Privacy Policy

This policy explains how Seedglass, Inc. ("Seedglass", "we"; seedglass.com) handles personal information. It covers people with Seedglass accounts (customers and their users) and people whose professional details Seedglass holds (Candidates). Seedglass is a Delaware corporation and is responsible for the personal information described here, except where it acts for a customer, as set out below.

Who decides what

• "Candidate" means a person whose professional information Seedglass holds and whose background Seedglass's machine learning may identify as possibly matching the criteria of a customer's job. Being a Candidate does not make someone an applicant or a candidate for a job; that happens only if the customer, independently, decides to pursue them.
• What Seedglass does. We take job descriptions provided by our customers and use machine learning to identify people whose background may match the criteria for each job. We then present potential fits to customers, along with custom-written outreach messages. A person at the customer approves each message, unless the customer has turned on autonomous sending for a role. Autonomous sending is off by default; turning it on is the customer's standing approval of the messages sent for that role. Customers decide whether to follow up with anyone who received a message. Seedglass does not take part in any way in the decision whether to start an interview process with someone contacted through Seedglass.
• Seedglass is not a recruiter and does not assess job applicants or applications. Our matching decides only whether a company is shown you as a potential fit, with a suggested message it can send, edit or discard. The company decides whether to contact you (by approving each message, or by turning on autonomous sending for a role) and whether to follow up; Seedglass takes no part in any decision to interview you. Seedglass makes no automated decisions that have legal or similarly significant effects on anyone.
• The company that contacted you decides who to contact, what to say and whether to send, and alone decides whether to pursue anyone for a job. Seedglass staff who help a company manage the service do so on its instruction, never make those decisions, and never send outreach. Messages are sent from that company's own email account or, where the company has chosen it, from an address Seedglass operates for that company; the message is the company's, and its footer names that company as the sender. That company has its own privacy policy, and you can stop its messages through the link in any message it sent you; that choice is separate from Seedglass's own commitments.
• Seedglass is an independent controller of its Candidate database ("Candidate Data"): sourcing, updating and matching.
• Seedglass's system sends the messages the company approves (or, where it has turned on autonomous sending for a role, the messages for that role) and sorts the replies. For that sending and sorting Seedglass acts on the company's instructions, as its processor. Drafting uses Candidate Data, for which Seedglass is the controller.

Information about customers and their users

We collect account details (name, work email, credentials) and product activity, and use them as a controller to provide, secure and improve the service, to bill, and to tell account owners about renewals, security incidents and changes to the service. Account details are needed to have an account. When someone who is not yet a customer submits a work email through our sign-up form, we use it to reply to that request and to follow up about the service, on the basis of our legitimate interest in answering business inquiries. They can ask us to stop at any time.

Information about Candidates

We hold professional information about Candidates, such as name, role, employer, professional history, public work and contact details. It comes from publicly available professional sources and from professional data services companies. We use it to connect Candidates with career opportunities at our customers, including recruiting outreach that our customers approve and send.

Why we process personal information

We process customer account information to provide the service under our agreement with the customer, and because we have a legitimate interest in running the service and keeping it secure. We process Candidate information because we and our customers have a legitimate interest in connecting professionals with relevant career opportunities, and Seedglass has a legitimate interest in providing and improving its matching services, creating aggregated or de-identified insights, and training machine learning models on the professional information it collects, to provide and improve our matching services. A new purpose is assessed, and this notice updated, before use. We have assessed these interests against your rights in a written legitimate-interests assessment. You can object at any time; an objection also removes your profile from training from then on. It cannot undo what models already trained have learned.

How replies are read, and what we learn from them

• We do not track opens or clicks. Messages sent through Seedglass carry no tracking pixels and their links are not rewritten, so neither Seedglass nor the sending company learns whether you opened a message or clicked a link. Using the unsubscribe link in a message records that choice; that is the only link whose use we record. Account emails that Seedglass sends to its customers and staff show our logo, loaded from our server, so opening one may leave an ordinary entry in our server logs.
• Replies to a customer's messages are read automatically so that the service can act on them: to record interest, a no, or a request to stop.
• Seedglass personnel do not read a customer's connected mailbox content except: (i) to provide support or keep the service running, limited to named personnel with production access and logged; (ii) to investigate or contain a security incident; (iii) where the customer has bought managed outreach, to help manage the service on its instruction (for example onboarding help and routing replies); (iv) at the customer's request for specific messages; or (v) as required by law. Seedglass personnel never send outreach, and do not edit or decline the customer's drafts, change a Candidate's status, or submit to the customer's applicant tracking system without the customer's explicit approval. Customer-approved support sessions, recorded in the customer's security log, will replace (i) once available.
• Seedglass trains its models on customer data, including what companies decide (their "outcomes"), other than connected-mail data, which is never used to train models, under the single training rule in our Terms of Service or the customer's Master Services Agreement: learning for that company, and learning across companies only where that company has chosen it, in aggregated form with differential privacy and other privacy-preserving techniques, never on message text, and never in a form that identifies a company or person. Differential privacy is a training method with a tracked privacy budget, not a guarantee.
• Data from connected email accounts is used only to provide the service to that customer and is never added to Seedglass's own records. We do not use Google Workspace API data to develop, improve or train generalized AI or machine learning models.
• The professional information Seedglass collects itself (Candidate Data, never customers' data and never mail) may be used to train and improve machine learning models to provide and improve our matching services, and to create aggregated or de-identified insights. We do not seek to collect special-category information, we do not use it to match people, and we do not use models to infer it. If we receive it incidentally (for example, in a resume), we do not use it for matching. We do not collect biometric identifiers.
• We send text only to paid AI APIs, which process it to provide the service. None of them may use it to train models. One also searches the public web to find a Candidate's professional contact details from their name, role and employer. Named providers are listed for customers on request under a confidentiality agreement.

Connected email accounts and Google user data

• Customers may connect an email account so that the messages they approve are sent from their own address, and so that replies reach them in Seedglass.
• Access is used only to send on the customer's instruction and to collect replies. The customer can revoke it at any time, in their email provider's security settings or in Seedglass.
• The text of replies and other inbound messages read from email (bodies, subjects, previews and reply summaries) is deleted 30 days after it is received; the record that a reply arrived, from whom, when and how it was classified is kept with the customer's data. Anything that comes from a customer's connected mailbox, such as a resume attached to a reply or a bounce, is that customer's data: it is used only to provide the service to that customer, is never added to Seedglass's own records, and is deleted with that customer's data. A bounce in a customer's mailbox prompts us to check that address ourselves; only the result of our own check (that the address no longer works) is kept in our records, and it stops all outreach to that address.
• Google user data is never used for advertising and never sold, and it is never transferred except as needed to provide the service, for security, or as the law requires.
• When a customer disconnects an account, Seedglass stops accessing the mailbox and deletes the stored access tokens for it. Stored message text from that mailbox is deleted with the customer's data, or earlier on request.
• The same commitments apply to every other connected email account.
• Seedglass's use of information received from Google APIs, and its transfer of that information to any other app, will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Security and security incidents

• We keep written security policies: data is encrypted in transit and at rest, staff access to production needs multi-factor sign-in and is reviewed quarterly, each customer's data is kept logically separate, backups are checked daily, and the service is penetration tested by an independent third party at least once a year.
• Examining a specific message is allowed only to investigate or contain a declared security incident. Access is limited to authorized staff and to what the incident needs, and the customer is told about it.
• If a security incident affects a customer's data, we tell that customer's account owner without undue delay after becoming aware of it and no later than 72 hours after confirming it, with updates at least every 24 hours until it is contained. Where the law requires it, we also tell the people affected and the authorities.

Service providers

• We use service providers to operate the service: cloud hosting (including storage, database and email delivery), AI models, payments, contact and company data, and search services. Some process data on our instructions; others are sources we query for public professional information.
• We do not publish the names of our service providers. Specific names are given to customers only on request, under a confidentiality agreement. Write to team@seedglass.com.

When Candidate information is shown to or sent to a customer

• Customers do not buy Candidate information. They pay for the service, and Seedglass does not give them its Candidate database or let them export it.
• A customer sees a Candidate's professional profile in Seedglass, for a role that customer is hiring for.
• When a customer advances a Candidate, at that customer's instruction and for its own hiring decision, Seedglass sends that one Candidate's name, email address, phone number and professional profile address to the customer's own applicant tracking system, together with the Candidate's resume if the customer has turned that on and one is on file. From then on, the customer holds that record under its own privacy policy.
• Nothing else leaves Seedglass for a customer, and no Candidate information is sent for any purpose other than that customer's hiring.

How long we keep information

• Customer account records are kept while the account is active, and afterwards for as long as legal, tax or accounting obligations require. A customer's own data (what its team adds, its outcomes and its connected-mail data) is deleted from our active systems within 30 days after its service ends, or after it exports it if later.
• Candidate records are kept only as long as they are needed for the purpose we hold them for: helping our customers find and reach people for their roles. We decide by these criteria:
  • whether the Candidate's professional profile is still relevant to roles our customers are hiring for, or are likely to hire for;
  • whether the Candidate has asked us to stop, to delete their information, or has objected;
  • whether we must keep information to meet a legal obligation, or to establish, exercise or defend a legal claim.

  We apply these criteria to Candidate profiles and delete profiles that no longer meet them.

• Reply text from a customer's connected mailbox is deleted 30 days after it is received, as described above.
• When we delete (on request, or because a record no longer meets the criteria), we remove it from our active systems within 30 days, and copies in encrypted backups are deleted as those backups expire in their normal cycle; until deleted, that data stays protected and is not used for anything else. Security logs are kept for 400 days.
• Exceptions:
  • information we must keep under a legal hold;
  • when you ask us to stop, we keep the email address or profile link you asked us to stop contacting, and the date, for as long as we need to honor it;
  • when you ask us to delete your information, we keep a keyed one-way code derived from your profile link or email address, for as long as we need to honor your request, so that our sourcing never adds you again; it cannot be read back without a key held by Seedglass's security owner;
  • when you ask one company to delete your information, we keep a keyed one-way code derived from your profile link or email address, for as long as we need to honor it, so that company's searches never add you again; other companies are not affected, and the code cannot be read back without a key held by Seedglass.
• You can remove yourself through the privacy request page.

Transfers

• Our systems are hosted in the United States, and our service providers may process data in the United States or in other countries where they operate.
• Transfers from the EU, UK and Switzerland rely on the European Commission's Standard Contractual Clauses (with the UK Addendum), not on the EU-US Data Privacy Framework. For a copy, write to team@seedglass.com.

Your choices

• Customers and their users can access, correct, delete, restrict and port their account information, and object to our use of it.
• Candidates can ask for a copy of what Seedglass holds about them, ask for it to be corrected, deleted or restricted, and object to our use of it, including to profiling: we use professional information to estimate how well someone's work fits a role. No score, grade or rank from these estimates is ever shown to customers or anyone else using Seedglass, and they are not used to make decisions with legal or similarly significant effects. (Portability applies to information processed under contract or consent; Candidate information is processed under legitimate interest.)
• To stop messages from a company that contacted you, use the link in its message. That company's own policy applies to its messages.
• To stop all contact through Seedglass, or to make any request about Seedglass's own records, use the privacy request page or write to team@seedglass.com. We verify a request by emailing a link that you must open to confirm it.
• We confirm receipt within 10 business days and respond to verified requests within 30 days, or sooner where the law where you live requires it. Where a law allows an extension (for example, two further months under the GDPR for complex requests), we will tell you within the first 30 days and explain why.
• If you are not satisfied with our answer, you can complain to the data protection authority where you live.

If we found your details

"We" here means Seedglass, Inc. (seedglass.com). If Seedglass holds your professional details, whether or not anyone has written to you, this policy is Seedglass's notice to you: what we hold, where it came from, why, and your rights, as set out above. We do not write separately to people we have not contacted, because doing so for everyone in our database would involve disproportionate effort (GDPR and UK GDPR Art. 14(5)(b)). Instead we publish this notice, and anyone can find out what we hold or remove themselves at any time through the privacy request page. Anyone we do contact is told at first contact. If a company contacted you, its own privacy policy applies to its messages, and you can stop them through the link in any message it sent.

Our representatives in the EU, UK and Switzerland

People in the European Union, the United Kingdom and Switzerland can also contact our representative there about how we handle their personal information:

• EU (GDPR Art. 27): Prighter EU Rep GmbH, Schellinggasse 3, 1010 Vienna, Austria.
• UK (UK GDPR Art. 27): Prighter Ltd, 20 Mortlake High Street, London, SW14 8JN, United Kingdom.
• Switzerland (FADP): Prighter CH GmbH, Obergrundstrasse 17, 6003 Luzern, Switzerland.

California residents

• What we collected in the last 12 months:
  • identifiers, such as name and email address;
  • professional or employment-related information;
  • commercial information, such as subscription records;
  • internet or other electronic network activity, such as product activity;
  • inferences drawn from professional information, such as how well a Candidate's work fits a role.
• Where it came from: customers, their use of the service, publicly available professional sources and professional data providers.
• What we use it for: to provide and secure the service, and to connect Candidates with career opportunities at our customers; to provide and improve our matching services, including training machine learning models for them; and to create de-identified insights. These are business purposes, not a sale or sharing. De-identified information is kept so that it cannot reasonably be linked to you, we commit not to re-identify it, and anyone we give it to must agree the same.
• Who we disclosed it to: each category, for a business purpose, to the service providers described above. Candidates' identifiers and professional information were shown to customers in Seedglass, and sent to a customer's own applicant tracking system when that customer advanced the Candidate for a role, as described above. Inferences stay inside Seedglass.
• Sale and sharing: Customers pay for the service, not for Candidate information. They cannot buy, keep or export Seedglass's Candidate database, and they receive one Candidate's details only when they advance that Candidate for their own hiring decision.
• Sensitive personal information: the only kind we collect is account login credentials, which we use only to provide the service.
• How long we keep it: each category for as long as the "How long we keep information" section says.
• Your rights:
  • You have the right to know what personal information we collect, use and disclose, to have it deleted, and to have it corrected.
  • We will not discriminate against you for using these rights.
• How to ask: use the privacy request page or email team@seedglass.com. We verify a request by emailing a link that you must open to confirm it. An authorized agent can make a request for you with your signed permission; we may ask you to confirm your identity with us directly.

Changes

If this policy changes materially, we will email each customer's account owner at least 30 days before the change takes effect. For everyone, we update the date above.

Contact

team@seedglass.com