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Text Content

Please note: This website includes an accessibility system. Press Control-F11 to
adjust the website to the visually impaired who are using a screen reader; Press
Control-F10 to open an accessibility menu.

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Dear user of SmartRecruiters, please take a look at our Privacy Policies
section. This Privacy Policy applies in a general manner to SmartRecruiters
employees, candidates, users and website visitors and is applicable to a
worldwide territorial scope.

Privacy PolicyCookie Policy

SmartRecruiters is protecting your Privacy

SmartRecruiters is committed to protect your privacy. Should we ask you to
provide certain information by which you can be identified when using this
website and our services, then you can be assured that it will only be used in
accordance with this privacy policy.

Data Privacy Framework SmartRecruiters adhesion

SmartRecruiters, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S.
DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy
Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.
SmartRecruiters, Inc. has certified to the U.S.

Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework
Principles (EU-U.S. DPF Principles) with regard to the processing of personal
data received from the European Union in reliance on the EU-U.S. DPF and from
the United Kingdom (and Gibraltar) in reliance on the UK Extension to the
EU-U.S. DPF.

SmartRecruiters, Inc. has certified to the U.S. Department of Commerce that it
adheres to the Swiss-U.S.

Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the
processing of personal data received from Switzerland in reliance on the
Swiss-U.S. DPF.

In compliance with the EU-U.S. DPF and the Swiss-U.S. DPF, SmartRecruiters
commits to cooperate and comply respectively with the advice of the panel
established by the EU data protection authorities (DPAs) and the Swiss Federal
Data Protection and Information Commissioner (FDPIC) with regard to unresolved
complaints concerning our handling of human resources data received in reliance
on the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment
relationship.

If there is any conflict between the terms in this privacy policy and the
EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles
shall govern.

To learn more about the Data Privacy Framework (DPF) program, and to view our
certification, please visit https://www.dataprivacyframework.gov/

Data Privacy Framework compliance

SmartRecruiters comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF),
the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework
(Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.

SmartRecruiters U.S. entities adhering to the DPF principles:

-SmartRecruiters, Inc.

SmartRecruiters has certified to the U.S. Department of Commerce that it adheres
to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with
regard to the processing of personal data received from the European Union in
reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) under
the UK Extension to the EU-U.S. DPF. SmartRecruiters has certified to the U.S.
Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework
Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal
data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is
any conflict between the terms in this privacy policy and the EU-U.S. DPF
Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To
learn more about the Data Privacy Framework (DPF) program, and to view our
certification, please visit https://www.dataprivacyframework.gov/.

SmartRecruiters is responsible for the processing of personal data it receives,
under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF
and subsequently transfers to a third party acting as an agent on its behalf.
SmartRecruiters complies with the EU-U.S. DPF Principles and the Swiss-U.S. DPF
Principles for all onward transfers of personal data from the EU, UK, and
Switzerland, including the onward transfer liability provisions.

SmartRecuiters does not use and disclose personal information for purposes that
are materially different from the purposes for which it was collected. We will
share your Personal Data with third parties only in the ways that are described
in this privacy statement. We will provide individuals with reasonable
mechanisms to exercise their choices.

SmartRecruiters will only collect, use, and disclose information as described in
this privacy policy. We will offer individuals the opportunity to choose
(opt-out) whether their personal information is (a) to be disclosed to a
non-agent third party, or (b) to be used for a purpose other than the purpose
for which it was originally collected or subsequently authorized by the
individual. SmartRecruiters will provide individuals with reasonable mechanisms
to exercise their choices.

The Federal Trade Commission has jurisdiction over SmartRecruiters’s compliance
with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S.
DPF. In certain situations, SmartRecruiters may be required to disclose personal
data in response to lawful requests by public authorities, including to meet
national security or law enforcement requirements.

If there is any conflict between the terms in this privacy policy and the
EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles
shall govern. To learn more about the Data Privacy Framework (DPF) program, and
to view our certification, please visit
https://www.dataprivacyframework.gov/s/participant-search.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the
Swiss-U.S. DPF, SmartRecruiters commits to refer unresolved complaints
concerning our handling of personal data received in reliance on the EU-U.S.
DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to TRUSTe, an
alternative dispute resolution provider based in the United States. If you do
not receive timely acknowledgment of your DPF Principles-related complaint from
us, or if we have not addressed your DPF Principles-related complaint to your
satisfaction, please visit https://feedback-form.truste.com/watchdog/request for
more information or to file a complaint. These dispute resolution services are
provided at no cost to you.

For complaints regarding EU-U.S. DPF, the UK Extension to the EU-U.S DPF, and
Swiss-U.S. DPF compliance not resolved by any of the other DPF mechanisms, you
have the possibility, under certain conditions, to invoke binding arbitration.
Further information can be found on the official DPF website:
https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.

--------------------------------------------------------------------------------

This Application collects some Personal Data from its Users.

OWNER AND DATA CONTROLLER

SmartRecruiters, Inc. 166 Geary St
15th Floor Suite #1612
San Francisco, CA 94108

Owner contact email: dpo@smartrecruiters.com

TYPES OF DATA COLLECTED

Among the types of Personal Data that this Application collects, by itself or
through third parties, there are: Trackers; Usage Data; email address; device
information; purchase history; unique device identifiers for advertising (Google
Advertiser ID or IDFA, for example); various types of Data; Universally unique
identifier (UUID); crash data; Data communicated while using the service.

Complete details on each type of Personal Data collected are provided in the
dedicated sections of this privacy policy or by specific explanation texts
displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data,
collected automatically when using this Application.

Unless specified otherwise, all Data requested by this Application is mandatory
and failure to provide this Data may make it impossible for this Application to
provide its services. In cases where this Application specifically states that
some Data is not mandatory, Users are free not to communicate this Data without
consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to
contact the Owner.

Any use of Cookies – or of other tracking tools — by this Application or by the
owners of third-party services used by this Application serves the purpose of
providing the Service required by the User, in addition to any other purposes
described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or
shared through this Application.

MODE AND PLACE OF PROCESSING THE DATA

METHODS OF PROCESSING

The Owner takes appropriate security measures to prevent unauthorized access,
disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools,
following organizational procedures and modes strictly related to the purposes
indicated. In addition to the Owner, in some cases, the Data may be accessible
to certain types of persons in charge, involved with the operation of this
Application (administration, sales, marketing, legal, system administration) or
external parties (such as third-party technical service providers, mail
carriers, hosting providers, IT companies, communications agencies) appointed,
if necessary, as Data Processors by the Owner. The updated list of these parties
may be requested from the Owner at any time.

PLACE

The Data is processed at the Owner’s operating offices and in any other places
where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the
User’s Data to a country other than their own. To find out more about the place
of processing of such transferred Data, Users can check the section containing
details about the processing of Personal Data.

RETENTION TIME

Unless specified otherwise in this document, Personal Data shall be processed
and stored for as long as required by the purpose they have been collected for
and may be retained for longer due to applicable legal obligation or based on
the Users’ consent.

THE PURPOSES OF PROCESSING

The Data concerning the User is collected to allow the Owner to provide its
Service, comply with its legal obligations, respond to enforcement requests,
protect its rights and interests (or those of its Users or third parties),
detect any malicious or fraudulent activity, as well as the following: Heat
mapping and session recording, Displaying content from external platforms,
Advertising, Traffic optimization and distribution, Remarketing and behavioral
targeting, Managing contacts and sending messages, Analytics, Tag Management,
Infrastructure monitoring, Hosting and backend infrastructure, User database
management, Access to third-party accounts, Collection of privacy-related
preferences, Content performance and features testing (A/B testing), Handling
payments, Data transfer outside the EU and Data transfer outside of the UK.

For specific information about the Personal Data used for each purpose, the User
may refer to the section “Detailed information on the processing of Personal
Data”.

DETAILED INFORMATION ON THE PROCESSING OF PERSONAL DATA

Personal Data is collected for the following purposes and using the following
services:

ACCESS TO THIRD-PARTY ACCOUNTS

This type of service allows this Application to access Data from your account on
a third-party service and perform actions with it.

These services are not activated automatically, but require explicit
authorization by the User.

GITHUB ACCOUNT ACCESS (GITHUB INC.)

This service allows this Application to connect with the User’s account on
GitHub, provided by GitHub Inc. Personal Data processed: device information;
email address; Trackers; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers;
internet or other electronic network activity information.

This processing constitutes:

• a sale according to the CCPA, CPA and CTDPA

MAILCHIMP ACCOUNT ACCESS (INTUIT INC.)

This service allows this Application to connect with the User’s account on
Mailchimp, provided by Intuit Inc. Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet or
other electronic network activity information.

This processing constitutes:

• a sale according to the CCPA, CPA and CTDPA

GOOGLE DRIVE ACCOUNT ACCESS (GOOGLE LLC)

This service allows this Application to connect with the User’s account on
Google Drive, provided by Google LLC.

Personal Data processed: Data communicated while using the service; Usage Data.
Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet or
other electronic network activity information.

This processing constitutes:

• a sale according to the CCPA, CPA and CTDPA

ADVERTISING

This type of service allows User Data to be utilized for advertising
communication purposes. These communications are displayed in the form of
banners and other advertisements on this Application, possibly based on User
interests.

This does not mean that all Personal Data are used for this purpose. Information
and conditions of use are shown below.

Some of the services listed below may use Trackers to identify Users or they may
use the behavioral retargeting technique, i.e. displaying ads tailored to the
User’s interests and behavior, including those detected outside this
Application. For more information, please check the privacy policies of the
relevant services.

Services of this kind usually offer the possibility to opt out of such tracking.
In addition to any opt-out feature offered by any of the services below, Users
may learn more on how to generally opt out of interest-based advertising within
the dedicated section “How to opt-out of interest-based advertising” in this
document.

TABOOLA (TABOOLA INC.)

Taboola is an advertising service provided by Taboola Inc. Personal Data
processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet or
other electronic network activity information.

This processing constitutes:

• a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

• a sharing according to the CCPA

• targeted advertising according to the VCDPA, CPA, CTDPA and UCPA

DEMANDBASE (DEMANDBASE LTD.)

Demandbase is an advertising service provided by Demandbase Ltd. Personal Data
processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy – Opt out.

Category of personal information collected according to the CCPA: internet or
other electronic network activity information.

This processing constitutes:

• a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

• a sharing according to the CCPA

• targeted advertising according to the VCDPA, CPA, CTDPA and UCPA

SALESFORCE (SALESFORCE.COM, INC.)

Salesforce is an advertising service provided by Salesforce.com, Inc. Personal
Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet or
other electronic network activity information.

This processing constitutes:

• a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

• a sharing according to the CCPA

• targeted advertising according to the VCDPA, CPA, CTDPA and UCPA

NEXTROLL (NEXTROLL, INC.)

NextRoll is an advertising service provided by NextRoll, Inc. NextRoll, Inc.
performs a hash of the User’s email address in order to serve targeted
advertising to other devices connected to them (i.e. cross-device

tracking).

Personal Data processed: device information; purchase history; Trackers; unique
device identifiers for advertising (Google Advertiser ID or IDFA, for example);
Usage Data.

Place of processing: United States – Privacy Policy– Opt Out.

Category of personal information collected according to the CCPA: identifiers;
commercial information; internet or other electronic network activity
information.

This processing constitutes:

• a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

• a sharing according to the CCPA

• targeted advertising according to the VCDPA, CPA, CTDPA and UCPA

ANALYTICS

The services contained in this section enable the Owner to monitor and analyze
web traffic and can be used to keep track of User behavior.

META ADS CONVERSION TRACKING (META PIXEL) (META PLATFORMS, INC.)

Meta ads conversion tracking (Meta pixel) is an analytics service provided by
Meta Platforms, Inc. that connects data from the Meta Audience Network with
actions performed on this Application. The Meta pixel tracks conversions that
can be attributed to ads on Facebook, Instagram and Meta Audience Network.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy– Opt out.

Category of personal information collected according to the CCPA: internet or
other electronic network activity information.

This processing constitutes:

• a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

META EVENTS MANAGER (META PLATFORMS, INC.)

Meta Events Manager is an analytics service provided by Meta Platforms, Inc. By
integrating the Meta pixel, Meta Events Manager can give the Owner insights into
the traffic and interactions on this Application.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy– Opt out.

Category of personal information collected according to the CCPA: internet or
other electronic network activity information.

This processing constitutes:

• a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

GOOGLE ANALYTICS 4 (GOOGLE LLC)

Google Analytics 4 is a web analysis service provided by Google LLC (“Google”).
Google utilizes the Data collected to track and examine the use of this
Application, to prepare reports on its activities and share them with other
Google services.

Google may use the Data collected to contextualize and personalize the ads of
its own advertising network. In Google Analytics 4, IP addresses are used at
collection time and then discarded before Data is logged in any data center or
server. Users can learn more by consulting Google’s official documentation.

Personal Data processed: Trackers.

Place of processing: United States – Privacy Policy– Opt Out.

Category of personal information collected according to the CCPA: internet or
other electronic network activity information.

This processing constitutes:

• a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

DEMANDBASE CONVERSION TRACKING (DEMANDBASE LTD.)

Demandbase conversion tracking is an analytics service provided by Demandbase
Ltd. that connects data from the Demandbase advertising network with actions
performed on this Application.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet or
other electronic network activity information.

This processing constitutes:

• a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

COLLECTION OF PRIVACY-RELATED PREFERENCES

This type of service allows this Application to collect and store Users’
preferences related to the collection, use, and processing of their personal
information, as requested by the applicable privacy legislation.

IUBENDA CONSENT DATABASE (IUBENDA SRL)

The iubenda Consent Database allows to store and retrieve records of Users’
consent to the processing of Personal Data, and information and preferences
expressed in relation to the provided consent.

In order to do so, it makes use of a Tracker that temporarily stores pending
information on the User’s device until it is processed by the API. The Tracker
(a browser feature called localStorage) is at that point deleted.

Personal Data processed: Data communicated while using the service; Trackers.
Place of processing: Italy – Privacy Policy.

Category of personal information collected according to the CCPA: internet or
other electronic network activity information.

IUBENDA PRIVACY CONTROLS AND COOKIE SOLUTION (IUBENDA SRL)

The iubenda Privacy Controls and Cookie Solution allows the Owner to collect and
store Users’ preferences related to the processing of personal information, and
in particular to the use of Cookies and other Trackers on this Application.

Personal Data processed: Trackers.

Place of processing: Italy – Privacy Policy.

Category of personal information collected according to the CCPA: internet or
other electronic network activity information.

CONTENT PERFORMANCE AND FEATURES TESTING (A/B TESTING)

The services contained in this section allow the Owner to track and analyze the
User response concerning web traffic or behavior regarding changes to the
structure, text or any other component of this Application.

FIREBASE REMOTE CONFIG (GOOGLE LLC)

Firebase Remote Config is an A/B testing and configuration service provided by
Google LLC. Personal Data processed: various types of Data as specified in the
privacy policy of the service. Place of processing: United States – Privacy
Policy.

Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:

• a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

DATA TRANSFER OUTSIDE THE EU

The Owner is allowed to transfer Personal Data collected within the EU to third
countries (i.e. any country not part of the EU) only pursuant to a specific
legal basis. Any such Data transfer is based on one of the legal bases described
below.

Users can inquire with the Owner to learn which legal basis applies to which
specific service.

DATA TRANSFER TO COUNTRIES THAT GUARANTEE EUROPEAN STANDARDS (THIS APPLICATION)

If this is the legal basis, the transfer of Personal Data from the EU to third
countries is carried out according to an adequacy decision of the European
Commission.

The European Commission adopts adequacy decisions for specific countries
whenever it considers that country to possess and provide Personal Data
protection standards comparable to those set forth by EU data protection
legislation. Users can find an updated list of all adequacy decisions issued on
the European Commission’s website.

Personal Data processed: various types of Data.

Category of personal information collected according to the CCPA: identifiers.

DATA TRANSFER ABROAD BASED ON STANDARD CONTRACTUAL CLAUSES (THIS APPLICATION)

If this is the legal basis, the transfer of Personal Data from the EU to third
countries is carried out by the Owner according to “standard contractual
clauses” provided by the European Commission.

This means that Data recipients have committed to process Personal Data in
compliance with the data protection standards set forth by EU data protection
legislation. For further information, Users are requested to contact the Owner
through the contact details provided in the present document.

Personal Data processed: various types of Data.

Category of personal information collected according to the CCPA: identifiers.

DATA PRIVACY FRAMEWORK SMARTRECRUITERS ADHESION

SmartRecruiters, Inc. has certified to the U.S. Department of Commerce that it
adheres to the Swiss-U.S.

Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the
processing of personal data received from Switzerland in reliance on the
Swiss-U.S. DPF.

If there is any conflict between the terms in this privacy policy and the
EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles
shall govern.

To learn more about the Data Privacy Framework (DPF) program, and to view our
certification, please visit https://www.dataprivacyframework.gov/

DATA TRANSFERS UNDER EU-US DATA PRIVACY FRAMEWORK AND ITS UK AND SWISS EXTENSION

Data Transfers. SmartRecruiters complies with the EU-U.S. Data Privacy Framework
(EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data
Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of
Commerce.

SmartRecruiters has certified to the U.S. Department of Commerce that it adheres
to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles)
with regard to the processing of personal data received from Switzerland in
reliance on the Swiss-U.S. DPF.

SmartRecruiters U.S. entities adhering to the DPF principles:

-SmartRecruiters, Inc.

Where applicable law requires that international data transfers are governed by
a data transfer mechanism, SmartRecruiters uses one or more of the following: EU
Standard Contractual Clauses with a data recipient outside the EEA or the UK,
verification that the recipient has implemented Binding Corporate Rules, or
verification that the recipient adheres to the EU-U.S. Data Privacy Framework,
the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework
(Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.

If SmartRecruiters shares EU Personal Information with a third-party service
provider that processes Personal Information solely on SmartRecruiters’s behalf,
then we may be held liable for that third party’s processing of EU Personal
Information in violation of the Principles, unless SmartRecruiters can prove
that it is not responsible for the event giving rise to the damage.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and
the Swiss-U.S. DPF, SmartRecruiters commits to refer unresolved complaints
concerning our handling of personal data received in reliance on the EU-U.S. DPF
and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to
https://feedback-form.truste.com/watchdog/request, an alternative dispute
resolution provider based in the United States (at no cost to you).

If you do not receive timely acknowledgment of your DPF Principles-related
complaint from us, or if we have not addressed your DPF Principles-related
complaint to your satisfaction, please visit
https://www.dataprivacyframework.gov/s/article/How-to-Submit-a-Complaint-Relating-to-a-Participating-Organization-s-Compliance-with-the-DPF-Principles-dpf
for more information or to file a complaint.

SmartRecruiters is subject to the investigatory and enforcement powers of the
Federal Trade Commission (FTC) and under certain conditions, you have the right
to invoke binding arbitration as set forth under Annex I of these Principles.

DISPLAYING CONTENT FROM EXTERNAL PLATFORMS

This type of service allows you to view content hosted on external platforms
directly from the pages of this Application and interact with them.

This type of service might still collect web traffic data for the pages where
the service is installed, even when Users do not use it.

WISTIA WIDGET (WISTIA, INC.)

Wistia is a video content visualization service provided by Wistia, Inc. that
allows this Application to incorporate content of this kind on its pages.

Personal Data processed: Trackers; Usage Data. Place of processing: United
States – Privacy Policy.

Category of personal information collected according to the CCPA: internet or
other electronic network activity information.

This processing constitutes:

• a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

GRAVATAR (AUTOMATTIC INC.)

Gravatar is an image visualization service provided by Automattic Inc. that
allows this Application to incorporate content of this kind on its pages.

Please note that if Gravatar images are used for comment forms, the commenter’s
email address or parts of it may be sent to Gravatar – even if the commenter has
not signed up for that service.

Personal Data processed: email address; Usage Data. Place of processing: United
States – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers;
internet or other electronic network activity information.

This processing constitutes:

• a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

GOOGLE FONTS (GOOGLE LLC)

Google Fonts is a typeface visualization service provided by Google LLC that
allows this Application to incorporate content of this kind on its pages.

Personal Data processed: Trackers; Usage Data. Place of processing: United
States – Privacy Policy.

Category of personal information collected according to the CCPA: internet or
other electronic network activity information.

This processing constitutes:

• a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

HANDLING PAYMENTS

Unless otherwise specified, this Application processes any payments by credit
card, bank transfer or other means via external payment service providers. In
general and unless where otherwise stated, Users are requested to provide their
payment details and personal information directly to such payment service
providers. This Application isn’t involved in the collection and processing of
such information: instead, it will only receive a notification by the relevant
payment service provider as to whether payment has been successfully completed.

STRIPE (STRIPE, INC.)

Stripe is a payment service provided by Stripe, Inc. Personal Data processed:
Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet or
other electronic network activity information.

HEAT MAPPING AND SESSION RECORDING

Heat mapping services are used to display the areas of this Application that
Users interact with most frequently. This shows where the points of interest
are. These services make it possible to monitor and analyze web traffic and keep
track of User behavior.

Some of these services may record sessions and make them available for later
visual playback.

CRAZY EGG (CRAZYEGG)

Crazy Egg is a heat mapping service provided by Crazy Egg, Inc. Personal Data
processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet or
other electronic network activity information.

This processing constitutes:

• a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

HOSTING AND BACKEND INFRASTRUCTURE

This type of service has the purpose of hosting Data and files that enable this
Application to run and be distributed as well as to provide a ready-made
infrastructure to run specific features or parts of this Application.

Some services among those listed below, if any, may work through geographically
distributed servers, making it difficult to determine the actual location where
the Personal Data are stored.

AMAZON WEB SERVICES (AWS) (AMAZON WEB SERVICES, INC.)

Amazon Web Services (AWS) is a hosting and backend service provided by Amazon
Web Services, Inc. Personal Data processed: various types of Data as specified
in the privacy policy of the service.

Place of processing: Germany – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers.

INFRASTRUCTURE MONITORING

This type of service allows this Application to monitor the use and behavior of
its components so its performance, operation, maintenance and troubleshooting
can be improved.

Which Personal Data are processed depends on the characteristics and mode of
implementation of these services, whose function is to filter the activities of
this Application.

SENTRY (FUNCTIONAL SOFTWARE, INC. )

Sentry is a monitoring service provided by Functional Software, Inc. .

Personal Data processed: various types of Data as specified in the privacy
policy of the service. Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers.

CRASHLYTICS (GOOGLE LLC)

Crashlytics is a monitoring service provided by Google LLC.

Personal Data processed: crash data; device information; Universally unique
identifier (UUID). Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers;
internet or other electronic network activity information.

MANAGING CONTACTS AND SENDING MESSAGES

This type of service makes it possible to manage a database of email contacts,
phone contacts or any other contact information to communicate with the User.

These services may also collect data concerning the date and time when the
message was viewed by the User, as well as when the User interacted with it,
such as by clicking on links included in the message.

MAILGUN (MAILGUN TECHNOLOGIES, INC.)

Mailgun is an email address management and message sending service provided by
Mailgun Technologies, Inc.

Personal Data processed: email address.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:

• a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

• a sharing according to the CCPA

• targeted advertising according to the VCDPA, CPA, CTDPA and UCPA

MARKETO EMAIL MARKETING (ADOBE SYSTEMS INCORPORATED)

Marketo Email Marketing is an email address management and message sending
service provided by Adobe Systems Incorporated

Personal Data processed: Trackers; Usage Data; various types of Data. Place of
processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers;
internet or other electronic network activity information.

This processing constitutes:

• a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

• a sharing according to the CCPA

• targeted advertising according to the VCDPA, CPA, CTDPA and UCPA

REMARKETING AND BEHAVIORAL TARGETING

This type of service allows this Application and its partners to inform,
optimize and serve advertising based on past use of this Application by the
User.

This activity is facilitated by tracking Usage Data and by using Trackers to
collect information which is then transferred to the partners that manage the
remarketing and behavioral targeting activity.

Some services offer a remarketing option based on email address lists.

LINKEDIN WEBSITE RETARGETING (LINKEDIN CORPORATION)

LinkedIn Website Retargeting is a remarketing and behavioral targeting service
provided by LinkedIn Corporation that connects the activity of this Application
with the LinkedIn advertising network.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet or
other electronic network activity information.

This processing constitutes:

• a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

• a sharing according to the CCPA

• targeted advertising according to the VCDPA, CPA, CTDPA and UCPA

TAG MANAGEMENT

This type of service helps the Owner to manage the tags or scripts needed on
this Application in a centralized fashion.

This results in the Users’ Data flowing through these services, potentially
resulting in the retention of this Data.

GOOGLE TAG MANAGER (GOOGLE LLC)

Google Tag Manager is a tag management service provided by Google LLC. Personal
Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet or
other electronic network activity information.

TRAFFIC OPTIMIZATION AND DISTRIBUTION

This type of service allows this Application to distribute their content using
servers located across different countries and to optimize their performance.

Which Personal Data are processed depends on the characteristics and the way
these services are implemented. Their function is to filter communications
between this Application and the User’s browser. Considering the widespread
distribution of this system, it is difficult to determine the locations to which
the contents that may contain Personal Information of the User are transferred.

JSDELIVR (PROSPECT ONE SP. Z O.O. SP. K.)

jsDelivr is a traffic optimization and distribution service provided by Prospect
One Sp. z o.o. sp. k. Personal Data processed: Usage Data.

Place of processing: Poland – Privacy Policy.

Category of personal information collected according to the CCPA: internet or
other electronic network activity information.

This processing constitutes:

• a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

• a sharing according to the CCPA

• targeted advertising according to the VCDPA, CPA, CTDPA and UCPA

USER DATABASE MANAGEMENT

This type of service allows the Owner to build user profiles by starting from an
email address, a personal name, or other information that the User provides to
this Application, as well as to track User activities through analytics
features. This Personal Data may also be matched with publicly available
information about the User (such as social networks’ profiles) and used to build
private profiles that the Owner can display and use for improving this
Application.

Some of these services may also enable the sending of timed messages to the
User, such as emails based on specific actions performed on this Application.

MARKETO LEAD GENERATION (ADOBE SYSTEMS INCORPORATED)

Marketo Lead Generation is a User database management service provided by Adobe
Systems Incorporated

Personal Data processed: email address; various types of Data as specified in
the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:

• a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

FRESHSALES (FRESHWORKS, INC.)

Freshsales is a User database management service provided by Freshworks, Inc.

Personal Data processed: various types of Data as specified in the privacy
policy of the service. Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:

• a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

SALESFORCE SALES CLOUD (SALESFORCE.COM, INC.)

Salesforce Sales Cloud is a User database management service provided by
salesforce.com, inc. Personal Data processed: various types of Data as specified
in the privacy policy of the service. Place of processing: United States –
Privacy Policy.

Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:

• a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

INFORMATION ON OPTING OUT OF INTEREST-BASED ADVERTISING

In addition to any opt-out feature provided by any of the services listed in
this document, Users may learn more on how to generally opt out of
interest-based advertising within the dedicated section of the Cookie Policy.

FURTHER INFORMATION ABOUT THE PROCESSING OF PERSONAL DATA

SMARTRECRUITERS IS PROTECTING YOUR PRIVACY

DATA PRIVACY FRAMEWORK SMARTRECRUITERS ADHESION

SmartRecruiters, Inc. has certified to the U.S. Department of Commerce that it
adheres to the Swiss-U.S.

Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the
processing of personal data received from Switzerland in reliance on the
Swiss-U.S. DPF.

If there is any conflict between the terms in this privacy policy and the
EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles
shall govern.

To learn more about the Data Privacy Framework (DPF) program, and to view our
certification, please visit https://www.dataprivacyframework.gov/

DATA PRIVACY FRAMEWORK COMPLIANCE

SmartRecruiters U.S. entities adhering to the DPF principles:

-SmartRecruiters, Inc.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the
Swiss-U.S. DPF, SmartRecruiters commits to refer unresolved complaints
concerning our handling of personal data received in reliance on the EU-U.S.
DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to TRUSTe, an
alternative dispute resolution provider based in the United States. If you do
not receive timely acknowledgment of your DPF Principles-related complaint from
us, or if we have not addressed your DPF Principles-related complaint to your
satisfaction, please visit https://feedback- form.truste.com/watchdog/request
for more information or to file a complaint. These dispute resolution services
are provided at no cost to you.

COOKIE POLICY

This Application uses Trackers. To learn more, Users may consult the Cookie
Policy.

FURTHER INFORMATION FOR USERS

LEGAL BASIS OF PROCESSING

• The Owner may process Personal Data relating to Users if one of the following
applies: Users have given their consent for one or more specific purposes.

• provision of Data is necessary for the performance of an agreement with the
User and/or for any pre- contractual obligations thereof;

• processing is necessary for compliance with a legal obligation to which the
Owner is subject; processing is related to a task that is carried out in the
public interest or in the exercise of official authority vested in the Owner;

• processing is necessary for the purposes of the legitimate interests pursued
by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that
applies to the processing, and in particular whether the provision of Personal
Data is a statutory or contractual requirement, or a requirement necessary to
enter into a contract.

FURTHER INFORMATION ABOUT RETENTION TIME

Therefore:

• Personal Data collected for purposes related to the performance of a contract
between the Owner and the User shall be retained until such contract has been
fully performed.

• Personal Data collected for the purposes of the Owner’s legitimate interests
shall be retained as long as needed to fulfill such purposes. Users may find
specific information regarding the legitimate interests pursued by the Owner
within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever
the User has given consent to such processing, as long as such consent is not
withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a
longer period whenever required to fulfil a legal obligation or upon order of an
authority.

Once the retention period expires, Personal Data shall be deleted. Therefore,
the right of access, the right to erasure, the right to rectification and the
right to data portability cannot be enforced after expiration of the retention
period.

THE RIGHTS OF USERS BASED ON THE GENERAL DATA PROTECTION REGULATION (GDPR)

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following, to the extent permitted
by law:

• WITHDRAW THEIR CONSENT AT ANY TIME. USERS HAVE THE RIGHT TO WITHDRAW CONSENT
WHERE THEY HAVE PREVIOUSLY GIVEN THEIR CONSENT TO THE PROCESSING OF THEIR
PERSONAL DATA.

• OBJECT TO PROCESSING OF THEIR DATA. USERS HAVE THE RIGHT TO OBJECT TO THE
PROCESSING OF THEIR DATA IF THE PROCESSING IS CARRIED OUT ON A LEGAL BASIS OTHER
THAN CONSENT.

• ACCESS THEIR DATA. USERS HAVE THE RIGHT TO LEARN IF DATA IS BEING PROCESSED BY
THE OWNER, OBTAIN DISCLOSURE REGARDING CERTAIN ASPECTS OF THE PROCESSING AND
OBTAIN A COPY OF THE DATA UNDERGOING PROCESSING.

• VERIFY AND SEEK RECTIFICATION. USERS HAVE THE RIGHT TO VERIFY THE ACCURACY OF
THEIR DATA AND ASK FOR IT TO BE UPDATED OR CORRECTED.

• RESTRICT THE PROCESSING OF THEIR DATA. USERS HAVE THE RIGHT TO RESTRICT THE
PROCESSING OF THEIR DATA. IN THIS CASE, THE OWNER WILL NOT PROCESS THEIR DATA
FOR ANY PURPOSE OTHER THAN STORING IT.

• HAVE THEIR PERSONAL DATA DELETED OR OTHERWISE REMOVED. USERS HAVE THE RIGHT TO
OBTAIN THE ERASURE OF THEIR DATA FROM THE OWNER.

• RECEIVE THEIR DATA AND HAVE IT TRANSFERRED TO ANOTHER CONTROLLER. USERS HAVE
THE RIGHT TO RECEIVE THEIR DATA IN A STRUCTURED, COMMONLY USED AND MACHINE
READABLE FORMAT AND, IF TECHNICALLY FEASIBLE, TO HAVE IT TRANSMITTED TO ANOTHER
CONTROLLER WITHOUT ANY HINDRANCE.

• LODGE A COMPLAINT. USERS HAVE THE RIGHT TO BRING A CLAIM BEFORE THEIR
COMPETENT DATA PROTECTION AUTHORITY.

Users are also entitled to learn about the legal basis for Data transfers abroad
including to any international organization governed by public international law
or set up by two or more countries, such as the UN, and about the security
measures taken by the Owner to safeguard their Data.

DETAILS ABOUT THE RIGHT TO OBJECT TO PROCESSING

WHERE PERSONAL DATA IS PROCESSED FOR A PUBLIC INTEREST, IN THE EXERCISE OF AN
OFFICIAL AUTHORITY VESTED IN THE OWNER OR FOR THE PURPOSES OF THE LEGITIMATE
INTERESTS PURSUED BY THE OWNER, USERS MAY OBJECT TO SUCH PROCESSING BY PROVIDING
A GROUND RELATED TO THEIR PARTICULAR SITUATION TO JUSTIFY THE OBJECTION.

USERS MUST KNOW THAT, HOWEVER, SHOULD THEIR PERSONAL DATA BE PROCESSED FOR
DIRECT MARKETING PURPOSES, THEY CAN OBJECT TO THAT PROCESSING AT ANY TIME, FREE
OF CHARGE AND WITHOUT PROVIDING ANY JUSTIFICATION. WHERE THE USER OBJECTS TO
PROCESSING FOR DIRECT MARKETING PURPOSES, THE PERSONAL DATA WILL NO LONGER BE
PROCESSED FOR SUCH PURPOSES. TO LEARN WHETHER THE OWNER IS PROCESSING PERSONAL
DATA FOR DIRECT MARKETING PURPOSES, USERS MAY REFER TO THE RELEVANT SECTIONS OF
THIS DOCUMENT.

HOW TO EXERCISE THESE RIGHTS

Any requests to exercise User rights can be directed to the Owner through the
contact details provided in this document. Such requests are free of charge and
will be answered by the Owner as early as possible and always within one month,
providing Users with the information required by law. Any rectification or
erasure of Personal Data or restriction of processing will be communicated by
the Owner to each recipient, if any, to whom the Personal Data has been
disclosed unless this proves impossible or involves disproportionate effort. At
the Users’ request, the Owner will inform them about those recipients.

TRANSFER OF PERSONAL DATA OUTSIDE OF THE EUROPEAN UNION

DATA TRANSFER TO COUNTRIES THAT GUARANTEE EUROPEAN STANDARDS

If this is the legal basis, the transfer of Personal Data from the EU to third
countries is carried out according to an adequacy decision of the European
Commission.

DATA TRANSFER ABROAD BASED ON STANDARD CONTRACTUAL CLAUSES

TRANSFER OF PERSONAL DATA OUTSIDE OF THE UNITED KINGDOM

DATA TRANSFERS ACCORDING TO A UK ADEQUACY REGULATION

If this is the legal basis, the transfer of Personal Data from the UK to third
countries may take place according to a so called “adequacy regulation” of the
UK Government.

The UK Government adopts adequacy regulations for specific countries or
territories whenever such countries or territories guarantee Personal Data
protection standards comparable to those set forth by UK data protection
legislation. Users can find an updated list of all adequacy regulations on the
website of the Information Commissioner’s Office (ICO).

FURTHER INFORMATION FOR USERS IN SWITZERLAND

This section applies to Users in Switzerland, and, for such Users, supersedes
any other possibly divergent or conflicting information contained in the privacy
policy.

Further details regarding the categories of Data processed, the purposes of
processing, the categories of recipients of the personal data, if any, the
retention period and further information about Personal Data can be found in the
section titled “Detailed information on the processing of Personal Data” within
this document.

THE RIGHTS OF USERS ACCORDING TO THE SWISS FEDERAL ACT ON DATA PROTECTION

• Users may exercise certain rights regarding their Data within the limits of
law, including the following: right of access to Personal Data;

• right to object to the processing of their Personal Data (which also allows
Users to demand that processing of Personal Data be restricted, Personal Data be
deleted or destroyed, specific disclosures of Personal Data to third parties be
prohibited);

• right to receive their Personal Data and have it transferred to another
controller (data portability); right to ask for incorrect Personal Data to be
corrected.

HOW TO EXERCISE THESE RIGHTS

FUTHER INFORMATION FOR CALIFORNIA CONSUMERS

This section of the document integrates with and supplements the information
contained in the rest of the privacy policy and is provided by the business
running this Application and, if the case may be, its parent, subsidiaries and
affiliates (for the purposes of this section referred to collectively as “we”,
“us”, “our”).

This section applies to all Users (Users are referred to below, simply as “you”,
“your”, “yours”), who are consumers residing in the state of California, United
States of America, according to the “California Consumer Privacy Act of 2018”
(the “CCPA”), as updated by the “California Privacy Rights Act” (the “CPRA”) and
subsequent regulations. For such consumers, this section supersedes any other
possibly divergent or conflicting information contained in the privacy policy.

This part of the document uses the term “personal information“ as defined in the
California Consumer Privacy Act (CCPA/CPRA).

NOTICE AT COLLECTION

CATEGORIES OF PERSONAL INFORMATION COLLECTED, USED, SOLD, OR SHARED

In this section we summarize the categories of personal information that we’ve
collected, used, sold, or shared and the purposes thereof. You can read about
these activities in detail in the section titled “Detailed information on the
processing of Personal Data” within this document.

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you:
identifiers, commercial

information and internet or other electronic network activity information. We do
not collect sensitive personal information.

We will not collect additional categories of personal information without
notifying you.

What are the purposes for which we use your personal information?

We may use your personal information to allow the operational functioning of
this Application and features thereof (“business purposes”). In such cases, your
personal information will be processed in a fashion necessary and proportionate
to the business purpose for which it was collected, and strictly within the
limits of compatible operational purposes.

We may also use your personal information for other reasons such as for
commercial purposes (as indicated within the section “Detailed information on
the processing of Personal Data” within this document), as well as for complying
with the law and defending our rights before the competent authorities where our
rights and interests are threatened or we suffer an actual damage.

We won’t process your information for unexpected purposes, or for purposes
incompatible with the purposes originally disclosed, without your consent.

How long do we keep your personal information?

Unless stated otherwise inside the “Detailed information on the processing of
Personal Data” section, we will not retain your personal information for longer
than is reasonably necessary for the purpose(s) they have been collected for.

How we collect information: what are the sources of the personal information we
collect?

We collect the above-mentioned categories of personal information, either
directly or indirectly, from you when you use this Application.

For example, you directly provide your personal information when you submit
requests via any forms on this Application. You also provide personal
information indirectly when you navigate this Application, as personal
information about you is automatically observed and collected.

Finally, we may collect your personal information from third parties that work
with us in connection with the Service or with the functioning of this
Application and features thereof.

How we use the information we collect: disclosing of your personal information
with third parties for a business purpose

For our purposes, the word “third party” means a person who is not any of the
following: a service provider or a contractor, as defined by the CCPA.

We disclose your personal information with the third parties listed in detail in
the section titled “Detailed information on the processing of Personal Data”
within this document. These third parties are grouped and categorized in
accordance with the different purposes of processing.

Sale or sharing of your personal information

For our purposes, the word “sale” means any “selling, renting, releasing,
disclosing, disseminating, making available, transferring or otherwise
communicating orally, in writing, or by electronic means, a consumer’s personal
information by the business to a third party, for monetary or other valuable
consideration ”, as defined by the CCPA.

This means that, for example, a sale can happen whenever an application runs
ads, or makes statistical analyses on the traffic or views, or simply because it
uses tools such as social network plugins and the like.

For our purposes, the word “sharing” means any “sharing, renting, releasing,
disclosing, disseminating, making available, transferring, or otherwise
communicating orally, in writing, or by electronic or other means, a consumer’s
personal information by the business to a third party for cross-context
behavioral advertising, whether or not for monetary or other valuable
consideration, including transactions between a business and a third party for
cross-context behavioral advertising for the benefit of a business in which no
money is exchanged”, as defined by the CCPA.

Please note that the exchange of personal information with a service provider
pursuant to a written contract that meets the requirements set by the CCPA, does
not constitute a sale or sharing of your personal information.

Your right to opt out of the sale or sharing of your personal information and
how you can exercise it

We sell or share your personal information with the third parties listed in
detail in the section titled “Detailed information on the processing of Personal
Data” within this document. These third parties are grouped and categorized in
accordance with the different purposes of processing.

You have the right to opt out of the sale or sharing of your personal
information. This means that whenever you request us to stop selling or sharing
your personal information, we will abide by your request.

Such requests can be made freely, at any time, without submitting any verifiable
request.

To fully exercise your right to opt out, you can contact us at any time using
the contact details provided in this document.

For a simplified opt-out method you can also use the privacy choices link
provided on this Application.

If you want to submit requests to opt out of the sale or sharing of personal
information via a user-enabled global privacy control, like the Global Privacy
Control (“GPC ”), you are free to do so and we will abide by such request in a
frictionless manner (as defined in the CPRA regulations). The GPC consists of a
setting or extension in the browser or mobile device and acts as a mechanism
that websites can use to indicate they support the GPC signal. If you want to
use GPC, you can download and enable it via a participating browser or browser
extension. More information about downloading GPC is available here.

We use any personal information collected from you in connection with the
submission of your opt-out request solely for the purposes of complying with the
opt-out request.

Once you have opted out, we are required to wait at least 12 months before
asking whether you have changed your mind.

What are the purposes for which we use your personal information?

We won’t process your information for unexpected purposes, or for purposes
incompatible with the purposes originally disclosed, without your consent.

How long do we keep your personal information?

YOUR PRIVACY RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT AND HOW TO
EXERCISE THEM

THE RIGHT TO ACCESS PERSONAL INFORMATION: THE RIGHT TO KNOW AND TO PORTABILITY

You have the right to request that we disclose to you:

• the categories of personal information that we collect about you; the sources
from which the personal information is collected; the purposes for which we use
your information;

• to whom we disclose such information;

• the specific pieces of personal information we have collected about you.

You also have the right to know what personal information is sold or shared and
to whom. In particular, you have the right to request two separate lists from us
where we disclose:

• the categories of personal information that we sold or shared about you and
the categories of third parties to whom the personal information was sold or
shared;

• the categories of personal information that we disclosed about you for a
business purpose and the categories of persons to whom it was disclosed for a
business purpose.

The disclosure described above will be limited to the personal information
collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be
“portable”, i.e. delivered in an easily usable format to enable you to transmit
the information to another entity without hindrance — provided that this is
technically feasible.

THE RIGHT TO REQUEST THE DELETION OF YOUR PERSONAL INFORMATION

You have the right to request that we delete any of your personal information,
subject to exceptions set forth by the law (such as, including but not limited
to, where the information is used to identify and repair errors on this
Application, to detect security incidents and protect against fraudulent or
illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will
delete your personal information and notify any of our service providers and all
third parties to whom we have sold or shared the personal information to do so —
provided that this is technically feasible and doesn’t involve disproportionate
effort.

THE RIGHT TO CORRECT INACCURATE PERSONAL INFORMATION

You have the right to request that we correct any inaccurate personal
information we maintain about you, taking into account the nature of the
personal information and the purposes of the processing of the personal
information.

THE RIGHT TO OPT OUT OF SALE OR SHARING OF PERSONAL INFORMATION AND TO LIMIT THE
USE OF YOUR SENSITIVE PERSONAL INFORMATION

You have the right to opt out of the sale or sharing of your personal
information. You also have the right to request that we limit our use or
disclosure of your sensitive personal information.

THE RIGHT OF NO RETALIATION FOLLOWING OPT-OUT OR EXERCISE OF OTHER RIGHTS (THE
RIGHT TO NON- DISCRIMINATION)

We will not discriminate against you for exercising your rights under the CCPA.
This means that we will not discriminate against you, including, but not limited
to, by denying goods or services, charging you a different price, or providing a
different level or quality of goods or services just because you exercised your
consumer privacy rights.

However, if you refuse to provide your personal information to us or ask us to
delete or stop selling your personal information, and that personal information
or sale is necessary for us to provide you with goods or services, we may not be
able to complete that transaction.

To the extent permitted by the law, we may offer you promotions, discounts, and
other deals in exchange for collecting, keeping, or selling your personal
information, provided that the financial incentive offered is reasonably related
to the value of your personal information.

HOW TO EXERCISE YOUR RIGHTS

To exercise the rights described above, you need to submit your verifiable
request to us by contacting us via the details provided in this document.

For us to respond to your request, it’s necessary that we know who you are.
Therefore, you can only exercise the above rights by making a verifiable request
which must:

• provide sufficient information that allows us to reasonably verify you are the
person about whom we collected personal information or an authorized
representative;

• describe your request with sufficient detail that allows us to properly
understand, evaluate, and respond to it.

We will not respond to any request if we are unable to verify your identity and
therefore confirm the personal information in our possession actually relates to
you.

Making a verifiable consumer request does not require you to create an account
with us. We will use any personal information collected from you in connection
with the verification of your request solely for the purposes of verification
and shall not further disclose the personal information, retain it longer than
necessary for purposes of verification, or use it for unrelated purposes.

If you cannot personally submit a verifiable request, you can authorize a person
registered with the California Secretary of State to act on your behalf.

If you are an adult, you can make a verifiable request on behalf of a child
under your parental authority. You can submit a maximum number of 2 requests
over a period of 12 months.

HOW AND WHEN WE ARE EXPECTED TO HANDLE YOUR REQUEST

We will confirm receipt of your verifiable request within 10 days and provide
information about how we will process your request.

We will respond to your request within 45 days of its receipt. Should we need
more time, we will explain to you the reasons why, and how much more time we
need. In this regard, please note that we may take up to 90 days to fulfill your
request.

Our disclosure(s) will cover the preceding 12-month period. Only with regard to
personal information collected on or after January 1, 2022, you have the right
to request that we disclose information beyond the 12-month period, and we will
provide them to you unless doing so proves impossible or would involve a
disproportionate effort.

Should we deny your request, we will explain you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless
such request is manifestly unfounded or excessive. In such cases, we may charge
a reasonable fee, or refuse to act on the request. In either case, we will
communicate our choices and explain the reasons behind it.

FURTHER INFORMATION FOR VIRGINIA CONSUMERS

This section of the document integrates with and supplements the information
contained in the rest of the privacy policy and is provided by the controller
running this Application and, if the case may be, its parent, subsidiaries and
affiliates (for the purposes of this section referred to collectively as “we”,
“us”, “our”).

This section applies to all Users (Users are referred to below, simply as “you”,
“your”, “yours”), who are consumers residing in the Commonwealth of Virginia,
according to the “Virginia Consumer Data Protection Act” (the “VCDPA”), and, for
such consumers, it supersedes any other possibly divergent or conflicting
information contained in the privacy policy.

This part of the document uses the term “personal data” as defined in the VCDPA.

CATEGORIES OF PERSONAL DATA PROCESSED

In this section, we summarize the categories of personal data that we’ve
processed and the purposes thereof. You can read about these activities in
detail in the section titled “Detailed information on the processing of Persona
Data” within this document.

CATEGORIES OF PERSONAL DATA WE COLLECT

We have collected the following categories of personal data: identifiers,
commercial information and internet information

We do not collect sensitive data.

We will not collect additional categories of personal data without notifying
you.

WHY WE PROCESS YOUR PERSONAL DATA

To find out why we process your personal data, you can read the sections titled
“Detailed information on the processing of Personal Data” and “The purposes of
processing” within this document.

We won’t process your information for unexpected purposes, or for purposes
incompatible with the purposes originally disclosed, without your consent.

You can freely give, deny, or withdraw such consent at any time using the
contact details provided in this document.

HOW WE USE THE DATA WE COLLECT: SHARING OF YOUR PERSONAL DATA WITH THIRD PARTIES

We share your personal data with the third parties listed in detail in the
section titled “Detailed information on the processing of Personal Data” within
this document. These third parties are grouped and categorized in accordance
with the different purposes of processing.

For our purposes, the word “third party” means “a natural or legal person,
public authority, agency, or body

other than the consumer, controller, processor, or an affiliate of the processor
or the controller” as defined by the VCDPA.

SALE OF YOUR PERSONAL DATA

For our purposes, the word “sale” means any “exchange of personal data for
monetary consideration by us to a third party“ as defined by the VCDPA.

Please note that according to the VCDPA, the disclosure of personal data to a
processor that processes personal data on behalf of a controller does not
constitute a sale. In addition, other specific exceptions set forth in the VCDPA
may apply, such as, but not limited to, the disclosure of personal data to a
third party for the provision of a product or service requested by you.

As specified in the “Detailed information on the processing of Personal Data”
section of this document, our use of your personal information may be considered
a sale under VCDPA.

Your right to opt out of the sale of your personal data and how you can exercise
it

You have the right to opt out of the sale of your personal data. This means that
whenever you request us to stop selling your data, we will abide by your
request. To fully exercise your right to opt out you can contact us at any time
using the contact details provided in this document.

We use any personal data collected from you in connection with the submission of
your opt-out request solely for the purpose of complying with the request.

PROCESSING OF YOUR PERSONAL DATA FOR TARGETED ADVERTISING

For our purposes, the word “targeted advertising” means “displaying
advertisements to you where the advertisement is selected based on personal data
obtained from your activities over time and across nonaffiliated websites or
online applications to predict your preferences or interests” as defined by the
VCDPA.

Please note that according to the VCDPA, targeted advertising does not include:
“advertisements based on activities within a controller’s own websites or online
applications; advertisements based on the context of a consumer’s current search
query, visit to a website or online application; advertisements directed to a
consumer in response to the consumer’s request for information or feedback; or
processing personal data solely for measuring or reporting advertising
performance, reach, or frequency”.

To find out more details on the processing of your personal data for targeted
advertising purposes, you can read the section titled “Detailed information on
the processing of Personal Data” within this document.

Your right to opt out of the processing of your personal data for targeted
advertising and how you can exercise it

You have the right to opt out of the processing of your personal data for
targeted advertising. This means that whenever you ask us to stop processing
your data for targeted advertising, we will abide by your request. To fully
exercise your right to opt out you can contact us at any time, using the contact
details provided in this document.

We use any personal data collected from you in connection with the submission of
your opt-out request solely for the purposes of complying with the opt-out
request.

YOUR PRIVACY RIGHTS UNDER THE VIRGINIA CONSUMER DATA PROTECTION ACT AND HOW TO
EXERCISE THEM

You may exercise certain rights regarding your data processed by us. In
particular, you have the right to do the following:

• ACCESS PERSONAL DATA: THE RIGHT TO KNOW. YOU HAVE THE RIGHT TO REQUEST THAT WE
CONFIRM WHETHER OR NOT WE ARE PROCESSING YOUR PERSONAL DATA. YOU ALSO HAVE THE
RIGHT TO ACCESS SUCH PERSONAL DATA. CORRECT INACCURATE PERSONAL DATA. YOU HAVE
THE RIGHT TO REQUEST THAT WE CORRECT ANY INACCURATE PERSONAL DATA WE MAINTAIN
ABOUT YOU, TAKING INTO ACCOUNT THE NATURE OF THE PERSONAL DATA AND THE PURPOSES
OF THE PROCESSING OF THE PERSONAL DATA.

• REQUEST THE DELETION OF YOUR PERSONAL DATA. YOU HAVE THE RIGHT TO REQUEST THAT
WE DELETE ANY OF YOUR PERSONAL DATA.

• OBTAIN A COPY OF YOUR PERSONAL DATA. WE WILL PROVIDE YOUR PERSONAL DATA IN A
PORTABLE AND USABLE FORMAT THAT ALLOWS YOU TO TRANSFER DATA EASILY TO ANOTHER
ENTITY — PROVIDED THAT THIS IS TECHNICALLY FEASIBLE.

• OPT OUT OF THE PROCESSING OF YOUR PERSONAL DATA FOR THE PURPOSES OF TARGETED
ADVERTISING , THE SALE OF PERSONAL DATA , OR PROFILING IN FURTHERANCE OF
DECISIONS THAT PRODUCE LEGAL OR SIMILARLY SIGNIFICANT EFFECTS CONCERNING YOU.

• NON-DISCRIMINATION. WE WILL NOT DISCRIMINATE AGAINST YOU FOR EXERCISING YOUR
RIGHTS UNDER THE VCDPA. THIS MEANS THAT WE WILL NOT, AMONG OTHER THINGS, DENY
GOODS OR SERVICES, CHARGE YOU A DIFFERENT PRICE, OR PROVIDE A DIFFERENT LEVEL OR
QUALITY OF GOODS OR SERVICES JUST BECAUSE YOU EXERCISED YOUR CONSUMER PRIVACY
RIGHTS. HOWEVER, IF YOU REFUSE TO PROVIDE YOUR PERSONAL DATA TO US OR ASK US TO
DELETE OR STOP SELLING YOUR PERSONAL DATA, AND THAT PERSONAL DATA OR SALE IS
NECESSARY FOR US TO PROVIDE YOU WITH GOODS OR SERVICES, WE MAY NOT BE ABLE TO
COMPLETE THAT TRANSACTION. TO THE EXTENT PERMITTED BY THE LAW, WE MAY OFFER A
DIFFERENT PRICE, RATE, LEVEL, QUALITY, OR SELECTION OF GOODS OR SERVICES TO YOU,
INCLUDING OFFERING GOODS OR SERVICES FOR NO FEE, IF YOU HAVE EXERCISED YOUR
RIGHT TO OPT OUT, OR OUR OFFER IS RELATED TO YOUR VOLUNTARY PARTICIPATION IN A
BONA FIDE LOYALTY, REWARDS, PREMIUM FEATURES, DISCOUNTS, OR CLUB CARD PROGRAM.

HOW TO EXERCISE YOUR RIGHTS

To exercise the rights described above, you need to submit your request to us by
contacting us via the contact details provided in this document.

For us to respond to your request, we need to know who you are.

We will not respond to any request if we are unable to verify your identity
using commercially reasonable efforts and therefore confirm that the personal
data in our possession actually relate to you. In such cases, we may request
that you provide additional information which is reasonably necessary to
authenticate you and your request.

Making a consumer request does not require you to create an account with us.
However, we may require you to use your existing account. We will use any
personal data collected from you in connection with your request solely for the
purposes of authentication, without further disclosing the personal data,
retaining it longer than necessary for purposes of authentication, or using it
for unrelated purposes.

If you are an adult, you can make a request on behalf of a child under your
parental authority.

HOW AND WHEN WE ARE EXPECTED TO HANDLE YOUR REQUEST

We will respond to your request without undue delay, but in all cases and at the
latest within 45 days of its receipt. Should we need more time, we will explain
to you the reasons why, and how much more time we need. In this regard, please
note that we may take up to 90 days to fulfill your request.

Should we deny your request, we will explain to you the reasons behind our
denial without undue delay, but in all cases and at the latest within 45 days of
receipt of the request. It is your right to appeal such decision by submitting a
request to us via the details provided in this document. Within 60 days of
receipt of the appeal, we will inform you in writing of any action taken or not
taken in response to the appeal, including a written explanation of the reasons
for the decisions. If the appeal is denied you may contact the Attorney General
to submit a complaint.

We do not charge a fee to respond to your request, for up to two requests per
year. If your request is manifestly unfounded, excessive or repetitive, we may
charge a reasonable fee or refuse to act on the request. In either case, we will
communicate our choices and explain the reasons behind them.

FURTHER INFORMATION FOR COLORADO CONSUMERS

This section applies to all Users (Users are referred to below, simply as “you”,
“your”, “yours”), who are consumers residing in the State of Colorado, according
to the “Colorado Privacy Act” (the “CPA”), and, for such consumers, it
supersedes any other possibly divergent or conflicting information contained in
the privacy policy.

This part of the document uses the term “personal data” as defined in the CPA.

CATEGORIES OF PERSONAL DATA PROCESSED

CATEGORIES OF PERSONAL DATA WE COLLECT

We have collected the following categories of personal data: identifiers,
commercial information and internet information

We do not collect sensitive data.

We will not collect additional categories of personal data without notifying
you.

WHY WE PROCESS YOUR PERSONAL DATA

We won’t process your information for unexpected purposes, or for purposes
incompatible with the purposes originally disclosed, without your consent.

You can freely give, deny, or withdraw such consent at any time using the
contact details provided in this document.

HOW WE USE THE DATA WE COLLECT: SHARING OF YOUR PERSONAL DATA WITH THIRD PARTIES

For our purposes, the word “third party” means “a person, public authority,
agency, or body other than a consumer, controller, processor, or affiliate of
the processor or the controller.” as defined by the CPA.

SALE OF YOUR PERSONAL DATA

As specified in the “Detailed information on the processing of Personal Data”
section of this document, our use of your personal data may be considered a sale
under the CPA.

For our purposes, the word “sale”, “sell”, or “sold” means “the exchange of
personal data for monetary or other valuable consideration by a controller to a
third party” as defined by the CPA.

Please note that according to the CPA, the disclosure of personal data to a
processor that processes personal data on behalf of a controller does not
constitute a sale. In addition, other specific exceptions set forth in the CPA
may apply, such as, but not limited to, the disclosure of personal data to a
third party for the provision of a product or service requested by you.

Your right to opt out of the sale of your personal data and how you can exercise
it

You have the right to opt out of the sale of your personal data. This means that
whenever you request us to stop selling your data, we will abide by your
request.

To fully exercise your right to opt out you can contact us at any time, using
the contact details provided in this document.

For a simplified opt-out method you can also use the privacy choices link
provided on this Application.

We use any personal data collected from you in connection with the submission of
your opt-out request solely for the purpose of complying with the request.

PROCESSING OF YOUR PERSONAL DATA FOR TARGETED ADVERTISING

As specified in the “Detailed information on the processing of Personal Data”
section of this document, we may use your personal data for targeted advertising
purposes.

For our purposes, the word “targeted advertising” means “displaying to a
consumer an advertisement that is selected based on personal data obtained or
inferred over time from the consumer’s activities across nonaffiliated websites,
applications, or online services to predict consumer preferences or interests”
as defined by CPA.

Please note that according to the CPA, targeted advertising does not include:
“advertisements directed to a consumer in response to the consumer’s request for
information or feedback; advertisements based on activities within a
controller’s own websites or online applications or any affiliated website or
online application; advertisements based on the context of a consumer’s current
search query, visit to an internet web site or online application; or processing
personal data solely to measure or report advertising frequency, performance or
reach”.

Your right to opt out of the processing of your personal data for targeted
advertising and how you can exercise it

To fully exercise your right to opt out you can contact us at any time, using
the contact details provided in this document.

For a simplified opt-out method you can also use the privacy choices link
provided on this Application.

We use any personal data collected from you in connection with the submission of
your opt-out request solely for the purposes of complying with the opt-out
request.

Universal opt-out mechanism: Global privacy control

If you want to submit requests to opt-out of the sale of personal data or the
targeted advertising via a user- enabled global privacy control, like the Global
Privacy Control (“GPC”), you are free to do so and we will abide by such
request. The GPC consists of a setting or extension in the browser or mobile
device and acts as a mechanism that websites can use to indicate they support
the GPC signal. If you want to use GPC, you can download and enable it via a
participating browser or browser extension. More information about downloading
GPC is available here.

YOUR PRIVACY RIGHTS UNDER THE COLORADO PRIVACY ACT AND HOW TO EXERCISE THEM

You may exercise certain rights regarding your data processed by us. In
particular, you have the right to do the following:

• opt out of the processing of your personal data for the purposes of targeted
advertising, the sale of personal data, or profiling in furtherance of decisions
that produce legal or similarly significant effects concerning you.

• access personal data. You have the right to request that we confirm whether or
not we are processing your personal data. You also have the right to access such
personal data.

• correct inaccurate personal data. You have the right to request that we
correct any inaccurate personal data we maintain about you, taking into account
the nature of the personal data and the purposes of the processing of the
personal data.

• request the deletion of your personal data. You have the right to request that
we delete any of your personal data.

• obtain a copy of your personal data. We will provide your personal data in a
portable and usable format that allows you to transfer data easily to another
entity – provided that this is technically feasible.

In any case, we will not increase the cost of, or decrease the availability of,
a product or service, based solely on the exercise of any of your rights and
unrelated to the feasibility or the value of a service. However, to the extent
permitted by the law, we may offer a different price, rate, level, quality, or
selection of goods or services to you, including offering goods or services for
no fee, if our offer is related to your voluntary participation in a bona fide
loyalty, rewards, premium features, discounts, or club card program.

HOW TO EXERCISE YOUR RIGHTS

To exercise the rights described above, you need to submit your request to us by
contacting us via the contact details provided in this document.

For us to respond to your request, we need to know who you are and which right
you wish to exercise.

If you are an adult, you can make a request on behalf of a child under your
parental authority.

HOW AND WHEN WE ARE EXPECTED TO HANDLE YOUR REQUEST

Should we deny your request, we will explain to you the reasons behind our
denial without undue delay, but in all cases and at the latest within 45 days of
receipt of the request. It is your right to appeal such decision by submitting a
request to us via the details provided in this document. Within 45 days of
receipt of the appeal, we will inform you in writing of any action taken or not
taken in response to the appeal, including a written explanation of the reasons
for the decisions. If the appeal is denied you may contact the Attorney General
to submit a complaint.

We do not charge a fee to respond to your request, for up to two requests per
year.

FURTHER INFORMATION FOR CONNECTICUT CONSUMERS

This section applies o all Users (Users are referred to below, simply as “you”,
“your”, “yours”), who are consumers residing in the State of Connecticut,
according to “An Act Concerning Personal Data Privacy and Online Monitoring ”
(also known as “The Connecticut Data Privacy Act” or the “CTDPA”), and, for such
consumers, it supersedes any other possibly divergent or conflicting information
contained in the privacy policy.

This part of the document uses the term “personal data” as defined in the CTDPA.

CATEGORIES OF PERSONAL DATA PROCESSED

CATEGORIES OF PERSONAL DATA WE COLLECT

We have collected the following categories of personal data: identifiers,
commercial information and internet information

We do not collect sensitive data.

We will not collect additional categories of personal data without notifying
you.

WHY WE PROCESS YOUR PERSONAL DATA

We won’t process your information for unexpected purposes, or for purposes
incompatible with the purposes originally disclosed, without your consent.

You can freely give, deny, or withdraw such consent at any time using the
contact details provided in this document.

HOW WE USE THE DATA WE COLLECT: SHARING OF YOUR PERSONAL DATA WITH THIRD PARTIES

SALE OF YOUR PERSONAL DATA

As specified in the “Detailed information on the processing of Personal Data”
section of this document, our use of your personal data may be considered a sale
under the CTDPA.

Please note that according to the CTDPA, the disclosure of personal data to a
processor that processes personal data on behalf of a controller does not
constitute a sale. In addition, other specific exceptions set forth in the CTDPA
may apply, such as, but not limited to, the disclosure of personal data to a
third party for the provision of a product or service requested by you.

Your right to opt out of the sale of your personal data and how you can exercise
it

You have the right to opt out of the sale of your personal data. This means that
whenever you request us to stop selling your data, we will abide by your
request.

To fully exercise your right to opt out you can contact us at any time, using
the contact details provided in this document.

For a simplified opt-out method you can also use the privacy choices link
provided on this Application.

We use any personal data collected from you in connection with the submission of
your opt-out request solely for the purpose of complying with the request.

PROCESSING OF YOUR PERSONAL DATA FOR TARGETED ADVERTISING

As specified in the “Detailed information on the processing of Personal Data”
section of this document, we may use your personal data for targeted advertising
purposes.

For our purposes, the word “targeted advertising” means “displaying to a
consumer an advertisement that is selected based on personal data obtained or
inferred over time from the consumer’s activities across non affiliated
websites, applications, or online services to predict consumer preferences or
interests” as defined by CTDPA.

Please note that according to the CTDPA, targeted advertising does not include:
“advertisements based on activities within a controller’s own web sites or
online applications; advertisements based on the context of a consumer’s current
search query, visit to an internet web site or online application;
advertisements directed to a consumer in response to the consumer’s request for
information or feedback; or processing personal data solely to measure or report
advertising frequency, performance or reach”.

Your right to opt out of the processing of your personal data for targeted
advertising and how you can exercise it

To fully exercise your right to opt out you can contact us at any time, using
the contact details provided in this document.

For a simplified opt-out method you can also use the privacy choices link
provided on this Application.

We use any personal data collected from you in connection with the submission of
your opt-out request solely for the purposes of complying with the opt-out
request.

Universal opt-out mechanism: Global privacy control

YOUR PRIVACY RIGHTS UNDER THE CONNECTICUT DATA PRIVACY ACT AND HOW TO EXERCISE
THEM

You may exercise certain rights regarding your data processed by us. In
particular, you have the right to do the following:

• access personal data. You have the right to request that we confirm whether or
not we are processing your personal data. You also have the right to access such
personal data.

• request the deletion of your personal data. You have the right to request that
we delete any of your personal data.

HOW TO EXERCISE YOUR RIGHTS

To exercise the rights described above, you need to submit your request to us by
contacting us via the contact details provided in this document.

For us to respond to your request, we need to know who you are and which right
you wish to exercise.

If you are an adult, you can make a request on behalf of a child under your
parental authority.

HOW AND WHEN WE ARE EXPECTED TO HANDLE YOUR REQUEST

Should we deny your request, we will explain to you the reasons behind our
denial without undue delay, but in all cases and at the latest within 45 days of
receipt of the request. It is your right to appeal such decision by submitting a
request to us via the details provided in this document. Within 45 days of
receipt of the appeal, we will inform you in writing of any action taken or not
taken in response to the appeal, including a written explanation of the reasons
for the decisions. If the appeal is denied, you may contact the Attorney General
to submit a complaint.

We do not charge a fee to respond to your request, for up to one request per
year.

FURTHER INFORMATION FOR UTAH CONSUMERS

This section applies to all Users (Users are referred to below, simply as “you”,
“your”, “yours”), who are consumers residing in the State of Utah, according to
the “Consumer Privacy Act” (the “UCPA”), and, for such consumers, it supersedes
any other possibly divergent or conflicting information contained in the privacy
policy.

This part of the document uses the term “personal data” as defined in the UCPA.

CATEGORIES OF PERSONAL DATA PROCESSED

CATEGORIES OF PERSONAL DATA WE COLLECT

We have collected the following categories of personal data: identifiers,
commercial information and internet information

We do not collect sensitive data.

We will not collect additional categories of personal data without notifying
you.

WHY WE PROCESS YOUR PERSONAL DATA

HOW WE USE THE DATA WE COLLECT: SHARING OF YOUR PERSONAL DATA WITH THIRD PARTIES

For our purposes, the word “third party” means “a person other than: the
consumer, controller, or processor; or an affiliate or contractor of the
controller or the processor” as defined by the UCPA.

SALE OF YOUR PERSONAL DATA

As specified in the “Detailed information on the processing of Personal Data”
section of this document, our use of your personal data may be considered a sale
under the UCPA.

Please note that according to the UCPA, the disclosure of personal data to a
processor that processes personal data on behalf of a controller does not
constitute a sale. In addition, other specific exceptions set forth in the UCPA
may apply, such as, but not limited to, the disclosure of personal data to a
third party for the provision of a product or service requested by you.

Your right to opt out of the sale of your personal data and how you can exercise
it

You have the right to opt out of the sale of your personal data. This means that
whenever you request us to stop selling your data, we will abide by your
request.

To fully exercise your right to opt out you can contact us at any time, using
the contact details provided in this document.

For a simplified opt-out method you can also use the privacy choices link
provided on this Application.

We use any personal data collected from you in connection with the submission of
your opt-out request solely for the purpose of complying with the request.

PROCESSING OF YOUR PERSONAL DATA FOR TARGETED ADVERTISING

As specified in the “Detailed information on the processing of Personal Data”
section of this document, we may use your personal data for targeted advertising
purposes.

Please note that according to the UCPA, targeted advertising does not include:
“advertisements based on activities within a controller’s own websites or online
applications or any affiliated website or online application; advertisements
based on the context of a consumer’s current search query, visit to an web site
or online application; advertisements directed to a consumer in response to the
consumer’s request for information, product, a service or feedback; or
processing personal data solely to measure or report advertising performance,
reach or frequency.”

Your right to opt out of the processing of your personal data for targeted
advertising and how you can exercise it

To fully exercise your right to opt out you can contact us at any time, using
the contact details provided in this document.

For a simplified opt-out method you can also use the privacy choices link
provided on this Application.

We use any personal data collected from you in connection with the submission of
your opt-out request solely for the purposes of complying with the opt-out
request.

YOUR PRIVACY RIGHTS UNDER THE UTAH CONSUMER PRIVACY ACT AND HOW TO EXERCISE THEM

You may exercise certain rights regarding your data processed by us. In
particular, you have the right to do the following:

• access personal data. You have the right to request that we confirm whether or
not we are processing your personal data. You also have the right to access such
personal data.

• request the deletion of your personal data. You have the right to request that
we delete any of your personal data.

• opt out of the processing of your personal data for the purposes of targeted
advertising or the sale of personal data.

HOW TO EXERCISE YOUR RIGHTS

To exercise the rights described above, you need to submit your request to us by
contacting us via the contact details provided in this document.

For us to respond to your request, we need to know who you are and which right
you wish to exercise.

If you are an adult, you can make a request on behalf of a child under your
parental authority.

HOW AND WHEN WE ARE EXPECTED TO HANDLE YOUR REQUEST

Should we deny your request, we will explain to you the reasons behind our
denial without undue delay, but in all cases and at the latest within 45 days of
receipt of the request.

We do not charge a fee to respond to your request, for up to one request per
year.

ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING

LEGAL ACTION

The User’s Personal Data may be used for legal purposes by the Owner in Court or
in the stages leading to possible legal action arising from improper use of this
Application or the related Services.

The User declares to be aware that the Owner may be required to reveal personal
data upon request of public authorities.

ADDITIONAL INFORMATION ABOUT USER’S PERSONAL DATA

In addition to the information contained in this privacy policy, this
Application may provide the User with additional and contextual information
concerning particular Services or the collection and processing of Personal Data
upon request.

SYSTEM LOGS AND MAINTENANCE

For operation and maintenance purposes, this Application and any third-party
services may collect files that record interaction with this Application (System
logs) or use other Personal Data (such as the IP Address) for this purpose.

INFORMATION NOT CONTAINED IN THIS POLICY

More details concerning the collection or processing of Personal Data may be
requested from the Owner at any time. Please see the contact information at the
beginning of this document.

CHANGES TO THIS PRIVACY POLICY

The Owner reserves the right to make changes to this privacy policy at any time
by notifying its Users on this page and possibly within this Application and/or
– as far as technically and legally feasible – sending a notice to Users via any
contact information available to the Owner. It is strongly recommended to check
this page often, referring to the date of the last modification listed at the
bottom.

Should the changes affect processing activities performed on the basis of the
User’s consent, the Owner shall collect new consent from the User, where
required.

DEFINITIONS AND LEGAL REFERENCES

PERSONAL DATA (OR DATA)

Any information that directly, indirectly, or in connection with other
information — including a personal identification number — allows for the
identification or identifiability of a natural person.

USAGE DATA

Information collected automatically through this Application (or third-party
services employed in this Application), which can include: the IP addresses or
domain names of the computers utilized by the Users who use this Application,
the URI addresses (Uniform Resource Identifier), the time of the request, the
method utilized to submit the request to the server, the size of the file
received in response, the numerical code indicating the status of the server’s
answer (successful outcome, error, etc.), the country of origin, the features of
the browser and the operating system utilized by the User, the various time
details per visit (e.g., the time spent on each page within the Application) and
the details about the path followed within the Application with special
reference to the sequence of pages visited, and other parameters about the
device operating system and/or the User’s IT environment.

USER

The individual using this Application who, unless otherwise specified, coincides
with the Data Subject.

DATA SUBJECT

The natural person to whom the Personal Data refers.

DATA PROCESSOR (OR PROCESSOR)

The natural or legal person, public authority, agency or other body which
processes Personal Data on behalf of the Controller, as described in this
privacy policy.

DATA CONTROLLER (OR OWNER)

The natural or legal person, public authority, agency or other body which, alone
or jointly with others, determines the purposes and means of the processing of
Personal Data, including the security measures concerning the operation and use
of this Application. The Data Controller, unless otherwise specified, is the
Owner of this Application.

THIS APPLICATION

The means by which the Personal Data of the User is collected and processed.

SERVICE

The service provided by this Application as described in the relative terms (if
available) and on this site/application.

EUROPEAN UNION (OR EU)

Unless otherwise specified, all references made within this document to the
European Union include all current member states to the European Union and the
European Economic Area.

Cookies are Trackers consisting of small sets of data stored in the User’s
browser.

TRACKER

Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons,
embedded scripts, e-tags and fingerprinting – that enables the tracking of
Users, for example by accessing or storing information on the User’s device.

LEGAL INFORMATION

This privacy statement has been prepared based on provisions of multiple
legislations.

This privacy policy relates solely to this Application, if not stated otherwise
within this document. Latest update: November 16, 2023

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Privacy Policies are a way to inform our customers, prospects and users about
how and why SmartRecruiters processes personal data.

These Privacy Policies are built in collaboration with iubenda, a partner
generating Privacy Policies for its customers.

Our Privacy Policies take into account European Data Protection Board Guidelines
regarding transparency, clarity, and plain language.

These Policies are in place in order to comply with California Consumer Privacy
Act & California Privacy Rights Act (CCPA/CPRA) and General Data Protection
Regulation (GDPR).

You can find out more about data processing done by SmartRecruiters by clicking
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