Privacy Policy

Last updated: December 24, 2025

This Privacy Policy explains how Subtribe ("Subtribe", "we", "our", or "us") collects, uses, discloses, and protects personal data when individuals use our applicant tracking and AI-powered hiring platform (the "Platform"). By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy.

If you do not agree with this Privacy Policy, please do not use the Platform.

1. Who We Are and Scope

Subtribe provides software-as-a-service (SaaS) tools that help employers manage recruitment, including receiving, screening, and processing job applications.

  • For most recruitment activities, Subtribe acts as a data processor / data processor-equivalent processing personal data on behalf of the employer (the "Employer"), who is the primary data controller / data fiduciary.
  • In some cases (for example, account management, security, analytics, billing, product improvement), Subtribe may act as an independent data controller / data fiduciary.

This Privacy Policy applies to:

  • Job applicants and candidates using the Platform.
  • Employer users and other business contacts who interact with us.

Employers may have their own privacy notices. Those notices govern their use of your data outside of our Platform.

2. Personal Data We Collect

We collect the following categories of personal data, depending on how you interact with the Platform.

2.1 Data You Provide Directly

When you apply for a job or create a profile, you may provide:

  • Identification and contact details: full name, email address, phone number, city/country.
  • Professional and educational information: resume/CV, work history, education, skills, certifications.
  • Professional links: LinkedIn, GitHub, portfolio and similar URLs.
  • Application-related information: answers to screening questions, cover letters, assessments, preferences, and any documents you upload.
  • Compensation and availability details: current and expected salary, notice period, preferred start date.
  • Communication content: messages exchanged via the Platform, interview scheduling information, and feedback shared through the Platform.

Do not submit information that is not requested or that is unrelated to your application (for example, highly sensitive personal information), unless required by law or the Employer and explicitly requested.

2.2 Automatically Collected Data

When you access the Platform, we automatically collect:

  • Device and log information: IP address, browser type and version, operating system, device identifiers, access times.
  • Usage information: pages viewed, actions taken, time spent, referrer URLs, clickstream data.
  • Technical identifiers: session identifiers, error logs, and diagnostic data.

2.3 Cookies and Similar Technologies

We use cookies and similar technologies (such as local storage, analytics tags, and pixels) to:

  • Maintain and secure your session.
  • Remember your preferences (for example, language).
  • Understand how the Platform is used, to improve performance and features.
  • Support analytics and product usage metrics.

You can control cookies through your browser settings and, where applicable, via cookie banners or preference tools. Essential cookies may be required for the Platform to function.

3. How We Use Personal Data

We use personal data for the following purposes:

  • Providing our services: Processing job applications and enabling recruitment activities.
  • Communication: Sending notifications and messages related to your use of the Platform.
  • Platform features: Operating tools that assist Employers in the recruitment process. Employers remain responsible for their final hiring decisions.
  • Security and improvement: Maintaining platform security and improving our services.
  • Legal compliance: Meeting our legal obligations and protecting our rights.

Where required by law, we rely on one or more of the following legal bases to process your personal data: your consent, performance of a contract, compliance with legal obligations, or our legitimate interests. The specific legal basis may vary by jurisdiction.

4. Automated Processing and AI

Our Platform uses AI-powered tools to assist Employers in the recruitment process. These tools are designed to support, not replace, human decision-making. Employers remain responsible for all final hiring decisions.

4.1 How Our AI Works

  • The AI analyzes resumes against job requirements defined by the Employer
  • Candidates are ranked based on qualification match, with explanations provided for each ranking
  • We accept resume uploads in PDF and image formats (JPG, PNG) only

4.2 AI Learning and Personalization

The AI may learn from usage patterns and preferences to improve matching accuracy and platform services over time.

4.3 Decision-Making

We provide information to assist decision-making; hiring decisions remain with the Employer. If your local law grants you rights related to automated decision-making, you may exercise those rights as described in the "Your Rights and Choices" section.

5. When We Act for Employers

In the recruitment context, Subtribe processes personal data on behalf of the Employer. The Employer determines what data is collected and how it is used for their recruitment purposes.

You should review the Employer's privacy notice for details on how they use your personal data. To exercise certain rights where the Employer is the data controller/fiduciary, we may refer your request to the Employer.

6. Data Sharing and Transfers

We share personal data only as needed and with appropriate safeguards.

6.1 Sharing With Employers

When you apply for a job, your application data is made available to the relevant Employer. Their use of your data is governed by their own privacy policies.

6.2 Service Providers

We use trusted third-party service providers to operate our business. These providers process personal data under our instructions and are bound by contractual obligations to safeguard your data.

6.3 Legal, Compliance, and Business Transfers

We may disclose personal data:

  • Where required by law, regulation, legal process, or government request.
  • To protect the rights, property, or safety of Subtribe, our users, Employers, or the public.
  • In connection with a corporate transaction (for example, merger, acquisition, financing, or sale of assets), subject to appropriate confidentiality protections.

6.4 International Data Transfers

Personal data may be stored and processed in countries other than your own, including where our service providers or cloud infrastructure are located. We implement appropriate safeguards for such transfers (for example, contractual protections and technical/organizational measures) as required by applicable law.

7. Data Retention

We retain personal data for as long as necessary to fulfill the purposes described in this policy, or as required by law. Retention periods may vary based on the context and the Employer's requirements.

When personal data is no longer needed, we delete it or irreversibly anonymize it. We may use aggregated or anonymized data for analytics and service improvement.

8. Your Rights and Choices

Your rights depend on your jurisdiction and whether Subtribe or the Employer is acting as the data controller/fiduciary. Subject to applicable law, you may have the right to:

  • Access your personal data and receive information about how it is processed.
  • Rectify inaccurate or incomplete personal data.
  • Erase your personal data, or request restriction of processing, where applicable.
  • Object to certain processing (for example, direct marketing or certain profiling).
  • Data portability, to receive personal data in a structured, commonly used, machine-readable format where required by law.
  • Withdraw consent where processing is based on your consent, without affecting the lawfulness of processing before withdrawal.
  • Rights related to automated decision-making and profiling, if provided under local law.

To exercise your rights:

  • If your data is processed as part of a specific Employer's recruitment process, you may need to contact that Employer directly.
  • You can also contact us using the details in the "Contact and Grievance" section. Where we act as a processor, we will forward your request to the relevant Employer where appropriate.

We may need to verify your identity and may not be able to fulfill a request where we are prohibited from doing so by law or where it would adversely affect the rights of others.

9. India Privacy Notice (DPDP Act)

Where the India Digital Personal Data Protection Act, 2023 ("DPDP Act") applies, the Employer typically acts as the Data Fiduciary for recruitment activities, and Subtribe acts as a Data Processor on their behalf.

Personal data is processed based on your consent, performance of a contract, compliance with legal obligations, or other legitimate purposes permitted under applicable law.

You may withdraw consent at any time by contacting us or the Employer. Withdrawal of consent may affect your ability to participate in certain recruitment processes.

10. United States Privacy Notice

This section applies to residents of the United States, including California, Virginia, Colorado, Connecticut, and other states with comprehensive privacy laws.

We collect categories of personal information as described in Section 2 of this Policy, including identifiers, professional information, and internet activity data. We use this information for the purposes described in Section 3.

We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising.

Depending on your state, you may have the right to:

  • Access, delete, or correct your personal information.
  • Opt out of the sale or sharing of personal information.
  • Not be discriminated against for exercising your privacy rights.

To exercise these rights, contact us at contact@thesubtribe.com. You may also designate an authorized agent to submit requests on your behalf.

11. Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction.

No system can be completely secure. If we become aware of a data breach that poses a significant risk to your rights, we will notify affected parties and regulators as required by law.

12. Children's Privacy

The Platform is not intended for use by individuals under 16 years of age (or the age defined by local law in your jurisdiction). We do not knowingly collect personal data from children through the Platform. If you believe a child has provided personal data, please contact us so that we can take appropriate action.

13. Third-Party Links and External Services

The Platform may link to external websites or services (for example, Employer career pages, scheduling tools, or external assessment providers). This Privacy Policy does not apply to those external sites or services. Their privacy practices are governed by their own policies, which you should review.

14. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last updated" date at the top of this page and, where required by law, provide additional notice (for example, via email, in-app notification, or banners).

Your continued use of the Platform after any update constitutes your acknowledgement of the updated Privacy Policy.

15. Contact and Grievance

If you have questions about this Privacy Policy or our data practices, or wish to exercise your rights, you can contact us at:

15.1 Grievance Officer (India - DPDP Act)

For individuals in India, you may contact our designated grievance contact for privacy and data protection concerns:

We will endeavor to acknowledge and resolve grievances within the timelines prescribed by applicable law.

Where available under law, you may also have the right to escalate unresolved complaints to the relevant supervisory or data protection authority in your jurisdiction.