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PRIVACY POLICY

Paycor Gravity Recruiting Scheduling Performance Smart Sourcing Paths


PAYCOR

UPDATED: July, 18, 2023

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. This policy will 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., its product lines, and its affiliated companies:
Nimble Software Systems, Inc. (Paycor Scheduling), Paltech Solutions, Inc.
(Paycor Performance), Talenya Ltd. Inc. (Paycor Smart Sourcing), Paycor Paths,
Paycor Gravity, and Paycor Recruiting, (collectively 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 product lines and services we offer, including, but not limited to,
applications hosted on paycor.com, app.ximble.com, app.7geese.com,
recruitingbypaycor.com, newtonsoftware.com, gravityapp.com and all mobile
applications released by us through the Apple App Store or the Google Play Store
(collectively “Website” or “Websites”).


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, or a third party acting on your behalf and under your direction, 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 utilize a third party to access your account (Pinwheel)
 6. you sign up to receive alerts or notifications
 7. you make a purchase, and
 8. 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
 * Social networking information (if we are provided with access to your account
   on social network connection services)
 * Correspondence or communication sent via the Website
 * Preferred language and country information
 * Username
 * 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.
 * 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 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

Cookies.
Please visit the Cookie Policy for information on Paycor’s cookie and automated
information collection practices.

Live Chat. 
We partner with a trusted third-party vendor to provide you with live chat
features to better assist you. When using the live chat features, please only
provide necessary information and do not provide sensitive information. For
recordkeeping, training, and quality assurance purposes, we or our third-party
vendor may record and maintain a transcript of any communications in the live
chat.

Recording Use of the Website.
We partner with trusted third-party vendors to analyze the performance and
traffic of our Website. This may include things like buttons you click, mouse
movements, other behavior on the Website, date and time of access, pages
visited, web beacons, and cookie or pixel tag information. Please review the
entirety of our Cookies and Other Automatic Information Collection section to
learn more about cookies, pixels tags, and analytic technologies.


SHARING OF INFORMATION

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

 * With a potential 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.
 * 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.
 * Working with companies that we own or control, that are owned or controlled
   by Paycor, or that are under common ownership or control including, but not
   limited to, Nimble Software Systems, Inc. (Paycor Scheduling), Paltech
   Solutions, Inc. dba 7Geese (Paycor Performance), and Talenya Ltd. Inc.
   (Paycor Smart Sourcing). Data collected by these entities is subject to this
   Privacy Policy.

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.


DATA PRIVACY FRAMEWORK

Paycor, Inc. and Nimble Software Systems, Inc. (collectively “Registrant”)
complies with the EU-U.S. Data Privacy Framework, the UK Extension to the
EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy 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 the
Data Privacy Framework. Registrant has certified that it adheres to the Data
Privacy Framework Principles with respect to such data. If there is any conflict
between the policies in this privacy policy and data subject rights under the
Data Privacy Framework Principles, the Data Privacy Framework Principles shall
govern. To learn more about the Data Privacy Framework program, and to view our
certification page, please visit https://www.dataprivacyframework.gov/s/ 

Registrant 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.

Registrant is EU-U.S. and Swiss-U.S. Data Privacy Framework certified.
Nonetheless, Registrant does not rely on such certifications in the absence of
the authority to do so.


DATA PRIVACY FRAMEWORK PRINCIPLES

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

Registrant affirms the following in compliance with the Data Privacy Framework
Principles:

 * Registrant 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 Data Privacy Framework have the right to
   access their data and to correct, amend or erase data that is incorrect or
   has not been processed in accordance with the Data Privacy Framework
   principles.
 * For Personal Information that Registrant processes as a controller,
   individuals wishing to exercise this right may do so by utilizing
   Registrant’s Access Request Portal or as otherwise disclosed in this Policy.
 * If your Personal Information has been provided to the Registrant 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.
 * Registrant may be required to release personal data in response to lawful
   requests by public authorities, including to meet national security and law
   enforcement requirements.
 * Registrant’s accountability for personal data that it receives in the United
   States under the Data Privacy Framework and subsequently transfers to a third
   party is described in the Data Privacy Framework Principles. In particular,
   Registrant remains responsible and liable under the Data Privacy Framework
   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
   Registrant proves that it is not responsible for the event giving rise to the
   damage.
 * Registrant 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,
   Registrant will update this policy accordingly and provide individuals with
   appropriate opt-in or opt-out choice prior to releasing that information.
 * Registrant 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
   Registrant’s Access Request Portal or emailing the Privacy Team in the
   contact below.


INQUIRIES

In compliance with the Data Privacy Framework Principles, Registrant 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 Registrant
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.

Registrant has further committed to refer unresolved privacy complaints under
the Data Privacy Framework Principles to an independent dispute resolution
mechanism, the BBB EU DATA PRIVACY FRAMEWORK. 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/programs/all-programs/dpf-consumers/ProcessForConsumers
for more information and to file a complaint. This service is provided free of
charge to you.

If your Data Privacy Framework 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 Data Privacy
Framework Annex 1 at
https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2


ARTIFICIAL INTELLIGENCE & AUTOMATED DECISION-MAKING

Paycor Services may utilize Artificial Intelligence (AI) for the synthesis of
data to assist our customers by providing insights for their consideration. In
no case does Paycor use this information for automated decision-making or
profiling. Employers, as the data controller, are responsible for any prior or
subsequent use of data provided to Paycor directly, or through Services.
Employers should provide notice to, collect consent from, and provide recourse
mechanisms to individuals if required and appropriate. Furthermore, Paycor does
not guarantee the accuracy of data produced via AI and encourages its clients to
validate any information they receive.


NOTICE FOR RESIDENTS OF CALIFORNIA

If you are a California resident who is not a Paycor Applicant, Employee, or
Independent Contractor, click here for more information.

If you are a Paycor Applicant, Employee, Independent Contract, or Paycor
Business Contact who resides in California, click here for more information.


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 multi-factor
authentication. Depending on the situation, 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 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.


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
in our sole discretion at any time, with or without advance notice, unless
otherwise required by law or the Data Privacy Framework 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.

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


PAYCOR GRAVITY

EFFECTIVE DATE: July 18, 2023

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

In addition to the provisions outlined in the Paycor Privacy Policy, the
following information below applies to the use of Paycor Gravity.


COLLECTION OF PERSONAL INFORMATION

Personal Information collected may include:

 * Job openings that you share via the Gravity application
 * Any further personal data contained in any files that you share via the
   Gravity application


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

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 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.


PAYCOR RECRUITING

The Recruiting application is used by companies to post job openings, collect
potential job applicant information and track applicants through the hiring
process.

In addition to the provisions outlined in the Paycor Privacy Policy, the
following information below applies to the use of Paycor Recruiting.


USERS

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

Users 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 the
purchase of goods or services from Paycor or its affiliates. If users provide a
mobile device number and opt into such text messaging as provided below, they
hereby consent to the Paycor’s use of the mobile device number in accordance
with this Privacy Policy and any applicable terms of use until such consent is
withdrawn. Users 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.


PAYCOR SCHEDULING

EFFECTIVE DATE: July 18, 2023

Paycor Scheduling brings together all of Ximble’s most powerful features along
with Paycor’s familiar design and usability to bring flexibility to the staff
scheduling process.

In addition to the provisions outlined in the Paycor Privacy Policy, the
following information below applies to the use of Paycor Scheduling.


SHARING OF INFORMATION

We may share Personal information with third parties pursuant to the use of
Paycor Scheduling under any of the following:

 * With other users of Paycor Scheduling’s Website, Mobile App, or other
   products and services under the same underlying subscription or free trial as
   you (“Other Users”). As a result of your use of the Website or other products
   or services of Paycor Scheduling, Other Users will have access to information
   you provide to Paycor Scheduling (including, without limitation, matters
   regarding your work schedule) and may send you messages via email or through
   the Mobile App. You hereby consent to such disclosure of information to Other
   Users, and Paycor Scheduling shall have no responsibility for any
   communications from Other Users.


PROFILE INFORMATION

We store information that we collect through cookies, log files and clear gifs
to create a profile of our users. A profile is stored information that we keep
on individual users that details their viewing preferences. Consequently,
collected information is tied to the user’s personally identifiable information
to provide offers and improve the content of the Website for the user. This
profile is used to tailor a user’s visit to our Website, and to direct pertinent
marketing promotions to them. We do not share your profile with other third
parties, subject to the exceptions set forth in Paycor’s Privacy
Policy regarding sharing of your personal information in certain circumstances.


PAYCOR PERFORMANCE

EFFECTIVE DATE: July 18, 2023

Paycor Performance modernizes the entire performance review process. With
automated workflows, prompts, tasks, and notifications, remove the manual burden
on HR leaders, managers and employees by allowing teams to easily see upcoming
activities and ensure all priorities are being met. 

In addition to the provisions outlined in the Paycor Privacy Policy, the
following information below applies to the use of Paycor Performance.


INTERNATIONAL TRANSFER OF INFORMATION COLLECTED

7Geese operates out of Canada and stores information with service providers
located in the United States. Your Personal Information may be maintained and
processed by us, our affiliates and other third-party service providers in
Canada, the United States or other jurisdictions where our service providers are
located.

We take measures to ensure that any Personal Information transfers comply with
all applicable data protection laws and that your Personal Information remains
protected to the standards described in this Privacy Policy. In the event that
Personal Information is transferred to the US or other foreign jurisdiction, it
will be subject to the laws of that jurisdiction and may be disclosed to or
accessed by the courts, law enforcement and governmental authorities in
accordance with those laws.


PAYCOR SMART SOURCING

EFFECTIVE DATE: July 18, 2023

Paycor Smart Sourcing’s AI-powered, talent-sourcing bots (“Bots”) collect and
use data from various online sources to rapidly identify the right talent for
each job and to reach out to that talent – sometimes before they may even start
searching for their next job.

In addition to the provisions outlined in the Paycor Privacy Policy, the
following information below applies to the use of Paycor Smart Sourcing.


COLLECTION AND USE OF PERSONAL INFORMATION

Paycor Smart Sourcing may collect Personal Information from you or about you:

 * When you uploaded Personal Information to publicly available websites and
   social media platforms
 * From third parties in order to obtain contact information for candidate leads

Personal Information collected may include:

 * Race, ethnicity, religion, health, and sexual orientation (anonymized) if
   provided through the use of services


HOW WE PROCESS AN INDIVIDUAL’S PERSONAL DATA

Following collection of personal data, our system creates a candidate profile
for each individual whose personal data has been collected. The process involves
merging the personal data collected from various different sources and, where
there are any discrepancies, uploading the most recent available.

Our system also uses certain predictive algorithms to fill in blanks in
individual profiles, such as where the personal data collected does not include
a particular skill or experience which might normally be included. In situations
such as these, our system in conjunction with information collected by our Bots,
predicts whether a person is likely to have a certain skill and adds it to their
profile..  Before providing the profiles to the customer, the Bots search
through the original sources of the personal data collected to determine if any
information needs to be updated. Once all relevant data has been updated, the
profiles are pseudonymized and provided to the customer. This process may be
repeated until the customer selects the individuals they wish to engage or
interview; all throughout the customer’s search the profiles remain
pseudonymized.

For individuals located within the US, we will provide contact information if we
are able to obtain it. For individuals based in the EU and Israel, we will
contact them to, notify: that we hold their personal data, how and why we hold
and process that personal data, and that they have been selected by a customer
for direct contact in connection with a potential job opportunity. For
Individuals based in Israel and the EU, we will not provide the customer with
the contact and other identifying details until we have obtained their consent.


PAYCOR PATHS

Paycor Paths is used by individuals and Employers to deliver personalized and
effective employee learning experiences. Through Paycor Paths, companies can
offer a safe place to explore authentic and honest thoughts, emotions, and
ideas.

In addition to the provisions outlined in the Paycor Privacy Policy, the
following information below applies to the use of Paycor Paths.


SHARING OF INFORMATION

We may share Personal information with third parties pursuant to the use of
Paycor Paths under any of the following:

 * With your colleagues or group members if you are participating in activities
   hosted by Paycor Paths

 * With competition sponsors, pursuant to a contest, who may use your
   information in accordance with the competition rules and its own privacy
   policy, which might differ from this Policy.
 * Upon Your direction via applications which allow you to share your content
   and work product with designees.


USE OF INFORMATION

In addition to the circumstances listed in the Paycor Privacy Policy, Paycor
Paths may use your information for the following purposes:

Social Network Profiles

 * If you choose ton log into our site or Services via social networks, Paycor
   Paths will request your permission to access your networks, without
   limitation, Facebook, Twitter, and LinkedIn.

Site Improvement and Personalization

 * To tailor the content and information that we may send or display to you, to
   offer location customization, and personalized help and instructions, and to
   otherwise personalize your experiences while using the Sites or our services.
 * For other research and analytical purposes, such as to examine trends in
   participation, success in campaigns and/or competition, as well as overall
   web usage.
 * If you are an authorized user under an enterprise license, to track your
   progress through professional development, mentoring, and engagement
   activities and share such information with your employer and/or enterprise
   sponsor.

User Generated Content

 * You may post content on certain of our Sites to our forums and blogs,
   including your comments, pictures, and any other information that you would
   like to be available on our Sites. If you post content to our Sites, all the
   information that you post will be available to all visitors to our Sites. If
   you post your own content on our Site or Services, your posting may become
   public.

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When you visit any website, it may store or retrieve information on your
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give you a more personalized web experience. Because we respect your right to
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However, blocking some types of cookies may impact your experience of the site
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relevant adverts on other sites.    They do not store directly personal
information, but are based on uniquely identifying your browser and internet
device. If you do not allow these cookies, you will experience less targeted
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These cookies allow us to count visits and traffic sources so we can measure and
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information on how Google Analytics supports the Site and uses information sent
from the Site, please review Google’s privacy policy available at
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These cookies do not store any personally identifiable information. Cookies
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