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Privacy Policy

Effective date: May 7, 2026 · Last updated: May 23, 2026

On this page 1. Scope 2. Information we collect 3. How we use information 4. AI processing 5. When we share information 6. Schools & student data (FERPA, COPPA, SOPIPA) School privacy package 7. Retention & deletion 8. Security 9. Your rights 10. Children 11. International users 12. Changes to this policy 13. Contact

1. Scope

This Privacy Policy describes how EverRoad Pathways LLC, doing business as GiftMatch Compass (“GiftMatch Compass,” “we,” “us”), collects, uses, shares, and protects information when you use GiftMatch Compass (the “service”). It applies to all users, with additional terms for Schools and student users in Section 6.

2. Information we collect

CategoryExamplesSource
Account informationName, email, password hash, optional profile photo, optional U.S. state.You (at signup) or your Google sign-in if you use it.
Assessment responsesYour answers to the trait-scoring assessment, preference/reflection questions, and the resulting trait profile.You (when you take the assessment).
Experience and education contentResume text extracted during upload and job/volunteer/project/education entries you type or save.You.
Generated outputArchetype profile, narrative, career matches, reflections, saved self-serve AI Coach tool work, and related artifacts personalized to you.Generated by the service from the inputs above.
Feedback“Was this helpful?” ratings and similar in-product feedback.You.
Billing informationFor paid plans, limited billing metadata (subscription status, last-four, country) received from Paddle.Paddle, our authorized reseller and merchant of record.
Technical informationIP address, user agent, session cookie, timestamps, error logs.Your browser.
Approximate locationFor users in the United States, an approximate location (U.S. state, and on the AI Coach jobs feature, approximate city) derived from your IP address at the time you visit, used to localize features such as state-specific salary notes and to pre-fill the job-search location. For users outside the United States, this derivation is skipped.Derived server-side from your IP address using a locally hosted IP-to-location database. No third-party service receives your IP for this lookup.

When you upload a resume, we extract text from the file to create structured experience or education entries. We do not send the original uploaded file to OpenAI for parsing or keep it after processing. We store the extracted entries and any generated output you choose to save. We do not collect GPS-precise geolocation, government identifiers (SSN, driver’s license, passport), biometrics, health records, or financial account numbers, and we ask you not to include such data in resume or experience entries. The approximate location described in the table above is derived at city/state resolution from your IP address; it is not GPS-precise.

3. How we use information

We use your information to: (a) create and operate your account; (b) generate your archetype, narrative, career matches, deep dives, and reflections; (c) secure the service and prevent abuse; (d) deliver the plan you purchased and process renewals; (e) respond to support requests; (f) improve the service, including through aggregate analytics (never using covered student data for advertising); and (g) comply with legal obligations.

4. AI processing

To generate narrative content, parse uploaded documents, support self-serve AI Coach tools, and provide interview voice practice, we send relevant portions of your trait profile, archetype profile, saved experience/education entries, extracted document text, typed answers, or audio recordings to OpenAI under its API or commercial terms. Resume parsing sends extracted text, not the original uploaded resume file. When voice practice is enabled, recorded answers are sent to OpenAI’s audio transcription endpoint and generated interview questions may be sent to OpenAI’s speech endpoint. OpenAI processes inputs to return output to us and, under the API or commercial terms we use, does not train its public models on your content by default. We do not include your password or billing data in these prompts. Generated output is returned to the service and stored with your account when you save it.

5. When we share information

We share information only as follows:

  • Service providers that help us run the service under contract and only for the purposes we authorize — e.g., cloud hosting, email delivery, error logging, OpenAI as described in Section 4, and Paddle for billing.
  • Career and job-search providers when you use self-serve AI Coach job search — for example, the career title and location you search may be sent to job-listing providers so we can return relevant postings and application links. The approximate location described in Section 2 is derived locally on our server and is not sent to any third party.
  • Schools that have licensed the service for their students — we share that student’s account and generated output back to the School as authorized in the School agreement.
  • Legal and safety — when required by law, subpoena, or court order, or to protect the rights, safety, or property of users or the public.
  • Business transfer — in a merger, acquisition, or asset sale, subject to the receiving party honoring this Policy for previously collected information.

We do not sell personal information, do not use covered student information for targeted advertising, and do not build advertising profiles from student data.

6. Schools & student data (FERPA, COPPA, SOPIPA)

When a School licenses GiftMatch Compass for its students:

  • FERPA (20 U.S.C. § 1232g; 34 C.F.R. Part 99). To the extent the School discloses education records to us, GiftMatch acts as a “school official” with a “legitimate educational interest,” uses such records only for the educational purposes authorized by the School, is under the School’s direct control with respect to those records, and does not re-disclose them except as the School directs or the law requires.
  • COPPA (15 U.S.C. §§ 6501–6506; 16 C.F.R. Part 312). GiftMatch does not knowingly collect personal information directly from children under 13 outside of a School-authorized deployment. Where a School provides GiftMatch to students under 13, the School provides verifiable parental consent consistent with the FTC’s school-authorization guidance, and GiftMatch limits collection to information reasonably necessary for the educational service. OpenAI Zero Data Retention / Modified Abuse Monitoring has been approved for EverRoad’s specified OpenAI API organization, but applies only when enabled for the relevant OpenAI project, used through that configured project, and limited to eligible OpenAI endpoints and features. Under-13 School deployments will not use OpenAI-based personal-data processing unless either those controls are active for the deployment and the traffic uses eligible OpenAI endpoints/features, or a separate written arrangement permits it.
  • AI processing for student records. For School deployments involving students under 18 or education records, OpenAI-based personal-data processing is routed only through a configured OpenAI Zero Data Retention / Modified Abuse Monitoring project and eligible OpenAI endpoints, or handled as separately approved in the School’s written agreement, data-processing terms, and subprocessor approval.
  • SOPIPA / state student-privacy laws. For student users covered by California’s SOPIPA (Cal. Bus. & Prof. Code §§ 22584 et seq.) and analogous state laws, GiftMatch does not use covered information to target advertising, does not create non-educational profiles, does not sell or rent covered information, and maintains reasonable security practices. Parents and eligible students may request access, correction, or deletion through their School.
  • Data export & deletion. Schools may request export or deletion of their students’ records at any time. On termination of a School agreement, we delete or return covered student data within a commercially reasonable period unless retention is required by law.

Schools, parents, and procurement teams can also review our School Privacy & Compliance Package, which includes school data terms, current launch prerequisites, a subprocessor list, security posture, and AI processing details. If you are a parent or eligible student with questions about a School deployment, contact your School first; they can loop us in under their agreement.

7. Retention & deletion

We keep account and generated content for as long as your account is active. If you delete your account (or a School deletes a student account), we remove account-linked profile, assessment, generated, and saved work data from active user systems within a commercially reasonable period and purge routine backups on our standard backup-rotation schedule. Some records may be retained longer when required or reasonably necessary for security, billing, legal, compliance, or audit purposes.

8. Security

We use commercially reasonable administrative, technical, and physical safeguards, including encrypted transport (HTTPS), hashed passwords, access controls, and audit logging. No system is perfectly secure, and we cannot guarantee that unauthorized access will never occur. If we discover a security incident affecting your information, we will notify you and applicable authorities consistent with law.

9. Your rights

Depending on where you live, you may have rights to access, correct, delete, or export your personal information, to opt out of certain uses, and to appeal a decision we make about a request. To exercise a right, email us from the address on your account, or — if you are a student under a School license — contact your School.

California residents: you may also request a list of the categories of personal information we have collected and shared in the last twelve months. We do not “sell” personal information or share it for cross-context behavioral advertising as those terms are defined under the California Consumer Privacy Act.

10. Children

The direct-signup service is intended for users 13 and older. We do not knowingly collect personal information from children under 13 through direct signup. If we learn we have collected such information without the required consent, we will delete it promptly. Schools may onboard students under 13 only through a signed agreement that provides verifiable parental consent consistent with COPPA.

11. International users

GiftMatch Compass is operated by EverRoad Pathways LLC from the United States and is directed at users in the United States. We do not market the service to, or actively offer it in, the European Economic Area, the United Kingdom, Australia, or other jurisdictions outside the United States. Pricing is displayed in U.S. dollars only, and the service interface is offered only in English. If you access the service from outside the U.S., you do so on your own initiative; some features (such as state-specific salary notes and automatic job-search location pre-fill) are U.S.-only and will not be available for your account. You understand that your information will be processed in the U.S., which may have different data-protection laws than your country, and by using the service you consent to that transfer.

12. Changes to this policy

We will update this Policy as the service evolves. When we make material changes, we will revise the “Last updated” date and provide additional notice when appropriate (for example, by email or in-app notice). Material changes to how we handle student data will be communicated to Schools under their agreements.

13. Contact

Privacy questions, data-rights requests, or School/parent inquiries can be sent to support@giftmatchcompass.com. Please indicate whether you are an individual user, a parent/guardian, or a School administrator so we can route the request appropriately.

GiftMatch Compass
operated by EverRoad Pathways LLC
Columbus, Ohio, United States

© 2026 GiftMatch Compass · operated by EverRoad Pathways LLC · Columbus, Ohio, United States

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