Legal

Privacy Policy

How we collect, use, and protect your data on THE CAREER ASSEMBLY.

1. Controller

The data controller responsible for processing personal data is: The Career Circle LLC operating the platform under the brand THE CAREER ASSEMBLY 418 Broadway, Ste R Albany, NY 12207 United States Email: privacy@thecareerassembly.com

2. Scope of this Policy

This Privacy Policy applies to all users of the THE CAREER ASSEMBLY platform. We process personal data in accordance with:

  • General Data Protection Regulation (GDPR)
  • California Consumer Privacy Act (CCPA/CPRA)
  • Other applicable international data protection laws

3. Categories of Data Collected

3.1 Account Data

  • Email address
  • Full name (if provided)
  • Password (securely hashed)

3.2 Profile Data

  • Industry preference
  • Geographic region
  • Seniority level

3.3 Verification Data

  • Email verification status
  • Optional: LinkedIn profile (if provided voluntarily)
  • Optional: Social login data (Google, Apple)

3.4 Usage Data

  • IP address (pseudonymized)
  • Device and browser information
  • Platform interactions and session data

3.5 User Content

  • Reviews submitted by users
  • Ratings and feedback
  • Dispute reports and communications

3.6 Verification Proof Data

  • Documents or context submitted to verify a professional interaction
  • This data is used solely for validation and deleted after verification is completed

4. Purpose and Legal Basis of Processing

We process personal data for the following purposes:

4.1 Platform Operation

  • Account creation and authentication
  • Platform access and functionality

4.2 Security and Fraud Prevention

  • Prevention of fake accounts and coordinated manipulation
  • Detection of suspicious activity and platform abuse
  • Content moderation and policy enforcement

4.3 Verification of Users

  • Email verification
  • Optional LinkedIn or social login verification

4.4 Platform Integrity (Behavioral Signals)

  • Analysis of behavioral patterns for fraud detection
  • Calculation of internal trust scores for content ranking and moderation priority
  • These signals are processed under the legal basis of legitimate interest (Art. 6(1)(f) GDPR)

4.5 Platform Improvement

  • Analysis of aggregated usage patterns
  • Optimization of user experience

Legal basis: Art. 6(1)(b) GDPR (contract performance), Art. 6(1)(f) GDPR (legitimate interest — ensuring the integrity, trustworthiness, and security of the platform), and Art. 6(1)(a) GDPR (consent, where applicable).

5. Anonymous Reviews

All reviews are published anonymously. No personal data is publicly displayed. Internal linkage to user accounts is maintained for moderation, security, and legal compliance. This approach ensures:

  • Protection of user identity in public-facing content
  • Integrity of content through internal accountability
  • Compliance with data minimization principles (Art. 5(1)(c) GDPR)

6. Data Sharing

We do not sell personal data. Personal data may only be shared:

  • If required by law or valid legal process (e.g., court orders, subpoenas)
  • For legal enforcement or defense of legal claims
  • To protect platform integrity and the safety of users
  • With processors bound by Data Processing Agreements (see Section 7)

7. Processors (Art. 28 GDPR)

We use third-party service providers (processors) to operate the platform. These may include:

  • Hosting and infrastructure providers
  • Authentication service providers
  • Email service providers

All processors are contractually bound through Data Processing Agreements (DPAs) in accordance with Art. 28 GDPR.

8. International Data Transfers (Art. 44 GDPR)

Personal data may be transferred to countries outside the European Economic Area (EEA), including the United States. Where such transfers occur, we ensure appropriate safeguards:

  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • Additional technical and organizational measures where necessary
  • Assessment of the legal framework in the recipient country

9. Data Retention

We retain data only as long as necessary for the purposes outlined in this policy:

  • Account data: until account deletion is processed
  • Technical and security logs: typically 30–90 days
  • Reviews: may remain stored in anonymized form after account deletion
  • Verification proof data: deleted after the verification process is completed
  • Behavioral signal data: retained only as long as necessary for integrity purposes

Users may request deletion at any time in accordance with their rights under applicable law.

10. Rights of Data Subjects

Depending on your jurisdiction, you have specific rights regarding your personal data.

For EU/EEA Users (GDPR)

  • Access your data (Art. 15 GDPR)
  • Correct inaccurate data (Art. 16 GDPR)
  • Request deletion (Art. 17 GDPR)
  • Restrict processing (Art. 18 GDPR)
  • Data portability (Art. 20 GDPR)
  • Object to processing based on legitimate interest (Art. 21 GDPR)
  • Not be subject to automated decision-making with legal effects (Art. 22 GDPR)

For California Residents (CCPA/CPRA)

  • Know what personal data is collected and how it is used
  • Request deletion of personal data
  • Access and download your data
  • Opt out of data selling (we do not sell data)
  • Non-discrimination for exercising privacy rights

Requests can be submitted via: privacy@thecareerassembly.com. We aim to respond within 30 days. Account deletion: To delete your account, send an email to privacy@thecareerassembly.com with the subject "Delete Account". Our admin team will manually process your request and confirm deletion within 30 days.

11. Data Security

We implement appropriate technical and organizational measures, including:

  • Encryption of data in transit and at rest
  • Role-based access controls
  • Secure data storage with regular security assessments
  • Pseudonymization of personal data where feasible

However, no system can guarantee absolute security. We encourage users to maintain strong, unique passwords.

12. Provision of Data

Providing an email address is required to create an account. Without this, access to the platform is not possible. Additional profile information (industry, region, seniority) is voluntary.

13. Automated Decision-Making & Behavioral Signals

THE CAREER ASSEMBLY does not use automated decision-making that produces legal effects or similarly significant effects on users within the meaning of Art. 22 GDPR. The platform does use behavioral signals for the following purposes:

  • Fraud detection and prevention of platform manipulation
  • Calculation of internal trust scores for content ranking and moderation priority
  • Anomaly detection in user behavior patterns

These signals are processed under the legal basis of legitimate interest (Art. 6(1)(f) GDPR). They do not result in automated decisions that restrict user access or rights without human review.

14. Children's Privacy

The platform is not intended for individuals under 18 years of age. We do not knowingly collect personal data from minors. If we become aware that data has been collected from a minor, it will be deleted promptly.

15. Future Features

Future features (e.g. analytics, matching, premium services) may be introduced. Such features will only be implemented with:

  • Updated privacy information communicated to users
  • Additional consent where required by applicable law

16. Changes to this Policy

We may update this Privacy Policy from time to time to reflect changes in legal requirements, platform operations, or data processing practices. The current version will always be available on the platform. Material changes will be communicated to users.

17. Data Protection Officer

In accordance with Article 37 GDPR, we have appointed a Data Protection Officer (DPO) who is responsible for overseeing our data protection strategy and ensuring compliance. For all data protection inquiries, you can contact our DPO directly:

  • Email: dpo@thecareerassembly.com
  • Subject line: "Data Protection Inquiry"

We aim to respond to all data protection inquiries within 30 days.

18. Contact

For all privacy-related inquiries: privacy@thecareerassembly.com

19. Supervisory Authority (EU)

You have the right to lodge a complaint with a supervisory authority in your country of residence if you believe your personal data is being processed in violation of applicable data protection law.

20. Related Policies

This Privacy Policy should be read in conjunction with our other legal documents:

21. Effective Date

This Privacy Policy is effective as of April 8, 2026. Last updated: April 12, 2026