DRAFT / Counsel Review — awaiting verified legal approval
Applicant & Employer Privacy Notice
Last updated October 15, 2026. This document is a working draft and is not final until reviewed by counsel.
Proposed legal issuer: MULLER MANAGEMENT CORP. Proposed trade brand: THE HIRING CIRCLE — DBA planned / not filed. Corporate standing, jurisdictional status and legal authority require verification; no Florida registration or domestication is asserted.
Version 2026-10-15-draft-1 · Reading a draft is not signing an agreement.
Scope and status
THE HIRING CIRCLE is the proposed trade brand / DBA of MULLER MANAGEMENT CORP. DBA registration and current entity/jurisdictional status remain unverified. Salaried direct-hire hospitality recruiting is limited to New York City and Miami. The agency does not employ workers, process payroll, sponsor visas or promise immigration outcomes. Candidates never pay placement fees. This is a proposed notice for counsel review, not an assertion of privacy certification or verified registration.
Information collected
Applicants: legal/preferred name, contact details, worldwide residence, target city, professional experience, annual salary expectation, availability, languages, relocation preferences, self-reported work authorization/sponsorship needs, CVs and optional certificates, portfolio and consented photo. Employers: business and hiring-contact details, venue images, job descriptions, annual salary ranges, openings, requirements, interviews and placement/billing records. Accounts and signing workflows also handle authentication information, agreement versions, affirmative actions, typed signer name, timestamps and hashes; IP recording for signing requires the presented consent where enabled. Technical processing includes session data, device/user-agent metadata where recorded, and hashed network identifiers for intake abuse prevention. Do not submit SSNs, passports, banking credentials or unrelated medical/protected-trait information.
Purposes and basis for processing
Use information for account access, human-reviewed recruiting, communication within the portal, candidate-authorized introductions, interviews, placement administration, draft billing, security, rights requests and required recordkeeping. Counsel must determine applicable legal bases and disclosures for US and any overseas applicants; this draft does not assume consent is the correct basis for every purpose.
Disclosure and confidentiality
Founders can access recruiting records for authorized operations. Employer access to candidate identity/contact/current shared CV requires candidate consent specific to the match, both parties’ applicable signed agreements and founder-approved introduction. Interest is not sharing consent. Anonymous summaries precede clearance. Signed copies and private files use authorized temporary links. Withdrawing sharing consent stops future access through the portal; it cannot recall information already lawfully received or screenshots/downloads. Employers must honor the applicable confidentiality terms.
Providers, storage and transfers
Lovable Cloud hosts the connected account database and private file storage. Authentication, hosting and operational service providers may process information to deliver the service. A verified provider/subprocessor inventory, actual storage regions, cross-border transfer assessment and contractual arrangements remain a counsel/owner launch prerequisite; no US-only storage or complete vendor list is asserted. No third-party background-check or live payment integration is enabled.
Retention and legal holds
A final purpose-specific retention schedule is not approved. Access-controlled records are retained pending review; signed agreements/audit evidence may require different retention from CVs. Requests to delete files or accounts enter a review queue, not an instant-erasure promise. Legal holds pause deletion until authorized review/release; a hold review date does not automatically expire the hold. Document versions may be retained privately. No fixed mandatory period or universal right to erase immutable legal records is claimed.
Rights and requests
Signed-in candidates and employers can request a copy, correction through their profile, sharing withdrawal and deletion in Privacy & data requests; they can download an account-data export containing their own records, not other people’s private data or founder notes. Deletion/account closure and retained legal records require identity, applicability and hold review. Applicable rights, exceptions and response deadlines depend on jurisdiction and counsel assessment. Job discrimination, accessibility and privacy concerns can be recorded through the authenticated reporting form. The displayed contact@thehiringcircle.com address is a placeholder until mailbox activation; do not rely on email delivery yet.
Security and incident handling
Role-scoped access, private storage, temporary authorized download links and file type/size checks reduce risk; they do not guarantee security. Incident-response duties, NY SHIELD applicability, notifications, backups and deletion verification need documented owner/counsel review. No sale, marketing-cookie or automated-screening functionality is implemented in the inspected application; future changes require notice review.
Children and notice changes
The service is intended for adult professional applicants and authorized employer representatives, not children. Age eligibility and any lawful verification process require counsel review; no discriminatory age filter is used. Material notice changes create a new version and may require a new affirmative action. This draft is not a final agreement.