Privacy Policy

This Privacy Policy explains how CleoHR, Inc. ("CleoHR," "we," "us") collects, uses, discloses, and protects personal information when you use our websites and verified-hiring services (the "Services"). It applies to employers who use Cleo to hire and to candidates who apply through Cleo.

This page is a clear, good-faith template. Before you go live, have qualified legal counsel review and tailor it to your jurisdictions, data flows, and the consumer-reporting and biometric laws that apply to your business.

1. Information we collect

We collect information you provide directly, information generated as you use the Services, and information from third parties that help us verify identity and run background, drug, and work-authorization checks.

Account & contact data: name, work email, phone number, company, and role.
Candidate application data: the information a candidate submits to apply, including responses to screening questions.
Verification data: government-ID images, biometric data used for liveness and face match, background-check results, drug-screening results, and I-9 / E-Verify information, processed with appropriate consent.
Usage & device data: log data, device identifiers, and cookies used to operate and secure the Services.

2. How we use information

To provide, operate, and improve the Services, including screening and verification.
To produce a candidate-owned Work Passport credential and enable reuse with the candidate's consent.
To meet legal, regulatory, and compliance obligations (for example, FCRA, BIPA, and I-9 retention).
To secure the Services, prevent fraud, and communicate with you.

3. Consent for verification

Background checks, biometric verification, and drug screening are performed only with the disclosures and authorizations required by law. Where a background check is a "consumer report," we provide the applicable disclosures and obtain consent before the check, and we follow adverse-action procedures where required.

4. How we share information

We share personal information with the employer you are applying to, with service providers and consumer-reporting agencies that perform verification on our behalf, and as required by law. We do not sell personal information.

5. Data retention

We retain information for as long as needed to provide the Services and to comply with legal obligations (such as I-9 retention requirements), after which we delete or de-identify it.

6. Security

We use administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit and at rest, access controls, and monitoring. No method of transmission or storage is completely secure.

7. Your rights & choices

Depending on where you live, you may have rights to access, correct, delete, or port your personal information, and to withdraw consent. Candidates own their Work Passport and can request access at any time. To exercise a right, contact us using the details below.

8. Children's privacy

The Services are intended for people who are old enough to work lawfully and are not directed to children under 13.

9. Changes to this policy

We may update this policy from time to time. We will post the new version here and update the "Last updated" date above.

10. Contact us

Questions about this policy or your information? Reach us through our contact page. CleoHR is based in Boston, MA.