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Privacy Policy

Effective Date: February 1, 2025 Last Updated: February 1, 2025 B2D AI, LLC dba PeopleContext (“People Context,” “we,” “us,” or “our”) is committed to respecting the privacy of individuals and complying with applicable data protection laws, including the General Data Protection Regulation (GDPR), the UK GDPR, the California Consumer Privacy Act (CCPA), and other global privacy regulations. This Privacy Policy explains how we collect, use, and share personal data, particularly professional and developer-related data made available through our products and services.

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1. Who We Are

PeopleContext is a U.S.-based data provider specializing in professional profile data, developer technographics, and contact data for recruiting and HR technology use cases. We license structured datasets and insights to business customers for B2B use cases such as recruiting, candidate sourcing, and talent intelligence. We do not provide services directly to individual consumers.

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2. What Data We Collect

We collect and process publicly available data, including:
  • Name, email, and professional contact details
  • Public professional profiles (e.g., LinkedIn, GitHub)
  • Company and job-related information
  • Public activity, contributions, or engagement with professional and technical communities
  • Technical and behavioral signals derived from public sources
We do not collect or process sensitive personal data as defined under Art. 9 GDPR (such as race, religion, health, political views, or biometric data), nor do we collect consumer behavioral data from private sources.

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3. How We Collect Data

All data is collected through lawful means, including:
  • Crawling and aggregating publicly accessible web pages
  • Extracting data from open APIs
  • Analyzing open-source contributions and public metadata
We do not collect data from private, password-protected, or restricted-access sources.
We process personal data under the lawful basis of legitimate interests (Art. 6(1)(f) GDPR). Our legitimate interest is in helping companies find, evaluate, and engage with professional talent for recruiting and related business purposes. We have conducted a Legitimate Interests Assessment (LIA) to ensure our interests do not override the fundamental rights and freedoms of individuals. Individuals may object to processing at any time by contacting us at the address below.

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5. Transparency for Third-Party Collected Data (Art. 14 GDPR)

Where we collect personal data from publicly available sources rather than directly from the individual, we satisfy our transparency obligations under Article 14 GDPR through this publicly accessible Privacy Policy. This Policy discloses the categories of data we collect, the sources we use, our legal basis for processing, the purposes of processing, and how individuals can exercise their rights. We rely on the exemption under Art. 14(5)(b) GDPR, which permits controllers to forgo individual notification where providing it would involve disproportionate effort. Given that we process data relating to hundreds of millions of individuals sourced from public platforms, individual direct notification is not operationally feasible and would itself risk constituting unsolicited contact under applicable law. We supplement this published notice by requiring our customers, through our Acceptable Use Policy, to provide individuals with appropriate transparency before first contact.

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6. Your Rights (GDPR, UK GDPR & CCPA)

You have the right to:
  • Access the data we hold about you
  • Request correction or deletion of your data
  • Object to the processing of your data
  • Request a copy of your data in a portable format
  • Opt out of the sale of your data (as defined by the CCPA)
To exercise these rights, email us at justin@peoplecontext.com with the subject line “Privacy Request” and your name and relevant platform handle (e.g. GitHub username or LinkedIn URL). We will respond to verified requests within 30 days, consistent with Art. 12 GDPR. For complex requests we may extend by a further 30 days with notice.

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7. How We Use the Data

We license our data to business customers for internal use cases including:
  • Recruiting and candidate discovery
  • Talent sourcing and pipeline building
  • B2B marketing and outreach
  • Sales and market intelligence
Our customers are contractually bound to use the data in compliance with applicable privacy laws and our Acceptable Use Policy.

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8. Data Sharing

We may share data with:
  • Customers who license our datasets or use our APIs
  • Service providers under contract (e.g., cloud hosting, analytics)
  • Legal or regulatory bodies when required by law
We do not sell data to consumer data brokers.

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9. International Data Transfers

We are based in the United States and may transfer data to or from jurisdictions outside the EU/EEA and UK. For transfers of EU personal data, we rely on the European Commission’s Standard Contractual Clauses (June 2021, Module 2). For UK personal data, we rely on the ICO’s International Data Transfer Agreement (IDTA) and/or the UK Addendum to the EU SCCs, as applicable.

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10. Data Retention

We retain personal data only as long as needed to fulfill our business purposes or comply with legal obligations. We run periodic refresh cycles to update records and remove profiles that are no longer publicly available.

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11. Security

We maintain industry-standard technical and organizational measures to protect data from unauthorized access, alteration, or disclosure, including TLS 1.2+ encryption in transit, AES-256 encryption at rest, multi-factor authentication, role-based access controls, and audit logging.

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12. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact: B2D AI, LLC dba PeopleContext Email: justin@peoplecontext.com Subject line: “Privacy Request” We are in the process of appointing an Article 27 GDPR representative for the EU and UK. In the interim, all data protection inquiries can be directed to the contact above.

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13. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last Updated” date at the top of this page. We encourage you to review this policy periodically.