Privacy Policy

Ember Hiring Technologies
Privacy Policy
Last updated: April 25, 2025

Ember Hiring Technologies Inc., ("Company", "we" or "us"), respect your privacy and are committed to protecting it through our compliance with this policy (this “Privacy Policy”). This Privacy Policy describes our practices for collecting, using, maintaining, protecting, and disclosing information that we collect from you or that you provide to us when you visit our website, www.emberhiring.com (“Site”), install and use our Mobile application (the “Mobile App”), purchase and use services made available for sale on our Site or the Mobile App (“Purchased Services”) or use any products and services made available by us (collectively with the Site, the Mobile App, and the Purchased Services, the “Services”).

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using the Services, you agree to this Privacy Policy. If you are using the Services on behalf of an entity, you are agreeing to this Privacy Policy for that entity and are representing to us that you have the authority to do so (in which case “you” will also refer to that entity). If you do not agree with our policies and practices, your choice is not to use the Services.

General
1. Definitions
“Distribution List” means a list of Subscribers and all associated information related to those Subscribers (for example, email addresses).

“Personal Information” means information that can be used to identify you or a Subscriber, including, but not limited to, first and last name, date of birth, email address, gender, occupation or other demographic information.

“Subscriber” means a person you contact through our Services, or a person whom you might choose to contact at some point in the future using our Services. A Subscriber is anyone on your Distribution List or about whom you have given us information.

“Candidate” means a person we contact through our Services on your behalf. A Candidate’s information can be found either through our own information sources, or from the information you provide.

“CCPA” means the California Privacy Rights Act of 2018, as amended, and any regulations promulgated thereunder.
“CPRA” means the California Consumer Privacy Act of 2020, as amended, and any regulations promulgated thereunder.
“VCDPA” means the Virginia Consumer Data Protection Act of 2021, as amended, and any regulations promulgated thereunder.
“CPA” means the Colorado Privacy Act of 2023, as amended, and any regulations promulgated thereunder.
“CACPDP” means the Connecticut Act Concerning Personal Data Privacy and Online Monitoring 2023, as amended, and any regulations promulgated thereunder.
“UCPA” means the Utah Consumer Privacy Act (UCPA) 2023, as amended, and any regulations promulgated thereunder.
“Governmental Privacy Laws” are all state and federal laws which Company is or may become subject to, whether in existence now or promulgated in the future. This includes the CCPA, CPRA, VCDPA, CPA, CACPDP, and the UCPA.


“you” or “user” a person(s) and/or organization who have access and use of the Services

2. Changes
This Privacy Policy may change from time to time. If we make any changes, we will post the changes on this page and indicate at the top of this page the date this Privacy Policy was last revised. We may also notify you of any material changes either through a pop-up notice, e-mail or through other reasonable means. Any such changes are effective immediately when we post them, and apply to all access to and use of the Services thereafter. Your continued use of the Services after the date any such changes become effective constitutes your acceptance of the new policy. You are expected to check this page from time to time so you are aware of any changes.If you have any questions or comments, or you have a concern about the way in which we have handled any privacy matter, please email us at support@emberhiring.com.

3. Accessing and Requesting Changes to Your Personal Information
If you are a customer of the Company, you may review and request changes to your Personal Information through your customer account representative.

If you do not have a customer account representative with us, or if you cannot access or change any of your Personal Information through your customer account representative, but you still wish to inquire about, access, correct, update or delete Personal Information that we may hold about you, please email us at support@emberhiring.com. Please understand that, before responding to your request, we may ask you for additional information in order to verify your identity, or take other actions that we believe are appropriate in order to verify your identity.

Please also understand that we may not be obligated or able to alter or delete your Personal Information and may retain information to provide you with requested services or fulfill obligations to you, for security reasons, if we are required under applicable law or regulations, for internal business use or for other valid reasons. We are also not obligated to comply with requests that are unreasonably burdensome or expensive, or with requests that would interfere with the rights of another individual. In some circumstances, we may charge a reasonable fee to fulfill your request.

4. Notices to California Residents
If you are a resident of the state of California, California’s “Shine the Light” law permits you to request information regarding the disclosure of your Personal Information by us to a third party for the third party's direct marketing purposes. Other Governmental Privacy Laws may require similar requests under their applicable framework. To make such a request, please send an email to support@emberhiring.com.

In accordance with the California Consumer Privacy Act of 2018 (“CCPA”), and all other applicable Governmental Privacy Laws, please see the following summary of Personal Information that we have collected in the past twelve (12) months (preceding the effective date of this Privacy Policy), as well as the sources of that Personal Information, the purposes of collection, and third parties with who we have shared such Personal Information in the past twelve (12) months (This information is provided based on the categories of Personal Information and business and commercial purposes defined within the CCPA.)

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In addition to those purposes described above, we may use or disclose any Personal Information that we collect as necessary to comply with applicable law or legal obligations as described in this Privacy Policy.

Sale of Personal Information. We do not “sell” your Personal Information, as defined under the CCPA, and we have not sold your Personal Information in the past twelve (12) months (preceding the effective date of this Privacy Policy).

California Residents’ Rights under the CCPA. Under the CCPA, California residents have certain rights regarding their Personal Information. Subject to certain exceptions, California residents have or may exercise the following rights:
· Right to Know about Personal Information Collected, Disclosed or Sold. A California resident has the right to be informed about the information practices of a business, and the specific pieces of Personal Information that a business holds about that resident.
· Right to Request Deletion of Personal Information. A California resident may request that a business delete their Personal Information.
· Right to Opt-Out of the Sale of Personal Information. A California resident has the right to opt-out of the sale of their Personal Information by a business.
· Right to Non-Discrimination for Exercise of Consumer Privacy Rights. A California resident has the right not to receive discriminatory treatment by a business for the exercise of privacy rights provided by the CCPA.
To submit requests to the Company to exercise these rights, California residents (or their authorized agents) may email us at: support@emberhiring.com. To the extent that other Governmental Privacy Laws provide similar rights, residents (or their authorized agents) may likewise email us at support@emberhiring.com.
Please understand that we are only obligated to respond to verifiable consumer requests. If we receive a request for information about you, we need to know that it is actually coming from you, or an agent who is legally authorized to act on your behalf. In order to verify a request, we may ask for certain Personal Information, including at least the name, email and mailing address of the person who is the subject of the request, and we may implement authentication procedures that are appropriate to the nature of the request. We may also use any information that we have already collected in order to verify a request. If we collect any new Personal Information (that we do not already hold for another purpose) in order to verify a request, we will only use that information to verify the request.
Please remember that we are only obligated to respond to a request for access twice within a 12-month period, or as determined by the applicable Governmental Privacy Law.


5. Children Under the Age of 18
Our Services are intended for users who are 18 years of age and older and can form legally binding contracts with us to use the Services. If you are under the age of 18, you are not permitted to submit any personal information to us. If you believe we might have any information from or about a child under 18, please contact us at support@emberhiring.com.


Your Information
6. Information We Collect
We process personal data as defined under data protection laws in various ways depending upon your use of the Services. We process personal data on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Services; and (3) as necessary for our legitimate interest in providing the Services where those interests do not override your fundamental rights and freedom related to data privacy.


(a) Information you voluntarily provide to us:
i. Account Information: When you register to use the services and create an account (“Account”) through your Gmail account, we obtain your name and email address to personalize your experience with the Services. We will request access to your Gmail account during registration.
ii. List and email information: When you add a Distribution List or create an email with the Services, we have and may access the list, the data on your list and the information in your email.
iii. Other Voluntary Information: When you use the Services, consult with our customer service team, subscribe to our emails, send us an email or a chat message, integrate the Services with another website or service, or communicate with us in any way, you are voluntarily giving us information that we collect. That information may include either your or your Subscribers’ name, physical address, email address and IP address. By giving us this information, you consent to this information being collected, used, disclosed, transferred to the United States and stored by us, as described in our Terms of Use and in this Privacy Policy. Communication between you and our servers are encrypted using HTTPS and enforced in our software.


(b) Information we collect automatically. When you use the Services, browse our Site or install and use our Mobile App, we may collect information about your visits to our Site, your usage of the Services, and your web browsing. That information may include your IP address, your operating system, your browser ID, your browsing activity, and other information about how you interacted with our Site, our Mobile App or other websites. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies. Our use of cookies and other tracking technologies is discussed further below.


(c) Information from your use of the Services. We may receive information about how and when you use the Services. This information may include, for example, your webpage views, interactions with the Site or Mobile App, IP address, time, date, browser used, and actions you have taken within the Site or Mobile App. This type of information helps us to improve our Services for both you and for all of our users.


(d) Cookies and tracking. We and our partners use cookies and similar tracking technologies, such as pixels and web beacons, to improve our services, debug the Site and the Mobile App, analyze trends, administer the Site, track users’ movements around the Site, and gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level.


(e) Browser extensions: Our browser extensions lets you use the Services directly through your enabled browsers. We do not collect your browsing history while you use our extension. When visiting other websites, our browser extensions can read data from websites you visit such as LinkedIn, GitHub and AngelList.


If you would like to opt out of having any of your Personal Information or your non-personally identifiable information collected by us in connection with the Services, please email us at support@emberhiring.com.


7. Use and Disclosure of Personal Information and data


We may use and disclose Personal Information and data obtained via the Services only for the following purposes:


(a) With your user permissions enabled, we may use the Google email address you provide to set up your Account and to send emails to Subscribers and/or Candidates you add to campaigns. We also use it to track the status of your contacts (such as open and reply tracking). We can also read the body of your emails for the strict purposes of notifying users on your team when a Subscriber/Candidate has responded to a campaign only with your explicit permission. Our use of information received, and our transfer of information to any other app, from Google APIs will adhere to Google's Limited Use Requirements, found at https://developers.google.com/terms/api-services-user-data-policy (URL subject to change at Google’s discretion).


(b) To send you System Alert messages. We may inform you of temporary or permanent changes to our Services, such as planned outages, new features, version updates, releases, abuse warnings, and changes to our Privacy Policy.


(c) To communicate with you about your Account and provide customer support.


(d) To enforce compliance with our Terms of Use and applicable law. This may include developing tools and algorithms that help us prevent violations.


(e) To protect the rights and safety of our users and third parties, as well as our own.


(f) To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms, and to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.


(g) To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.


(h) To prosecute and defend a court, arbitration, or similar legal proceeding.


(i) To transfer your information in the case of a sale, merger, acquisition, after obtaining explicit prior consent from you. In that event, any acquirer will be subject to our obligations under this Privacy Policy, including your rights to access and choice. We will notify you of the change and request for your explicit consent either by sending you an email or posting a notice on our Site.


8. Prohibited Use and Disclosure of Personal Information and data
We do NOT transfer, use or sell your personal information or user data for prohibited purposes including:
(a) Transferring or selling Personal Information or user data to third parties like advertising platforms, data brokers, or any information resellers.
(b) Transferring, selling, or using Personal Information or user data for serving ads, including retargeting, personalized or interest-based advertising.
(c) Transferring, selling, or using Personal Information or user data to determine credit-worthiness or for lending purposes.
9. Data Collected for and by our users
As you use our Services we import the contents of outbound messages to Candidates and the responses to those messages into our system for viewing by our automated system Services. We do not allow humans to read the data, unless:
(a) You first obtained the user's affirmative agreement to view specific messages, files, or other data, with the limited exception of use cases approved by Google under additional terms applicable to the Nest Device Access program;
(b) It is necessary for security purposes (for example, investigating a bug or abuse);
(c) It is necessary to comply with applicable law; or
(d) The data (including derivations) is aggregated and used for internal operations in accordance with applicable Government Privacy Laws and other jurisdictional legal requirements.
We take reasonable and appropriate measures to protect this email data from loss, misuse and unauthorized access, disclosure, alteration and destruction including encryption of the information in transit and at rest.


As you use our Services, you may import into our system Personal Information and other data you have collected from your Subscribers or other individuals. We have no direct relationship with your Subscribers or any person other than you, and for that reason, you are responsible for making sure you have the appropriate permission for us to collect the data and process your information about those individuals.


If you are a Subscriber and no longer want to be contacted by one of our users, please unsubscribe directly from that user’s newsletter or contact the user directly to update or delete your data. If you contact us, we may remove or update your information within a reasonable time and after providing notice to the user of your request.


10. Public Information and Third-Party Websites
(a) Links to third-party websites. Our Services may include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.


11. Third Parties
Sometimes, we need to use third party service providers to provide and support the features of our Services. Currently, the third party service providers we work with include Nylas and Google Where available, we have entered into Data Processing Agreements with these third-parties by which the third party service providers have committed to compliance with the requirements of the Governmental Privacy laws regarding the processing of personal data.


12. Distribution Lists and Email Campaigns
A Distribution List can be created in several ways, including by importing contacts, such as through csv. Your Distribution Lists are stored within our databases behind a secure network. Messages sent through email are not secure. Please do not use the Services to send confidential information.


13. Notice of Breach of Security
If a security breach causes an unauthorized intrusion into our system that materially affects you or people on your Distribution Lists, then we will notify you as soon as possible and later report the action we took in response.


14. Infrastructure
We use Google Cloud Platform (“GCP”) for all of our infrastructure. GCP provides hosting services for most of the web and takes security with the utmost importance. The Company take the appropriate measures to ensure that its employees, agents, contractors, and successors comply with the Google API Services User Data Policy, found at https://developers.google.com/terms/api-services-user-data-policy (URL subject to change at Google’s discretion).


15. Safeguarding Your Information
We take reasonable and appropriate measures to protect Personal Information and user data from loss, misuse and unauthorized access, disclosure, alteration and destruction, considering the risks involved in the processing and the nature of the Personal Information and user data.


16. We Operate in the United States
Our servers and offices are located in the United States, so your information may be transferred to, stored, or processed in the United States. Although the data protection, Governmental Privacy laws, and other laws of the United States may not be as comprehensive as those in your country, we take many steps to protect your privacy. By using our Services, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the United States and to those third parties with whom we share it as described in this Privacy Policy.


17. Data Accuracy, Retention and Deletion
We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do so. If your data changes (for example, if you have a new email address), then you are responsible for notifying us of those changes. If you would like to update any information on your Account, please email us at support@emberhiring.com.


We will retain your information for as long as your Account is active or as long as needed to provide you with our Services. We may also retain and use your information to comply with our legal obligations, resolve disputes, prevent abuse, and enforce this Privacy Policy and our Terms of Use. If you wish for your information to be deleted, you can send an email to support@emberhiring.com to request deletion of your information, including Personal Information. You may also request a copy of all Personal Information in our possession, by emailing support@emberhiring.com.


18. California Privacy
Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship,
(a) a list of the categories of Personal Information, such as name, email and mailing address and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and;
(b) the names and addresses of all such third parties. To request the above information, please contact us by email at support@emberhiring.com.