Job-Bolt Employer Privacy Policy and Data Processing Addendum

Effective Date: May 11, 2026

This Employer Privacy Policy and Data Processing Addendum explains how Job-Bolt, Inc. (“Job-Bolt,” “we,” “our,” or “us”) collects, uses, shares, stores, protects, and processes information relating to employers, recruiters, staffing agencies, hiring organizations, business customers, account users, and other organizations that use the Job-Bolt platform (“Employer,” “Customer,” “you,” or “your”).

This Policy also describes Job-Bolt’s role when processing candidate personal information on behalf of Employers.

By creating an employer account, using the Job-Bolt platform, inviting candidates, reviewing candidate interviews, sharing candidate materials, or otherwise using Job-Bolt, you agree to this Policy.

1. About Job-Bolt

Job-Bolt provides a software-as-a-service platform that helps Employers conduct, record, transcribe, summarize, score, organize, review, and share candidate video interviews.

Job-Bolt may process candidate video recordings, audio recordings, transcripts, summaries, scores, structured notes, candidate first name, candidate last name, candidate email address, technical data, and related interview outputs in order to provide the platform.

Job-Bolt does not make hiring decisions. Employers are solely responsible for reviewing Job-Bolt outputs, applying human judgment, and making all final hiring, rejection, advancement, compensation, classification, and employment-related decisions.

2. Scope of This Policy

This Policy applies to:

1. Employer account information.
2. Employer user information.
3. Billing and payment information.
4. Employer communications with Job-Bolt.
5. Platform usage and technical information.
6. Candidate information processed through the Job-Bolt platform on behalf of Employers.
7. Candidate interview videos, audio, transcripts, summaries, scores, notes, and related outputs.
8. Information shared through Job-Bolt’s employer sharing and access features.

This Policy does not apply to information collected, stored, used, copied, downloaded, exported, screenshotted, scraped, recorded, forwarded, or otherwise retained by Employers outside the Job-Bolt platform. Employers are independently responsible for their own privacy, security, employment, data protection, and recordkeeping obligations outside Job-Bolt.

3. Roles of the Parties

For candidate personal information processed through the platform:

1. The Employer is generally the controller, business, or responsible party.
2. Job-Bolt is generally the processor, service provider, contractor, or vendor acting on behalf of the Employer.
3. The Employer determines the purpose and lawful basis for processing candidate information.
4. The Employer determines which candidates are invited, which roles are being filled, which questions are asked, which outputs are reviewed, who receives access, and how hiring decisions are made.
5. Job-Bolt processes candidate information to provide the platform and related services according to the Employer’s instructions, applicable agreements, this Policy, and applicable law.

In limited cases, Job-Bolt may act as an independent controller or business for purposes such as account administration, billing, platform security, fraud prevention, legal compliance, analytics, service improvement, dispute resolution, and enforcement of agreements.

4. Employer Information We Collect

Job-Bolt may collect information from or about Employers and employer users, including:

1. Business name.
2. Business address.
3. Business email address.
4. Employer contact name.
5. Employer user name.
6. Employer user email address.
7. Job title or business role.
8. Account login credentials.
9. Account settings.
10. Subscription plan information.
11. Billing information.
12. Payment status.
13. Invoice history.
14. Communications with Job-Bolt.
15. Support requests.
16. Contract information.
17. Platform usage information.
18. Security and audit logs.
19. IP address.
20. Device information.
21. Browser information.
22. Approximate location derived from IP address.
23. Other information provided by the Employer or required to operate the account.

Job-Bolt may use third-party payment processors. Job-Bolt may not receive or store full payment card details if payment is processed by a third-party payment provider.

5. Candidate Information Processed on Behalf of Employers

When Employers use Job-Bolt to invite and evaluate candidates, Job-Bolt may process candidate information on behalf of the Employer, including:

1. Candidate first name.
2. Candidate last name.
3. Candidate email address.
4. Role or job title associated with the interview.
5. Employer or hiring organization associated with the interview.
6. Video recording.
7. Audio recording.
8. Candidate image, voice, and likeness.
9. Interview environment visible or audible during the interview.
10. Spoken responses.
11. Written responses, if applicable.
12. Uploaded documents, if applicable.
13. Interview questions.
14. Interview timestamps.
15. Interview duration.
16. Interview completion status.
17. Transcripts.
18. AI-generated summaries.
19. Structured notes.
20. Scores, ratings, tags, and related outputs.
21. Technical, usage, security, and fraud-prevention data.
22. Internal technical identifiers generated by Job-Bolt, such as session IDs, system IDs, log IDs, or similar backend reference numbers used to operate and secure the platform.

Job-Bolt does not intentionally collect candidate phone numbers as part of the standard candidate interview process unless a specific Employer workflow or integration provides that information.

6. How Job-Bolt Uses Employer Information

Job-Bolt may use Employer information to:

1. Create and manage employer accounts.
2. Provide access to the platform.
3. Authenticate employer users.
4. Provide services and platform functionality.
5. Process billing and payments.
6. Send invoices and account notices.
7. Provide customer support.
8. Respond to inquiries.
9. Manage subscriptions and contracts.
10. Monitor usage and enforce usage limits.
11. Maintain security.
12. Detect fraud, abuse, scraping, unauthorized access, or misuse.
13. Troubleshoot technical issues.
14. Improve platform reliability, performance, and user experience.
15. Develop and improve services where legally permitted.
16. Send service, security, legal, product, and administrative updates.
17. Enforce agreements and policies.
18. Comply with legal, tax, accounting, insurance, and regulatory obligations.
19. Protect the rights, safety, and security of Job-Bolt, Employers, candidates, and others.

Job-Bolt does not sell Employer information.

7. How Job-Bolt Processes Candidate Information

Job-Bolt processes candidate information on behalf of Employers to:

1. Invite candidates to interviews.
2. Conduct and record video interviews.
3. Record audio responses.
4. Capture candidate image, voice, likeness, and visible interview environment.
5. Transcribe candidate responses.
6. Generate summaries.
7. Generate structured notes.
8. Generate scores, ratings, tags, and related interview outputs.
9. Organize candidate materials for Employer review.
10. Make interview materials available to the Employer and Employer-authorized users.
11. Support Employer sharing features.
12. Maintain audit logs.
13. Provide technical support.
14. Maintain platform security.
15. Detect fraud, abuse, impersonation, scraping, automated misuse, or improper activity.
16. Comply with applicable law.
17. Enforce agreements.
18. Protect legal rights.
19. Maintain records where required or permitted for legal, audit, dispute-resolution, security, fraud-prevention, or compliance purposes.

Job-Bolt does not make final hiring decisions and does not determine whether a candidate is hired, rejected, advanced, interviewed again, compensated, classified, or selected for any role.

8. Employer Instructions

The Employer instructs Job-Bolt to process candidate information as necessary to provide the platform and related services.

The Employer’s instructions include:

1. These Terms and this Policy.
2. The applicable order form, subscription, invoice, or agreement.
3. Platform settings selected by the Employer.
4. Candidate invitations sent or authorized by the Employer.
5. Interview workflows configured or approved by the Employer.
6. Sharing settings selected by the Employer.
7. Written instructions provided by the Employer, where accepted by Job-Bolt.

Job-Bolt may decline instructions that Job-Bolt reasonably believes are unlawful, unsafe, technically infeasible, inconsistent with the platform, or likely to create legal, security, operational, or reputational risk.

9. Employer Obligations

Employers are solely responsible for their own hiring process and use of Job-Bolt.

Employers represent and warrant that they will:

1. Have a lawful basis for collecting and processing candidate information.
2. Provide all required candidate notices.
3. Obtain all required candidate consents.
4. Provide any required AI, video interview, biometric, or automated-tool disclosures.
5. Comply with employment, labor, privacy, data protection, accessibility, anti-discrimination, and recordkeeping laws.
6. Use Job-Bolt outputs only for lawful hiring, recruiting, evaluation, compliance, legal, or related business purposes.
7. Maintain appropriate human review of candidate materials and Job-Bolt outputs.
8. Ensure interview questions and evaluation criteria are lawful, job-related, and non-discriminatory.
9. Respond to candidate privacy requests where the Employer is the controller, business, or responsible party.
10. Respond to candidate accommodation requests.
11. Limit access to candidate materials to authorized persons with a legitimate need to know.
12. Protect candidate information outside the Job-Bolt platform.
13. Avoid sharing candidate materials with unauthorized or inappropriate recipients.
14. Avoid using candidate information for unrelated marketing, unlawful profiling, harassment, retaliation, or discrimination.
15. Not represent that Job-Bolt made or controlled a hiring decision.

10. AI Hiring, Video Interview, and Automated Tool Compliance

Certain jurisdictions regulate AI, automated employment decision tools, video interviews, scoring tools, biometric processing, profiling, and candidate evaluation technologies.

These laws may require notices, consent, audits, public disclosures, deletion rights, human review, appeal rights, recordkeeping, impact assessments, or other compliance obligations.

Employers are solely responsible for determining whether any such laws apply to their use of Job-Bolt and for complying with those laws.

These may include laws or requirements in New York City, California, Illinois, Maryland, Colorado, the European Union, the United Kingdom, and other jurisdictions. The EU AI Act treats certain AI systems used in employment, worker management, recruitment, or candidate evaluation as high-risk depending on the use case.

Job-Bolt may provide technical documentation, candidate-facing language, audit-support materials, platform notices, or other compliance-support materials. However, Job-Bolt does not provide legal advice and does not guarantee that an Employer’s use of Job-Bolt complies with any specific law.

11. Candidate Notices and Consents

Employers are responsible for providing legally required notices and obtaining legally required consents before inviting candidates to complete Job-Bolt interviews.

This may include notice and consent for:

1. Video recording.
2. Audio recording.
3. Transcription.
4. AI-assisted analysis.
5. Scoring.
6. Summaries.
7. Structured notes.
8. Candidate evaluation outputs.
9. Use of candidate image, voice, likeness, and visible interview environment.
10. Data sharing with Employer-authorized users.
11. Data retention.
12. Candidate rights.
13. Deletion requests.
14. Accommodations.
15. Human review, where required.

Job-Bolt may provide candidate-facing terms, privacy notices, consent screens, or disclosure language, but Employers remain responsible for determining whether those materials are sufficient for their legal obligations.

12. Employer Sharing, Authorized Users, and Shared Access

Job-Bolt may allow Employers to share access to candidate interview materials with employees, contractors, recruiters, hiring managers, interviewers, advisors, service providers, affiliates, representatives, legal personnel, compliance personnel, or other individuals involved in the Employer’s hiring, recruiting, evaluation, compliance, legal, or business process.

Depending on platform settings, shared recipients may be able to view or access candidate first name, last name, email address, interview video, audio recording, transcript, summaries, scores, notes, tags, ratings, interview status, and related interview outputs.

Employers are solely responsible for determining who is authorized to access candidate materials and for ensuring that any sharing is lawful, appropriate, job-related, confidential, secure, and consistent with applicable privacy, employment, data protection, anti-discrimination, confidentiality, and recordkeeping laws.

Employers are responsible for all access, use, disclosure, copying, downloading, exporting, screenshotting, recording, scraping, forwarding, saving, retention, or further sharing of candidate materials by their users, authorized recipients, shared-link recipients, or other persons who receive access through the Employer.

Job-Bolt does not control and is not responsible for the Employer’s decision to share candidate materials with any internal or external recipient.

13. Subprocessors and Service Providers

Job-Bolt may use subprocessors and service providers to operate and support the platform.

These may include:

1. Cloud hosting providers.
2. Data storage providers.
3. AI infrastructure providers.
4. Transcription providers.
5. Analytics providers.
6. Monitoring and logging providers.
7. Security providers.
8. Customer support providers.
9. Email and communications providers.
10. Payment processors.
11. Legal, accounting, tax, compliance, and insurance providers.

Job-Bolt will use commercially reasonable efforts to ensure that subprocessors who process candidate personal information are subject to written obligations designed to protect personal information.

Job-Bolt remains responsible for its subprocessors’ processing of candidate personal information to the extent required by applicable law and applicable written agreements.

Job-Bolt may update its subprocessors from time to time. Where required by law or contract, Job-Bolt will provide notice of material subprocessor changes and allow Employers to object according to the applicable data processing agreement.

14. Sharing of Employer Information

Job-Bolt may share Employer information with:

1. Service providers and vendors that help operate Job-Bolt.
2. Payment processors.
3. Cloud infrastructure providers.
4. Security and fraud-prevention providers.
5. Analytics providers.
6. Customer support providers.
7. Professional advisors.
8. Legal, accounting, tax, compliance, and insurance providers.
9. Government authorities, regulators, courts, or law enforcement where required or permitted by law.
10. Parties involved in a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or change of control.

Job-Bolt does not sell Employer information.

15. No Sale of Candidate Data

Job-Bolt does not sell candidate personal information.

Job-Bolt does not knowingly share candidate personal information for cross-context behavioral advertising.

Job-Bolt does not use candidate interview recordings, transcripts, or responses to train general AI models unless permitted by applicable law and authorized by a valid legal basis, customer agreement, candidate consent, or other applicable authorization.

Job-Bolt may create and use de-identified, aggregated, or anonymized information for security, analytics, product improvement, benchmarking, service development, and business purposes, provided that such information does not identify a candidate and is not used to make a hiring decision about the candidate.

16. Retention of Employer Information

Job-Bolt retains Employer information for as long as necessary to:

1. Provide the platform.
2. Maintain the employer account.
3. Process billing and payments.
4. Provide support.
5. Comply with legal, tax, accounting, insurance, and regulatory obligations.
6. Resolve disputes.
7. Enforce agreements.
8. Maintain security.
9. Prevent fraud and misuse.
10. Protect Job-Bolt’s rights.

After an employer account is closed, Job-Bolt may retain certain Employer information as required or permitted by law, contract, backup procedures, dispute-resolution needs, security needs, or legitimate business purposes.

17. Retention and Deletion of Candidate Information

Unless a shorter period is required by law or requested by the Employer, Job-Bolt will make candidate interview videos, audio recordings, transcripts, summaries, scores, and related interview outputs available to the Employer for up to one year from the date of the interview.

After one year, Job-Bolt will delete or de-identify candidate interview videos, audio recordings, transcripts, summaries, scores, and related interview outputs stored within Job-Bolt-controlled systems, unless retention is required or permitted for:

1. Legal compliance.
2. Dispute resolution.
3. Security.
4. Fraud prevention.
5. Backup integrity.
6. Audit purposes.
7. Enforcement of agreements or terms.
8. Protection of Job-Bolt’s rights.
9. Compliance with lawful Employer instructions.
10. Legal recordkeeping obligations.
11. Establishment, exercise, or defense of legal claims.

Job-Bolt’s deletion obligations apply only to candidate materials stored within Job-Bolt-controlled systems.

Deletion from Job-Bolt’s systems does not require or guarantee deletion of copies previously accessed, viewed, downloaded, exported, scraped, copied, recorded, screenshotted, printed, saved, summarized, forwarded, uploaded, or otherwise retained by Employers, Employer users, shared recipients, or third parties outside the Job-Bolt platform.

18. Candidate Privacy Requests

If a candidate submits a request to access, correct, delete, restrict, object to, port, appeal, or otherwise exercise privacy rights relating to candidate information, the Employer is responsible for responding where the Employer is the controller, business, or responsible party under applicable law.

Job-Bolt may assist the Employer with candidate privacy requests as required by law, contract, or applicable data processing agreement.

Job-Bolt may refer candidate requests to the Employer where appropriate.

If Job-Bolt receives a legally binding request from a regulator, court, or government authority relating to candidate information, Job-Bolt may respond as required by law and may notify the Employer where legally permitted.

19. Security

Job-Bolt uses reasonable administrative, technical, and organizational safeguards designed to protect Employer and candidate information.

These safeguards may include:

1. Encryption in transit.
2. Encryption at rest.
3. Access controls.
4. Logging and monitoring.
5. Authentication controls.
6. Vendor controls.
7. Security procedures.
8. Internal confidentiality controls.
9. Incident-response processes.

No system is completely secure. Job-Bolt cannot guarantee absolute security.

Employers are responsible for maintaining the security of their own accounts, credentials, devices, systems, networks, downloads, exports, integrations, screenshots, recordings, shared links, and candidate information stored outside Job-Bolt.

Employers must promptly notify Job-Bolt of any unauthorized access, suspected breach, compromised credentials, improper sharing, or security incident involving Job-Bolt or candidate information obtained through Job-Bolt.

20. Security Incidents

If Job-Bolt becomes aware of a security incident involving candidate personal information processed on behalf of an Employer, Job-Bolt will notify the Employer without undue delay where required by applicable law or contract.

The notice may include information reasonably available to Job-Bolt, such as:

1. Nature of the incident.
2. Categories of information involved.
3. Approximate number of affected individuals, if known.
4. Measures taken or planned by Job-Bolt.
5. Recommended steps for the Employer, if applicable.

Employers are responsible for determining whether legal notification to candidates, regulators, or other parties is required, unless Job-Bolt is legally required to provide such notification directly.

21. International Transfers

Employer and candidate information may be processed in the United States and other countries.

Where required, Job-Bolt uses appropriate safeguards for international transfers, which may include:

1. Standard Contractual Clauses.
2. UK International Data Transfer Addendum or equivalent UK safeguards.
3. Transfer risk assessments.
4. Data processing agreements.
5. Other legally recognized transfer mechanisms.

Employers are responsible for determining whether their transfer of candidate information to Job-Bolt is lawful and whether additional transfer documentation or safeguards are required.

22. CCPA/CPRA Service Provider Terms

Where the California Consumer Privacy Act, as amended by the California Privacy Rights Act, applies, Job-Bolt acts as a service provider or contractor for candidate personal information processed on behalf of the Employer.

Job-Bolt will not:

1. Sell candidate personal information.
2. Share candidate personal information for cross-context behavioral advertising.
3. Retain, use, or disclose candidate personal information for purposes other than the business purposes described in the agreement, this Policy, or as otherwise permitted by law.
4. Retain, use, or disclose candidate personal information outside the direct business relationship between Job-Bolt and the Employer, except as permitted by law.
5. Combine candidate personal information received from the Employer with personal information from other sources except as permitted by the CCPA/CPRA and applicable regulations.

Job-Bolt will provide the same level of privacy protection required of service providers or contractors under applicable California privacy law.

The Employer may take reasonable and appropriate steps to help ensure that Job-Bolt processes candidate personal information in a manner consistent with the Employer’s obligations under applicable California privacy law.

Job-Bolt will notify the Employer if Job-Bolt determines it can no longer meet its obligations under applicable California privacy law, where required.

23. GDPR, UK GDPR, EEA, Switzerland, and UK Processing Terms

Where GDPR, UK GDPR, Swiss data protection law, or similar laws apply:

1. The Employer is generally the controller.
2. Job-Bolt is generally the processor.
3. Candidate personal data is processed for the purposes described in this Policy, the applicable agreement, and Employer instructions.
4. Job-Bolt will process candidate personal data only on documented instructions from the Employer, unless required by law.
5. Job-Bolt will ensure that persons authorized to process candidate personal data are subject to confidentiality obligations.
6. Job-Bolt will implement appropriate technical and organizational measures.
7. Job-Bolt will assist the Employer with data subject requests where required by law and contract.
8. Job-Bolt will assist the Employer with security, breach notification, data protection impact assessments, and consultations with supervisory authorities where required by law and contract.
9. Job-Bolt will make available information reasonably necessary to demonstrate compliance where required by law and contract.
10. Job-Bolt will delete or return candidate personal data at the end of services, unless retention is required or permitted by law.
11. Job-Bolt will impose appropriate data protection obligations on subprocessors.

The parties may enter into a separate Data Processing Agreement. If there is a conflict between this Policy and a signed Data Processing Agreement, the signed Data Processing Agreement controls for the covered processing.

24. Audit and Compliance Information

Upon reasonable written request, Job-Bolt may provide information reasonably necessary to demonstrate compliance with this Policy and applicable data processing obligations.

This may include security summaries, subprocessor information, compliance documentation, audit summaries, or other materials reasonably available to Job-Bolt.

Any audit or review must:

1. Be conducted during normal business hours.
2. Be subject to reasonable notice.
3. Not interfere with Job-Bolt’s operations.
4. Not compromise the security, confidentiality, or privacy of Job-Bolt, other customers, candidates, systems, or third parties.
5. Be subject to confidentiality obligations.
6. Be limited to information relevant to the Employer’s use of Job-Bolt.

Job-Bolt may satisfy audit obligations by providing third-party audit reports, certifications, security documentation, written responses, or other compliance materials where appropriate.

25. De-Identified and Aggregated Information

Job-Bolt may create and use de-identified, aggregated, or anonymized information for:

1. Security.
2. Analytics.
3. Product improvement.
4. Benchmarking.
5. Research.
6. Service development.
7. Business operations.

Job-Bolt will not use de-identified or aggregated information to make a hiring decision about a candidate.

Job-Bolt will use reasonable measures designed to prevent de-identified information from being used to identify a candidate.

26. Cookies and Similar Technologies

Job-Bolt may use cookies, pixels, local storage, log files, and similar technologies to:

1. Operate the platform.
2. Maintain employer sessions.
3. Authenticate users.
4. Improve performance.
5. Prevent fraud.
6. Analyze usage.
7. Secure the service.
8. Troubleshoot technical issues.

Employer users may be able to control cookies through browser settings, but disabling cookies may affect platform functionality.

27. Communications

Job-Bolt may send Employers and employer users:

1. Account notices.
2. Billing notices.
3. Security alerts.
4. Service messages.
5. Product updates.
6. Support communications.
7. Legal notices.
8. Administrative messages.
9. Marketing communications, where permitted by law.

Employer users may opt out of marketing communications, but may still receive necessary service, legal, security, and transactional messages.

28. Children and Minors

Job-Bolt is not intended for children under 16.

Employers may not use Job-Bolt to interview or process information about children or minors unless legally permitted and properly authorized.

Employers are responsible for obtaining any required parental, guardian, school, or legal consent where applicable.

29. Changes to This Policy

Job-Bolt may update this Policy from time to time. The updated version will be posted with a revised effective date.

Continued use of Job-Bolt after an updated Policy is posted means the Employer accepts the updated Policy, unless additional consent or agreement is required by law.

30. Contact

For privacy questions, contact:

Job-Bolt
hello@job-bolt.com