Privacy Policy

1. Interpretation and Definitions

Interpretation

Words with capitalized initial letters have meanings defined below. These definitions apply whether the terms appear in singular or plural form.

Definitions

• Account means a unique account created for you to access our Service or parts of our Service.
• Affiliate means any entity that directly or indirectly controls, is controlled by, or is under common control with the Company.
• Company refers to Xenspire Group Inc, 11 Apex Dr, Suite 300, Marlborough, MA 01752, United States.
• Cookies are small files placed on your device to enable website functionality and analytics.
• Country refers to the United States.
• Device means any device that can access the Service, such as a computer, mobile phone, or tablet.
• Personal Data means any information that identifies or relates to an identifiable individual.
• Service refers to our website and related services.
• Service Provider means third parties who process data on our behalf to help deliver the Service.
• Usage Data means data collected automatically when using the Service.
• Website refers to www.xenspire.com.
• You means the individual or legal entity using the Service.

2. Information We Collect

Personal Data

We may collect the following categories of Personal Data:

• First and last name
• Email address
• Phone number (including mobile number for SMS communications)
• Company name, job title, and professional information
• Account credentials
• Communications with us

Usage Data

Usage Data may include:

• IP address
• Browser type and version
• Pages visited, time spent, and referring URLs
• Device identifiers and operating system

Cookies and Tracking Technologies

We use Cookies and similar technologies to:

• Enable essential website functionality
• Analyze usage and performance
• Improve user experience

You may control Cookies through your browser settings. Disabling Cookies may affect some functionality.

3. How We Use Your Information

We use Personal Data for the following purposes:

• To provide, operate, and maintain the Service
• To create and manage Accounts
• To communicate with you, including email and SMS (with consent where required)
• To support recruiting, hiring, talent matching, and business services
• To improve, analyze, and optimize our products and platforms
• To ensure security, prevent fraud, and enforce policies
• To comply with legal and regulatory obligations

4. Legal Basis for Processing

We process Personal Data based on one or more of the following legal grounds:

• Consent – when you provide explicit permission
• Contractual necessity – to perform services you request
• Legal obligations – to comply with laws and regulations
• Legitimate business interests – provided they do not override your rights

5. SMS Communications & Consent

By providing your mobile number, you consent to receive SMS messages related to our services. Message frequency may vary. Message and data rates may apply.

Opt-Out

You may opt out at any time by replying STOP to any SMS message or contacting us directly.

6. Data Sharing and Disclosure

We do not sell your Personal Data.

We may share data only in the following circumstances:

• With Service Providers who process data on our behalf under confidentiality obligations
• With Affiliates for internal business operations
• To comply with legal obligations, court orders, or lawful requests
• To protect the rights, safety, and security of the Company or users

7. Data Security

We implement reasonable administrative, technical, and organizational safeguards, including:

• Encryption of sensitive data
• Access controls and role-based permissions
• Regular security reviews and audits

However, no system is 100% secure, and we cannot guarantee absolute security.

8. Data Retention

We retain Personal Data only as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required by law or for legitimate business needs (e.g., compliance, dispute resolution).

9. Your Privacy Rights

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

• Access your Personal Data
• Correct inaccurate data
• Request deletion of data
• Restrict or object to processing
• Withdraw consent at any time
• Request data portability

To exercise your rights, contact us using the details in the Contact Information section.

10. California Privacy Rights (CCPA / CPRA)

If you are a California resident, you have additional rights, including:

• The right to know what Personal Data we collect and why
• The right to request deletion of your data
• The right to opt out of the sale or sharing of Personal Data (we do not sell data)
• The right to non-discrimination for exercising privacy rights

Requests may be submitted via email or phone. We may verify your identity before responding.

11. Children’s Privacy

Our Service is not intended for individuals under the age of 13. We do not knowingly collect Personal Data from children. If you believe a child has provided us data, please contact us to have it removed.

12. International Data Transfers

Your information may be processed and stored in the United States or other locations where our Service Providers operate. We take reasonable steps to ensure appropriate safeguards are in place.

13. Data Breach Notification

In the event of a data breach involving Personal Data, we will notify affected individuals and authorities as required by applicable law.

14. Changes to This Privacy Policy

We may update this Privacy Policy periodically. Updates will be posted on this page with a revised “Last updated” date. Continued use of the Service constitutes acceptance of the updated policy.