Global Privacy Policy

Effective Date: [INSERT DATE]

Last Updated: [INSERT DATE]

Data Controller: Sphere Rocket VA USA LLC

Address: 11511 Luna Road, Suite 650, Dallas, Texas, USA

Website: https://sphererocketjobs.com

Privacy Contact: legal@sphererocket.com

1. Our Commitment to Privacy

Sphere Rocket VA USA LLC operates SphereRocketJobs.com, a global talent matching and recruitment technology platform.

We recognize the importance of protecting the personal information of individuals seeking professional opportunities through our Platform.

This Privacy Policy explains what information we collect, how we use it, when we disclose it, how we protect it, and how individuals may exercise their privacy rights.

Our Platform may serve Candidates located in the Philippines, Southeast Asia, Latin America, the United States, and other countries.

We seek to process personal information in accordance with applicable data protection requirements, including, where applicable, the Philippines Data Privacy Act of 2012, Brazil's Lei Geral de Proteção de Dados (LGPD), Mexico's Federal Law on Protection of Personal Data Held by Private Parties, Colombia's Law 1581 of 2012, and other applicable laws.

2. Categories of Information We Collect

We may collect the following categories of information, depending on how you use the Platform.

A. Account and Contact Information

• Name.
• Email address.
• Telephone number.
• Country and general location.
• Account credentials and authentication information.
• Preferred language and communication preferences.

B. Professional and Recruitment Information

• Resume or curriculum vitae.
• Employment history.
• Professional experience.
• Education and certifications.
• Technical skills.
• Work samples and portfolio information.
• Preferred job categories.
• Preferred compensation or rates.
• Availability and working preferences.
• Relevant software experience.
• Job applications and application history.

C. Interview and Assessment Information

• Video and audio interview recordings.
• Spoken and written interview responses.
• Interview transcripts.
• AI-generated summaries and assessments.
• Skills evaluation results.
• Relevant communication observations.
• Job-related screening and matching information.
• Candidate feedback and assessment corrections.

D. Technical Information

• IP addresses.
• Device and browser information.
• Account login history.
• Security and authentication events.
• Cookies and similar technologies.
• Platform activity and usage information.

E. Verification Information

Where reasonably necessary and legally permitted, we or authorized service providers may process identity-verification information, professional references, certifications, or other verification records.

Additional notices and authorizations will be provided where legally required.

We do not routinely require Candidates to submit sensitive personal information unrelated to recruitment. We ask Candidates not to include unnecessary medical, financial, religious, political, or other highly sensitive information in resumes or interview answers.

3. Purposes of Processing

We process information for the following purposes:

1. Creating and maintaining candidate accounts.

2. Enabling Candidates to apply for available opportunities.

3. Conducting interviews and assessments.

4. Generating candidate profiles, interview summaries, and screening information.

5. Recommending potentially relevant opportunities.

6. Sharing relevant profiles with authorized Hiring Organizations.

7. Facilitating communications and introductions.

8. Supporting legitimate recruitment and selection activities.

9. Protecting accounts and preventing fraud or misuse.

10. Responding to privacy requests and support inquiries.

11. Complying with legal obligations.

12. Maintaining and improving the security, reliability, accessibility, and performance of the Platform.

We will not use interview recordings to generate public promotional content or identifiable AI replicas of Candidates without a separate appropriate authorization.

We will not use identifiable Candidate recordings or application data to train third-party general-purpose AI models without first establishing and disclosing a valid legal basis and obtaining consent where required.

4. Legal Bases for Processing

Where applicable law requires an identified legal basis, we rely on one or more of the following, as appropriate:

• Performance of a contract or actions requested before entering a contract.
• Legitimate interests in operating a secure and effective recruitment platform, where permitted and not overridden by Candidate rights.
• Compliance with legal obligations.
• Specific, informed consent for processing activities where required.
• Other grounds expressly permitted by applicable law.

Different processing activities may rely on different legal bases.

Where consent is required, Candidates will be informed of the relevant purpose and provided an appropriate opportunity to accept, decline, or withdraw consent.

Withdrawal of consent does not invalidate processing lawfully performed before withdrawal.

5. AI Interview Technology

Sphere Rocket Jobs uses AI-assisted interviewing and recruitment technologies to support candidate assessment and matching.

When a Candidate participates in an AI interview, the system may record the session, transcribe responses, organize information, produce summaries, and generate assessments related to job-relevant criteria.

Automated processing may assess elements such as:

• Completeness and relevance of responses.
• Described professional experience.
• Job-specific technical knowledge.
• Problem-solving approaches.
• Communication of work-related information.
• Experience with relevant software and business tools.

AI assessments may be inaccurate or incomplete.

We seek to provide mechanisms for Candidates to request correction of inaccurate information and human review of decisions where applicable law requires it.

For independent third-party opportunities, Sphere Rocket's AI assessment is a screening aid, not the final hiring decision.

We do not intend to use facial recognition, voiceprints, or biometric identification as part of ordinary interview scoring. If biometric processing is introduced for verification or another purpose, we will provide additional disclosures and obtain required authorization before such processing begins.

6. Sharing Information with Hiring Organizations

Candidate profiles and relevant assessment information may be shared with participating Hiring Organizations for legitimate recruitment and matching purposes.

Information made available may include:

• Professional profile details.
• Work experience and qualifications.
• Submitted resumes and portfolios.
• Relevant interview recordings and transcripts.
• Skills assessments and AI-assisted summaries.
• Candidate availability and compensation preferences.

Hiring Organizations are expected to use Candidate information only for lawful recruitment and related purposes.

They must not sell Candidate information, use it for unrelated marketing without a valid legal basis, or disclose it to unauthorized parties.

Where a Hiring Organization independently determines the purposes and means of further processing, that organization may act as a separate data controller and must comply with its own privacy obligations.

7. Affiliated Companies and Service Providers

We may share information with companies under common ownership or control, authorized operational service providers, and technology vendors where reasonably necessary for disclosed Platform purposes.

These may include:

• Hosting and database providers.
• Video interviewing and recording services.
• AI transcription and assessment services.
• Security and identity verification vendors.
• Customer support service providers.
• Affiliated BPO or recruitment organizations acting in their identified roles.
• Authorized Hiring Organizations.

We seek to limit access to the information reasonably necessary for each recipient's function and use appropriate contractual confidentiality, security, and data protection safeguards.

8. International Data Processing and Transfers

Sphere Rocket operates from the United States while supporting Candidates and Hiring Organizations in multiple countries.

Candidate information may be accessed or processed by authorized personnel, Hiring Organizations, affiliates, and service providers located outside the Candidate's country of residence.

Such transfers may include processing in the United States or other locations specifically identified in our applicable international transfer disclosures.

Where required, international transfers will be supported by lawful mechanisms such as appropriate contractual safeguards, legally recognized transfer mechanisms, applicable exceptions, or other measures permitted under local data protection laws.

Candidates may contact our privacy team for information about the applicable transfer mechanisms and safeguards.

We will not represent that an international transfer is lawful solely because the Candidate has agreed to this Privacy Policy.

9. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, subject to applicable legal requirements.

Retention periods depend on the information involved, the status of the Candidate's account, the applicable recruitment process, legal obligations, and the need to protect legitimate rights.

We may periodically request that Candidates confirm their continued interest in maintaining an active recruitment profile.

Candidates may request deletion or deactivation of their information, subject to legal retention requirements and other lawful grounds for continued processing.

Where data must be retained for compliance or dispute purposes, we may restrict it from ordinary recruitment use until deletion becomes appropriate.

10. Privacy Rights

Depending on their jurisdiction and applicable law, Candidates may have rights to:

• Request information about the processing of their data.
• Access personal information held about them.
• Correct inaccurate or incomplete information.
• Request deletion or erasure.
• Object to certain processing.
• Withdraw consent where processing relies on consent.
• Restrict certain processing activities.
• Request portability of qualifying information.
• Request information about automated decision-making and profiling.
• Request review of qualifying automated decisions.
• File a complaint with an applicable data protection authority.

We will provide reasonable methods to submit privacy requests and will respond within applicable legal time limits.

Identity verification may be required before fulfilling a request involving personal information.

11. Rights of Candidates in the Philippines

Candidates located in the Philippines may have rights under Republic Act No. 10173, the Data Privacy Act of 2012, and its implementing rules and regulations.

These include applicable rights relating to information, access, correction, objection, erasure or blocking, data portability, and complaints.

Information about AI-assisted assessment and profiling will be disclosed as appropriate.

Candidates may submit requests through the Platform's privacy request process or contact the designated privacy representative.

They may also contact the National Privacy Commission regarding applicable complaints.

12. Rights of Candidates in Latin America

Candidates in Latin America may benefit from additional privacy rights depending on their country.

Brazil: Candidates may exercise applicable rights under the LGPD, including access, correction, deletion in qualifying circumstances, information about sharing, and review requests regarding qualifying decisions made solely through automated processing.

Mexico: Candidates may exercise applicable rights of access, rectification, cancellation, and opposition (ARCO), together with other applicable rights, under Mexico's personal data protection framework.

Colombia: Candidates may exercise applicable rights under Law 1581 of 2012, including rights to know, update, correct, and request deletion of personal data where appropriate, and to revoke authorization where permitted.

Other countries may provide additional protections, which will be respected where applicable.

Nothing in this Privacy Policy is intended to reduce mandatory protections under local law.

13. Data Security

We use or intend to implement appropriate technical and organizational measures designed to protect Candidate information against unauthorized access, alteration, disclosure, and loss.

These may include encrypted transmission, secure authentication, access restrictions, audit logging, role-based permissions, secure storage, vendor assessments, incident response procedures, and periodic access reviews.

No online service can guarantee absolute security.

Where a data breach triggers notification obligations, we will notify affected individuals and relevant authorities as required by applicable law.

14. Cookies and Analytics

The Platform may use necessary cookies for authentication, security, and essential functionality.

We may also use optional analytics or similar technologies to understand Platform performance and improve user experience.

Where required, Candidates will be provided appropriate notices and consent controls for nonessential cookies and tracking technologies.

15. Recruitment Communications

We may send Candidates service-related communications, including:

• Account verification messages.
• Interview invitations.
• Application status updates.
• Relevant job opportunity notifications.
• Security notices.
• Material policy updates.

Candidates may manage optional job notifications and marketing preferences where offered.

Operational or legally required account communications may continue while an account remains active or where otherwise legally permitted.

16. Children's Information

Sphere Rocket Jobs is intended for adults aged 18 or older.

We do not knowingly solicit applications from individuals under 18.

If we learn that a minor has submitted personal information without an applicable lawful basis, we will take appropriate action to restrict processing and address the information in accordance with applicable law.

17. Changes to This Privacy Policy

We may amend this Privacy Policy to reflect changes in law, technology, services, or data processing practices.

Material changes will be communicated through reasonable notice.

Where new consent is legally required, we will seek it before beginning the relevant processing.

Previous versions may be maintained for accountability and audit purposes.

18. Contact and Privacy Requests

Sphere Rocket VA USA LLC

11511 Luna Road, Suite 650

Dallas, Texas, USA

Privacy Contact: legal@sphererocket.com

Privacy Requests: https://sphererocketjobs.com/privacy-request

Website: https://sphererocketjobs.com

Where required by applicable law, additional information about local representatives, privacy officers, or international transfer safeguards will be provided through country-specific notices.