Privacy Policy

Table of Contents

• 1. About This Policy
• 2. Information We Collect
• 3. Legal Basis and Consent
• 4. How We Use Your Information
• 5. AI and Automated Decision-Making
• 6. Information Sharing and Employer Matching
• 7. Data Security and Protection
• 8. Your Privacy Rights
• 9. Data Retention and Deletion
• 10. International Data Transfers
• 11. Privacy Breach Notification
• 12. Employment Equity and Human Rights
• 13. Third-Party Services
• 14. Provincial Privacy Law Compliance
• 15. Changes to This Policy
• 16. Contact Information

1. About This Policy

ClarixAI Inc. ("ClarixAI," "we," "us," or "our") operates an AI-powered recruitment platform that connects job seekers with employers through intelligent matching technology. This Privacy Policy explains how we collect, use, disclose, and protect your personal information in accordance with:

• Canada's Personal Information Protection and Electronic Documents Act (PIPEDA)
• Provincial privacy legislation where applicable
• Canadian Human Rights Act
• Provincial human rights legislation
• Employment equity requirements

2. Information We Collect

We collect personal information through various means, always in accordance with data minimization principles. The types of information we collect include:

2.1 Information You Provide Directly

• Account Information: Name, email address, password, phone number
• Professional Information: Skills, work experience, education, certifications, career objectives
• Resume and Portfolio: CV documents, work samples, references
• Preference Settings: Job search preferences, location preferences, salary expectations
• Communication Data: Messages, inquiries, support requests
• Demographic Information: Age, gender, location (collected only for employment equity purposes with explicit consent)

2.2 Information We Collect Automatically

• Usage Data: Platform interactions, feature usage, search queries, time spent on platform
• Technical Information: IP address, device type, browser information, operating system
• Location Information: General location data (with your consent)
• Cookies and Tracking: Essential cookies for platform functionality, analytics cookies (with consent)

2.3 Information from Third Parties

• Social Media: Profile information when you connect social accounts (with consent)
• Educational Institutions: Verification of credentials (with consent)
• Previous Employers: Reference checks (with explicit consent)
• Data Enrichment Services: Professional information verification (with consent)

3. Legal Basis and Consent

We collect and process your personal information based on the following legal grounds:

3.1 Consent

For most processing activities, we rely on your explicit, informed consent. You have the right to:

• Understand what information we collect and why
• Provide granular consent for different processing purposes
• Withdraw consent at any time
• Refuse consent without penalty to basic service access

3.2 Contract Performance

Some processing is necessary to provide our recruitment services as outlined in our Terms of Service.

3.3 Legal Obligations

We may process information to comply with Canadian federal and provincial laws, including employment equity legislation.

4. How We Use Your Information

We use your personal information for the following purposes, with appropriate consent:

4.1 Service Delivery

• Provide AI-powered job matching services
• Create and maintain your profile
• Facilitate communication between job seekers and employers
• Process job applications and recommendations

4.2 Platform Improvement

• Improve our AI algorithms and matching accuracy
• Enhance user experience and platform functionality
• Conduct research and analytics (with anonymized data)
• Develop new features and services

4.3 Communication

• Send service-related notifications
• Provide customer support
• Send marketing communications (with opt-in consent)
• Notify about job opportunities and platform updates

4.4 Security and Legal Compliance

• Protect platform security and prevent fraud
• Comply with legal and regulatory requirements
• Investigate and resolve disputes
• Enforce our terms of service

5. AI and Automated Decision-Making

As required by PIPEDA and emerging AI governance frameworks, we provide full transparency about our automated decision-making processes:

5.1 Automated Decision-Making Systems

• Job Matching Algorithm: Matches job seekers with relevant opportunities based on skills, experience, and preferences
• Skill Assessment: Evaluates candidate qualifications against job requirements
• Recommendation Engine: Suggests career paths and skill development opportunities
• Employer Matching: Ranks candidates for employer review

5.2 Your Rights Regarding AI Decisions

• Right to Explanation: You can request details about how AI decisions affecting you are made
• Human Review: You can request human review of automated decisions
• Algorithm Transparency: We provide information about our AI model training and bias prevention measures
• Opt-Out Option: You can limit automated processing of your information

5.3 Bias Prevention and Fairness

We implement the following measures to ensure fair and non-discriminatory AI processing:

• Regular algorithm auditing for bias
• Diverse training data sets
• Ongoing monitoring of AI outputs
• Human oversight of AI decisions
• Compliance with Canadian Human Rights Act principles

6. Information Sharing and Employer Matching

We share your information in specific circumstances, always with appropriate consent and safeguards:

6.1 Employer Sharing

• Explicit Consent Required: We only share your information with employers when you explicitly apply for positions or consent to profile sharing
• Profile Visibility Controls: You control what information employers can see and when
• Application Withdrawal: You can withdraw applications and request removal of shared information
• Employer Obligations: We require employers to comply with privacy and human rights laws

6.2 Service Providers

• Cloud hosting providers (with data processing agreements)
• Analytics and improvement services
• Security and fraud prevention services
• Customer support platforms

6.3 Legal Requirements

• Court orders and legal proceedings
• Regulatory investigations
• Emergency situations involving safety
• Employment equity reporting (anonymized)

7. Data Security and Protection

We implement comprehensive security measures to protect your personal information:

7.1 Technical Safeguards

• End-to-end encryption for sensitive data
• Secure data transmission (TLS/SSL)
• Regular security audits and penetration testing
• Access controls and authentication systems
• Data backup and recovery procedures

7.2 Organizational Measures

• Privacy impact assessments for new features
• Staff training on privacy and security
• Data handling policies and procedures
• Regular security awareness training
• Incident response procedures

8. Your Privacy Rights

Under PIPEDA and provincial privacy laws, you have comprehensive rights regarding your personal information:

8.1 Access Rights

• Right to Access: Request copies of your personal information
• Information About Processing: Understand how your information is being used
• Source Information: Know where your information came from
• Sharing Information: Understand who has access to your information

8.2 Correction and Update Rights

• Correct inaccurate information
• Update outdated information
• Complete incomplete information
• Challenge accuracy of information

8.3 Deletion and Portability Rights

• Right to Delete: Request deletion of your personal information
• Data Portability: Receive your information in a structured format
• Account Closure: Close your account and delete associated data
• Selective Deletion: Delete specific categories of information

8.4 Control Rights

• Consent Withdrawal: Withdraw consent for specific processing activities
• Objection Rights: Object to certain uses of your information
• Marketing Opt-Out: Unsubscribe from marketing communications
• Processing Restrictions: Limit how your information is processed

8.5 How to Exercise Your Rights

To exercise your privacy rights:

1. Contact us using the information in Section 16
2. Provide sufficient information to verify your identity
3. Specify which rights you want to exercise
4. We will respond within 30 days as required by law

9. Data Retention and Deletion

We retain your personal information only as long as necessary for the purposes outlined in this policy:

9.1 Retention Periods

• Active Account Data: Retained while your account is active
• Job Application Data: Retained for 2 years after application unless deleted earlier
• Communication Records: Retained for 1 year for customer service purposes
• Analytics Data: Anonymized and retained for 3 years for service improvement
• Legal Compliance Data: Retained as required by applicable laws

9.2 Deletion Procedures

• Secure deletion of personal information when retention periods expire
• Immediate deletion upon request (where legally permissible)
• Anonymization of data used for analytics and improvement
• Deletion of backup copies according to our backup retention schedule

10. International Data Transfers

Your information may be transferred outside Canada under the following safeguards:

10.1 Transfer Safeguards

• Contractual protections equivalent to PIPEDA requirements
• Adequacy assessments of recipient countries' privacy laws
• Specific consent for transfers to countries without adequate protection
• Data processing agreements with international service providers

10.2 Current Transfer Locations

We may transfer data to:

• United States (with appropriate safeguards)
• European Union (under adequacy decisions)
• Other countries with adequate privacy protections

11. Privacy Breach Notification

In accordance with PIPEDA's breach notification requirements:

11.1 Breach Response Procedures

• Immediate containment and assessment of breaches
• Notification to the Privacy Commissioner of Canada within 72 hours
• Notification to affected individuals without unreasonable delay
• Cooperation with privacy commissioner investigations

11.2 What We Will Tell You

If a breach affects you, we will provide:

• Description of the breach and information involved
• Steps we're taking to address the breach
• Measures you can take to protect yourself
• Contact information for questions and assistance

12. Employment Equity and Human Rights

We are committed to promoting employment equity and preventing discrimination:

12.1 Employment Equity Data

• Collection of demographic information is voluntary and requires explicit consent
• Used only for employment equity analysis and reporting
• Kept separate from recruitment and hiring processes
• Aggregated and anonymized for reporting purposes

12.2 Accommodation Information

• Information about accommodation needs is collected with explicit consent
• Shared with employers only when necessary for accommodation discussions
• Protected as sensitive personal information
• Deleted when no longer needed for accommodation purposes

12.3 Anti-Discrimination Measures

• AI algorithms are designed to prevent discriminatory outcomes
• Regular auditing for bias in job matching and recommendations
• Training for staff on human rights and privacy obligations
• Procedures for handling discrimination complaints

13. Third-Party Services

We work with third-party service providers who may have access to your information:

13.1 Service Provider Categories

• Cloud hosting and infrastructure providers
• Analytics and business intelligence services
• Customer support and communication platforms
• Security and fraud prevention services
• Payment processing services

13.2 Third-Party Obligations

All service providers must:

• Sign data processing agreements
• Comply with PIPEDA requirements
• Implement appropriate security measures
• Use information only for specified purposes
• Return or delete information upon contract termination

14. Provincial Privacy Law Compliance

We comply with applicable provincial privacy legislation:

14.1 Quebec (Bill 64)

• Enhanced consent requirements for sensitive information
• Mandatory privacy impact assessments
• Strengthened breach notification obligations
• Additional rights for Quebec residents

14.2 Alberta (PIPA)

• Compliance with Alberta's Personal Information Protection Act
• Specific consent requirements for employee information
• Notification obligations to Alberta Privacy Commissioner

14.3 British Columbia (PIPA)

• Compliance with BC's Personal Information Protection Act
• Specific requirements for employee personal information
• Notification obligations to BC Privacy Commissioner

15. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements:

15.1 Notification of Changes

• Email notification to registered users for material changes
• Website notification for 30 days before changes take effect
• Opportunity to review and object to changes
• Right to withdraw consent if you disagree with changes

15.2 Version Control

• Previous versions available upon request
• Clear indication of effective dates
• Summary of material changes

16. Contact Information

For questions about this Privacy Policy or to exercise your privacy rights, please contact us:

Privacy Commissioner Contacts

If you have concerns about our privacy practices, you may also contact:

• Office of the Privacy Commissioner of Canada: 1-800-282-1376 or www.priv.gc.ca
• Information and Privacy Commissioner of Ontario: 1-800-387-0073 or www.ipc.on.ca
• Commission d'accès à l'information du Québec: 1-888-528-7741 or www.cai.gouv.qc.ca

Version Française

Une version française de cette politique de confidentialité est disponible sur demande. Veuillez nous contacter à privacy@clarix-ai.com pour obtenir la version française.