Privacy Policy

This Privacy Policy describes how AI Recruitment Technologies Inc. ("Company," "we," "us," or "our") collects, uses, and discloses information in connection with the Alphie platform and related services (the "Service").

1. Scope and Your Relationship With Us

This Policy covers two distinct data flows, and your rights depend on which applies to you:

1.1 Data Collected on Our Customers' Websites

When you visit a website that has deployed the Alphie script, we process your information on behalf of that website operator (our customer). For purposes of the California Consumer Privacy Act ("CCPA") as amended by the California Privacy Rights Act ("CPRA"), and analogous laws in other U.S. states, we act as a Service Provider (or Processor) to that customer. Under the GDPR, the UK GDPR and similar laws in other countries, the customer is the controller and we are its processor. The customer is the party that determines why your data is collected and how it is used, and the customer's privacy policy governs that relationship. Sections 3, 4, 5, and 6 of this Policy describe what we do with that data.

1.2 Data Collected Directly by Us

When you visit meetalphie.com, create an account with us, or otherwise interact with us directly, we act as the controller (or Business) of your information. Section 7 of this Policy describes what we do with that data.

2. Geographic Scope

How the Service treats you depends on where you are, based on your IP address:

• United States, Canada, Australia, New Zealand, Singapore, India and Mexico. The Service may identify the company you work for, unless you decline in the website's consent banner or your browser sends a Global Privacy Control signal.
• European Economic Area, United Kingdom, Switzerland and all other countries. The Service identifies the company you work for only after you accept in the website's consent banner.
• China, Russia, sanctioned countries, and locations we can't determine. The Service doesn't identify you.

The full country rules are in our Data Processing Addendum at meetalphie.com/dpa. We and our sub-processors process data in the United States and the European Union. Where the law requires a transfer mechanism, such as for data from the European Economic Area, the United Kingdom or Switzerland, we rely on the European Commission's Standard Contractual Clauses and the UK Addendum, as set out in the DPA. If you're in the European Economic Area, the United Kingdom or Switzerland, Section 11.3 explains your rights.

Part A — Data We Process on Our Customers' Behalf to Provide the Service

3. Information We Process on Behalf of Customers

When the Alphie script is deployed on a customer website, we may process the following categories of personal information about visitors:

Identifiers

Professional email address. We may also process device and cookie identifiers in connection with your session, behavioral and usage data while on a customer website, and general location information.

Professional or Employment Information

Employer name.

Internet or Electronic Network Activity

Pages viewed, referring URLs, session duration, interaction with Alphie AI components, and device and browser information.

Sources

We collect this information from (a) the visitor's browser, (b) the visitor themselves, if they input or upload information, (c) third-party identity resolution partners, including data brokers, that provide professional information, and (d) publicly available sources.

Sensitive Personal Information

We do not intentionally collect Sensitive Personal Information as defined under the CPRA. If such information is incidentally received, we do not use or disclose it for any purpose other than those permitted under CPRA § 7027(m).

Personalized content. On some customer websites, the Service uses Resolved Company Data to personalize content the customer chooses to display to visitors (for example, messaging relevant to a visitor's industry or company size). This content is authored, configured, and controlled by the customer. We do not use it to advertise our own products or to market to visitors on our own behalf. As used here, "Resolved Company Data" means the company-level identity and firmographic attributes generated through the Service (for example, company name, domain, industry, employee count, and revenue range); it never includes a visitor's IP address.

Contacts at Identified Companies

Customers can use the Service to find the business contact details (name, job title, work email address and professional profile URL) of people who work at companies that visited the customer's website, from our data providers, and to contact them on the customer's behalf. We support this only for people located in the United States and, using work email addresses only, the United Kingdom. Every outreach email includes an unsubscribe link, and we honor unsubscribe requests.

4. How We Use This Information

We process the above information for the following business purposes only:

• Providing the Service to the customer whose website you visited
• Verifying and maintaining the quality, integrity, and security of the Service
• Debugging and error resolution
• Complying with legal obligations and responding to legal process

We do not use this information to build general-purpose profiles of individuals, to train AI models, to sell products to visitors directly, or for our own marketing.

We generate aggregated statistics about widget usage (such as conversation counts, durations, and automated topic categories) that do not include the content of any conversation and cannot be used to identify any person or company.

5. Identity Resolution

5.1 How Deanonymization Works

To power Alphie's identity resolution features, we use third-party identity resolution providers. When you visit a website using Alphie, these providers may receive your IP address and use cookies or web beacons to associate your session with publicly available professional profiles. Our servers receive your IP address only to pass it to these providers during your visit. We don't store it or write it to our logs, and the providers return only resolved company or professional information to us. For visitors outside the United States, we use only our EU-based provider. We may use one or more such providers, and the specific provider used may vary over time as we evaluate accuracy and service quality. The current list of providers is on our Sub-processors page.

5.2 Provider Evaluation

As part of maintaining service quality, we may review resolved visitor profiles to verify accuracy and to compare the performance of identity resolution providers. We do not combine profiles across customers except to compute aggregate accuracy metrics, we do not retain profiles longer than reasonably necessary for this evaluation, and we do not use profiles for any other purpose.

6. No Sale or Sharing

We do not "sell" personal information processed through customer websites, and we do not "share" it for cross-contextual behavioral advertising, as those terms are defined under the CCPA/CPRA. We do not contribute this data to any general-purpose data broker database.

Part B — Data Collected Directly by Us for Business Purposes

7. Information We Collect Directly

When you interact with us directly, we collect:

Identifiers and contact information

Name, email address, phone number, company name, job title, and account credentials when you register for the Service, request a demo, contact us, or subscribe to communications.

Billing information

Payment method and billing address (processed by our payment processor; we do not store full card numbers).

Website analytics

Pages viewed, referring URLs, device and browser information, and interaction with meetalphie.com.

Communications

Records of emails, support tickets, and other correspondence with us.

We use this information to provide and operate the Service, process payments, respond to inquiries, send service and marketing communications (with opt-out available), improve our website, and comply with legal obligations.

8. Limited Use of Google User Data

Alphie's use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

9. How We Share Information

We disclose information in the categories described above to the following categories of recipients:

• Service providers that help us operate the Service and run our business, including the following categories of service providers: video conferencing, collaboration, hosting, analytics, customer support, payment processing, email delivery, AI developers, and identity resolution providers
• Contractors who agree to use personal information only for purposes of providing a requested service to us, including professional advisors such as lawyers, accountants, and auditors
• Authorities and other parties where required by law, in response to lawful requests, or to protect our rights, property, or safety or that of others
• Successors in connection with a merger, acquisition, reorganization, or sale of assets

We do not sell personal information collected through meetalphie.com, and we do not share it for cross-contextual behavioral advertising.

10. Cookies and Tracking Technologies

10.1 On Our Website

We use cookies and similar technologies on meetalphie.com for essential functionality, analytics, and marketing attribution. You can control cookies through your browser settings. Visitors from countries where we ask for consent see our cookie banner, and anyone can change or withdraw their choice at any time through the "Cookie settings" link in the footer.

10.2 Global Privacy Control

We honor Global Privacy Control ("GPC") signals. When your browser transmits a GPC signal to meetalphie.com or to a website using the Alphie script, we treat it as a request to opt out of sale or sharing and, for the Alphie script, as a request to disable identity resolution for that session.

10.3 Do Not Track

We do not currently respond to browser "Do Not Track" signals, because no consensus standard exists. We do honor GPC as described above.

10.4 Consent Tools

The Alphie script reads the website's consent banner, including tools that use the IAB Transparency and Consent Framework or the IAB Global Privacy Platform. If you decline, the Service doesn't identify you. In the countries where Section 2 says the Service waits for your consent, it identifies your company only after you accept.

Part C — Privacy Requests

11. Data Deletion and Access Requests

For Part A data, please send your requests to the website operator whose site you visited; we will cooperate with verified requests routed through them. For Part B data that we process as a Business or controller, you can send us one or more of the following privacy requests and we will respond in accordance with the process described in Section 12. We will never discriminate against you on the basis of your submission of any privacy requests.

11.1 Privacy Requests

• Request to Know or Access — request a copy of the personal information we hold about you, including categories, sources, purposes, and recipients
• Request to Delete — request deletion of personal information, subject to legal exceptions
• Request to Correct — request correction of inaccurate personal information
• Opt-out requests applying to the sale or sharing of information; limiting the use of sensitive personal information; and profiling/automated decision-making do not apply because we do not engage in any practices that trigger these opt-out rights.

11.2 California Delete Act

In compliance with the California Delete Act (2026), we will cooperate with verified deletion requests routed through our customers or the California Privacy Protection Agency's consumer deletion mechanism, and we will delete affected data from our systems within the statutory time frame.

11.3 Residents of the EEA, the UK and Switzerland

If you're in the European Economic Area, the United Kingdom or Switzerland, you can also ask us to restrict or stop processing your personal data, or to give it to you in a portable format, and you can complain to your local data protection authority. For data we process on a customer's behalf, the customer is the controller, so the quickest route is to contact them. If you contact us, we'll pass your request on and help them respond.

12. How to Submit a Request

12.1 Submitting a Request

To submit a request, email us at legal@meetalphie.com with the subject line "Privacy Request" and specify the request you wish to make.

12.2 Verification

We will verify your identity before responding to a request by matching information you provide against information in our records. If we cannot verify your identity, we may ask for additional information or decline the request.

12.3 Authorized Agents

You may designate an authorized agent to make a request on your behalf. We require written authorization from you and may verify your identity directly before responding.

12.4 Response Times

We respond to verifiable requests within the time periods required by applicable law (typically 45 days under U.S. state laws, extendable to 90 days in complex cases, and one month under the GDPR and UK GDPR, extendable by two months). If we cannot comply with a request, we will explain why.

13. Automated Decision-Making and AI

The Service uses automated processing, including machine learning, to resolve visitor identities, generate enrichment data, and produce summaries and recommendations. We do not use these outputs to make decisions that produce legal or similarly significant effects on individuals, and we require our customers (under our Terms of Service) not to use them for such purposes without appropriate human review. If you believe automated processing has produced an outcome that significantly affects you, please contact us.

Part D — General

14. Children's Privacy

The Service is not directed to children under 16, and we do not knowingly collect personal information from children under 16. If you believe we have collected information from a child under 16, please contact us at legal@meetalphie.com and we will delete it.

15. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, to provide the Service, and to comply with legal obligations. Specifically:

• Visitor data processed on customer websites -- the resolved company and professional information we receive, and contact details found for outreach, are kept in the customer's dashboard while the customer's account is open, and deleted when the customer deletes the account or earlier at the customer's request. As described in Section 5.1, we don't store visitors' IP addresses.
• Account and billing data — retained for the duration of your relationship with us and for a reasonable period after to comply with tax, accounting, and legal obligations.
• Website analytics — retained for up to 24 months unless a longer period is required by law.

16. Data Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, disclosure, or alteration. No security measure is perfect, and we cannot guarantee absolute security.

17. Third-Party Links and Services

The Service may link to or integrate with third-party platforms (including LinkedIn, Slack, and others). This Policy does not apply to those third parties, and we encourage you to review their privacy policies.

18. Changes to This Policy

We may update this Policy from time to time. For material changes, we will notify you by updating the "Last Updated" date and, where appropriate, by providing a more prominent notice (such as an email or in-product banner). Your continued use of the Service after the effective date of the change constitutes acceptance.

19. Contact Us

AI Recruitment Technologies Inc.

Email: legal@meetalphie.com

If you have questions about this Policy, wish to exercise your rights, or have a concern we have not addressed, please contact us.

Version 2.2 -- Supersedes Policy dated September 21, 2026