Privacy Policy

Last Updated and Effective: 5th March 2025

This privacy notice is for “Recrew” the Website, (both owned and managed by  “Global Roots, Inc. (referred as “Company”)) (hereinafter “Platform” “we,” “us,” or “our”), and describes how and why we might collect, store, use, and/or share your when you use our services through the Platform (“Services”), such as when you visit the Website and/or engage with us in other related ways, including any sales, marketing, or events. 

Reading this Privacy Policy will help you understand your privacy rights and choices. We will not use or share your information with anyone except as described in this privacy policy (the “Privacy Policy”). If you do not agree with our policies and practices, please do not use our Platform and Services. 

By using the Services, you agree to the collection and use of your information in accordance with this Privacy Policy. It does not apply to information collected by:

(i) use offline or through any other means, including on any other website operated by us or any third party; or
(ii) any third party, including through any application or content (including advertising) that may link to or be accessible from our website or Services.

If you see an undefined term in this Privacy Policy, it has the same definition as in our Terms of Use. Please note that this Privacy Policy is read in conjunction with the Terms of use.

We adhere to the data practices described in this privacy policy. We recognize and respect the privacy interests of the individuals about whom we process information, and about whom we maintain information in our database.  The purpose of this Privacy Policy is to provide information about:

• The types of information that we collect and how we collect it.
• How the information is used by Us.
• Security of the information collected.

INFORMATION WE COLLECT:

1. Information You Give to Us. The information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The Information we collect may include but is not limited to: name, email, job title, industry, address and telephone number(s).
   
   ‍Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
   
   • information revealing race or ethnic origin
   • information revealing political opinions
   • information revealing religious or philosophical beliefs
   • information revealing trade union membership
   • social security numbers or other government identifiers
   • professional experience data

2. Communications with Company. When you communicate with Company or use the Website and/or Platform to communicate with us, we collect information about your communication and any information you choose to provide.
3. Other Information. You may otherwise choose to provide us information when you fill in a form, conduct a search, respond to surveys, post to community forums, participate in promotions, or use other features on the Platform (if available and applicable). 
4. We also may associate the above information with information we receive from other sources, such as other companies that compile datasets from public and private sources: this additional information includes information about consumer’s demographics, IP address, interest, likely purchasing preferences, hobbies or other lifestyle data.
5. Geo-location Information. When you use certain features of the Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. The Website and the Platform may also collect this information even when you are not using the Website and the Platform if this connection is enabled through your settings or device permissions.
6. Usage Information. We collect information about your interactions with the Website and/or Platform such as the pages or content you view, your searches for a product/service that is provided by Company, and other actions on the Platform.
7. Log Data and Device Information. We automatically collect log data and device information when you access and use the Platform, even if you have not created an account with Company and/or the Platform. That information includes, among other things: details about how you’ve used the Website and the Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Website and the Platform.
8. Cookies and Similar Technologies. We use cookies and other similar technologies. We may also allow our business partners to use these tracking technologies on the Platform or engage others to track your behavior on our behalf.  Our Cookie Policy is available for your information.
9. Information We Collect from Third Parties. Company may collect information, including information, which others provide about you when they use the Website and/or Platform or reach the Platform through a third-party, or obtain information from other sources and combine that with information we collect through the Platform. We do not control, supervise or are responsible for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your information to us should be directed to such third parties.
10. Do Not Track Disclosure. We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the “Preferences” or “Settings” page of your web browser.
11. Social Media Login Data. We may allow you to create an account and log in to use the Services through the following third-party Social Media Services like Facebook, Twitter and other social media services. If you decide to register through or otherwise grant us access to the Social Media service, We may collect information that is already associated with your Social Media Service's account, such as your name, your email address, your activities or your contact list associated with that account. You may also have the option of sharing additional information with us through your Social Media Service's account. If you choose to provide such information and information, during registration or otherwise, You are giving us the permission to use, share, and store it in a manner consistent with this Privacy Policy.
12. We do not sell your personal information for processing by direct marketing agencies. We may however use your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing by us, we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims. Please note that you may, at any time ask the Company to cease processing your data for these direct marketing purposes by sending an e-mail to compliance@recrew.ai

HOW WE USE INFORMATION WE COLLECT:

1. To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
2. To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
3. To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
4. To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
5. To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
6. To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
7. To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.
8. To promote the Platform other member content may be displayed on other websites, in applications, within emails, and in online and offline advertisements.
9. To facilitate payments. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. We may provide paid products and/or services within the Services. In that case, we may use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your information is governed by their Privacy Policy. 
10. We may review, scan, or analyze your communications on the Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We will not review, scan, or analyze your communications to send third party marketing messages to you, and we will however have access to your reviews or analyses of these communications.
11. To analyze and process aggregated data to improve the accuracy of our AI-powered recommendations and insights. 
12. To send you relevant communications, offers, and product recommendations, unless you opt out.

SHARING AND DISCLOSURE:

We may need to share your information in the following situations:

1. Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
2. Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
3. Third-Party Authorization: Information we collect is shared as per your consent. For instance, when you authorize third-party applications or websites to access your registered account or participate in promotional events hosted by our partners or third parties.
4. Legal Compliance: We may disclose your information to legal or governmental authorities or authorized third parties if required or permitted by law. This includes situations involving compliance with legal obligations, claims asserted against us, or verified requests related to a criminal investigation, illegal activity, or any activity that may pose legal liability or harm to us and/or to you.
5. Protection and Compliance Assurance: These disclosures are critical for legal compliance, protection of interests or safety, enforcing terms and conditions, and maintaining the security and safety of our Services.
6. Notification of Legal Requests: Unless restricted by law, court order, or for reasons such as creating risk or harm, we may notify you about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Company and Platform. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that guest about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
7. To investigate, prevent, or act regarding suspected or actual prohibited activities, including but not limited to, fraud and situations involving potential threats to the physical safety of any person or to prevent financial loss to any person or entity, including  Company, its customers, clients, and other parties.
8. Engagement with Sub-Processors: We engage various third-party service providers to aid in delivering Website-related services and Platform access. These providers assist in the development, maintenance, debugging, and other supportive roles, limiting access to information and ensuring its protection in line with this Policy. You can find the list of sub-processors below  and they shall be governed by the privacy policies available on their websites. By using the Services and the Platform, you consent to the use of the sub-processors listed below. In the event of any changes to the sub-processors, we will intimate you about the same, and in the event you have an objection to the use of such sub-processor, please send the same within 15(fifteen) days of intimation, failing which, it shall be assumed that you have agreed to the engagement with such sub-processors
9. OpenAI is responsible for data processing, with its data policies outlined in the OpenAI Data Policy (you can access it at: https://openai.com/data-policy), which also governs its retention period. Together AI handles data hosting, and further details on its policies can be found in the Together AI Privacy documentation (you can access it at: https://together.ai/privacy). Similarly, LLAMA Index is involved in data processing, with its privacy and data retention guidelines available in the LLAMA Index Privacy section (you can access it at: https://llamaindex.ai/privacy).

OTHER RIGHTS THAT YOU HAVE

To exercise your data protection rights, you can make certain requests and ask us:

• Data Controller: If you are a visitor to the Platform,  you should know that the entities listed next to the Website is the controller of your personal data.
• Bases for using your information: We have a lawful basis to process your personal data, the purposes for processing personal data are described in this Privacy Policy under “How We Use Information we Collect”. You shall be required to determine the applicability based on whether you are a visitor or a user.  In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need the personal data to protect your vital interests or those of another person. We may disclose the following categories of personal data to third parties: identifiers/contact information, demographic information (such as gender and age), commercial information, internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above. We share each category with third-party business partners and service providers, third-party sites or platforms such as social networking sites, and other third parties as described in the “Sharing and Disclosure” section of this Privacy Policy.
• Your information protection rights: We respect the various rights available to you, as a user of our Platform. The rights provided to you are as listed below, To exercise these rights, please contact us at the following e-mail id: compliance@recrew.ai. 
• Right to Access: You can request access to the information we hold about you.
• Right to Rectification: You are responsible for keeping your personal information up-to-date. You have the right to ask us to correct inaccurate or incomplete personal information concerning you.
• Right to Erasure: You can request the deletion of your information.
• Right to Restrict Processing: You can restrict the processing of your information.
• Right to Data Portability: You can request an export of the information that we hold about you.
• Right to Object: You can object to the processing of your information.
• Right not to be Subject to Automated Processing: We do not conduct automated processing of any information. Human intervention is involved, making this right inapplicable to our processes.
• Right to refuse or withdraw consent: You can withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal.
  

2. YOUR OPT-OUT AND DELETION CHOICES

• You may opt-out by sending an e-mail at the following e-mail id: compliance@recrew.ai. When you do this, you will need to provide your name and any email addresses you would like “opted out” of our marketing databases. We cannot guarantee that we will be able to comply with your request if this information is incomplete or unintelligible.
• We will then remove your personal information from our active marketing databases, and maintain your information in our “suppression” database in order to maintain your opt-out status. We may require that you verify any of the information that you submit, such as through a verified email response or another verified response.
• If you would like to opt-out of direct mail advertising in general, we recommend that you visit the DMA Choice website, at dmachoice.thedma.org. The DMA Choice service is run by the Direct Marketing Association and allows you to follow few easy steps to ensure that your marketing preferences are honored.
• If you would like to delete your Data from our Database you may do so by sending an e-mail at the following e-mail id: compliance@recrew.ai. Please be sure to leave a message indicating your consumer preference, your name, you current address, your email address, and any prior home or email addresses you would like deleted of our marketing databases, and a callback number. We cannot guarantee that we will be able to comply with your request if this information is incomplete or unintelligible.
• If you wish to opt out of online targeted ads (sometimes referred to as “interest-based”, “behavioural” or “personalized” advertising), including those facilitated with our Information (as described in Section 2) you can also visit the opt-out portals operated the industry groups the National Advertising Initiative (NAI) or the Digital Advertising Alliance (DAA), and you can learn more about how those opt-outs work on those linked web pages. Please note that these online opt-outs are cookie-based (unlike our direct opt-out).  Thus, if you browse the web from multiple browsers or devices, you will need to opt out from each browser and/or device, and for the same reason, if you switch browsers or clear your browser cookies, you will need to perform this opt-out function again.  Opting-out in this way will not prevent you from seeing all types of online ads;  but it generally will prevent targeted ads customized to what advertisers think may be most likely to be relevant and of interest to you.
• If we market to you by email, in our corporate capacity – such as if you are a customer or prospective customer of ours and we send information about our Services — you may “unsubscribe” from our marketing emails through a link placed in your emails.
• To adjust your advertising preferences in iOS (version 12.4 and earlier), visit Settings > Privacy > Advertising > Limit Ad Tracking or Settings > Privacy > Advertising > Reset advertising ID. For version 14.5 and later, please visit Apple Support here. To adjust your advertising preferences in Android, visit Settings > Google > Ads > Opt out of interest-based ads or Settings > Google Services & Preferences > Ads > Opt out of Ads Personalization. Additionally, visit https://youradchoices.com/appchoices to download the AppChoices Tool to control interest-based advertising on apps on your mobile device and https://thenai.org/opt-out/mobile-opt-out/
  for more information and instructions on opting out on mobile device.

3. COOKIES AND SIMILAR TECHNOLOGIES

• Cookies and How We Use Them: We use certain industry-standard technologies, including cookies and similarly functional technologies, which we describe below.   We use these technologies on the Websites listed here, for instance, and our partners, data sources and customers may use these technologies to market to you.
• We may work with third parties to provide or enhance our services (e.g. for purposes of tailoring ads, or placing browser cookies), or to offer marketers ways to access or use our Information, often in de-identified form. These partners may set and access their own cookies, pixel tags and similar technologies on your device, which may have cookies with varying expiration periods. Those partners may likewise use cookies to collect various types of information about your browser, device, or browsing activities.
• We may use cookies to, among other things, “remember” you, determine visitor patterns and trends, collect information about your activities on our clients’ sites, or interact with the advertising you see.   Cookies are used in this way to provide relevant content to you and  ads that better match your interests.
• Disabling Cookies: Most web browsers are set up to accept cookies. You may be able to set your browser to warn you before accepting certain cookies or to refuse certain cookies. However, if you disable the use of cookies in your web browser, some features of our website and other services may be difficult to use or become inoperable.

4. DATA RETENTION. We retain your data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. If you wish to request the deletion of your data, please contact us at the following e-mail id: hello@recrew.ai

5. LINKS.  The Platform may provide links to other websites (or we may otherwise provide information about companies or events) that we think users will find interesting or useful.  We are not responsible for the privacy practices of these other sites or companies.

6. SECURITY AND DATA INTEGRITY:  We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your information, transmission of information to and from our Services is at your own risk. You should only access the Services within a secure environment.

7. CHILDREN’S PRIVACY. Our Services are not directed at children. We do not knowingly collect data from children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us using the details provided in Section 9 and we will take steps to delete their data.

8. STORAGE OF INFORMATION IN THE UNITED STATES. If you are accessing any of our Website(s) from a location outside of the United States, your connection will be through and to servers located in the United States and all Information you provide will  be processed and securely maintained in our web servers and internal systems located within the United States. Thus, you should be aware that in accessing this website or otherwise communicating with us, the information we collect or receive from you may be subject to laws with lesser or different privacy standards than those in your own country.

9. CHANGES AND UPDATE: We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

10. CONTACT: If you have questions or comments about this Privacy Policy or want to exercise your rights, you may email us at compliance@recrew.ai. Please note that we may refuse to act on requests to exercise information protection rights in certain cases, such as where providing access might infringe someone else’s privacy rights or impact our legal obligations.

TO U.S. STATE PRIVACY LAW STATE RESIDENTS

• Some U.S. states have privacy laws providing privacy rights to their residents. These laws include the; Texas Data Privacy Security Act (TDPSA), California Consumer Privacy Act (CCPA), Colorado Privacy Act, Connecticut Data Privacy Act, Montana Consumer Data Privacy Act, Oregon Consumer Privacy Act, Utah Consumer Privacy Act, and Virginia Consumer Data Protection Act. However, these rights are available to all Users located in the U.S.
• The Right to Opt Out of the Processing for Purposes of Sale and Targeted Advertising/“Share”: You have the right to opt out of the processing of your personal data for purposes of the sale of your personal data. Your personal data is “sold” when provided to a third party for monetary or other valuable consideration. Valuable consideration is a broad term and may cover the SysCode Entities listed above sharing data with their affiliates (if applicable). You have the right to opt out of the processing of your personal data for purposes of targeted advertising (also known as share under CCPA). SysCode uses targeted advertising to more effectively optimize our advertising and to show our users job ads that are more relevant to them. 
• The Right to Opt Out of Profiling in Furtherance of a Legal or Similarly Significant Effect: You have the right to opt out of the processing of personal data for purposes of profiling in furtherance of a decision that produces a legal or similarly significant effect. To opt out, please send an email to the e-mail Id’s listed in Section 13 of this Privacy Policy from the email address associated with your account.
• The right to Limit the Use of Your Sensitive Personal Data: Some states require SysCode Entities listed above to obtain consent prior to the collection of sensitive personal information. All sensitive data collected by respective SysCode Entities is with your consent, or as permitted or required under applicable laws. This includes  collection of some demographic data as part of our commitment to inclusivity and fairness. You can update or remove your demographic data at any time by sending an email to listed in Section 13 of this Privacy Policy from the email address associated with your account.  Some states provide users the right to limit the use and disclosure of sensitive personal information beyond what is necessary to perform the services as reasonably expected by users and those other activities allowed under its regulations. 
• The Right to Non-discrimination: You have a right to not be discriminated against for exercising any of your rights.

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• If you have been denied a request to exercise your rights as described in this section, you may appeal our decision by sending an email to the e-mail ids listed in Section 13 of this Privacy Policy from the email address associated with your account. If your appeal is declined, you may submit a complaint with your state’s Attorney General.
• Categories of Personal Data Shared with Third Parties: Company shares your personal data with third parties for a variety of reasons, and include employers, affiliates and/or advertisers. 
• Cookies and Tracking technologies : See above. 
• Please contact us at the e-mail ids listed in Section 13 of this Privacy Policy from the email address associated with your account.

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FOR CANADIAN RESIDENTS

• If you are a Canadian Resident, then, the we may process your information if you have given us specific permission (i.e., express consent) to use your information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time by contacting us at the e-mail ids listed in Section 13 of this Privacy Policy from the email address associated with your account.
• In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations

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EU/ EEA/ UK RESIDENTS

This notice provides additional information for users in the European Union (EU) and the United Kingdom (UK). Users in the EU and UK have certain privacy rights as specified under EU and UK law, including the General Data Protection Regulations (GDPR) and the UK Data Protection Act 2018. This notice ensures we cover the EU and UK-specific requirements. This notice should be read in conjunction with the rest of this Privacy Policy.

Data Controller: If you are a visitor to our Platform and a resident in the EU or UK, you should know that we are the controller of your personal data.

Bases for using your information: We have a lawful basis to process your personal data, the purposes for processing personal data are described in this Privacy Policy under “How We Process Your Information”. You shall be required to determine the applicability based on whether you are a visitor or a user.  In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need the personal data to protect your vital interests or those of another person. We may disclose the following categories of personal data to third parties: identifiers/contact information, demographic information (such as gender and age), commercial information, internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above. We share each category with third-party business partners and service providers, third-party sites or platforms such as social networking sites, and other third parties as described in the “When And With Whom We Share Your Information” section of this Privacy Policy.

Your information protection rights: We respect the various rights available to you, as a user of our Services. The rights provided to you are as listed below:

1. Right to Access: You can request access to the information we hold about you.
2. Right to Rectification: You can request us to rectify or correct any information about you.
3. Right to Erasure: You can request the deletion of your information.
4. Right to Restrict Processing: You can restrict the processing of your information.
5. Right to Data Portability: You can request an export of the information that we hold about you.
6. Right to Object: You can object to the processing of your information.
7. Right to refuse or withdraw consent: You can withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal.

AI Use Notice for Employment & Recruitment

The platform uses Artificial Intelligence (AI) to assist in the recruitment process, including CV parsing, candidate screening, and matching job opportunities based on qualifications and experience. AI may analyze your submitted CV and application details to provide recommendations to recruiters and employers. By submitting your application, you acknowledge that AI may process your personal data for these purposes. 

If you do not want your application to be processed through AI, You have the right to the following, which may be undertaken by contacting us at the e-mail id listed in Section 13 of this Privacy Policy from the email address associated with your account:

• Request human review of automated decisions,
• Obtain further explanation on how AI influences hiring outcomes,
• Correct or update your data, and
• Object to AI processing under applicable laws.

‍For more details, please refer to our AI Transparency Notice, in addition to this Privacy Policy.