Privacy Policy

TruGem Privacy Policy

Last updated: 7/3/2026

TruGem is a product of STARK ANALYTICS, LLC ("Stark Analytics," "we," "us"). This Privacy Policy explains how we collect, use, and protect information when you use the TruGem platform (the "Service").

1. Who we are.

TruGem is a hiring decision-intelligence platform that helps organizations conduct structured candidate evaluations. Stark Analytics, LLC is located at 6601 Yale Street, #121, Westland, MI 48185. For privacy questions, contact support@stark-analytics.com.

2. Information we collect.

• Account information: names, email addresses, and roles of users (HR administrators, hiring managers, and reviewers) who access the Service.
• Candidate information: information your organization enters about candidates, which may include names, email addresses, resumes, source information (such as how the candidate was sourced), and evaluation scores across defined competency dimensions.
• Evaluation data: scores and assessments entered by reviewers and managers, and private notes. Private notes are visible only to the individual who wrote them.
• Usage information: basic technical data needed to operate and secure the Service.

3. How we use information.

We use information to provide the Service: to enable structured candidate evaluations, generate aggregated and anonymized scoring, produce reports, and support hiring decisions made by your organization. We use account information to authenticate users and enforce role-based access.

4. Your organization controls candidate data.

Candidate and evaluation data is entered and controlled by the organization (the "customer") using the Service. Each organization's data is isolated from other organizations. Stark Analytics processes this data on behalf of the customer and does not use candidate data for purposes other than providing the Service.

5. How we share information.

We do not sell personal information. We may share information with service providers who help us operate the Service (such as hosting and infrastructure providers) under appropriate confidentiality obligations, and as required by law.

6. Data security.

We use reasonable technical and organizational measures to protect information, including access controls and tenant isolation. No method of transmission or storage is completely secure.

7. Data breach response.

We maintain administrative, technical, and organizational safeguards designed to protect personal information, including access controls, tenant isolation, and audit logging. In the event we become aware of a data breach affecting personal information processed through the Service, we will: (a) act promptly to investigate, contain, and remediate the incident; (b) assess the nature and scope of the affected information; and (c) notify affected organizations (our customers) without undue delay so they can meet their own notification obligations. Where we are legally required to provide notification of a breach, we will do so in accordance with applicable law and within the timeframes those laws require. Because candidate and evaluation data is controlled by the organization using the Service, we will support and coordinate with the affected organization regarding any notifications to individuals, which are generally the responsibility of that organization as the data controller.

8. Data retention.

We retain candidate and evaluation records in accordance with a retention schedule designed to meet applicable legal recordkeeping obligations, which for hiring records can require retaining information for a period of time after a hiring decision. Authorized administrators within your organization may place a legal hold on a hiring decision; while a hold is in effect, candidate records associated with that decision cannot be deleted or anonymized, regardless of any deletion request, until the hold is lifted. Subject to any applicable legal hold, authorized administrators may delete a candidate from the Service; because a candidate may appear in more than one hiring decision, this removes or anonymizes that candidate's records across the organization. When a candidate is deleted, records associated with completed (closed) evaluations are anonymized rather than fully removed: the candidate's name and personal details are permanently removed while the underlying evaluation record is preserved, so the integrity of past hiring decisions is maintained. Records not associated with a completed evaluation are fully deleted. Every such deletion is recorded in a permanent, tamper-resistant deletion log available to your organization's administrators, providing an accountable record of what was deleted or anonymized, by whom, and when. Organizations with questions about retention or deletion may contact support@stark-analytics.com.

9. Your rights.

Depending on your location, you may have rights regarding your personal information, such as access, correction, or deletion. Because candidate data is controlled by the organization using the Service, individuals should direct such requests to the relevant organization; we will support the organization in fulfilling them. For other requests, contact support@stark-analytics.com.

10. Confidentiality of evaluations.

Individual reviewer scores are anonymized in aggregate views by default. Authorized administrators may access individual scores only through a logged, audited process within the Service. Private notes are an exception to administrative access: they are visible only to the individual who wrote them and are not accessible to other users, including administrators.

11. Changes to this policy.

We may update this Privacy Policy from time to time. Material changes will be reflected by updating the "Last updated" date.

12. Contact.

Questions about this Privacy Policy or our data practices: support@stark-analytics.com, or STARK ANALYTICS, LLC, 6601 Yale Street, #121, Westland, MI 48185.