PRIVACY POLICY

Introduction

Emissary Software LLC (“Emissary” or the “Company”) provides recruiting and HR communication services to its corporate customers (“Customers”) through the Emissary platform (the “Platform”). We’ve developed this Privacy Policy (the “Privacy Policy”) to describe how we collect, use, disclose, and store personal information (“Personal Information”) from our website visitors, service providers, and individuals using the Platform for and on behalf of Customers.

This Privacy Policy applies when you visit Emissary.ai (the “Website”) or our mobile application (together with our Website, the “Site”), register an account as a user of the Platform, and when you interact with us in other ways, including but not limited to, by mail, email, phone, live chat, and SMS/MMS/text (collectively, together with the Site and the Platform, the “Service”). This Privacy Policy also applies to Personal Information processed for business administration purposes where your employer provides services to us as a service provider.

In the performance of the Service, we also process personal data of individuals who interact with our Customer. We do so as a service provider, acting on behalf of our Customers, and in accordance with their instructions. We do that upon their instructions to us as their service provider as such we are acting as a processor, not a controller, of Personal Information. If you have questions related to how an Emissary Customer uses your Personal Information, please contact that Customer directly. We are not responsible for the privacy or data security practices of our Customers.

By using our Service, you agree to our Terms of Use and to our collection, use, and disclosure practices and other activities described in this Privacy Policy. If you do not agree and consent, discontinue use of the Service. This Privacy Policy may change from time to time. Your continued use of our Services after we make changes to our Privacy Policy is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

Sources of Personal Information We Collect

Directly From You. We collect information you provide directly to us including when you visit our Site, send messages to someone through our Platform, or otherwise interact with us. We may also ask you to provide certain Personal Information when you register an account on the Platform, use certain parts of our Site, when you attend our events and webinars, when you interact with us at a conference or communicate with us in person, by phone, email, text or otherwise.

From Third Party Sources. We may collect Personal Information about you through data aggregation service providers, your colleagues or, where available, through publicly available sources, such as professional networking sites and general market research. We may also, from time to time, receive information about you from a contact who believes our Service would be of interest to you. If you are using our Platform on behalf of a Customer, that Customer may provide us with your Personal Information or one of their employees may share your contact information with us so that they can message you through the Platform.

Automatically Through Our Platform and Other Correspondence. As you navigate through and interact with our Site or our Platform, or when you correspond with us (whether through our Platform, by phone, text, SMS or any other means), we and our service providers may use automatic data collection technologies to collect the Technical Data described in the “Categories of Personal Information We Collect” section of our Privacy Policy. Please Note: we also use Google Analytics on our Site to collect information such as your IP address, your internet service provider, the web page you linked to our Website from, and other clicking and browsing behavior, to analyze how users use our Website.

Purpose for Collecting Personal Information

We collect and use information about you for the business and commercial purposes described in this Privacy Policy. Our business purposes for collecting and using information, including in the last 12 months, include:

• To present our Site and/or our Platform and its contents to you.
• To allow you to register your company to use our Service.
• To manage our Service, including registration and account transactions.
• To perform services requested by you, such as sending messages, responding to your request and providing customer service.
• To allow you to communicate through our Platform.
• To respond to your requests and provide customer service.
• To allow you to participate in interactive features on our Site.
• To provide you with information, products, or services that you request from us.
• To prevent or take action regarding illegal activities, including suspected fraud.
• To improve our marketing and promotional efforts and product offerings.
• To monitor and analyze trends, usage, and activity.
• To provide you with notices about your account, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Site or any products or services we offer or provide though it.
• To store (and update where necessary) your contact details on our database, so that we can contact you in relation to our agreements.
• To administer and manage our business relationship with you and to obtain services from you.
• To comply with legal or regulatory requirements.
• To help us establish, exercise or defend legal claims.
• In any other way we may describe when you provide the information.
• To fulfill any other purpose for which you provide it
• For any other purpose with your consent.

We may also use your information to contact you about our goods and services that may be of interest to you.

Please Note: To the extent we have access to calendaring and scheduling information as a result of the Google Calendar Integration (such data, “Google User Data”) we only use that data to provide and improve the functionality of our Service. Our use and transfer to any other app of Google User Data will adhere to Google API Services User Data Policy, including the Limited Use Requirements.

How We Disclose the Personal Information We Collect About You

We share your Personal Information in accordance with the practices described in this Privacy Policy. The types of entities to whom we disclose and have disclosed information within the last 12 months include the following:

• Service Providers. Agents, contractors, and other third party service providers in connection with their work on our behalf (collectively “Service Providers”).
• Professional advisors. Professional advisors, such as accounting, bookkeeping or legal firms, financial services firms, auditors, insurers, and consultants as necessary in the course of the professional services they provide to us.
• Affiliates. Related entities including our parent and sister companies.
• Feedback, Testimonials and User Provided Content. If you provide feedback or testimonials on the Service we may post and share this feedback, testimonial or other user provided content, including your information, on the Service, with partners, or in marketing and promotional materials. We may, in our sole discretion, edit feedback, testimonials or user provided content for length and content.
• Business Transfer. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
• Enforcement of Rights. To enforce or apply our Subscription Agreement or Acceptable Use Policy and other agreements, including for billing and collection purposes.
• Security, Compliance with Law. As we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request and in order to investigate, prevent or take action regarding illegal activities, including suspected fraud, or as otherwise required by law. We may also share your information to protect the rights, property, life, health, security and safety of us, the Service or any person or party.
• Purpose Fulfillment. To fulfill the purpose for which you provide it.
• Consent. For any other business or commercial purposes disclosed to you and with your consent.

Please Note: Google User Data is only transferred to third parties for the purpose of providing or improving the functionality of our Service.

Deidentified Personal Information

We may use or permit our Service Providers to use aggregated information and information that has been deidentified or anonymized that does not identify you (including information that has been de-identified or anonymized so that it can no longer be associated with a natural person) without obligation to you except as prohibited by applicable law. We may also, if permitted by applicable law, combine Personal Information with information which has been de-identified or anonymized. Should this occur, we will treat such combined information as Personal Information and will not attempt to reidentify it. Additionally, if we receive deidentified / anonymized Personal Information from our Customers we will not attempt to re-identify it.

Third Party Sites

There may be hyperlinks on our Site to other sites or locations that are operated and controlled by third parties (“Third Party Sites”). These Third Party Sites may use their own cookies, web beacons and other technology to independently collect personal information about you. We make no representations regarding the policies or business practices of such Third Party Sites. Collection of your personal information by third parties is not governed by this Privacy Policy. Please consult the privacy policies of those third parties to determine how they collect and use the personal information they collect.

Cookies and Other Tracking Technologies

We collect data through the use of cookies, web logs, web beacons and other tracking technologies (“Tracking Technologies”), including:

• Operational Cookies: These cookies are essential in order for you to use our Service, such as allowing you to log in, manage your account, and navigate the website securely.
• Analytics and Performance Cookies: These cookies collect information about how you use our Service. For instance, they may track the images you click on as you visit our Site and the amount of time you spend on particular pages of our Site, They help us to understand what is important to our customers and enable us to provide a more personalized experience.
• Customization Cookies: These cookies allow us to gather information on how our Service is being used so that we can provide content that is relevant to you.
• Targeting and Advertising Cookies: These cookies help us deliver information and advertisements that are more tailored to you and your interests, as well as limit the number of times you receive the same advertisement. We also use cookies to measure the effectiveness of our advertising campaigns.
• Social Networking Cookies: These cookies allow users to share our pages and content to third-party social networking sites.
• Web Beacons. We use electronic images known as web beacons or pixels on the Service. When you access the Site, e-mail, video, or an advertisement that has a pixel, the pixel may permit us or another party to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may use pixels from third parties so we can you advertising both on and off the Service, understand its effectiveness, and provide you with additional functionality, such as the ability to connect our Service with your social media account.

Some information about your use of the Service and certain unaffiliated sites or services (described below) may be collected using Tracking Technologies across time and services and used by us and other parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and unaffiliated websites and services. You may see our ads on third-party websites or apps because we use third-party ad networks to serve our ads. The networks use this information to show you advertisements that may be tailored to your individual interests.

Some of the tracking technologies used in connection with our services are owned and operated by either our service providers or other third parties. For example, we use Tracking Technologies from analytics providers, such as Google Analytics, to help us analyze your use of the Service, compile statistic reports on the Service’s activity, and provide us with other information relating to your activity and internet usage. We also work with third parties to provide serve advertisements on our Site and/or on other websites. These other parties may use Tracking Technologies on our Service (including in e-mails and advertisements) and on other Sites and services to track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you on our Service and other parties’ services or devices after you have left the Service (“Interest-based Advertising”).

We may serve ads on other websites and services, which are targeted to reach people who have visited our Service or that are also identified in one of more of our databases (“Matched Ads”). This is done by us uploading a customer list to another party or incorporating a pixel from another party into our own Service, and the other party matching common factors between our data and their data.

Choices About How We Use and Disclose Your Information

Review and Update of Account Information

You may access, update, or remove certain account information that you have provided to us through the Service. If you would like to update or revise information in your account, you may do so through your account or by contacting us as set forth in the section entitled “Contact Us”. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and as necessary to provide the Services you have requested.

Tracking Technology Choices

• Cookies and Pixels. You may always decline our cookies if your browser permits. If you use multiple browsers on your device, you will need to instruct each browser separately. Please be aware that if you disable or remove tracking technologies some parts of the services may not function correctly.
• Opt-out Preference Signals. Opt-out Preference Signals. Our Site is configured to recognize and honor Global Privacy Control (GPC) browser signals as valid requests to opt out of the sale and sharing of personal information associated with your browser. If you use different browsers or profiles, you must enable GPC for each separately. For more information, visit https://globalprivacycontrol.org/.
• Do Not Track Signals. Some web browsers may transmit "do not track" signals to websites. Currently, there is no universally accepted standard for how websites should interpret or respond to these signals. Therefore, this website does not currently respond to browser Do Not Track signals. However, you can generally express your privacy preferences regarding online tracking by adjusting your browser settings or utilizing widely available opt-out programs.
• Google Analytics. You can opt-out of your data being used by Google Analytics by visiting https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.
• Digital Advertising Alliance Opt-Out of Online Behavioral Advertising. Some of the other parties that collect personal information from or about you on the services in order to provide more relevant advertising to you participate in the Digital Advertising Alliance Self-Regulatory Program for Online Behavioral Advertising. This program offers a centralized location where users can make choices about the use of their personal information for online behavioral advertising. To learn more about the DAA and your opt-out options please visit http://aboutads.info/choices. You can opt out of receiving targeted ads from members of the Network Advertising Initiative by visiting https://thenai.org/opt-out/ . Please note that if you opt-out of online behavioral advertising using any of these methods, the opt-out will only apply to the specific browser or device from which you opt-out. Further, opting-out only means that the selected members should no longer deliver Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads from other ad networks.

We are not responsible for effectiveness of, or compliance with, any other parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

Communications

To opt out of receiving e-mail promotions from us, please follow the unsubscribe instructions in our promotional e-mail correspondence or contact us as described in the Contact Us section of this Privacy Policy. Please Note: If you unsubscribe from receiving marketing communications, we may still contact you for the purpose of providing you with Service related messages.

If you wish to opt out of our text messaging, you may do so at any time by texting “STOP”, “END”, “CANCEL”, “UNSUBSCRIBE” or “QUIT”. Please note that opting out of promotional communications from We does not affect our non-promotional communications with you, including those related to your account, scheduling, orders placed with We, or our ongoing business relations

Some browsers include a "Do Not Track" (DNT) setting that can send a signal to the websites you visit indicating you do not wish to be tracked. Our Site does not respond to browser DNT signals. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Site may then be inaccessible or not function properly.

Profiling and Automated Decision-Making

We do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects as defined under applicable state privacy laws.

Children

We do not knowingly collect Personal Data for children between 13-18. If you believe we have mistakenly or unintentionally collected Personal Information of a minor please contact us by and we will take steps to delete their Personal Data from our systems.

Visiting this Site from Outside the United States

Emissary is located in the United States. Your personal information may be stored and processed in the United States or any other country in which Emissary or our partners, affiliates, service providers, subsidiaries or agents maintain facilities. By using our Services, you consent to any such transfer of information outside of your country. Data protection laws in the United States and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information in the United States and other jurisdictions as set forth in this Privacy Policy. 

Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.  Emissary also has policies and procedures designed to promote commercially reasonable security practices. Nonetheless The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Service, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Additionally, the transmission of information via the Internet is not completely secure, and we cannot guarantee the security of data sent to us electronically over cellular and wireless networks that we do not control.

Retention of your Personal Information

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

• The length of time we may have an ongoing relationship with you or the Customer for whom you are employed;
• Whether there is a legal obligation to which we are subject; or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Your State Privacy Rights

1. Your rights

If you are the resident of a state of the United States which has passed a comprehensive privacy law, at or before the time of collection, you have a right to receive notice of our practices, including the categories of personal information and sensitive personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared and how long such information is retained. You can find those details in our Privacy Policy, above.

Additionally you may have the following rights

• Right to Portability. The right to access your information in a portable format.
• Right to Delete. The right to request that we delete personal information that we have collected from you (and direct our Service Providers to do the same). Once we have verified your request, we will review your request to see if an exception allowing us to retain the information applies. Note: there are some reasons we will not be able to fully address your request, such as if we need to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to exercise our rights, for our internal purposes, or to comply with a legal obligation.
• Right to Correct. The right to request that we correct inaccurate personal information that we may maintain about you, subject to appropriate verification.
• Right to Opt-Out of the Sale or Sharing of Personal Information. The right to opt-out of the “sale” or “sharing” of your personal information, as such terms are defined under state privacy law. Note: We do not share your Personal Information with third parties for their own direct marketing purposes.
• Right to Opt-Out of Targeted Advertising. The right to opt-out of targeted advertising. Opting out does not mean that you will stop receiving ads, it just means that those ads will not be targeted based on your personal information.
• Right to Limit Use and Disclosure of Sensitive Personal Information. The right to limit our use of sensitive Personal Information for any purposes other than to provide the Service you request or as otherwise permitted by law. Please Note: We do not intentionally collect sensitive Personal Information as that term is defined in applicable law. We request that you do not share sensitive Personal Information with us through our Service.
• Right to Appeal. If we deny your request, and you wish to appeal, you may appeal our decision.
• Right to Non Discrimination. The right not to be discriminated against for exercising any of the rights listed above.

How to Make a Request

You can initiate a request by sending an e-mail to privacy@emissary.ai using the subject line “Privacy Request”. When processing your request, we may request additional information about you or your interactions with Emissary to confirm or verify your identity or for security purposes before we can respond to your requests.

To exercise your right to opt out of the sale or sharing of personal information (including to opt out of targeted advertising), please click on the Do Not Sell or Share My Personal Information link which also is on our website footer or email us at privacy@emissary.ai. Alternatively, you can use certain preference signals to exercise your sale and sharing opt-out right automatically with all businesses that you interact with online, including Emissary. If you enable a browser-based opt-out preference signal, such as Global Privacy Control (GPC), upon receipt or detection, we will treat the signal as a valid request to opt out of the sale or sharing of personal information linked to that browser and any consumer profile we have associated with that browser. Note: if you use different browsers or browser profiles, you will have to enable the signal on each browser or profile.

Nevada residents may send an email to privacy@emissary.ai to submit a verified request to direct us to stop the sale of your covered information.

You can designate an authorized agent to make a request to exercise your rights on your behalf. In order to do that, please provide the agent with written permission, signed by you, authorizing the agent to submit the request on your behalf. The agent must submit that written permission along with the request. We will contact you to verify your identity — and the authorized agent’s permission — before a response to the request is sent.

In certain instances, your request (or the request of your agent) may be denied as required or permitted by law.

Record of Requests

We keep a record of requests that we receive regarding these requests. residents. 

Supplemental Information for the EEA and the U.K.

Your Rights.

Individuals located in the UK or the EEA have certain statutory rights regarding their Personal Information. Subject to any exemptions provided by law, you may have the right to:

• Access. Request access to your Personal Information (commonly known as a “data subject access request”) and to certain additional information about our processing of your Personal Information that this Notice is designed to address.
• Correct. Request correction of the Personal Information we hold about you. This enables you to update or correct any inaccuracies in your Personal Information.
• Delete. Ask us to delete or remove your Personal Information from our system where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have exercised your right to object to processing (see below).
• Transfer. Ask us to transfer a machine-readable copy of your Personal Information to you and/or a third party of your choice, where our processing is based on your consent.
• Object. You can object: (1) to processing of your Personal Information at any time for direct marketing purposes, (2) to decisions being taken by automated means which produce legal effects concerning you or significantly affect you, and (3) in certain other situations to our continued processing of your Personal Information.
• Restrict. Restrict processing of your Personal Information. This enables you to ask us to suspend the processing of Personal Information about you where, for example, you want us to establish its accuracy or the reason for processing it.
• Withdraw. Withdraw your consent to our processing of your Personal Information, where we have collected and processed it with your consent. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

If you would like to submit a question or complaint about our use of your Personal Information or request a response, contact us at privacy@emissary.ai. Please note that we try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. You can submit these requests by email at privacy@emissay.ai or by mail to our postal address, listed in the ”Contact Us” Section below. Please let us have enough information to identify you. We may need to request specific information from you to help us confirm your identity. We may also ask you for further information in relation to your request to speed up our response.

In the performance of the Services, Emissary processes Personal Information of its Customer’s customers. We do so as a service provider acting on behalf of our Customers and in accordance with their instructions. If you are a customer of one of our Customers and wish to exercise your statutory rights in relation to Personal Information processed by Emissary on behalf of a Customer, you should contact that Customer with your request. We will then help them to fulfill that request in accordance with their instructions and our legal obligations.

We hope that we can resolve any query or concern that you raise about our use of your Personal Information. However, If you are located in the UK or the EEA, you also have the right to lodge a complaint with a supervisory authority. In the UK this is the Information Commissioner’s Office (www.ico.org.uk). In the EEA this will be the supervisory authority in the European Union (or EEA) country where you work, normally live or where you consider any alleged infringement of data protection laws occurred.

Processing Purposes.

We may inform you that we will process your Personal Information for other purposes not identified in the section ‘Purpose for Collecting Personal Information’ above. Where we do so, we will provide you with an additional privacy notice explaining how we will use your information for these purposes.

Legal basis for processing your Personal Information.

Website Users.

Where we process your Personal Information to present our Website and its contents to you, to provide you with information on products, or services that you request from us, to allow you to participate in interactive features on our Website, we consider this processing is necessary for our legitimate interests and that your interests and fundamental rights do not override those interests.

Where we process your Personal Information to send you advertising which we think may be of interest to you, we do so on the basis of your consent in accordance with your marketing preferences.

Where we use cookies to collect Personal Information for the purposes of monitoring and analyzing trends, usage, and activity, we do so on the basis of your consent.

Customer Personnel.

Where we process your information to allow you to register to use our Service; to manage our Service (including registration and account transactions), to respond to your requests and provide customer service; to allow you to participate in interactive features on our Site; to prevent or take action regarding illegal activities, including suspected fraud; to improve our marketing and promotional efforts and product offerings; to provide you with notices about your account; to enforce our rights arising from any contracts entered into between you and us; and to notify you about changes to our Site, the Platform or any products or services we offer or provide though them, we consider this is necessary for our legitimate interests and that your interests and fundamental rights do not override those interests.

Where we process your information to provide you with the Services (including the Site and the Platform) that you request from us; to allow you to communicate through our Platform, to perform services requested by you such as monitoring customer support services and customer

relationship management, this processing is necessary to perform the contract we have entered into with you.

Where we process your Personal Information to send you advertising which we think may be of interest to you, we do so on the basis of your consent in accordance with your marketing preferences.

Where we use cookies to collect Personal Information for the purposes of monitoring and analyzing trends, usage, and activity, we do so on the basis of your consent.

We will rely on a legal obligation if we are legally required to hold or otherwise use your Personal Information to comply with legal or regulatory requirements, such as disclosure to regulators.

Service Providers.

Where we process your Personal Information in connection with obtaining services from you, this processing is necessary to perform the contract we have entered into with you.

Where we process your information to administer and manage our business relationship with you, we consider this is necessary for our legitimate interest and that your interest and fundamental rights do not override those interest.

Other Individuals.

Where we process your information to provide you with information that you have requested from us, we consider this is necessary for our legitimate interests and that your interests and fundamental rights do not override those interests.

International Data Transfers.

Whenever we transfer your Personal Information outside the UK or EEA, we ensure that a similar degree of protection is afforded to it by ensuring appropriate safeguards are implemented. This may include, where appropriate, relying on an adequacy decision, or signing up to the European Union Standard Contractual Clauses or UK International Data Transfer Agreement. To find out more information regarding the specific mechanism used by us when transferring your Personal Information outside the UK or EEA, please contact us using the contact details below in the “Contact Us” section of this privacy policy.

How to Contact Us.

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:

• European Union (EU)
• United Kingdom (UK)

Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website: https://app.prighter.com/portal/18287275715

Updates to Our Privacy Policy

We reserve the right to amend this Privacy Policy from time to time to reflect changing legal requirements or our processing practices. Any such changes will be posted on this Site and will be effective upon posting. If we make a material change to this Privacy Policy, we will provide you with notice in accordance with the applicable law.

Contact Us

To ask questions or comment about this privacy policy and our privacy practices, contact us via e-mail at privacy@emissary.ai or by mail at 511 6^th Ave, STE 528, New York, NY 10011.

Last Reviewed

This Privacy Policy was last reviewed and effective as of October 3, 2025.

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