Privacy Policy

BeWanted, Inc., a Delaware corporation doing business as Vamo ("Vamo," "we," "us," or "our"), is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard information when you use our platform, services, website, and related offerings (collectively, the "Services"). By accessing or using our Services, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy.

This Privacy Policy applies to all users of our Services, including job seekers ("Candidates"), employers and recruiters ("Clients"), and website visitors. If you do not agree with this Privacy Policy, please do not use our Services.

Our Use of Artificial Intelligence

Vamo uses artificial intelligence and machine learning technologies to provide effective talent recruitment and matching services. Our AI-powered platform helps Clients discover, evaluate, and engage with qualified software engineering Candidates who meet specific criteria.

AI-Powered Features

Our AI and machine learning systems are used to:

• Match Candidates with job opportunities based on skills, experience, and requirements;
• Generate Candidate recommendations and matching scores;
• Analyze and assess technical skills and qualifications;
• Personalize search results and Platform experiences;
• Infer additional characteristics about Candidates based on profile information (such as skill levels, experience categories, or potential job fit); and
• Improve and optimize our Services and matching algorithms.

Third-Party AI Providers

We may use third-party AI service providers to power certain features of our Platform. When we engage third-party AI providers:

• We contractually prohibit these providers from using your data to train their own AI models or for any purpose other than facilitating our Services;
• We require these providers to delete your data within thirty (30) days unless otherwise required by law;
• We remain responsible for ensuring these providers comply with this Privacy Policy and applicable data protection laws; and
• We conduct due diligence on AI providers to ensure appropriate data protection measures.

Automated Decision-Making

Our AI systems may make automated recommendations or generate matching scores, but final hiring decisions are always made by Clients, not by automated systems alone. Candidates have the right to object to automated decision-making that produces legal effects or similarly significantly affects them. To exercise this right or learn more about our automated processing, contact us at legal@vamo.app.

Opting Out of AI Features

Clients may request to limit or opt out of certain AI-powered features by contacting their account manager or our support team at support@vamo.app. Please note that opting out of AI features may limit the functionality and effectiveness of our Services.

1. Information We Collect

We collect various types of information in connection with the Services, including:

1.1 Information You Provide Directly

Account Registration Information: When you create an account, we collect your name, email address, phone number, company name (for Clients), job title, password, and other registration details.

Profile Information: For Candidates, we collect professional information including resumes, CVs, work history, education, skills, certifications, portfolios, GitHub profiles, LinkedIn profiles, salary expectations, work authorization status, and location preferences. For Clients, we collect company information, hiring needs, job descriptions, and organizational details.

Communications: We collect information from your communications with us, including messages, emails, chat conversations, support requests, feedback, and survey responses.

Payment Information: If you make payments through our Services, we collect billing information, including payment card details, billing address, and transaction history. Payment processing is handled by third-party payment processors who collect and process your payment information in accordance with their own privacy policies.

Assessment and Evaluation Data: We collect information from technical assessments, coding challenges, skills tests, interview feedback, and performance evaluations.

1.2 Information Collected Automatically

Device and Usage Information: We automatically collect information about your device and how you interact with our Services, including IP address, browser type and version, operating system, device identifiers, screen resolution, pages visited, time spent on pages, links clicked, referring URLs, and access times.

Cookies and Tracking Technologies: We use cookies, web beacons, pixel tags, and similar tracking technologies to collect information about your browsing activities. For more information, see Section 8 (Cookies and Tracking Technologies).

Location Information: We may collect general location information based on your IP address or more precise location data if you grant permission through your device settings.

1.3 Information from Third-Party Sources

Publicly Available Professional Profiles: If you have a profile, resume, or CV on publicly available websites such as LinkedIn, GitHub, Stack Overflow, personal websites, or other professional networking platforms, we may collect publicly accessible information about your professional qualifications and contact information. This information may include your name, education, work history, job titles, skills, certifications, publications, projects, years of experience, contact information (email address and phone number if publicly listed), and other employment-related information. We collect this information to provide Candidate profiles to our Clients for recruitment purposes. We do not collect sensitive personal data (such as health information, political affiliations, or protected characteristics) from public sources.

Other Third-Party Sources:

• Professional networking platforms (e.g., LinkedIn, GitHub);
• Background check providers and verification services;
• Publicly available sources and databases;
• Referral sources and references you provide;
• Data analytics and marketing partners; and
• Other users who provide information about you (e.g., referrals, recommendations).

2. How We Use Your Information

We use the information we collect for the following purposes:

2.1 Providing and Managing Services

• Creating and managing your account;
• Facilitating connections between Candidates and Clients;
• Processing job applications and recruitment activities;
• Conducting technical assessments and skills evaluations;
• Coordinating interviews and communications;
• Processing payments and transactions; and
• Providing customer support and responding to inquiries.

2.2 Personalization and Recommendations

• Matching Candidates with relevant job opportunities;
• Recommending Candidates to Clients based on job requirements;
• Personalizing your experience on the Platform; and
• Providing tailored content and suggestions.

2.3 Communication and Marketing

• Sending transactional emails and notifications related to your use of the Services;
• Providing updates about job opportunities, platform features, and service announcements;
• Sending marketing communications, newsletters, and promotional materials (with your consent where required); and
• Conducting surveys and soliciting feedback.

2.4 Analytics and Improvement

• Analyzing usage patterns and trends;
• Improving our Services, algorithms, and matching technology;
• Developing new features and products;
• Conducting research and data analysis; and
• Testing and optimizing platform performance.

2.5 Security and Legal Compliance

• Detecting, preventing, and addressing fraud, security breaches, and technical issues;
• Verifying identity and preventing unauthorized access;
• Enforcing our Terms of Service and other policies;
• Complying with legal obligations and responding to lawful requests; and
• Protecting our rights, property, and safety, and that of our users.

3. How We Share Your Information

We may share your information in the following circumstances:

3.1 With Clients and Candidates

We share Candidate profiles and information with Clients for recruitment purposes. When a Candidate applies to a job or is recommended for a position, we share relevant professional information with the Client. Candidates control the visibility of their profiles and can choose which information to share.

3.2 With Service Providers

We share information with third-party service providers who perform services on our behalf, including:

• Cloud hosting and infrastructure providers;
• Payment processors and financial institutions;
• Email and communication service providers;
• Analytics and data analysis providers;
• Background check and verification services;
• Customer support and help desk platforms;
• Marketing and advertising partners; and
• Security and fraud prevention services.

These service providers are contractually obligated to use your information only as necessary to provide services to us and to protect your information.

3.3 For Legal Reasons

We may disclose your information when required by law or when we believe in good faith that such disclosure is necessary to:

• Comply with legal obligations, court orders, subpoenas, or other legal processes;
• Respond to lawful requests from government authorities;
• Enforce our Terms of Service and other agreements;
• Protect our rights, property, and safety, or that of our users or the public;
• Detect, prevent, or address fraud, security, or technical issues; and
• Prevent harm or illegal activities.

3.4 Business Transfers

If we are involved in a merger, acquisition, asset sale, bankruptcy, reorganization, or similar transaction, your information may be transferred as part of that transaction. We will notify you of any such transfer and any choices you may have regarding your information.

3.5 With Your Consent

We may share your information with third parties when we have your explicit consent to do so.

3.6 Aggregated and De-Identified Information

We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you. Such information is not subject to this Privacy Policy.

4. Data Retention

We retain your personal information 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. The specific retention period depends on the nature of the information and the purposes for which it is processed.

Specific Retention Periods

• Account Information: We retain your account information for as long as your account is active or as needed to provide Services. If you close your account, we may retain certain information for legitimate business purposes, legal compliance, fraud prevention, or dispute resolution for up to seven (7) years after account closure.
• Candidate Profiles: Candidate profiles collected from public sources remain in our database until the Candidate requests removal or opts out. Upon verified opt-out request, profiles are removed from active use within ten (10) business days, though certain information may be retained for legal compliance, fraud prevention, or dispute resolution.
• Client-Created Candidate Data: Retained according to the Client's instructions and our agreement with the Client, or until the Client requests deletion.
• Communications: We retain communications records (emails, support tickets, chat logs) for reasonable periods to provide support, resolve disputes, and comply with legal obligations, typically for three (3) years after the last communication.
• Transaction Records: Financial and payment information is retained as required by law and accounting standards, typically for at least seven (7) years from the date of the transaction.
• Marketing Data: Marketing communications preferences and engagement data are retained until you unsubscribe, plus an additional two (2) years to honor your preferences and comply with legal obligations.
• Analytics Data: Usage and analytics data may be retained in aggregated or de-identified form indefinitely for research, product improvement, and analysis purposes, as such data cannot be attributed to any individual.
• Legal Holds: When information is subject to legal holds, litigation, investigations, or regulatory requests, we retain such information until the hold is lifted or the matter is resolved, which may exceed the standard retention periods.

When we destroy personal information, we do so in a manner that prevents that information from being restored or reconstructed. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the information and whether we can achieve those purposes through other means, and applicable legal and regulatory requirements.

5. Your Rights and Choices

Depending on your location and applicable law, you may have certain rights regarding your personal information:

5.1 Access and Portability

You have the right to request access to the personal information we hold about you and to receive a copy of such information in a structured, commonly used, and machine-readable format.

5.2 Correction and Update

You have the right to request correction of inaccurate personal information and to update incomplete information. You can update most information directly through your account settings.

5.3 Deletion

You have the right to request deletion of your personal information, subject to certain exceptions (e.g., legal obligations, legitimate business interests, fraud prevention). To delete your account, contact us at legal@vamo.app.

5.4 Objection and Restriction

You have the right to object to certain processing of your personal information and to request restriction of processing in certain circumstances.

5.5 Withdraw Consent

Where we rely on your consent to process personal information, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before withdrawal.

5.6 Marketing Communications

You can opt out of marketing emails by clicking the "unsubscribe" link in any marketing email or by adjusting your account settings. Note that you cannot opt out of transactional or service-related communications.

5.7 Do Not Track

Some browsers have "Do Not Track" features. Currently, there is no industry standard for how to respond to these signals, and we do not respond to Do Not Track signals.

5.8 Exercising Your Rights

To exercise any of these rights, please contact us at legal@vamo.app. We will respond to your request within the timeframe required by applicable law, typically within 30 days. We may request additional information to verify your identity before processing your request.

5.9 Candidate Profile Removal and Opt-Out

If you are a software engineer, developer, or other Candidate whose professional information appears on our Platform and you wish to opt out or have your profile removed:

1. We will remove your profile from our Platform and search results within ten (10) business days of your verified request;
2. We will cease sharing your information with new Clients;
3. We will not use your information for matching or recommendations;
4. Clients who previously accessed your profile through our Platform may retain it in accordance with their own data retention policies and legal obligations, but we will not provide them with updated information; and
5. To request profile removal, contact us at legal@vamo.app with your full name, email address, and any other identifying information to help us locate your profile.

Please note that if your information is publicly available on the internet, removal from our Platform does not remove it from the original public sources. We may be required to retain certain information for legal compliance, fraud prevention, or dispute resolution purposes even after removal from active use.

6. International Data Transfers

Vamo is based in the United States. If you access our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States and other countries where our service providers operate.

These countries may have data protection laws that differ from those in your country. By using our Services, you consent to the transfer of your information to the United States and other countries. We take appropriate safeguards to ensure that your personal information remains protected in accordance with this Privacy Policy, including:

• Standard contractual clauses approved by the European Commission;
• Data processing agreements with third-party service providers;
• Adherence to recognized privacy frameworks and certifications; and
• Other legally recognized transfer mechanisms.

7. Data Security

We implement reasonable administrative, technical, and physical security measures designed to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures include:

• Encryption of data in transit and at rest using industry-standard protocols;
• Secure socket layer (SSL) technology for data transmission;
• Access controls and authentication mechanisms;
• Regular security assessments and vulnerability testing;
• Employee training on data protection and security practices;
• Network firewalls and intrusion detection systems; and
• Incident response and breach notification procedures.

However, no method of transmission over the Internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for any activities that occur under your account.

In the event of a data breach that affects your personal information, we will notify you and applicable regulatory authorities as required by law.

7.1 Client-Created Candidate Profiles

When Clients upload their own Candidate data to our Platform or create custom Candidate profiles from information they independently maintain, Vamo acts as a data processor or service provider on behalf of that Client. In these situations:

• The Client is the data controller and is responsible for compliance with data protection laws;
• We process this data only on behalf of and according to the instructions of that Client;
• This Client-uploaded Candidate data is not made available to other Clients using our Platform; and
• Candidates should direct privacy requests regarding Client-uploaded data to the Client who uploaded their information.

7.2 Google API Services Compliance

To the extent we use Google API Services (such as Google Workspace APIs, Gmail API, Google Calendar API, or other Google services), our use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. We do not use information received from Google Workspace APIs to develop, improve, or train generalized artificial intelligence or machine learning models.

8. Cookies and Tracking Technologies

We use cookies, web beacons, pixel tags, and similar tracking technologies to collect information about your browsing activities and to provide, personalize, and improve our Services.

8.1 Types of Cookies We Use

• Essential Cookies: Required for the operation of our Services, enabling core functionality such as security, authentication, and network management.
• Performance and Analytics Cookies: Help us understand how visitors interact with our Services by collecting information about pages visited, time spent, and other usage data.
• Functionality Cookies: Allow us to remember your preferences and provide enhanced, personalized features.
• Advertising and Marketing Cookies: Used to deliver relevant advertisements and measure the effectiveness of marketing campaigns.

8.2 Third-Party Cookies

We may allow third-party service providers, including analytics providers (e.g., Google Analytics) and advertising networks, to place cookies on our Services. These third parties may collect information about your online activities over time and across different websites.

8.3 Managing Cookies

Most web browsers are set to accept cookies by default. You can adjust your browser settings to refuse cookies or alert you when cookies are being sent. However, disabling cookies may affect the functionality and performance of our Services. You can also opt out of certain third-party cookies through industry opt-out mechanisms such as the Network Advertising Initiative (NAI) or the Digital Advertising Alliance (DAA).

9. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us at legal@vamo.app. If we become aware that we have collected personal information from a child under 18 without parental consent, we will take steps to delete that information.

10. California Privacy Rights

If you are a California resident, the California Consumer Privacy Act ("CCPA") provides you with specific rights regarding your personal information:

10.1 Right to Know

You have the right to request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collection, and the categories of third parties with whom we share personal information.

10.2 Right to Delete

You have the right to request deletion of your personal information, subject to certain exceptions.

10.3 Right to Opt Out of Sale

We do not sell personal information as defined by the CCPA. If our practices change, we will update this Privacy Policy and provide you with the opportunity to opt out.

10.4 Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising your CCPA rights.

10.5 Authorized Agents

You may designate an authorized agent to make requests on your behalf. We will require verification of the agent's authority to act on your behalf.

To exercise your CCPA rights, contact us at legal@vamo.app or through our designated request form. We will verify your identity and respond within 45 days.

10.6 California Shine the Light Law

In addition to the CCPA, California's "Shine the Light" law (Civil Code Section 1798.83) permits California residents to request information about our disclosure of personal information to third parties for their direct marketing purposes. We do not share personal information with third parties for their direct marketing purposes without your consent. If you want to opt out of any sharing of your information for direct marketing purposes, please contact us at legal@vamo.app.

11. European Privacy Rights (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, the General Data Protection Regulation ("GDPR") and related laws provide you with specific rights:

11.1 Legal Basis for Processing

We process personal information based on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contract with you (e.g., providing Services);
• Consent: You have given explicit consent for specific processing activities;
• Legitimate Interests: Processing is necessary for our legitimate business interests (e.g., improving Services, fraud prevention), provided such interests are not overridden by your rights; and
• Legal Compliance: Processing is necessary to comply with legal obligations.

11.2 Your GDPR Rights

Under GDPR, you have the rights described in Section 5 (Your Rights and Choices), including access, rectification, erasure, data portability, objection, and restriction of processing. You also have the right to lodge a complaint with a supervisory authority if you believe your rights have been violated.

11.3 Data Protection Officer

For questions about data protection or to exercise your GDPR rights, contact us at legal@vamo.app.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify you by:

• Posting the updated Privacy Policy on our website with a revised "Last Updated" date;
• Sending an email notification to the address associated with your account; or
• Displaying a prominent notice on the Platform.

We encourage you to review this Privacy Policy periodically. Your continued use of the Services after we post changes constitutes your acceptance of the updated Privacy Policy.

13. Third-Party Links and Services

Our Services may contain links to third-party websites, applications, or services that are not owned or controlled by Vamo. This Privacy Policy does not apply to such third-party sites or services. We are not responsible for the privacy practices or content of third parties. We encourage you to review the privacy policies of any third-party sites or services before providing any personal information.

14. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

BeWanted, Inc. (DBA Vamo)
Email: legal@vamo.app
Website: vamotalent.com