

We may update this policy periodically. Any changes will be posted on this page and significant updates will be communicated via email.

    11. Contact Information

For questions or requests related to this policy, contact us at:

• Email: support@talentropy.ai
• Phone: