Privacy Policy

1. Who We Are

WiHire.ai is a consent-first AI hiring platform operated by PIXONIQ LLC, a Michigan limited liability company headquartered in Troy, Michigan, USA ("Company," "we," "us," "our"). Our AI guide Zeyla™ (U.S. Trademark Application Serial No. 99761935) assists users throughout the platform within the consent boundaries each user defines. Our consent-gated AI architecture is the subject of pending U.S. Patent Application Nos. 64/033,113 and 64/055,868.

By using WiHire.ai, you acknowledge that you have read, understood, and agree to the data practices described in this Privacy Policy.

2. Information We Collect

Information you provide directly

• Registration data: full name, email address, career level, and role type (candidate or recruiter)
• Candidate profile: skills, work history, salary expectations, location preferences, and work-style preferences
• Recruiter profile: name, work email, company name, Employer Identification Number (EIN) for identity verification, and recruiter type
• Survey responses: voluntary feedback on job search frustrations and platform features
• Communications: messages submitted to Zeyla™ or to our support team via email

Information collected automatically

• Usage data: pages visited, features used, and consent decisions with timestamps
• Device and technical data: browser type, operating system, and IP address — used solely for fraud prevention and platform security, not for profiling or advertising
• Consent records: every consent grant and withdrawal, recorded in a write-protected, append-only audit log with timestamps

Information we do not intentionally collect

• Racial or ethnic origin, religion, sexual orientation, gender identity, disability status, or other sensitive personal characteristics
• Data for advertising, retargeting, or behavioural profiling purposes
• Your resume, identity, or contact information without your explicit, per-match consent

Do Not Track

Some browsers transmit "Do Not Track" signals. WiHire.ai does not currently respond to Do Not Track browser signals as there is no established industry standard for doing so. We do not engage in cross-site tracking of any kind.

2.1 Cookies and Similar Technologies

WiHire.ai uses cookies and similar tracking technologies to operate and improve our platform. This section explains what cookies are, how we use them, and your choices regarding their use.

What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help remember your preferences, enable certain functionality, and provide analytics about site usage. Cookies may be set by WiHire.ai (first-party) or by third-party service providers (third-party).

Cookies We Use

We use the following categories of cookies on WiHire.ai:

Strictly Necessary Cookies

• Purpose: Essential for the platform to function. Enable authentication, session management, and security features.
• Examples: Session identifiers, CSRF tokens, authentication tokens.
• Legal Basis: Legitimate interest (GDPR Art. 6(1)(f)) or contractual necessity.
• Can Be Disabled: No. Disabling these cookies will prevent you from using the platform.

Functional Cookies

• Purpose: Remember your preferences and settings to improve your experience.
• Examples: Language preferences, UI customisation settings, consent preferences.
• Legal Basis: Consent (GDPR Art. 6(1)(a)).
• Can Be Disabled: Yes. Disabling these cookies may reduce functionality but will not prevent platform use.

Analytics Cookies

• Purpose: Understand how visitors interact with our platform so we can improve performance and user experience.
• Examples: Page views, session duration, navigation patterns. We use anonymised, aggregated analytics — no individual-level profiling.
• Legal Basis: Consent (GDPR Art. 6(1)(a)).
• Can Be Disabled: Yes. You can withdraw consent at any time.

Third-Party Cookies

We do not use advertising networks, social media pixels, or behavioural tracking cookies. The only third-party services that may set cookies are:

• Cloudflare: Sets security cookies (cf_bm, cf_clearance) for bot detection and DDoS protection. These are strictly necessary for platform security.
• Google Fonts: Sets cookies (CONSENT, NID) for font delivery optimisation. These are set by Google's servers.

Cookie Management

You have the following choices regarding cookies:

• Browser Settings: Most browsers allow you to block or delete cookies. Instructions are available in your browser's help menu.
• Opt-Out Links: For analytics cookies, you may opt out via:
  • Google Analytics: https://tools.google.com/dlpage/gaoptout
• Withdrawal of Consent: Email [email protected] with subject "Cookie Consent Withdrawal" to withdraw consent for non-essential cookies.

Cookie Retention

• Session Cookies: Deleted when you close your browser.
• Persistent Cookies: Remain on your device for up to twelve (12) months, unless manually deleted.
• Consent Records: Retained for twenty-four (24) months to demonstrate lawful consent.

Updates to This Cookie Section

We may update this cookie section as our platform evolves. Material changes will be communicated via the same channels as our Privacy Policy updates.

Contact

For questions about our use of cookies, email [email protected] with subject "Cookie Inquiry."

Geographic Availability

3. Security & Data Breach Notification

This section explains how WiHire.ai protects your data, what constitutes a reportable security breach, and our notification obligations in the event of a breach.

Our Security Commitment

PIXONIQ LLC implements industry-standard technical and organisational measures to protect your personal data, including encryption in transit and at rest, TOTP two-factor authentication for recruiter accounts, row-level security controls, and regular encrypted backups. However, no security system is impenetrable. We cannot guarantee absolute security of your data.

What Is a Reportable Security Breach?

A reportable security breach is any confirmed or reasonably suspected unauthorized access, acquisition, disclosure, or loss of personal data that compromises the security, confidentiality, or integrity of that data. This includes but is not limited to:

• Unauthorized access to user accounts or personal data
• Loss or theft of devices containing personal data
• Data corruption or deletion without authorized cause
• Compromise of authentication credentials or encryption keys
• Any security incident resulting in unauthorized access to candidate resumes, profiles, or consent records

Breach Severity Tiers & Response Timelines

We assess breaches based on the type, volume, and sensitivity of data affected. Response timelines are measured from the moment we confirm a breach:

Low Severity

• Definition: Limited impact — affected data is encrypted, anonymised, or non-sensitive in nature. No user credentials or PII exposed.
• Response: Internal remediation and documentation. No external notification required.
• Timeline: Document within 30 days. No user notification required.

Medium Severity

• Definition: Moderate impact — some PII potentially exposed, but no financial data, government IDs, or sensitive health information. Limited number of users affected.
• Response: Notify affected users directly. Document and remediate.
• Timeline: Notify affected users within 30 days of confirmation.

High Severity

• Definition: Significant impact — sensitive PII exposed (e.g., resumes, employment history, contact information). Large number of users affected. Potential for identity theft or discrimination.
• Response: Notify affected users. Notify relevant state Attorneys General if required by law. Offer credit monitoring services.
• Timeline: Notify affected users within 72 hours. Notify state AGs within timeframe required by applicable law.

Critical Severity

• Definition: Severe impact — large-scale exposure of sensitive data including TOTP/2FA credentials, AI match scores that could enable discrimination, or extensive candidate PII. Active exploitation suspected.
• Response: Immediate incident response. Notify affected users, state AGs, and the Federal Trade Commission. Engage external forensic specialists if needed.
• Timeline: Notify affected users within 24 hours. Notify FTC and relevant state AGs within 72 hours.

Notification Obligations by Jurisdiction

WiHire.ai serves users in the United States only. In the event of a breach, we will notify affected users and, where required by law, the appropriate regulatory authorities:

Michigan Residents

Under the Michigan Data Breach Notification Act (MCL 445.72), we will notify affected Michigan residents without unreasonable delay. If the breach affects 1,000 or more Michigan residents, we will also notify the Michigan Attorney General.

California Residents

Under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), we will notify affected California residents in an expedient time frame. We will provide notice within 30-45 days of breach confirmation. If the breach affects 500 or more California residents, we will notify the California Attorney General.

Residents of Other US States

For users in other US states, we will comply with the notification requirements of that state's applicable data breach law. We will identify and contact the relevant supervisory authority in your state. Timelines vary by jurisdiction but typically range from 30 to 60 days.

NYC Local Law 144 Considerations

If a breach involves AI bias audit data or candidate scoring data that could affect automated employment decision tool compliance under NYC Local Law 144, we will include relevant disclosures in our breach notice and coordinate with affected recruiters to meet their independent compliance obligations.

What Information Will Be Included in Breach Notices

All breach notifications to affected users will include:

• Description of the incident and what happened
• Date and timeframe of the breach (if known)
• Types of personal data potentially affected
• Steps we have taken to address the breach and protect your data
• Steps you can take to protect yourself
• Contact for questions: [email protected]
• For High/Critical breaches: information about credit monitoring services

How You Will Be Notified

In the event of a breach requiring user notification, we will send an email to your registered email address from [email protected]. The email will be clearly labeled as a security notice and will include all information required under applicable law.

Your Rights Following a Breach

If you are affected by a High or Critical severity breach, you may be eligible for credit monitoring services. We will include information about available services in your breach notification. Additionally, you may:

• Request a copy of the personal data we hold about you
• Request correction of any inaccurate data
• Request deletion of your account and personal data
• File a complaint with the FTC at reportfraud.ftc.gov
• Contact your state's Attorney General if you believe your rights have been violated

How to Report a Suspected Breach

If you believe your account has been compromised, or you have detected suspicious activity on the platform, please contact us immediately at [email protected] with subject "Security Breach Report."

Regulatory Contacts

You may also report concerns directly to the following authorities:

• Federal Trade Commission: reportfraud.ftc.gov
• Michigan Attorney General: michigan.gov/ag
• California Attorney General: oag.ca.gov

Updates to This Section

We may update this security breach notification section as our security practices evolve or as applicable law changes. Material changes will be communicated via the same channels as our Privacy Policy updates.

4. How We Use Your Information

We use personal data only for the following purposes:

• AI matching: scoring candidate profiles against roles across six dimensions — skills, seniority, domain, salary, location, and work style — to generate anonymised match scores
• Resume generation: Zeyla™ generates tailored resume content for specific matched roles, only after the candidate provides explicit per-match consent
• Transactional communications: invitation confirmations, platform updates, and responses to enquiries, delivered via Resend from [email protected]
• Platform improvement: anonymised, aggregated analytics used to improve AI accuracy and prioritise features — no individual-level profiling
• Legal and compliance obligations: fraud prevention, EIN verification, and compliance with applicable legal obligations

We will not use your personal data for purposes materially different from those listed above without first providing notice and, where required by applicable law, obtaining your consent.

4. Consent-Gated Data Sharing

The following describes how candidate data is — and is not — shared with recruiters on our platform:

• Recruiters receive only anonymised AI match scores — no candidate name, resume, or contact information — until the candidate grants explicit, per-match consent
• Candidate identity and resume are shared with a specific recruiter only upon that candidate's affirmative, per-match consent
• Upon withdrawal of consent, candidate data will be re-anonymised in the recruiter's view within a commercially reasonable time, not to exceed seventy-two (72) hours
• All consent actions are recorded in a write-protected, append-only audit log with timestamps
• A candidate's current or former employer is not granted access to that candidate's profile under any circumstance

This architecture is the subject of pending U.S. Patent Application Nos. 64/033,113 and 64/055,868 and may not be reproduced without written authorisation from PIXONIQ LLC.

5. Third-Party Service Providers

We engage the following third-party processors to operate the platform. Each is bound by data processing agreements consistent with applicable law:

• Supabase: database hosting and user authentication — data stored in US-region servers
• Resend: transactional email delivery only — email content and recipient addresses are shared solely for delivery purposes
• Cloudflare: DNS management, web hosting (Cloudflare Pages), and email routing

We do not engage advertising networks, social media pixel trackers, or third-party analytics services that share individual-level data with external parties. As of the effective date of this policy, we do not sell, rent, or trade personal data. In the event of a merger, acquisition, or sale of all or substantially all of our assets, your personal data may be transferred to the successor entity, subject to the same protections described in this policy. We will provide notice of any such transfer.

6. Data Retention

• Waitlist registrations: retained for up to twenty-four (24) months from date of registration, or until a deletion request is fulfilled, whichever is earlier
• Active user profiles: retained for the duration of account activity and deleted within thirty (30) days following a valid account closure request
• Consent audit records: retained for seven (7) years to satisfy applicable legal, regulatory, and record-keeping obligations. These records are maintained in a write-protected, append-only format and are not subject to deletion requests to the extent required by law
• AI-generated resume content: retained only for the duration of an active, consented match — deleted within seventy-two (72) hours of consent withdrawal

7. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights with respect to your personal data:

• Right of access: request a copy of the personal data we hold about you
• Right to rectification: request correction of inaccurate or incomplete data
• Right to erasure: request deletion of your account and personal data, subject to our legal retention obligations
• Right to data portability: receive your data in a structured, machine-readable format
• Right to withdraw consent: withdraw any previously granted consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal
• Right to object to AI profiling: request that your profile not be used for automated AI matching decisions
• Right to lodge a complaint: if you are located in the EU or UK, you have the right to lodge a complaint with your local data protection supervisory authority. For US residents, certain state laws may provide additional rights — contact us to enquire

California Residents (CCPA/CPRA)

California residents have the right to know what personal information is collected, disclosed, or sold; the right to delete personal information; the right to opt out of the sale of personal information (we do not sell personal information); and the right to non-discrimination for exercising these rights. To submit a California privacy request, email [email protected] with subject "CCPA Request."

To exercise any right, email [email protected] with the subject line "Privacy Request." We will respond within thirty (30) days, or within the timeframe required by applicable law if shorter.

8. AI in Employment — Legal Disclosures

EEOC Compliance

The U.S. Equal Employment Opportunity Commission has confirmed that Title VII, the ADEA, and the ADA apply to AI-based candidate selection tools. WiHire.ai's six-dimension scoring constitutes a selection procedure under the Uniform Guidelines on Employee Selection Procedures (UGESP, 41 CFR Part 60-3). This model has not been independently validated against actual job performance outcomes. PIXONIQ LLC makes no representation that its scoring model is free from disparate impact on any protected class under applicable law.

Right to Human Review and Appeal

You have the right to request human review of any AI-based match decision and to appeal any decision you believe is discriminatory or erroneous. Email [email protected] with subject "Human Review Request" or "AI Decision Appeal." We respond within thirty (30) days.

Colorado AI Act (SB 24-205, effective February 1, 2026)

Colorado residents have the right to opt out of AI-based profiling, to receive an explanation of AI decisions affecting them, to request human review, and to appeal AI decisions. To exercise these rights, email [email protected] with subject "Colorado AI Rights Request."

Independent Bias Audit Status

As of the effective date of this policy, WiHire.ai has not undergone an independent third-party bias audit of its AI scoring model. We are committed to bias assessments as the platform scales. Recruiters using the platform to fill roles in New York City must independently comply with NYC Local Law 144, which requires annual independent bias audits of automated employment decision tools.

Right to File a Regulatory Complaint

Nothing in this Privacy Policy limits your right to file a complaint with the EEOC (www.eeoc.gov), the U.S. Department of Labor (www.dol.gov), your state's civil rights or labor agency, or any applicable data protection supervisory authority.

9. How We Process Your Resume

Original File Storage

When you upload a resume to WiHire, we store the file in its original format in a private, encrypted Supabase Storage bucket. The original file is never modified, reformatted, or converted by WiHire or by Zeyla™ — recruiters always receive the file you uploaded, exactly as you uploaded it. Each file is hashed using SHA-256 at upload time, and the hash is verified before every authorised access to confirm integrity.

AI-Assisted Processing (Optional — Consent Required)

If, and only if, you opt in to AI-assisted matching at upload time (or later in Privacy Settings), Zeyla™ extracts the text from your resume to generate an internal analysis used solely to match you to relevant roles. The derived text is encrypted at rest using AES-256 column-level encryption, is never disclosed to recruiters or third parties, and never replaces the original file in any recruiter view. Withdrawing consent at any time triggers deletion of the derived analysis within thirty (30) days.

Who Can Access Your Resume

• You — you can view, download, set as primary, or delete any of your uploaded resumes from the resume vault at any time.
• Recruiters — only when you have granted active, role-specific consent under the Consent Policy. Recruiter access is logged with the consent identifier, the recruiter's employer FEIN, and the role context for chain-of-custody purposes. Signed download URLs expire after five (5) minutes.
• Zeyla™ — only when you have opted in to AI-assisted matching. Zeyla operates on the encrypted derived text, not on the original file.
• WiHire engineering / privacy staff — only when strictly necessary to investigate a security incident, fulfil a privacy or erasure request, or comply with a binding legal order. All such access is recorded in the audit log.

Every state-changing event (upload, primary change, AI-consent grant or revocation, recruiter access, integrity verification, deletion, GDPR erasure) is recorded in an append-only audit log that cannot be modified or deleted, in compliance with GDPR Article 5(2), CO SB-205, CCPA, and NYC Local Law 144.

Your Rights Over Your Resume Data

• Access — request a copy of your stored resume metadata, AI-derived analysis (if any), and audit log entries.
• Deletion — soft-delete a resume from the resume vault at any time, or submit a GDPR Article 17 erasure request to physically purge originals and derived analysis.
• Portability — export your stored documents in their original format and your audit log in machine-readable form (JSON / CSV).
• Correction — replace any uploaded resume with a corrected version; previous versions are retained for audit and can be erased on request.
• Opt-out of AI processing — withdraw AI-processing consent at any time. Original file storage is unaffected; only the derived analysis is deleted.
• Integrity report — request a written confirmation of the SHA-256 integrity status of any of your stored documents.

Contact & Response SLA

To exercise any of the rights above, email [email protected] with the subject line of your request (e.g. "Resume Access Request"). We respond within thirty (30) days for GDPR / UK GDPR rights and within forty-five (45) days for CCPA rights, with a single permitted extension where the request is complex, in line with each statute.

Data Retention Schedule

• Original resume files — account duration plus ninety (90) days following account closure.
• AI-derived parsed text — until you withdraw AI-processing consent, plus thirty (30) days for purge propagation.
• Resume access audit logs — seven (7) years (regulatory chain-of-custody requirement).
• Compliance / decision audit logs — seven (7) years (regulatory chain-of-custody requirement).
• Tailored resumes (Section 9.8) — one (1) year from creation by default, or earlier on candidate request via GDPR erasure.

Retention timestamps are stored on each record and reviewed by an automated job; once an item has reached its retention horizon, it is flagged in the audit log and purged on the next scheduled sweep.

9.8 Agent-Principal Processing

Where an enterprise agent-principal (consulting firm, staffing firm, vendor manager, or managed service provider) is matched with you under the Consent Policy, WiHire may produce an AI-tailored derivative of your resume against a specific client job description. The following privacy guarantees apply to that processing:

• Separate storage. Each tailored version is stored as a new record in tailored_resumes, in a private bucket distinct from your original resume vault. Your original resume is never modified.
• Factual integrity. Tailored content is constrained to material already present in your original resume. Each tailored version stores a SHA-256 attestation that includes the source-file hash, the model used, and a summary of changes. Any version that fails the factual-integrity check is flagged and is not deliverable.
• Notification + approval rights per version. You receive an email per tailored version with a link to candidate-approve-tailored.html. You may approve, reject, or ignore each version. No tailored version is delivered to any onward client without your explicit approval.
• Chain of custody. Every tailoring event — start, integrity check, completion, candidate decision, delivery — is written to an append-only tailoring_audit_log with cryptographically chained event hashes.
• Revocability. You may revoke agent-principal access at any time in Privacy Settings. Revocation halts pending tailoring and blocks future onward delivery; previously approved versions can additionally be erased via the GDPR endpoint described below.
• GDPR erasure for tailored versions. The gdpr-erase-tailored endpoint allows you to soft-delete one or all of your tailored versions independently of the originals. Files are purged from storage; the audit trail is retained for the regulatory period in pseudonymised form.
• Sub-processor. Tailoring uses the Anthropic Claude API (model recorded per row) under our DPA Annex A.9.

10. Security Measures

We implement industry-standard technical and organisational measures to protect personal data, including:

• Encryption of data in transit using current industry-standard protocols
• Encryption of data at rest using current industry-standard algorithms
• TOTP two-factor authentication, mandatory for all recruiter accounts
• Row-level security controls enforced at the database layer
• Regular encrypted backups stored in geographically distributed locations
• EIN-based identity verification for recruiter accounts to prevent unauthorised access

No security system is impenetrable. We cannot guarantee absolute security of your data. In the event of a personal data breach, we will notify affected users and applicable supervisory authorities within the timeframes required by the laws of their respective jurisdictions.

11. Children's Privacy (COPPA)

WiHire.ai is intended solely for users aged eighteen (18) and over. We do not knowingly collect personal data from children under the age of 13, in compliance with the Children's Online Privacy Protection Act (COPPA), or from minors under the age of 18 as required by applicable law in other jurisdictions. If you believe we have inadvertently collected data from a minor, contact us immediately at [email protected] and we will promptly delete such data.

12. Changes to This Policy

We reserve the right to update this Privacy Policy at any time. For material changes — defined as changes that substantially affect your rights or our data practices — we will provide notice to registered users by email at least fourteen (14) days before the changes take effect. The effective date at the top of this page reflects the most current version. Non-material changes (such as corrections to formatting or contact details) may take effect upon posting.

Continued use of the platform following the effective date of a material update constitutes your acceptance of the revised policy. If you do not agree to the updated policy, you should discontinue use of the platform and submit a data deletion request.

13. Governing Law and Jurisdiction

This Privacy Policy is governed by the laws of the State of Michigan and the applicable federal laws of the United States of America, without regard to conflict-of-law principles. Any dispute arising under or relating to this policy shall be subject to the exclusive jurisdiction of the state and federal courts located in Oakland County, Michigan, and you hereby consent to personal jurisdiction in those courts.

If you are located outside the United States, you acknowledge that your personal data will be processed in the United States, which may not provide the same level of data protection as your home jurisdiction. By using the platform, you consent to this transfer. EU and UK users retain all rights afforded under GDPR and UK GDPR respectively.