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PRIVACY POLICY


LAST UPDATED: JULY 12, 2023

PowerToFly Inc. (“PowerToFly”) values your privacy. This Privacy Policy
describes the types of personal data we obtain through our website at
www.powertofly.com (the “Site”) and in connection with our related events and
services, how we use the personal data we obtain and to whom we may disclose it.
We will refer to our Site and related events and services together as the
“Services.”

Our Services are available to prospective employers (each an “Employer”) and to
talent who may be seeking employment, who may be of interest to Employers or who
register for or participate in our events and other Services (each a
“Candidate”).

This policy applies to the data collected from and about Candidates, data
collected from Employers’ representatives who use the Services, and other data
collected from our Website, including visitors who browse the Website and/or
submit data via the Website.

This policy does not apply to data that we collect from our own workforce
members. This policy also does not apply to data we handle solely in our
capacity as a service provider on behalf of a customer (“Service Provider
data”). Depending on the service, Service Provider data includes like data
provided to us by an Employer about their current employees. Service Provider
data is subject to the privacy policies of the customer, and you should read
those policies carefully. We are not responsible for the privacy practices of
our customers. If you have any questions about a customer’s privacy practices,
please contact the customer.


1. COLLECTION OF PERSONAL DATA

Depending on what areas of the Services you use, we obtain different types of
personal data from or about you. We may also collect personal data about
non-users.

Data You Provide to Us

You may provide the following types of personal data to us, including when you
register to use the Services as an Employer or Candidate or otherwise interact
with the Services (e.g., contact us through the Site or attend our events):

1.1 Identifiers, such as your name, phone number, email address, IP address, or
other similar identifiers.

1.2 Account log in and password to access your account on the Services.

1.3 Professional or employment-related data, such as your work history, job
title, and educational background, skills.

1.4 Other identifying and biographical data, including protected classification
characteristics, such as such as age, race or ethnic data, ancestry, national
origin, citizenship, sex, gender, gender identity, and sexual orientation.

1.5 Commercial data, such as data about your transactions related to the
Services and details about your communications and dealings with us.

1.6 Payment data, such as card number, expiration date, authorization number or
security code, billing data, bank account number, and routing number. We use a
third party, Stripe, to process payments made through payment cards on the Site.
Stripe’s use of your personal data is governed by their privacy policy, which is
available at https://stripe.com/us/privacy.

1.7 Internet or other electronic network activity data as described in more
detail below under “data We Collect Automatically.”

1.8 Audio and video data, such as recordings of certain calls and PowerToFly
events.

1.9 Geolocation data, such as general geolocation inferred from your IP address.

1.10 Other data you may provide us when interacting with the Services including
data you upload when creating an account on the Services. .

1.11 Inferences drawn from any of the above.


Data We Collect Automatically

When you visit or use the Site, we and our service providers may automatically
collect certain internet or other electronic network activity data from your
browser or mobile device, including through cookies, log files and other
technologies, which may qualify as personal data such as IP address, device
identifiers, certain data in cookies, and certain details about pages you visit
on our Site, and links you click on the Site.

A cookie is a small amount of data (often including a unique identifier), that
is sent to your browser from a website’s computers and stored on your device. We
may use cookies to improve your experience with the Site, by, for example,
allowing the Site to keep you logged in. We may also use cookies to collect
aggregate data about Site users. The data collected for these purposes
(including your IP address, browser or device data and other data collected by
automated means) may be disclosed to or collected directly by our third-party
web analytics service providers, such as Google Analytics. To learn more about
opting out of certain Google activities, click here:
http://tools.google.com/dlpage/gaoptout. If you don’t want cookies, most web
browsers include an option that allows you to not accept them. However, if you
set your browser to refuse cookies, some portions of our Site may not function
efficiently. We do not currently respond to web browser “do not track” signals
on this Site.

Data We Collect from Social Media Platforms

When you “like” or “follow” us or interact with us on Facebook, Instagram,
Twitter, or other social media sites, we may collect some data from you,
including your name, e-mail address, account handle, and any comments or content
you post relevant to us, depending on your settings on those platforms. We also
collect your data if you sign up through a social media account, such as your
name, photo, job data and email address associated with that account.

Data Collected from Other Third Parties

We may also obtain different types of personal data about you from third
parties, such as employers, data enhancers, data aggregators, and data brokers.
This data may include any of the data described above, including identifiers
(e.g., name, email, and phone number), certain protected classification
characteristics (e.g., gender, sex, and age), race and ethnic origin,
professional or employment-related data, and inferences drawn from other
personal data. This data may be combined with the categories of data listed
above.


2. USE OF PERSONAL DATA

We use the personal data we obtain for a number of purposes, including, but not
limited to:

 * provide the Services, including creating and managing your PowerToFly Site
   account and connecting you with a potential Employer
 * send you transactional communications (such as account confirmations and
   notifications) or promotional and marketing communications
 * respond to your inquiries or requests
 * communicate about, and administer your participation in, special events,
   programs, surveys, contests, sweepstakes, and other offers or promotions
 * handle billing
 * enable you to post on our blog and interact with PowerToFly through social
   media
 * improve our Services, and generate and analyze statistics about your use of
   the Services
 * support our business operations and perform accounting, auditing and other
   internal functions
 * detect, prevent and respond to fraud, intellectual property infringement,
   violations of law or our terms of use and policies, or other misuse of the
   Services, and
 * comply with and enforce applicable legal requirements, contractual
   obligations and our policies.

We also may aggregate or otherwise de-identify the personal data we collect
through the Site and in connection with our Services (the “Aggregated Data”) and
use it for any and all purposes. We also may augment such Aggregated Data with
data we obtain from other sources and use it for any purposes.

Interest-Based Advertising

On our Site, we and third parties may collect data about your online activities
to provide you with advertising about services or products tailored to your
interests. You may see certain ads on other websites because we or such third
parties participate in advertising networks. Ad networks track your online
activities over time by collecting data through automated means, including
through the use of cookies, web server logs and web beacons. The data ad
networks may collect includes data about your visits to websites that
participate in the relevant advertising networks, such as the pages or
advertisements you view and the actions you take on the websites. This data
collection takes place both on our Site and on third-party websites or apps that
participate in the ad networks. This process allows us and third parties to
deliver more tailored advertising. In addition, it helps us track the
effectiveness of our marketing efforts.




3. DISCLOSURE OF PERSONAL DATA

We disclose personal data about you:

 * if you are a Candidate, to Employers who may have job opportunities available
   or interest in placing job candidates, or to other Candidates who use the
   Services
 * with vendors and service providers, including our cloud storage provider,
   payment processor or chat software provider
 * where we deem disclosure appropriate to address a legal matter, such as to
   comply with a binding subpoena or other valid legal process, or to comply
   with government reporting obligations
 * when we believe in good faith that disclosure is necessary or appropriate (a)
   to protect our rights, the integrity of the Site or our services, or your
   safety or the safety of others, or (b) to detect, prevent, or respond to
   fraud, intellectual property infringement, violations of law or our terms of
   use and policies, or other misuse of the Services
 * in connection with the negotiation or completion of a merger, acquisition, or
   sale of all or a portion of our assets (including in the event of a
   reorganization, dissolution or liquidation)
 * with your consent or at your direction
 * as otherwise permitted or required by law

If it is necessary to transfer your Personal Data from your place of residence
to countries that do not offer adequate protections, then we will ensure that
appropriate safeguards as required by applicable laws are put in place prior to
the transfer of the data, such as by incorporating standard contractual clauses.
You can contact us to exercise any right you may have to review such clauses, or
you can find more data about such clauses here.

In addition, we may share Aggregated Data with third parties for any and all
purposes.




4. LEGAL BASIS FOR PROCESSING BUSINESS DATA

The laws in some jurisdictions require companies to tell you about the legal
grounds they rely on to use or disclose your personal data. To the extent those
laws apply, our legal grounds are as follows:

 * To honor our contractual commitments to you: Much of our processing of
   personal data is to meet our contractual obligations to Candidates or other
   individuals, or to take steps at their request in anticipation of entering
   into a contract with them.
 * Consent: Where required by law, and in some other cases, we handle personal
   data on the basis of consent.
 * Legitimate interests: In many cases, we handle personal data on the ground
   that it furthers our legitimate interests (or those of our customers) in
   commercial activities such as the following in ways that are not overridden
   by the interests or fundamental rights and freedoms of the affected
   individuals:
   * Facilitating useful connections between Employers and Candidates, and
     engaging in other recruiting and HR activities for Employers
   * Providing customer service
   * Engaging in marketing
   * Protecting our customers, personnel and property
   * Analyzing and improving our business
   * Managing legal issues
 * Legal compliance: We need to use and disclose personal data in certain ways
   to comply with our legal obligations.




5. SOCIAL MEDIA

The Site includes social media functions, such as Facebook and LinkedIn Sign In
features, and widgets. These functions and widgets may collect data about you,
including the IP address of the device you use to connect to the Internet. Your
interactions with the social media platforms, including any functions and
widgets they provide, are governed by the privacy policies of the relevant
social media companies. We suggest that you review their privacy policies. We
are not responsible for any acts or omissions by any social media site or other
third-party service that you choose to use in connection with this Site or our
services.




6. LINKS TO OTHER WEBSITES, APPS OR SERVICES

This Site may contain links to other websites, apps or other online services for
your convenience and data. These websites, apps and services may be operated by
companies not affiliated with PowerToFly. Linked websites, apps or services may
have their own privacy policies or notices, which we strongly suggest you
review. We are not responsible for the content and data handling practices of
any third party websites, apps or services.




7. YOUR RIGHTS AND CHOICES

You can change your Candidate profile data at any time by editing your profile
or the content that you have posted. You can unsubscribe from marketing emails
by clicking the “unsubscribe” link they contain. Controls related to cookies and
other automated data collection are described in the Use of Personal data
section above.

Residents of the United Kingdom, European Economic Area, and jurisdictions with
similar laws have certain legal rights to obtain confirmation of whether we hold
personal data about them, to access personal data we hold about them, and to
obtain its correction, update, amendment, or deletion in appropriate
circumstances. In limited cases, they have the right to receive data we hold
about them in portable form and to have it transmitted to a third party. They
also have rights to object to our handling of their personal data, to restrict
its processing, and to withdraw any consent they have provided. For example,
individuals in the United Kingdom and European Economic Area have a right to opt
out of our processing of personal data for direct marketing purposes. If you are
a California resident, your rights are described in Section 10 below.

To exercise your rights, or to have your account deleted, please contact us as
described at the end of this Privacy Policy.

Many of the rights described above are subject to significant limitations and
exceptions under the applicable law. For example, objections to the processing
of personal data, and withdrawals of consent, typically will not have
retroactive effect. Individuals also have a right to lodge a complaint with the
relevant supervisory authority, but we encourage you to contact us first, and we
will do our best to resolve any concern.




8. SECURITY OF YOUR PERSONAL DATA

We maintain administrative, technical, and physical safeguards in an effort to
protect the personal data collected through this Site. But, no method of data
transmission over the Internet or data storage is 100% secure and, we cannot
guarantee the absolute security of any data.




9. RETENTION OF PERSONAL DATA

We will retain your data for the period necessary to fulfill the purposes
outlined in this Privacy Policy unless a longer retention period is required or
permitted by law. data may persist in copies made for backup and business
continuity purposes for longer than the original copy of the data.




10. PRIVACY DETAILS FOR CALIFORNIA RESIDENTS


This notice to California Residents pursuant to the California Consumer Privacy
Act (“CCPA”)supplements the data contained in the rest of our Privacy Policy.
Data about individuals who are not residents of California may be handled
differently and is not subject to the same California rights described below.
Any terms defined in the CCPA have the same meaning when used in this notice.

Data We Collect and Categories of Entities to Which the data was Disclosed

The following chart provides data about our practices in the 12 months leading
up to the effective date of this Policy in relation to the categories of
personal data that we collected from California residents generally and the
categories of third parties to whom we disclosed the data for business purposes:




Categories of Personal data

Category(ies) of entities to which the personal data was disclosed

Identifiers, such as your name, phone number, email address, IP address, or
other similar identifiers.

 * Our clients (e.g., employers)
 * Vendors and service providers (which include non affiliated entities
   providing operating systems, platforms and other services to support
   day-to-day operations)
 * Advertising networks and analytics providers

Account log in and password to access your account on the Services.

Protected classification characteristics under California or Federal law, such
as age, race, ancestry, national origin, sex (including gender and gender
identity), and sexual orientation.

 * Our clients (e.g., employers)
 * Vendors and service providers (which include non affiliated entities
   providing operating systems, platforms and other services to support
   day-to-day operations)

Race or ethnic data of Candidates.

 * Our clients (e.g., employers)
 * Vendors and service providers (which include non affiliated entities
   providing operating systems, platforms and other services to support
   day-to-day operations)

Sexual orientation of Candidates.

 * Our clients (e.g., employers)
 * Vendors and service providers (which include non affiliated entities
   providing operating systems, platforms and other services to support
   day-to-day operations)

Commercial data, such as records of products with or services purchased,
obtained, or considered from us.

 * Vendors and service providers (which include non affiliated entities
   providing operating systems, platforms and other services to support
   day-to-day operations)

Internet or similar network activity, such as browsing history, search history,
data on interaction with our website, emails, and/or advertisements.

 * Our clients (e.g., employers)
 * Vendors and service providers (which include non affiliated entities
   providing operating systems, platforms and other services to support
   day-to-day operations)
 * Advertising networks and analytics providers

Geolocation Data, such general geolocation inferred from an IP address.

 * Our clients (e.g., employers)
 * Vendors and service providers (which include non affiliated entities
   providing operating systems, platforms and other services to support
   day-to-day operations)
 * Advertising networks and analytics providers

Sensory Data, such as audio and video recordings.

 * Our clients (e.g., employers)
 * Vendors and service providers (which include non affiliated entities
   providing operating systems, platforms and other services to support
   day-to-day operations)

Professional or employment-related data, such as content of resumes, CVs, and
job applications.

 * Our clients (e.g., employers)
 * Vendors and service providers (which include non affiliated entities
   providing operating systems, platforms and other services to support
   day-to-day operations)
 * Advertising networks

Inferences drawn from other personal data, such as your preferences,
characteristics and behavior.

 * Our clients (e.g., employers)
 * Vendors and service providers (which include non affiliated entities
   providing operating systems, platforms and other services to support
   day-to-day operations)
 * Advertising networks and analytics providers

Other data.

Disclosure will depend on the nature of the data provided, but may include:

 * Our clients (e.g., employers)
 * Vendors and service providers (which include non affiliated entities
   providing operating systems, platforms and other services to support
   day-to-day operations)
 * Advertising networks and analytics providers

Please note that we use the “sensitive personal data” listed above (username and
password; race or ethnic origin; and sexual orientation) for purposes permitted
by the CCPA, including to perform the services reasonably expected by you. As
part of our services, we provide Employers with data about potential Candidates
that may interest them, including both when a Candidate submits job applications
through us and when we provide Employers with details about other potential
Candidates to consider recruiting. In this latter case, we may disclose not only
contact data and professional data, but also details that may be of interest to
Employers seeking to ensure a diverse applicant pool, such as Candidate’s race
or ethnic origin. Under the CCPA, Candidates have the right to opt out of our
disclosure of all of that data, and they can do so by using our Your Privacy
Choices form or following the other instructions below.

Sale and Sharing of Personal data

As explained in the “Use of Personal data” section above, we provide personal
data to third-party advertising providers for targeted advertising purposes, so
that we can provide you with more relevant and tailored ads regarding our
services, and use analytics partners to assist us in analyzing use of our
services and our user/customer base. The disclosure of your personal data to
some of these third parties to assist us in providing these services may be
considered a “sale” of personal data under the CCPA, or, the “sharing” of your
personal data for purposes of “cross-context behavioral advertising.”

Additionally, we disclose certain personal data of Candidates to Employers to
assist in their recruitment efforts. We do this at the direction of the
Candidates, such as when a Candidate submits a job application to an Employer
through our service. We also do it independently, such as when an Employer hires
us to find potential Candidates for them, and we provide the Employer with data
about potential Candidates whom the Employer may want to contact, including some
that have not used our service to connect with the Employer, and in this latter
case, our disclosure of this data may be considered a “sale” of personal data
under the CCPA.

The following chart lists the categories of personal data we have sold or shared
over the last 12 months and the categories of third parties to which we have
sold or shared:

Category of Personal data

Categories of Third Parties to Which We Have “Sold” this PI

Categories of Third Parties to Which We Have “Shared” this PI

Identifiers

 * Advertising partners and advertisers
 * Analytics providers
 * Employers

 * Advertising partners and advertisers

Internet network and device activity data

 * Advertising partners and advertisers
 * Analytics providers
 * Employers

 * Advertising partners and advertisers

Protected classification characteristics under California or Federal law,
including age, race, ancestry, national origin, sex (including gender and gender
identity), and sexual orientation

 * Employers

None

Race or ethnic origin

 * Employers

None

Sexual orientation

 * Employers

None

Professional or employment related data

 * Employers

None

Inferences

 * Employers

None

Please note that we do not “sell” or “share” personal data (as those terms are
defined under the CCPA) if we have actual knowledge that the consumer is less
than 16 years of age.

To learn more about how to exercise your right under the CCPA to opt out of the
sale and sharing of your personal data, please review the “Your CCPA Rights And
Choices” section below.

Your CCPA Rights And Choices

If you are a California resident, California law may permit you to request that
we:

 * Inform you about the categories of personal data we have collected about you
   in the past 12 months; the categories of sources of such data; the business
   or commercial purpose for collecting or selling your personal data; and the
   categories of third parties to whom we disclose personal data, and more
   specific data about what categories of personal data were “sold,” “shared,”
   or disclosed to particular categories of third parties, similar to the detail
   in the sections of this Privacy Policy above.

 * Provide access to and/or a copy of certain personal data we hold about you.
 * Delete certain personal data we have about you.
 * Correct certain personal data we have about you.
 * Limit the use and disclosure of certain sensitive personal data we have about
   you.

Certain data is exempt from such requests under applicable law. You also may
have the right to receive certain data about certain kinds of financial
incentives that we offer to you (if any). You also have certain rights under the
CCPA not to be subject to certain negative consequences for exercising CCPA
rights.

If you would like to exercise any of the rights described above, you may do so
directly through the following means:

Completing this form.
or
Emailing us at privacy@powertofly.com

The best way to exercise your CCPA right to opt out of what the CCPA calls
“sales” or “sharing” of personal data, or to limit our use of your sensitive
personal data, is to follow the instructions, but you also could start the
process by contacting us through the other ways listed above. Your browser may
also offer a way to activate the Global Privacy Control signal (“GPC”). Our
websites each treat a qualifying browser for which the user has activated the
GPC signal as having opted out of what CCPA calls a “sale” of any California
personal data that is collected on that site from that browser using cookies and
similar technology.

We may take reasonable steps to verify your identity before responding to your
request, which may include, depending on the sensitivity of the data involved,
the nature of our relationship with you, and the type of request you are making,
verifying your name, email address, and other data regarding your use of our
Services. For security and legal reasons, PowerToFly will not normally accept
requests that require us to access third-party websites or services.

If you are an agent making a request on behalf of a consumer, we reserve the
right to take steps to verify that you are authorized to make that request,
which may include requiring you to provide us with written proof such as a
notarized authentication letter or a power of attorney. We also may require the
consumer to verify their identity directly with us. We are not responsible for
the security risks of this or any other arrangements that a consumer may have
with an agent. For clarity, this is not permission for any user to share their
login credentials with an agent or any third party. Such sharing is prohibited.

How Long Do We Retain Your Personal Data

We plan to retain your personal data until we determine it is no longer
necessary to fulfill the purposes for which it was collected, or longer if
required to fulfill our legal and contractual obligations.


11. NON-U.S. VISITORS AND USERS

We are based in the United States, and recipients of the data disclosures
described in this Privacy Policy are located in the United States and elsewhere
in the world, including where privacy laws may not provide as much protection as
the laws of the country in which you are located.


12. AGE RESTRICTIONS

The Services are not intended for individuals under the age of 16. We do not
knowingly collect personal data from individuals under 16, and no part of the
Services are designed to attract anyone under the age of 16. If you become aware
that your child has provided us with personal data, please contact us as
indicated below.


13. CHANGES TO OUR PRIVACY POLICY

We may revise our Privacy Policy from time to time. The most current version of
the Privacy Policy will govern our use of your personal data and will be located
on this webpage. If we make a change to our Privacy Policy that is material, we
will notify you by posting a prominent notice on this Site. We also may notify
you by email of such significant changes. By continuing to access the Site or
otherwise use our Services after those changes become effective, you agree to
the revised Privacy Policy.


14. CONTACT US

If you have any questions about this Privacy Policy or any of our data handling
practices, please contact us directly at privacy@powertofly.com or by mail to
228 Park Avenue South, Suite 75391, New York, NY 10003, USA.




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