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PRIVACY POLICY

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EFFECTIVE DATE: February 20, 2020

Paycor, Inc. values your privacy, and is committed to providing exceptional
client service and ease of mind that your business, financial and/or personal
information is secure. We use reasonable care to protect your data from loss,
misuse, unauthorized access, disclosure, alteration, or destruction. We have
created this privacy statement and notice (“Privacy Policy”) with your privacy
and security in mind to help you understand what information we are collecting
and how it is being used as we seek to deliver you exceptional service.

The following discloses the information gathering, use, and dissemination
practices for Paycor, Inc. (referred to as “Paycor,” “we,” “us,” or “our”),
including how we protect the personal information that you share with us. This
Privacy Policy applies to your use of our websites as well as the products and
services we offer, including applications hosted on paycor.com,
newtonsoftware.com, and the gravityapp.com and all mobile applications released
by us through the Apple App Store or the Google Play Store (collectively
“Website” or “Websites”). The job applicant tracking software system found at
newtonsoftware.com, recruitingbypaycor.com, and apply-recruitingbypaycor.com
(“Recruiting”) and the job-sharing application found at thegravityapp.com
(“Gravity”) are governed by this Privacy Policy (except where indicated) as well
as the additional terms addressing each individual application (the “Recruiting
Application” section and the “Gravity Application” section).


DISCLAIMER

Paycor believes all the statements and information provided in this Privacy
Policy to be accurate and reliable, but presents them without guarantee,
expressed or implied.


COLLECTION AND USE OF PERSONAL INFORMATION

Paycor collects personal information from you or about you when:

(1) you visit our Website
(2) you are asked to register before entering a limited access site
(3) you request information or contact from Paycor
(4) you voluntarily provide it via the Website
(5) you sign up to receive alerts or notifications
(6) you make a purchase, and
(7) your current, prospective, or former employer or a similarly affiliated
entity (referred to as “Employer”) provides it to Paycor to facilitate the
processing of benefits management, payroll services, tax compliance, scheduling
and timekeeping, onboarding, related human resources-related services, and data
analytics, (collectively “Services”).

Personal Information collected may include:

 * Name
 * Gender
 * Date of birth
 * Street address
 * Phone number
 * E-mail address
 * Employer names
 * Employment history
 * Job title
 * Unique personal identification number (for example: Social Security Number)
 * Direct deposit account number
 * Contact information
 * Profile photo and related photos
 * Job application information
 * Job openings that you share via the Gravity application
 * Correspondence or communication sent via the Website
 * Preferred language and country information
 * User name
 * Password
 * Device identification information
 * Browser fingerprint
 * Geolocation information
 * IP address
 * Biometric information as described in our Biometric Information Policy.  Our
   collection, storage, and use of biometric information is as set out in, and
   is governed by, our Biometric Information Policy.
 * Other reasonably relevant information pertaining to your use of the Website,
   including without limitation, standard web log information and content
   provided to Paycor or its designated third-parties when contacted for
   assistance.
 * and any other information you may voluntarily provide (“Personal
   Information”).

These categories of information may be disclosed to authorized third parties to
facilitate the provision of Services.


LAWFUL BASIS FOR PROCESSING PERSONAL INFORMATION AND ROLE OF EMPLOYERS

Paycor only processes your Personal Information where a lawful basis exists and
does so under a legal or contractual obligation, your consent, or for legitimate
interests pertaining to Paycor’s business and operations. In many instances,
including for the purposes listed in the preceding paragraph, your Personal
Information is collected, either directly or indirectly, as a result of your
employment with an Employer. In such instances, your Employer is also a Paycor
customer and has contracted with us to assist with these Services. In such
cases, your Employer may provide us the Personal Information necessary to
provide the Services to you and we are merely processing this Personal
Information on behalf of you and your Employer. Therefore, in addition to this
Policy, you should also familiarize yourself with any policies your Employer may
have regarding your Personal Information.

For more information regarding the disclosure of information with authorized
third parties, see “Sharing of Information” below.


TEXT MESSAGING

You have an option to choose to receive text messages (SMS) from us to keep you
informed of updates. This service is optional and does not require you to
purchase goods or services from Paycor or its affiliates. If you give us your
mobile device number and opt into such text messaging as provided below, you
hereby consent to the Paycor’s use of your mobile device number in accordance
with this Privacy Policy and any applicable terms of use until you withdraw such
consent. You further consent to receive phone calls or pre-recorded messages,
including those from automated dialing systems. Message and data rates may
apply.

 * To join Paycor’s text messaging program, you can opt-in and configure your
   text-based notifications and security settings through the Website directly.
 * To discontinue receiving SMS messages from Paycor, you can opt-out of your
   text-based notifications and security settings through the Website.

This Text Messaging section is not applicable to the Recruiting application.


COOKIES AND OTHER AUTOMATED INFORMATION COLLECTION

Please visit the Cookie Policy for information on Paycor’s cookie and automated
information collection practices. See Gravity Application section for additional
details about how the Gravity application utilizes cookies.


SHARING OF INFORMATION

We may share Personal Information with third parties under any of the following
circumstances:

 * With your Employer or as instructed by your Employer.
 * In connection with a court order, subpoena, government investigation, or when
   otherwise required by law, rule or regulation.
 * In response to lawful requests by public authorities, including to meet
   national security or law enforcement requirements.
 * In the event of a corporate sale, merger, acquisition, or similar event.
 * Working with contracted third party entities to support the Website’s
   operation and administration.
 * Working with contracted third party entities to perform certain
   business-related functions (e.g., mailing campaigns to customers, maintaining
   databases, providing products or services to you on our behalf, fulfilling or
   responding to your requests or purchases) to the extent needed for such third
   parties to perform their specific functions.
 * Working with companies that we own or control, that are owned or controlled
   by Paycor, or that are under common ownership or control. Data collected by
   these entities are subject to their respective privacy policies and
   applicable terms and conditions. These companies may include, but are not
   limited to, Nimble Software Systems, Inc. (data may be shared and used as
   part of the Perform Time service) and Paltech Solutions, Inc. dba
   7Geese (data may be shared and used as part of the Perform HR service).
 * In connection with providing aggregated anonymous information concerning
   member usage of the Services to third parties, such as for advertisers, for
   purposes that we deem appropriate for service administration.

We will not sell, rent, loan, transfer, or otherwise disclose any Personal
Information to third parties except as set forth in this Privacy Policy, with
your consent, or as otherwise disclosed to you at the time of Personal
Information collection.


CHOICE AND PREFERENCES

We want to provide you with relevant information that you have requested. If we
provide subscription-based services, such as email newsletters, we will allow
you to make choices about what information you provide at the point of
information collection or at any time after you have received a communication
from us while you are subscribed. Any transactional or service-oriented messages
are usually excluded from such preferences, as such messages are required to
respond to your requests or to provide goods and services, and are not intended
for the purposes of marketing.

We will not intentionally send you email newsletters and marketing emails unless
you consent to receive such marketing information. After you request to receive
these emails, you may opt out of them at any time by selecting the “unsubscribe”
link at the bottom of each email. Please note that by opting out or
unsubscribing you may affect other services you have requested we provide to
you, in which email communication is a requirement of the service provided. Any
such communications you receive from us will be administered in accordance with
your preferences and this Privacy Policy.


PRIVACY SHIELD

Paycor complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S.
Privacy Shield Framework as set forth by the U.S. Department of Commerce
regarding the collection, use, and retention of personal information from
European Union member countries, the United Kingdom, and Switzerland transferred
to the United States pursuant to Privacy Shield. Paycor has certified that it
adheres to the Privacy Shield Principles with respect to such data. If there is
any conflict between the policies in this privacy policy and data subject rights
under the Privacy Shield Principles, the Privacy Shield Principles shall govern.
To learn more about the Privacy Shield program, and to view our certification
page, please visit https://www.privacyshield.gov/

Paycor retains the Personal Information of European Union, Swiss, and United
Kingdom residents only for as long as it is necessary to fulfill the stated
purposes or as legally required and thereafter appropriately disposes of such
information. Paycor has retention periods for the various records containing
Personal Information. When Personal Information is no longer necessary or
relevant for the identified purpose or to fulfill a legal or business
requirement, it is securely destroyed. Paycor will either physically or
electronically erase the Personal Information or otherwise render it incapable
of individually identifying you.


TRANSFERS OF DATA TO THE U.S.

We are EU-U.S. and Swiss-U.S. Privacy Shield certified. Nonetheless, in
accordance with the decision by the Court of Justice of the European Union
(C-311/18, also known as “Schrems II“), on July 16, 2020, we ceased relying on
our EU-U.S. and Swiss-U.S. Privacy Shield certifications as a legal basis for
international data transfers from the EEA or Switzerland to the U.S.


PRIVACY SHIELD PRINCIPLES

Paycor is committed to ensuring that your Personal Information is correct,
up-to-date, and as publicly available as you wish it be when displayed on the
Website.

Paycor affirms the following in compliance with the Privacy Shield Principles:

 * Paycor is subject to the jurisdiction and enforcement authority of the US
   Federal Trade Commission
 * EU, Swiss, and UK individuals whose personal data has been transferred into
   the United States pursuant to the Privacy Shield have the right to access
   their data and to correct, amend or erase data that is incorrect or has not
   be processed in accordance with the Privacy Shield principles.
 * For Personal Information that Paycor processes as a controller, individuals
   wishing to exercise this right may do so by utilizing Paycor’s Access Request
   Portal or as otherwise disclosed in this Policy
 * If your Personal Information has been provided to Paycor by your Employer we
   may not have the authority to grant you access to that data. In that case we
   will either refer you back to your Employer or pass on your request to the
   appropriate party.
 * Paycor may be required to release personal data in response to lawful
   requests by public authorities including to meet national security and law
   enforcement requirements
 * Paycor’s accountability for personal data that it receives in the United
   States under the Privacy Shield and subsequently transfers to a third party
   is described in the Privacy Shield Principles. In particular, Paycor remains
   responsible and liable under the Privacy Shield Principles if third-party
   agents that it engages to process personal data on its behalf do so in a
   manner inconsistent with the Principles, unless Paycor proves that it is not
   responsible for the event giving rise to the damage.
 * Paycor does not transfer data to non-agent third parties nor do we permit the
   use of such information for reasons other than those for which the data was
   originally provided. If this practice should change in the future, we will
   update this policy accordingly and provide individuals with appropriate
   opt-in or opt-out choice prior to releasing that information.
 * We will provide an individual opt-out choice, or opt-in for sensitive data,
   before we use your data for a purpose other than which it was originally
   collected or subsequently authorized. To request to limit the use and
   disclosure of your personal information, please do so by utilizing
   Paycor’s Access Request Portal or emailing the Privacy Team.


INQUIRIES

In compliance with the Privacy Shield Principles, Paycor commits to resolve
complaints about your privacy and our collection or use of your Personal
Information. If you have inquiries or complaints regarding this Policy or would
like to access your Personal Information, you should first contact Paycor via:
(1) utilize Paycor’s Access Request Portal or email the Privacy Team; or (2)
mail to Attn: Privacy Request, Paycor Inc., 4811 Montgomery Rd., Cincinnati,
Ohio 45212.

Paycor has further committed to refer unresolved privacy complaints under the
Privacy Shield Principles to an independent dispute resolution mechanism, the
BBB EU PRIVACY SHIELD. If you are an individual in the European Union,
Switzerland or United Kingdom and do not receive timely acknowledgment of your
complaint, or if your complaint is not satisfactorily addressed, please visit
https://bbbprograms.org/privacy-shield-complaints for more information and to
file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels,
under certain conditions, you may invoke binding arbitration for some residual
claims not resolved by other redress mechanisms. See Privacy Shield Annex 1
at https://www.privacyshield.gov/article?id=ANNEX-I-introduction


AUTOMATED DECISION-MAKING

Paycor’s Performance Management service allows Employers to engage its employees
through surveys or similar feedback mechanisms which may utilize Artificial
Intelligence (AI) in the form of Natural Language Processing (NLP) for the
synthesis of qualitative question responses. In no case does Paycor use this
information for automated decision-making or profiling. Employers, as the data
controller, are responsible for any prior and subsequent use of data provided to
Paycor or through the Services and should provide notice to, collect consent
from, and provide recourse mechanisms to individuals if required and as
appropriate.


CALIFORNIA

If you reside in California, pursuant to California Civil Code Section 1798
and/or the California Consumer Privacy Act you may be entitled to request that
Paycor delete your Personal Information and/or provide a notice describing the
categories of Personal Information Paycor collects and how that data is used and
shared. Paycor does not share any California consumer Personal Information with
third parties for marketing purposes without consent and requests about data
processed for payroll, HR, or other employment purposes should be addressed by
your Employer. If you reside in California and would like a copy of this notice,
please submit a written request via: (1) utilize Paycor’s Access Request
Portal or email the Privacy Team; or (2) mail to Attn: California Privacy Rights
Notice Request, Paycor Inc., 4811 Montgomery Rd., Cincinnati, Ohio 45212. Please
allow 30 days for a response.

Do Not Track Disclosure

Other than as disclosed in this Privacy Policy, the Website does not track users
over time and across third-party websites to provide targeted advertising.
Therefore, the Website does not operate any differently when it receives Do Not
Track (“DNT”) signals from your internet web browser.


EXTERNAL LINKS

This site contains links to other sites. Paycor is not responsible for the
privacy practices or the content of such websites. If you follow a link to any
of these websites, please note that these websites have their own privacy
policies and that we do not accept any responsibility or liability for their
policies. Please check the individual policies before you submit any information
to those websites.


SECURITY

This Website has security measures in place to protect the loss, misuse, and
alteration of the information under our control. We take a number of security
precautions to ensure the integrity and confidentiality of our data. These
precautions can be categorized as internal security and external security. At
Paycor, we use these security categories to limit the individuals or groups
authorized to access and/or change data in such categories. This prevents
unauthorized individuals from accessing, copying, editing, or deleting data. We
also implement an audit system that tracks access, both successful and
unsuccessful, to confidential data. This audit information is used to constantly
evaluate and refine our security measures and to identify individuals who might
attempt to inappropriately access data and to take remedial action. Paycor uses
industry-standard technology to encrypt and authenticate transactions. Learn
more about Paycor’s Security practices at https://www.paycor.com/security.

As you know, however, the Internet is not a 100% secure environment, and as a
result, we cannot ensure or warrant the security of any information that you
transmit to us. There is no guarantee that information may not be accessed,
disclosed, altered, or destroyed by breach of any of our administrative,
technical, or physical safeguards. It is your responsibility to protect the
security of your login information and computing device. Please help keep your
account safe by using a strong, confidential password and utilizing multi-factor
authentication. Depending on the situation, other you may want to implement
security measures in addition to those provided by Paycor.


INFORMATION OF MINORS

The Website is not intended for use by children under 16 years old and we do not
knowingly collect any information from children under 16 years old through the
Website. If you are under 16 years old, you may not use our Website.


UPDATING PERSONAL INFORMATION

You control the accuracy of your Personal Information. If your Personal
Information changes, please have your Employer correct, update or delete it from
our Website.

Outside of its legal obligations to your Employer, Paycor has no obligation to
maintain or provide any of your Personal Information and may, unless legally
prohibited, delete all of your Personal Information in our systems or otherwise
in our possession or under our control. We may also retain all or a subset of
your Personal Information for business or legal purposes.

Paycor responds to requests within the time limit set out by the applicable
privacy legislation and, if applicable, provides the individual with an estimate
of any cost associated with administering and responding to the request. Paycor
requires sufficient information to authenticate requests for access.


RECRUITING APPLICATION

The Recruiting application is used by companies to post job openings, collect
potential job applicant information and track applicants through the hiring
process. The Recruiting application is accessed and used by two distinctly
different types of users:

(1) companies that post job openings and review candidates who apply for those
job openings;

(2) candidates for those job openings who use the Recruiting application to
apply for them (“Applicants”).

Applicants that do not consent to the terms and conditions of this Privacy
Policy should not use the Recruiting application.

Text Messaging

You have an option to choose to receive text messages (SMS) from us to keep you
informed of updates. This service is optional and does not require you to
purchase goods or services from Paycor or its affiliates. If you provide your
mobile device number and opt into such text messaging as provided below, you
hereby consent to the Paycor’s use of your mobile device number in accordance
with this Privacy Policy and any applicable terms of use until you withdraw such
consent. You further consent to receive phone calls or pre-recorded messages,
including those from automated dialing systems. Message and data rates may
apply.

 * Applicants can opt-in through the Recruiting application directly or by
   requesting that the Employer enable this service.
 * To discontinue receiving SMS messages from Paycor, reply STOP to any message
   you have received from Paycor.


GRAVITY APPLICATION

The Gravity application is used by individuals and Employers (as applicable,
“you”) to share jobs on socials networks, manage employee referral programs, and
incent people to share jobs and generate applicants.

Assigning Cookies

When you sign in through the Gravity application, Paycor will assign you a
unique identifier and send such information to your computer or device hard
drive in the form of a cookie, which is a very small bit of code. This code is
uniquely yours and allow you to use the Gravity application’s functionality with
minimal subsequent registration procedures. Cookies are also used to record you
as the source of any candidate or job referrals on the Gravity application. If
you apply for a job opening that has been shared through the Gravity
application, Paycor will assign you a unique identifier and send such
information to your computer or device hard drive in the form of a cookie. This
code is unique to you and will correlate your job application to the person that
posted such job opening on the Gravity application. It does not contain any of
your Personal Information.

Personal Profile Information

When you register on the Gravity application, Paycor uses a third-party
provider, Akamai, to manage the Gravity application login registration process
and create a personal profile for you on the Gravity application (“Personal
Profile”). Each Personal Profile is assigned a unique personal identification
number and requires that you choose a username and password to access your
Personal Profile on the Gravity application, which helps Paycor to ensure that
only you can access your Personal Profile and Personal Information on the
Gravity application. Because you assist Paycor in developing your Personal
Profile username and password, you have a significant role in protecting your
Personal Profile and Personal Information. No one can access or edit your
Personal Profile without knowing your Personal Profile username and password, so
do not share these with others.

Personal Choices

Paycor acknowledges an individual’s right to access their Personal Information.
If you want to review or update your Personal Information, you may do so on the
Gravity application by visiting your Personal Profile. Note that if you are a
candidate (and not a user of the Gravity application) who would like to access
your Personal Information, you will need to request this information from your
Employer.

Social Network Profiles

When you post a job opening on the Gravity application, Paycor will request your
permission to access your social networks including, without limitation,
Facebook, Twitter, and LinkedIn so that you can share such job openings with
your social network connections. Paycor will not post any job openings or other
content on your social networks, or amend any of your posted job openings or
content without your authorization. The Gravity application will also not track
any of your social network activity, other than when you specifically use the
Gravity application to share job openings on your social networks. All use of
your Personal Information by any social network service provider is subject to
each network’s posted terms of service and privacy policy.

Vouching Content

Paycor may ask you to vouch for people that have applied to job openings you
have shared on the Gravity application. Your Employer will be responsible for
determining who is allowed to view your responses to such vouching requests.

Sharing Of Information – Gravity

In addition to the circumstances articulated previously in this Privacy Policy
above, with regard to the Gravity application, Paycor may also disclose your
Personal Information with:

 * Your Employer, solely in regards to the existence of your Gravity application
   account, information on job openings you share using the Gravity application,
   your Gravity application account point totals, and vouching recommendations
   (pursuant to the Vouching Content section); and
 * Any other parties to whom you permit disclosure, including, without
   limitation, social network websites.

Security – Gravity

The security of your Personal Information is important to Paycor. With the
exception of Personal Profile login information stored by Akamai, as detailed
under the Assigning Cookies section above, your Personal Information may be
stored locally on your device and may be transmitted to servers owned, leased or
utilized by Paycor in the United States.


UPDATES TO THIS PRIVACY POLICY

It may be appropriate to update our Privacy Policy and other terms and
conditions from time to time. We reserve the right to update this Privacy Policy
at any time in our sole discretion, with or without advance notice, unless
otherwise required by law or the Privacy Shield Principles. We will post any
changes on the Privacy Policy page of the Website so you are always aware of any
change. We encourage you to periodically review this Privacy Policy to stay
informed about how we are helping to protect the Personal Information we receive
from you.


GENERAL CONTACT INFORMATION

If you have any questions about this privacy statement, the practices of this
Website, or your dealings with this Website, you can contact our Data Protection
Officer and privacy team through the following methods.

Send mail to:
Attn: Privacy Request
Paycor
4811 Montgomery Road
Cincinnati, OH 45212
Call 800.381.0053

Email

If you are a Paycor client, contact your Paycor Specialist

Paycor Biometric Information Policy

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