Your information, explained
Privacy Policy
This Policy explains what Portunio collects, why we use it, how AI-assisted opportunity qualification works, when information is shared, and the choices available to you.
Effective and last updated: August 29, 2026
The short version
- Your private email is used for sign-in, security, and notifications; it is not displayed to other users.
- Public profile fields are public by design. Opportunity drafts, evidence, assessments, and threads remain limited to the people involved and trusted service providers.
- Portunio uses AI to ask follow-up questions and organize evidence. It can be wrong, does not create a universal person score, and does not make the receiver’s final decision.
- We do not sell personal information or use it for cross-context behavioral advertising.
Scope, controller, and contact
This Policy applies to portunio.com, Portunio public addresses, account areas, opportunity submission and messaging flows, and related communications (together, the “Service”). It does not govern a third-party site merely because Portunio links to it.
Portunio is operated by CognaLabs Studio LLC, a Wyoming limited liability company. CognaLabs Studio LLC determines why and how personal data is processed for the Service and acts as the data controller, business, or equivalent responsible organization. Portunio provides the Service internationally under a U.S. legal baseline. Questions and privacy requests may be sent to privacy@portunio.com. Legal notices may be sent to legal@portunio.com. Our mailing address is 1105 Town Blvd NE, Apt. 4307, Atlanta, GA 30319, United States.
A receiver who independently downloads or uses information from an opportunity outside Portunio may become responsible for that separate use. Senders and receivers must handle information they receive lawfully and only for the relevant opportunity.
Information we collect
- Account and authentication
- Email address, name, avatar, authentication-provider identifiers, sign-in events, verification state, account role, and session or security tokens. Portunio does not store social-provider passwords.
- Receiver profile and preferences
- Public handle, name, photo, role, location, biography, current interests, exclusions, attention policy, notification settings, and share-kit content. Fields marked public can be viewed and indexed by anyone.
- Opportunity and sender content
- Original pitch text, structured answers, requested effort, LinkedIn or website URLs, evidence and source links, drafts, corrections, status, receiver actions, and messages in the opportunity thread.
- Professional and public-source data
- Information retrieved from a public professional profile or a website you identify, such as work history, headline, skills, public claims, source URL, retrieval time, and a snapshot used to assess context. A public record does not by itself prove identity or ownership.
- AI and derived information
- Follow-up questions, summaries, classifications, relevance and evidence signals, confidence, uncertainty, routing recommendations, safety indicators, and model/policy version information. We retain original input separately from derived output where the Service design requires it.
- Usage, device, and operations
- IP address and request metadata in security or hosting logs, browser/device signals, locale, referral source, timestamps, feature and funnel events, delivery status, error records, and abuse-prevention signals. We design analytics to avoid raw identity and sensitive content.
- Support and legal
- Messages you send us, request-verification information, reports, appeals, consent records, and information needed to address disputes, safety issues, or legal requests.
Where information comes from
We collect information directly from you; from another participant when they submit, receive, or reply to an opportunity; automatically from your browser and use of the Service; from Google or LinkedIn when you choose that sign-in method; and from public professional profiles or websites that a user asks Portunio to evaluate.
Do not submit another person’s private or sensitive information unless you have a lawful reason and authority to do so. If you provide information about someone else, you are responsible for giving any notice and obtaining any permission required by law.
Why we use information and our legal bases
Where law uses different terminology, we rely on the equivalent permitted grounds. Providing account, verification, and opportunity information is normally needed to perform the Service; without it, the relevant feature may not work. Optional profile fields and optional imports can be left blank.
- Provide the Service — contract
- Create and secure accounts, recover drafts, publish the profile fields you select, qualify and route opportunities, operate private threads, and deliver requested notifications.
- Operate safely — legitimate interests and legal obligations
- Authenticate users, prevent spam, fraud, harassment and misuse, enforce our Terms, audit sensitive access, protect people and systems, comply with law, and establish or defend legal claims.
- Improve Portunio — legitimate interests
- Measure privacy-safe product events, evaluate routing quality and false negatives, troubleshoot, research usability, and improve features. We balance these interests against your rights and use aggregation or de-identification where practical.
- User choices — consent
- Publish optional profile information, import a public profile when you ask, enable optional communications or non-essential technologies, and process information where consent is legally required. You may withdraw consent, but earlier lawful processing remains valid.
How AI-assisted qualification works
Portunio may send relevant profile preferences, opportunity text, answers, public professional context, and evidence to contracted AI infrastructure providers. Models use that context to identify the ask, generate follow-up questions, compare the opportunity with the receiver’s stated policy, organize supporting evidence and uncertainty, and recommend a route or presentation.
Outputs are probabilistic and may be incomplete, biased, or wrong. Portunio keeps the receiver’s judgment final, does not create a universal person score, and does not treat a public profile as proof of identity. Low-confidence or unusual cases may be held for further information or human review rather than finally rejected.
Portunio is not designed to make solely automated decisions that produce legal or similarly significant effects. It must not be used as the decision-maker for employment, credit, housing, insurance, healthcare, education admissions, government benefits, or other high-impact decisions. You may correct inputs, provide additional context, ask for human review of a Portunio enforcement decision, or contact privacy@portunio.com with a concern about an assessment.
Public profiles, threads, and sealed identity
A published receiver address and the profile fields selected for it are public. Search engines, visitors, and people who receive a shared link may copy or re-share public information. Removing it from Portunio cannot guarantee removal from third-party caches or copies.
Opportunity drafts, assessments, and threads are not public. “Sealed identity” means social concealment between participants until the relevant disclosure choice; it is not anonymity from Portunio. Portunio may know and process identity or contact information for authentication, safety, support, and legal compliance. We may disclose it in exceptional cases described in this Policy and the Terms.
International transfers
Portunio serves users internationally and uses providers whose systems or personnel may be located in the United States, the European Economic Area, the United Kingdom, and other countries where our contracted providers operate. Those countries may have different data-protection laws.
Where required, we use an available lawful transfer mechanism, such as an adequacy decision, approved contractual clauses, a UK transfer addendum, a data-processing agreement, the data subject’s explicit informed consent for a permitted transfer, or another mechanism recognized by applicable law. We also apply access controls, minimization, encryption in transit, and vendor review appropriate to the transfer. Contact privacy@portunio.com for information about safeguards relevant to your data.
How long we keep information
We determine retention using the amount, nature and sensitivity of the information, risk of harm, product and safety needs, participant expectations, technical constraints, and legal requirements. We periodically review data for deletion or de-identification.
- Guest sessions and drafts
- For the limited period needed to recover the draft, complete verification, prevent abuse, or link it to a submitted opportunity or verified account, then deleted or de-identified on a rolling schedule.
- Accounts and public profiles
- While the account or published address is active, and for a reasonable closing period after deletion to complete requests, prevent fraud, resolve disputes, and meet legal duties. Public caches controlled by others may last longer.
- Opportunities, evidence, and threads
- While needed to provide the record to the participants, support follow-up, enforce safety, and resolve disputes. Deletion may be limited where another participant needs a legitimate record or law requires preservation.
- Security, audit, delivery, and legal records
- For the period reasonably necessary for security investigation, append-only accountability, deliverability, compliance, limitation periods, and legal claims.
- Backups and de-identified information
- Backups are isolated and overwritten under our backup cycle. Aggregated or irreversibly de-identified information may be retained without a fixed end date because it no longer identifies you.
Security
We use measures intended to protect personal data, including encrypted transport, restricted server-side credentials, role- and row-based access controls, separation of public profile data from private identity data, rate limits, audit events, provider review, and access limited to operational need. No online service can guarantee absolute security.
Protect your sign-in links and devices, use only email accounts you control, and notify security@portunio.com promptly if you suspect unauthorized access. We will investigate incidents and notify affected people and regulators when required by law.
Your privacy rights
Depending on where you live and the processing involved, you may have the right to be informed; access and receive a copy; correct; delete; restrict or object; withdraw consent; receive portable data; object to direct marketing; opt out of a sale, behavioral-advertising share, or qualifying profiling; limit certain sensitive-data uses; and not be discriminated against for exercising a right. You may also ask for information about sources, purposes, recipients, retention, transfer safeguards, and AI-assisted processing.
Send a request to privacy@portunio.com from the email associated with your account and describe the right you want to exercise. You may use an authorized agent where law permits. We may verify identity or authority, and we may deny or limit a request where an exception applies, such as protecting another person, security, free expression, legal compliance, or a claim. We will explain the decision and any appeal route.
If we deny a U.S. state privacy request, you may appeal by replying to our decision or writing “Privacy Appeal” to privacy@portunio.com. You may also contact your state attorney general or, in California, the California Privacy Protection Agency. If EU or UK law applies, you may complain to the supervisory authority where you live or work or where an alleged infringement occurred. In the preceding 12 months, the categories collected and disclosed for business purposes are those listed in Sections 2 and 6, and none were sold or shared for cross-context behavioral advertising.
Age limits and changes to this Policy
The Service is for professional opportunity exchange and is not directed to anyone under 18. Do not create an account or submit personal data if you are under 18. If we learn that we collected a minor’s data contrary to this rule, we will take reasonable steps to delete it. A parent or guardian may contact privacy@portunio.com.
We may update this Policy to reflect product, provider, or legal changes. We will post the revised version with a new date and provide prominent or direct notice before a material change takes effect when required. We will request fresh consent where a new purpose legally requires it.