Effective Date: [September 1, 2025]
Version: V1.0
LEXIOM TECHNOLOGIES INC. ("Lexiom," "we," "us," or "our") prioritizes your privacy. This
Privacy Policy ("Policy") outlines how we collect, use, disclose, and protect the personal information
of users ("user," "you," "your") of our Lexiom product and related services (collectively, the
"Services"). The Services include: (i) searching for job seekers online based on your needs; (ii)
providing candidate information (including contact details and LinkedIn contact information); (iii)
generating AI-powered Email content and LinkedIn outreach content; and (iv) account management (e.g.,
email registration, LinkedIn/Gmail account binding).
Please read this Policy carefully before using the Services. By accessing or using the
Services, you acknowledge that you have read, understood, and agreed to the practices described
herein.
Lexiom operates the Services. For most personal information processed through the Services
(e.g., information collected for account registration, job seeker searches, and AI content generation),
where Lexiom determines the purpose and means of processing, Lexiom acts as a "data controller" (or
"business" under applicable laws such as the CCPA/CPRA).
If Lexiom processes personal information on behalf of third parties (e.g., sharing
candidate data with you as authorized), Lexiom acts as a "data processor" (or "service provider"). This
Policy primarily governs our activities as a data controller; processing activities as a data processor
are subject to separate agreements with relevant parties.
Personal information refers to any information (recorded electronically or otherwise) that
can identify a specific individual alone or in combination with other information. For the Services,
this includes:
●
Your information: Full name, professional role (role), company name, job title, email
address (used for account registration), LinkedIn account information (e.g., profile details, contact
permissions), and Gmail account information (e.g., sending permissions).
●
Candidate information: Job seekers’ full names, contact details (e.g., phone numbers,
emails), and LinkedIn contact information.
This excludes information that has been fully anonymized (i.e., information that can no
longer identify any individual, even when combined with other data).
Sensitive personal information is data that, if leaked or misused, could easily infringe on
an individual’s dignity or endanger their personal/property safety. This includes (but is not limited
to) biometric data, religious beliefs, medical records, financial account details, and information about
individuals under the age of 16. The Services do not intentionally collect or process sensitive personal
information, unless explicitly disclosed by you or required by law.
We collect Personal Information only for the purposes of providing and improving the
Services. Below is a detailed breakdown of collection purposes, types of information collected, and
intended uses:
|
No.
|
Collection Purpose
|
Types of Collected Personal Information
|
|
1
|
Account Registration & Login
|
Your email address (used as login credentials),
password (stored in encrypted form), full name (for account identification).
|
|
2
|
Binding Third-Party Accounts
(LinkedIn/Gmail)
|
LinkedIn account information (e.g., profile ID,
contact access permissions, connection data) and Gmail account information (e.g., email
sending permissions, draft access, and email content access). We read customer email
content to help users more efficiently identify candidates’ job-seeking intentions, and we
will comply with Google Gmail security requirements and applicable Google policies.
|
|
3
|
Providing Job Seeker Search Services
|
Your role, company name, and job title (to tailor
job seeker matching to your hiring needs); candidate information (full name, contact
details, LinkedIn contact information) (to deliver candidate lists to you).
|
|
4
|
AI-Generated Content (Email/LinkedIn
Outreach)
|
Your input (e.g., hiring requirements, candidate
background notes) and candidate information (to train and optimize AI for contextually
relevant content).
|
|
5
|
Customer Support & Service Improvement
|
Your contact details (email, phone number if
provided), communication history (e.g., support tickets, chat records), and feedback on the
Services.
|
We use the Personal Information described above to:
●
Provide, operate, and maintain the Services (e.g., verifying your account, enabling
LinkedIn/Gmail integration, delivering candidate search results).
●
Generate AI-powered content: Create personalized Email drafts and LinkedIn outreach
messages based on your needs and candidate profiles.
●
Read customer email content to help users more efficiently identify candidates’ job-seeking intentions and support recruitment communications, and we will handle such access in compliance with Google Gmail security requirements and applicable Google policies.
●
Improve the Services: Analyze user behavior (e.g., search preferences, content usage) to
optimize matching accuracy, AI performance, and user experience.
●
Communicate with you: Respond to your inquiries, send service updates (e.g., account
notifications, feature announcements), and provide customer support.
●
Ensure security: Protect the integrity of the Services, prevent unauthorized access to your
account, and detect/fight fraud or illegal activities.
●
Comply with legal obligations: Fulfill requirements under applicable data protection laws,
tax regulations, or legal processes.
We process your Personal Information based on the following legal grounds (as applicable to
your region):
We rely on the following under the GDPR/UK GDPR:
●
Performance of a contract: Processing is necessary to fulfill our agreement with you (e.g., providing job seeker
search services or AI content generation as requested).
●
Legal obligation: Processing is required to comply with laws (e.g., retaining records for tax or audit
purposes).
●
Legitimate interests: Processing is necessary to pursue our legitimate business interests, such as improving
the Services, ensuring security, or providing customer support—provided these interests do not override
your privacy rights.
●
Consent: Where required (e.g., binding LinkedIn/Gmail accounts), we process information only with
your explicit consent. You may withdraw this consent at any time (see Section 10).
Under the CCPA/CPRA, we process Personal Information to:
●
Perform a service requested by you (e.g., job seeker searches, AI content
generation).
●
Comply with legal obligations or protect our legal rights (e.g., responding to
subpoenas).
We process Personal Information in accordance with local laws (e.g., Singapore’s PDPA,
Australia’s Privacy Act):
●
With your consent (for optional activities like third-party account binding).
●
To fulfill contractual obligations (e.g., delivering the Services you
purchased).
●
For legitimate business purposes (e.g., service maintenance, fraud prevention).
We do not sell your Personal Information for monetary gain. We may share Personal
Information only in the following limited circumstances, and only with parties that commit to protecting
data security:
We engage trusted third-party vendors to assist with operating the Services. These
providers are contractually required to process data only as instructed by Lexiom and to implement
adequate security measures. Examples include:
●
Cloud hosting providers (to store your account data and candidate information
securely).
●
AI technology partners (to support the development and optimization of AI content
generation features).
●
LinkedIn and Google (to facilitate account binding and access permissions for
LinkedIn/Gmail integration—subject to their respective privacy policies).
In the event of a merger, acquisition, asset sale, or other corporate restructuring, your
Personal Information may be transferred to the acquiring entity. We will notify you of such a transfer
via email or a prominent notice on the Services, where required by law.
We may disclose Personal Information if required by law, regulation, legal process (e.g., a
subpoena), or governmental request. We may also disclose information to protect our rights, property, or
safety, or the rights, safety, or property of other users or third parties (e.g., responding to fraud or
harassment claims).
Lexiom is based in [Insert Lexiom’s Country of Operation, e.g., the United States]. Your
Personal Information may be processed in:
●
Lexiom’s operating jurisdictions.
●
Countries where our service providers are located (e.g., cloud servers in the EU,
Singapore, or the U.S.).
These countries may have different data protection laws. To ensure your data is protected
during cross-border transfers, we use the following lawful mechanisms:
●
For transfers from the EEA/UK/Switzerland to non-"adequate" countries: We rely on the
EU-U.S. Data Privacy Framework (DPF), UK Extension to the EU-U.S. DPF, Swiss-U.S. DPF (if Lexiom is
certified), or Standard Contractual Clauses (SCCs) approved by the European Commission or UK
ICO.
●
For transfers from other regions: We use adequacy decisions (e.g., EU adequacy for Japan,
Canada) or other locally recognized mechanisms.
We and our service providers use cookies, web beacons, and similar tracking technologies to
enhance the Services, analyze user behavior, and maintain account security. Below is a summary of key
technologies used:
|
No.
|
Technology Name
|
Purpose
|
Types of Personal Information Processed
|
Technology Provider
|
Contact Information for Provider
|
|
1
|
Essential Cookies
|
Enable account login, session management, and basic
service functionality (e.g., saving your search filters).
|
Your login status, session ID (encrypted), search
preferences.
|
Lexiom Technologies Inc.
|
mokahr.dev@gmail.com
|
|
2
|
Google Analytics
|
Analyze website/app traffic, user engagement (e.g.,
search frequency, AI content usage), and optimize service performance.
|
IP address (anonymized), device information (e.g.,
browser type, OS), browsing behavior (e.g., page visits).
|
Google LLC
|
https://support.google.com/analytics
|
|
3
|
LinkedIn Insight Tag
|
Facilitate LinkedIn account binding, track the
effectiveness of LinkedIn-related features (e.g., candidate outreach), and enable LinkedIn
profile matching.
|
IP address, LinkedIn user ID (if logged in), page
visit data.
|
LinkedIn Corporation
|
https://www.linkedin.com/help/linkedin/answer/65521
|
You may manage your cookie preferences at any time:
●
Through the cookie banner displayed when you first access the Services.
●
Via your browser settings (e.g., Chrome, Firefox, Safari) to block or delete cookies. Note
that disabling essential cookies may prevent you from using core features of the Services (e.g., account
login).
We implement technical, administrative, and physical measures to protect your Personal
Information from unauthorized access, disclosure, alteration, or destruction. These measures
include:
●
Encryption of data in transit (via TLS 1.2+) and at rest (via AES-256
encryption).
●
Access controls (e.g., role-based permissions, multi-factor authentication for admin
accounts).
●
Regular security audits and vulnerability assessments (conducted by third-party
experts).
No method of data transmission or storage is 100% secure. While we strive to protect your
data, we cannot guarantee absolute security. If a data breach occurs, we will notify you and relevant
authorities promptly (as required by law) and take corrective action.
We retain your Personal Information only for as long as necessary to fulfill the purposes
outlined in this Policy, unless a longer retention period is required or permitted by law (e.g., tax
records, legal disputes).
●
Your account information: Retained for 2 years after your account is deactivated (to comply with legal obligations
and resolve potential disputes).
●
Candidate information: Retained for 1 year after you last accessed the candidate list (or longer if you request
to archive it, subject to local laws).
●
AI training data: Your input and candidate information used for AI training are anonymized after 6 months
(to prevent identification of individuals).
Once retention periods expire, we securely delete or anonymize the Personal Information
(e.g., via permanent data wiping or encryption with unrecoverable keys).
Your privacy rights may vary based on your region, but we generally support the following
rights. To exercise these rights, please contact us at mokahr.dev@gmail.com (see Section 14 for full contact details). We will verify your identity (e.g., via a
confirmation email to your registered address) before processing your request, to protect your data from
unauthorized access.
●
Access: Request a copy of the Personal Information we hold about you (e.g., your account details,
candidate lists you’ve accessed).
●
Correction: Request correction of inaccurate or incomplete Personal Information (e.g., updating your
job title or company name).
●
Deletion: Request deletion of your Personal Information (e.g., closing your account and erasing
your data), subject to legal retention requirements.
●
Restriction: Request restriction of processing (e.g., pausing AI training using your data) if you
dispute the accuracy of the information or object to processing.
●
Data Portability: Request your Personal Information in a structured, machine-readable format (e.g., CSV
file of your account data) to transfer to another service provider.
●
Withdraw Consent: Withdraw consent for optional processing (e.g., unbinding your LinkedIn account). Note
that withdrawing consent may limit your ability to use certain features (e.g., AI-generated LinkedIn
outreach).
●
EEA/UK (GDPR/UK GDPR): You have the rights listed in Section 10.1. You may also lodge a complaint with your
local data protection authority (e.g., ICO in the UK, CNIL in France) if you are dissatisfied with our
response to your request.
●
California (CCPA/CPRA): As a "consumer," you have the rights in Section 10.1. You also have the right
to:
○
Opt out of "sharing" of your Personal Information for cross-context behavioral advertising
(Lexiom does not currently engage in this activity, but you may still request opt-out).
○
Not be discriminated against for exercising your privacy rights (e.g., we will not charge
you more or reduce service quality).
●
Singapore (PDPA): You have the right to access and correct your Personal Information. Withdrawing consent
may affect our ability to provide the Services (e.g., unbinding Gmail will prevent sending AI-generated
Emails).
●
Australia/New Zealand (Privacy Act/Privacy Act 2020): You have the right to access/correct your Personal Information and complain to the Office
of the Australian Information Commissioner (OAIC) or New Zealand’s Privacy Commissioner.
The Services are not intended for individuals under the age of 16. We do not knowingly
collect Personal Information from children under 16. If we become aware that we have collected Personal
Information from a child under 16, we will immediately cease processing and take steps to delete the
data. Parents or guardians who believe their child has provided information to us may contact us at
mokahr.dev@gmail.com to request deletion.
The Services may contain links to third-party websites or services (e.g., LinkedIn, Gmail,
or job boards). This Policy does not apply to these third parties. We are not responsible for the
privacy practices or content of third-party platforms. We encourage you to review the privacy policies
of any third parties you interact with through the Services.
We may update this Policy to reflect changes in our practices, legal requirements, or the
Services. When we make changes:
●
We will post the updated Policy on the Lexiom website (e.g.,
https://hire-r1-voyage.mokahr.com/privacy-policy.html
) and update the "Effective Date" at the top.
●
For material changes (e.g., new data collection purposes, changes to data sharing practices), we will
notify you via email (to your registered address) or a prominent notice on the Services at least 7 days
before the changes take effect (as required by law).
Your continued use of the Services after the effective date of the updated Policy
constitutes your acceptance of the changes. We encourage you to review this Policy
periodically.
If you have questions, concerns, or requests regarding this Policy or our privacy
practices, please contact us via:
●
Mailing Address: LEXIOM TECHNOLOGIES INC., []
●
Privacy Inquiries / Data Subject Requests: mokahr.dev@gmail.com
●
Security Issues: mokahr.dev@gmail.com
We aim to respond to all requests within the timeframe required by applicable law (e.g., 30
days under the CCPA/CPRA, 1 month under the GDPR).
Last Updated: [September 1, 2025]
Version: V1.0