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The terms authorize Indeed to use user activity data, User Content, and employer-provided data to develop, train, build, and improve AI and machine learning models, including through the Browser Extension and Talent Scout features. This authorization applies to both job seeker and employer data.
This analysis describes what Indeed's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision authorizes the use of job seeker profile data, application materials, interaction data, and employer User Content for AI model development and training. The scope includes data processed through third-party ATS integrations and the Browser Extension, extending beyond direct platform interactions.
Interpretive note: The precise scope of 'as allowed by applicable laws' introduces jurisdictional variance; the lawful basis for AI training use of personal data may differ materially between GDPR, CCPA, and U.S. common law jurisdictions.
The updated terms state that Indeed may automatically draft job application content based on job seeker profile information and preferences. The drafted content may be AI-generated and subject to Indeed's AI-Generated Content Terms in Section D.9 of the General Terms. The agreement continues to establish that job seekers remain responsible for reviewing, correcting, editing, or deleting any drafted applications or application content before submission. You should review any AI-drafted content carefully to ensure it accurately reflects your qualifications and preferences before adopting and submitting applications.
View change record →The updated terms establish new explicit tax obligations for users. Indeed now states it will calculate and bill applicable taxes based on user location or linked employer location, and users are responsible for any applicable taxes, duties, or levies. Additionally, the terms now state that reducing or canceling sponsored ad budgets will result in loss of access to premium features exclusive to higher budget plans. Previously, the agreement described auto-apply activity as a pricing factor; this reference has been removed from the pricing methodology section.
View change record →Under these terms, job seeker and employer activity, communications, and User Content submitted through the platform, its extensions, and integrated ATS systems may be recorded, processed, and used to train AI and machine learning models. The agreement states this use is subject to applicable laws and the Data Processing Agreement, but no specific opt-out mechanism for AI training use is identified in the excerpted provisions.
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"When using Site features, programs, and services accessed through the Extension, you agree to your activities, communication, materials, and User Content (including on your ATS) being recorded, processed, analyzed, reviewed, and stored (including via automated means) for data analysis, quality control, enforcement of the Sites' rules and other Indeed policies, content moderation, and to improve the Extension, the Site or any other Indeed program or service. To achieve these purposes, we use such data about your particular activity, communication, and materials to develop, train, build, and use statistical models, including artificial intelligence and machine learning models. In accordance with Indeed's Data Processing Agreement and as allowed by applicable laws, we may use Indeed Job Seeker data to improve our services, including by developing, training, fine-tuning, building, and using artificial intelligence, including statistical and machine learning models.Excerpt from Indeed's Terms of Service
1. REGULATORY LANDSCAPE: This provision engages GDPR Article 6 (lawful basis for processing) and Article 22 (automated decision-making) for EU/EEA users, CCPA's data use disclosure and opt-out rights for California residents, and the EU AI Act's requirements for high-risk AI systems used in employment contexts. The UK GDPR and ICO guidance on AI and automated processing are also relevant for UK users. The FTC's guidance on AI and data practices may apply for U.S. users. 2. GOVERNANCE EXPOSURE: High. The use of job seeker and employer data for AI model training raises questions about whether the lawful basis asserted (contractual necessity or legitimate interest) is sufficient under GDPR, particularly for special category data such as demographic information. The scope of the authorization (extending to ATS-integrated data and third-party extension interactions) broadens the data surface beyond what users may anticipate from a standard job platform. 3. JURISDICTION FLAGS: EU/EEA users have heightened exposure given GDPR's restrictions on secondary use of personal data and requirements for explicit consent or legitimate interest assessments. California residents may have rights under CCPA to opt out of certain data uses, including those that constitute 'sharing' for cross-context behavioral advertising. Illinois users should assess whether AI training on biometric-adjacent data implicates BIPA, though Indeed disclaims biometric data collection. 4. CONTRACT AND VENDOR IMPLICATIONS: The Data Processing Agreement incorporated by reference governs employer-side processing obligations. Employers using Talent Scout or Smart Screening should review the DPA to assess controller and processor designations, particularly where candidate personal data is used for AI training. Procurement teams should assess whether employer consent to AI training use of candidate data is consistent with their own privacy notices and candidate consent frameworks. 5. COMPLIANCE CONSIDERATIONS: Organizations with EU/EEA employees or candidates should conduct a legitimate interest assessment or confirm the lawful basis for AI training data use. Data mapping exercises should include Indeed platform interactions, ATS integrations, and Browser Extension data flows. Privacy notices for candidates should be reviewed to ensure AI training data use is disclosed. Employers in New York City should assess compliance with Local Law 144 on automated employment decision tools, which requires bias audits and candidate notices.
This provision authorizes the use of job seeker profile data, application materials, interaction data, and employer User Content for AI model development and training. The scope includes data processed through third-party ATS integrations and the Browser Extension, extending beyond direct platform interactions.
Under these terms, job seeker and employer activity, communications, and User Content submitted through the platform, its extensions, and integrated ATS systems may be recorded, processed, and used to train AI and machine learning models. The agreement states this use is subject to applicable laws and the Data Processing Agreement, but no specific opt-out mechanism for AI training use is …
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