Privacy Policy

Empower HR provides HR, payroll and performance software for Caribbean businesses. It is operated by bConsulted LLC, 5990 Richmond Highway, Alexandria, VA 22303. [Company registration number and a privacy contact to be confirmed.] For the employee data a customer keeps in Empower HR, the customer is the controller and we process it on the customer's instructions. For the data of visitors to this site and of people who contact us, we are the controller.

[To be confirmed by counsel: the Jamaica Data Protection Act, 2020, and the laws of the other territories where customers use Empower HR.] [Name and contact details of our data protection officer, if one is required.]

• From visitors: pages visited, the campaign that brought you here (UTM tags) and a one-way hash of your IP address.
• From people who contact us or join a list: your name, email, company, phone, territory and message.
• From customers: account details, and the employee records, documents, pay and performance data a customer enters.

These providers process data on our behalf. [Counsel to confirm the list, transfer safeguards and contracts.]

• Google Cloud and Firebase (USA, US East): hosting, databases, sign-in and messaging between our systems.
• Amazon Web Services (USA, US East): storage of employee documents, CVs and payroll documents.
• Resend (USA): sending email.
• Anthropic (USA): AI features, such as reading CVs, when a customer uses them.
• OpenAI (USA): search embeddings for Recruiting and payroll's regulatory library.
• Sentry (European Union, Germany): error reports from the payroll app.
• Google Analytics and PostHog (USA): website and product analytics, where switched on.
• Stripe (USA): card payments for paid plans.
• GoHighLevel (USA): our sales and marketing follow-up for people who contact us.

[Retention periods to be confirmed.] Recruiting candidates are anonymised after the customer's retention period (36 months unless the customer sets another). Customers decide how long they keep their employees' records.

[Counsel to set out the rights of data subjects under the applicable laws, and how to exercise them.] Employees of a customer should contact their employer first. Anyone can write to [privacy contact email].

[How we tell customers and visitors about changes to this policy.]