1. WHO WE ARE

We are Evingar, Inc., doing business as SpamRight ("SpamRight," "we," "us," or "our"), a company registered in Colorado, United States. We operate the website https://www.spamright.com and related services (the "Services").

This Privacy Policy explains how we collect, use, share, and protect personal information. It applies to Job Seekers, Talent Seekers, and visitors to our website.

For the purposes of applicable data protection laws, SpamRight is the controller of the personal information described here.

2. INFORMATION WE COLLECT

From Job Seekers (candidates):

• Identity and contact details: name, email address, phone number, LinkedIn profile URL

• Location: country, state/region, and postal/zip code

• Professional information: work experience, platforms, skills, certifications, project roles, industries, products, and related experience

• Preferences: employment type, availability, work-location preferences, minimum salary or hourly rate, willingness to relocate or travel

• Eligibility information: visa/work-authorization status

• Verification signals: LinkedIn identity verification status

From Talent Seekers (hiring companies):

• Identity and contact details: name, email address, and company information

• Hiring criteria: the search parameters and requirements you enter

• Account and usage information: searches run, candidates viewed, and unlock requests made

From all users and visitors:

• Payment information (Talent Seekers): processed by our payment provider (see Section 8). We do not store full card numbers.

• Technical and usage data: information collected automatically when you use the website, such as device and browser information and interactions with the site (see Section 13, Cookies).

• Communications: information you provide when you contact us.

3. HOW WE COLLECT INFORMATION

• Directly from you, through our forms, your profile submissions, and your communications with us

• Automatically, through cookies and similar technologies when you use our website

• From our payment provider, which confirms payment status to us

• From LinkedIn, limited to confirming identity-verification status where applicable

4. HOW WE USE INFORMATION

We use personal information to:

• Provide, operate, and maintain the Services

• Review and approve Job Seeker and Talent Seeker applications

• Match Job Seekers to Talent Seeker searches

• Make Job Seeker profiles available to Talent Seekers (see Section 6)

• Facilitate unlock requests and contact exchange

• Process payments and manage credits

• Communicate with you about your account, requests, and the Services

• Improve and secure the Services and prevent misuse

• Comply with legal obligations

5. LEGAL BASES FOR PROCESSING

Where required by law, we rely on the following bases: performance of our agreement with you (to provide the Services); your consent (for example, when you submit a profile to be shown to Talent Seekers, or for certain cookies); our legitimate interests (to operate, secure, and improve the Services); and compliance with legal obligations.

You may withdraw consent at any time by contacting us or requesting deletion of your information.

6. HOW WE SHARE INFORMATION

With Talent Seekers (core to the Service). SpamRight is a talent marketplace. By submitting a Job Seeker profile, you understand and agree that your profile information will be made available to Talent Seekers for the purpose of evaluating you for opportunities. Your direct contact details are shared with a specific Talent Seeker only when you accept that Talent Seeker's unlock request. If you do not want your information shown to Talent Seekers, do not submit a Job Seeker profile, or contact us to remove it.

With service providers (sub-processors). We share information with third-party vendors who process data on our behalf to run the platform. See Section 7.

For legal reasons. We may disclose information where required by law, to enforce our terms, or to protect the rights, safety, and security of our users or the platform.

In a business transfer. If SpamRight is involved in a merger, acquisition, or sale of assets, information may be transferred as part of that transaction, subject to this Policy.

We do not sell your personal information for money.

7. THIRD-PARTY SERVICE PROVIDERS

We rely on the following categories of trusted providers, each of which processes personal information on our behalf and under agreement with us:

• Website hosting: Squarespace

• Forms and data capture: Fillout

• Database: Airtable

• Client portal: Softr

• Automation: Make

• Payments: Stripe

• Email and productivity: Google Workspace

This list may change as our tools evolve. Each provider is authorized to use personal information only as needed to perform services for us.

8. PAYMENTS

Talent Seeker payments are processed by Stripe. When you make a purchase, your payment details are provided directly to and handled by Stripe under its own terms and privacy policy. SpamRight does not receive or store your full payment card details. We receive confirmation of payment and limited billing information needed to manage your account and credits.

9. DATA RETENTION

We keep personal information for as long as your account is active or as needed to provide the Services, and afterward as needed to comply with our legal obligations, resolve disputes, and enforce our agreements. [Decision: set a default, e.g. "We retain profile information until you request deletion, and for up to [12] months after an account becomes inactive."] Certain records (such as transaction records held by our payment provider) may be retained for longer where required by law.

You may request deletion of your information as described in Section 10.

10. YOUR PRIVACY RIGHTS

Depending on where you live, you may have the right to:

• Access the personal information we hold about you

• Correct inaccurate information

• Delete your information

• Receive a copy of your information in a portable format

• Object to or restrict certain processing

• Opt out of the sale or sharing of personal information (note: we do not sell personal information for money)

• Withdraw consent where processing is based on consent

To exercise any of these rights, email hello@spamright.com. We will respond within the timeframe required by applicable law. We will not discriminate against you for exercising your rights.

If you are a Job Seeker, you can update most of your information directly through your profile form; deletion requests can be sent to the email above.

[Decision for legal review: confirm which laws apply to your user base — e.g., the Colorado Privacy Act, the California Consumer Privacy Act (CCPA/CPRA), Canada's PIPEDA now that you accept Canadian users, and the GDPR if you have EU users — and add any law-specific disclosures they require.]

11. DATA SECURITY

We take reasonable technical and organizational measures to protect personal information, and we rely on the security controls of our service providers. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12. INTERNATIONAL USERS AND DATA TRANSFERS

SpamRight is operated from the United States, and our service providers may store and process information in the United States and other countries. If you access the Services from outside the United States, you understand that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country.

13. COOKIES AND TRACKING

Our website uses cookies and similar technologies to operate the site, remember preferences, and understand how the site is used. [Decision: confirm what analytics/cookies your Squarespace site actually uses, and whether you need a cookie consent banner — you likely do if you serve EU or Canadian visitors. Describe them here, and link a cookie banner tool if used.] You can control cookies through your browser settings.

14. CHILDREN'S PRIVACY

The Services are intended for adults using the platform for professional purposes and are not directed to children. We do not knowingly collect personal information from anyone under the age of 16. If you believe a child has provided us information, contact us and we will delete it.

15. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above. Your continued use of the Services after changes take effect constitutes acceptance of the updated Policy.

16. CONTACT US

For any questions or to exercise your privacy rights:

Evingar, Inc. (dba SpamRight) Email: hello@spamright.com