Privacy Policy

Policy Effective Date: February 19, 2019

GetHired values the privacy of the users, employers, job seekers, and others who visit and use the Service (collectively or individually, “You” or “Users”).

By registering for, accessing, browsing, or using the service, you acknowledge that you have read, understood, and agree, effective as of the date of such action, to the information handling practices described in this Privacy Policy.

This Privacy Policy is incorporated into and is subject to the GetHired Terms of Service. Your use of the Service and any personal information you provide through the Service are subject at all times to this Privacy Policy and the Terms of Service.

TABLE OF CONTENTS

1.THE INFORMATION WE COLLECT

2.THE WAY WE USE INFORMATION

3.WHEN WE DISCLOSE INFORMATION

4.YOUR CHOICES

5.RESUMES

6.OUR COMMITMENT TO DATA SECURITY

7.OUR COMMITMENT TO CHILDREN'S PRIVACY

8.INTERNATIONAL VISITORS

9.IN THE EVENT OF MERGER OR SALE

10.CHANGES AND UPDATES TO THIS PRIVACY POLICY

11.YOUR RIGHTS TO ACCESS DATA

12.HOW TO COMPLAIN

13.CALIFORNIA PRIVACY RIGHTS

14.CONTACT INFORMATION

1. The Information We Collect; Personal Data

User-Provided Information, including Personally Identifiable Information (PII): Due to the nature and scope of our product, you may provide to GetHired what is generally called “personally identifiable” information (such as your name, email address, postal mailing address, home/mobile telephone number) when using the Service, such as when you register an Account on the Service, log in to the Service, post a resume or Job Posting through the Service, use the GetHired Onboarding feature, or otherwise use the features and functionality of the Service. As permitted by applicable law in the country from which you access our Website and use our services, we may collect, use, store and transfer different kinds of Personal Data about you. We have grouped these into the following categories of “Personal Data”:

Identity Datasuch as first name, maiden name, last name, resume/CV, Social Media profile, username or similar identifier.

Contact Datasuch as billing addresses, email addresses and telephone numbers.

Financial Datasuch as payment card details. However, please note that payment methods (e.g., credit card number and/or PayPal and/or bank account details) are not collected by us directly, but by secure payment service providers.

Transaction Datasuch as details about payments to and from you, and details regarding the services that you have subscribed to in relation to this Website.

Technical Datasuch as Device IDs, your login data, access dates and times, browser type and version, device information, cookie data, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.

Profile Datasuch as your username and password, orders made by you, preferences, user- generated content, job searches, candidate searches, job applications, feedback and survey responses.

Usage Datasuch as information about how you use our Website, products and services.

Marketing and Communications Datasuch as your preferences in receiving marketing from us and our third-parties and your communication preferences.

Use of Information Across Parties for the Service: In using the Service, the information we collect can be considered PII, and may be shared between GetHired and a third party for the Service we are providing.

oWe may obtain information, including personally identifiable information from third parties and sources other than the Service, such as advertisers or social media networks for which you have approved our access to information (e.g., information from your Facebook account provided by the Facebook APIs, if you choose to permit GetHired access to such

information). If we combine or associate information from such other sources with personally identifiable information that we collect through the Service, we will treat the combined information as personally identifiable information in accordance with this Privacy Policy.

oWhen we share information with (to) a 3rd party, it is then subject to that third party’s own data collection, use, and disclosure policies. We do ensure that we work with known, quality partners, but should you wish to know more about the specific privacy policies of these providers, including whether these providers may collect or share Personally Identifiable Information between providers, please review the individual privacy policies of our current list of 3rd party services and their privacy policy links below.

LinkedIn,

Facebook,

Twitter,

Google,

GoodHire,

Universal Background Check,

TokBox,

Twilio,

E-Verify

oIn this context, third parties may collect personally identifiable information about a user’s online activities, over time and across different sites, services, and applications, when that user uses our site, service, or application.

Cookies Information: When you access the Service, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your computer. GetHired may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Service. GetHired site uses cookies to maintain active user sessions, However, persistent cookies can be removed. Please review your web browser “Help” file to learn the proper way to modify your cookie settings.

Response to Do Not Track Signals - Certain web browsers may provide an option by which you may have the browser inform websites or internet services you visit that you do not wish to have information (which may or may not contain PII) about your activities tracked by cookies or other persistent identifiers across time and across third-party Internet websites, online or cloud computing services, online applications, or mobile applications. These are commonly called “do not track” signals. GetHired site requires cookies to maintain active user session, and therefore Do Not Track requests are not acted upon by GetHired.

Third Party Web Beacons: To bring you the best experience and product set possible, we may also implement and integrate third party content, such as advertising, on the Service that uses “clear gifs,” “web beacons,” or other similar techniques, and which may allow the third party content provider to read and write cookies to your browser, or implement similar tracking mechanisms, in connection with your viewing of that third party content displayed on or through the Service.

Other System Information Automatically Collected: When you access the Service or open one of our HTML emails, we may automatically record certain information from your system by using different types of tracking technology. This “automatically collected” information may include Internet Protocol address, a unique device or user ID, version of software installed, system type, the content and pages that you access on the Service, and the dates and times that you visit the Service.

2. The Way We Use Information

GetHired uses the information that you provide or that we collect to operate, maintain, enhance, and provide all of the features and services found on the Service as well as to track user-generated content and Users to the extent necessary to comply as a service provider with the Digital Millennium Copyright Act.

We will use your email address and other provided contact information, without further consent, for administrative communications such as notifying you of major Service updates, for customer service

purposes, to address copyright infringement or defamation issues, or to contact you regarding any content, resumes, Job Posting and other materials that you have posted to, transmitted through, or downloaded from the Service.

GetHired uses all of the information that you provide or that we collect to understand the usage trends and preferences of our Users, to improve the way the Service works and looks, and to create new features and functionality.

GetHired may use “Automatically Collected” information and “Cookies” information, alone or in combination with other information we have collected from you, to: (a) personalize the service, such as remembering your information so that you will not have to re-enter it during your visit or the next time you access the Service; (b) provide customized third party advertisements, content, and information, (c) monitor aggregate site usage metrics such as total number of visitors and pages accessed; (d) provide such metrics to Users as they pertain to such User’s content; and (e) track your entries, submissions, and status in any Job Posting, promotions or other activities.

GetHired may use your email address or other personally identifiable information to send (a) messages about the Service, such as when you receive communications from another User, (b) promotional messages related to the Service and the activities of third parties we work with, and (c) employment related inquiries through the Service on behalf of other Users from whom you have opted to receive communications. Generally, you have the ability to unsubscribe from further communications from a User of the Service, through links provided in the messages sent on behalf of such User.

GetHired acknowledges that you have the right to access your personal information. With respect to personally identifiable Information provided by an enterprise client (e.g., payroll channel) of GetHired to GetHired, we collect such information under the direction of that client and have no direct relationship with the individuals whose personal information we process. If you are a customer of such a GetHired client or channel partner and would no longer like to be contacted by such company, please contact that company directly. If you seek access or want to correct, amend, or delete inaccurate data, you must direct to request to that company (the data controller). If requested to remove data, we will respond within a reasonable timeframe. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by our service agreements with our enterprise clients.

We will retain personal information that we process on behalf of our enterprise clients for as long as needed to provide services to such client. GetHired will retain this personal information as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and in accordance with our internal record keeping policies.

3. When We Disclose Information

GetHired does not share your personally identifiable information with other organizations for their marketing or promotional uses without your prior consent. Please be aware, however, that any personally identifiable information that you voluntarily choose to display on or provide to the Service

– such as when you publish contact information in a Marketing Communication or Account profile –

becomes publicly available and may be collected and used by others without restriction. For example, if you send a Marketing Communication through the Service that includes personally identifiable information, some of the intended recipients may forward or provide such communication publicly to others without your consent.

We may disclose User information to affiliated companies or other businesses or persons who: provide web site hosting, maintenance, and security services; fulfill orders; conduct data analysis and create reports; offer certain functionality; and assist GetHired in delivering or improving the Service and creating new features. These disclosures are generally made under terms comparable to this Privacy Policy, and the recipients are limited to using the information for the purposes for which the information was provided and only to the extent necessary to complete the intended work.

The Service enables users to communicate with others in a variety of ways. Any personally identifiable information you voluntarily choose to include in a communication with other Users, or to post on the Service (such as in a resume or a Profile), will be available to such Users and other recipients of the communication. If you voluntarily provide personally identifiable information to the Service, such as by making a resume public or making a Profile public, GetHired may share this information with a relevant employer or other Users of the Service.

The Service may allow you to participate in certain programs designed to highlight you as a featured job-seeker and/or your Profile (as that term is defined in the Terms of Service) as a featured Profile. If you choose to participate in any such program, GetHired may publish and/or distribute your Profile or any personally identifiable information in your Profile to other Users as part of such program.

However, you will always retain the ability to withdraw your participation from any such program at any time.

The GetHired Onboarding feature is designed to enable employees to fill out paperwork online as part of their employment onboarding process. If you use the GetHired Onboarding feature, the personal information that you submit will be collected, stored and used for the purpose of providing the GetHired Onboarding feature and related services to you and your employer, which includes sharing such information with your employer to the extent permitted by applicable law.

In order to provide you with more exposure, GetHired may publish any personally identifiable information in your Profile which you have chosen to be available to the general public by setting it to public, from time to time, on other jobs websites not affiliated with GetHired. In that event, any personally identifiable information in your Profile which is so intended to be available to the general public will be available to the users of such other websites. However, you will always retain the ability to control the status of your Profile by setting it to private or public.

GetHired may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as U.S. Copyright law) or respond to a court order, judicial or other government subpoena, or warrant in the manner required by the requesting entity.

GetHired also reserves the right to disclose User information that we believe, in good faith, is appropriate or necessary: to take precautions against liability; to protect GetHired from fraudulent, abusive, or unlawful uses; to investigate and defend ourselves against third-party claims or

allegations; to assist government enforcement agencies; to protect the security or integrity of the Service; or to protect the rights, property, or personal safety of GetHired, our users, or others.

4. Your Choices

You may, of course, decline to share your personally-identifiable information with GetHired, in which case GetHired will not be able to provide to you some of the features and functionality found on the Service. You may update or correct your user information and preferences at any time by accessing your account preferences page through the Service. Please note that while changes to your Account are reflected promptly in active user databases, we may retain all information that we collect or that you provide for a variety of purposes, including backups and archiving, prevention of fraud and abuse, and analytics. Please note also that once you have publicly shared information, it may be re-shared by other users, and your subsequent modification or removal of that information will not necessarily affect copies previously propagated by others.

To protect your privacy and security, we take reasonable steps to verify your identity before granting you account access or making corrections to your information. YOU ARE RESPONSIBLE FOR

MAINTAINING THE SECRECY OF YOUR UNIQUE PASSWORD AND ACCOUNT INFORMATION AT ALL TIMES.

5. Resumes

When you create or post a resume to the Service or submit a resume through the Service in response to a Job Posting, that resume is stored in our searchable resume database in the United States. You may control the status of your resume by setting it to private or public.

If you set your resume as private, it is not searchable by potential employers or others with access to our resume database. You may still use your resume to apply online to a Job Posting. If you do apply online to a Job Posting, your resume will be transferred to the relevant employer, who may retain a copy of your resume or distribute it to third parties. We cannot control their use or retention of your resume information.

If you set your resume as public, but want your contact information to be confidential, your resume will be searchable by potential employers, but we will hide your contact information. You must also remove your contact information from any resume you post to the Service. You should be aware that if you have a rare skill or job title, for example, it may still be possible for you to be identified even without your contact details being included. If you are worried about being identified, you should not include specific details by which you could be identified. If you use a confidential resume to apply to a job online, the employer to whom you send your resume will be able to view your contact information in order to contact you about your application.

If you allow your resume to be searchable without making it confidential, then all Users with access to our searchable resume database (or copies thereof) will have access to your resume. Employers or other Users with access to our searchable resume database may be located in countries whose data protection legislation may not be equivalent to the laws in your country. For example, your resume may be viewed and accessed by employers outside the European Economic Area who have

access to our searchable database. By making your resume searchable, you are expressly consenting to such transfers of data.

We attempt to limit access to our searchable resume database to legitimate Users such as employers, recruiters, hiring managers, headhunters and human resource professionals, as well as law enforcement and national security agencies, but cannot guarantee that other parties will not gain access to this database. We cannot control the use made of resumes by third parties who access such resumes while they are in our searchable database. You may remove your resume from our searchable database at any time; details of how to do this are given below. However, employers, recruiters and others who have been provided access to the database by GetHired may have retained a copy of your resume in their own files or databases. We cannot control the retention, use or privacy of resumes or profiles that have been downloaded by third parties. Accordingly, you should not put sensitive information, personality profiles, or other information you would not want made public, in your resume.

If you provide us with details of a reference, it is your responsibility to ensure that the person is aware that you have forwarded his/her details and has consented in writing for you to do so.

If you use our facilities to build a resume or to post a resume in our database of jobseekers’ resumes, then you will be providing us with personal data we will use in accordance with this Privacy Policy. Your resume must not contain sensitive data relating to your (i) racial or ethnic origin (ii) political beliefs (iii) philosophical or religious beliefs (iv) membership of a trade union or political party

(v)physical or mental health or genetic makeup (vi) addictions, sexual life (vii) the commission of criminal offences or proceedings and associated penalties or fines, or (viii) any Social Security Number or national identification number, if you set your resume as private unless you have previously sent to us your written consent that we may process your sensitive personal data, if GetHired determines this to be a requirement of applicable law. If your resume does contain such data and you set your resume as public, then you agree that we may retain this information and use it in accordance with this Privacy Policy. We cannot control third parties’ access to such information from our searchable database.

GetHired Onboarding

When you use the GetHired Onboarding feature, you submit the Onboarding Materials online as part of your employment onboarding process, including your federal tax forms (such as the I-9 and W-4 form), state and local tax forms, company policy forms, employer handbooks, direct deposit authorizations, benefit enrollment information, and other onboarding materials that your employer may require. In order to submit your Onboarding Materials, you voluntarily provide us with personal information that is required to complete such paperwork, including but not limited to your first and last name, address, birth date, telephone number, social security number, financial information (such as your bank information), occupation, marital status, benefits and dependent information, and other personal information that is required to complete your onboarding paperwork. The information that you submit through the GetHired Onboarding feature will be collected, stored and used for the purpose of providing the GetHired Onboarding feature and related services to you and your employer, which includes sharing such information with your employer to the extent permitted by applicable law.

If you use the GetHired Onboarding feature, you acknowledge and understand that your Onboarding Materials may be distributed to third parties, including your employer, in order to provide the GetHired Onboarding service to you. You also acknowledge that such third parties may retain copies of your Onboarding Materials in accordance with applicable law.

6. OUR COMMITMENT TO DATA SECURITY

GetHired uses certain physical, managerial, and technical safeguards designed to preserve the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you transmit to GetHired, and you do so at your own risk. GetHired cannot guarantee that information you provide or that we collect may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

If GetHired learns of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. GetHired may post a notice on the Service if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach you should notify us at suki@gethired.com.

7.COMMITMENT TO CHILDREN'S PRIVACY

If you are under 13 years of age, then you may not use or access the Service at any time or in any manner.

Protecting the privacy of young children is especially important. For that reason, GetHired does not knowingly collect or maintain personally identifiable information from persons under 13 years-of-age. If GetHired learns that personally-identifiable information of persons less than 13-years-of-age has been collected on or through the service, then GetHired will take the appropriate steps to delete this information.

If you are the parent or legal guardian of a child under 13 who you believe has registered an Account on the Service, then please contact GetHired at suki@gethired.com to have that child’s Account terminated and information deleted.

8. INTERNATIONAL VISITORS

For users visiting the service from the European Economic Area (EEA) or any other non-U.S. territories, please note that any data you enter into the Service will be transferred outside the European Economic Area or such other non-U.S. territory for use by GetHired and its affiliates for any of the purposes described herein. In addition, because GetHired operates globally, we may make information we gather available to worldwide business units and affiliates. By providing any data on the Service, you hereby expressly consent to such transfers of your data to the United States or other countries.

9. IN THE EVENT OF MERGER OR SALE

In the event that GetHired is acquired by or merged with a third-party entity, we reserve the right, in any of these circumstances, to transfer or assign the information that we have collected from Users as part of that merger, acquisition, sale, or other change of control.

10. CHANGES AND UPDATES TO THIS PRIVACY POLICY

This Privacy Policy may be revised periodically and this will be reflected by an updated publication date at the top of this Privacy Policy. Please revisit this page to stay aware of any changes. In general, we only use your personal information in the manner described in the privacy policy in effect when we received that personal information. Your continued use of the service constitutes your agreement to this Privacy Policy and any future revisions.

For revisions to this Privacy Policy that may be materially less restrictive on our use or disclosure of personal information you have provided to us, we will make reasonable efforts to notify you and obtain your consent before implementing revisions with respect to such information.

11.YOUR RIGHTS TO ACCESS DATA (FOR DATA SUBJECTS IN THE EEA). Data subjects in the EEA have the following rights with respect to their Personal Data:

Right to Information: The right to know what Personal Data we hold about you and how we use it.

Right to Access: The right to be provided with a copy of your Personal Data (subject to certain restrictions).

Right of Rectification: The right to require us to correct any incomplete or inaccurate Personal Data we hold about you, though we may need to verify the accuracy of the new data you provide to us. If you have a user account with us, you also have the option of correcting your information directly in your account.

Right to erasure/be forgotten: This enables you to ask us to delete or remove Personal Data where there is no good reason for us to continue to process it. Note, however, that we may not always be able to comply with your request for erasure and in such circumstances, will notify our reasons to you.

Right to restrict processing: The right to require us to restrict processing of your Personal Data, i.e., you can request that we suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Right to request data portability: In certain circumstances, you have the right to request the transfer of your Personal Data to you or to a third party in a commonly used machine-readable format. Note, however, that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to object to processing: You have the right to object to the processing of your Personal

Data in the following circumstances: (i) at any time to your Personal Data being processed for direct marketing (including profiling); or (ii) in certain other situations, to our continued processing of your Personal Data, e.g., our processing of your Personal Data when such processing is based on our legitimate interests. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Right to withdraw consent at any time: You have the right to withdraw your consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you

withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Right not to be subject to a decision based solely on automated decision-making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. However, your right does not apply if: (i) you gave us your explicit consent to use your personal data to make our decision; (ii) we are allowed by law to make our decision; or (iii) our automated decision was necessary to enable us to enter into a contract with you.

Method for Requesting Information Pursuant to Your Rights

Upon request, GetHired will provide you with information about whether we hold any of your personal information. If you would like to exercise any of the data subject access rights in the table above (each, an “Access Request”) please send an email to DPO@gethired.com, and we will send you a Data Subject Access Request Form. We will respond to your request within a reasonable timeframe.

No Fee Usually Required

You will not usually be required to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What We May Need from You

Once we receive your Access Request, we may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

12. HOW TO COMPLAIN

All Data Subjects. If you have any complaint about the treatment of your Personal Data, or inquiries regarding our data practices, please contact us as set forth in Section 14 so we may resolve any query or concern you have.

Data Subjects Based in the European Economic Area. The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) country where you work, normally live or where any alleged infringement of data protection laws occurred.

13. CALIFORNIA PRIVACY RIGHTS

California residents have the right to request certain information regarding our disclosure of personal information (as defined by the California Shine the Light Act) to third parties for their direct marketing

purposes unless we provide them with an ability to exercise choice regarding such disclosures. We comply with this law by providing California residents with the ability to opt-out of, or prospectively withdraw their consent, if they have previously opted-in to, the disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, to receive confirmation of how we comply with this law, or to make a request or to opt out at any time, please contact us

at DPO@gethired.com or mail us at the address provided in Section 14 below. Any request must include “California Privacy Rights Request” in the first line of the description and must include the requestor’s name, street address, city, state, and ZIP code.

14.CONTACT INFORMATION

Please contact GetHired with any questions or comments about this Privacy Policy, your personal information, and our third-party disclosure practices or your consent choices at: GetHired, Inc., 540 University Ave, Suite# 50, Palo Alto, CA 94301, or by email: DPO@gethired.com. We will strive to respond to your inquiry within 30 days of its receipt.