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CROSSCHQ PRIVACY POLICY

Last Updated: October 15, 2021

This Privacy Policy (“Policy”) describes how Crosschq, Inc. (“Crosschq” or “we”,
“us” or “our”) treats information collected or provided in connection with a
user’s (“you” or “user”) visit to or use of Crosschq’s website(s) and/or
Crosschq’s products and services (the “Services“). Please note that your use of
the Crosschq site constitutes your acceptance of and consent to this Policy.
When you sign up to use the Services, you also consent to receive electronic
notices and disclosures, as set forth in Section 5 below.

Crosschq reserves the right to change this Policy at any time. Please check this
page periodically for changes. Your continued use of the Services following the
posting of changes to this Policy will mean you accept those changes.

This Policy seeks to answer questions you may have about the Services and
Crosschq’s information practices. Please contact us at support@crosschq.com if
you have questions not addressed below.

 1.  What information does Crosschq collect through the Services?
 2.  How does Crosschq use the collected information?
 3.  When does Crosschq share information about you?
 4.  How can you access, change, or delete information about you?
 5.  Will you receive notices and disclosures electronically?
 6.  Does this Policy apply to third parties?
 7.  What choices do you have about online tracking, analytics and email
     communications from Crosschq?
 8.  How does Crosschq protect your information?
 9.  Where is your information processed or stored?
 10. Who can use the Services?
 11. How does Crosschq comply with international data protection laws?
 12. How can you contact Crosschq with more questions?

 

1. What Information Does Crosschq Collect through the Services?

Information Provided Directly To Us by our Corporate Website Users

We collect information you provide directly to us through the Services. For
example, we may collect your name, email address, or other contact information
when you access certain Crosschq content available through the Services such as
whitepapers, videos, webinars, and other materials, or request additional
information about Crosschq or the Services. Crosschq also collects information
from you when you fill out any form in the Services such as when you submit
questions or comments.

Information Provided by our Customers

If you want to use the Services as a customer to assist your organization in
collecting job references, searching and distributing job prospects, or
analyzing new hire data/outcomes, Crosschq may collect the following information
(collectively, the “Customer Information”), including, but not limited to:

 * * Account creation information, including your name, email address and a
     custom password;
   * Contact information such as address and phone number;
   * Corporate and license information;
   * If you are an employer, employer identification number;
   * If you are using our New Hire Analytics module, employee names, employee
     emails, employee phone numbers, and additional employment-related
     information;
   * If paying your customer invoices via credit-card or ACH billing, payment
     information, including credit card and/or bank account information and
     billing address.

Please note: We do not store the credit card or bank account numbers used to
make payments in the Services. Such information may be passed on to our
third-party payment processor, Stripe or Intuit. You can review information on
Stripe’s privacy practices at https://stripe.com/privacy and information on
Intuit’s privacy practices at https://www.intuit.com/privacy/statement.

Information Provided by Job Candidates

If you are a job Candidate who will be the subject of a reference request
(“Candidate”), Crosschq may collect the following information (collectively, the
“Reference Request Information”), including, but not limited to:

 * * Account creation information, including your full name, e-mail address, and
     custom password;
   * Your contact information, including phone number and address;
   * Contact information for the references you provide, along with their
     relationship to you;
   * Your job history, education history, skills, and other job-related
     information, if available on public websites or from a customer’s ATS;

Information Provided by References

If you are providing a reference for a Candidate (“Reference”), Crosschq may
collect the following information (collectively, the “Reference Contact
Information”), including but not limited to:

 * * Your contact information, including your full name, email address, and
     phone number;
   * When you complete your reference survey you are given the option to opt-in
     to becoming a job prospect. If you opt-in to becoming a job prospect your
     job history, education history, skills, and other job-related information
     may be collected if available on various public websites. This information
     is shared with customers who may evaluate your profile to see if you match
     one of their current job openings.

Automatically Collected Information

When you visit our website or use the Services, we may automatically gather
certain technical and usage information, which may be associated with your
access or user account. This technical and usage information (“Technical
Information”) includes usage information such as information on when, how often
and for how long you use the Services; and server log data such as a computer’s
IP address, browser type, device type, operating system and version, or the
webpage you were visiting before you came to the Services.

Technical Information also includes “Cookies,” which are small text files
containing a string of alphanumeric characters that are downloaded by your web
browser when you visit a website. Like many online services, we may use both
session cookies and persistent cookies when you access and use the Services.
Cookies are used to remember your user account information and your preferences,
to customize the Services for you and to assist us in measuring and analyzing
utilization of the Services.

Third-party web analytics services providers we engage, such as Google
Analytics, may use cookies in order to provide analytics services for the
Services to us. A session cookie disappears after you close your browser. A
persistent cookie remains after you close your browser and may be used by your
browser on subsequent visits to the Services. Persistent cookies can be removed.
Please review your web browser’s documentation to learn the best way to modify
your cookie settings and see Section 7 below for details regarding Crosschq’s
Cookie policies and procedures.

2. How does Crosschq use the collected information?

Crosschq uses the information it maintains about you (including information you
provide, Customer Information, Reference Request Information, and Technical
Information):

 * * * For the purposes for which you provided it;
     * To create your account and enable you to use the Services;
     * To verify your identity;
     * To provide the features and functionality of the Services;
     * For customer support and to respond to your inquiries;
     * To respond to and fulfill your requests;
     * To contact you by text message, email or other means regarding your
       account and certain services or information you have requested;
     * To improve the Services;
     * For internal record-keeping purposes and for legal purposes;
     * If you opted in as a job prospect, to allow our customers to determine if
       your profile/experience matches a job opening, and to contact you
       regarding job openings;
     * To address fraud or safety concerns, or to investigate complaints or
       suspected fraud or wrongdoing; and
     * To resolve disputes, to protect ourselves and other users, and to enforce
       any legal terms that govern your use of the Services.

We may use Customer Information to:

 * * * contact you regarding your use of the Services;
     * process billing and payment;
     * send you product announcements;
     * invite you to participate in special events or provide feedback via
       surveys;
     * send you communications regarding updates or modifications to the
       Services; or
     * provide your company with email reports on account activity and
       additional insights.

We may use Customer Information and Technical Information to:

 * * * personalize the content that you and others see based on personal
       characteristics or preferences;
     * troubleshoot problems;
     * provide you with required notices, in connection with disputes between
       you and another user;
     * or alert you to changes in our policies or agreements that may affect
       your use of the Services.

Crosschq may also use Technical Information to analyze your use of the Services
to help us improve the Services and develop and improve other products and
services.

3. When does Crosschq share information about you?

Employers or Other Customers Requesting References. We provide Reference
reports, which may include Reference Request Information, about Candidates to
the requesting employer or Customer. We may also provide an employer or Customer
other communications related to Reference reports such as notification of a
dispute or suspected fraudulent activity.

Service Providers. We may provide access to your information to select third
parties who perform services on our behalf. These third parties provide a
variety of services to us, including without limitation conducting components of
Reference requests, emailing and texting, billing, fulfillment, data storage,
analysis and processing, identity verification, logging transactions, fraud,
accounting, auditing, and legal services.

Affiliates. We may share information with our affiliates for use as described in
this Policy.

Legal Requirements. We will use and disclose information where we, in good
faith, believe that the law or legal process (such as a court order, search
warrant or subpoena) requires us to do so or in other circumstances where we
believe it is necessary to protect the rights or property of Crosschq, our
users, or third parties.

De-identified information. We may share de-identified information with third
parties, including without limitation: (1) sharing aggregated, de-identified
information about our user base, including analysis and predictive algorithms;
and (2) providing de-identified information to third-party partners for our
business arrangements, including without limitation to jointly offer a product
or service to you or create interoperability between our products and services
and theirs.

Consent. We may disclose your information to nonaffiliated third parties based
on your consent to do so.

Business Transfer. In the event of a merger, sale of capital stock or assets,
reorganization, consolidation or similar transaction involving Crosschq, or in
contemplation of such a transaction (e.g., due diligence), the information we
possess may be transferred as a corporate asset to the acquiring entity.

Analytics. We use Google Analytics for purposes of analyzing usage of the
Services. You can find more information about Google privacy practices here.

Note that Crosschq will not provide your personally identifiable information to
third parties for their own marketing purposes without your consent.

4. How can you access, change or delete information about you?

Users and Candidates should promptly update their contact information if it
changes or is inaccurate. Users and Candidates may review, access, and change
certain account information such as email address, phone number and mailing
address via Crosschq’s Services. Candidates and references, including references
that opt-in to be a job prospect, can request deletion of certain information in
Crosschq’s control by contacting Crosschq as set forth at the end of this
Policy. Note that if personally identifiable information is deleted, it may be
stored in a backup for a period up to ninety (90) days after deletion.

Once a Candidate has approved a request for their references and the Customer,
such as an employer, has received the Reference report, Crosschq does not
control the Customer’s retention of such information.

5. Will you receive notices and disclosures electronically?

Yes. The Services are offered through Crosschq’s website, mobile site, and app.
To obtain Services from us, you must create an online account and (1) be able to
access Services on a computer or other device that is capable of accessing the
Internet, (2) have an active email account, and (3) consent to our use of our
website, app, text or email to provide you any written information that we may
be required to send you in connection with the Services, your account, and/or
Reference requests and reports.

Your Consent to Electronic Disclosures

By creating an account and/or authorizing a Reference request, you acknowledge
and agree:

 * * * you can access and read information we post on our website or mobile app;
     * to provide an email address that is active and effective for receiving
       emails from us;
     * to receive electronically on our website, app, or via email the notices
       and disclosures, required by law related to your account and the
       Services;
     * and you have received the following disclosures as required by the
       federal Electronic Signatures in Global and National Commerce Act
       (“ESIGN”).

Please read this Federal ESIGN disclosure and consent carefully and keep a copy
for your records. Your consent is voluntary, but we cannot provide the Services
to you if you do not consent. If you are unwilling to receive these disclosures
and notices electronically, you may terminate the creation of your account by
closing your browser at any time before you create an account and/or authorize a
Reference request.

Scope of Communications to Be Provided in Electronic Form

Your consent to receive electronic communications and transactions includes, but
is not limited to, all legal and regulatory notices or disclosures and
communications associated with your account, the Services, your request for
References, and any product or service we agree to provide you (each, a
“Communication”).

Method of Providing Communications to You in Electronic Form

All Communications that we provide to you in electronic form will be provided
either (1) via email, telephone or text, (2) by making it available online and
accessible via your account portal, or (3) by requesting you download a PDF file
containing the Communication.

How to Withdraw Consent

You may at any time withdraw your consent to receive Communications in
electronic form. To begin receiving Communications in paper form, please contact
us at the following address: 145 E Prospect Ave. Suite 200, Danville CA 94526.
Please specify the information you wish to receive in paper form. Be sure to
state that you are requesting a copy of the disclosures, notices, etc., and
include your name and mailing address. Your request will apply only to those
specific items you designate. We will not impose any fee to process the
withdrawal of your consent to receive electronic Communications. Any withdrawal
of your consent to receive electronic Communications will be effective only
after we have a reasonable period of time to process your withdrawal.

How to Update Your Records

It is your responsibility to provide us with true, accurate and complete email
address, contact, and other information related to your account, and to maintain
and update promptly any changes in this information. You can update information
(such as your email address) through your account portal. If you give us an
incorrect email address or fail to update or correct your email address, an
electronic Communication will be deemed provided to you if we use the email
address in our records for the electronic Communication.

Required Equipment

In order to use the Services and to view and retain a copy of this Policy and
certain Communications, you understand that you must have a computer or device
equipped with at least: a browser with 128-bit encryption, a current version of
a software that can open and display PDF files (e.g., Adobe), and either a
printer or other electronic storage device.

Retaining Copies of the Communications

To retain a copy of any Communication we provide electronically, you can
download an electronic copy to your computer or a storage device (such as a disk
or USB storage device), request a copy by email, or print copies on a printer
attached to your computer. You will not be charged for a downloaded or emailed
copy.

6. Does this Policy apply to third parties?

No. The Services may contain links to third-party websites, but this Policy does
not apply to information that you may provide to or that may be collected by
such third parties. We encourage you to review such third parties’ privacy
policies and terms and conditions before engaging with such third parties.

7. What are your choices regarding online tracking, analytics and certain email
communications from Crosschq?

Online Tracking and Cookies. Like many websites, the Services do not currently
respond to “do not track” browser headers. But you can take steps to limit
tracking by erasing cookies from your computer’s hard drive and by setting your
browser to block all cookies or warn you before a cookie is stored. If you
disable cookies, you may be prevented from taking full advantage of the Services
because they may not function properly without cookies.

Analytics. To prevent Google Analytics from using your information for
analytics, you may install the Google Analytics Opt-out Browser Add-on by
clicking here.

Promotional Emails. As discussed in this Policy, subject to any restrictions
under applicable laws, we may send periodic promotional or informational emails
to you. You may opt-out of such communications by clicking unsubscribe in the
email. Please note that it may take up to 10 business days for us to process
opt-out requests. If you opt out of receiving emails about recommendations or
other information we think may interest you, we may still send you emails about
your account or any services you have requested or received from us.

Opting Out of Crosschq Text Messages. The number of text messages you receive
may depend upon factors including how you use our services and whether you take
steps to generate additional text messages from us (such as by sending a HELP
request). If you no longer want to receive Crosschq text messages, you may text
STOP at any time. After doing so, we will send you confirmation of your opt-out
via text message. If you have revoked consent and want to re-enroll in our text
message program, you can re-enroll by texting START at any time, or emailing us
at support@crosschq.com.

8. How does Crosschq protect your information?

Crosschq maintains safeguards to help protect the security of information we
maintain about you. We may use encryption, passwords, and other technical and
physical security measures designed to help protect your information against
unauthorized access and disclosure. However, no security measures are 100%
effective and we cannot guarantee your information will not be collected,
disclosed and/or used by others. You should take steps to protect against
unauthorized access to your password, phone, and computer by, among other
things, signing off after using a shared computer, choosing a robust password
that nobody else knows or can easily guess, keeping your log-in and password
private, and not recycling passwords from other websites or accounts. Crosschq
is not responsible for the unauthorized use of your information nor for any
lost, stolen, or compromised passwords, or for any activity on your account via
unauthorized password activity.

WE EXPRESSLY DISCLAIM ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS OR
IMPLIED, WITH RESPECT TO ENSURING, GUARANTEEING, OR OTHERWISE OFFERING ANY
DEFINITIVE PROMISE OF SECURITY IN CONNECTION WITH YOUR INFORMATION OR TECHNICAL
INFORMATION.

9. Where is your information processed or stored?

Crosschq uses servers located in the United States. Crosschq may also use
partners or affiliates located in other countries besides the US to store and
process your information. By using the Services, you consent to the transfer of
information outside of your country, even if your country has more rigorous data
protection standards.

10. Who can use the Services?

You must be 18 years of age or older to use the Services. If you are a parent or
guardian and believe that your child under the age of 13 has provided personally
identifiable information to us through the Services, please contact us at
support@crosschq.com. If we discover that an individual under 13 has provided us
with personal information, we will take steps to delete the account and any such
personally identifiable information to the extent required by applicable law.

11. How does Crosschq comply with international data protection laws?

Under applicable data protection laws, you have the following data protection
rights in respect of your personal information collected by Crosschq:

 * If you wish to access, correct, update or request deletion of your personal
   information, you can do so at any time by contacting us at
   support@crosschq.com.
 * If you are a resident of the European Economic Area or the UK, you can object
   to processing of your personal information, ask us to restrict processing of
   your personal information or request portability of your personal
   information. You can exercise these rights by contacting us at
   support@crosschq.com.
 * You have the right to opt out of text based messaging at any time by replying
   to the text message with the word “STOP”.
 * If we have collected and processed your personal information with your
   consent, you can withdraw your consent at any time and request that your
   personal data be deleted. This will not affect the lawfulness of any
   processing conducted prior to your withdrawal, nor will it affect processing
   of your personal information conducted in reliance upon lawful processing
   grounds other than consent.
 * You have a right to complain to a data protection authority about our
   collection and use of your personal information. For more information, please
   contact your local data protection authority.

12. How can I contact you with more questions?

If you have any questions, concerns or complaints about this Policy or
Crosschq’s handling of your personal information, or if you would like to access
or update personal information that is not available via the Crosschq Service,
please contact us at support@crosschq.com.

VERB /KRÄS'CHEK/

Verify (figures or information) by using an alternative source or method.
”Always Crosschq your candidates.”

Verb /kräs'CHek/ Verify (figures or information) by using an alternative source
or method.
”Always Crosschq your candidates.”

NOUN /'KRÄSCHEK/

An instance of cross-checking figures or information.
“Did you read her Crosschq?”

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