Privacy Policy
Last updated: May 26, 2026
About this policy
Cultivar Collective is a boutique recruiting agency based in Toronto, working with companies and candidates across Canada and the United States. We take privacy seriously — both because the law requires it and because trust is the foundation of how we work with the people we represent.
This policy explains what information we collect, why we collect it, how we use it, and the choices you have. It applies to:
Candidates we work with or reach out to about opportunities
Clients who engage us to find talent for their teams
Visitors to cultivarcollective.ca
Our services are primarily directed at the Canadian and United States markets. While we welcome inquiries from elsewhere, this policy is written with Canadian privacy law as its foundation, with additional provisions for visitors and individuals located in the European Economic Area, the United Kingdom, and Quebec where noted.
Our Privacy Officer is Oleksandra, Founder of Cultivar Collective. If you have questions about anything in this policy, or want to exercise any of the rights described below, you can reach our Privacy Officer at info@cultivarcollective.ca.
What we collect
The information we collect depends on how you interact with us. Here's what that looks like in practice.
If you're a candidate
When you engage with us about a role or join our network, we typically collect:
Your name, email address, phone number, and location
Your resume or CV, including work history, education, and skills
Your LinkedIn profile and other professional links you share with us
Work authorization status when relevant to the roles you're considering
Compensation expectations and preferences about role type, company stage, and work arrangement
Notes from our conversations and interviews
References, when a specific opportunity calls for them and you've given us permission to contact them
Any other information you choose to share with us about your career or job search
If we reach out to you initially based on your public professional profile (such as LinkedIn), we limit what we collect to publicly available career information and contact you promptly so you can decide whether to engage further. You're free to ask us not to retain your information at that stage, and we'll honor the request.
Some categories of personal information are considered sensitive and require additional care — for example, information that could relate to health, disability, accommodation needs, immigration or work authorization status, or demographic information shared for diversity reporting purposes. We only collect sensitive information when it's necessary for a specific purpose, and we'll ask for your explicit consent before doing so.
If you're a client
When you engage Cultivar Collective for a search, or when we're in conversation about a potential engagement, we typically collect:
Names, titles, email addresses, and phone numbers of the people we work with at your company, including hiring managers, interviewers, and others involved in the search
Information about the role you're hiring for, including requirements, compensation range, team structure, and context about your business
Confidential information you share with us about your company, hiring plans, or strategic direction in the course of our work together
Your feedback on candidates we present and notes from interviews and decision-making conversations
Billing and payment information necessary to invoice for our services
Notes from our conversations and meetings
If you contact us about a potential engagement that doesn't move forward, we may retain a record of that conversation for our business records.
If you visit our website
When you visit cultivarcollective.ca, we automatically collect some information through cookies and analytics tools:
Pages you visit and how you navigate the site
Approximate location based on your IP address
Device and browser type
How you arrived at our site (for example, from a search engine, LinkedIn, or a direct link)
If you fill out a form on our site or send us an email, we collect the information you choose to share.
You can manage cookie preferences through the banner that appears when you first visit, and you can update your choices at any time through the link in our footer.
Our legal basis for processing your information
Privacy laws in Canada (PIPEDA), the European Economic Area (GDPR), and the United Kingdom (UK GDPR) require us to identify a legal basis for processing your personal information. Depending on the activity, our basis is one of the following:
Consent — for candidate sourcing, sharing your information with clients for specific opportunities, sending marketing communications, and use of non-essential cookies.
Performance of a contract — for delivering recruiting services under an engagement agreement and managing the business relationship with our clients.
Legitimate interests — for understanding how our website is used, improving our services, communicating about relevant opportunities with professionals in our network, and protecting our business. Where we rely on legitimate interests, we balance those interests against your rights and interests.
Legal obligation — for retaining records required by tax, accounting, employment, or other laws, and for responding to lawful requests from authorities.
If you have questions about the legal basis for a specific activity, you can ask our Privacy Officer at info@cultivarcollective.ca.
How we use this information
We use the information we collect to do our work well and to communicate clearly with the people we serve. Here's what that means in practice.
For candidates
We use your information to:
Understand your background, experience, and what you're looking for in your next role
Match you to relevant opportunities with our clients
Have informed conversations with you about your career and job search
Reach out to you about specific roles we believe could be a fit
Present you to clients for opportunities you've agreed to be considered for
Coordinate interviews and communicate updates throughout the process
Conduct reference checks when an opportunity calls for them and you've given us permission
Stay in touch about future opportunities while you're an active candidate in our network
Develop anonymized, aggregated insights about hiring trends, compensation, and the talent market — never in a way that identifies you individually
For clients
We use your information to:
Understand your hiring needs and the context around the role
Source, evaluate, and present candidates aligned with what you're looking for
Coordinate the search process, including scheduling, feedback, and decision-making
Communicate with you throughout the engagement
Invoice for our services and manage the business relationship
Maintain records of our work together for business and legal purposes
Develop anonymized, aggregated insights about hiring trends and the talent market — never in a way that identifies your company or any individual
For website visitors
We use information collected through the website to:
Understand how visitors use our site and improve it over time
Measure the effectiveness of our content and outreach
Respond to inquiries submitted through forms or email
Maintain the security and proper functioning of the site
Automated decision-making
We do not make decisions about candidates or clients based solely on automated processing. The tools we use to organize information and surface relevant matches are designed to support human judgment, not replace it. Every decision about presenting a candidate or recommending a hire is made by a person at Cultivar Collective.
If this ever changes — for example, if we introduce a tool that produces automated decisions with significant effects on individuals — we'll update this policy and seek consent where required by law.
What we don't do with your information
We don't sell your information to anyone. We don't share candidate information with companies you haven't agreed to be considered by. We don't use the confidential business information clients share with us for any purpose outside of the work we're doing together.
How we share information
We share information only when it's necessary to do our work, and only with the right safeguards in place. Here's how that works.
Sharing candidate information with clients
We share candidate information with our clients only when you've given us your permission to be considered for a specific opportunity. This permission is given for each role individually — never as blanket consent to share your information with any client we work with.
When you agree to be presented for a role, we typically share:
Your resume or CV
A summary of your background and why we believe you're a fit
Compensation expectations and other relevant context for the role
Notes from our conversations that help the client understand your candidacy
If at any point you decide you don't want to move forward with an opportunity, just let us know and we'll stop the process.
Keeping client information confidential
The information clients share with us is confidential. This includes hiring plans, internal context about the company, and decision-making conversations. We don't share this kind of information with other clients or with anyone outside our work together.
In the normal course of a search, we do share certain information with candidates being considered for a role — including the compensation range, role details, team and company context, and relevant feedback from interviews. This is standard practice and helps candidates make informed decisions about opportunities. We use judgment about what's appropriate to share and when, and we don't share information that a client has indicated should stay confidential.
Service providers we rely on
We use third-party service providers to operate our business. These include:
Applicant tracking and customer relationship management software to organize candidate and client information
Email and productivity tools to communicate and manage our work
Website hosting and analytics providers
Scheduling and meeting tools
Payment and invoicing platforms
These providers process information on our behalf under written agreements that require them to handle it securely and only for the purposes we've engaged them for. A current list of the specific providers we use is available on request — just email our Privacy Officer at info@cultivarcollective.ca.
Some of these providers are based in or store data in the United States, which we describe further below.
Legal requirements
We may disclose information when we're legally required to — for example, in response to a court order, subpoena, or regulatory request, or to protect our legal rights. If this happens, we'll only share what's necessary to comply with the request.
Business changes
If Cultivar Collective is ever acquired, merged with another business, or restructured, candidate and client information may be transferred as part of that transaction. Any new owner would be required to honor the commitments we've made in this policy.
Where your information is stored
Cultivar Collective is based in Canada, but some of the service providers we work with are based in or store data in the United States and, in some cases, other countries. This includes our applicant tracking system, email and productivity tools, and website infrastructure.
When information is transferred outside of Canada, we put safeguards in place to protect it. These typically include written contracts with our service providers that require them to maintain appropriate security and confidentiality standards, and — where applicable to transfers involving the European Economic Area or the United Kingdom — Standard Contractual Clauses or equivalent mechanisms recognized under those jurisdictions' privacy laws.
When information is stored or processed in the United States, it becomes subject to US laws, including laws that may allow government authorities to access it under certain circumstances. We choose service providers carefully, but we want you to understand that cross-border data transfer is part of how we operate.
If you have questions about where specific information is stored or how it's protected, you can contact our Privacy Officer at info@cultivarcollective.ca.
How long we keep it
We keep information only as long as we need it to do our work, meet our legal and business obligations, and stay in touch with people who want to remain in our network. Here's what that looks like in practice.
Candidates
We keep candidate information for up to two years after our last meaningful interaction with you — for example, a conversation about a role, an interview, or a check-in about your job search. After that, we delete or anonymize your information unless you've given us your consent to retain it longer (for example, to stay in our network for future opportunities).
If you'd like us to remove your information sooner, you can ask us at any time and we'll take care of it.
Clients
We keep client information for the duration of our working relationship and for a reasonable period afterward — typically up to seven years — to maintain business records, comply with tax and accounting obligations, and support any future work together.
Website visitors
Information collected through website analytics is retained according to standard analytics practices, generally between 14 months and 26 months depending on the tool. You can manage cookie preferences through the banner on our site.
Records we may need to keep longer
In some cases, we may need to retain certain information beyond these periods to comply with legal obligations, resolve disputes, or enforce our agreements. When we do, we keep only what's necessary and protect it the same way we protect everything else.
Your rights
You have meaningful rights over the personal information we hold about you. These rights apply to everyone we work with under Canadian privacy law. Some additional rights may apply if you're located in the European Economic Area, the United Kingdom, or other jurisdictions with specific privacy frameworks — those are described in the EEA/UK section below.
Access
You can ask us what information we have about you, how we've used it, and who we've shared it with. We'll respond within a reasonable timeframe, typically within 30 days.
Correction
If any information we have about you is inaccurate or out of date, you can ask us to correct it.
Deletion
You can ask us to delete the information we hold about you. We'll honor your request unless we're legally required to keep certain information — for example, billing records or information needed to resolve a dispute. If that's the case, we'll explain what we need to keep and why.
Withdrawing consent
You can withdraw your consent for us to use your information at any time. For candidates, this means we'll stop reaching out about opportunities and remove you from our active network. Some withdrawals may affect our ability to work together — for example, if you withdraw consent for us to share your information with clients, we won't be able to present you for opportunities — and we'll be clear with you about what to expect.
How to exercise your rights
To exercise any of these rights, just email our Privacy Officer at info@cultivarcollective.ca. We may ask you to provide reasonable proof of identity before acting on a request — this is to protect you from someone else trying to access or change your information. The level of verification we ask for will be proportionate to the sensitivity of the request.
Asking questions or making a complaint
If you have questions about how we've handled your information, or if you believe we haven't met our obligations under this policy or applicable privacy laws, you can contact our Privacy Officer at info@cultivarcollective.ca. We take these concerns seriously and will respond promptly.
If you're not satisfied with our response, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada (priv.gc.ca) or, depending on where you live, your provincial privacy regulator — for example, the Commission d'accès à l'information du Québec, the Information and Privacy Commissioner for British Columbia, or the Office of the Information and Privacy Commissioner of Alberta.
If you're located in the European Economic Area or the United Kingdom
If you're located in the EEA or UK, the General Data Protection Regulation (GDPR) and UK GDPR give you additional rights beyond those described above. These include:
Right to data portability — you can ask us to provide your personal information in a structured, commonly used, machine-readable format, where technically feasible.
Right to object — you can object to our processing of your information based on legitimate interests, including for marketing purposes.
Right to restrict processing — you can ask us to limit how we use your information in certain circumstances, such as while we verify a correction request.
Right not to be subject to solely automated decisions — as described above, we don't make decisions about you based solely on automated processing.
To exercise any of these rights, contact our Privacy Officer at info@cultivarcollective.ca. You also have the right to lodge a complaint with your local data protection authority.
Cultivar Collective does not have an EU or UK establishment. For most processing activities involving EEA or UK individuals, our Privacy Officer is your point of contact for questions and requests.
If you're located in Quebec
Quebec's Act respecting the protection of personal information in the private sector (Law 25) provides additional rights and protections. These include the right to be informed when your personal information is used to make a decision based exclusively on automated processing, the right to data portability, and specific requirements around cross-border transfers. The rights and protections described throughout this policy apply to Quebec residents, and our Privacy Officer — Oleksandra, Founder — is the designated person responsible for the protection of personal information for the purposes of Law 25.
If our work with Quebec candidates or clients becomes a focused area of our business, we will provide a French-language version of this policy and additional Law 25 disclosures. In the meantime, Quebec residents can contact our Privacy Officer at info@cultivarcollective.ca with any questions, requests, or complaints.
Cookies and website tracking
When you visit cultivarcollective.ca, we use cookies and similar tools to make the site work, understand how it's being used, and improve it over time. Here's what's involved.
Essential cookies
These cookies are necessary for the site to function — for example, remembering your cookie preferences or supporting basic site features. They're always active and don't require your consent.
Analytics cookies
We use analytics tools to understand how visitors find and use our site, which pages are most useful, and where we can improve. This information is collected in aggregate and isn't used to identify you individually.
Advertising and social media cookies
If we use tools from advertising and social media platforms — including LinkedIn and Meta — that help us understand how people find our site or measure the effectiveness of our content, those tools may set cookies that track activity across sites. Where these are deployed, they will only be activated with your consent through our cookie banner.
Embedded tools
Our website may include embedded tools like scheduling widgets and contact forms. These may set their own cookies as part of how they function.
Managing your preferences
When you first visit our site, you'll see a cookie banner asking which categories of cookies you're comfortable with. You can accept all, reject non-essential cookies, or customize your choices. You can change your preferences at any time using the link in our website footer.
If you'd prefer to manage cookies at the browser level, most browsers let you block or delete cookies through their settings. Note that blocking essential cookies may affect how the site functions.
Electronic communications
We communicate with candidates and clients primarily by email and sometimes by phone or text message. Here's what to expect.
Outreach to candidates
We may reach out to you about specific job opportunities we believe could be a fit, based on your professional background and experience. Where we do so based on publicly available professional information (such as a LinkedIn profile), we rely on the conspicuous publication exception under Canada's Anti-Spam Legislation (CASL), and we make sure our outreach is relevant to your professional role. If we contact you about a role and you'd prefer not to hear from us, just let us know — we'll respect that immediately.
Outreach to companies
We may reach out to companies about hiring needs, market insights, or to introduce Cultivar Collective's services. These messages are directed to people in roles where this kind of outreach is relevant — such as founders, hiring managers, and people leaders. Every message includes a way to opt out, and we honor opt-out requests promptly.
Ongoing communication
Once we're working together, we'll communicate as needed to support the search, share updates, and stay in touch about future opportunities. You can ask us to stop contacting you at any time.
How to opt out
To stop receiving messages from us, you can reply to any email asking to be removed, or contact us at info@cultivarcollective.ca. We'll process opt-out requests within 10 business days, as required by Canadian anti-spam law.
Security
We take reasonable steps to protect the information we hold from unauthorized access, loss, or misuse. This includes:
Choosing service providers that maintain appropriate security standards
Using strong access controls and authentication on the systems we use
Limiting access to information based on what's necessary for the work
Keeping our software and tools up to date
No system is completely secure, and we can't guarantee that information will never be compromised. If a security incident occurs that creates a real risk of significant harm to individuals whose information we hold, we will notify the affected individuals and the Office of the Privacy Commissioner of Canada as required under PIPEDA's mandatory breach notification rules, and we will notify any other regulators or individuals as required by applicable law. We will also maintain internal records of any breach as required.
If you have concerns about the security of your information or notice anything that doesn't seem right, please contact our Privacy Officer at info@cultivarcollective.ca.
Children's privacy
Cultivar Collective's services are designed for working professionals, and our website is not directed at children. We don't knowingly collect personal information from anyone under the age of 18. If you believe we've inadvertently collected information from someone under 18, please contact us at info@cultivarcollective.ca and we'll delete it.
Changes to this policy
We may update this policy from time to time to reflect changes in our practices, the tools we use, or applicable laws. When we make changes, we'll update the "last updated" date at the top of this page.
If we make significant changes that affect how we handle your information, we'll provide notice at least 30 days before the changes take effect — for example, by email if we have an active relationship with you, or through a prominent notice on our website.
We encourage you to review this policy periodically so you know how your information is being handled.
Contact us
If you have questions about this policy, want to exercise any of your rights, or have concerns about how we've handled your information, please reach out to our Privacy Officer:
Oleksandra, Founder & Privacy Officer
Cultivar Collective
Email: info@cultivarcollective.ca
Toronto, Ontario, Canada
We're committed to addressing privacy questions and requests promptly and thoughtfully. If you contact us about a privacy matter, we'll respond within a reasonable timeframe — typically within a few business days, and within 30 days for formal access or deletion requests as outlined above.