Table of Contents

1

Information We Collect

1.1 User Account Information

When you register for a RecruiterX account, we collect:

1.2 Healthcare Provider Data (NPPES)

Our platform maintains a database of 6.9 million+ healthcare provider records sourced from the National Plan and Provider Enumeration System (NPPES), a publicly available federal database. This data includes:

1.3 Enrichment Data

When users initiate enrichment of provider records, we may obtain additional contact information from licensed third-party data providers, including:

1.4 Usage and Interaction Data

1.5 Payment Data

Payment processing is handled by a PCI-compliant third-party payment processor. We do not store full credit card numbers on our servers. We may retain:

1.6 Communication Data

When candidates respond to outreach campaigns, we collect:

2

How We Use Information

We use the information we collect for the following purposes:

2.1 Recruitment Operations

2.2 Data Enrichment

2.3 Platform Improvement and Analytics

2.4 Account Management

3

Data Sources

RecruiterX obtains provider data from the following sources:

3.1 NPPES (National Plan and Provider Enumeration System)

The primary source for our provider database. NPPES is a publicly available registry maintained by the Centers for Medicare & Medicaid Services (CMS). All NPI data is public information published by the federal government and freely accessible at npiregistry.cms.hhs.gov.

3.2 Third-Party Enrichment Services

We utilize licensed third-party data enrichment services to obtain verified business email addresses, phone numbers, current employer information, and LinkedIn profile URLs. Data is obtained through licensed API access in compliance with each provider's terms of service.

3.3 User-Provided Data

Information that users directly provide when creating accounts, uploading job descriptions, configuring campaigns, or interacting with our platform features.

3.4 Candidate-Provided Data

Information that healthcare providers voluntarily share when responding to outreach campaigns, including updated contact information, availability, and professional preferences.

4

Information Sharing and Disclosure

We do not sell personal information. We share data only in the following circumstances:

4.1 Service Providers

4.2 Business Purposes

4.3 Legal Requirements

We may disclose information when required by law, regulation, legal process, or governmental request, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

4.4 Business Transfers

In the event of a merger, acquisition, or sale of all or a portion of our assets, personal information may be transferred as part of that transaction. We will notify affected users of any change in ownership or control of personal information.

5

Data Security

We implement appropriate technical and organizational measures to protect information, including:

5.1 Technical Safeguards

5.2 Organizational Safeguards

Important: No method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

6

Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

6.1 Access and Portability

You may request a copy of the personal information we hold about you. For registered users, much of this information is accessible through your account settings.

6.2 Correction

You may request that we correct any inaccurate personal information. Healthcare providers who believe their contact information in our database is incorrect may contact us for correction.

6.3 Deletion

You may request deletion of your personal information, subject to certain exceptions (such as legal retention requirements). For registered users, we will delete your account and associated data upon verified request. For healthcare providers in our database, please see Section 6.5 below.

6.4 Opt-Out of Campaigns

Healthcare providers who receive SMS or email outreach may opt out at any time:

All opt-out requests are processed immediately and the opt-out status is permanently recorded in our database to prevent future contact.

6.5 Provider Data Requests

Healthcare providers whose information appears in our database (sourced from the public NPPES registry) may:

6.6 California Residents (CCPA)

California residents have additional rights under the California Consumer Privacy Act, including the right to know what personal information is collected, the right to request deletion, and the right to opt out of the sale of personal information. We do not sell personal information.

To exercise any of these rights, contact us at support@recruiterx.ai.

7

TCPA Compliance

RecruiterX is committed to compliance with the Telephone Consumer Protection Act (TCPA) and all applicable telecommunications regulations.

7.1 Prior Express Consent

Our platform is designed to support our users' compliance with TCPA requirements:

7.2 Opt-Out Mechanisms

7.3 Quiet Hours

RecruiterX enforces quiet hours restrictions on outbound messaging:

7.4 Wrong Number Handling

When a phone number is identified as a wrong number (i.e., no longer belonging to the intended provider), it is permanently logged against that NPI in our database to prevent future contact attempts to that number.

7.5 Do Not Call Registry

Our platform provides mechanisms to check and honor the National Do Not Call Registry. Users are responsible for ensuring their outreach activities comply with all applicable Do Not Call requirements.

8

Healthcare Data Notice

RecruiterX is NOT a HIPAA-covered entity. We do not collect, store, process, or transmit Protected Health Information (PHI) as defined under the Health Insurance Portability and Accountability Act (HIPAA).

8.1 What We Do Store

Our database contains only the following categories of healthcare-related data:

8.2 What We Do NOT Store

8.3 NPI Data Is Public Information

The National Provider Identifier (NPI) and associated data in the NPPES registry are designated as public information by the Centers for Medicare & Medicaid Services (CMS) and are freely available for download at download.cms.gov/nppes. Our use of this data is consistent with its public availability and intended purpose.

9

Cookies and Tracking

9.1 Cookies We Use

9.2 Local Storage

We use browser local storage to cache certain data for performance optimization, including:

9.3 Third-Party Tracking

We do not use third-party advertising trackers. We may use privacy-respecting analytics tools to understand platform usage patterns. We do not participate in cross-site tracking or advertising networks.

10

Data Retention

10.1 User Account Data

Account data is retained for as long as your account remains active. Upon account deletion request, we will delete or anonymize your personal data within 30 days, except where retention is required by law.

10.2 Provider Database Records

NPPES-sourced provider records are maintained indefinitely as they are sourced from a continuously updated public registry. Enrichment data (contact information obtained from licensed third-party data providers) is retained to prevent redundant paid lookups and is refreshed periodically to ensure accuracy.

10.3 Campaign and Communication Data

SMS and email campaign records, including message content and delivery status, are retained for a minimum of 5 years to support compliance with TCPA and other telecommunications regulations, and to maintain opt-out records.

10.4 AI Conversation Logs

Conversations conducted through our Solomon AI system are retained for quality assurance, training, and compliance purposes. Conversation data may be anonymized after 12 months.

10.5 Payment Records

Transaction records and billing history are retained for a minimum of 7 years in accordance with applicable tax and accounting regulations.

11

Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will:

Your continued use of RecruiterX after changes become effective constitutes your acceptance of the revised policy. We encourage you to review this page periodically for the latest information on our privacy practices.

12

Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

RecruiterX Privacy Inquiries

Operated by Teleias, LLC

Christian Claudio, Data Controller

Email: support@recruiterx.ai

Website: www.recruiterx.ai

We aim to respond to all privacy-related inquiries within 30 days.