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PRIVACY POLICY

Privacy Policy

UPDATED: 3 OCTOBER 2023



We at Beamery Inc. and its affiliates ("Beamery", “we”, “us”, “our”) know that
our users and candidates (“you”, “your”) care about how your personal data is
used and shared and we take your privacy seriously. We are focused on protecting
your personal data and your privacy rights.


1. WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy applies to the processing of Personal Data collected by us
when:

• you visit www.beamery.com (our "Website") or use the various products and
services provided by Beamery (“Services”), (“Users”);
• you are being, have been, or will be considered for a position of employment
at Beamery ("Candidates”);
• you are an employee of Beamery;
• you have subscribed to receive communications regarding Beamery’s marketing
and publicity activities;
• you register for, attend or take part in events, webinars, programs, training,
certifications, or contests run, sponsored, or attended by Beamery;
• you contact or communicate with us, for example, by requesting a demo;
• you visit our offices;
• you participate in reviews, surveys, research or other similar activities
facilitated by or on behalf of us;
• you or the company you are employed by provide services to us;
• Beamery otherwise collects your data for its own purposes and is deemed a
‘”controller”’ under the GDPR or ‘business’ under the CCPA.

For Beamery Employees: This Privacy Policy supplements your employment contract
with us.

For Beamery Users: This Privacy Policy supplements our Website Terms of Use. If
you are a Beamery Grow User, you have entered into the Beamery Grow Subject
Agreement with Beamery, which contains clauses regarding the use and/or
processing of Personal Data. In the event of any conflict between the terms of
this Privacy Policy and the Beamery Grow Subject Agreement, the relevant terms
of the Beamery Grow Subject Agreement shall prevail.

Beamery as a Service Provider: Beamery customers are organizations that use our
enterprise products and services to process personal data about individuals that
are being, have been or will be considered for a position of employment
(“Customer Data Subjects”) and to manage their relationships with these
individuals. Beamery processes personal data of Customer Data Subjects only
according to our customers’ instructions as a “processor” or “service provider”
and this Privacy Statement does not apply.

This policy does not apply to the practices and processing of our customers, to
companies that we do not own or control, to individuals that we do not employ or
manage, to services


2. WHAT INFORMATION DOES BEAMERY COLLECT?

The Personal Data that we collect depends on our relationship with you.

A. INFORMATION YOU PROVIDE TO US:




Sensitive Information: We may collect information sensitive information (for
example, your race, gender, or sexual orientation) for our diversity and
inclusion reporting but only where you voluntarily provide this. We may also
collect sensitive information if required by the relationship, for example, to
make payments to you.

De-identified Information: We may also de-identify Personal Data to reduce the
chances of being individually identified (e.g. replacing a name by a random
number and deleting the original name; grouping 30 individual Candidates from
London into one group “Candidates from London”). We use that de-identified
and/or aggregated information for our own purposes, including statistics,
analysis, AI, machine learning, and development of our product, or to provide
that information to our partners for visitor statistics and analysis of our
Website, Services, and our partner's services. We use one-way data hashing for
analytics purposes to ensure there is less risk of personal identification
reversal. We use hashing on all Personal Data. For any linkable Personal Data,
we ensure that we process aggregated data only, so there is a many-to-many
relationship, and any reference can less likely be traced to an individual. Any
technical data we store for service delivery (like IP addresses) is not tied to
any other data piece that contains Personal Data and is treated as a technical
data point only.

B. INFORMATION COLLECTED AUTOMATICALLY:

Cookies/similar technologies: Whenever you interact with our Website or
Services, we automatically process information on server logs by using “browser
cookies” or similar technologies. These technical means are either transferred
to or communicated with your computer or mobile device to remember that you have
registered and are logged in to your Beamery account or to recognize the browser
or mobile device and tell us how and when pages on our Website are visited. You
can find more details about our use of cookies or similar technologies in our
Legal - Cookie Policy

Log Data: When you visit the Website, our servers automatically record
information about the browser or mobile app with which our Website is opened.
Log Data includes your computer’s/mobile’s browser type, IP address, the
requested webpage of our Website or feature of our Service, webpages visited
before our Website, the time spent on those pages or features, subjects of
searches on our Website and Services, access times and dates, and other related
statistics. We use this Log Data to monitor and analyze the use of the Website
and the Services and for the Website’s technical administration, to increase our
Website’s functionality and user-friendliness, and to better tailor it to our
visitors’ needs. Additionally, we use Log Data including your IP address for
security purposes like whitelisting, prevention, and recognition of attacks and
malware.

Third-Party Analytics: Our Website includes social media features, such as the
Facebook® Like button and widgets such as the “Share This” button for Twitter®
and LinkedIn®. These features may collect your IP address and the page you are
visiting on our Website, and they may set a cookie or similar technical device
to enable the feature to function properly. Social media features and widgets
are either hosted by a third party or hosted directly on our Website. Your
interactions with these features are governed by the privacy policy of the
company providing the feature.

Prevent or Opt-out: You can change the preferences on your browser or mobile
device to prevent or limit your computer or device’s acceptance of these
technical means, but this may prevent you from taking advantage of some of our
Website’s or Service’s features. As the means by which you can refuse cookies
through your internet browser controls vary depending on the browser or device
used, you should visit your device or browser's help menu for more information.

We use cookies served by Google Analytics to collect limited data directly from
end-user browsers to enable us to understand the usage of our Website and
Services, including making use of the demographics and interests reports
services of Google Analytics. Further information on how Google collects and
uses this data can be found at www.google.com/policies/privacy/partners/. You
can opt out of all Google-supported analytics within the Website by visiting
https://tools.google.com/dlpage/gaoptout.

We utilize Google reCAPTCHA to verify users and prevent automated spam. This
means some user data is sent to Google for validation. By interacting with the
forms on our Website, you agree to Google's data handling as outlined in their
Privacy Policy and Terms of Service.

If you click on any link to a third-party website or service, such third party
may also transmit cookies to you. This Privacy Policy does not cover the use of
cookies by any third parties.

C. INFORMATION WE MAY RECEIVE FROM THIRD PARTIES:

We may receive information about you from third parties. For example, if you
access our Website or Services through a third-party connection or log-in, such
as, through Facebook Connect, by “following,” “liking,” the Beamery application,
linking your Beamery account to the Services, etc., that third party may pass
certain information about your use of its service to us. This information could
include, but is not limited to, the user ID associated with your account (for
example, your Facebook user ID), an access token necessary to access that
service, any information that you have permitted the third party to share with
us including contacts or “friends”, and any information you have made public in
connection with that service.

If you allow us access to your “friends list”, your friends’ user IDs, and your
connection to those friends, we may process them to provide social features to
you that you have actively turned on and which make your experience on our
Website and in our Services more social, e.g. to allow you to invite your
friends to use our Services as well as provide you with updates if and when your
friends join Beamery. Friends list information and shared contacts may also be
used to improve Beamery’s Services only if and to the extent it is permitted
under applicable law. You should always review and, if necessary, adjust your
privacy settings on third-party websites and services before linking or
connecting them to the Services.

Beamery will also receive the Google User Data that you give us access to.
However, Beamery’s use and transfer to any other app of information received
from Google APIs will adhere to Google API Services User Data Policy, including
the Limited Use requirements.


3. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We may retain your Personal Data for a period of time consistent with the
original purpose of collection (for example, until consent is withdrawn or as
long as required to fulfil our legitimate interest or legal obligations). We
determine the appropriate retention period for Personal Data on the basis of the
amount, nature, and sensitivity of the Personal Data being processed, the
potential risk of harm from unauthorized use or disclosure of the Personal Data,
whether we can achieve the purposes of the processing through other means, and
on the basis of applicable legal requirements (such as applicable statutes of
limitation).

For Beamery Grow Users, please see the Legal - Legal Hub

When you update your Personal Data, we may maintain a copy of the original data
in our records (to the extent permitted by applicable law).


4. WHERE DO WE PROCESS YOUR PERSONAL DATA?

Your Personal Data may be collected, transferred to and stored by us in the
United Kingdom ("UK"), European Economic Area ("EEA"), and the United States of
America ("USA") or Australia. We may also transfer your information to other
countries where our affiliates and service providers operate facilities.

Therefore, your Personal Data may be processed outside your country or
jurisdiction, including in places that are not subject to an adequacy decision
by the European Commission or your local legislature or regulator. Where this
occurs, we take all steps reasonably necessary to ensure that your Personal Data
is treated securely and in accordance with applicable data protection laws and
this Privacy Policy. You can request a list of our sub-processors who process
Personal Data, their respective locations, and the adequate transfer mechanism
used by email to privacy@beamery.com.

If you are a resident of the EEA, the UK, or Switzerland, we use a variety of
legal mechanisms to help ensure your Personal Data and rights are protected. We
ensure that the recipient of your Personal Data offers an adequate level of
protection and security, for instance, by entering into the appropriate
back-to-back agreements and, if required, standard contractual clauses or an
alternative mechanism for the transfer of data as approved by the European
Commission (Art. 46 GDPR) or other applicable regulators. Where required by
applicable law, we will only share, transfer, or store your Personal Data
outside of your jurisdiction with your prior consent. Please see further
information on Beamery's Data Protection Framework certification in Section 12.


5. WHAT WILL BEAMERY USE YOUR PERSONAL DATA FOR / WILL BEAMERY SHARE ANY OF THE
PERSONAL DATA IT RECEIVES?

We will use your data as applicable to the relationship per the table above,
such as to provide the Services to you, to consider you for a position of
employment with Beamery, or to pay you for your services to us.

We may also contact you by email or by other means. For example, we may
communicate with you about your use of the Website or Services or in relation to
new Beamery products, services, events or other marketing initiatives, or
employment vacancies. If you do not want to receive email or other
communications from us, please indicate your preferences by adjusting the
settings in your Beamery account or follow the instructions we provide to you in
each of our emails to unsubscribe or opt-out of the relevant publication or
updates.
Beamery will still send you notices that are required by applicable law,
regardless of whether you opt-out or unsubscribe from communications.

Beamery may use automated decision-making leveraging a variety of signals
derived from records we collect to help monitor, identify, and suspend accounts
sending spam or engaging in other abusive or fraudulent activity. Holders of
accounts suspended under these circumstances are notified of the suspension and
given an opportunity to request human review of the suspension decision.

Finally, we may use your Personal Data for product improvement, and/or analytics
purposes.

We neither rent nor sell your Personal Data or your Candidates’ Information to
any third party. However, we may share such Personal Data with your consent or
as necessary with third parties as described below.

A. TRUSTED THIRD PARTIES:

We employ other companies and individuals to either perform tasks on our behalf
or to provide specific features to you at your request. Unless we tell you
otherwise, such third parties do not have any right to use the Personal Data we
share with them beyond what is necessary to assist us. This includes third-party
companies and individuals employed by us to facilitate our Website or Services,
including the provision of maintenance services, sales and marketing
applications, database management, web analytics, and general improvement of the
Website or Services.

B. PROTECTION OF BEAMERY AND OTHERS:

We may be compelled to access, read, preserve and/or disclose any information to
(i) comply with applicable law or court order; (ii) enforce or apply our Website
Terms of Use, or other agreements with you in our sole discretion; or (iii)
protect the rights, property, or safety of Beamery, our employees, our users, or
others in our sole discretion. We may send information to fraud protection and
credit risk reduction agencies, but only in a manner limited to and consistent
with that specific purpose.

C. EVENT SPONSORS:

We may disclose your Personal Data to sponsors of events that you attend.

D. ACTUAL OR POTENTIAL BUYER:

We may disclose your Personal Data to an actual or potential buyer (and its
agents and advisers) in connection with any actual or proposed purchase, merger,
or acquisition of any part of our business, provided that we inform the buyer it
must use such data only for the purposes disclosed in this Privacy Policy.

E. WITH YOUR CONSENT:

Except as set forth above, you will be notified when your Personal Data may be
shared with third parties and will be able to object to the sharing of this
information. Please take note: Our Website offers publicly accessible blogs and
community forums. You should be aware that any information you provide in these
areas may be read, collected, and used by others who access them.


6. IS MY PERSONAL DATA SECURE?

Beamery implements appropriate technical and organizational measures to protect
Personal Data from loss, misuse, and unauthorized access, disclosure,
alteration, and destruction. You can find details concerning our security
measures (such as encryption) in our Security.

Our Website may contain links to other sites. We cannot and have not reviewed
these sites and cannot be responsible for the privacy policies and/or practices
on these other sites. When following a link to another site, you must read that
site’s privacy policy and ensure you accept the terms of the same.


7. DO WE PROCESS DATA OF CHILDREN?

Our Website or Services are not directed to persons under the age of 16. We
neither knowingly allow such persons to register for the Website or Services on
our Website nor knowingly collect Personal Data from children under 16. No one
under age 16 may provide any Personal Data to us or on the Website or Services.

If a parent or guardian becomes aware that their child has provided us with
Personal Data without the parent’s consent, they should contact us at
privacy@beamery.com. If we become aware that a child under 16 has provided us
with Personal Data, we will take steps to delete such information from our
systems.


8. WHAT RIGHTS DO I HAVE AND HOW DO I EXERCISE THEM?

In relation to your Personal Data, you always have the following rights to the
extent available under applicable law:

• Right to obtain information about the processing of your Personal Data;
• Right to obtain access to your Personal Data know what Personal Data we
process on you;
• Right to rectify inaccurate Personal Data concerning you;
• Right to erase your Personal Data;
• Right to restrict processing of your Personal Data;
• Right to transmit your Personal Data to another provider;
• Right to object to any data processing that is based on our legitimate
interest;
• Right to withdraw consent, to the extent we base processing on consent;
• Right not to be subject of a decision solely based on automated processing
including profiling;
• Right to complain to a data protection authority; and
• Not be discriminated against for exercising your rights described above.

If you wish to exercise any of these rights, please contact us at
privacy@beamery.com.

A. USERS OF OUR WEBSITE OR SERVICES:

You may be able to add, update, or delete information via your Beamery account,
Website or the Services. However, when you update information, we may maintain a
copy of the original information in our records (to the extent permitted by
applicable law). You may also make these requests to privacy@beamery.com. If you
demand the erasure or object to any data processing, please keep in mind that
some Personal Data may be needed to register with us or to take advantage of
some of our Website, products and Services.

B. CANDIDATES OF BEAMERY:

Candidates of Beamery can make data access, correction or deletion requests to
privacy@beamery.com. Beamery does not make any hiring decision solely based on
automated processing, including profiling.

C. COMMUNICATIONS FROM BEAMERY:

All communications from Beamery should include an “unsubscribe” option. It may
take some time to process this request, so please wait a few days before raising
a query if communications do not cease immediately. If you continue to receive
communications from Beamery or there is no “unsubscribe” option, you can send a
request to be removed from all mailing to privacy@beamery.com.

D. BEAMERY’S PUBLIC POSTS:

To request removal of your Personal Data from our website, social media, blog or
community forum, contact us at privacy@beamery.com. In some cases, we may
technically not be able to remove your Personal Data, in which case we will let
you know if we are unable to do so and why.

E. OTHER:

Send any requests to privacy@beamery.com. Please note that where Beamery
processes your data as a ‘processor’ these requests should be sent directly to
the applicable ‘controller’.


10. CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time and provide the new
information to you on our Website. Please review this document occasionally to
familiarize yourself with any changes.


11. ADDITIONAL TERMS FOR CALIFORNIA RESIDENTS

The California Consumer Privacy Act (as amended by the California Privacy Rights
Act) requires businesses to disclose whether they sell or share Personal Data.
As a business covered by the CCPA, we do not sell Personal Data. We may share
Personal Data (in the form of identifiers and internet activity information)
with third-party advertisers for purposes of targeting advertisements on
non-Beamery websites, applications, and services. In addition, we may allow
third parties to collect Personal Data from our sites or services if those third
parties are authorized service providers who have agreed to our contractual
limitations as to their retention, use, and disclosure of such Personal Data, or
if you use Beamery sites or services to interact with third parties or direct us
to disclose your Personal Data to third parties.


We use and disclose the categories personal information for various business
purposes, including providing the Website and Services, processing and managing
interactions and transactions, quality assurance, security, debugging, research
and development, and marketing.

• Identifiers including the name, unique personal identifier, online identifier,
Internet Protocol address, email address, account name, or other similar
identifiers. We obtain such information when you provide it to us.
• Internet or other electronic network activity information, including
information regarding interactions with our Website and/or Services. We obtain
this information automatically in the course of your interactions with our
Services.
• Inferences, including your preferences, likelihood of interest in certain of
our Services or inferences of your skills for employment purposes.
• Professional and employment-related information (for Candidates and
Employees).
• Education information (for Candidates and Employees).
• Financial information (for service providers and Employees).
• Characteristics of protected classifications under California or federal law
(for Candidates and Employees). We obtain such information when you provide it
to us.

We do not sell personal information that we collect either from you or from
Customer Users. In addition, we do not share personal information with third
parties for their own direct marketing purposes.

"Do Not Track" or "DNT" is a browser setting that users can set in their web
browsers. When a user turns on the "DNT" signal in the web browser, the browser
sends a message to websites requesting them not to track the user. Since uniform
standards for "DNT" signals have not been adopted, our Website does not
currently process or respond to "DNT" signals. In addition, some of our
third-party service providers may use standard technology, such as cookies,
pixel tags, and web beacons, to collect information about internet activities.
We will continue to monitor developments around DNT browser technology and the
implementation of such a standard.

For further information on your rights under CCPA, see Section 8 of this Privacy
Policy.


12. DATA PRIVACY FRAMEWORK, CONCERNS, AND RESOLUTION

Beamery complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the
UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework
(Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Beamery has
certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data
Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the
processing of personal data received from the European Union and the United
Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.
Beamery has certified to the U.S. Department of Commerce that it adheres to the
Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with
regard to the processing of personal data received from Switzerland in reliance
on the Swiss-U.S. DPF. If there is any conflict between the terms in this
privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF
Principles, the Principles shall govern. To learn more about the Data Privacy
Framework (DPF) program, and to view our certification, please visit
https://www.dataprivacyframework.gov/. We may be required to disclose personal
information in response to lawful requests by public authorities, including to
meet national security or law enforcement requirements. As required under the
principles, when Beamery receives information under the Data Privacy Framework
and then transfers it to a third-party service provider acting as an agent on
Beamery’s behalf, Beamery has certain liability under the Data Privacy Framework
if both (i) the agent processes the information in a manner inconsistent with
the Data Privacy Framework and (ii) Beamery is responsible for the event giving
rise to the damage.

In compliance with applicable law, Beamery commits to resolving complaints about
your privacy and our collection or use of your Personal Data promptly.
Individuals with inquiries or complaints regarding this Privacy Policy should
first contact Beamery at privacy@beamery.com or send a letter (preferably by
tracked registered post to ensure delivery confirmation) to the address below.
We may need to verify your identity and place of residence before completing
your rights request. You may have the option to select binding arbitration under
the EU-U.S. Data Privacy Framework Panel for the resolution of your complaint
under certain circumstances.

Attn: Data Protection Officer
Beamery Ltd
20th-21st Floors, 105 Bunhill Row
London, EC1Y 8LZ
United Kingdom

In the US, Beamery is subject to the investigatory and enforcement powers of the
U.S. Federal Trade Commission (FTC).

If you have an unresolved privacy or data use concern that we have not addressed
satisfactorily, please contact our U.S.-based third-party dispute resolution
provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

If you are a resident of the European Economic Area (EEA), United Kingdom (UK),
or Switzerland and are dissatisfied with the manner in which we have addressed
your concerns about our privacy practices, you may seek further assistance, at
no cost to you, from our designated independent recourse mechanism, listed
above. In the EEA, you can approach any supervisory authority that is competent
under the General Data Protection Regulation. If you are an EEA resident, the
data protection authorities' contact details are available here. If you are
resident in the UK, the contact details for the Information Commissioner's
Office are available here. If you are resident in Switzerland, the contact
details for the data protection authorities are available here. However, we
encourage you to contact us first at privacy@beamery.com, and we will do our
very best to resolve your concern.


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