Data Privacy Policy

Effective Date: July 1, 2025 | Version 2.0
HirelyUp LLC | Wyoming, USA | privacy@hirelyup.com

OVERVIEW: HirelyUp LLC (“HirelyUp”, “we”, “us”, or “our”) is committed to protecting your personal data and your right to privacy. This Privacy Policy explains who we are, what personal data we collect about you, how we use it, how we protect it, and what rights you have over it. This policy applies to all users of HirelyUp, clients and freelancers, whether you access the platform through hirelyup.com, our mobile applications, or any other HirelyUp-operated interface.

GDPR, CCPA, and Global Data Protection Compliance

1. Introduction and Our Privacy Commitment

We are designed to comply with:

The General Data Protection Regulation (GDPR), applicable to users in the European Union and European Economic Area
The California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), applicable to California residents
The UK Data Protection Act 2018 and UK GDPR, applicable to UK users
Brazil’s Lei Geral de Proteção de Dados (LGPD), applicable to Brazilian users
All applicable US federal and state privacy laws

2. Data Controller Information

HirelyUp LLC is the data controller for personal data collected through the HirelyUp platform.

Data Controller: HirelyUp LLC
Email: privacy@hirelyup.com
Address: HirelyUp LLC, Wyoming, USA
For EU/UK users, we appoint a Data Protection Representative (DPR) accessible at privacy@hirelyup.com

3. Personal Data We Collect

3.1 Data You Provide Directly. When you register and use HirelyUp, you provide us with:

Identity data: full legal name, username, profile photo, date of birth (for age verification), government-issued ID (for KYC, processed by Stripe)
Contact data: email address, phone number, country, city, timezone
Professional data: work experience, education, skills, portfolio samples, certifications, professional bios
Financial data: bank account details and payment method information (processed and stored by Stripe, we do not store raw payment card or bank details)
Tax data: W-9 or W-8BEN information for IRS compliance (for freelancers receiving payments above reporting thresholds)
Communications: messages sent through our in-app messaging system, video call recordings where consent is given
User-generated content: job descriptions, proposals, reviews, ratings, portfolio items

3.2 Data Collected Automatically. When you use HirelyUp, we automatically collect:

Device and browser data: IP address, browser type and version, operating system, device identifiers
Usage data: pages viewed, features used, time spent on platform, click-stream data, search queries
Cookies and tracking: session cookies, persistent cookies, analytics pixels (see Cookie Policy)
Transaction data: payment history, job history, proposal history, hire/completion records
Log data: server access logs, error logs, security event logs

3.3 Data from Third Parties. We may receive personal data about you from:

Stripe: identity verification status, payment processing records, fraud signals
Social login providers (if applicable): basic profile data if you choose to sign in with Google or LinkedIn
Publicly available sources: professional profile information to help verify credentials

4. How We Use Your Personal Data

4.1 Legal Bases for Processing (GDPR). Under GDPR, we process your personal data on the following legal bases:

Contract performance: processing necessary to provide you with HirelyUp’s services, including account management, job matching, payment processing, and dispute resolution
Legal obligation: processing required to comply with applicable laws including KYC/AML requirements, tax reporting, and law enforcement requests
Legitimate interests: fraud prevention, platform security, product improvement, and business analytics, where these interests are not overridden by your rights
Consent: where you have given specific consent, such as for marketing communications or optional data sharing (you may withdraw consent at any time)

4.2 Purposes of Processing. We use your personal data to:

Provide and operate the HirelyUp platform and all its features
Verify your identity and prevent fraud and money laundering (KYC/AML compliance)
Process payments, manage escrow accounts, and facilitate financial transactions
Match clients with relevant freelancers and display job recommendations
Send transactional emails and in-platform notifications about your account, jobs, and payments
Resolve disputes between clients and freelancers
Provide customer support and respond to your inquiries
Enforce our Terms and Conditions and investigate violations
Analyze platform usage to improve our services and user experience
Comply with legal obligations including tax reporting and law enforcement requests
Send marketing communications about HirelyUp (only with your consent, which you may withdraw at any time)

4.3 What We Will NEVER Do With Your Data. HirelyUp makes the following binding commitments regarding your data:

We will never sell your personal data to third parties for their marketing purposes
We will never share your financial account details with clients, freelancers, or other third parties
We will never use your work product or communications to train AI models without your explicit opt-in consent
We will never share your government-issued ID or KYC documents with clients — only verification status is shared
We will never use your data for any purpose other than those described in this policy without your consent

This is a key difference from some competing platforms. HirelyUp will never default-enroll you in AI training data programs. Any AI-related data use requires your explicit, affirmative opt-in consent.

5. How We Share Your Personal Data

5.1 Sharing Within the Platform. Your public profile information (name, photo, skills, ratings, portfolio) is visible to all registered HirelyUp users. Your contact details are only shared with clients you are actively engaged with through an active contract.

5.2 Third-Party Service Providers. We share your data with carefully vetted third-party service providers who process data on our behalf:

Stripe: payment processing, escrow management, identity verification
Google Workspace: email and communication services
Stream (Stream Chat): in-app messaging infrastructure
Amazon Web Services (AWS) or Google Cloud: platform hosting and data storage
SendGrid: transactional email delivery
HubSpot: customer relationship management (limited contact data only)

All third-party processors are bound by Data Processing Agreements (DPAs) requiring them to process your data only on our instructions and to maintain appropriate security standards.

5.3 Legal Disclosure. We may disclose your personal data to law enforcement, regulatory authorities, or courts when required to do so by applicable law, to protect the rights or safety of HirelyUp users, or to enforce our Terms and investigate fraud.

5.4 Business Transfers. If HirelyUp is involved in a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction. We will notify you via email and prominent platform notice before your data becomes subject to a materially different privacy policy.

6. International Data Transfers

HirelyUp operates from the United States and your data is primarily stored on US-based servers. If you are located in the EU, UK, or other jurisdictions with data transfer restrictions:

Transfers to our US servers are covered by Standard Contractual Clauses (SCCs) approved by the European Commission
We maintain appropriate safeguards for all international data transfers as required by GDPR Chapter V
UK transfers are covered by UK International Data Transfer Agreements (IDTAs)
You may request a copy of the transfer safeguards applicable to your data by emailing privacy@hirelyup.com

7. Data Retention

We retain your personal data for as long as necessary to provide our services and comply with legal obligations:

Active account data: retained for the duration of your account plus 3 years after account closure
Financial and transaction records: 7 years from the date of the transaction (IRS and financial regulation requirements)
KYC and identity verification records: 5 years from account closure (AML compliance)
Marketing consent records: 3 years from last interaction
Security and fraud logs: 2 years
Backup data: overwritten within 90 days of deletion from primary systems

After retention periods expire, your data is securely deleted or anonymized so it can no longer be associated with you.

8. Data Security — How We Protect Your Information

8.1 Technical Security Measures.

Encryption in transit: all data transmitted between your device and HirelyUp is encrypted using TLS 1.2 or higher (HTTPS)
Encryption at rest: all personal data stored on our servers is encrypted using AES-256 encryption
Payment security: all payment data is handled by Stripe, which is PCI DSS Level 1 certified — the highest level of payment security
Access controls: strict role-based access controls (RBAC) limit employee access to personal data to those with a documented business need
Two-factor authentication (2FA): available and strongly recommended for all user accounts
Regular security audits: we conduct regular penetration testing and vulnerability assessments of our platform
Intrusion detection: automated systems monitor for unauthorized access attempts and anomalous behavior

8.2 Organizational Security Measures. All HirelyUp employees and contractors with access to personal data are bound by confidentiality obligations. Employee access to personal data is logged and audited. We maintain an Information Security Policy governing all data handling practices. Security incidents are investigated immediately with root cause analysis and remediation.

8.3 Data Breach Response. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay and no later than 72 hours after becoming aware of the breach (as required by GDPR Article 33). Our breach notification will include a description of the nature of the breach and categories of data affected, the likely consequences of the breach, the measures taken to address the breach, and steps you can take to protect yourself.

HirelyUp will never request your password via email or phone. If you receive any such request, it is a phishing attempt — report it immediately to security@hirelyup.com.

9. Your Privacy Rights

9.1 Rights for All Users. All HirelyUp users have the following rights regarding their personal data:

Right to access: you may request a complete copy of all personal data we hold about you at any time
Right to rectification: you may correct inaccurate personal data directly in your account settings or by contacting us
Right to deletion (right to be forgotten): you may request deletion of your personal data, subject to our legal retention obligations
Right to data portability: you may request your data in a machine-readable format (JSON or CSV) for transfer to another service
Right to restrict processing: you may request that we limit how we use your data in certain circumstances
Right to withdraw consent: where we process data based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing

9.2 Additional Rights for EU/UK Users (GDPR).

Right to object: you may object to processing based on legitimate interests, including direct marketing
Right to not be subject to automated decisions: we do not make legally significant decisions about you based solely on automated processing without human review
Right to lodge a complaint: you have the right to complain to your local supervisory authority — for EU users, find your national DPA at edpb.europa.eu

9.3 Additional Rights for California Residents (CCPA/CPRA).

Right to know: you may request information about the categories of personal information we collect, use, disclose, or sell
Right to opt-out of sale: we do not sell personal information. If this changes, you will have the right to opt out
Right to non-discrimination: we will not discriminate against you for exercising your CCPA rights
Right to limit use of sensitive personal information: you may limit our use of sensitive personal information to necessary service provision

9.4 Exercising Your Rights. To exercise any of your privacy rights, contact us at privacy@hirelyup.com with the subject line “Privacy Rights Request.” We will respond within 30 days (45 days for complex requests, with notice of the extension). We may need to verify your identity before processing your request. Rights requests are free of charge, though we may charge a reasonable fee for manifestly excessive or repetitive requests.

10. Cookies and Tracking Technologies

HirelyUp uses cookies and similar tracking technologies. You can manage your cookie preferences through your browser settings or our Cookie Preferences center available on the platform. We use:

Strictly necessary cookies: essential for platform functionality — cannot be disabled
Performance and analytics cookies: help us understand platform usage (requires consent in EU/UK)
Functional cookies: remember your preferences and settings
Marketing cookies: used for targeted advertising (only with explicit consent — currently disabled on HirelyUp)

A full Cookie Policy is available at hirelyup.com/cookies.

11. Children’s Privacy

HirelyUp is not directed at children under 18 years of age. We do not knowingly collect personal data from minors. If you believe a child has provided us with personal data, contact us at privacy@hirelyup.com and we will delete it promptly.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be communicated by email and prominent in-platform notice at least 30 days before taking effect. Your continued use of HirelyUp after the effective date constitutes acceptance of the revised policy. We maintain an archive of previous versions accessible at hirelyup.com/privacy-history.

13. Privacy Contact and Data Protection Officer

Privacy inquiries: privacy@hirelyup.com
Data deletion requests: privacy@hirelyup.com — Subject: Data Deletion Request
Data access requests: privacy@hirelyup.com — Subject: Data Access Request
Security incidents: security@hirelyup.com
Address: HirelyUp LLC, Wyoming, USA