Applicant Privacy Notice 

Last Updated: 2/4/2026

This Applicant Privacy Notice explains how Foley.io collects, uses, stores, and shares personal information about job applicants and candidates.

This notice applies to all individuals who apply for employment with us in:

Arizona, Colorado, Connecticut, Florida, Georgia, Illinois, Indiana, Kansas,
Massachusetts, Michigan, Nebraska, New Hampshire, New Jersey, New York, North 
Carolina, Pennsylvania, South Carolina, Tennessee, Texas, Virginia, and Wisconsin.

Personal Information We Collect

We collect the following categories of information during the recruiting and hiring process:

Information You Provide Directly

• Name, contact information, address

• Resume/CV and employment history

• Education information

• Skills, qualifications, certifications

• Cover letters, writing samples, portfolios

• Salary expectations

• Work authorization status

Information Collected During Interviews and Assessment

• Interview notes

• Assessment or test results

• Communications between you and our recruiting team

• Criminal history (as permitted by state law)

• Employment verification

• Education verification

• Credit verification (if relevant to role)

• Professional licenses

• Drug test results

These screenings are conducted only after a conditional offer of employment and are managed by third-party background-check providers in compliance with the Federal Fair Credit Reporting Act (FCRA) and applicable state laws.

Voluntary EEO / Demographic Data

We may collect voluntary demographic information such as:

• Gender

• Race/ethnicity

• Veteran status

• Disability status

Providing this information is optional, and it is not used in hiring decisions.

Information Collected Automatically Through Ashby ATS

• IP address

• Browser information

• Device details

• Usage data related to the application portal

Because Ashby is a third party service provider, your use of that site or service may also be subject to the provider’s own terms and privacy notice. We are not responsible for the privacy practices of those providers in connection with information they collect and use for their own independent purposes.

Where We Collect Personal Information From

We may collect applicant data from:

• Directly from you

• Employee referrals

• Recruiters or staffing agencies

• Publicly available professional profiles (e.g., LinkedIn)

• Background-check vendors

• Assessment providers

• Ashby application platform

Purposes for Processing Applicant

Information

 We process your information for

• Reviewing applications and qualification

• Scheduling and conducting interviews

• Assessing suitability for employment

• Communicating with you throughout the hiring process

• Conducting background checks and drug testing

• Complying with federal, state, and local law

• Maintaining records of our hiring decisions 

• Improving our recruitment processes

 If hired, certain information will become part of your employee record.

Legal Bases

For jurisdictions that require disclosure of legal bases (e.g., Colorado CPA), we process your data under:

• Legitimate interests (staffing and workforce management)

• Compliance with legal obligations (e.g., right-to-work verification, FCRA)

• Consent (only when required, such as EEO voluntary data)

• Pre-contractual necessity (reviewing your application at your request)

We do not sell your personal data.

How We Share Your Information

We may share your data with:

• Ashby ATS (application processing)

• Background-check vendors

• Drug testing providers 

• Assessment tools (if used for specific roles)

•  Recruitment agencies 

•  Cloud hosting providers 

• Professional advisors (legal or compliance)

• Government agencies where required by law

We do not sell or share applicant data for cross-context behavioral advertising.

Data Retention

We retain applicant data for a period necessary to:

• Evaluate candidates

• Maintain hiring records

• Comply with applicable legal requirements (including anti-discrimination laws)

Typically, we retain applicant data for 1–3 years, depending on state requirements and litigation risk. If you are hired, your data becomes part of your personnel file.

Your Privacy Rights

Depending on your state of residence, you may have rights to:

• Access your personal data

• Correct inaccuracies

• Delete your personal data

• Obtain a copy of your data

• Opt out of certain types of data processing (where applicable)

To exercise these rights, contact us at: legal@foley.io

We will verify your identity before responding.

Background Check & Drug Screen Notice

Before conducting a background check, we will provide:

• A standalone FCRA disclosure

• A written authorization form

• Any applicable state-specific notices

We use a third‑party background check provider to obtain background reports on applicants and candidates where permitted by applicable law and appropriate for the role. That provider collects and processes your personal information in accordance with its own terms and privacy notice.

If any adverse action is taken based on a background check, you may receive:

• A pre-adverse action notice

• A copy of the report

• A summary of your rights under FCRA

Security Measures

We implement administrative, technical, and physical safeguards designed to protect personal information, including:

• Access controls

• Encryption

• Secure cloud hosting

• Limited personnel access

No system is perfectly secure, and we cannot guarantee the security of your data.

General Disclaimer

This Applicant Privacy Notice is provided for informational purposes only and does not create any contractual rights or obligations between Foley and any applicant, candidate, or other individual. It is not a guarantee of employment or of any particular terms or conditions of employment.

We may update or modify this Applicant Privacy Notice from time to time to reflect changes in our data practices or applicable legal requirements. Changes will be posted on our website or application portal with a revised “Last Updated” date.

Nothing in this Applicant Privacy Notice is intended to limit any rights you may have under applicable law or to expand any obligations we have beyond those required by such law. In the event of any conflict between this Applicant Privacy Notice and applicable law, the applicable law will govern.

This Applicant Privacy Notice applies only to information collected in connection with your application or candidacy for a position with us and does not govern your use of our websites, products, or services in any other context, which may be subject to separate terms and privacy notices.

To the fullest extent permitted by applicable law, we disclaim responsibility for any loss or damage arising from your use of electronic means to submit application materials or to communicate with us, including, without limitation, any loss or damage arising from security breaches or technical failures that are beyond our reasonable control.

Contact Us

For questions about this policy or your privacy rights, contact:

You can reach us by email at legal@foley.io or at the following mailing address:

140 Huyshope Avenue

Hartford, CT 06106

Phone: (860) 791-9305