Privacy is part of professional recruitment.

01

Scope and application

Angerstein Global Risk Management LLC ("Angerstein," "AGRM," "we," "our," or "us") respects the privacy of candidates, prospective candidates, clients, prospective clients, business contacts, website visitors, service providers, and other individuals with whom we interact.

This Privacy Policy explains how we collect, use, maintain, process, disclose, protect, and otherwise handle personal information in connection with our direct-hire recruitment, candidate sourcing, business development, website, communications, and related professional services.

Nothing in this Policy creates an employment relationship between Angerstein and a candidate, guarantees referral to an employer, guarantees an interview or employment, or limits an employer's independent hiring authority.

• www.angersteingrm.com and Angerstein-operated pages linking to this Policy
• candidate registration, résumé submission, job-interest, and future application processes
• employer inquiries and recruitment engagements
• telephone, voicemail, email, text message, and other communications
• recruitment, applicant-tracking, customer-relationship-management, scheduling, sourcing, or related platforms Angerstein may use
• professional networking platforms, job boards, business directories, lawful public sources, and referrals
• in-person, electronic, and other business interactions

02

Candidate and prospective-candidate information

The information collected depends on the nature of your interaction. Angerstein may maintain professional observations or recruiting notes concerning qualifications, experience, stated employment preferences, communications, and suitability for particular opportunities when maintained for legitimate recruitment purposes and in accordance with applicable law.

Angerstein does not make an employer's final hiring decision.

• name, email address, telephone number, and general geographic location
• résumé or curriculum vitae, employment history, job titles, occupational experience, and education
• professional qualifications, licenses, certifications, skills, languages, and portfolio information
• compensation expectations, desired employment type, geographic preferences, and availability
• professional references and publicly available professional information
• information provided during screening or recruitment conversations
• positions of interest, interview availability, scheduling information, and communications
• information concerning referrals, interviews, offers, placements, and other recruitment activity
• other information voluntarily provided that is reasonably related to recruitment services

03

Employer, client, and business-contact information

When you communicate with Angerstein on behalf of an employer, prospective employer, vendor, professional organization, or other business, we may collect information reasonably necessary to establish, perform, administer, or evaluate that relationship.

• name, professional title, employer or organization, business email, telephone number, and business address
• job requisitions, position descriptions, compensation information, hiring requirements, and desired qualifications
• recruitment priorities, interview availability, correspondence, contracts, and engagement information
• billing or invoicing information where applicable

04

Information obtained from other sources

Angerstein may lawfully obtain professional information from employers, references, referrals, public websites, professional networking platforms, job boards, business directories, professional licensing databases, public government records, service providers, recruitment technology providers, and other lawful professional or commercial sources.

Where appropriate, Angerstein may contact a person whose professional information indicates potential suitability for an opportunity even when that person did not initially submit information directly to us. The person has no obligation to participate.

05

Website and technical information

When you visit an Angerstein website or interact with electronic communications, Angerstein or its hosting and technology providers may automatically process limited technical information for security, administration, troubleshooting, fraud prevention, performance, and service improvement.

• Internet Protocol address, browser type, operating system, and device information
• approximate location derived from an IP address, referring website, pages viewed, and access time
• website navigation, interaction, cookie or similar identifiers, and diagnostic information

06

How personal information may be used

Angerstein may use personal information for legitimate recruitment, client-service, operational, legal, security, and administrative purposes.

07

Candidate submission to employers

Candidate confidentiality is important to Angerstein. As a matter of practice, we intend to obtain candidate authorization before providing a prospective employer with a personally identifiable résumé, curriculum vitae, or substantially complete identifiable professional profile for a particular opportunity, except where another lawful basis permits disclosure.

Angerstein may discuss general or non-identifying candidate-market information without identifying a particular person. Once candidate information is provided to an employer, that independent employer may process it under its own privacy, recruitment, employment, recordkeeping, and legal obligations.

08

How information may be disclosed

Personal information may be disclosed where reasonably necessary and legally permissible to the following categories of recipients.

09

Candidate fees and sale of information

Angerstein does not sell candidate résumés or candidate contact information to data brokers. Angerstein does not require candidates to pay for referral to an employer or consideration for an employment opportunity.

Angerstein may receive compensation from an employer under a written recruitment agreement when an agreed placement or hiring event occurs. That commercial arrangement is separate from the candidate's privacy rights and is not treated by Angerstein as the sale of a résumé.

Some privacy statutes define sale or sharing more broadly than an ordinary monetary transaction. If an Angerstein activity becomes regulated as sale, sharing, targeted advertising, or similar processing, we will provide any notice and choice required by applicable law.

10

Sensitive personal information

Do not send highly sensitive information unless Angerstein specifically requests it for a legitimate and lawful purpose through an appropriate communication method. Candidates should not place unnecessary sensitive information in résumés.

• Social Security numbers, bank or payment-card information, passwords, and account credentials
• complete driver's-license, passport, immigration-document, or government-identification numbers
• medical records, detailed medical information, genetic or biometric information
• full dates of birth, confidential financial records, or other information unnecessary for recruitment

11

Equal employment and protected information

Angerstein is committed to lawful recruitment practices. Race, color, religion, sex, pregnancy, national origin, age, disability, genetic information, and other characteristics protected by applicable law will not be used for an unlawful discriminatory referral or recruitment purpose.

Where protected information is voluntarily provided, required by law, or lawfully collected for compliance purposes, it will be used and maintained only as legally permissible and appropriate. Angerstein may refuse an employer instruction or criterion that we reasonably believe would require unlawful discrimination.

12

Artificial intelligence and software-assisted recruitment

Angerstein may use software-assisted tools, automation, or artificial-intelligence-enabled systems to support resume parsing, organization, skills identification, candidate searching, comparison with stated job requirements, scheduling, transcription, communication support, database organization, duplicate detection, and administrative workflow.

Technology is intended to assist human recruiting activity rather than replace professional judgment. Angerstein does not make an employer's final hiring decision and does not knowingly use an automated system as the sole basis for a final employment decision on behalf of an independent employer.

Where law requires additional notice, consent, assessment, human review, or other protection for automated processing, Angerstein will provide it. We prohibit intentional use of technology for unlawful discrimination.

13

Background checks and consumer reports

Angerstein does not request background-check information through ordinary website contact forms or unsecured email. If Angerstein or an employer determines that a consumer report, criminal-history search, motor-vehicle record, employment verification, or similar screening is appropriate, the process may require separate disclosures, authorizations, privacy notices, and legally mandated procedures.

14

Cookies, telephone, text, and email communications

Angerstein's website and service providers may use cookies or similar technology for functionality, security, abuse prevention, preferences, diagnostics, performance, and traffic analysis. Browser settings may limit these technologies, but doing so can affect functionality. Angerstein will provide consent or opt-out mechanisms when required by law.

If you provide contact information, Angerstein may communicate about recruitment opportunities, searches, employer inquiries, scheduling, relationship administration, requested information, security, and other matters reasonably related to your interaction with us. Message and data rates may apply to text messages.

Where specific consent is legally required for automated calls, texts, or marketing, Angerstein will obtain it. Opting out of promotional messages does not prevent appropriate transactional, recruitment, security, or legal communications.

15

Data security and minimization

Angerstein uses reasonable administrative, technical, and organizational measures appropriate to its operations and designed to protect personal information from unauthorized access, acquisition, misuse, alteration, disclosure, accidental loss, and destruction.

Measures may include access controls, password protection, multi-factor authentication, restricted record access, secure communications, system updates, confidentiality obligations, data minimization, secure disposal, backup, vendor review, and incident response. Access should be limited to persons and providers with a legitimate business need.

No electronic transmission, cloud service, email system, website, or storage method can be guaranteed completely secure. Please provide only information reasonably necessary for the interaction and contact Angerstein promptly if you believe information has been compromised.

16

Data retention and future opportunities

Angerstein retains information for periods reasonably necessary to provide recruitment services, maintain candidate and client relationships, consider future opportunities, perform contracts, document recruitment activity, resolve disputes, prevent fraud, protect rights, and satisfy applicable recordkeeping obligations.

Records subject to a legal hold, investigation, discrimination charge, regulatory matter, litigation, contractual dispute, or other proceeding may be kept until the matter is resolved. When information is no longer reasonably necessary and no retention obligation applies, it may be deleted, destroyed, anonymized, or de-identified. Residual copies may remain temporarily in secure backups.

Unless a candidate requests otherwise, Angerstein may retain professional candidate information for future opportunities. Certain records may still be retained when necessary for law, documentation, fraud prevention, opt-out suppression, or legal rights.

17

Privacy rights and requests

Depending on residence, relationship, and applicable law, a person may have rights to confirmation, access, correction, deletion, portability, withdrawal of consent, restriction, objection, or opt-out from certain sale, sharing, targeted advertising, profiling, or automated processing. Applicable rights remain subject to statutory definitions, exemptions, verification, recordkeeping, and other legal limits.

Angerstein will not unlawfully discriminate against a person for exercising an applicable privacy right. We may take reasonable steps to verify identity and authority. An authorized agent may act where law permits, subject to appropriate proof and verification.

Submit a request by telephone or email using the Privacy Contact information below. A Texas privacy appeal should state “Texas Privacy Appeal” in the subject line or request.

18

Texas, California, and other U.S. state notices

Texas residents may have rights under the Texas Data Privacy and Security Act where that law applies, including rights concerning access, correction, deletion, portability, and opt-out from qualifying targeted advertising, sale, or profiling. Texas law contains definitions, exclusions, and exemptions, including distinctions for information processed in employment or commercial contexts. Qualifying appeals will be handled as required by law.

Where the California Consumer Privacy Act applies, California residents may have rights to know categories and specific pieces of personal information, sources, purposes, recipient categories, access, deletion, correction, opt-out from qualifying sale or sharing, limitation of certain sensitive-information uses, and non-discrimination.

Residents of other states may have additional rights concerning access, correction, deletion, portability, targeted advertising, sale, profiling, sensitive data, or appeals. Angerstein will honor legally applicable rights and does not intend to waive any non-waivable right.

19

Third-party websites, platforms, and employer practices

Links may lead to independent employer websites, job boards, networking platforms, media services, Google translation services, or other third parties. Angerstein does not control their independent privacy practices, and a link does not mean the third party follows this Policy. Review the third party's notice before providing information.

Angerstein may use hosting, productivity, communications, security, analytics, mapping, or other technology supplied by Google or other providers. Those providers may independently process device, technical, cookie, account, or usage information under their own terms.

Employers are independent organizations. After lawful candidate disclosure, an employer may independently process information for recruitment, interviewing, assessment, employment, screening, compliance, recordkeeping, and human-resources purposes under its own policies and legal duties.

20

International users and children's privacy

Angerstein is a United States company headquartered in Texas. Information may be processed in the United States or another jurisdiction where an authorized provider maintains systems. Laws differ by jurisdiction. Before undertaking regulated international processing, Angerstein will implement any required transfer mechanism, local representative, consent, contractual protection, or additional notice.

The website and recruitment services are not directed to children under 13. Angerstein does not knowingly collect personal information online from a child under 13 without legally required authorization and will take appropriate action if it learns that such information was collected unlawfully.

21

Recruitment fraud, security incidents, and legal preservation

Angerstein will not require a candidate to purchase cryptocurrency, gift cards, equipment, software, training, or other products as a condition of consideration. Do not provide banking credentials, passwords, payment-card information, or other financial credentials in response to an unsolicited message. Verify suspicious communications using the contact information published on this website.

Angerstein maintains procedures intended to evaluate and respond to suspected unauthorized access. Where an incident creates a legally defined breach, required notices will be provided within applicable requirements.

Nothing in this Policy requires deletion, alteration, disclosure, or other processing that would violate law. Information may be preserved where reasonably necessary or permitted for legal compliance, litigation, administrative proceedings, discrimination charges, subpoenas, investigations, disputes, fraud prevention, security, accounting, or establishment and defense of legal claims.

22

Changes and governing effect

Angerstein may revise this Policy to reflect changes in law, technology, recruiting systems, website functionality, services, vendors, privacy practices, or business operations. The current version will identify its last-updated date, and any additional notice or consent required for a material change will be provided.

This Policy describes privacy practices and does not create contractual rights beyond applicable law or an independently enforceable written agreement. If a specific candidate authorization, client agreement, consent, disclosure, or jurisdiction-specific notice applies to an activity, the more specific document governs to the extent of conflict. No provision is intended to waive a right that cannot lawfully be waived.