Privacy Policy

This privacy notice for The Well Recruiting Solutions Inc., a Delaware corporation ("The Well," "we," "us," or "our") describes how and why we collect, store, use, and share ("process") your information when you use our services ("Services"), such as when you visit our website at thewell.solutions, apply for a role, are referred to us, or are sourced by us as a candidate for our recruiting and talent-matching services, or engage with us in other related ways, including sales, marketing, phone calls, text messages, video interviews, or events.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have questions or concerns, please contact us at Email Us.

Summary of Key Points

• What personal information do we process? We process the professional and contact information you provide, information collected automatically when you use our website, and the content of interviews and conversations with us. Candidates are a primary focus of our Services.
• Do we create profiles or inferences? Yes. To match candidates with employers, we create candidate profiles and inferences about professional experience and working style, including with the help of AI. See "Use of Artificial Intelligence" below.
• Do we process biometric information? No. We analyze written interview transcripts. We do not collect voiceprints or facial scans.
• Do we process sensitive personal information? We do not seek out or intentionally collect the categories of sensitive personal information defined by law, such as government identifiers, precise geolocation, or information about health, race, or religion. Candidates and clients may nonetheless disclose it to us voluntarily, for example in a resume, an interview, or a recorded conversation, and where that happens we process it only as necessary to provide and improve the Services.
• Do we receive information from third parties? Yes. We receive information from third-party job boards and career sites, professional networking sites, national licensing and credentialing databases, licensed data and research providers, referrals, and from our clients in connection with a search.
• Do we use AI or automated decision-making? We use AI to assist our recruiters. A person reviews results and makes all submission decisions. You may request human review or ask us not to use AI to evaluate you.
• What are your rights? Depending on where you live, you may have rights to access, correct, or delete your information, and to limit automated processing.

Definitions

"Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. It includes any information that applicable law defines as "personal information," "personal data," "personally identifiable information," or "nonpublic personal information."

Personal Information does not include information that is: (a) lawfully made available from federal, state, or local government records, or that we have a reasonable basis to believe the individual has lawfully made available to the general public; or (b) deidentified or aggregated so that it can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual, and that we maintain and use only in deidentified form without attempting to reidentify it.

"Candidate" means an individual we identify, research, screen, contact, or introduce in connection with a role. "Client" means a company that engages us to fill one or more roles.

Our Role and Information We Receive from Clients

Our role. For Personal Information about candidates, The Well acts as an independent controller and, where the CCPA applies, as a "business." We determine the purposes and means of processing for our own recruiting purposes. We are not a "service provider," "processor," or "third party" acting on behalf of any client with respect to candidate Personal Information, and we do not process candidate Personal Information under client direction or instruction. When we disclose candidate Personal Information to a client, the client receives it as a separate and independent controller, responsible for its own handling of that information.

Information we receive from clients. We do not collect, receive, or process Personal Information about a client's customers, clients, end investors, advisors, or registered representatives, and we do not access client networks, systems, or applications. The Personal Information we receive from a client is limited to (a) business contact information for the client's personnel involved in a search, and (b) role-related information the client shares so that we can assess fit, which may include information describing an individual at the client, such as a hiring manager's or executive's responsibilities, working style, priorities, and expectations for the role.

Information about individuals in a business context. Information of the kind described in (b) above concerns individuals in their professional capacity, and we use it only to evaluate, prepare, and present candidates for the role. Some privacy laws treat information collected in a business-to-business or employment context differently from consumer information; where a law draws that distinction, we handle the information accordingly.

Information We Collect

Personal information you disclose to us. We collect personal information that you provide to us, or that you provide to third party job sites, career sites, or networking sites consistent with their policies. The personal information we collect may include names, phone numbers, mailing addresses, email addresses, job titles, resumes or resume-like details, professional experience, licenses and credentials, role and location preferences, and contact preferences.

Interview and conversation content. When you speak with us, including by phone, text message, or video interview, we may collect the content of those communications, including recordings and written transcripts created in connection with our recruiting business.

Recordings and transcripts. Where we have the consent required by applicable law, we record and transcribe certain calls and video meetings with candidates and clients. These recordings and transcripts may contain information about you and about other individuals discussed during the conversation.

Candidate profiles and inferences. To match candidates with employers, we create candidate profiles. These profiles include inferences we draw about professional experience and working style. Some of this analysis is performed with the help of AI, as described below in "Use of Artificial Intelligence." We analyze written transcripts. We do not create voiceprints or facial scans.

Information from third parties. We receive information about candidates from third-party job boards and career sites, professional networking and social media sites, national licensing and credentialing databases, licensed data and research providers, referrals, and from our clients, consistent with applicable law. We use this information to identify and evaluate potential candidates.

Information automatically collected. When you visit our website, we automatically collect certain technical information that does not reveal your specific identity, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, country, general location, and information about how and when you use our website. We collect this through server logs and through cookies and similar technologies. This information is used mainly to maintain the security and operation of our website and for internal analytics and reporting.

How We Process Your Information

We process your personal information for the following purposes:

• To provide recruiting and talent-matching services. We process your professional information to identify, evaluate, and match candidates with potential employers, including by using automated tools and AI in alignment with our AI Usage Policy. A member of our team reviews results and makes all submission decisions. Our tools assist; they do not decide.
• To communicate with you about opportunities, your candidacy, and our Services.
• To operate, improve, and secure our Services, including analytics, troubleshooting, and fraud prevention.
• For marketing and promotional purposes, where permitted, including measuring the effectiveness of our campaigns. You can opt out of marketing at any time.
• To comply with law and to establish, exercise, or defend legal claims.

We process your information only when we have a valid legal reason to do so, and, where required, with your consent.

Information Sharing

We may share personal information in the following situations:

• With client firms. As part of our recruiting Services, we share candidate information with prospective employers in connection with hiring needs, job postings, and potential placements, only with your explicit permission and only for the purpose of facilitating a specific career opportunity.
• With service providers. We share information with vendors who process information on our behalf under written contracts, such as cloud hosting, communications, analytics, and AI service providers. These providers are permitted to use the information only to provide services to us.
• For business transfers. We may share or transfer information in connection with a merger, financing, acquisition, or sale of assets.
• When required by law. We may share information with law enforcement or government agencies when required by law.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising in a manner that requires an opt-out under applicable law.

Candidate Confidentiality

We take candidate confidentiality seriously. We will never share your name, contact information, current employer, or any identifying information with a client firm without your explicit prior approval. All introductions are made only after you have reviewed the opportunity and given your consent to proceed.

Cookies and Tracking Technologies

Our website may use cookies and similar tracking technologies, such as web beacons and pixels, to collect and store information and enhance your experience. You can usually set your browser to remove or reject cookies. If you do, certain features of our website may be affected.

Use of Artificial Intelligence

We use AI to help our recruiters provide talent-matching services. Our tools help identify, summarize, and surface candidates whose experience and working style may fit a role, and they generate candidate profiles and inferences for this purpose.

How this affects your information. We do not train or fine-tune any embedding model, large language model, or other foundation model on Personal Information; we use those models only as fixed, pre-trained tools. We will use third-party artificial-intelligence tools only on service tiers or under contractual terms that prohibit the provider from using submitted information to train or improve the provider's generally available models. We do not sell Personal Information.

For more detail, see our How We Use AI in Recruiting page. To make a request, email Email Us.

Data Retention

We keep candidate and professional information for as long as it is necessary for the purposes set out in this notice, unless a longer retention period is required or permitted by law. Because recruiting relationships are long-term, we generally retain candidate records for up to seven (7) years after our last substantive contact with you, and retain engagement, billing, and placement records for as long as needed to administer and enforce our client agreements and to meet our tax, accounting, and legal obligations. Records related to automated decision processing are retained for at least four years to comply with applicable recordkeeping rules. You may request deletion at any time as described below.

When we have no ongoing legitimate business need to process your personal information, we will delete or anonymize it, or, if that is not possible because it is held in backup archives or subject to a legal hold, we will securely store and isolate it from any further processing until deletion is possible.

How We Keep Your Information Safe

We have implemented reasonable technical and organizational security measures designed to protect your personal information. However, no transmission over the internet or method of storage is completely secure, so we cannot guarantee absolute security. You should access our Services within a secure environment.

Children's Privacy

We do not knowingly collect data from or market to children under 18 years of age. If we learn that we have collected personal information from a person under 18, we will take reasonable steps to delete it. If you believe we may have collected such information, contact us at Email Us.

Your Rights

Depending on where you live, you may have some or all of the following rights:

• Access. You may request access to the personal information we hold about you.
• Correction of factual information. You may request that we correct inaccurate factual personal information, such as your job title, licenses, employment history, or contact details. When we correct factual information, any inferences our tools derive from it are updated accordingly. Assessments, inferences, scores, and categorizations generated by our matching tools reflect our analysis and are not factual data subject to correction, but if you disagree with how our tools have characterized you, you may request human review and provide additional context for a recruiter to consider.
• Deletion. You may request that we delete your personal information, subject to legal exceptions.
• Automated decision-making. You may request human review of any AI-assisted matching, and you may ask us not to use AI to evaluate you. See "Use of Artificial Intelligence" above.
• Withdraw consent. Where we rely on your consent, you may withdraw it at any time. This will not affect processing already carried out.
• Opt out of marketing. You may unsubscribe from marketing communications at any time using the link in our emails or by contacting us. We may still send you service-related messages.

If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you may complain to your local data protection authority. To exercise any right, contact us at Email Us. We will not discriminate against you for exercising your privacy rights.

Most browsers and some mobile systems include a Do-Not-Track feature. No uniform standard for recognizing these signals has been finalized, so we do not currently respond to them. If a standard is adopted, we will update this notice.

California Residents' Privacy Rights

If you are a California resident, you have specific rights regarding your personal information under the California Consumer Privacy Act, as amended.

Categories of personal information we have collected in the past twelve months:

• Identifiers, such as name, address, phone, email, and IP address
• California Customer Records categories, such as name, contact information, education, and employment history
• Internet or network activity, such as browsing and search activity on our website
• Geolocation data, such as device location
• Audio, electronic, or visual information, such as recordings and transcripts created in connection with our business
• Professional or employment-related information, such as work history and professional qualifications
• Inferences, such as a candidate profile summarizing professional preferences, experience, and working-style tendencies to support recruiting matches

We do not collect protected classification characteristics, commercial information, or biometric information. We do collect education details you share with us, such as degrees, institutions, and dates of attendance, but not student records maintained by a school, such as transcripts, grades, or disciplinary records. Our tools analyze written interview transcripts, not voiceprints or facial scans.

Automated decision-making. We use automated tools, including AI, to assist our recruiters in evaluating and ranking candidates. A person reviews results and makes all submission decisions. You may request human review, ask us not to use AI to evaluate you, and access or correct the factual information used, as described above under "Your Rights."

Sale or sharing. The Well has not sold personal information in the preceding twelve months and will not sell personal information in the future. We use personal information for our own business purposes, which is not considered a sale.

Your California rights include the right to know, the right to delete, the right to correct factual information, the right to non-discrimination, and the right to use an authorized agent. To exercise these rights, contact us at Email Us. We will verify your identity before acting on your request.

Other U.S. State Privacy Rights

A number of states, including Texas, Minnesota, Delaware, Virginia, Colorado, Connecticut, Utah, Oregon, and Montana, give their residents rights to confirm whether we process their personal information, to access and obtain a copy of it, to correct it, to delete it, and to opt out of targeted advertising, sale, and certain profiling. Several of these laws exclude information processed in an employment or business-to-business context; where an exclusion applies, these rights may not extend to that information.

To exercise any of these rights, email Email Us. We will take steps to verify your request and will respond within the period your state's law requires. If we decline your request, you may appeal by replying to our response; we will tell you the outcome of the appeal and, where applicable, how to contact your state attorney general.

Changes to This Notice

We may update this notice from time to time. The updated version will be indicated by an updated date and will be effective as soon as it is accessible. We recommend you check back from time to time in the event there are any updates which pertain to you.

Contact Us

If you have questions or comments about this notice, or would like to request access, correction, or deletion of the data we collect from you, please contact us:

The Well Recruiting Solutions
21501 N 78th Ave #100, Peoria, AZ 85382
Email Us
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