Privacy Policy.

Effective Date: December 1, 2025

Sanctum (“Sanctum,” “we,” “us,” and “our”) delivers digital work by outsourcing business processes to human agents. This Privacy Policy explains how we collect, use, and share your personal information, and how you can exercise your privacy rights.

1. Scope

This Privacy Policy applies to personal information processed by us in our business, including on our websites, mobile applications, and related online and offline offerings (collectively, the “Services”).

2. Personal Information We Collect

The personal information we collect depends on how you interact with the Services and applicable law. We may collect different information depending on whether you are:

• a Client of Sanctum (“Client”) outsourcing a business process (“Project”)
  
  
• an Agent performing work for a Client (“Agent”)
  
  
• another type of individual interacting with the Services
  
  

2.1 Information You Provide to Us

Account information

When you create an account (Client or Agent), we may collect your name, physical and email address, date of birth, phone number, username, and password.

Client information

If you are a Client, we may also collect business name and address, your title, and industry information. We may also collect information about Authorized Users you allow to access the Services on your behalf.

Agent information

If you are an Agent, we may collect background information (education, employment history, references, CV) to assess suitability. We may also collect identity validation information like taxpayer ID or a copy of government-issued ID.

Project information

We collect information about Projects such as the type of Project and work product produced by an Agent.

Payment information

We may receive payment info to allow you to pay us and/or be paid. We use third-party payment providers in most cases. We may receive billing address and transaction details but do not directly store payment card info except in limited instances.

Your communications with us

We collect personal information (email, phone number, mailing address) when you request info, register for newsletters or programs, request support, or otherwise communicate with us.

Surveys

If you participate in surveys, we may collect the information you provide, including personal information.

Interactive features

We may offer collaboration tools, forums, blogs, chat/messaging, and social media pages. Information shared publicly through these features is considered “public” and not protected by this policy. You assume the risk that personal info shared publicly may be viewed and used by third parties.

Sweepstakes or contests

We may run sweepstakes and contests. Contact info may be used to manage participation and for promotional purposes where lawful. Some jurisdictions require publishing winner information.

Customer service and support

If you contact support, we collect information you provide. Calls may be recorded for training and QA.

Conferences, trade shows, events

We may collect personal info from individuals at events where they express interest in the Services.

Business development and strategic partnerships

We may collect personal info to assess or pursue business opportunities.

Job applications

If you apply for a job through the Services, we collect info in your application, CV, and cover letter.

2.2 Information Collected Automatically

Agent training

‍We may facilitate recording (audio/video) of online meetings between Clients and Agents for training or other purposes. Meetings are conducted with third-party tools (ex: Zoom). Agents are notified when recording occurs and may decline, though this may affect project eligibility. Clients may store and share recordings.

Agent work information

Agents may use software that collects Work Information such as text descriptions of work performed, keystrokes, mouse clicks, screenshots, and webcam images. Agents are informed when collection occurs and may decline, though this may prevent participation. Collected information may be shared with Clients and used for fraud detection, analytics, and other purposes.

Automatic data collection

We may automatically collect IP address, user settings, MAC address, cookie IDs, device IDs, browser and OS details, inferred location, ISP, pages visited, links clicked, interaction data (frequency/duration), and other usage data. This may be associated with accounts and devices.

Cookies, pixel tags/web beacons, and analytics

We and third parties may use cookies, pixel tags, local storage, and similar technologies to collect information.

• Cookies: store preferences. You can block/delete cookies, but Services may not work properly.
  
  
• Pixel tags/web beacons: track engagement (page visits, ad clicks). We may also use web beacons in emails.
  
  
• Analytics: we use Google Analytics and similar providers. You can opt out through Google’s tools.
  
  

Information from other sources

We may obtain info from third parties, including social logins, references, and public online work history or reviews.

3. How We Use Your Information

We use personal information to:

3.1 Provide Services or Requested Information

Including:

• fulfilling our contract with you
  
  
• managing your information
  
  
• processing payments
  
  
• responding to requests and support needs
  
  
• providing access to features and functionality
  
  

3.2 Serve Administrative Purposes

Including:

• marketing, research and development
  
  
• security and fraud prevention
  
  
• measuring engagement
  
  
• developing new products/services
  
  
• quality control and safety
  
  
• identity verification
  
  
• audits
  
  
• account and policy communications
  
  
• preventing/prosecuting illegal activity
  
  
• enforcing agreements
  
  
• legal compliance
  
  

3.3 Marketing Our Services

We may tailor content and ads as permitted by law. With Agent consent, we may publish Agent bios to help Clients find suitable Agents. You can opt out anytime.

3.4 Consent + Other Disclosed Uses

We may use info for other purposes disclosed when collected or with your consent.

3.5 De-identified or Aggregated Data

We may create and use de-identified or aggregated data for analytics, research, and lawful business purposes.

3.6 Automated Decision Making

We may use automated decision-making or profiling tools, but not for decisions that significantly affect you unless required by contract, consented to, or allowed by law.

3.7 Share Content with Others

We may allow referrals or sharing content with friends/colleagues through the Services.

4. How We Use Automatic Collection Technologies

We use technologies for:

• Operationally necessary purposes
  
  
  • access, security, fraud prevention
    
    
• Performance purposes
  
  
  • analytics, understanding usage
    
    
• Functionality purposes
  ‍
  
  • remembering preferences and logins
    
    
• Advertising/targeting purposes
  
  
  • interest-based advertising on our Services or third-party sites
    
    

Cross-device tracking

We may track browsing activity across devices through partner matching of identifiers and patterns.

5. Disclosing Your Information to Third Parties

We may share personal info with:

• Your organization (if you use Services through an employer)
  
  
• Clients (if you are an Agent working with a Client)
  
  
• Service providers (payments, IT, marketing, customer service, HR, investor relations)
  
  
• Business partners (to provide requested services)
  
  
• Affiliates (company-related entities)
  
  
• Advertising partners (interest-based ads via technologies)
  
  
• APIs/SDKs used within our Services
  
  
• Legal and safety disclosures when required to protect rights, safety, enforce agreements, or comply with law
  
  
• Merger, sale, or asset transfer contexts as permitted by law
  
  

6. International Data Transfers

Your information may be transferred, processed, and stored globally, including in the United States or other countries with different data-protection laws. We safeguard data per applicable law.

7. Your Choices

General

You may object to or opt out of certain uses.

Email communications

Use unsubscribe links to opt out of marketing emails. Transactional emails still apply.

Mobile devices

You can disable push notifications and precise location collection through device settings.

Do Not Track

We do not respond to DNT signals.

Cookies and interest-based advertising

You may restrict cookies in browser/device settings. Opt-out portals are available through industry programs, but must be done per browser/device.

8. Your Privacy Rights

We do not “sell” personal information under the California Consumer Privacy Act.

Depending on your jurisdiction, you may have rights to:

• confirm processing
  
  
• access a copy of your data
  
  
• data portability
  
  
• restrict processing
  
  
• correct inaccuracies
  
  
• withdraw consent
  
  
• request erasure (with legal exceptions)
  
  

To exercise rights, contact us. We will verify identity before fulfilling requests. California residents will not face discrimination for exercising rights.

9. Supervisory Authority

If you are in the EEA or UK, you may lodge a complaint with your data protection authority.

10. Data Retention

We retain personal info while you use the Services or as needed for business purposes, legal compliance, dispute resolution, audits, and enforcement.

11. Security of Your Information

We take reasonable steps to protect your data, but no system is 100% secure. We do not accept liability for unauthorized disclosure to the fullest extent permitted by law.

If we become aware of a breach, we may notify you electronically via the Services, email, or mail.

12. Third-Party Websites/Applications

Our Services may link to third-party sites. We do not control them and are not responsible for their privacy practices. Use at your own risk.

13. Children’s Information

The Services are not intended for children under 13 (or local equivalent). We do not knowingly collect children’s data. If we learn we did so unlawfully, we will delete it and terminate the account.

14. Changes to This Privacy Policy

We may update this policy at our discretion. Material changes will be notified as required. Continued use after updates means acceptance.

15. Contact Us

If you have questions or requests, contact:

Sanctum
42 Broadway Suite 12-443
New York, NY 10004
legal@infinityconstellation.com

Last updated:
December 1, 2025

‍Last reviewed:
December 1, 2025