Abode Privacy Policy

1. Scope and Who We Are

Scholars, Inc. d/b/a Abode (“Abode,” “we,” “us,” or “our”) provides software that helps organizations manage recruiting, talent, employee, mentorship, learning, onboarding, early-career, and other workforce programs.

This Privacy Policy explains how we collect, use, disclose, and protect personal information when you visit our websites, including www.abodehr.com (the “Website”), or use the Abode platform, including our web and mobile applications at my.abodehr.com and related services (the “Platform”). We refer to the Website and the Platform together as the “Services.”

This Privacy Policy applies to personal information processed through the Services. It does not replace any agreement between Abode and an organization that uses Abode, including any Master Services Agreement, Data Processing Addendum, Order Form, or other agreement.

2. Our Role

Most people use Abode because their employer, prospective employer, university, program sponsor, or another organization (a “Customer”) has invited them to participate in a program powered by Abode. Personal information that a Customer, or a user acting on a Customer’s behalf, submits to or collects through the Platform is “Customer Data.”

When Abode processes personal information on behalf of a Customer, the Customer generally determines why and how that information is processed. In those circumstances, the Customer acts as the data controller or business and Abode acts as its data processor or service provider.

If you have questions about information that a Customer has provided to Abode or would like to exercise rights relating to that information, you may contact the Customer directly. We will assist our Customers in responding to applicable privacy requests as required by law and our agreements with them.

Abode acts as a controller or business for information that we collect for our own business purposes, such as information about Website visitors, prospective customers, and people who contact us or attend our events, as well as account administration, security, communications, product improvement, and operation of our business.

In short:

  • Website visitors, prospective customers, and event participants: Abode is the controller.
  • Platform users and individuals whose information a Customer provides: the Customer is the controller, and Abode is its processor or service provider. Abode is the controller only for the limited account, security, and support information it uses for its own business purposes.

3. Information We Collect

The information we process depends on how you interact with Abode, the features used by the Customer, and the information the Customer chooses to provide.

Information from Website visitors and prospective customers

When you visit our Website, request a demo, subscribe to our communications, apply for an award or program we run, register for an event, or otherwise contact us, we may collect:

  • Name, email address, telephone number, job title, employer, and other business contact information
  • Information you include in forms, applications, and messages to us
  • Your communication preferences
  • Information about how you use the Website, as described under “Usage and technical information” below

We may also obtain business contact information from publicly available sources, such as professional networking sites, and from event co-hosts and other business partners.

Information provided by you or a Customer through the Platform

We may process information such as:

  • Name, email address, telephone number, and other contact information
  • Employer, organization, department, location, job title, manager, and employment information
  • School, degree, graduation date, field of study, and other education information
  • Candidate, recruiting, application, internship, employment, or program information
  • Profile information, photographs, biographies, interests, skills, preferences, and goals
  • Optional, self-reported demographic information, where a Customer has enabled it (see “Sensitive personal information” below)
  • Responses to surveys, assessments, forms, polls, and feedback requests
  • Program participation, tasks, milestones, assignments, events, resources, and activities
  • Mentorship, networking, team, cohort, or matching preferences and information
  • Communications and content submitted through the Services
  • Documents or other information uploaded to the Services
  • Information provided when contacting Abode for support

Customers determine which information they collect through Abode and may configure their programs differently.

Sensitive personal information

Most Customers do not collect sensitive personal information through Abode. Where a Customer chooses to enable it, the Platform can ask participants to self-report demographic information such as gender, race or ethnicity, veteran status, disability status, sexual orientation or LGBTQIA+ identity, age range (for example, over 40), first-generation college or immigrant status, neurodivergence, caregiver status, or socioeconomic background. A Customer may also record work authorization or visa sponsorship status.

Providing this information is always optional. You can leave these fields blank or choose “Prefer not to say,” and Customers can turn these fields off entirely so they are never collected.

We process sensitive personal information only as necessary to provide the Services, at the direction of our Customers, with appropriate authorization, or as otherwise permitted by law. Abode does not use sensitive personal information to infer characteristics about individuals, for advertising, or as a criterion in mentor, peer, or team matching.

Usage and technical information

When you use the Services, we may automatically collect information such as:

  • IP address
  • Browser and device information
  • Operating system
  • Login and authentication information
  • Dates and times of access
  • Pages, features, and functionality used
  • Links or buttons selected
  • Session and diagnostic information
  • Error logs
  • Security and audit logs
  • General interaction and feature-usage information

We use this information to operate, secure, maintain, analyze, and improve the Services.

Information from integrations and third parties

Customers may connect Abode with other systems, such as applicant tracking systems, human resources information systems, identity providers, calendar systems, communication platforms, or other business applications.

When these integrations are enabled, we may receive information from those systems as directed by the Customer.

We may also receive information from service providers that assist us with authentication, communications, analytics, security, infrastructure, customer support, and other business functions.

4. How We Use Personal Information

Depending on the context, we may use personal information to:

  • Provide, operate, maintain, and support the Services
  • Create and administer accounts
  • Authenticate users and manage access
  • Deliver programs configured by our Customers
  • Manage recruiting and talent workflows
  • Facilitate communications between Customers and participants
  • Provide tasks, resources, events, surveys, forms, and program content
  • Facilitate mentorship, networking, cohort, team, or other matching functionality
  • Measure participation, engagement, program effectiveness, and outcomes
  • Generate dashboards, reporting, analytics, and insights
  • Provide Customer support and troubleshoot technical issues
  • Respond to inquiries and demo requests, and send information about Abode products, events, and programs, which you can opt out of at any time
  • Maintain the security and integrity of the Services
  • Detect and prevent fraud, misuse, or unauthorized access
  • Monitor system performance and improve our products and Services
  • Develop new functionality
  • Comply with legal obligations
  • Enforce our agreements and protect the rights, safety, and property of Abode, our Customers, users, and others

We do not use Customer Data to train or fine-tune general-purpose artificial intelligence models.

5. Artificial Intelligence and Automated Processing

Certain Abode features may use artificial intelligence, machine learning, statistical analysis, or automated technologies to help Customers analyze program information, identify trends, summarize information, generate insights, or improve workflows.

Depending on what a Customer enables, these features may, for example, extract information from documents such as resumes, summarize activity and updates, help draft program content, suggest mentor, peer, or team matches based on criteria the Customer selects, and help Customers analyze their program data.

Abode may use approved technology providers, including AI service providers, to provide these capabilities. We send an AI provider only the information needed for the feature being used. AI providers are not permitted to use Customer Data to train their own models, and they are listed on our subprocessor page.

Customer Data submitted to Abode’s AI features is not used by Abode to train or fine-tune general-purpose AI models.

Customers can turn many AI features on or off for their organization in their workspace settings. If you do not want your information processed by an AI feature, contact your organization’s Abode administrator.

AI-generated outputs are intended to assist users and should not be treated as the sole basis for employment or other decisions that produce legal or similarly significant effects unless appropriate human review and other safeguards are in place.

Abode does not use artificial intelligence or other automated tools to score, rank, or screen job applicants or candidates for hiring decisions.

6. Cookies and Similar Technologies

Our Website and the Abode application may use cookies, local storage, and similar technologies necessary to:

  • Authenticate users
  • Maintain sessions
  • Remember preferences
  • Protect account security
  • Measure system performance
  • Understand how the Services are used
  • Diagnose technical problems
  • Improve functionality

Some analytics or support providers may also use cookies or similar technologies in connection with the Services.

We do not use cookies within the authenticated Abode application for third-party behavioral advertising.

7. How We Disclose Information

We may disclose personal information in the following circumstances.

Customers and authorized users

Information may be visible to the Customer that sponsors or administers your Abode account and to other users as configured by the Customer.

For example, certain profile, community, mentorship, cohort, program, event, or participation information may be visible to program administrators, managers, mentors, peers, or other participants depending on the Customer’s configuration.

Service providers and subprocessors

We use trusted service providers and subprocessors to help us provide the Services, including providers of:

  • Cloud hosting and infrastructure
  • Authentication and identity management
  • Email, SMS, and in-app communications
  • Customer support
  • Product analytics
  • Integration infrastructure
  • Security and monitoring
  • Artificial intelligence and machine learning services

These providers are permitted to process information only as necessary to provide services to Abode and are subject to contractual obligations designed to protect personal information.

Our current subprocessor list is available at:

https://www.abodehr.com/subprocessors

Integrations

If a Customer enables an integration between Abode and another system, information may be exchanged with that system at the Customer’s direction.

Legal and safety purposes

We may disclose information when we reasonably believe disclosure is necessary to:

  • Comply with applicable law, regulation, legal process, or governmental request
  • Protect the rights or property of Abode or others
  • Investigate fraud, security incidents, or misuse
  • Protect the safety of users or others
  • Establish, exercise, or defend legal claims

Corporate transactions

If Abode is involved in a merger, acquisition, financing, reorganization, sale of assets, or similar transaction, personal information may be disclosed or transferred as part of that transaction, subject to applicable law.

Third-party websites and services

The Services may contain links to third-party websites, applications, or services.

Those third parties operate under their own privacy practices, and this Privacy Policy does not govern their collection or use of personal information.

8. Sale, Sharing, and Your Choices

Abode does not sell Customer Data or personal information for monetary consideration.

We do not use personal information for third-party targeted advertising.

We also do not share personal information for cross-context behavioral advertising as those terms are defined under applicable U.S. state privacy laws.

You can opt out of marketing emails from Abode at any time by using the unsubscribe link in the email or by contacting us at support@abodehr.com. We will still send service-related messages, such as account and program notifications, which you can manage in your notification settings or through the Customer that sponsors your account.

9. Data Retention

We retain personal information for as long as necessary to provide the Services, fulfill the purposes described in this Privacy Policy, comply with contractual requirements, satisfy legal obligations, resolve disputes, and enforce our agreements.

Unless a Customer agreement specifies otherwise, our standard retention practices include:

  • Production Customer Data is generally deleted within 30 days after account or Customer deactivation or upon request
  • Backup copies are generally deleted within 60 days
  • Certain system and security logs may be retained for up to 400 days
  • Customer support communications may be retained for a limited period after resolution
  • Customer-provided files may be deleted sooner when directed by the Customer

Retention periods may differ where required by a Customer agreement, law, security requirement, legal hold, or legitimate business need.

Customers may also request return or export of their data in accordance with their agreement with Abode.

10. Security

We maintain administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, loss, or misuse.

These measures include, where appropriate:

  • Encryption of data in transit and at rest
  • Access controls and least-privilege permissions
  • Multi-factor authentication
  • Security logging and monitoring
  • Vulnerability management
  • Secure development practices
  • Employee security training
  • Third-party penetration testing
  • Incident response procedures

Abode maintains a SOC 2 Type II program and an ISO/IEC 42001-certified Artificial Intelligence Management System.

No system can guarantee absolute security, but we continuously evaluate and improve our security program.

Additional information about our security practices is available at:

https://www.abodehr.com/security

11. International Data Transfers

Abode is based in the United States and may process personal information in the United States and other countries where our service providers operate.

Where required, we use appropriate safeguards for international transfers of personal information, which may include contractual protections such as the European Commission’s Standard Contractual Clauses and the UK International Data Transfer Addendum.

Abode also supports contractual data-residency commitments where agreed with a Customer.

12. Your Privacy Rights

Depending on where you live and applicable law, you may have rights relating to your personal information, including the right to:

  • Request access to personal information
  • Obtain a copy of personal information
  • Request correction of inaccurate personal information
  • Request deletion of personal information
  • Request restriction of certain processing
  • Object to certain processing
  • Request portability of personal information
  • Withdraw consent where processing is based on consent
  • Appeal certain decisions relating to a privacy request
  • Opt out of certain sales, sharing, targeted advertising, or profiling where applicable
  • Lodge a complaint with a privacy or data protection authority

You will not be discriminated against for exercising privacy rights provided by applicable law.

Information controlled by an Abode Customer

If your information was provided to Abode by your employer, prospective employer, university, program sponsor, or another Customer, please submit your request directly to that organization.

Because Abode acts as its processor or service provider, we generally must follow the Customer’s instructions regarding that information.

If you send the request directly to Abode, we may refer your request to the applicable Customer and assist the Customer as required.

Information controlled by Abode

For personal information for which Abode acts as the controller or business, including information about Website visitors and prospective customers, you may submit a privacy request by contacting us at:

support@abodehr.com

We may need to verify your identity before completing certain requests.

Authorized agents may submit requests where permitted by applicable law, although we may require verification of the agent’s authority.

13. Children’s Privacy

The Services are designed for workforce, education, recruiting, mentorship, and talent programs and are intended for individuals 18 years of age or older.

No one under 18 may use the Services or provide personal information through them, and Abode does not knowingly collect personal information from individuals under 18. Customers may not invite individuals under 18 to the Platform or provide their personal information to Abode.

If we learn that we have collected personal information from someone under 18, we will delete it. If you believe this has happened, contact us at support@abodehr.com.

14. Regional Supplements

California and other U.S. state privacy rights

Residents of California and certain other U.S. states may have additional rights under state privacy laws.

Depending on applicable law, these may include rights to know, access, correct, delete, or obtain a portable copy of personal information and rights to opt out of certain sales, sharing, targeted advertising, or profiling.

For personal information for which Abode acts as a business or controller, the categories of personal information we may process include:

  • Identifiers and contact information
  • Account and authentication information
  • Professional and employment-related information
  • Education information
  • Internet and electronic activity information
  • Communications and Customer support information
  • Demographic or other sensitive information when voluntarily provided or provided by a Customer
  • Inferences or analytics generated from information described above

We collect and use these categories for the purposes described in this Privacy Policy.

We may disclose these categories to service providers, subprocessors, Customers, integrations selected by Customers, professional advisers, and government authorities where required by law.

Abode does not sell personal information and does not share personal information for cross-context behavioral advertising.

If our practices change in a way that creates an applicable opt-out right, we will provide the required mechanisms for exercising that right.

European Economic Area, United Kingdom, and Switzerland

Where applicable under the General Data Protection Regulation, UK GDPR, or similar laws, our legal bases for processing personal information may include:

  • Performance of a contract
  • Compliance with legal obligations
  • Legitimate interests
  • Consent

When we process personal information on behalf of a Customer, the Customer determines the applicable legal basis for that processing.

Individuals in the European Economic Area, United Kingdom, or Switzerland may have rights to access, correct, delete, restrict, object to processing of, or obtain a portable copy of their personal information and may have the right to lodge a complaint with their local data protection authority.

Our EU and UK representatives

Under Article 27 of the GDPR, Abode has appointed Instant EU GDPR Representative Ltd. as its representative in the European Union: Office 2, 12A Lower Main Street, Lucan, Co. Dublin, K78 X5P8, Ireland. Contact: Adam Brogden, contact@gdprlocal.com, +353 1 554 9700.

Under Article 27 of the UK GDPR, Abode has appointed GDPR Local Ltd. as its representative in the United Kingdom: 1st Floor Front Suite, 27-29 North Street, Brighton, BN1 1EB, England. Contact: Adam Brogden, contact@gdprlocal.com, +44 1772 217800.

15. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes to our Services, practices, technologies, or legal requirements.

When we make changes, we will update the “Last Updated” date above.

If we make material changes, we may provide additional notice through the Services, by email, or through another appropriate method.

16. Contact Us

If you have questions about this Privacy Policy or Abode’s privacy practices, please contact us at:

Scholars, Inc. d/b/a Abode

Email: support@abodehr.com

Mailing address: 1615 Platte St, Denver, CO 80202

Website: https://www.abodehr.com

For security-related matters, please contact:

support@abodehr.com

Last revised: October 5, 2026