PRIVACY POLICY

We process your personal data for the specific, legitimate, and transparent purposes outlined below, in strict compliance with applicable US privacy laws. Our processing activities are guided by the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, and integrity and confidentiality.

We only collect, use, and disclose personal information in accordance with the laws that are in effect in the states of the United States. These laws include the California Consumer Privacy Act (CCPA), which was updated by the California Privacy Rights Act (CPRA), as well as legislation that are comparable in Virginia, Colorado, Connecticut, and Utah. We adhere to the principles of transparency, necessity, and respect for your rights when it comes to our data practices.

In practice, this means:

Service Delivery

• We process personal information to provide the services you request, such as job matching, account creation, communication with employers, and customer support.
• This includes using professional and preference data to connect candidates with relevant opportunities.

Security and Fraud Prevention

• We use technical and behavioral information (e.g., IP address, device details, log files) to protect against fraud, unauthorized access, and illegal activity.
• This helps us ensure the integrity and availability of our systems.

Legal and Compliance Requirements

• We may process and retain certain information where required to comply with U.S. laws, respond to legal requests, enforce our agreements, or protect our rights.

Personalization and Improvement

• With appropriate notices and choices, we use personal information to improve and personalize our services (such as refining job recommendations or tailoring site functionality).
• We may also use de-identified or aggregated data for analytics and research.

Consent-Based Uses

• In limited cases, such as processing sensitive personal information (e.g., disability or accommodation data), or when using optional tools like cookies for advertising, we rely on your explicit consent.
• You may withdraw your consent at any time by contacting us as described in this policy.

No Sale Without Your Right to Opt-Out

• We do not “sell” personal information as that term is defined under CCPA/CPRA. If we ever engage in practices considered “sharing” or “selling” under state law (such as cross-context behavioral advertising), you will be provided with clear notice and the right to opt out.

Our Role

• When we operate RangamWorks.com and determine the purposes and means of processing personal information, we act as a “business” (controller). When we process personal information on behalf of employers or clients, we act as a “service provider” (processor) and follow their instructions and the governing contract.

To deliver essential services and maintain the security of your datawe carefully share only essential professional information with vetted job providers. We empower you to control this process through your account settings, where you can easily manage your data-sharing preferences to align with your individual job search strategy. This ensures you remain informed of potential opportunities while maintaining control over your professional profile.

These providers are bound by contractual obligations and comply with stringent data protection standards, including those mandated by the United States law. The services include:

• Secure Cloud Infrastructure, Advanced Security Measures, and Service Analytics: We utilize third-party services to store your data securely, implement robust security protocols, and analyse service usage to enhance your experience. These partners are committed to protecting your data and adhere to relevant privacy regulations. We use Google Analytics 4 (GA4) and Dynatrace to collect aggregated performance and diagnostic data. Google and Dynatrace act as processors under data protection agreements. GA4 data sharing is governed by Standard Contractual Clauses (SCCs) and does not collect IP addresses by default when configured correctly. Dynatrace session monitoring is restricted to anonymized behavior metrics unless you provide explicit consent.

• Trusted Recruitment Partners: Candidate data (such as resumes, job preferences, and professional experience) is shared with employers, managed service providers (MSPs), and vendor management systems (VMS) only for the purpose of recruitment and placement. This information may not be used for advertising, marketing, or any unrelated profiling. Sensitive information, such as disability or ethnicity, is only shared with explicit consent and in accordance with Equal Employment Opportunity (EEO) requirements and the Fair Credit Reporting Act (FCRA). All partners are contractually prohibited from forwarding or repurposing candidate information without a new lawful basis.

  We also integrate with Moodle, a third-party learning management system (LMS), to facilitate training, onboarding, and professional development. By using Moodle through our Systems, you acknowledge and agree that your name, email address, and related utilization records (including course completions and quiz attempts) may be shared with and stored on Moodle’s servers. Moodle processes such data solely on behalf of Rangam Consultants and does not use it for its own purposes. All transfers are encrypted, and access is restricted to authorized Rangam personnel and trainers.

• Legal Compliance and Law Enforcement: We will disclose information when legally obligated to do so, including responding to valid legal requests from law enforcement or regulatory authorities in the jurisdictions where we operate.
• Business Restructuring: In the event of a merger, acquisition, or other business transfer, user data may be part of the transferred assets . Users will be notified in advance and provided options to manage their data preferences.

• AI Vendors as Subprocessors: We partner with third-party providers, such as OpenAI and other artificial intelligence (AI) vendors, to power certain platform features including resume optimization, chatbot support, and accessibility analysis. These vendors act strictly as subprocessors, meaning they only process personal information on our behalf and under our instructions.

  Training Restrictions: We do not permit AI vendors to use your personal information for their own model training or product development unless you have given us explicit consent.

  Residency & Retention: AI vendor processing typically occurs in the United States, and any data is retained only for the period required to deliver the requested feature before being deleted or de-identified.

  Your Choice: If you prefer not to have your information processed by these AI features, you may opt out at any time by contacting us at privacy@rangam.com.

Our Commitment to Your Privacy:

• We have a strict policy against selling user data to third parties. We do not sell or share your personal information, as defined under the California Consumer Privacy Act (CCPA).
• We conduct regular audits and assessments to ensure our third-party partners adhere to our privacy standards and applicable data protection laws.
• Our Privacy Policy provides detailed information about how we handle your data and your rights.

Our services are primarily operated and hosted in the United States. If you access our services from outside the United States, please be aware that your information may be transferred to, stored in, and processed in the United States or other countries where we or our service providers operate.

When personal information is transferred outside the United States, we implement appropriate safeguards — such as contractual commitments and technical protections — to help ensure your information remains secure and is handled in accordance with this Privacy Policy.

In some cases, recruiting or support personnel may access personal information from outside the United States. Access is limited to authorized staff following role-based access controls, least-privilege principles, confidentiality obligations, and audit requirements. Where required, we implement Standard Contractual Clauses (SCCs) or equivalent safeguards to ensure this access is consistent with applicable privacy laws.

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Personal Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Correct

If your personal information is inaccurate, you can ask us to correct it.

How to do it: Provide the incorrect data and the corrected version via the request channels mentioned in contact information. We’ll respond within 45 days.

Right to Appeal Automated Decision

In states such as Virginia, Colorado, and Connecticut, you may appeal an automated decision, including algorithmic candidate ranking. Appeals can be submitted to [privacy@rangam.com], and they will be reviewed by a human decision-maker.

Right to Opt-Out of Sale or Share

Depending on your state of residence (for example, Colorado or Connecticut), you may have the right to opt out of certain types of automated decision-making or profiling.

How to do it: Submit an opt-out request using the same channels listed above.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Additional State Privacy Rights

Depending on your state of residence, you may have additional privacy rights under laws such as the Virginia Consumer Data Protection Act (VCDPA), Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CTDPA), and Utah Consumer Privacy Act (UCPA). These rights may include access, correction, deletion, portability, and the right to opt-out of targeted advertising, profiling, and the sale of personal data.

Exercising Access, Data Portability, Correction, Opt-Out and Deletion Rights

To exercise the access, data portability, correction, opting-out and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at 908-704-8843

Emailing us at privacy@rangam.com

Or mailing us at 270 Davidson Avenue, Suite 103, Somerset, NJ 08873

Further, you may opt out through the “do not sell or share my personal information” by clicking here.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (extended by 45 more, total of 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Children’s Privacy

Our services are not directed to children under 13, and we do not knowingly collect personal information from them. If we become aware that we have collected personal information from a child under 13, we will delete it promptly.

The organization implements AI-driven tools as part of its recruitment and job matching processes, with the objective of enhancing efficiency and optimizing candidate placement in accordance with applicable legal frameworks. You may opt-out or request more details about how the technology works, including the key factors and testing for fairness.

• TalentArbor Platform: AI-Powered Inclusive Hiring Support. This platform utilizes AI algorithms designed to support inclusive hiring practices. It aims to mitigate biases in the recruitment process, potentially by analysing job descriptions for inclusive language, anonymizing candidate information, and identifying diverse talent pools. We are committed to ensuring that AI-driven tools comply with applicable US equal employment opportunity and anti-discrimination laws, including the Americans with Disabilities Act (ADA) and Title VII of the Civil Rights Act.
• ChatArbor AI Assistant: Job Search Guidance and Support. This AI assistant provides job seekers and other users who visit our website for guidance and support throughout their job search journey. It can answer questions, provide information about job openings, and assist with application processes. It's important that this assistant operates in a fair and unbiased manner, providing equitable support to all users regardless of their background or characteristics. For system maintenance, quality assurance, and to continuously improve Chat Arbor's performance, authorized administrators access and periodically review previous user conversations. This access is controlled and used for model training, identifying areas for enhancement, and ensuring the assistant's effectiveness. While administrators have access, stringent security measures protect user data confidentiality. We are committed to respecting user privacy and adhering to data protection principles, aiming to minimize the collection of personally identifiable information. By using Chat Arbor, you acknowledge and consent to this data handling for system improvement.

• Job Alignment Indicator (JAI): Accessibility Analysis for Neurodivergent Talent. The JAI tool uses AI to analyse job requirements and assess their accessibility for neurodivergent individuals. This is a positive step towards creating more inclusive workplaces. It's important to ensure that the AI driving the JAI is well-tested and validated to accurately assess accessibility and avoid perpetuating stereotypes or biases related to neurodiversity.

  Automated scraping, bulk downloading, or excessive searching of resumes is prohibited. If automated tools are used for candidate ranking, employers must be transparent about the key factors considered. Candidates may request details about how automated tools affect their placement.

• AI-Driven Resume Assistance: Automated Resume Optimization. This feature uses AI to help candidates optimize their resumes. While this can be beneficial, it's important to be transparent about how the AI assists with optimization and to ensure that it doesn't inadvertently disadvantage candidates who may not have access to or be familiar with such tools. It's also crucial that the AI doesn't promote a narrow definition of what constitutes a "good" resume, potentially overlooking qualified candidates with diverse backgrounds and experiences.

You have the right to request a human review of any decision made through automated means. To exercise this right, please email us at privacy@rangam.com with the subject line "AI AUTOMATED DECISION REVIEW."

Accessibility Commitment

We conduct accessibility reviews of our platform at least annually against recognized standards such as WCAG and Section 508 of the Rehabilitation Act. Independent third-party audits are performed, and results are available upon request.

We understand the importance of safeguarding your personal information. We take reasonable administrative, technical, and physical measures to protect it against unauthorized access, use, or disclosure, consistent with U.S. privacy and security laws.

• Hosting and Data Location
  • Our primary hosting infrastructure is located on Amazon Web Services (AWS) in the United States.
  • If you access our services from outside the U.S., please note that your information will be transferred to and maintained in the United States, where privacy laws may differ from those in your country of residence.
• Security Measures

  We use industry-standard practices to protect your information, including:

  • Encryption: Personal data is encrypted both in transit (using TLS) and at rest.
  • Access Controls: We implement strict access restrictions, role-based permissions, and multi-factor authentication to ensure that only authorized personnel may access personal data.
  • Monitoring & Detection: We employ automated monitoring tools to detect suspicious activity, prevent fraud, and reduce security risks.
  • Regular Testing: Our systems undergo routine vulnerability testing, penetration testing, and independent security assessments.

  Applicant Tracking System (ATS)

  Candidate information is stored in a secure SQL-based Applicant Tracking System (ATS). The ATS is encrypted at rest and in transit, subject to access logging, and supported by disaster recovery measures with defined recovery point objectives (RPO) and recovery time objectives (RTO). Candidate records follow retention schedules, and individuals may request deletion through their account or by contacting us directly

• Incident Response
  • If we identify a data incident that results in unauthorized access to personal information, we will investigate promptly and take corrective action. Where required, we will notify affected individuals and regulators without unreasonable delay, generally within 30 to 45 days, in accordance with U.S. state data breach notification laws.
• Data Retention For details, please see our Data Retention Schedule (Annex A), which sets out specific categories and timeframes.
• Secure Disposal and De-Identification
  • When data is deleted, we use secure methods such as permanent deletion from our systems.
  • In some cases, we de-identify information (removing direct identifiers) so that it may be used for internal research, analytics, and service improvements without compromising your privacy.
• Compliance with U.S. Standards
  • Our security program is designed in line with industry frameworks and guidance from U.S. authorities, including the Federal Trade Commission (FTC) and the National Institute of Standards and Technology (NIST).
  • While no system is 100% secure, we continuously review and enhance our safeguards to adapt to emerging threats.

How We Use Cookies: Empowering Your Choices

We utilize cookies and similar tracking technologies to enhance your experience and provide essential functionalities. These technologies help us in the following ways:

• Essential Functionality: These cookies are crucial for the basic operation of our services, enabling features such as authentication, security measures, and site navigation. Without these cookies, certain parts of our service may not function correctly.
• Analytics & Performance: We use cookies to gather insights into user behaviour and how our services are being used. This information helps us to improve performance, understand user preferences, and optimize our platform.
• Personalization: Cookies allow us to remember your preferences, such as language settings and region, and to tailor content and advertisements to better suit your interests.
• Google Tag Manager and Similar Technologies: We use Google Tag Manager (“GTM”) and comparable tools to help manage the scripts, analytics, and marketing tags used on our website. GTM itself does not collect personal information, but it enables other tags that may set cookies, pixels, or scripts on your device. Some of these tags may support analytics, performance tracking, or marketing. Under the California Privacy Rights Act (CPRA) and similar state privacy laws, the use of certain tags may be considered a “sale” or “sharing” of personal information. You can manage or disable analytics and marketing cookies, including GTM-triggered tags, at any time through our Cookie Management Page or by visiting our Do Not Sell or Share My Personal Information page.

Your Rights and Control:

We are committed to respecting your privacy and empowering you to manage your cookie preferences. You have the right to control which cookies are used.

• Cookie Management Page: You can manage your cookie settings and preferences at any time through our dedicated Cookie Management Page. This page provides you with granular control over the different types of cookies we use.
• Global Privacy Standards: We comply with applicable US privacy laws, including the California Consumer Privacy Act (CCPA/CPRA) and other US state laws governing targeted advertising and data sharing.
• Transparency: We aim to be transparent about our use of cookies and the information we collect. This policy provides you with a clear overview, and our Cookie Management Page offers further details.

By using our services, you consent to the use of cookies as described in this policy. However, you can withdraw or modify your consent at any time through our Cookie Management Page.

You may also exercise your right to opt-out of cross-context behavioral advertising by visiting our Do Not Sell or Share My Personal Information page.

Rangam reviews and updates this Privacy Policy at least once every 12 months, or as needed, to reflect changes in legal or operational requirements.

We recommend that you periodically review this policy to stay informed about our data practice.

If you have any inquiries regarding this Privacy Policy or wish to exercise your data protection rights, please contact our Privacy Officer or privacy team via:

• Email: privacy@rangam.com
• Phone: 908-704-8843
• Mail: 270 Davidson Avenue, Suite 103, Somerset, NJ 08873

By using our services, you acknowledge that you have read and understood this Privacy Policy and agree to our data processing practices.

Data Retention Schedule