Draft for review. The United States has no single federal privacy law, so this wording is written to the strictest commonly applicable state standard, principally California’s CCPA as amended by the CPRA. It has not yet completed a legal review, so it does not yet bind anyone.

Privacy notice

This notice explains how Accolgo handles your personal information. Accolgo is an early-warning system for the first months of a new job. It asks a new starter, their line manager and a buddy short check-in questions, and shares a plain-language summary with the line manager so that a supportive conversation happens at the right moment.

Which law applies

There is no single federal privacy law in the United States covering information of this kind. Instead there is a patchwork of state statutes. This notice is written to California’s Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), because it is the most prescriptive and because its exemption for employee and job-applicant information expired on 1 January 2023, which places workforce data of exactly this kind squarely within its scope. If you are covered by another state’s law, you keep whatever rights that law gives you.

Who is responsible

Your employer (the organization that invited you) decides why and how your check-in information is used, so under the CCPA it is the business. Accolgo processes it only on that employer’s documented instructions, as its service provider, which is a defined role under the CCPA and a deliberately narrow one: a service provider may not sell your information, may not share it for cross-context behavioral advertising, and may not use it for its own purposes. Questions should go first to your organization’s people team; you can also contact Accolgo directly.

What we collect

Your name, work email, job title, start date and who your manager and buddy are.
Your check-in answers: worded replies to short questions, an optional note, and an optional request for a conversation.
From managers and buddies: their check-in answers about how the starter seems.
Follow-up records: that a manager marked a conversation as done, with an optional short note.

We collect this for one purpose, to support your settling in, and that purpose is explained to you before your first check-in. We do not collect health, financial, biometric, precise geolocation or any other category the CCPA treats as sensitive personal information.

What we never do

We do not sell your personal information, and we do not share it for cross-context behavioral advertising. Under the CCPA both of those are defined terms, and both are simply outside what this product does.
No scores, ratings or league tables of people.
No answer is shown to another respondent: the manager sees a summary and, where it explains a signal, the starter’s own worded replies, never the buddy’s raw answers presented as anyone else’s.
A “private word” with someone senior who is not your manager reaches only the head of people. Your manager is never told it was raised. This is enforced in the database itself, so a manager cannot reach it through the app, an export, or a direct query.
No automated decision is made about you. Accolgo surfaces a signal and suggests a conversation; every decision about a person stays with people.
Nothing is collected covertly: every check-in is asked for openly, by email, and this notice is shown before the first one.

Your rights

Under the CCPA you have the right to know what personal information is collected about you and why, to access a copy of it, to have it corrected if it is wrong, to have it deleted, and not to be discriminated against for exercising any of those rights. Because Accolgo does not sell or share information as those terms are defined, there is no opt-out to exercise, but the right exists and we will confirm that position on request.

A request for your information includes what your manager and buddy said about you, balanced against their own privacy interest. Requests go to your organization’s people team or to Accolgo, and are acknowledged within ten business days and answered within forty-five calendar days, extendable once where the CCPA permits.

If you believe your information has been mishandled, you may complain to the California Privacy Protection Agency or your state Attorney General. We would ask that you raise it with us or your employer first so we can put it right.

Where information lives

Your check-in information is stored in the European Union, in Supabase’s Dublin (Ireland) region. This is worth stating plainly to an American reader, because it is not what most US buyers assume. Some operators process limited information elsewhere: transactional email (Resend) and, when nudge drafting is enabled, the drafting provider (Anthropic) may process it in the United States, and error monitoring (Sentry) in the EU.

No US state privacy law currently restricts where this information may be stored. Accolgo remains responsible for it wherever it is processed, and requires each processor to protect it to a comparable standard by written agreement.

How long we keep it

Personal information is kept only as long as the onboarding program needs it, then deleted on the schedule in our data retention policy, or earlier if your organization asks or you exercise your right to deletion, save for anything the law requires us to keep. The CCPA requires that retention period to be disclosed rather than open-ended, which is what the retention page does.