Personal Information Notice
Version 1.0 · Updated 19 October 2026 · Effective 16 October 2026
This notice provides the detailed information for people whose Personal Data is processed through F2D (Fast to Data) and should be read alongside our Privacy Policy. For F2D information, this notice takes precedence if the notices differ. Our Privacy Policy covers other relationships with MiraDay, including accounts and website use.
At a glance
Why this matters to you. MiraDay maintains F2D, its recruiting data infrastructure bringing together professional profiles, company information and job information. Employers and recruiters use professional profiles and related recruiting information in F2D to find candidates. Your profile may be in it even if you have never signed up to MiraDay or applied for a job through us. We obtain information from professional public sources, licensed data providers, Customers through the Contribution Channel, and profile pages captured using the Extension.
What we do. We verify and enrich professional profiles, match and rank them against roles, and deliver relevant F2D Data to Customers for Recruiting Purposes. Customer Content and Contributed Fields, including copies and derivatives, are not used to train, fine-tune or improve our own or third-party models. Independently obtained public or licensed F2D fields have the separate, limited matching and ranking uses described in Section 5.5. Customers may not use delivered F2D Data or its derivatives to train, fine-tune or improve AI models, including internal recruiting models. The order and relevance of a result can affect whether and when a recruiter reviews your profile. Outputs are suggestions for human review, not final hiring decisions.
Your choices. You can check whether we hold an F2D profile about you, request access or correction, ask for removal, object to processing, or ask for human review through the Privacy Center or privacy@miraday.ai. You do not need a MiraDay account. Section 9 explains your rights and the different treatment of F2D and Customer copies.
Your right to object. You may object to processing based on legitimate interests, including profiling, matching and ranking. You can also ask us to stop contacting you about roles. Customers must stop role outreach immediately when you opt out. Platform suppression blocks relevant F2D-based outreach; for a Customer’s independently collected contacts it flags the objection rather than automatically blocking every message; we explain other objections and removal requests in Section 9. Privacy notices needed to explain or respond to your request are separate from role outreach.
1. Who this notice covers and who is responsible
1.1 Who we are. Forward AI Labs, Inc. operates MiraDay, a global talent intelligence platform available at miraday.ai, built for in-house recruiting teams and search firms with a focus on critical hiring for leadership, executive and technical roles (the “Services”). We are the controller of Personal Data processed for our independent F2D purposes and of the other processing described in this notice as our own processing. A controller decides why and how personal data is used.
1.2 This notice covers you if Personal Data about you is in our F2D, including in a professional profile or related company or job information, is captured directly for it, or is being considered for entry through the Contribution Channel. It also covers your requests and our transparency and rights records about that processing. If you are a MiraDay user, this notice applies separately to any F2D profile about you. Being included does not make you a Customer or require you to accept our Terms of Service.
1.3 Information held only in a Customer’s Workspace. An employer or recruiter may hold your application, CV, interview notes or communications in its Workspace. For that Workspace Data, we act on the Customer’s instructions under our Data Processing Addendum (“DPA”); the Customer is responsible for its processing and its own privacy notice applies. If you do not know which Customer is involved, contact us and we will help identify the relevant organization where the law allows. Section 3 explains the separate copy that may enter F2D.
1.4 Terms used here. A “Customer” is the individual or organization using the Services under the applicable agreement; an “Authorized User” is a natural person permitted to use the Services for the relevant Customer, including an individual Customer using a Personal Workspace and an organization’s authorized members. A “Personal Workspace” belongs to the individual Customer; an “Organization Workspace” belongs to the organizational Customer. The same person may use both, and their content and access are separate. An Organization Administrator manages organizational membership and access; this does not itself give access to a Personal Workspace. A “Channel” is a project conversation and task context within a Workspace. “Customer Content” includes content brought into that Workspace through enabled Connectors; candidate data within it is “Workspace Data”. These terms follow our Terms of Service, Section 1, while “you” here means the person whose data is processed, not the Customer.
“F2D (Fast to Data)” is MiraDay’s recruiting data infrastructure, bringing together professional profiles, company information and job information. “F2D Data” means information actually made available to Customers through F2D, subject to applicable access, source and use restrictions. This notice concerns Personal Data processed through F2D, including professional profiles and related recruiting information about identifiable individuals; information that is not Personal Data is outside its scope. “Contributed Fields” are the professional fields listed in Annex 1 of the Data Sharing Addendum (“DSA”); the “Contribution Channel” is the process by which those fields move from a Workspace into F2D. “Extension” means the MiraDay browser extension. “Outputs” include the suggestions, rankings, summaries and other material generated by the Services’ AI features.
1.5 Contact details. Contact privacy@miraday.ai or use the Privacy Center for questions and requests. Our company address and privacy contact information is set out in the Privacy Policy, Section 11.
2. What information we hold about you
2.1 Professional profile information. An F2D profile may include your name; current and past job titles and employers; employment dates; education, qualifications and certifications; skills and languages; city or region; public professional profile links and source links; and publicly available professional work and activity relevant to recruiting, such as publications or a professional profile summary. It may also include work email addresses and work telephone numbers lawfully obtained in a professional recruiting context, including through the Contribution Channel described in Section 3.
2.2 AI-generated information. We generate or infer professional summaries, matching information, rankings, suggestions and supporting evidence from profile information and the role requirements supplied by a Customer. These are assessments or generated information, not necessarily facts you supplied, and they can be inaccurate. We use them to help Customers review potential candidates through the AI-assisted recruiting features described in Sections 4 and 5. The relevance and order of results can affect whether and when your profile is reviewed. You can request access to personal information we hold about you and ask us to review disputed information or processing through Section 9.
2.3 Transparency, contact and rights records. We keep records needed to maintain this public notice, send email notifications for Contribution Channel inclusion, manage relevant role outreach, record your objections or opt-outs, verify and respond to requests, and show that we honoured them. These may include notice versions and publication dates, an email address, the dates and status of inclusion-notification, role-related or request-related messages, your correspondence with us, verification records and minimal suppression identifiers. A suppression record is a limited record used to recognise information that must not be re-added or used for further outreach.
2.4 Sensitive information. We do not collect or infer special category data, such as health, ethnicity, religion, political opinions, trade union membership or sexual orientation, or criminal offence data for F2D. Section 5 explains our approach to protected characteristics in matching.
3. Where your information comes from and how it enters F2D
3.1 Our sources. We obtain information from publicly accessible professional sources; licensed professional data providers; employers and recruiters using the Contribution Channel; and professional profile pages captured using the Extension. Provider data may itself come from public sources. Information about relevant data providers may be requested from privacy@miraday.ai. We record source information to verify profiles and explain the origin of the data we hold; you can ask us about the source of your information through the Privacy Center.
3.2 What is contributed. Eligible Contributed Fields include name; current and past job titles, employers, departments and employment dates; education, qualifications and certifications; skills, languages and expertise; city or region; public professional profile and source links; professional works or portfolio links; work email addresses and work telephone numbers. The complete whitelist and field limits are set out in DSA Annex 1, version 1.0. A professional field may be extracted from a document, but the document itself does not enter F2D through this channel. Independently obtained public or licensed data remains subject to the professional-field scope in Section 2.1 and the applicable field exclusions and source restrictions in this notice and DSA Annex 1. An excluded field does not become eligible for F2D merely because it is obtained from a different source.
Original CVs and attachments, original profile-page captures and screenshots, private notes, tags, scores, interview feedback and assessments, messages, recordings and transcripts, prompts and task instructions, compensation information, credentials, precise addresses, photos, age or date of birth, personal email addresses or telephone numbers, special category or criminal offence data (including inferred data), and children’s data do not enter through the Contribution Channel. Email and telephone fields are handled within the defined recruiting contact-field limits rather than through unrestricted copying of message content or address books. Data obtained from connected Google or Microsoft accounts, including messages, attachments and professional fields derived from that data, does not enter the Contribution Channel or F2D.
3.3 How the Contribution Channel operates. It applies to eligible fields in both Personal and Organization Workspaces under the Terms, with no separate contribution switch. Workspace isolation does not prevent eligible fields from entering the shared F2D. The Customer’s acceptance of those arrangements is not your consent to our processing. We rely on our own lawful basis, described in Section 4, for the F2D copy and are responsible for providing information about it as described in Section 10. When your information enters F2D through this channel and a lawful email delivery channel is available, we send you an email notification as described in Section 10.1.
3.4 Checks and separate copies. Before writing Contributed Fields into F2D, we check the record against our suppression list using the identifiers available to us. Records that match a suppression entry are not admitted. Customer-instructed handling of Workspace Data remains subject to the DPA. We act as an independent controller when processing a contributed copy for our own F2D purposes under the DSA, including any preparatory processing for those purposes; our role depends on the actual activity and purpose, not solely on the database write date. The Customer’s original Workspace copy remains separate. Creating an F2D copy does not itself remove or change the original record. Before making it available to another Customer, we satisfy the applicable information requirements or assess and document an applicable exception, with public information and appropriate safeguards. We record the first acquisition for our own F2D processing, rather than relying solely on the database write date.
3.5 Extension captures. The Extension is enabled at the individual account level. A page saved through a target Channel belongs to that Channel’s Personal or Organization Workspace. The Extension may capture a professional page into that Customer’s Workspace, where we process it on that Customer’s instructions. Eligible fields may subsequently enter through the Contribution Channel. Where a capture is made directly for F2D, we control that capture from the outset. The field limits, checks and transparency arrangements in this notice apply to the F2D route. Screenshots do not enter F2D.
4. Why we use your information and our lawful bases
4.1 Building and maintaining profiles. We compile, verify, update and enrich F2D to help employers and recruiters discover people for professional opportunities. This includes receiving Contributed Fields to improve accuracy and currency and reduce duplicate outreach. Our basis under the EU and UK GDPR is legitimate interests, Article 6(1)(f): our interest and Customers’ interests in providing an accurate professional recruiting resource. We assess necessity and balance those interests against your rights. We rely on legitimate interests for this processing, rather than treating your potential interest in a role as consent.
4.2 Matching and delivering profiles. We search, match, rank and present profiles in response to a Customer’s recruiting requirements and deliver F2D Data for Recruiting Purposes. Those purposes mean identifying, evaluating, contacting and hiring for the Customer’s own roles or, for a recruitment agency or search firm, a specific client engagement, including talent, company, labour-market and compensation research supporting those recruiting activities. They exclude sales prospecting, marketing, advertising, list building, resale and unrelated commercial research. We rely on legitimate interests in connecting recruiting requirements with relevant professional profiles. Section 5 describes the AI processing, and Section 6 explains Customers’ separate responsibilities.
4.3 AI processing and source-specific model-use limits. We use professional information to provide the matching, ranking and other AI-assisted recruiting features described in Section 5. Customer Content, Contributed Fields and their copies and derivatives are not used to train, fine-tune or improve our own or third-party models. Independently obtained public or licensed fields have the limited matching and ranking uses in Section 5.5. For evaluation and improvement of our own recruiting matching and ranking models using those independently acquired fields, we rely on legitimate interests under Article 6(1)(f), within lawful source permissions and subject to necessity, balancing and the safeguards in this notice. AI inference to provide a result is different from model training.
4.4 Transparency, privacy requests and role contact. We publish this notice, send inclusion notifications to Contribution Channel candidates where a lawful email delivery channel is available, and use necessary contact and verification records to respond to privacy requests, relying on applicable legal obligations and legitimate interests in transparency and implementing your choices. Platform role outreach is sent by email on an Authorized User’s explicit instruction, with the Customer as sender. The Customer determines the lawful basis and is responsible for its notice and electronic communications obligations; we process its messages on its instructions under the DPA. Our separate processing to maintain and deliver F2D Data is described in Sections 4.1–4.2. Inclusion notifications and privacy-request replies are separate from role outreach. Section 9 explains objections and the scope of suppression.
4.5 Protecting rights and the Services. We keep minimal suppression records to honour objections and removal requests, and records necessary to secure the Services, prevent abuse, comply with applicable legal obligations and establish, exercise or defend legal claims. We rely on the applicable legal obligation, Article 6(1)(c), or legitimate interests in protecting rights, people and systems, Article 6(1)(f), depending on the activity. We do not use suppression records for matching, role promotion or unrelated purposes.
4.6 Our balancing and safeguards. Our safeguards include professional-field limits, this public notice, email notifications for Contribution Channel candidates where a lawful email delivery channel is available, and rights channels, restrictions on Customers’ use, human review, retention rules and suppression checks. You can request information about our legitimate interests assessments at privacy@miraday.ai. We do not rely on your acceptance of the Terms of Service as a lawful basis for processing your F2D profile.
5. AI matching, profiling and model use
5.1 How matching works. The Services use large language models and our own matching models, including through Agent Teams, which are groups of AI agents working on a task. For F2D searches, they compare professional profile information with job-related requirements provided by the Customer and produce matching information, suggestions, rankings, summaries or supporting evidence. Automated evaluation of professional information in this way may constitute profiling. Further information about inputs, Outputs and limitations is available through the Documentation or on request at privacy@miraday.ai.
5.2 What it means for you. A result’s relevance and order may affect whether and when a recruiter sees your profile. Outputs are probabilistic and can be inaccurate, incomplete or outdated. They are provided for human review and are not final hiring decisions or guarantees of suitability. Customers must maintain appropriate human oversight and verify material facts before relying on an Output. Whether a particular recruiting workflow amounts to a solely automated decision with legal or similarly significant effects depends on its actual operation, not just its description as a suggestion.
5.3 Human review. You may ask us to review how our AI handled your F2D profile in a particular search, explain your concerns and contest relevant information or results. Contact the Privacy Center or privacy@miraday.ai with enough information to identify the processing. Where a decision or Workspace processing belongs to a Customer, we help route the request to it and assist as our DPA requires. EU and UK rules on significant automated decisions differ; we provide the review route described here without requiring you first to prove that a particular result meets that legal threshold.
5.4 Protected characteristics. The Services do not offer protected characteristics as search or ranking criteria. We do not knowingly use protected characteristics, or criteria intended to stand in for them or known to be used for that purpose, as matching and ranking inputs. We assess and mitigate features that may act as such substitutes and monitor matching for fairness and bias using measures appropriate to its use and risk. An ordinary recruiting criterion is not treated as such a substitute merely because it correlates with a protected characteristic. This does not remove the need to assess discrimination risks in actual recruiting. Details of our approach and available results may be requested from privacy@miraday.ai.
5.5 AI inputs and model-training limits. We use F2D information as inputs to provide AI-assisted recruiting features. Customer Content and Workspace Data, including Contributed Fields after they enter F2D and their copies and derivatives, are not used to train, fine-tune or improve our or third-party models, including in aggregated, de-identified or anonymized form. Necessary troubleshooting, task validation and support remain limited to the relevant Customer’s service and lawful instructions; they do not authorize reuse of Customer task content in a general evaluation library or for unrelated product improvement. Profile fields independently obtained from public or licensed sources, excluding Customer contributions and their derivatives, may be used to operate, evaluate and improve our own recruiting matching and ranking models within lawful source permissions. These independent fields are never used to train general-purpose or foundation models and are never shared with model providers for their training. Extension captures are subject to the relevant source, field and purpose restrictions and do not create an exception to the Customer-data prohibition. Connected Google or Microsoft account data is not used for model training, fine-tuning or improvement in any form. Copying, transforming or relabelling data does not remove its source restrictions. These limits concern our processing and our providers; Customers’ separate permitted uses are described in Section 6.
Third-party model providers process inputs and Outputs to provide AI features under contracts that prohibit model training. Their retention is limited by the applicable service, security and legal purposes and the safeguards in the relevant agreements, as Section 8.2 explains. These are our provider arrangements; Customers’ permitted uses of their own F2D Data copies are explained in Section 6.
6. Who receives your information and what happens to customer copies
6.1 Customers and recruiting clients. We make relevant F2D Data available to Customers and their Authorized Users through the Services, including by display, retrieval, saving into a Workspace or export. Customers are separate controllers of the copies they receive from that point, with their own duties to establish a lawful basis, provide required information and respect your rights. A recruitment agency or search firm may provide data to its client for a specific recruiting engagement under restrictions no less protective than those required by our Terms and DSA.
Our Terms restrict F2D Data to Recruiting Purposes and prohibit resale, publication outside permitted recruiting disclosures, and use to build, enrich or verify databases or products offered to others. Customers must not use F2D Data or data derived from it to train, fine-tune or improve any AI model, including an internal recruiting model. Necessary inference for permitted Recruiting Purposes is allowed, subject to the Terms, the DSA, source restrictions and applicable law. Receiving or incorporating a copy does not remove these restrictions, including after the subscription ends.
6.2 Copies after a subscription ends. A Customer may continue to use F2D Data lawfully saved during its subscription into its own applicant-tracking or CRM system in the ordinary course of Recruiting Purposes, subject to the same use and data-protection restrictions. Bulk export in anticipation of termination does not qualify for this continued use. The receiving Customer determines how long its independent copy remains necessary for its lawful Recruiting Purposes, reviews that need periodically, and handles applicable deletion requests and the end of the recruiting purpose. Ending a subscription does not remove the Customer’s duties to handle rights requests. We notify the Customer of relevant corrections and deletions as required by the DSA; the Customer remains responsible for applying them.
6.3 Providers and verification. We share relevant information with hosting, infrastructure, AI, message delivery, support and security providers as needed to operate F2D and respond to requests, under contractual safeguards. Information about their identities, functions and locations may be requested from privacy@miraday.ai. Data providers may receive minimal identifiers to verify or enrich profiles and, where arrangements support it, to stop supplying records of people who have opted out. They may act as separate controllers or processors depending on the service.
6.4 Other recipients. We may disclose information to professional advisers, such as lawyers and auditors, where necessary for legal advice, compliance reviews or disputes, subject to confidentiality obligations. We may provide information to courts, regulators or law-enforcement authorities where required by applicable law, or to parties directly involved in establishing, exercising or defending legal claims or investigating and preventing misuse of the Services, where necessary and permitted by law. In a merger, acquisition or transfer of our business, necessary information may be disclosed to a prospective buyer or transferred to a buyer or successor, subject to appropriate safeguards and applicable data-protection obligations. In each case, we limit disclosure to information necessary for the relevant matter and apply confidentiality, access restrictions and other appropriate safeguards as applicable. Before responding to a public-authority request, we assess the authority’s powers, the legal basis and the scope of the request, applying the safeguards described in our Privacy Policy. We do not provide personal data to third parties for their own advertising. Truly anonymised information, which cannot reasonably identify you, may be used or shared for statistics; merely removing direct identifiers does not necessarily make information anonymous.
7. Where information is processed and how it is protected
7.1 Processing locations. Information may be hosted, processed or accessed by MiraDay and its approved infrastructure, model, support and other service providers in the countries where the relevant operations take place. Locations depend on the source, service and provider involved. Transfers remain subject to Section 7.2 and the applicable DSA safeguards. You may request information about relevant processing locations and safeguards through privacy@miraday.ai.
7.2 Transfer safeguards. For transfers subject to EU or UK data protection law, we rely on an applicable adequacy decision or put in place appropriate contractual safeguards, with additional protective measures where required. Details are available in our Privacy Policy. You can request further information or a copy of applicable safeguards at privacy@miraday.ai, subject to permitted redactions that do not prevent you from understanding the protections.
7.3 Security. We apply measures appropriate to the risk, including encryption in transit and at rest, controlled access, separation of Customer Workspaces, monitoring and vendor review, as described in our Privacy Policy. We do not present planned certifications or audits as completed. Where a breach is likely to create a high risk to your rights and freedoms, we notify you without undue delay as applicable law requires.
8. How long we keep information and how we remove it
8.1 Professional profiles and AI information. We retain F2D profiles while they remain relevant and verifiable for Recruiting Purposes. We review their continued need and accuracy when sources change, concerns are raised or routine checks identify a problem, and restrict or remove information that is no longer justified. Professional summaries and tags follow the underlying profile. Search-related records are retained while needed to provide or substantiate a search, handle a challenge or meet an applicable legal obligation, then deleted or anonymized. You may request removal sooner. These criteria do not depend on a contributing Customer’s subscription.
8.2 Capture and provider records. Extension page content and screenshots are kept only while needed to extract and verify relevant information or investigate a specific issue; screenshots do not enter F2D. Extension activity logs are kept while needed for security, audit and support. Third-party model providers process inputs and Outputs under contractual purpose, access and retention limits, including any applicable service, security or legal requirements. We review those limits against the processing involved. A profile without contact details follows the same retention criteria as any other F2D profile.
8.3 Contact, request and exceptional retention. We retain outreach and interaction records while needed to manage recruiting communications, honour contact choices and address related disputes. We keep only the records needed to verify identity, respond to and evidence rights requests or complaints, and meet applicable legal obligations or defend claims. Security and access logs are kept while needed to protect and audit the Services; routine debugging records are removed when no longer needed. Backups follow a controlled replacement cycle, with deleted information kept from active use. A specific legal obligation or claim may require restricted retention for longer, subject to review of that need. Previous versions of this notice are kept as needed to document what information was provided. Any evaluation records remain subject to the source and purpose restrictions in Section 5.5 and are kept only while necessary for the permitted evaluation. This does not authorize Customer Content or its derivatives to enter a general evaluation library or be reused for unrelated product improvement.
8.4 Suppression. When you opt out of F2D inclusion or request deletion, we keep only the identifiers needed to recognize matching records and demonstrate that we honoured your choice. We retain and review that limited record while needed to prevent re-entry or meet applicable legal obligations, and remove it when those purposes end. It is used only for suppression and compliance. Matching depends on the identifiers available; if a profile reappears, contact us so we can correct the match and remove it.
9. Your rights and choices
9.1 Requesting access to your information. You can submit a request through the Privacy Center or privacy@miraday.ai to ask whether we hold a profile about you, obtain a copy of your personal information, understand its sources, uses and recipients, or request correction of inaccurate or incomplete information. Please provide the information needed to verify your identity as described in Section 9.6. We review and respond to each request individually and, once your identity has been verified, provide access to the information you are entitled to receive under applicable law. You do not need to create a Services account or agree to our Terms to exercise these rights.
9.2 Objecting and stopping contact. You may object at any time to processing based on legitimate interests, including profiling, matching and ranking. We stop that processing unless we demonstrate compelling legitimate grounds overriding your interests, rights and freedoms, or processing is needed for legal claims, and explain our response. You can also choose removal from F2D as described below. Separately, our policy requires the sender to stop role outreach immediately when you unsubscribe or ask it to stop. Platform suppression blocks F2D-based outreach within the applicable suppression scope. For a Customer’s independently collected contacts, it flags the objection rather than technically blocking every message; the Customer remains responsible for immediately honouring applicable opt-outs. These tools do not guarantee global suppression of independent copies. Where outreach constitutes direct marketing, the legal right to object is absolute. Use the Privacy Center, privacy@miraday.ai or the unsubscribe link in the message.
9.3 Removal, restriction and suppression. You can ask us to delete your F2D profile or restrict its use in applicable circumstances, including while accuracy or an objection is being assessed. We remove active F2D profiles when you choose to opt out, subject to limited records retained for suppression, applicable law or legal claims, as Section 8 explains. Tell us if you want to stop one use, all F2D use or only role contact, so we can implement your choice accurately.
9.4 Customer copies. When we correct or delete F2D information at your request, we apply the change to F2D-derived copies still held in a Customer’s Workspace and notify the Customer to address copies held elsewhere as the DSA requires. A contributing Customer’s independently collected original Workspace Data is different: removal of our F2D copy does not itself erase that original record. You may contact that Customer for it; we can help route your request. Copies exported to or saved in the Customer’s own systems are under that Customer’s control and it remains responsible for them, including after its subscription ends.
9.5 Other rights. You may request human review, express your views and contest the AI processing as Section 5 explains. Data portability applies where its legal conditions are met, including relevant processing based on consent or contract; it does not apply to F2D profiles solely processed on legitimate interests. If we rely on your consent for a particular activity, you may withdraw it without affecting lawful processing before withdrawal. We do not describe F2D inclusion as consent-based processing.
9.6 Verification and response. We normally verify by sending a link to an email address associated with you. If that is unavailable or we reasonably doubt identity, we use proportionate alternative verification and ask only for what is necessary. Someone may act with your written authority. Under EU and UK data protection rules, we respond without undue delay and normally within one month; where a permitted extension is needed, we tell you why within that initial period. Requests are free unless applicable law permits a fee for a manifestly unfounded or excessive request. Other local laws may provide additional rights or different deadlines; we apply the requirements relevant to your request.
9.7 Complaints. You can complain at privacy@miraday.ai or through the Privacy Center. We review complaints and respond in accordance with applicable law. You may also complain to the UK’s Information Commissioner’s Office or, in the EEA, the supervisory authority in the country where you live or work or where an alleged infringement occurred (authority list). You do not have to complete our complaints process before exercising a right to complain to an authority.
10. Public notice and updates
10.1 Public notice and email notifications. We publish this notice on our website to explain how we process information in F2D, including information obtained through the Contribution Channel and direct Extension captures. When your information enters F2D through the Contribution Channel and a lawful email delivery channel is available, we send you an email notification. The email explains that your information has entered F2D, links to this notice and explains how to exercise your privacy rights. This privacy notification is separate from Customer-instructed role outreach. Where a lawful email delivery channel is unavailable, we must still meet the applicable information requirements or assess and document a valid exception under Section 3.4; lack of an email address does not itself establish an exception. We keep records of notices, delivery status and any exception relied on. The notice timing requirements in the Privacy Policy, Section 2.3 apply; withholding delivery to Customers does not extend an earlier notice deadline. You can find information about your rights and how to contact us in Section 9.
10.2 Access to information and your choices. This notice explains our sources, the information we hold, our purposes, recipients, retention and your rights. You can use the Privacy Center or contact privacy@miraday.ai to ask whether we hold information about you, request information about its source and exercise the rights described in Section 9. Under the notice arrangements in Section 10.1, the absence of contact details does not by itself prevent a profile from being included in F2D or made available to Customers for Recruiting Purposes, subject to the other restrictions in this notice, including the information requirements or assessed exception described in Section 3.4. Publication is not a statement that every individual has read this page, and inclusion is not your consent to processing. A Customer remains responsible for the information and rights obligations that apply to its own processing; this notice does not replace them.
10.3 Changes and new purposes. We publish version dates, keep previous versions available and provide a change summary. We keep this notice and the Privacy Policy consistent when relevant processing changes. Before using F2D information for a new purpose, we update the information about that purpose, its lawful basis and relevant rights, and provide any further information or communication required by applicable law. Where we rely on an information-duty exception, we reassess whether it remains applicable; an assessment for existing processing is not an automatic exemption for every new purpose or change. We obtain consent where required. Our Customer agreements do not remove our duties to you.
10.4 Young people and related information. The Services are designed for recruiting professionals; account holders must be at least 18. F2D does not record age or date of birth, so we do not routinely verify every candidate’s age. If you believe we hold a profile about someone under 18, contact privacy@miraday.ai and we will delete that F2D information. For website use, see the Privacy Policy and Cookie Policy. The DPA and DSA describe arrangements with Customers; they are not contracts you must accept to exercise your privacy rights.