1. Who This Policy Applies To

This policy applies to organizations, authorized Employer representatives, independent recruiters, headhunters, recruiting consultants, and other approved Talent-sourcing professionals using Employer-side platform access or DEMA Health recruiting and workforce services.

2. Information We May Collect

DEMA Health collects information reasonably necessary to verify Employer users, administer accounts, provide platform services, support legitimate recruiting activity, and operate and improve the beta.

Depending on how an Employer uses the service, this may include:

• Business or organization name and contact information
• Authorized representative name, title, professional email address, and other account information
• Business verification information
• Employer profile information
• Job, role, industry, workforce, and recruiting information voluntarily submitted
• Talent searches, filters, shortlists, profile interactions, and recruiting activity
• Platform messages and communications where supported by the service
• Access level, package, service, and transaction information
• Information submitted when requesting behavioral job matching, role analysis, Talent-search assistance, or other DEMA Health services
• Technical, security, fraud-prevention, and platform-use information reasonably necessary to operate and protect the service

3. How Employer Information May Be Used

Employer information may be used for legitimate business, operational, recruiting, security, and beta purposes, including:

• Verifying an organization, representative, recruiter, or permitted recruiting purpose
• Creating and administering Employer accounts
• Providing Talent discovery, recruiting, behavioral, and workforce services
• Managing access levels, packages, purchases, and permitted platform features
• Supporting authorized communication between Employers and Talent
• Responding to questions, service requests, technical issues, or account concerns
• Protecting Talent, Employers, DEMA Health, and the platform from fraud, misuse, unauthorized access, or other improper activity
• Evaluating and improving the Behavior-First Talent Discovery Beta, Employer tools, Talent experiences, behavioral workforce services, and future offerings
• Meeting applicable legal, accounting, security, recordkeeping, or compliance obligations

4. Confidential Employer Information

DEMA Health respects the confidentiality of business information provided through Employer accounts and services. Employer information is not sold or made publicly available merely because an organization participates in the beta.

Business information may be disclosed when reasonably necessary to provide requested services, support platform operations, protect the service, comply with law, or work with authorized service providers performing functions on DEMA Health's behalf.

5. Candidate Information and De-Identification

Talent profiles are designed to limit selected personally identifying information during initial discovery so Employers can begin by considering permitted behavioral and workforce information.

Information available during early discovery may include items such as a Talent ID, Behavioral Style, resume summary, role and industry categories, eligible work location, employment preferences, and other information permitted by the applicable access level.

6. Access to Additional Talent Information

Talent information available to an Employer depends on the applicable access level, package, feature, service, and stage of the recruiting process.

Expanded access may include additional qualification information, resume access, behavioral traits, behavioral reports or insights, job-matching information, communication capabilities, or other permitted information.

Access to information through one feature or package does not authorize unrelated use, redistribution, resale, database-building, or use beyond a legitimate recruiting or DEMA Health-approved purpose.

7. Permitted Use of Talent Information

Employers and approved recruiting professionals may use Talent information only for legitimate recruiting, employment consideration, workforce planning, or another purpose expressly authorized by DEMA Health.

Information legitimately provided through an authorized resume download, communication feature, candidate introduction, or other approved process may be retained and used as reasonably necessary for the legitimate employment opportunity or recruiting purpose for which it was provided, subject to applicable law and confidentiality requirements.

8. Behavioral Information

Behavioral Style, behavioral traits, behavioral reports, job-matching insights, role analyses, and related information are intended to provide additional workforce information.

Behavioral information is not a clinical diagnosis, background investigation, guarantee of future behavior, guarantee of job performance, or determination that an individual is qualified or unqualified for employment.

Employers remain responsible for considering relevant skills, experience, qualifications, interviews, job requirements, professional judgment, and other lawful employment criteria. Employment-selection technologies and other screening tools remain subject to applicable employment-discrimination requirements. citeturn719829search4turn719829search18

9. Background Information

Criminal-history information is generally not used as an initial Talent-discovery filter within the beta.

Employers remain responsible for conducting any legally permitted or required background screening at the appropriate stage of their own hiring process and for determining whether a particular applicant satisfies applicable job requirements.

Employment background screening is subject to separate legal requirements, and federal guidance cautions Employers to apply background screening consistently and without unlawful discrimination. citeturn719829search11turn719829search17

10. Service Providers and Platform Partners

DEMA Health may use third-party service providers and technology partners to operate or support portions of the beta and related services. Depending on the service, these providers may support areas such as website hosting, behavioral assessment administration, payment processing, communication, technical support, data storage, verification, analytics, or other operational functions.

Information may be provided to service providers only as reasonably necessary for them to perform authorized services or support DEMA Health's operations, subject to applicable contractual, privacy, security, and legal requirements.

11. Beta Evaluation, Analytics, and Service Improvement

Because the Behavior-First Talent Discovery service is in beta, DEMA Health may evaluate platform activity and workforce outcomes to understand how the service performs and how participants use behavior-first Talent discovery.

This may include analyzing de-identified or aggregated information relating to searches, profile interactions, shortlists, Talent communication, candidate progression, platform engagement, behavioral workforce services, and other relevant activity.

Beta findings may be used to improve platform functionality, Talent experiences, Employer tools, behavioral workforce models, services, and future offerings.

Individual Employer activity or Talent information is not intended to be publicly attributed through beta reporting without separate authorization where appropriate.

12. Security and Access Controls

DEMA Health uses administrative, technical, and organizational measures intended to protect information from unauthorized access, misuse, disclosure, alteration, or loss. Access to information is restricted according to business need, platform permissions, and applicable service requirements.

No internet-based service or information-security system can guarantee absolute security. DEMA Health may update safeguards and security practices as technology, platform operations, risks, and service requirements evolve.

13. Data Retention and Account Requests

Employer information may be retained for as long as reasonably necessary to provide services, administer accounts, maintain business and transaction records, protect the platform, satisfy applicable legal or accounting obligations, resolve disputes, enforce platform requirements, or support other legitimate operational purposes.

Employers may contact DEMA Health to request review, correction, deletion, or anonymization of eligible account information. Some information may need to be retained when reasonably necessary for legal, security, accounting, fraud-prevention, contractual, or legitimate business purposes.

14. Employer Account Responsibilities

Employers and approved recruiting professionals are responsible for maintaining accurate account information and protecting account credentials.

• Keep account and organization information accurate and current
• Protect login credentials from unauthorized use
• Limit access to authorized representatives
• Use Talent information only for permitted purposes
• Follow applicable employment, privacy, confidentiality, and nondiscrimination requirements
• Notify DEMA Health when unauthorized account access or suspected misuse becomes known

15. Updates to This Policy

DEMA Health may update this Employer Data Privacy & Confidentiality Policy as the beta, platform features, services, technology, operational practices, or applicable requirements change.

Material updates may be communicated through the website, Employer dashboard, email, or another appropriate method.