Privacy Policy

General Privacy Policy

Carbon Technology Group, Inc.

Effective Date: November 1, 2025

Last Updated: November 1, 2025


Introduction

Welcome to Carbon Technology Group, Inc. ("Carbon," "we," "us," or "our"). We provide AI-powered recruiting and hiring software (the "Services" or "Platform") to businesses and organizations ("Customers") to help them evaluate job applicants and candidates ("Applicants" or "you").

This Privacy Policy explains:

  • What information we collect from Applicants who use our Platform
  • How we use, share, and protect that information
  • Your rights and choices regarding your information
  • How we use artificial intelligence and machine learning
  • Special protections for voice recordings and biometric data
  • Your rights under California and other state privacy laws

Important: Carbon provides technology services to employers. We process Applicant information on behalf of our Customers (the employers). The employer who directed you to our Platform is the organization making hiring decisions, not Carbon.


Table of Contents

  1. Information We Collect
  2. How We Use Your Information
  3. Artificial Intelligence and Automated Decision-Making
  4. Voice Recordings and Biometric Information
  5. How We Share Your Information
  6. Data Retention and Deletion
  7. Your Rights and Choices
  8. State-Specific Privacy Rights
  9. Communications and Text Messaging
  10. Data Security
  11. Children's Privacy
  12. International Data Transfers
  13. Changes to This Privacy Policy
  14. Contact Us

1. Information We Collect

1.1 Information You Provide Directly

When you apply for a job through our Platform, we collect information you provide, including:

Contact Information:

  • Name
  • Email address
  • Phone number
  • Mailing address (if provided)

Application Information:

  • Resume or CV
  • Cover letter
  • Work history and experience
  • Education and qualifications
  • Skills and certifications
  • References (if provided)
  • Responses to application questions

Interview Information:

  • Voice recordings of interviews (voice-only, no video)
  • Transcripts of your interview responses
  • Assessment results and scores

Communication Preferences:

  • Whether you consent to receive text messages and phone calls
  • Preferred method of communication (text, call, or email)

1.2 Information Collected Automatically

When you use our Platform, we automatically collect:

Device and Usage Information:

  • IP address
  • Browser type and version
  • Device type (computer, mobile, tablet)
  • Operating system
  • Pages visited and actions taken on our Platform
  • Date and time of your visit

Cookies and Similar Technologies:

We use cookies and similar technologies to operate our Platform and improve your experience. See our Cookie Policy for details.

1.3 Information From Third Parties

We may receive information about you from:

Employers/Customers:

  • The employer who directed you to our Platform may provide us with information about the position you're applying for
  • Job posting details and requirements

Integration Partners:

  • If the employer uses third-party systems (like an Applicant Tracking System), we may receive information through those integrations

2. How We Use Your Information

2.1 Primary Purposes

We use your information to:

Provide Services to Employers:

  • Process your job application
  • Conduct interviews and assessments
  • Evaluate your qualifications for positions
  • Generate candidate scores and recommendations for the employer
  • Facilitate communication between you and the employer

Operate and Improve Our Platform:

  • Provide, maintain, and improve our Services
  • Develop new features and functionality
  • Troubleshoot technical issues
  • Ensure Platform security and prevent fraud

Communicate With You:

  • Send interview invitations and scheduling information
  • Provide updates about your application status (if you've consented)
  • Respond to your questions or requests
  • Send important notices about our Services

2.2 AI and Machine Learning

We use your information to:

  • Train and improve our AI models and algorithms
  • Develop better candidate assessment tools
  • Improve transcription and natural language processing capabilities

Note: We only use de-identified and aggregated data for AI training. Your individual information is never used to train our models in a way that could identify you. See Section 3 for more details.

2.3 Legal and Compliance Purposes

We use your information to:

  • Comply with applicable laws and regulations
  • Respond to legal requests (subpoenas, court orders, etc.)
  • Enforce our Terms of Service
  • Protect our rights, property, and safety, and the rights of others

3. Artificial Intelligence and Automated Decision-Making

3.1 How We Use AI

Carbon uses artificial intelligence and machine learning technologies to:

Analyze Resume Content:

  • Extract information from your resume (work history, skills, education)
  • Match your qualifications against job requirements
  • Generate a preliminary score based on job relevance

Conduct Voice Interviews:

  • Transcribe your spoken responses using speech-to-text AI
  • Analyze the content of your answers (what you said, not how you said it)
  • If the employer has enabled this feature: assess your spoken language communication ability (for positions where this is a job requirement)

Generate Assessments:

  • Create summary reports for employers
  • Highlight relevant qualifications and experience
  • Provide scores or ratings based on employer-defined criteria

3.2 Important Limitations of AI

AI is Not Perfect:

  • Our AI may make mistakes, misunderstand responses, or produce inaccurate results
  • AI-generated scores and assessments are probabilistic and should not be the sole basis for hiring decisions
  • Employers are required to exercise human review and judgment before making hiring decisions

AI Does Not Make Hiring Decisions:

  • Carbon's AI provides information and recommendations only
  • The employer makes all final hiring decisions
  • You are being evaluated by the employer, not by Carbon's AI alone

You Can Opt Out:

  • You can request a human-conducted interview instead of an AI interview
  • You can request human-only resume review instead of AI-assisted review
  • Declining AI does not negatively affect your application

3.3 Language Proficiency Assessment (If Applicable)

When Enabled: Some employers enable our spoken language proficiency assessment feature for positions where effective communication in a specific language is required for the job (for example, positions requiring English communication for patient safety or team collaboration).

What We Assess:

  • Clarity and comprehensibility of your spoken responses
  • Ability to understand and respond to questions
  • Grammar, vocabulary, and communication effectiveness
  • This is similar to an oral language proficiency test

What We Do NOT Assess:

  • Your accent or national origin
  • Voice characteristics for identity verification
  • Personality traits or emotional state
  • Any characteristics unrelated to job-required communication ability

Legal Basis:

  • The employer has determined that language proficiency is a bona fide occupational qualification (BFOQ) for the specific position
  • The requirement must be job-related and consistent with business necessity
  • The employer provides the justification in the job posting

Your Rights:

  • You can choose a human-conducted interview instead
  • Human interviewers will also assess language proficiency if it's a job requirement
  • You can contact us if you believe the assessment is discriminatory

3.4 Bias and Fairness

Our Commitment:

  • We design our AI to be as fair and unbiased as possible
  • We regularly test our models for bias and discrimination
  • We provide tools for employers to monitor for disparate impact

Employer Responsibility:

  • Employers are responsible for configuring criteria and thresholds
  • Employers must conduct bias testing as required by law
  • Employers must ensure their use of our Platform does not discriminate

Report Concerns: If you believe our AI has discriminated against you based on a protected characteristic, please contact us at privacy@carbontechnology.ai.


4. Voice Recordings and Biometric Information

4.1 Voice-Only Interviews

What We Collect:

  • Audio recordings of your interview responses (voice-only, no video)
  • Our interviews do NOT use video, facial recognition, or facial analysis

How We Use Voice Recordings:

  • Transcribe your speech to text using AI
  • Analyze the content of your responses
  • If enabled by the employer: assess spoken language communication ability
  • Quality assurance and system improvement

What We Do NOT Do:

  • Use your voice to identify or authenticate you
  • Create a permanent "voiceprint" database
  • Match your voice against other recordings
  • Analyze voice characteristics unrelated to communication (e.g., emotion, personality)

4.2 Retention and Deletion

Short Retention Period:

  • Voice recordings are automatically and permanently deleted 5 days after recording
  • This is a strict automatic process - recordings cannot be kept longer
  • Transcripts may be retained longer as part of your application record

Why 5 Days:

  • Allows time for quality assurance and technical issues
  • Minimizes privacy risk by not creating a permanent voice database
  • Balances business needs with your privacy rights

4.3 Special Notice for Illinois, Texas, and Washington Residents

Biometric Information Laws: Your state has special laws governing "biometric information," which may include voice recordings.

Illinois Residents (BIPA):

Under the Illinois Biometric Information Privacy Act:

  • We obtain your written consent before collecting voice data
  • We disclose the purpose and retention period
  • We will not sell, lease, or trade your voice data
  • You have the right to refuse without penalty
  • Voice recordings are deleted after 5 days

Texas Residents (CUBI):

Under the Texas Capture or Use of Biometric Identifier Act:

  • We obtain consent before capturing voice data
  • We will not sell, lease, or trade your voice data
  • Voice recordings are deleted after 5 days

Washington Residents:

Under Washington's biometric privacy law:

  • We provide notice before collecting biometric data
  • We obtain consent before collection
  • We will not enroll you in a facial recognition service (we don't use facial recognition)
  • Voice recordings are deleted after 5 days

Your Rights in These States:

  • Right to refuse voice recording without penalty
  • Right to request deletion of your voice data
  • Right to know how long we retain your data (5 days for recordings)
  • Alternative interview methods available (human-conducted interviews)

Contact for Biometric Privacy: privacy@carbontechnology.ai

4.4 Two-Party Consent States

If you are located in California, Connecticut, Florida, Illinois, Maryland, Massachusetts, Michigan, Montana, Nevada, New Hampshire, Pennsylvania, or Washington, we obtain your explicit consent before recording any conversation with you, as required by your state's recording laws.


5. How We Share Your Information

5.1 With the Employer

Primary Sharing: We share your information with the employer you're applying to, including:

  • Your resume and application materials
  • Interview transcripts and responses
  • Assessment scores and AI-generated recommendations
  • Communication preferences and contact information

The Employer Controls:

  • The employer decides whether to advance your application
  • The employer makes all hiring decisions
  • The employer has access to your information through our Platform

5.2 With Service Providers

We share information with third-party service providers who help us operate our Platform:

Technology Providers:

  • Cloud hosting providers (for data storage)
  • AI and machine learning service providers (for transcription and analysis)
  • Communication providers (for SMS/MMS and voice calls)
  • Analytics providers (for Platform improvement)

Contractual Protections:

  • All service providers are contractually required to protect your information
  • They can only use your information to provide services to us
  • They cannot sell or use your information for their own purposes

Current Service Providers: You can see our list of service providers at carbontechnology.ai/subprocessors

5.3 For Legal Reasons

We may share your information:

  • To comply with laws, regulations, or legal processes
  • To respond to lawful requests from government authorities
  • To enforce our Terms of Service or protect our legal rights
  • To protect the safety, rights, or property of Carbon, our users, or others
  • In connection with a merger, acquisition, or sale of assets (with notice to you)

5.4 With Your Consent

We may share your information with other parties when you give us permission to do so.

5.5 What We Do NOT Do

We Do Not:

  • Sell your personal information to third parties
  • Share your information with advertisers or marketers
  • Use your information for purposes unrelated to providing our Services
  • Share your voice recordings with anyone except as described in this policy

6. Data Retention and Deletion

6.1 How Long We Keep Your Information

Voice Recordings:

  • Automatically deleted after 5 days (permanent deletion)
  • Cannot be recovered after deletion
  • Deletion logs maintained for compliance

Interview Transcripts:

  • Retained as part of your application record
  • Retention period determined by the employer (typically 1-3 years)
  • Deleted when the employer requests deletion or upon contract termination

Application Materials:

  • Retained for as long as the employer maintains your application record
  • Typically 1-3 years after final hiring decision
  • May be retained longer if required by law (e.g., EEOC record-keeping)

Account Information:

  • Deleted when you request deletion (see Section 7)
  • May be retained for legal/compliance purposes as required by law

6.2 Automatic Deletion

Voice Recording Deletion Process:

  1. Voice recording captured during interview
  2. Transcription completed (usually within hours)
  3. Recording flagged for deletion 5 days after capture
  4. Automated deletion job runs daily and permanently deletes recordings older than 5 days
  5. Deletion logged for audit purposes

6.3 When We Delete Everything

Upon Request:

  • You can request deletion of your information at any time (see Section 7)
  • We will delete within 30-45 days unless retention is required by law

When Employer Relationship Ends:

  • When an employer stops using our Services, we delete or return their data
  • Applicant data is deleted within 30 days of contract termination
  • Exception: Data required by law may be retained longer

Aggregated Data:

  • We may retain de-identified, aggregated data indefinitely
  • This data cannot be traced back to you individually
  • Used for research, analytics, and AI improvement

7. Your Rights and Choices

7.1 Access Your Information

Right to Know: You can request to know what personal information we have collected about you, including:

  • Categories of information collected
  • Sources of information
  • Purposes for collection and use
  • Categories of third parties we share with

How to Request: Email privacy@carbontechnology.ai with subject line: "Access Request"

Response Time: We will respond within 45 days (may be extended by 45 days if needed)

7.2 Correct Your Information

Right to Correction: If your information is inaccurate or incomplete, you can request correction.

How to Request:

  • Email privacy@carbontechnology.ai with subject line: "Correction Request"
  • Specify what information needs correction and provide accurate information

7.3 Delete Your Information

Right to Deletion: You can request deletion of your personal information.

Exceptions: We may need to retain information to:

  • Complete the transaction for which it was collected (process your application)
  • Comply with legal obligations
  • Exercise or defend legal claims
  • Detect and prevent fraud or security incidents

How to Request: Email privacy@carbontechnology.ai with subject line: "Deletion Request"

What Gets Deleted:

  • Your application materials
  • Interview transcripts (if not legally required to retain)
  • Contact information
  • Voice recordings (already auto-deleted after 5 days)

Note: We will confirm your identity before processing deletion requests.

7.4 Opt Out of AI

You Can Choose:

  • Human-only resume review (instead of AI-assisted review)
  • Human-conducted interview (instead of AI interview)
  • Email-only communication (instead of text/call)

How to Opt Out:

  • Select your preference during the application process
  • Or email support@carbontechnology.ai

No Penalty: Opting out of AI does not negatively affect your application.

7.5 Opt Out of Text Messages and Calls

Your Choices:

  • You can opt out of text messages by texting STOP to any message we send
  • You can opt out of phone calls by emailing privacy@carbontechnology.ai
  • You can choose email-only communication during the application process

Immediate Opt-Out:

  • STOP requests are processed immediately (within seconds)
  • You will receive a confirmation message
  • We maintain a do-not-contact list to ensure compliance

7.6 Object to Processing

Your Right: You can object to our processing of your information for certain purposes.

How to Object: Email privacy@carbontechnology.ai with subject line: "Objection to Processing"

7.7 Data Portability

Your Right: You can request a copy of your information in a portable format (CSV, JSON, PDF).

How to Request: Email privacy@carbontechnology.ai with subject line: "Data Portability Request"


8. State-Specific Privacy Rights

8.1 California Residents (CCPA/CPRA)

Your California Privacy Rights:

Right to Know:

  • Categories of personal information collected
  • Categories of sources
  • Business/commercial purposes for collection
  • Categories of third parties we share with
  • Specific pieces of information collected

Right to Delete: Request deletion of personal information (subject to exceptions)

Right to Correct: Request correction of inaccurate information

Right to Opt Out of Sale/Sharing:

  • We do NOT sell your personal information
  • We do NOT share your personal information for cross-context behavioral advertising

Right to Limit Use of Sensitive Personal Information:

  • Voice recordings are considered "sensitive personal information"
  • We only use voice recordings for providing our Services (as disclosed to you)
  • You can limit use by not providing voice recordings (choose human interview)

Right to Non-Discrimination:

  • We will not discriminate against you for exercising your privacy rights
  • We will not deny services, charge different prices, or provide different quality of service

Shine the Light Law: If you are a California resident, you can request information about personal information shared with third parties for their direct marketing purposes. We do not share your information for direct marketing.

How to Exercise California Rights:

  • Email: privacy@carbontechnology.ai
  • Phone: (555) 123-4567
  • Online form: carbontechnology.ai/privacy-request

Authorized Agent: You may designate an authorized agent to make requests on your behalf. The agent must provide proof of authorization.

Verification: We will verify your identity before responding to requests (to protect your privacy).

Response Time: 45 days (may be extended by 45 days with notice)

Appeals: If you are dissatisfied with our response, you may appeal by emailing privacy@carbontechnology.ai with subject line: "CCPA Appeal"

8.2 Virginia, Colorado, Connecticut, Utah, and Other State Residents

If you reside in Virginia, Colorado, Connecticut, Utah, or another state with comprehensive privacy laws, you have similar rights:

Rights:

  • Right to confirm whether we process your personal data
  • Right to access your personal data
  • Right to correct inaccuracies
  • Right to delete your personal data
  • Right to obtain a copy of your data (portability)
  • Right to opt out of: (1) targeted advertising (we don't do this), (2) sale of personal data (we don't do this), (3) profiling in furtherance of decisions with legal/similarly significant effects

How to Exercise Rights: Email privacy@carbontechnology.ai or use our online form at carbontechnology.ai/privacy-request

Appeals Process: If we deny your request, you may appeal by emailing privacy@carbontechnology.ai with subject line: "Privacy Appeal - [Your State]"

8.3 Illinois, Texas, and Washington Residents

See Section 4.3 for your rights under biometric privacy laws.


9. Communications and Text Messaging

9.1 Types of Communications

We may contact you via:

  • Email: Application updates, interview invitations, important notices
  • Text Messages (SMS/MMS): If you consent, we may send application updates and reminders
  • Phone Calls: If you consent, we may call you about your application

9.2 Text Messaging (SMS/MMS)

Your Consent:

  • We only send text messages if you explicitly consent
  • You provide consent during the application process
  • Consent is optional - you can choose email-only communication

What We Text:

  • Interview invitations and reminders
  • Application status updates
  • Links to complete assessments
  • Important time-sensitive information

Message Frequency:

  • Varies depending on your application status
  • Typically 2-5 messages per application

Message and Data Rates:

  • Standard message and data rates may apply
  • Contact your mobile carrier for details about your plan

How to Opt Out:

  • Text STOP to any message we send (immediate opt-out)
  • Email privacy@carbontechnology.ai
  • Change preferences in your application portal

Help: Text HELP for assistance or email support@carbontechnology.ai

Carriers Supported:

  • Major carriers supported (AT&T, T-Mobile, Verizon, Sprint, etc.)
  • Message delivery may vary by carrier

TCPA Compliance:

  • We comply with the Telephone Consumer Protection Act (TCPA)
  • We obtain express written consent before sending marketing or promotional texts
  • We maintain do-not-contact lists
  • We honor opt-out requests immediately

9.3 Phone Calls

Your Consent:

  • We only call you if you consent
  • You provide consent during the application process
  • Calls may be automatically dialed or prerecorded

Purpose of Calls:

  • Interview scheduling
  • Application updates (if urgent)
  • Responding to your inquiries

How to Opt Out:

  • Select "email only" during application process
  • Email privacy@carbontechnology.ai
  • Tell us during any call that you'd like to opt out

9.4 Email Communications

You Will Always Receive:

  • Essential communications about your application (cannot opt out)
  • Important notices about our Services or this Privacy Policy

Optional Communications:

  • Application status updates
  • Interview tips and preparation materials

How to Opt Out:

  • Click "unsubscribe" in any email
  • Email privacy@carbontechnology.ai
  • Change preferences in your application portal

10. Data Security

10.1 How We Protect Your Information

Technical Measures:

  • Encryption in transit (TLS 1.2 or higher)
  • Encryption at rest for sensitive data
  • Access controls and authentication
  • Regular security assessments and testing
  • Intrusion detection and prevention systems

Organizational Measures:

  • Employee training on data security
  • Confidentiality agreements with all employees
  • Limited access (need-to-know basis only)
  • Background checks for personnel with data access
  • Incident response plan

Third-Party Security:

  • All service providers must meet security standards
  • Regular audits of service provider security
  • Contractual requirements to protect your data

10.2 Data Breach Notification

If a Breach Occurs:

  • We will investigate immediately
  • We will notify you without undue delay if your information was compromised
  • We will notify regulatory authorities as required by law
  • We will take steps to prevent future incidents

What We'll Tell You:

  • What information was affected
  • What happened
  • What we're doing about it
  • What you can do to protect yourself

10.3 Your Role in Security

Please:

  • Keep your login credentials confidential
  • Use a strong, unique password
  • Don't share your account access
  • Report suspicious activity immediately

10.4 Limitations

No System is Perfect:

  • We cannot guarantee 100% security
  • Internet transmission always carries some risk
  • We use commercially reasonable measures, but cannot ensure absolute security

11. Children's Privacy

Age Requirement: Our Services are not intended for individuals under 18 years of age. We do not knowingly collect information from children under 18.

If We Learn of Child Data: If we discover we have collected information from a child under 18, we will delete it immediately.

Parent/Guardian: If you believe your child has provided information to us, please contact us immediately at privacy@carbontechnology.ai.


12. International Data Transfers

Primary Location: Your information is processed in the United States.

Data Transfers: If you are located outside the United States:

  • By using our Services, you consent to transfer of your data to the U.S.
  • U.S. privacy laws may differ from those in your country
  • We take steps to protect your information regardless of where it is processed

Adequate Protection:

  • We use Standard Contractual Clauses (SCCs) where required
  • We comply with applicable data protection regulations
  • We ensure service providers provide adequate protection

13. Changes to This Privacy Policy

Updates: We may update this Privacy Policy from time to time.

Notice of Changes:

  • We will post the updated policy on this page
  • We will update the "Last Updated" date at the top
  • For material changes, we will provide additional notice (email or prominent notice on our Platform)

Your Continued Use: Continued use of our Services after changes means you accept the updated Privacy Policy.

Review Regularly: Please review this Privacy Policy periodically to stay informed about how we protect your information.


14. Contact Us

14.1 Privacy Questions

Email: privacy@carbontechnology.ai

Subject Line: Use a descriptive subject line (e.g., "Access Request," "Deletion Request," "Privacy Question")

Mail:

Carbon Technology Group, Inc.

Attn: Privacy Officer

6929 N Hayden Rd Suite C4-484

Scottsdale, AZ 85250

14.2 Data Subject Requests

To Exercise Your Rights:

  • Email privacy@carbontechnology.ai with your request
  • Use our online form: carbontechnology.ai/privacy-request
  • Call: (555) 123-4567

Required Information:

  • Your full name
  • Email address used in application
  • Type of request (access, deletion, correction, etc.)
  • Enough information for us to verify your identity

Response Time:

  • We will respond within 45 days
  • May extend by 45 days if needed (we'll let you know)

14.3 Security Issues

Report Security Concerns:

Email: security@carbontechnology.ai

Subject: "Security Issue"

Include:

  • Description of the issue
  • How you discovered it
  • Any relevant screenshots or information

14.4 Discrimination or Bias Concerns

Report Discrimination: If you believe our AI has discriminated against you or our Services were used in a discriminatory manner:

Email: compliance@carbontechnology.ai

Subject: "Discrimination Concern"

Include:

  • Your name and contact information
  • Position you applied for
  • Employer name
  • Description of the concern
  • Any relevant documentation

We take all discrimination concerns seriously and will investigate promptly.

14.5 TCPA / Communications Concerns

Text Message Issues:

  • Text STOP to opt out
  • Text HELP for assistance
  • Email privacy@carbontechnology.ai

Call Issues:

Email: privacy@carbontechnology.ai

Subject: "Do Not Call Request"

14.6 General Support

Non-Privacy Questions:

Email: support@carbontechnology.ai

Or visit: carbontechnology.ai/support


Appendix A: Definitions

Applicant/Candidate: An individual applying for employment through our Platform.

Biometric Information: Information derived from an individual's unique biological characteristics, which may include voiceprints in certain states.

Customer: A business or organization that uses our Services to evaluate job applicants.

De-identified Data: Information that cannot reasonably be used to identify an individual.

Personal Information: Information that identifies, relates to, or could reasonably be linked to an individual.

Processing: Any operation performed on personal data, including collection, storage, use, disclosure, or deletion.

Services/Platform: Carbon's AI-powered recruiting and hiring software and related services.

Voice Recording: Audio recording of an applicant's voice responses during an interview (voice-only, no video).


Appendix B: Categories of Personal Information

Under the California Consumer Privacy Act (CCPA), we collect the following categories of personal information:

CategoryExamplesCollected?
**Identifiers**Name, email, phone number, IP address✓ Yes
**Personal Information (CA Civil Code § 1798.80)**Name, address, phone, employment history✓ Yes
**Protected Classifications**Age, national origin (may be inferred from application materials)✓ Yes
**Commercial Information**Transaction history with us✗ No
**Biometric Information**Voice recordings (voiceprints in some states)✓ Yes
**Internet/Network Activity**Browsing history on our Platform, IP address✓ Yes
**Geolocation Data**General location based on IP address✓ Yes
**Audio/Visual Information**Voice recordings of interviews✓ Yes
**Professional/Employment Information**Resume, work history, skills, qualifications✓ Yes
**Education Information**Degrees, certifications, training✓ Yes
**Inferences**Candidate scores, assessment results✓ Yes
**Sensitive Personal Information**Voice recordings, precise geolocation (if enabled), account credentials✓ Yes

Appendix C: Disclosure of Personal Information

Categories of Third Parties We Share With:

  1. The Employer (the company you're applying to)
  • All categories of information collected
  1. Service Providers:
  • Cloud hosting providers (identifiers, all application information)
  • AI/ML providers (voice recordings, transcripts, for processing only)
  • Communication providers (identifiers, for text/call services)
  • Analytics providers (de-identified usage data only)
  1. Legal Authorities:
  • Any category as required by law

We Do NOT:

  • Sell your personal information
  • Share your information for cross-context behavioral advertising
  • Share your information with data brokers or advertisers

Appendix D: Data Retention Schedule

Data TypeRetention PeriodReason
**Voice Recordings**5 daysAutomatic deletion after transcription and QA
**Interview Transcripts**1-3 yearsMaintained with application record per employer policy
**Application Materials**1-3 yearsRequired for employer decision-making and legal compliance
**Assessment Scores**1-3 yearsPart of application record
**Contact Information**Until deletion requested or employer relationship endsCommunication and record-keeping
**Usage/Log Data**1 yearSecurity and analytics
**TCPA Consent Records**4 yearsLegal compliance
**Deletion Logs**7 yearsCompliance audit trail
**De-identified/Aggregated Data**IndefinitelyCannot be traced to individuals

Questions? Contact us at privacy@carbontechnology.ai

Carbon Technology Group, Inc.

6929 N Hayden Rd Suite C4-484

Scottsdale, AZ 85250

www.carbontechnology.ai

California Privacy Notice

Notice at Collection for California Residents

Carbon Technology

Effective Date: November 1, 2025

Last Updated: November 1, 2025


1. Introduction

This California Privacy Notice ("Notice") applies to California residents and supplements our general Privacy Policy. It describes how Carbon Technology ("we," "us," "our," or "Company") collects, uses, discloses, and protects the personal information of California residents in accordance with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

This Notice provides California residents with specific information about their privacy rights and how to exercise them under California law.

Contact Information:

Carbon Technology

6929 N Hayden Rd Suite C4-484

Scottsdale, AZ 85250

Email: privacy@carbontechnology.ai


2. Categories of Personal Information We Collect

Under California law, we collect the following categories of personal information from and about California consumers:

A. Personal Identifiers

Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers

B. Protected Classification Characteristics

Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information

C. Commercial Information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

D. Biometric Information

Physiological, biological, or behavioral characteristics that can be used alone or in combination with each other to establish individual identity

E. Internet or Other Electronic Network Activity

Browsing history, search history, information regarding a consumer's interaction with an internet website, application, or advertisement

F. Geolocation Data

Physical location or movements

G. Audio, Electronic, Visual, or Similar Information

Audio, electronic, visual, thermal, olfactory, or similar information such as photographs, video footage, or call recordings

H. Professional or Employment-Related Information

Current or past job history or performance evaluations

I. Education Information

Information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act

J. Inferences

Inferences drawn from any of the information identified above to create a profile about a consumer reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

K. Sensitive Personal Information

We collect the following categories of sensitive personal information from California residents:

  • Social security, driver's license, state identification card, or passport number
  • Contents of mail, email, and text messages where we are not the intended recipient
  • Biometric information for the purpose of uniquely identifying a consumer

3. Sources of Personal Information

We collect personal information about California residents from the following sources:

  • Directly from you when you provide it to us (e.g., when you create an account, make a purchase, contact us, or use our services)
  • Automatically through your use of our website or services (e.g., cookies, web beacons, and similar technologies)
  • Third-party sources such as:
  • Service providers and business partners
  • Data analytics providers
  • Social media platforms
  • Marketing partners
  • Public databases
  • Joint marketing partners
  • Other consumers (e.g., referrals)

4. Business and Commercial Purposes for Collection

We collect and use personal information about California residents for the following business and commercial purposes:

Business Purposes:

  • Providing Services: To fulfill orders, process transactions, and deliver products or services you request
  • Customer Service: To respond to your inquiries, requests, and provide customer support
  • Account Management: To create and manage your account
  • Communications: To send you administrative information, updates, and service-related announcements
  • Security and Fraud Prevention: To protect against fraudulent, unauthorized, or illegal activity
  • Legal Compliance: To comply with legal obligations and enforce our terms and policies
  • Internal Operations: For auditing, data analysis, and research to improve our products and services
  • Quality Assurance: To test, maintain, and improve our services and technology

Commercial Purposes:

  • Marketing: To send you promotional materials, special offers, and advertisements
  • Personalization: To personalize your experience and tailor content and recommendations
  • Analytics: To understand usage trends and preferences
  • Advertising: To deliver targeted advertisements based on your interests

5. Disclosure of Personal Information

A. Service Providers and Business Partners

We may disclose your personal information to service providers and business partners who perform services on our behalf, including:

  • Payment processors
  • Shipping and fulfillment companies
  • Data analytics providers
  • IT service providers
  • Marketing and advertising partners
  • Customer service providers
  • Cloud storage providers

B. Categories Disclosed for Business Purposes

In the preceding 12 months, we have disclosed the following categories of personal information about California residents for business purposes:

  • Personal Identifiers
  • Commercial Information
  • Internet or Network Activity Information
  • Professional or Employment-Related Information

The categories of third parties to whom we disclosed this information include:

  • Service providers (payment processors, cloud storage, IT services)
  • Data analytics providers
  • Marketing and advertising partners
  • Professional advisors and legal counsel

C. Sale or Sharing of Personal Information

Sale of Personal Information:

We do not sell personal information of California residents to third parties.

Sharing for Cross-Context Behavioral Advertising:

We do not share personal information of California residents for cross-context behavioral advertising.

D. Other Disclosures

We may also disclose your personal information:

  • To comply with legal obligations, court orders, or governmental requests
  • To protect our rights, property, or safety, and that of our users or the public
  • In connection with a merger, sale, or acquisition of all or a portion of our business
  • With your consent or at your direction

6. Data Retention

We retain personal information about California residents for as long as necessary to fulfill the purposes outlined in this Notice, unless a longer retention period is required or permitted by law. The criteria we use to determine retention periods include:

  • The length of time we have an ongoing relationship with you
  • Whether there is a legal obligation to which we are subject
  • Whether retention is advisable in light of our legal position (such as applicable statutes of limitations, litigation, or regulatory investigations)

7. Your California Privacy Rights

As a California resident, you have the following rights under the CCPA/CPRA:

A. Right to Know

You have the right to request that we disclose:

  • The categories of personal information we collected about you
  • The categories of sources from which we collected your personal information
  • Our business or commercial purpose for collecting, selling, or sharing personal information
  • The categories of third parties to whom we disclose personal information
  • The specific pieces of personal information we collected about you

You may submit up to two (2) requests to know in a 12-month period.

B. Right to Delete

You have the right to request that we delete personal information we collected from you, subject to certain exceptions under California law.

C. Right to Correct

You have the right to request that we correct inaccurate personal information we maintain about you.

D. Right to Opt-Out

You have the right to opt-out of:

  • The sale of your personal information
  • The sharing of your personal information for cross-context behavioral advertising

Note: We do not currently sell or share personal information, but we honor opt-out requests.

E. Right to Limit Use of Sensitive Personal Information

You have the right to limit our use and disclosure of your sensitive personal information to purposes necessary to perform services or provide goods reasonably expected by an average consumer.

F. Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising your California privacy rights. We will not:

  • Deny you goods or services
  • Charge different prices or rates for goods or services
  • Provide a different level or quality of goods or services
  • Suggest that you will receive a different price or level of quality

However, we may offer financial incentives permitted by law that can result in different prices, rates, or quality levels, provided we have obtained your prior opt-in consent.


8. How to Exercise Your California Privacy Rights

To exercise your rights as a California resident, you may submit a verifiable consumer request to us by:

Request Methods:

  • Online: https://carbontechnology.ai/privacy-request
  • Email: privacy@carbontechnology.ai
  • Mail: Carbon Technology, 6929 N Hayden Rd Suite C4-484, Scottsdale, AZ 85250

Verification Process:

To protect your privacy and security, we will verify your identity before processing your request. We may request additional information to verify your identity, such as:

  • Matching the information you provide with information we have on file about you
  • Requiring a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request
  • Other verification methods as appropriate to the sensitivity of the personal information

Authorized Agents:

You may designate an authorized agent to submit requests on your behalf. The authorized agent must provide:

  • Written permission signed by you authorizing the agent to act on your behalf
  • Proof of their own identity
  • Verification of their authority to act on your behalf

We may also require you to verify your identity directly with us and confirm that you provided the authorized agent permission to submit the request.

Response Timing:

We will respond to verifiable consumer requests within 45 days of receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing.

Opt-Out Preference Signals:

We recognize and process opt-out preference signals transmitted through the Global Privacy Control (GPC) or similar browser-based mechanisms as a valid request to opt-out of the sale or sharing of personal information.

Appeal Process:

If we deny your request, in whole or in part, you have the right to appeal our decision. You may submit an appeal by contacting us using the information provided above. We will respond to your appeal within 45 days of receipt.


9. California "Shine the Light" Law

California Civil Code Section 1798.83 permits California residents who have provided personal information to us to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year.

To make such a request, please contact us at:

Privacy Department

Carbon Technology

6929 N Hayden Rd Suite C4-484

Scottsdale, AZ 85250

Email: privacy@carbontechnology.ai


10. Minors' Privacy Under California Law

We do not knowingly collect, sell, or share personal information from California residents under 16 years of age without appropriate consent as required by California law.

If you are a California resident under 18 years old and have registered to use our services, you have the right to request removal of content or information you posted publicly on our services. To request removal, please contact us using the information provided in this Notice. Please note that removal does not ensure complete or comprehensive removal, as the content may remain in backup copies or may have been shared by others.


11. Cookies and Tracking Technologies

We use cookies, web beacons, pixels, and similar tracking technologies to collect information about your browsing activities. For California residents, certain uses of these technologies may constitute "sharing" for cross-context behavioral advertising under the CPRA.

For more information about the types of cookies we use and your choices, including how to opt-out, please see our Cookie Policy at https://carbontechnology.ai/cookie-policy.

Your Cookie Choices:

  • Most web browsers are set to accept cookies by default
  • You can choose to set your browser to remove or reject cookies
  • If you disable cookies, some features of our website may not function properly
  • You can use the Global Privacy Control (GPC) to opt-out of tracking

12. Do Not Track Signals

Some web browsers transmit "Do Not Track" (DNT) signals to websites. We currently do not respond to DNT signals. However, we do respond to the Global Privacy Control (GPC) as an opt-out signal for the sale or sharing of personal information under California law.


13. Third-Party Links and Services

Our website and services may contain links to third-party websites, applications, or services that are not owned or controlled by Carbon Technology. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies before providing any personal information.


14. Security Measures

We implement reasonable administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, disclosure, alteration, and destruction. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.


15. Changes to This California Privacy Notice

We may update this California Privacy Notice from time to time to reflect changes in our practices or legal requirements. When we make changes, we will update the "Last Updated" date at the top of this Notice. We encourage you to review this Notice periodically. If we make material changes that significantly affect your privacy rights, we will provide notice through our website or by other means as required by California law.


16. Contact Information

If you have questions, concerns, or complaints about this California Privacy Notice or our privacy practices as they relate to California residents, or if you wish to exercise your California privacy rights, please contact us at:

Privacy Department

Carbon Technology

6929 N Hayden Rd Suite C4-484

Scottsdale, AZ 85250

Email: privacy@carbontechnology.ai

Online Privacy Request Form: https://carbontechnology.ai/privacy-request


17. California Privacy Rights Metrics

In accordance with California law, we will publish metrics regarding California consumer privacy requests received in the preceding calendar year. These metrics will be made available on our website annually and will include:

  • The number of requests to know received and complied with, in whole or in part
  • The number of requests to delete received and complied with, in whole or in part
  • The number of requests to correct received and complied with, in whole or in part
  • The median or mean number of days within which we substantively responded to requests
  • The number of requests to opt-out received and complied with, in whole or in part

These metrics will be posted at: https://carbontechnology.ai/privacy-metrics


© 2025 Carbon Technology. All rights reserved.

This Notice applies specifically to California residents and their rights under California law.

Applicant Privacy Policy

Carbon Technology Group, Inc.

Effective Date: [Date]

Last Updated: [Date]


Introduction

Welcome to Carbon Technology Group, Inc. ("Carbon," "we," "us," or "our"). We provide AI-powered recruiting and hiring software (the "Services" or "Platform") to businesses and organizations ("Customers") to help them evaluate job applicants and candidates ("Applicants" or "you").

This Privacy Policy explains:

  • What information we collect from Applicants who use our Platform
  • How we use, share, and protect that information
  • Your rights and choices regarding your information
  • How we use artificial intelligence and machine learning
  • Special protections for voice recordings and biometric data
  • Your rights under California and other state privacy laws

Important: Carbon provides technology services to employers. We process Applicant information on behalf of our Customers (the employers). The employer who directed you to our Platform is the organization making hiring decisions, not Carbon.


Table of Contents

  1. Information We Collect
  2. How We Use Your Information
  3. Artificial Intelligence and Automated Decision-Making
  4. Voice Recordings and Biometric Information
  5. How We Share Your Information
  6. Data Retention and Deletion
  7. Your Rights and Choices
  8. State-Specific Privacy Rights
  9. Communications and Text Messaging
  10. Data Security
  11. Children's Privacy
  12. International Data Transfers
  13. Changes to This Privacy Policy
  14. Contact Us

1. Information We Collect

1.1 Information You Provide Directly

When you apply for a job through our Platform, we collect information you provide, including:

Contact Information:

  • Name
  • Email address
  • Phone number
  • Mailing address (if provided)

Application Information:

  • Resume or CV
  • Cover letter
  • Work history and experience
  • Education and qualifications
  • Skills and certifications
  • References (if provided)
  • Responses to application questions

Interview Information:

  • Voice recordings of interviews (voice-only, no video)
  • Transcripts of your interview responses
  • Assessment results and scores

Communication Preferences:

  • Whether you consent to receive text messages and phone calls
  • Preferred method of communication (text, call, or email)

1.2 Information Collected Automatically

When you use our Platform, we automatically collect:

Device and Usage Information:

  • IP address
  • Browser type and version
  • Device type (computer, mobile, tablet)
  • Operating system
  • Pages visited and actions taken on our Platform
  • Date and time of your visit

Cookies and Similar Technologies:

We use cookies and similar technologies to operate our Platform and improve your experience. See our [Cookie Policy] for details.

1.3 Information From Third Parties

We may receive information about you from:

Employers/Customers:

  • The employer who directed you to our Platform may provide us with information about the position you're applying for
  • Job posting details and requirements

Integration Partners:

  • If the employer uses third-party systems (like an Applicant Tracking System), we may receive information through those integrations

2. How We Use Your Information

2.1 Primary Purposes

We use your information to:

Provide Services to Employers:

  • Process your job application
  • Conduct interviews and assessments
  • Evaluate your qualifications for positions
  • Generate candidate scores and recommendations for the employer
  • Facilitate communication between you and the employer

Operate and Improve Our Platform:

  • Provide, maintain, and improve our Services
  • Develop new features and functionality
  • Troubleshoot technical issues
  • Ensure Platform security and prevent fraud

Communicate With You:

  • Send interview invitations and scheduling information
  • Provide updates about your application status (if you've consented)
  • Respond to your questions or requests
  • Send important notices about our Services

2.2 AI and Machine Learning

We use your information to:

  • Train and improve our AI models and algorithms
  • Develop better candidate assessment tools
  • Improve transcription and natural language processing capabilities

Note: We only use de-identified and aggregated data for AI training. Your individual information is never used to train our models in a way that could identify you. See Section 3 for more details.

2.3 Legal and Compliance Purposes

We use your information to:

  • Comply with applicable laws and regulations
  • Respond to legal requests (subpoenas, court orders, etc.)
  • Enforce our Terms of Service
  • Protect our rights, property, and safety, and the rights of others

3. Artificial Intelligence and Automated Decision-Making

3.1 How We Use AI

Carbon uses artificial intelligence and machine learning technologies to:

Analyze Resume Content:

  • Extract information from your resume (work history, skills, education)
  • Match your qualifications against job requirements
  • Generate a preliminary score based on job relevance

Conduct Voice Interviews:

  • Transcribe your spoken responses using speech-to-text AI
  • Analyze the content of your answers (what you said, not how you said it)
  • If the employer has enabled this feature: assess your spoken language communication ability (for positions where this is a job requirement)

Generate Assessments:

  • Create summary reports for employers
  • Highlight relevant qualifications and experience
  • Provide scores or ratings based on employer-defined criteria

3.2 Important Limitations of AI

AI is Not Perfect:

  • Our AI may make mistakes, misunderstand responses, or produce inaccurate results
  • AI-generated scores and assessments are probabilistic and should not be the sole basis for hiring decisions
  • Employers are required to exercise human review and judgment before making hiring decisions

AI Does Not Make Hiring Decisions:

  • Carbon's AI provides information and recommendations only
  • The employer makes all final hiring decisions
  • You are being evaluated by the employer, not by Carbon's AI alone

You Can Opt Out:

  • You can request a human-conducted interview instead of an AI interview
  • You can request human-only resume review instead of AI-assisted review
  • Declining AI does not negatively affect your application

3.3 Language Proficiency Assessment (If Applicable)

When Enabled: Some employers enable our spoken language proficiency assessment feature for positions where effective communication in a specific language is required for the job (for example, positions requiring English communication for patient safety or team collaboration).

What We Assess:

  • Clarity and comprehensibility of your spoken responses
  • Ability to understand and respond to questions
  • Grammar, vocabulary, and communication effectiveness
  • This is similar to an oral language proficiency test

What We Do NOT Assess:

  • Your accent or national origin
  • Voice characteristics for identity verification
  • Personality traits or emotional state
  • Any characteristics unrelated to job-required communication ability

Legal Basis:

  • The employer has determined that language proficiency is a bona fide occupational qualification (BFOQ) for the specific position
  • The requirement must be job-related and consistent with business necessity
  • The employer provides the justification in the job posting

Your Rights:

  • You can choose a human-conducted interview instead
  • Human interviewers will also assess language proficiency if it's a job requirement
  • You can contact us if you believe the assessment is discriminatory

3.4 Bias and Fairness

Our Commitment:

  • We design our AI to be as fair and unbiased as possible
  • We regularly test our models for bias and discrimination
  • We provide tools for employers to monitor for disparate impact

Employer Responsibility:

  • Employers are responsible for configuring criteria and thresholds
  • Employers must conduct bias testing as required by law
  • Employers must ensure their use of our Platform does not discriminate

Report Concerns: If you believe our AI has discriminated against you based on a protected characteristic, please contact us at privacy@carbontechnology.ai.


4. Voice Recordings and Biometric Information

4.1 Voice-Only Interviews

What We Collect:

  • Audio recordings of your interview responses (voice-only, no video)
  • Our interviews do NOT use video, facial recognition, or facial analysis

How We Use Voice Recordings:

  • Transcribe your speech to text using AI
  • Analyze the content of your responses
  • If enabled by the employer: assess spoken language communication ability
  • Quality assurance and system improvement

What We Do NOT Do:

  • Use your voice to identify or authenticate you
  • Create a permanent "voiceprint" database
  • Match your voice against other recordings
  • Analyze voice characteristics unrelated to communication (e.g., emotion, personality)

4.2 Retention and Deletion

Short Retention Period:

  • Voice recordings are automatically and permanently deleted 5 days after recording
  • This is a strict automatic process - recordings cannot be kept longer
  • Transcripts may be retained longer as part of your application record

Why 5 Days:

  • Allows time for quality assurance and technical issues
  • Minimizes privacy risk by not creating a permanent voice database
  • Balances business needs with your privacy rights

4.3 Special Notice for Illinois, Texas, and Washington Residents

Biometric Information Laws: Your state has special laws governing "biometric information," which may include voice recordings.

Illinois Residents (BIPA):

Under the Illinois Biometric Information Privacy Act:

  • We obtain your written consent before collecting voice data
  • We disclose the purpose and retention period
  • We will not sell, lease, or trade your voice data
  • You have the right to refuse without penalty
  • Voice recordings are deleted after 5 days

Texas Residents (CUBI):

Under the Texas Capture or Use of Biometric Identifier Act:

  • We obtain consent before capturing voice data
  • We will not sell, lease, or trade your voice data
  • Voice recordings are deleted after 5 days

Washington Residents:

Under Washington's biometric privacy law:

  • We provide notice before collecting biometric data
  • We obtain consent before collection
  • We will not enroll you in a facial recognition service (we don't use facial recognition)
  • Voice recordings are deleted after 5 days

Your Rights in These States:

  • Right to refuse voice recording without penalty
  • Right to request deletion of your voice data
  • Right to know how long we retain your data (5 days for recordings)
  • Alternative interview methods available (human-conducted interviews)

Contact for Biometric Privacy: privacy@carbontechnology.ai

4.4 Two-Party Consent States

If you are located in California, Connecticut, Florida, Illinois, Maryland, Massachusetts, Michigan, Montana, Nevada, New Hampshire, Pennsylvania, or Washington, we obtain your explicit consent before recording any conversation with you, as required by your state's recording laws.


5. How We Share Your Information

5.1 With the Employer

Primary Sharing: We share your information with the employer you're applying to, including:

  • Your resume and application materials
  • Interview transcripts and responses
  • Assessment scores and AI-generated recommendations
  • Communication preferences and contact information

The Employer Controls:

  • The employer decides whether to advance your application
  • The employer makes all hiring decisions
  • The employer has access to your information through our Platform

5.2 With Service Providers

We share information with third-party service providers who help us operate our Platform:

Technology Providers:

  • Cloud hosting providers (for data storage)
  • AI and machine learning service providers (for transcription and analysis)
  • Communication providers (for SMS/MMS and voice calls)
  • Analytics providers (for Platform improvement)

Contractual Protections:

  • All service providers are contractually required to protect your information
  • They can only use your information to provide services to us
  • They cannot sell or use your information for their own purposes

Current Service Providers: You can see our list of service providers at: [carbontechnology.ai/subprocessors]

5.3 For Legal Reasons

We may share your information:

  • To comply with laws, regulations, or legal processes
  • To respond to lawful requests from government authorities
  • To enforce our Terms of Service or protect our legal rights
  • To protect the safety, rights, or property of Carbon, our users, or others
  • In connection with a merger, acquisition, or sale of assets (with notice to you)

5.4 With Your Consent

We may share your information with other parties when you give us permission to do so.

5.5 What We Do NOT Do

We Do Not:

  • Sell your personal information to third parties
  • Share your information with advertisers or marketers
  • Use your information for purposes unrelated to providing our Services
  • Share your voice recordings with anyone except as described in this policy

6. Data Retention and Deletion

6.1 How Long We Keep Your Information

Voice Recordings:

  • Automatically deleted after 5 days (permanent deletion)
  • Cannot be recovered after deletion
  • Deletion logs maintained for compliance

Interview Transcripts:

  • Retained as part of your application record
  • Retention period determined by the employer (typically 1-3 years)
  • Deleted when the employer requests deletion or upon contract termination

Application Materials:

  • Retained for as long as the employer maintains your application record
  • Typically 1-3 years after final hiring decision
  • May be retained longer if required by law (e.g., EEOC record-keeping)

Account Information:

  • Deleted when you request deletion (see Section 7)
  • May be retained for legal/compliance purposes as required by law

6.2 Automatic Deletion

Voice Recording Deletion Process:

  1. Voice recording captured during interview
  2. Transcription completed (usually within hours)
  3. Recording flagged for deletion 5 days after capture
  4. Automated deletion job runs daily and permanently deletes recordings older than 5 days
  5. Deletion logged for audit purposes

6.3 When We Delete Everything

Upon Request:

  • You can request deletion of your information at any time (see Section 7)
  • We will delete within 30-45 days unless retention is required by law

When Employer Relationship Ends:

  • When an employer stops using our Services, we delete or return their data
  • Applicant data is deleted within 30 days of contract termination
  • Exception: Data required by law may be retained longer

Aggregated Data:

  • We may retain de-identified, aggregated data indefinitely
  • This data cannot be traced back to you individually
  • Used for research, analytics, and AI improvement

7. Your Rights and Choices

7.1 Access Your Information

Right to Know: You can request to know what personal information we have collected about you, including:

  • Categories of information collected
  • Sources of information
  • Purposes for collection and use
  • Categories of third parties we share with

How to Request: Email privacy@carbontechnology.ai with subject line: "Access Request"

Response Time: We will respond within 45 days (may be extended by 45 days if needed)

7.2 Correct Your Information

Right to Correction: If your information is inaccurate or incomplete, you can request correction.

How to Request:

  • Email privacy@carbontechnology.ai with subject line: "Correction Request"
  • Specify what information needs correction and provide accurate information

7.3 Delete Your Information

Right to Deletion: You can request deletion of your personal information.

Exceptions: We may need to retain information to:

  • Complete the transaction for which it was collected (process your application)
  • Comply with legal obligations
  • Exercise or defend legal claims
  • Detect and prevent fraud or security incidents

How to Request: Email privacy@carbontechnology.ai with subject line: "Deletion Request"

What Gets Deleted:

  • Your application materials
  • Interview transcripts (if not legally required to retain)
  • Contact information
  • Voice recordings (already auto-deleted after 5 days)

Note: We will confirm your identity before processing deletion requests.

7.4 Opt Out of AI

You Can Choose:

  • Human-only resume review (instead of AI-assisted review)
  • Human-conducted interview (instead of AI interview)
  • Email-only communication (instead of text/call)

How to Opt Out:

  • Select your preference during the application process
  • Or email support@carbontechnology.ai

No Penalty: Opting out of AI does not negatively affect your application.

7.5 Opt Out of Text Messages and Calls

Your Choices:

  • You can opt out of text messages by texting STOP to any message we send
  • You can opt out of phone calls by emailing privacy@carbontechnology.ai
  • You can choose email-only communication during the application process

Immediate Opt-Out:

  • STOP requests are processed immediately (within seconds)
  • You will receive a confirmation message
  • We maintain a do-not-contact list to ensure compliance

7.6 Object to Processing

Your Right: You can object to our processing of your information for certain purposes.

How to Object: Email privacy@carbontechnology.ai with subject line: "Objection to Processing"

7.7 Data Portability

Your Right: You can request a copy of your information in a portable format (CSV, JSON, PDF).

How to Request: Email privacy@carbontechnology.ai with subject line: "Data Portability Request"


8. State-Specific Privacy Rights

8.1 California Residents (CCPA/CPRA)

Your California Privacy Rights:

Right to Know:

  • Categories of personal information collected
  • Categories of sources
  • Business/commercial purposes for collection
  • Categories of third parties we share with
  • Specific pieces of information collected

Right to Delete: Request deletion of personal information (subject to exceptions)

Right to Correct: Request correction of inaccurate information

Right to Opt Out of Sale/Sharing:

  • We do NOT sell your personal information
  • We do NOT share your personal information for cross-context behavioral advertising

Right to Limit Use of Sensitive Personal Information:

  • Voice recordings are considered "sensitive personal information"
  • We only use voice recordings for providing our Services (as disclosed to you)
  • You can limit use by not providing voice recordings (choose human interview)

Right to Non-Discrimination:

  • We will not discriminate against you for exercising your privacy rights
  • We will not deny services, charge different prices, or provide different quality of service

Shine the Light Law: If you are a California resident, you can request information about personal information shared with third parties for their direct marketing purposes. We do not share your information for direct marketing.

How to Exercise California Rights:

  • Email: privacy@carbontechnology.ai
  • Phone: [Phone number]
  • Online form: [carbontechnology.ai/privacy-request]

Authorized Agent: You may designate an authorized agent to make requests on your behalf. The agent must provide proof of authorization.

Verification: We will verify your identity before responding to requests (to protect your privacy).

Response Time: 45 days (may be extended by 45 days with notice)

Appeals: If you are dissatisfied with our response, you may appeal by emailing privacy@carbontechnology.ai with subject line: "CCPA Appeal"

8.2 Virginia, Colorado, Connecticut, Utah, and Other State Residents

If you reside in Virginia, Colorado, Connecticut, Utah, or another state with comprehensive privacy laws, you have similar rights:

Rights:

  • Right to confirm whether we process your personal data
  • Right to access your personal data
  • Right to correct inaccuracies
  • Right to delete your personal data
  • Right to obtain a copy of your data (portability)
  • Right to opt out of: (1) targeted advertising (we don't do this), (2) sale of personal data (we don't do this), (3) profiling in furtherance of decisions with legal/similarly significant effects

How to Exercise Rights: Email privacy@carbontechnology.ai or use our online form at [carbontechnology.ai/privacy-request]

Appeals Process: If we deny your request, you may appeal by emailing privacy@carbontechnology.ai with subject line: "Privacy Appeal - [Your State]"

8.3 Illinois, Texas, and Washington Residents

See Section 4.3 for your rights under biometric privacy laws.


9. Communications and Text Messaging

9.1 Types of Communications

We may contact you via:

  • Email: Application updates, interview invitations, important notices
  • Text Messages (SMS/MMS): If you consent, we may send application updates and reminders
  • Phone Calls: If you consent, we may call you about your application

9.2 Text Messaging (SMS/MMS)

Your Consent:

  • We only send text messages if you explicitly consent
  • You provide consent during the application process
  • Consent is optional - you can choose email-only communication

What We Text:

  • Interview invitations and reminders
  • Application status updates
  • Links to complete assessments
  • Important time-sensitive information

Message Frequency:

  • Varies depending on your application status
  • Typically 2-5 messages per application

Message and Data Rates:

  • Standard message and data rates may apply
  • Contact your mobile carrier for details about your plan

How to Opt Out:

  • Text STOP to any message we send (immediate opt-out)
  • Email privacy@carbontechnology.ai
  • Change preferences in your application portal

Help: Text HELP for assistance or email support@carbontechnology.ai

Carriers Supported:

  • Major carriers supported (AT&T, T-Mobile, Verizon, Sprint, etc.)
  • Message delivery may vary by carrier

TCPA Compliance:

  • We comply with the Telephone Consumer Protection Act (TCPA)
  • We obtain express written consent before sending marketing or promotional texts
  • We maintain do-not-contact lists
  • We honor opt-out requests immediately

9.3 Phone Calls

Your Consent:

  • We only call you if you consent
  • You provide consent during the application process
  • Calls may be automatically dialed or prerecorded

Purpose of Calls:

  • Interview scheduling
  • Application updates (if urgent)
  • Responding to your inquiries

How to Opt Out:

  • Select "email only" during application process
  • Email privacy@carbontechnology.ai
  • Tell us during any call that you'd like to opt out

9.4 Email Communications

You Will Always Receive:

  • Essential communications about your application (cannot opt out)
  • Important notices about our Services or this Privacy Policy

Optional Communications:

  • Application status updates
  • Interview tips and preparation materials

How to Opt Out:

  • Click "unsubscribe" in any email
  • Email privacy@carbontechnology.ai
  • Change preferences in your application portal

10. Data Security

10.1 How We Protect Your Information

Technical Measures:

  • Encryption in transit (TLS 1.2 or higher)
  • Encryption at rest for sensitive data
  • Access controls and authentication
  • Regular security assessments and testing
  • Intrusion detection and prevention systems

Organizational Measures:

  • Employee training on data security
  • Confidentiality agreements with all employees
  • Limited access (need-to-know basis only)
  • Background checks for personnel with data access
  • Incident response plan

Third-Party Security:

  • All service providers must meet security standards
  • Regular audits of service provider security
  • Contractual requirements to protect your data

10.2 Data Breach Notification

If a Breach Occurs:

  • We will investigate immediately
  • We will notify you without undue delay if your information was compromised
  • We will notify regulatory authorities as required by law
  • We will take steps to prevent future incidents

What We'll Tell You:

  • What information was affected
  • What happened
  • What we're doing about it
  • What you can do to protect yourself

10.3 Your Role in Security

Please:

  • Keep your login credentials confidential
  • Use a strong, unique password
  • Don't share your account access
  • Report suspicious activity immediately

10.4 Limitations

No System is Perfect:

  • We cannot guarantee 100% security
  • Internet transmission always carries some risk
  • We use commercially reasonable measures, but cannot ensure absolute security

11. Children's Privacy

Age Requirement: Our Services are not intended for individuals under 18 years of age. We do not knowingly collect information from children under 18.

If We Learn of Child Data: If we discover we have collected information from a child under 18, we will delete it immediately.

Parent/Guardian: If you believe your child has provided information to us, please contact us immediately at privacy@carbontechnology.ai.


12. International Data Transfers

Primary Location: Your information is processed in the United States.

Data Transfers: If you are located outside the United States:

  • By using our Services, you consent to transfer of your data to the U.S.
  • U.S. privacy laws may differ from those in your country
  • We take steps to protect your information regardless of where it is processed

Adequate Protection:

  • We use Standard Contractual Clauses (SCCs) where required
  • We comply with applicable data protection regulations
  • We ensure service providers provide adequate protection

13. Changes to This Privacy Policy

Updates: We may update this Privacy Policy from time to time.

Notice of Changes:

  • We will post the updated policy on this page
  • We will update the "Last Updated" date at the top
  • For material changes, we will provide additional notice (email or prominent notice on our Platform)

Your Continued Use: Continued use of our Services after changes means you accept the updated Privacy Policy.

Review Regularly: Please review this Privacy Policy periodically to stay informed about how we protect your information.


14. Contact Us

14.1 Privacy Questions

Email: privacy@carbontechnology.ai

Subject Line: Use a descriptive subject line (e.g., "Access Request," "Deletion Request," "Privacy Question")

Mail:

Carbon Technology Group, Inc.

Attn: Privacy Officer

[Address]

[City, State, ZIP]

14.2 Data Subject Requests

To Exercise Your Rights:

  • Email privacy@carbontechnology.ai with your request
  • Use our online form: [carbontechnology.ai/privacy-request]
  • Call: [Phone number]

Required Information:

  • Your full name
  • Email address used in application
  • Type of request (access, deletion, correction, etc.)
  • Enough information for us to verify your identity

Response Time:

  • We will respond within 45 days
  • May extend by 45 days if needed (we'll let you know)

14.3 Security Issues

Report Security Concerns:

Email: security@carbontechnology.ai

Subject: "Security Issue"

Include:

  • Description of the issue
  • How you discovered it
  • Any relevant screenshots or information

14.4 Discrimination or Bias Concerns

Report Discrimination: If you believe our AI has discriminated against you or our Services were used in a discriminatory manner:

Email: compliance@carbontechnology.ai

Subject: "Discrimination Concern"

Include:

  • Your name and contact information
  • Position you applied for
  • Employer name
  • Description of the concern
  • Any relevant documentation

We take all discrimination concerns seriously and will investigate promptly.

14.5 TCPA / Communications Concerns

Text Message Issues:

  • Text STOP to opt out
  • Text HELP for assistance
  • Email privacy@carbontechnology.ai

Call Issues:

Email: privacy@carbontechnology.ai

Subject: "Do Not Call Request"

14.6 General Support

Non-Privacy Questions:

Email: support@carbontechnology.ai

Or visit: [carbontechnology.ai/support]


Appendix A: Definitions

Applicant/Candidate: An individual applying for employment through our Platform.

Biometric Information: Information derived from an individual's unique biological characteristics, which may include voiceprints in certain states.

Customer: A business or organization that uses our Services to evaluate job applicants.

De-identified Data: Information that cannot reasonably be used to identify an individual.

Personal Information: Information that identifies, relates to, or could reasonably be linked to an individual.

Processing: Any operation performed on personal data, including collection, storage, use, disclosure, or deletion.

Services/Platform: Carbon's AI-powered recruiting and hiring software and related services.

Voice Recording: Audio recording of an applicant's voice responses during an interview (voice-only, no video).


Appendix B: Categories of Personal Information

Under the California Consumer Privacy Act (CCPA), we collect the following categories of personal information:

CategoryExamplesCollected?
**Identifiers**Name, email, phone number, IP address✓ Yes
**Personal Information (CA Civil Code § 1798.80)**Name, address, phone, employment history✓ Yes
**Protected Classifications**Age, national origin (may be inferred from application materials)✓ Yes
**Commercial Information**Transaction history with us✗ No
**Biometric Information**Voice recordings (voiceprints in some states)✓ Yes
**Internet/Network Activity**Browsing history on our Platform, IP address✓ Yes
**Geolocation Data**General location based on IP address✓ Yes
**Audio/Visual Information**Voice recordings of interviews✓ Yes
**Professional/Employment Information**Resume, work history, skills, qualifications✓ Yes
**Education Information**Degrees, certifications, training✓ Yes
**Inferences**Candidate scores, assessment results✓ Yes
**Sensitive Personal Information**Voice recordings, precise geolocation (if enabled), account credentials✓ Yes

Appendix C: Disclosure of Personal Information

Categories of Third Parties We Share With:

  1. The Employer (the company you're applying to)
  • All categories of information collected
  1. Service Providers:
  • Cloud hosting providers (identifiers, all application information)
  • AI/ML providers (voice recordings, transcripts, for processing only)
  • Communication providers (identifiers, for text/call services)
  • Analytics providers (de-identified usage data only)
  1. Legal Authorities:
  • Any category as required by law

We Do NOT:

  • Sell your personal information
  • Share your information for cross-context behavioral advertising
  • Share your information with data brokers or advertisers

Appendix D: Data Retention Schedule

Last Updated: [Date]

Data TypeRetention PeriodReason
**Voice Recordings**5 daysAutomatic deletion after transcription and QA
**Interview Transcripts**1-3 yearsMaintained with application record per employer policy
**Application Materials**1-3 yearsRequired for employer decision-making and legal compliance
**Assessment Scores**1-3 yearsPart of application record
**Contact Information**Until deletion requested or employer relationship endsCommunication and record-keeping
**Usage/Log Data**1 yearSecurity and analytics
**TCPA Consent Records**4 yearsLegal compliance
**Deletion Logs**7 yearsCompliance audit trail
**De-identified/Aggregated Data**IndefinitelyCannot be traced to individuals

Questions? Contact us at privacy@carbontechnology.ai

Carbon Technology Group, Inc.

[Address]

[City, State, ZIP]

www.carbontechnology.ai