Privacy Policy

Effective date: June 1, 2026 · Last updated: June 25, 2026

1. Who we are and scope

This Privacy Policy explains how CestoneAI Holdings LLC, a Maryland (USA) limited liability company that also operates the recruiting-agency DBA “Placement Solutions” (“we,” “us,” or “our”), collects, uses, shares, and protects personal information through the paid recruiter platform at placement.solutions/app and the free job-seeker portal at portal.placement.solutions (together, the “Services”). It is effective June 1, 2026 and was last updated June 11, 2026.

For any privacy question, subprocessor inquiry, or to exercise your rights, contact us at hunter@placement.solutions. This Policy is governed by the laws of the State of Maryland, USA.

2. Definitions

User

Anyone who uses the Services, whether a Job Seeker or a Recruiter/Employer.

Job Seeker

An individual who uploads their own resume to the free portal to receive AI job matches.

Recruiter / Employer

A business account holder who uses the paid platform to source, match, and manage candidates.

Candidate Data

Personal information contained in or derived from a resume or candidate profile, whether self-uploaded by a Job Seeker or uploaded by a Recruiter.

Credits

The prepaid units consumed when you perform billable actions on the paid platform, such as an AI candidate match.

Subscription

A recurring paid plan (for example, Solo, Boutique, or Practice).

Services

The paid recruiter platform and the free job-seeker portal, collectively.

AI Providers

The third-party artificial-intelligence subprocessors that process resume and job text on our behalf, as listed in Section 6.

3. Information we collect

We collect information you provide and information generated through your use of the Services.

Resume and profile data

When you upload a resume or we build a candidate profile, we collect and store the personal information contained in or derived from it. This can include your name, email address, phone number, and location; your skills, practice areas, bar admissions, years of experience, education, and full work and employment history; your current company and title; your salary expectations (desired salary and salary minimum/maximum); links to your LinkedIn, GitHub, and Twitter/X profiles; profile and LinkedIn photos; your security-clearance status where it appears in the document; and the complete raw text of the resume itself. For candidates managed by a Recruiter, we also store recruiter-entered notes, tags, pipeline stage, and screening information. We retain the original parsed text so the AI can re-score and re-format your profile over time.

Account and authentication data

If you create an account or a portal login, we store a hashed password (never plaintext), email-verification tokens and their expiry, and session tokens and their expiry. These credentials are used only to authenticate you, verify your email, and maintain your logged-in session. We cannot recover your original password from what we store. If you choose to Sign in with Google, Google sends us your email address, name, profile-picture URL, and your Google account identifier (the OAuth sub claim). We use these only to create your account or sign you in, and we never receive or store your Google password. Free Job Seeker accounts can also sign in with an email magic link: we send a one-time sign-in link to your email address through Resend, our email processor. Signed-in sessions last up to 180 days unless you sign out sooner. If you upload a resume anonymously, you receive a one-time preview of your matches; creating a free account is required to keep and return to them.

Behavioral, usage, and device data

As you use the Services we automatically log activity and usage data, including clicks, page and view changes, and form submissions; candidate and account activity events; login sessions (with user-agent and IP address) and their timestamps; people-search sessions and queries; credit charges and usage events; and, for Job Seekers, the jobs you apply to and the jobs you save or bookmark. We also record your IP address and a privacy-preserving hashed form of it for security and abuse prevention, such as enforcing upload rate limits on the public portal.

Resume embeddings (FAISS vector index)

To power semantic search and matching, we convert your resume text and job descriptions into numerical “embeddings” (vector representations) and store them in a local FAISS vector index on our own servers. These embeddings are generated by our self-hosted model and are not, by themselves, sent to a third-party AI Provider. Because they are derived from your personal information, we treat them as personal information; when you delete your resume, the underlying record and its association to the index are removed as described in Section 10.

4. How we use your information

We use the information above to operate the Services, including to:

• extract and structure your resume into a usable profile;
• classify your candidate type (for example, attorney, paralegal, legal support, or non-legal/IT) and generate match scores with written reasoning;
• generate vector embeddings used to match candidates to jobs and jobs to candidates;
• let Job Seekers apply to and save jobs, and let Recruiters manage candidates, pipelines, and outreach drafts;
• authenticate accounts and maintain sessions;
• meter and bill credits and subscriptions through our payment processor;
• secure the Services, prevent abuse and fraud, and improve matching quality; and
• comply with our legal obligations.

5. Legal bases for processing

Where required by law, we rely on the following legal bases:

• Performance of the service you request. For Job Seekers, our primary basis is performing the service you ask for — parsing your resume and generating matches.
• Your consent. You give consent at upload by checking the “I agree to placement.solutions Terms and Privacy” box; we record that you consented and the time of consent. You may withdraw consent at any time, though withdrawal does not affect processing already carried out.
• Legitimate interests. For Recruiter, agency, and Employer accounts, we process Candidate Data on the basis of our and our customers’ legitimate interests in providing recruiting services, and on the customer’s representation that it has a lawful basis and any required consent for that data.
• Legal obligations. We process information as needed to comply with applicable law.

Recruiters who upload third-party Candidate Data must establish their own lawful basis or consent for that data.

6. AI processing and subprocessors

To provide AI features, we transmit the relevant resume text and job-listing text to third-party AI Providers that process it on our behalf under contract and return results to us. We use these providers to parse resumes, build a structured candidate profile, classify candidate type, score candidate-job fit with written reasoning, and generate outreach. Our AI Providers are:

• Moonshot AI (“Kimi”) — our current primary match-scoring and reasoning provider, which is based in the People’s Republic of China (api.moonshot.ai). Your resume text is transmitted to it over the internet. See Section 7.
• OpenAI (GPT-4o) — an additional or fallback provider.
• Anthropic (Claude) — an additional or fallback provider.
• AssemblyAI — used only if you use the interview “Scribe” transcription feature, to transcribe the audio you provide.
• Self-hosted Ollama — a model that runs locally on our own servers. Data processed by Ollama does not leave our infrastructure to a third party.

AI outputs are assistive and may be inaccurate; they do not make hiring decisions and are not a substitute for human review. We maintain a current list of subprocessors and the categories of data each receives, available on request to hunter@placement.solutions.

7. International transfers (including China)

We operate from the United States, and the data we control is stored on our own servers in the United States. By using the Services and submitting content for AI processing, you understand and consent to these international transfers. Where required by law, we rely on appropriate safeguards and will provide further detail on request.

8. How we share information

We do not sell your personal information. We share it only as described here:

• AI and infrastructure subprocessors described in Section 6, which process data on our behalf.
• Stripe, our payment processor, for paid accounts (see Section 9).
• Google, which provides Google Tag Manager and Google Analytics and receives the analytics and measurement data described in Section 8A.
• Resend, our transactional email processor, which sends sign-in links and account email on our behalf (Resend delivers through Amazon SES).
• Recruiters and Employers, when you apply to a role or when a Recruiter account lawfully accesses Candidate Data.
• Legal and safety disclosures, where required by law, to enforce our Terms, or to protect the rights, property, or safety of our users or others.

Recruiters who access Candidate Data through the Services act as independent controllers of that data and are responsible for their own lawful use of it. If you are a candidate whose data was uploaded by a Recruiter, you may also contact that Recruiter directly to exercise your rights.

8A. Analytics, measurement, and advertising

We use Google Tag Manager (container GTM-TK7W5NC3) to load measurement tags on every page of placement.solutions, portal.placement.solutions, and api.placement.solutions. Through Tag Manager we run Google Analytics 4 (measurement ID G-CG9S7CEDPP), which collects page views, approximate location derived from your IP address, device and browser information, and product interaction events such as resume upload progress, job matches viewed, account creation, plan checkout clicks, and sales contact clicks. We use Google Consent Mode v2; for visitors in the United States, consent defaults to granted. Google Analytics sets the _ga and _ga_* cookies, each lasting 2 years.

First-party event log. The same product interaction events are also logged to our own database (user_activity_log), keyed to your account or portal session. We use this first-party log for product improvement and support. We do not sell it.

Advertising pixels. We may enable the Meta Pixel (Meta Platforms) and the LinkedIn Insight Tag (LinkedIn) for advertising measurement and to build retargeting audiences. When enabled, these set cookies such as _fbp (Meta, 90 days) and li_sugr, lidc, and bcookie (LinkedIn).

You can opt out of this measurement with the Google Analytics opt-out browser add-on, your browser's cookie controls, Meta ad preferences, LinkedIn ad settings, and the Digital Advertising Alliance opt-out tool. Cookie-level detail is in our Cookie Policy.

9. Payments and billing data

Payments for subscriptions and credit packs are processed by our third-party payment processor, Stripe, Inc. When you make a purchase, your card or payment details are collected and processed directly by Stripe under Stripe’s own terms and privacy policy. CestoneAI Holdings LLC does not receive or store your full payment card number, expiration, or security code (CVV) on our servers.

We retain only limited billing records needed to operate your account, such as your subscription tier, your credit balance and credit ledger, a Stripe customer identifier, a Stripe subscription identifier, and transaction status returned to us by Stripe. To operate billing and prevent abuse, we also keep records of your purchases, credit grants, and per-action credit consumption (including timestamps, the action performed, and the number of credits charged). We may process these billing records, account activity, and limited technical signals (such as IP-derived signals and rate-limit counters) to detect and prevent payment fraud, investigate suspected misuse of credits or the free portal, and respond to chargebacks or payment disputes — in which case we may share relevant transaction and usage records with Stripe and the applicable card networks or financial institutions to resolve the matter.

The free job-seeker portal does not require payment information to build or download a resume or to receive AI job matches. If a Job Seeker chooses the optional Candidate Pro+ subscription, or purchases the one-time Professional Recruiter Resume Consult, payment is processed by Stripe as described above, our recruiting staff additionally receive the resume and target roles submitted for a Consult (including by email) to perform the human review, and we retain the corresponding limited billing and intake records.

10. Data retention and deletion

We retain your resume, profile, embeddings, applications, saved jobs, match results, and related records for as long as your account or portal profile is active and as needed to provide the Services, and thereafter only as required to comply with legal obligations, resolve disputes, and enforce our agreements. Security and operational logs (such as activity, session, and usage records) are retained for a limited period for security, abuse-prevention, and billing-audit purposes and are then deleted or de-identified.

When you delete your account through the in-product danger zone, we apply a soft-delete: we flag your account and your associated resumes and client records, retain the data for thirty (30) days to allow recovery, and then remove it from active systems. (For security reasons, administrator/“god” accounts cannot self-delete.) Deleting your resume removes it and its derived profile and embeddings from active use, along with your associated job applications, saved jobs, and match results. Residual copies may persist briefly in routine backups and are overwritten on our normal backup-rotation cycle; AI-provider logs may also persist for a limited additional period before they age out.

Anonymous (no-account) drafts. If you use the resume maker without creating an account, your draft resume and its temporary share link are tied to a 30-day anonymous session token. If you do not create an account to claim the draft, the anonymous draft, its link, and the session token are retained only for that session window and are then purged from active systems.

11. Security

We maintain administrative and technical measures designed to protect personal information and to detect and respond to security incidents. Data is encrypted in transit using TLS. Account passwords are protected using a salted password hash; newer accounts use the Argon2 algorithm. Session tokens are time-limited and tied to your account, and access to production systems is restricted.

No system is perfectly secure. In the event of a personal-data breach that affects your information, we will investigate, take steps to contain and remediate it, and notify affected users and any regulators where and within the timeframes that applicable law requires. Please report suspected security issues or unauthorized access to hunter@placement.solutions so we can act quickly.

12. Your rights

Subject to applicable law, you may request to access the personal information we hold about you, correct inaccurate information, delete your data, export a copy in a portable format, opt out of certain processing, and confirm that we do not sell your personal information. We will not discriminate against you for exercising these rights.

• Free portal: use the “Export” option on your profile to download your resume as PDF, DOCX, or TXT, and use the “Delete” option to erase your data.
• Account holders: you can export your data and delete your account from the account/profile settings (deletion is the 30-day soft-delete described in Section 10).
• By email: you can make any request, or withdraw consent, by writing to hunter@placement.solutions, and we will respond as required by applicable law.

Depending on where you live, you may have additional rights, such as the right to object to or restrict certain processing or to lodge a complaint with a supervisory authority. If your data was uploaded by a Recruiter who acts as an independent controller, please contact that Recruiter directly.

13. Cookies and tracking

We use cookies, browser local storage, and session tokens to keep you signed in, remember your preferences, secure requests, and support the behavioral analytics described in Section 3. Some are strictly necessary and cannot be turned off without breaking core functionality — for example, our authentication session cookie (ps_token) and short-lived sign-in/OAuth state cookies. The free portal can issue an anonymous session token at upload so you can return to your matches via your private link, and it may use bot-protection technology to prevent abuse of resume uploads.

You can clear cookies and local storage or adjust cookie behavior through your browser settings, but doing so will sign you out and may remove access to your anonymous portal session. For full detail on the specific cookies we set, their purpose, and how to control them, see our separate Cookie Policy.

14. Children

The Services are intended only for adults using them in a professional hiring and job-search context and are not directed to children. We do not knowingly collect personal information from anyone under 18 years of age (and in no case from anyone under 16), and we do not knowingly allow them to upload resumes or create accounts. If we learn that we have collected personal information from a child below the applicable age, we will delete it promptly. If you believe a child has provided us personal information, please contact hunter@placement.solutions.

15. Changes to this Policy

We may update this Policy from time to time. When we make material changes, we will revise the “Last updated” date and, where appropriate, notify account holders by email or in-product notice. Your continued use of the Services after the effective date of a change constitutes acceptance of the updated Policy.

16. Contact

The operator and data controller is CestoneAI Holdings LLC, a Maryland (USA) limited liability company doing business as “Placement Solutions.” For any privacy question, rights request, or subprocessor inquiry, contact us at hunter@placement.solutions. This Policy is governed by the laws of the State of Maryland, USA.