Legal

Recruitment Marketplace Privacy Policy

Last updated July 20, 2026

This Recruitment Marketplace Privacy Policy explains how 2raywall Solutions Inc., doing business as 2raywall (“Company”, “we”, “us”, or “our”), collects, uses, and shares personal information of candidates, job seekers, and other individuals (“you”) in connection with the CruiseControl Recruitment Marketplace and job board (the “Marketplace”). It applies in addition to our Recruitment Marketplace Terms of Use (https://cruisecontrolapp.com/legal/marketplace-terms) and our general Privacy Policy (https://cruisecontrolapp.com/legal/privacy).

Our role. With respect to candidate-submitted information collected through the public and cross-employer features of the Marketplace, 2raywall acts as an independent data controller. This is different from our role elsewhere on the CruiseControl platform, where we act as a data processor for our business customers. When you apply to, or interact with, an employer through the Marketplace, that employer separately and independently becomes a data controller of the information it receives and processes it under its own privacy practices; we are not responsible for an employer’s handling of your information.

1. INFORMATION WE COLLECT

We collect the following categories of personal information in connection with the Marketplace:

  • Profile and contact data: name, email address, phone number, location, and other contact details.
  • Career information: résumé/CV, work and education history, skills, certifications, qualifications, and other information you include in your profile or applications.
  • Application data: the Job Postings you view or apply to, your applications, cover letters, answers to screening questions, and related materials.
  • Communications: messages you send through the Marketplace and correspondence with us.
  • Account credentials: username, password, and authentication data (including single sign-on identifiers, if used).
  • Technical and usage data: IP address, device and browser characteristics, and information about how you use the Marketplace, collected automatically and through cookies and similar technologies (see our Cookie Policy: https://cruisecontrolapp.com/legal/cookies).
  • Information from other sources: information provided by employers, references you authorize, or public professional profiles you choose to connect.

Sensitive and biometric information. We do not collect biometric identifiers (such as facial geometry or voiceprints) unless a specific feature expressly offers it, in which case we will provide notice and obtain consent as required by law (including the Illinois Biometric Information Privacy Act and similar laws). Please provide only the information necessary for your application, and avoid submitting sensitive information that an Employer has not requested. Note that Employers may separately conduct their own background or reference checks through their own providers; those checks are controlled by the Employer and are outside this policy.

2. HOW WE USE YOUR INFORMATION

We use your personal information to:

  • Create, host, and maintain your candidate profile and account;
  • Operate the Marketplace, enable search, and match candidates with relevant Job Postings;
  • Submit and deliver your applications and Candidate Content to the employers you apply to or that you make your profile available to;
  • Enable communications between you and employers;
  • Send you service, application status, and account notifications, and — where permitted — relevant job alerts and marketing communications you may opt out of;
  • Maintain the security, integrity, and proper functioning of the Marketplace, and detect and prevent fraud and abuse;
  • Analyze and improve the Marketplace, including through aggregated, anonymized, and de-identified data used for analytics, benchmarking, research, product improvement, and the development and training of statistical, machine learning, and artificial intelligence models, provided such data does not identify you; and
  • Comply with legal obligations and enforce our terms and policies.

3. LEGAL BASES FOR PROCESSING

Where the EU/UK General Data Protection Regulation applies, we process your personal information on the following bases: your consent; the performance of a contract with you or steps taken at your request; our legitimate interests in operating and improving the Marketplace and connecting candidates with employers; and compliance with our legal obligations. You may withdraw consent at any time without affecting processing carried out before withdrawal.

4. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information, and we do not “share” it for cross-context behavioral advertising. We disclose personal information only as follows:

  • Employers. When you apply to a Job Posting, make your profile visible, or otherwise interact with an employer, we provide your application and relevant Candidate Content to that employer, which then acts as an independent controller of the information it receives.
  • Service providers. With vendors that perform services on our behalf (such as hosting, email delivery, analytics, and security), bound by appropriate confidentiality and data protection obligations.
  • Public and search-engine visibility. Where such features are enabled, certain profile and application information may be publicly visible and indexed by search engines, as described in the Marketplace Terms of Use.
  • Legal and safety. Where necessary to comply with law, respond to lawful requests, or protect the rights, property, or safety of any person.
  • Business transfers. In connection with a merger, acquisition, financing, or sale of assets.

5. INTERNATIONAL DATA TRANSFERS

Our servers are located in the United States, and your information may be transferred to, stored, and processed in the United States and other countries. Where we transfer personal information out of the European Economic Area, the United Kingdom, or Switzerland, we rely on appropriate safeguards recognized under applicable law — in particular, the European Commission’s Standard Contractual Clauses (and the UK International Data Transfer Addendum, as applicable). You may request a copy of the safeguards we use by contacting us using the details below.

6. HOW LONG WE KEEP YOUR INFORMATION

We keep your personal information for as long as your account or profile is active and as necessary to provide the Marketplace, and thereafter for any additional period required or permitted by law. You may update or request deletion of your profile at any time, subject to legal retention requirements. Note that once you have submitted an application or information to an employer, that employer retains and controls its own copy independently.

7. HOW WE KEEP YOUR INFORMATION SAFE

We implement appropriate technical and organizational security measures designed to protect your personal information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You should access the Marketplace within a secure environment.

8. MINORS

The Marketplace is intended for individuals who are at least 18 years of age, and we do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from a person under 18, we will delete it as quickly as reasonably practical.

9. YOUR PRIVACY RIGHTS

Depending on where you live, you may have rights to access, correct, delete, restrict, or object to the processing of your personal information, to data portability, and to withdraw consent. If you are in the EEA or the UK, you also have the right to lodge a complaint with your local data protection supervisory authority.

If you are a California resident, you have rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the “CCPA”), including the right to know, delete, and correct your personal information, to opt out of the sale or sharing of personal information, and to limit the use of sensitive personal information. As stated above, we do not sell or share your personal information. We will not discriminate against you for exercising your rights.

To exercise any of these rights, contact us using the details below. We will verify your request using information associated with your account, and you may use an authorized agent where permitted by law.

10. COOKIES

We use cookies and similar technologies in the Marketplace as described in our Cookie Policy: https://cruisecontrolapp.com/legal/cookies.

11. UPDATES TO THIS POLICY

We may update this Recruitment Marketplace Privacy Policy from time to time. The updated version will be indicated by an updated “Last updated” date and will be effective as soon as it is accessible. We encourage you to review it periodically.

12. HOW TO CONTACT US

If you have questions or comments about this policy, or wish to exercise your privacy rights, contact us at contact@cruisecontrolapp.com or by post to:

2raywall Solutions Inc.
18117 Biscayne Blvd Suite 201
Miami, FL 33160
United States