Privacy Policy

This Privacy Policy explains how Graydiant collects, uses, shares, and protects personal information when you visit our website, contact us through our forms, or interact with our survey-invitation pages. It also describes the privacy rights available to you depending on where you live.

Who we are

Graydiant is a talent platform that connects experienced professionals, generally aged 55 and over, with employers seeking their skills and experience. Through our website and services we help professionals share their background with prospective employers, and help employers reach and engage experienced candidates.

This Privacy Policy is issued by Gray Matter Solutions LLC, a New York limited liability company, doing business as Graydiant (“Graydiant”, “we”, “us”, or “our”), which is the controller responsible for the personal information described here.

You can reach us about privacy matters at:

• Email: admin@thatgraymatters.com

If you are located in the EEA or the UK, you can contact us about your rights at the email above. Where we are required to appoint an EEA or UK representative under applicable law, we will designate one and provide their details here.

We have not appointed a statutory Data Protection Officer; the contact above handles privacy questions and requests.

What this policy covers

This policy applies to personal information we collect through:

• our public website, including pages you view and the contact or interest forms you submit;
• our survey-invitation pages, which we use to invite specific people to view a short video and complete a survey;
• our access-controlled investor area, a firewalled part of our website where prospective investors sign in to view investor materials; and
• related communications, such as emails, calls, or text messages you exchange with us.

It applies to everyone we interact with through these channels, including employers and their representatives, professionals and candidates, survey recipients, prospective investors, and general website visitors.

This policy does not cover the practices of third parties we do not control. Where our pages embed or link to third-party services (for example, the video player and the survey form described below), those providers handle some information under their own terms, which we identify where relevant.

Information we collect

We collect only the information we need for the purposes described in this policy. The information differs depending on how you interact with us.

Information you give us through forms. When you submit a contact or interest form, you provide the details entered in that form, such as your name, email address, and any optional information you choose to add (for example, your company, role, or a message). If you are a professional, this may include background information relevant to matching, such as your experience, skills, and availability. Form submissions are sent to our inbox and kept as a backup copy in our administrative system.

Public-website analytics. We use privacy-protective analytics that do not use cookies and do not track you across other sites. We collect the pages viewed, the site that referred you, your browser and device type, and your country. Your IP address is used only to determine your country and is not stored.

Hosting and server logs. Our hosting provider (Railway) keeps standard server logs for a short period for security and troubleshooting. These logs may include technical data such as IP addresses and request details.

Survey-invitation pages. When we invite you to a survey, we process:

• Recipient details you were invited with (your name, email, and company), which are encrypted at rest;
• Activity for your invitation, such as when it was opened, how many networks accessed it, your progress through and completion of the video, and whether you submitted the survey. IP addresses connected with this activity are stored only in a one-way, scrambled (hashed) form, never as raw IP addresses;
• Essential cookies that keep the invitation working, including an invitation cookie, which keeps the invitation open as the person moves through it (up to 48 hours); and a security cookie, which protects the survey form from forged submissions (up to 1 hour). These are described in our Cookie Policy and are not used for advertising or cross-site tracking.

Embedded services on survey pages. The video plays from our Vimeo account with Vimeo’s tracking turned off; Vimeo still processes limited connection data to deliver the video. Your survey answers are submitted to and stored in our Typeform account, and Typeform may also process that data under its own terms.

Communications. If you email, call, or text us, we keep the content of and records about those communications, including records of the consents and choices you have given.

Please do not submit Social Security numbers, financial account numbers, government-ID numbers, health information, or date of birth through our forms. We do not need this information and ask that you not provide it.

Investor area. Our website includes an access-controlled (firewalled) area where prospective investors can sign in to view investor materials. When you use it, we collect your name and email address, your account sign-in details, and sign-in and access records — such as when you signed in, access events, and related session and device information. We use this to give you access, to secure the area, and to keep a record of who has accessed investor materials.

How we use your information

We use the personal information you provide only for Graydiant’s own business purposes (“Our Purposes”):

1. Responding to you — answering your inquiry, providing the information, materials, or services you request, and following up on your submission.
2. Suitability evaluation — evaluating professional backgrounds and employer needs, identifying and introducing potential matches between experienced professionals and employers, facilitating interviews and engagements, and sharing relevant profile or opportunity information with the other side of a potential match as part of the services you ask us to provide.
3. Account and service communications — creating and administering your profile, scheduling, and sending service-related notices.
4. Communicating about Graydiant — sending you information about Graydiant’s own services, events, and opportunities that may interest you, subject to your communication choices and your right to opt out at any time.
5. Surveys and research — inviting you to, delivering, and analyzing surveys, including measuring whether invitations were opened and completed, to understand our audience and improve our services.
6. Providing the investor area — authenticating prospective investors, giving access to investor materials, maintaining sign-in and access records, and securing that area.
7. Improving our services — understanding how our website and services are used, conducting analytics on aggregated or de-identified information, and developing and improving our matching and service offerings.
8. Security and integrity — protecting our website, services, and users, preventing fraud and misuse, and debugging.
9. Legal and compliance — complying with applicable laws, regulations, and legal process, keeping records (including records of your communication consents), and establishing, exercising, or defending legal claims.
10. Business administration — internal operations and auditing, and, if Graydiant is involved in a merger, acquisition, financing, or sale of assets, as part of that transaction and subject to the protections in this policy.

We collect and use only the information that is reasonably necessary and proportionate for these purposes. If we want to use your information for a purpose that is materially different from those listed above, we will tell you first and, where the law requires, ask for your consent.

What we do not do. We do not sell your personal information, and we do not share it with third parties for their own marketing or for cross-context behavioral (targeted) advertising. We do not use your information to train generative artificial-intelligence models.

Our legal bases for processing (EEA and UK)

If you are in the EEA or the UK, we rely on the following legal bases under the EU General Data Protection Regulation (GDPR) and the UK GDPR:

• Legitimate interests — to respond to your inquiries, to deliver and analyze our surveys, to operate, secure, and improve our website and services, and to communicate with you about Graydiant where permitted. We rely on this basis only where our interests are not overridden by your rights, and you may object as described below.
• Steps taken at your request before entering into a contract — where you ask us to provide services, such as matching.
• Consent — for optional marketing emails, for any marketing text messages, and for non-essential cookies where consent is required. You may withdraw your consent at any time, and doing so is as easy as giving it.
• Compliance with a legal obligation — where we must process information to meet legal or regulatory requirements.

Where we rely on consent, withdrawing it does not affect processing carried out before the withdrawal. If you have questions about the legal basis for a particular use, contact us using the details above.

How we share your information

We disclose personal information only in the following ways:

• Service providers and processors who handle information on our behalf under contracts that limit their use to providing services to us. These include our hosting provider (Railway) and our survey-form provider (Typeform), as well as our email and administrative tools. Typeform stores survey answers in our account and may process them under its own terms.
• Embedded video (Vimeo). Our survey videos are delivered by Vimeo. For embedded playback, Vimeo acts as an independent controller of limited connection data it receives to deliver the video, under its own privacy terms; we have Vimeo’s tracking features turned off.
• Prospective employers or candidates, as part of the matching services you ask us to provide — for example, sharing relevant profile information with a prospective employer, or relevant opportunity information with a prospective candidate.
• With your direction or consent, where you ask us to share information with someone.
• Legal, safety, and rights — where we are required by law or legal process, or where disclosure is necessary to protect the rights, safety, or property of Graydiant, our users, or others.
• Business transfers — in connection with a merger, acquisition, financing, or sale of assets, subject to the protections in this policy.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We do not place advertising or cross-site tracking technologies on our forms or survey pages.

Cookies and similar technologies

Our public website does not use cookies, and our website analytics do not rely on cookies or cross-site tracking. Our survey-invitation pages use a small number of essential cookies to keep each invitation working and to protect the survey form. Our access-controlled investor area uses essential authentication cookies to keep you signed in and secure your session. None of these are used for advertising or tracking across other sites.

Where the law requires consent for non-essential cookies, we ask for it before setting them. For full details of the cookies we use, their purposes, and how to control them, see our Cookie Policy.

International data transfers

Graydiant is based in the United States, and we and our service providers process personal information in the United States. If you are in the EEA or the UK, your personal information will be transferred to and processed in the United States, which may not provide the same level of data protection as your home country.

Where we transfer personal information out of the EEA or the UK, we rely on appropriate safeguards, including the European Commission’s Standard Contractual Clauses and, for the UK, the UK International Data Transfer Addendum (or the IDTA). Our arrangements with our service providers include these safeguards. You may request more information about the safeguards we use by contacting us at the details above.

How long we keep your information

We keep personal information only for as long as we need it for the purposes described in this policy, and then delete or de-identify it, unless the law requires us to keep it longer. Our current retention periods are:

You can ask us to delete your information sooner, as described under your rights below.

How we protect your information

We use reasonable technical and organizational measures designed to protect personal information against loss, misuse, and unauthorized access. These include encrypting survey recipient details at rest, storing IP addresses connected with survey activity only in one-way scrambled (hashed) form, limiting access to personal information to those who need it, and working with reputable service providers who maintain their own security practices.

No method of transmission or storage is completely secure, so we cannot guarantee absolute security. We also limit the information we collect in the first place, which reduces risk; this is why we ask you not to submit sensitive identifiers through our forms.

Your choices and marketing preferences

You are in control of the marketing communications you receive from us.

• Email. We send marketing emails only to people who have opted in, and you can unsubscribe at any time using the link in any marketing email or by contacting us. We will still send you non-marketing messages needed to respond to your inquiry or provide services you requested.
• Text messages (SMS). Where we offer text messaging, we send texts only to people who have separately opted in, and consent to texts is never a condition of using Graydiant. You can stop texts at any time by replying STOP, and reply HELP for help. Message and data rates may apply, and message frequency varies.
• Phone. You can ask us not to call you about marketing at any time.

We honor opt-out requests promptly as reasonable and, in any event, within the timeframes required by law. We keep records of your communication choices so that we can respect them.

Your privacy rights

Your rights depend on where you live. We honor the rights available to you under applicable law, and we will not discriminate against you for exercising them.

California residents. Under the California Consumer Privacy Act (as amended), you have the right to:

• know and access the personal information we have collected about you, including the categories, sources, purposes, and the categories of recipients;
• correct inaccurate personal information;
• delete personal information we have collected from you, subject to legal exceptions;
• opt out of the sale or sharing of your personal information — note that we do not sell or share personal information, so there is nothing to opt out of; and
• limit the use of sensitive personal information — if we provide password-protected access to the investor area, your log-in credentials are sensitive personal information, which we use only to authenticate you and provide access, and not for purposes that would trigger this right.

You may make these requests yourself or through an authorized agent. See also our separate California Notice at Collection.

EEA and UK residents. Under the GDPR and UK GDPR, you have the right to access your personal information; to have it corrected or erased; to restrict or object to processing (including objecting to direct marketing at any time); to data portability; and to withdraw consent where we rely on it. You also have the right to lodge a complaint with your local data protection authority — in the UK, the Information Commissioner’s Office (ICO).

Other U.S. states. If you live in a state with a comprehensive privacy law, you may have similar rights to access, correct, delete, and obtain a copy of your personal information, and to opt out of targeted advertising, sale, and certain profiling. We extend these rights to residents of those states as required by applicable law.

How to exercise your rights. Email us at admin@thatgraymatters.com. We will verify your request, respond within the timeframes required by applicable law, and let you know if an exception applies. If we decline a request, you may appeal where the law provides an appeal right.

Children’s privacy, changes, and contact

Children’s privacy. Graydiant’s website and services are intended for adults and are not directed to children. We do not knowingly collect personal information from anyone under 16. If you believe a child has provided us personal information, please contact us and we will delete it.

Changes to this policy. We may update this policy from time to time. When we make material changes, we will update the date at the top and, where required, provide additional notice or obtain your consent. We will not apply materially different uses to previously collected information without giving you notice and, where the law requires, obtaining your consent.

Contact us. If you have questions about this policy or how we handle your information, email us at admin@thatgraymatters.com.