Our approach to your personal data.

01 Overview

Emerson Search LLC ("Emerson Search," "we," "us," or "our") is an employment agency incorporated in Delaware that conducts recruiting and staffing operations throughout the United States. We serve as the data controller for all personal information addressed in this Privacy Policy.

This Privacy Policy describes the personal information we obtain from candidates, clients, and visitors to our website (emersonsearch.com), the purposes behind its collection, how we utilize and disclose it, and the rights available to you. It covers every individual who engages with us, whether via our website, email, phone, or in person at any of our nine US offices.

We comply with applicable US federal law (including Title VII, the ADA, and the FCRA where applicable), state law (including California’s CCPA/CPRA, Virginia’s VCDPA, Colorado’s CPA, and Connecticut’s CTDPA), and SOC 2 Type II controls. California residents should also review our dedicated Your Privacy Choices page.

02 Information we collect

2.1 — Information you give us directly

When you apply for a position, provide your résumé, participate in a consultation, or engage with us in any other way, we gather:

• Identifiers such as your full name, postal address, phone number, and email address;
• Professional and employment-related information including résumé/CV, work history, education, certifications, licenses, references, current and target compensation, work authorization status, and notice period;
• Information about your job preferences (industry, geography, remote/hybrid/on-site, seniority);
• Communications and notes we record during our discussions with you;
• Information you share voluntarily for diversity-equity-inclusion analytics, where you have explicitly opted in.

2.2 — Information we receive from third parties

With your authorization (and solely where permitted by law), we may obtain information from:

• Professional networking platforms such as LinkedIn, where your profile is publicly available;
• References and previous employers you have authorized us to contact;
• Background-check vendors (FCRA-compliant) when a client’s offer is contingent on a check;
• Our clients, when they refer you to us or share search-specific feedback;
• Publicly available sources such as company websites, news articles, and regulatory filings.

2.3 — Information we collect automatically

When you browse our website, certain technical data is collected automatically via cookies and comparable technologies: IP address, browser type and version, operating system, device identifiers, referring and exit pages, navigation patterns, and time spent on each page. Refer to Section 9 for additional detail.

2.4 — Sensitive personal information

We minimize the collection of sensitive personal information (as defined under US state privacy laws) to the greatest extent feasible. Such information — for instance, a Social Security Number for FCRA-compliant background screenings — is requested only with your express consent and only when absolutely required for a particular search in which you are actively participating. We do not request banking details, government-issued identification scans, or payment information.

03 How we use information

We utilize personal information for the purposes outlined below:

• Search delivery: matching candidates to suitable open roles and presenting qualified candidates to clients;
• Communication: contacting candidates about opportunities, scheduling interviews, and providing updates on active engagements;
• Client engagement: fulfilling our contractual obligations to our retained-search and direct-hire clients;
• Quality & compliance: internal audits, ensuring fair-hiring practices, complying with EEO and state employment laws;
• Aggregate analytics: understanding placement trends, time-to-hire benchmarks, and salary ranges — always in de-identified form;
• Marketing: sending career-relevant communications and market updates (you can unsubscribe at any time);
• Security: preventing fraud and impersonation (see our team directory for verified contacts).

04 Sharing & disclosure

We do not sell personal information. We have never done so and have no intention of doing so. We share personal information only in the following circumstances:

• To client employers with whom we are conducting a search, only after you have given us informed consent to be presented for a specific opportunity;
• To service providers bound by written confidentiality and data-processing agreements: applicant-tracking system (Greenhouse), email infrastructure (Google Workspace), background-check vendors (Checkr), payment processors (Stripe, for client billing only), and cloud hosting (AWS us-east-1, SOC 2-compliant);
• To professional advisors such as our attorneys, accountants, and auditors when required for the conduct of our business;
• To law enforcement when compelled by a valid subpoena, court order, or warrant under US law;
• In a corporate transaction — if Emerson Search LLC is acquired or merged, we will provide notice before personal information is transferred and becomes subject to a different privacy policy.

05 Legal bases for processing

Our processing of personal information rests on the following legal foundations under US state privacy statutes:

• Consent — when you actively submit your information for a specific search or sign up for our market updates;
• Performance of a contract — to fulfill our engagement letter with the client and our placement obligations with you;
• Legitimate interest — for fraud prevention, security monitoring, and internal quality assurance, balanced against your rights and interests;
• Compliance with legal obligation — for tax reporting, EEO record-keeping, and regulatory audits.

06 Data retention

Candidate personal information is kept for as long as reasonably required to deliver our services, satisfy legal obligations, address disputes, and uphold our agreements. The specific retention periods are as follows:

You are free to request earlier removal at any time through the contact information provided in Section 13, subject to any legal hold or contractual requirement mandating continued storage.

07 Security measures

We employ administrative, technical, and physical protections intended to shield personal information from accidental loss, unauthorized access, modification, or disclosure. Our security program encompasses:

• SOC 2 Type II certification (audited annually by an AICPA-accredited firm);
• Encryption in transit (TLS 1.3) and at rest (AES-256);
• Access controls based on least-privilege principles, with MFA required for all employees;
• Annual security training for all team members, including phishing awareness;
• Incident response plan with notification within 72 hours of any confirmed breach affecting your personal data;
• Background-checked employees with confidentiality agreements covering candidate data.

No internet transmission method is entirely secure. While we cannot promise absolute security, we apply rigorous industry-standard safeguards consistently.

08 Your rights

Based on the state in which you reside, you may exercise the following rights:

• Access the personal information we hold about you;
• Correct inaccuracies in your information;
• Delete your information (subject to retention obligations above);
• Port your data to another service in machine-readable format;
• Opt out of marketing communications at any time;
• Withdraw consent for ongoing search engagements;
• Non-discrimination — we will not retaliate or refuse service for exercising any of these rights.

California residents hold additional rights under the CCPA/CPRA; please visit our Your Privacy Choices page. To exercise any right, send an email to privacy@emersonsearch.com. We will reply within 30 days (45 days for requests from California residents).

09 Cookies & tracking

Our website employs the following types of cookies:

• Strictly necessary — session and security cookies that cannot be turned off;
• Analytics — Google Analytics 4 for understanding aggregate site usage (IP anonymization enabled);
• Functional — remembers your preferences (e.g. cookie banner acknowledgment);
• Marketing — only used with your explicit opt-in via our cookie banner.

You may adjust your preferences at any time via your browser settings or by selecting "Manage Preferences" in our cookie banner. We recognize the Global Privacy Control (GPC) signal as a valid opt-out request.

10 Children’s privacy

Our services are designed solely for adults (aged 18 and above) pursuing employment opportunities. We do not intentionally collect personal information from individuals under 18. Should we discover that data from a minor has been collected, we will remove it without delay. Please contact privacy@emersonsearch.com if you suspect a minor has submitted information to us.

11 International transfers

Emerson Search is headquartered in the United States, and all principal data processing takes place domestically. If you are situated outside the US and provide information to us, you consent to the transfer of your data to the US for processing. We depend on suitable safeguards, including Standard Contractual Clauses, where mandated by the laws of your country of residence (e.g., EU/UK GDPR).

12 Changes to this policy

We may revise this Privacy Policy periodically to account for changes in our operations, technology, legal obligations, or other relevant factors. When we implement material modifications, we will:

• Update the "Effective" date at the top of this page;
• Notify candidates with an active engagement via email at least 30 days before the change takes effect;
• Post a prominent notice on our website for at least 30 days;
• Maintain prior versions on request for transparency.

13 Contact us

For inquiries regarding this Privacy Policy or to exercise your data-protection rights, please reach out to our Privacy team:

Emerson Search LLC · Attn: Privacy Officer
110 East 42nd Street, Suite 1400
New York, NY 10017

Email: privacy@emersonsearch.com
Toll-free: +1 (866) 519-3742
Response time: 30 days (45 days for California CCPA/CPRA requests)

If you believe we have not adequately addressed your concern, you may also contact your state Attorney General’s office or, for California residents, the California Privacy Protection Agency at cppa.ca.gov.