Privacy Policy

Last Modification: 07/15/25

Introduction

DOXA Talent, Inc. and its subsidiaries and affiliates (collectively, “DOXA” “we,” “our,” or “us”) are committed to safeguarding your privacy. “Personal Information” refers to information that may directly or indirectly identify you. “Sensitive Personal Information” is a subset of Personal Information, defined under applicable privacy laws, and includes data such as information about children, financial account information with access credentials, health information, Social Security or other national identification numbers, racial or ethnic origin, political opinions, religious beliefs, trade union membership, sex life, criminal convictions, biometric data, genetic information, and precise geolocation.

This Privacy Notice (“Notice”) is intended to help you understand how we collect, use, disclose, share, and safeguard your Personal Information and to explain the rights and choices available to you. If you have any questions, please contact us using the details provided under Contact Us below.

Accessibility

We are committed to ensuring this Notice is accessible to individuals with disabilities. If you wish to access this Notice in an alternative format, please contact us at [email protected].

About DOXA

DOXA helps businesses build highly skilled, dedicated nearshore and offshore teams. Our solution includes staffing and recruiting, talent advisory, workforce management and consulting, sales outsourcing, technology services, and managed delivery solution. Most of our sourced talent are employees of Doxa, where we offer them full benefits, flexible work-from-home options, and career growth opportunities. We source top-tier talent from around the world, including from the Philippines, Colombia, Vietnam, and Kenya.

For more about the specific services provided, please visit www.doxatalent.com (collectively, the “Services”).

When This Notice Applies

This Notice applies to Personal Information we collect both online and offline, including:

Through our websites, emails, apps, and related digital platforms that link to or reference this Notice (collectively, the “Sites”)
Over the phone; and
In person.

For example, this Notice applies to the following:

Visitors to the Sites
Customers and Clients who use our Services, including their representatives
Direct Employees
Consultants
Independent Contractors
Community platform users
Suppliers who provide products or services to us
Candidates
Prospects
Franchise owners and prospects
Participants of webinars, conferences, trade events, surveys, etc.

By using our Site and/or our Services as well as engaging with us in any way, you agree to the collection and use of your information in accordance with this Privacy Policy.

This Notice also applies when we receive services that you are providing to us. It does not apply to the privacy practices of third parties we do not own or control.

What Are Our Sources of Personal Information?

We collect Personal Information from the following sources:

Sources of Information	Examples of Collecting Through Specified Sources
Information you provide to us	Requesting our Services or other information Applying for a job Inquiring about and applying and operating franchises Participating in surveys or other promotional activities Providing testimonials Contacting us through any channel, including online, over the phone, or in person. Subscribing to our emails, newsletters, or other materials
Information collected automatically	Contacting us through any channel, including online, over the phone, or in person. Subscribing to our emails, newsletters, or other materials
Information received from other parties	Job boards and professional networks (e.g. LinkedIn, AmpleMarket, Belkins) Social media platforms (e.g. WhatsApp) Customers (e.g. provides Personal Information for Services) Companies, business partners, or individuals that introduce you to us Third party job boards Business intelligence sources, such as data aggregators Referrals, such as from brokers, franchisees, and other individuals and companies who refer you to us Trade journals and industry news sources Trade shows Public databases, such as government filings DOXA subsidiaries, companies owned by, owning, or under common control with DOXA), and affiliates (e.g. partners, advisors, franchisees) Business partners and service providers who help us provide, improve, promote, and protect our Services (e.g. sub-contractors, advertising networks, analytics providers, search information providers, fraud protection services, payment service providers, customer relationship management (“CRM”) providers, human resource management providers) Providers that help prevent detect, and prosecute unlawful acts, money laundering, and fraudulent behavior Governments, law enforcement agencies, authorities, and regulatory bodies

If you provide Personal Information to a third party, it will be subject to that party’s privacy policy. Our use of such information will be governed by this Notice.

What Types of Personal Information Do We Collect?

We may collect the following categories of Personal Information:

Categories	Examples
Contact Information	Name, email, phone number, postal address, and emergency contacts or references you provide
Identifying Information	Photo (if provided or publicly available), passports, social security numbers, government issued identification, work eligibility documents, date of birth
Educational and Professional Background	Employment and education history, licenses (e.g., bar number), certifications, language skills, security clearances, practice details, professional associations, references, volunteer activities, and background checks
Other Career Placement Information	Resume/CV, skills, cover letters, applications, questionnaires, behavioral tests, personality traits
Career Planning Information	Job interests, compensation history, desired compensation and benefits, work location preferences, willingness to relocate, family circumstances relevant to career planning, hobbies, and interests
Audio, Visual, or Similar Data	Voicemails, audio and video recordings, surveillance footage at our offices
Account Information	Bank authorization for payments, W-9 information, login credentials, if you establish an account
Device Information	IP address, browser and OS details, time zone, plug-in types, and general location data when using our Sites
Consents and Preferences	Marketing preferences, communication channels, and text message consent
Other Information You Choose to Provide	Additional Personal Information you voluntarily submit

Personal Information shall not include any personal information which is anonymized, after which the identifiable data is destroyed. We may also collect and use non-Personal Information to analyze the effectiveness of our Services and to improve our Services. We may collect non-Personal Information through the Services, the Site and through cookies.

Do We Collect Sensitive Personal Information?

We and our third-party service providers collect what may be considered Sensitive Personal Information from candidates, including biometric data (voice recordings), behavioral assessments, criminal history, and diversity information.
We obtain your explicit consent before collecting each type of sensitive information and explain the specific purpose for collection.
You may withdraw your consent at any time, and you have the right to access, correct, or request deletion of your sensitive personal information.
We retain sensitive personal information only as long as necessary for the stated purpose or as required by law.
Our third-party vendors (background check providers and assessment platforms) are contractually required to comply with applicable legal requirements.

Who Do We Collect Personal Information From?

We collect Personal Information from the following categories of individuals:

Categories	Examples of Collection and Use of Personal Information
Visitors	If you visit or use our Site(s), office locations, or any of our Services, we may collect Personal Information necessary to provide and improve the Site(s) or Services you request.
Job Seekers and Candidates	If you apply for or are contacted by us regarding job opportunities either for our internal positions or roles through our staffing, recruiting, search, workforce management, or talent advisory services, we may collect and use your Personal Information
Prospective and Actual Franchisees	If you request information, apply for, or are contacted by us regarding franchising opportunities.
Customers, Clients, Vendors, Service Providers, and Other Business Partners	If you are an employee, representative, or agent of our customers or clients, service providers, vendors, or other suppliers, we may collect your Personal Information. Please note that we use third parties to conduct background checks, perform human resource management (e.g. handle employee verification, payroll, and benefits), conduct behavioral tests. If you provide Personal Information to a third party, it will be subject to that party’s privacy policy. Our use of such information will be governed by this Notice.
Referrers and Others Providing Candidate Information	If you submit information about another person (e.g., as a referral, reference, or emergency contact), you confirm that you have their authority to do so and to permit us to use their information in accordance with this Notice.

Why Do We Collect Your Personal Information?

We collect and use your Personal Information for the following business and commercial purposes:

Why	Purpose
To Contact You	For any of the purposes below, including outreach by phone, email, or text
To Recruit and Hire	For current or future job/staffing opportunities with us or our customers, including determining your eligibility and suitability. For example, we may share your résumé with potential or existing customers or keep you informed about job opportunities using your preferred contact method.
To Provide Our Services	Including staffing, recruiting, consulting, workforce design, talent management
To Receive Services	When working with vendors, suppliers, and contractors who provide services to us
To Operate and Improve Our Site(s)	Including account setup, navigation optimization, and site performance improvements
For Business Development	Such as using your contact details to market our Services or to reach out about opportunities
For Marketing and Promotions	To send newsletters, event announcements, promotional communications, surveys, and personalized content on our Site(s) or other platforms
To Improve Our Services	Through analytics, audits, troubleshooting, internal testing, and leveraging machine learning to match job seekers to roles more effectively
For Research and Thought Leadership	Including articles, white papers, podcasts, and other materials related to workforce trends and insights
For Public Interest Goals	Such as equal opportunity reporting and diversity and inclusion programs
For Aggregation and Anonymization	To create anonymized data sets for internal analytics or thought leadership (such datasets are not considered Personal Information)
To Ensure Security and Prevent Fraud	To maintain the security and integrity of our systems and comply with legal obligations
To Comply with Legal Obligations or Obtain Professional Advice	Including responding to legal requests, subpoenas, court orders, regulatory inquiries, or receiving professional advice

Who Do We Disclose Your Personal Information To?

We may disclose Personal Information to third parties. These third parties include:

Why	Purpose
Actual or Prospective Customers	We may share your Personal Information to customers and potential customers in connection with providing our Services (e.g., for job placements we believe are appropriate for you). Our customers process Personal Information in accordance with their own privacy practices and policies
Vendors, Contractors, and Service Providers	We may share your Personal Information with service providers who help us operate our business and deliver our Services. For example, we may share your Personal Information vendors that provide the following services/products: IT and cloud infrastructure Website and data hosting Applicant tracking and CRM systems Identification verification Assessments (e.g. performance, behavioral) Marketing services HR management or operations Background and criminal history checks Payment processing Financial or banking services Insurance Legal, accounting, auditing Safety and security
Third Party Advertising Partners	We may share your Personal Information with third-party advertising partners such as social media networks to perform marketing activities and to deliver targeted advertising based on your interests.
Business Transfer Partners	In the event of a proposed or actual merger, acquisition, reorganization, or sale of assets, we may share and transfer Personal Information
DOXA Affiliates	We may share Personal Information with affiliated companies under common ownership or control, including for shared services functions and to connect you with potential opportunities
Courts, Regulators, Law Enforcement, and Government Authorities	We may disclose Personal Information as required to: Comply with applicable laws and regulations Respond to subpoenas, court orders, or legal processes Cooperate with public authorities in the interests of national security or law enforcement Establish or exercise our legal rights or defend against legal claims Investigate, prevent, or take action in connection with suspected fraud, illegal activity, or threats to safety

Please note: Any Personal Information you choose to share in public areas of our Sites may be visible and used by others. We are not responsible for the use of Personal Information posted publicly on our Sites

DOXA does not sell your Personal Information, except where you explicitly consent to the use of cross-context behavioral advertising cookies. For more information, please refer to the Cookies, Targeted Advertising, and Online Tracking section below.

Cookies, Targeted Advertising, and Online Tracking

Our Sites use cookies, tracking pixels, web beacons, and other similar technologies (collectively, “Cookies”) to personalize your experience and analyze usage. For details about the types of cookies we use, how they are used, and how to manage your preferences, please see our Cookie Notice.

We may use cookies and tracking technologies to show you ads on third-party websites based on your browsing behavior. This may constitute a “sale” or “sharing” of Personal Information or “targeted advertising” under certain U.S. privacy laws. We only process Personal Information for these purposes if you consent via the cookie banner or cookie settings on our Site. You may manage your preferences or withdraw consent at any time using the Cookie Settings link at the bottom of our web pages.

Your Right to Opt-Out of Marketing Communications

In accordance with your marketing preferences and applicable data protection laws, we may periodically send you emails about promotional opportunities or services that may interest you—such as job alerts, newsletters, white papers, surveys, or event invitations.
You may opt out of receiving marketing emails at any time by clicking the unsubscribe link included in our communications. If you encounter any issues unsubscribing, you may submit a request using the methods described above or call our number +1 (208)-435-7581.

Universal Opt-Out Mechanisms

Our Sites recognize the Global Privacy Control (GPC) signal. If your browser or browser extension supports and sends a GPC signal, we will treat this as a valid request to opt out of the sale or sharing of your Personal Information.
To enable the GPC signal, visit: https://globalprivacycontrol.org/orgs. Please note that you must activate GPC separately for each supported browser or extension.
Some browsers offer a “Do Not Track” signal; however, due to the lack of industry consensus, our Sites do not currently respond to “Do Not Track” signals.

Automated Decision Making and Profiling

We do not make decisions based solely on automated processing of your personal information, including profiling, that produces legal effects or similarly significant impacts on individuals. All decisions related to the provision of our services and data processing are made by authorized personnel.

This ensures that your rights and interests are protected, and that you are not subject to decisions made without human involvement.
We do not engage in profiling that results in decisions with legal or similarly significant effects.

Security of Your Personal Information

DOXA takes appropriate physical, technical, organizational, and administrative safeguards to protect your Personal Information from unauthorized access, loss, misuse, or disclosure.

Please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure, and we are unable to guarantee the absolute security of the Personal Information we have collected from you. Therefore, you are also a key stakeholder in making sure that your Personal Information is protected. We advise against sending sensitive information (e.g., Social Security numbers, financial data) via unencrypted channels. For more information on protecting your identity, please visit: http://www.ftc.gov/bcp/menus/consumer/data.shtm.

If you become aware of any breach of security or privacy, please contact us immediately at [email protected].

Data Retention

We retain your Personal Information only as long as necessary for:

Providing and improving Services
Keeping you in our talent pool
Complying with legal, tax, or accounting obligations
Once no longer needed, we will delete, anonymize, or securely store your information until deletion becomes possible (e.g., in archived backups).

Your Privacy Rights

We are committed to respecting your privacy rights and complying with applicable data protection laws. Depending on your location, you may have rights that include:

Right to Know whether we process your Personal Information and to access it;
Right to Obtain a Copy of the Personal Information collected about you in a portable, readily usable format;
Right to Delete Personal Information we have collected from or about you (subject to certain exceptions);
Right to Correct inaccurate Personal Information we maintain about you;
Right to Opt-Out of:
- Targeted advertising
- The “sale” of your Personal Information (as defined under applicable law)
- Profiling that produces legal or similarly significant effects (where applicable)
Right to Withdraw Consent (where processing is based on consent); and
Right to Non-Discrimination for exercising your privacy rights.

To exercise these rights, you may contact us by emailing [email protected].

We may ask you for additional data to confirm your identity and for security purposes, before disclosing the information requested to you. If you would like to submit a request on behalf of another individual, you may do so by providing proof of authorization by the individual to submit such a request on their behalf. We reserve the right to charge a fee, where permitted by law. We may also decline to process requests that jeopardize the privacy of others, are excessive, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we may need to retain certain Personal Information for a limited period of time for record-keeping, accounting and fraud prevention purposes.

International Data Transfers & Jurisdiction Specific Provisions

As a global business, information collected, including your Personal Information, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

Where required by local law, we will obtain your express consent for the collection, processing, and transfer of your personal information. Your data may be transferred to the United States or other countries for processing and storage, and we will use appropriate safeguards to protect your information in accordance with applicable law.
We collect and process personal information from individuals in a number of countries outside the United States, including but not limited to the Philippines, Colombia, Vietnam, and Kenya. We comply with applicable local data protection laws in these jurisdictions. If you are located in a country with specific privacy rights or requirements, you may contact us at [email protected] to exercise your rights or request more information.

Notice to California Residents

This section supplements the information contained in our Privacy Policy and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”), if and to the extent that the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), applies to our business. We adopt this notice to provide transparency and to comply with the CCPA/CPRA as applicable.

1. Your California Privacy Rights

As a California resident, you have the following rights regarding your Personal Information:

The Right to Know and Access. You have the right to request that we disclose the categories and specific pieces of Personal Information we have collected about you, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, and the categories of third parties to whom we disclose Personal Information.
The Right to Delete. You have the right to request the deletion of your Personal Information that we have collected, subject to certain exceptions.
The Right to Correct. You have the right to request the correction of inaccurate Personal Information that we maintain about you.
The Right to Opt-Out of Sale/Sharing. You have the right to opt-out of the “sale” or “sharing” of your Personal Information for cross-context behavioral advertising. As stated in the “Cookies, Targeted Advertising, and Online Tracking” section, we do not sell your Personal Information in the traditional sense. However, we do use advertising cookies that may be considered a “sale” or “sharing” under the CCPA. You can opt-out by using the “Cookie Settings” link on our website or by enabling the Global Privacy Control (GPC) signal on your browser.
The Right to Limit the Use and Disclosure of Sensitive Personal Information. You have the right to limit our use and disclosure of your Sensitive Personal Information to that which is necessary to perform the services or provide the goods reasonably expected by an average consumer. As noted in this policy, we may collect Sensitive Personal Information from candidates for employment. You can exercise this right by contacting us at [email protected].
The Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of your privacy rights.

2. Collection and Disclosure of Personal Information

The following table details which categories of Personal Information we collect and process, as well as which categories of Personal Information we have “sold” or “shared” for a business purpose in the preceding 12 months.

Category of Personal Information Collected	Business Purpose for Collection	Disclosed for a Business Purpose to:	“Sold” or “Shared”
Contact Information	To contact you; to provide our Services; for business development; for marketing.	Actual or Prospective Customers; Vendors, Contractors, and Service Providers; DOXA Affiliates.	Third Party Advertising Partners.
Identifying Information	To recruit and hire; to provide our Services; to comply with legal obligations.	Actual or Prospective Customers; Vendors, Contractors, and Service Providers; DOXA Affiliates; Courts and Regulators.	No.
Educational and Professional Background	To recruit and hire; to provide our Services.	Actual or Prospective Customers; Vendors, Contractors, and Service Providers; DOXA Affiliates.	No.
Other Career Placement Information	To recruit and hire; to provide our Services.	Actual or Prospective Customers; Vendors, Contractors, and Service Providers; DOXA Affiliates.	No.
Career Planning Information	To recruit and hire; to provide our Services.	Actual or Prospective Customers; Vendors, Contractors, and Service Providers; DOXA Affiliates.	No.
Audio, Visual, or Similar Data	To provide our Services; to ensure security.	Vendors, Contractors, and Service Providers.	No.
Account Information	To provide our Services; to receive services; to comply with legal obligations.	Vendors, Contractors, and Service Providers.	No.
Device Information	To operate and improve our Site(s); to ensure security.	Vendors, Contractors, and Service Providers.	Third Party Advertising Partners.
Consents and Preferences	For marketing and promotions; to comply with legal obligations.	Vendors, Contractors, and Service Providers.	No.

3. Data Retention

We retain your Personal Information for as long as needed to fulfill the purposes for which it was collected, to comply with our legal obligations, to resolve disputes, and to enforce our agreements. The criteria used to determine our retention periods include the duration of our relationship with you, the existence of a legal obligation, and the statute of limitations.

4. Shine the Light

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us at [email protected].

5. How to Exercise Your Rights

To exercise the rights described above, please submit a verifiable consumer request to us by either:

Emailing us at [email protected]
Calling us at +1 (208)-435-7581

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. We will need to verify your identity before processing your request, which may require us to request additional information from you.

Notice to Individuals in the Philippines and Colombia

If you are located in the Philippines

We process your personal information in accordance with the Philippines Data Privacy Act of 2012 (DPA).

We will obtain your express, documented consent before collecting, processing, or transferring your personal information, unless another lawful basis applies.
You have the right to access, correct, delete, object to processing, and request data portability regarding your personal information.
You may withdraw your consent at any time, subject to legal or contractual restrictions.
We will inform you if your personal information will be transferred outside the Philippines and the safeguards in place for such transfers.
If you have any questions, requests, or complaints regarding your personal information or our privacy practices, you may contact our Data Protection Officer at [email protected].
You also have the right to file a complaint with the Philippines National Privacy Commission (https://privacy.gov.ph/).

If you are located in Colombia

We process your personal information in accordance with Colombia’s Law 1581 of 2012 and Decree 1377 of 2013.

We will obtain your prior, express, and informed consent before collecting, processing, or transferring your personal information, unless another lawful basis applies.
You have the right to know, update, rectify, delete, and revoke consent regarding your personal information.
You may exercise your rights or submit any requests or complaints by contacting our local data controller at [email protected]
International transfers of your personal information from Colombia will only be made to countries with adequate levels of data protection or with your express consent, or as otherwise permitted by law.
You also have the right to file a complaint with the Superintendence of Industry and Commerce (SIC) (https://www.sic.gov.co/).

How to Exercise Your Rights (Philippines and Colombia):

To exercise your rights or for any privacy-related inquiries, please contact:
Data Privacy Officer at [email protected] or via mail at:
9169 W State Street #775
Garden City, ID 83714-1733

Cross-Border Transfers

If your personal information is transferred outside the Philippines or Colombia, we will ensure that appropriate safeguards are in place to protect your data in accordance with applicable law.

Children’s Privacy

Our Sites are not intended for children under age 16. We do not knowingly collect Personal Information from children under 16 (or under 18 where applicable). Our Sites and Services are not addressed to minors. If you are a parent or guardian or you learn that your children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a minor without verifiable parent consent, we will take steps to remove that information.

Third-Party Sites and Public Forums

Our Sites may contain links to third-party websites and platforms. These sites have their own privacy and security policies, which we do not control. We encourage you to review them before submitting any Personal Information.

We may also offer public forums or message boards. Any Personal Information you post in such forums is public and may be accessed by others. Use caution when sharing information in these areas.

Contact Us

If you have questions about this Notice or our privacy practices, please contact:
DOXA Privacy Officer
9169 W State Street #775, Garden City, ID 83714-1733
ATTN: Privacy Officer
[email protected]

Consent:

By providing your personal information, you acknowledge that you have read and understood this privacy notice and consent to the collection, processing, and transfer of your personal information as described herein, unless another lawful basis applies.

Changes to This Notice

We may update this Privacy Notice from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. When we make changes, we will revise the “Last Updated” date at the top of this Notice.

If the changes are material—such as updates to how we collect, use, or share your Personal Information—we will provide additional notice. This may include:

Sending you an email notification (if we have your contact information),
Posting a prominent notice on our website homepage or within the relevant service platform, and/or
Requesting your renewed consent where required by law.

We encourage you to review this Notice periodically to stay informed about how we are protecting your information.