Privacy Policy

Privacy Policy

Cleo HR

Last Updated: March 25, 2026

1. Introduction

CleoHR ("we," "us," or "our"), a product of SalaryX, Inc., is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and disclose information when you interact with our AI recruiting assistant ("Cleo") embedded on our clients' websites and when you use our platform at CleoHR.com (together, the "Services").

This Policy applies to candidates and other individuals who interact with Cleo or visit our websites. Our employer customers (the "Clients") are typically the primary controllers of candidate information, and we process that information on their behalf as a service provider, except where we act as a controller for our own business operations.

2. Information We Collect

When you provide your mobile number to Cleo HR via our AI Agent or website, you are opting in to receive transactional messages (such as identity verification codes and interview scheduling alerts). We collect the following categories of information, depending on how you use the Services:

• Direct interaction information: Information you provide during your conversation with Cleo, such as your name, email address, phone number, and any other contact details you choose to share.

• Professional information: Resume and CV details, job history, skills, education, application responses (including answers to screening questions), role preferences, location preferences, and other information relevant to a job application.

• Communications: Messages and content you send through Cleo or otherwise in connection with your application, including scheduling preferences and availability.

• Device and usage information: Standard log data such as IP address, browser type, operating system, the pages or screens you view, and the dates and times of your interactions, which we use to maintain security and functionality of the Services.

• Mobile messaging information: Your mobile phone number, message content, delivery status, and related metadata when you opt in to receive SMS messages.

We do not intend to collect sensitive personal information (such as health data, racial or ethnic origin, or union membership) through Cleo unless explicitly requested by a Client for a lawful recruiting purpose; if such information is requested, it will be clearly indicated and subject to additional protections as required by law.

3. Mobile Messaging (SMS / Text Message Communications)

If you choose to receive text messages from Cleo HR / SalaryX, Inc. or our Clients, the following terms apply:

• Consent: Mobile information is collected only after you provide express written consent through the Cleo interface or other clearly disclosed opt-in mechanism. Consent to receive SMS or text messages is not a condition of any purchase or use of our Services. By opting in, you consent to receive recurring automated text messages from or on behalf of Cleo HR / SalaryX, Inc.

• Purpose: We use SMS / text messages primarily to send transactional messages related to your application, such as interview reminders, status updates, identity verification codes, and other recruiting-related communications.

• Frequency and charges: Message frequency may vary based on your interactions and application activity. Message and data rates may apply, depending on your mobile carrier and plan.

• Opt-out: You may opt out of receiving text messages at any time by replying STOP to any message you receive from us. Upon sending STOP, you will receive a single confirmation message and no further SMS messages will be sent. You may also contact us at support@cleohr.com to request removal.

• Help: For assistance, reply HELP to any message. You may also contact us at support@cleohr.com or call +1 617 741 7901.

• Opt-in confirmation: After opting in, you will receive a confirmation message that includes the sender identity, message purpose, frequency disclosure, opt-out instructions, and a note that message and data rates may apply.

• No sharing for marketing: We do not share, sell, or rent your mobile phone number or SMS opt-in consent data with third parties or affiliates for their own marketing or promotional purposes. Mobile opt-in data and consent records are retained for a minimum of four (4) years as required by applicable law and carrier guidelines.

4. How We Use Your Information

We use the information we collect for the following purposes:

• Recruiting and service delivery: To enable and manage your job applications, communicate with you about opportunities, schedule interviews, and provide updates on your application status on behalf of our Clients.

• Service improvement and AI training: To operate, maintain, and improve Cleo and our Services, including training and refining our AI models so that they respond more accurately and effectively. Where possible, we use de-identified or aggregated information for these purposes and do not use it in a way that identifies you personally.

• Security and fraud prevention: To protect the security and integrity of our systems, prevent fraud or abuse, and detect and address technical issues.

• Legal compliance: To comply with applicable laws and regulations, enforce our agreements, and respond to lawful requests from authorities.

• Business operations: To perform analytics, reporting, and other internal business functions, such as understanding use of the Services and improving user experience.

Where required by law (for example, in certain jurisdictions), we rely on one or more legal bases to process your personal information, including your consent, the performance of a contract, compliance with legal obligations, and our legitimate interests in providing and improving the Services.

Mobile information will not be shared with third parties or affiliates for marketing or promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

5. Data Sharing

We share personal information in the following circumstances:

• With Clients (employers): We share your application and interaction data with the specific employer whose site you were visiting or whose opportunity you applied to when you interacted with Cleo. That employer will handle your information in accordance with its own privacy policy.

• Service providers: We share information with trusted third-party vendors who perform services on our behalf, such as cloud hosting, SMS gateways, analytics, and security providers. These providers are contractually required to use the information only to provide services to us and to protect it appropriately.

• Legal and safety: We may disclose information if we believe in good faith that it is necessary to comply with a legal obligation, protect the rights, property, or safety of SalaryX, our Clients, users, or the public, or to detect, prevent, or address fraud or security issues.

• Business transfers: In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business, personal information may be transferred as part of that transaction, subject to appropriate safeguards.

No Sharing of Mobile Information: Cleo HR does not sell or share your mobile phone number or SMS opt-in consent with any third parties or affiliates for marketing or promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, including to provide the Services to our Clients and candidates, comply with legal obligations, resolve disputes, and enforce our agreements.

Retention periods may vary depending on the nature of the information and our Clients' requirements. Where we process information on behalf of a Client, we generally retain it in accordance with that Client's instructions.

7. International Data Transfers

SalaryX, Inc. is based in the United States, and your information may be stored and processed in the United States and other countries where our service providers operate. These locations may have data protection laws that differ from those in your jurisdiction.

Where required, we implement appropriate safeguards (such as contractual protections) to help ensure that any international transfers of personal information are carried out in compliance with applicable laws.

8. Your Rights and Choices

Depending on where you live, you may have certain rights regarding your personal information, such as the right to:

• Access the personal information we hold about you.

• Request correction of inaccurate or incomplete information.

• Request deletion of your personal information, subject to certain exceptions.

• Object to or restrict certain processing activities.

• Withdraw consent where processing is based on your consent.

You can opt out at any time by replying STOP to any message. For assistance, reply HELP or contact us at support@cleohr.com. Message and data rates may apply.

In many cases, because we process your information on behalf of a Client, you may need to direct these requests to the relevant employer. You can also contact us using the details below, and we will help route your request where appropriate or respond as required by law.

You can opt out of marketing or non-essential communications at any time by following the unsubscribe instructions in those communications or contacting us.

9. Cookies and Tracking Technologies

Our websites and Cleo widget may use cookies and similar tracking technologies to operate the Services, remember your preferences, and understand how users interact with our content. Where required by law, we will obtain your consent before placing non-essential cookies on your device.

You can manage cookies through your browser settings and, where available, through on-site cookie preference tools.

10. Data Security

We implement industry-standard technical and organizational measures — such as encryption, access controls, and data minimization — to protect personal information from unauthorized access, use, or disclosure. However, no system can be guaranteed to be completely secure, and we cannot guarantee absolute security of your information.

11. Children's Privacy

Our Services are not directed to children under the age of 16, and we do not knowingly collect personal information from children under this age. If we learn that we have collected personal information from a child in violation of applicable law, we will take steps to delete it.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. When we make material changes, we will update the "Last Updated" date at the top of this Policy and may provide additional notice as required by law.

13. Contact Us

If you have questions or concerns about this Privacy Policy or our privacy practices, please contact us at:

SalaryX, Inc. Attn: Privacy Department Email: privacy@cleohr.com