Privacy Policy

Thank you for choosing to be part of our community. At Promote Technology Limited and our subsidiary and affiliated sites, we are committed to protecting your personal data and respecting your privacy rights. This Privacy Policy (“Policy”) explains what personal data is collected and how it is processed by Promote Technology Limited. company, registered in the United Kingdom under Company Number 15767952 and registered address at 86-90 Paul Street, London, United Kingdom, EC2A 4NE. (Promote) and its subsidiaries and affiliates when you access or use any website, mobile site or mobile application operated by us or our brands that link to this Policy (collectively, the “Platform”). This Policy and other documents referenced in it apply to all personal data collected through our Platform and any related services, sales, marketing or events. In those cases, Promote and its subsidiaries and affiliates act as controllers of your personal data.

Personal data is any information relating to an identified or identifiable natural person. It includes things like email addresses, phone numbers, mailing addresses, payment card information, account numbers, and government-issued identification numbers. These are just examples and there are many other types of information that would be considered personal data.

This Policy describes our collection and use practices. To make this easier for you to navigate, please use the links below:

1. WHAT PERSONAL DATA WE COLLECT AND FOR WHAT PURPOSE
   1. Personal Data You Disclose To Us
   2. Data Automatically Collected By Us
   3. Data Collected From Other Sources
   4. Other Purposes For Which We May Use The Personal Data We Collect
2. DO WE COLLECT DATA FROM MINORS?
3. HOW WE HANDLE YOUR SOCIAL LOGINS
4. USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES
5. HOW YOUR PERSONAL DATA IS SHARED
6. PROCESSORS AND INTERNATIONAL DATA TRANSFER
7. HOW LONG WE KEEP YOUR INFORMATION
8. HOW WE KEEP YOUR INFORMATION SAFE
9. YOUR PRIVACY RIGHTS AND CHOICES
   1. How to Submit a Request to Exercise Your Right
   2. Your Account and Communication Choice
   3. California Shine the Light Notice
10. UPDATES TO THIS POLICY
11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
12. ANNEX 1 – ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

We hope you take some time to read through this Policy carefully, because it is important. If there are any terms in this Policy that you do not agree with, please immediately discontinue use of the Platform and our services. If you have any questions or concerns about our collection or use of your information, please contact us at [email protected]

WHAT PERSONAL DATA WE COLLECT AND FOR WHAT PURPOSES

The Platform uses personal data it collects directly from you, automatically from your device, or from third party providers. Below we describe the personal data that we collect from the various sources and the purposes we use the data for. We also describe the legal bases. Please note, those laws that apply to the processing of personal data (including regulations, guidelines, government issued rules, and court opinions interpreting laws) (hereinafter collectively referred to as “data protection laws”) may require us to describe our processing using certain terms or in a specific way. Although we have tried to use terms consistent with data protection laws, we aren’t always able to use terms that may be used in your jurisdiction. If you have any questions about this Policy, please contact us at [email protected]

A. Personal Data You Disclose To Us

We collect personal data that you provide to us when registering to use the Platform, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Platform or otherwise contacting us.

The personal data that we collect depends on the context of your interactions with us and the Platform, the choices you make and the products and features you use, including for the following purposes:

To facilitate account creation and logon process. We use personal data you provide to create an account with us, including: your first and last name, email address, mailing address, phone number, and other similar contact data; usernames, passwords, password hints, and similar security information used for authentication and account access; and employment, resume or CV and other job related data (e.g. nationality, date of birth, education) that you submit to us or provide us access to in connection with the Platform. Processing is necessary in order to enter into a contract with you or for the performance of the contract with you. Without providing your personal data, you cannot create an account with us.

To provide the services. We may use your personal data you decide to share with us in order to create a resume, cover letter or other type of document available on our Platform, including: your first and last name, employment history, resume, cover letter, country, social media handles, education history, biography, industry, phone number, and other job related data. Please note that without providing your personal data, we would not be able to create a resume, cover letter or other type of document available on our Platform. Additionally, you may decide which data you wish to share with us relevant to your job search. Processing is necessary for the performance of the contract with you.

To send administrative information to you. We may use your personal data to send you information about products or services you have purchased or information about changes to our terms, conditions, and policies, including: first and last name, email address, mailing address, phone number, and other similar contact data. Processing is necessary for the performance of the contract with you or in order to fulfill our legal obligations.

To fulfill and manage your orders for services. We may use your personal data to fulfill and manage your orders for services, subscriptions, and payments, and to address any issues with services provided through the Platform, including: your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our third-party payment providers as set forth below. You should review its privacy policies and contact the payment provider directly to respond to your questions. Processing is necessary for the performance of the contract with you.

To deliver job alerts via email. We may use your email address and job related preferences to provide you with email job alerts when you sign up for such service. Therefore, the processing is based on your consent. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.

To post testimonials. We post testimonials on the Platform that may contain personal data, including first name, job title and testimonial which you submitted. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.

To send you marketing and promotional communications. We or our third-party marketing partners may use your personal data for our marketing purposes, depending on your marketing preferences. These communications may include information about our new products, services, or features. The personal data collected for these purposes include name and email address. We have a legitimate interest in doing this if you are our customer, otherwise we ask for your consent. You can unsubscribe from our marketing emails at any time. You also have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.

To deliver targeted advertising to you. We may use your personal data to develop and display content and advertising (and work with third parties who do so) tailored to your interests or location and to measure its effectiveness. The personal data collected for these purposes include name, email address, job title and other information regarding your education and work experience. We will ask your consent to use your personal data for this purpose. You can unsubscribe from our marketing emails at any time. You also have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.

To request feedback. We may use your personal data to request feedback and to contact you about your use of our Platform so that we can improve our products and services and develop additional products and services to better serve our users. The personal data collected for these purposes include name and email address. The processing is based on our legitimate interest. When we rely on our legitimate interest, we will always assess whether your interests or fundamental rights and freedoms do not outweigh our interests.

We always carry out a legitmate interest assessment in such cases. If you have any questions about this, please contact us.

Interview Recordings – where you voluntarily record yourself, we may collect recordings of you through certain features, such as the Event Video Interview Questions. In addition, we may choose to record certain group or 1:1 sessions, in which case you will be presented with an on-screen notification that such a recording has started. If you do not wish to be recorded, please turn off your camera at such time. Processing is based on your consent. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.

B. Data Automatically Collected By Us

We automatically collect certain information when you visit, use or navigate the Platform.

To send you marketing and promotional communications. We or our third-party marketing partners may use your personal data for our marketing purposes, depending on your marketing preferences, including: device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Platform and other technical information. We have a legitimate interest in doing this if you are our customer, otherwise we ask for your consent. You can opt out of our marketing emails at any time (see the section Your Account and Communication Choices below). You also have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.

To deliver targeted advertising to you. We may use your personal data to develop and display content and advertising (and work with third parties who do so) tailored to your interests or location and to measure its effectiveness, including: device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Platform and other technical information. We will ask your consent to use your personal data for this purpose. You can unsubscribe from our marketing emails at any time. You also have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.

To protect the Platform, us, and others. We may use your personal data as part of our efforts to keep the Platform safe and secure (for example, for fraud monitoring and prevention) and to protect others from harm or abuse, including: device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Platform and other technical information. The processing of your personal data for this purpose is based on our legitimate interest.

To improve the Platform. We may use your personal data for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve the Platform, products, services, and your experience, including: device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Platform and other technical information. The processing of your personal data for this purpose is based on our legitimate interest or the processing is necessary to comply with legal and regulatory obligations.

C. Data Collected From Other Sources

We may use third party service providers to help us with our day-to-day business activities. Where we use third parties, they may share personal data about you with us.

To facilitate account creation and logon process. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the personal data you allowed us to collect from those third parties to facilitate account creation and logon process.

Personal data we may receive from your social media provider include: including: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public). Processing is necessary to enter into a contract with you, or for the performance of the contract with you or the processing is based on our legitimate interest.

To send system generated communications to you. We may use third parties to send you administrative information about products or services you have purchased. We may receive personal data about you from the third party, including name and email address. Processing is necessary for the performance of the contract with you or the processing is based on our legitimate interest.

To fulfill and manage your orders for services. All payment data is stored by our third-party payment provider when we fulfill and manage your orders for services, subscriptions, and payments. When you make a purchase our third party payment provider may share transaction information, such as: name, email address, billing address, transaction ID, time, and amount, and payment type. Processing is necessary for the performance of the contract with you. Third party payment providers act as independent controllers over your personal data when you conduct a transaction with them.

To send you marketing and promotional communications. Our third-party marketing partners may share your personal data for our marketing purposes, depending on your marketing preferences, including marketing leads and search results and links, including paid listings (such as sponsored links). We have a legitimate interest in doing this if you are our customer, otherwise we ask for your consent. You can unsubscribe from our marketing emails at any time. You also have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.

To deliver targeted advertising to you. We may use your personal data to develop and display content and advertising (and work with third parties who do so) tailored to your interests or location and to measure its effectiveness, including: marketing leads and search results and links, including paid listings (such as sponsored links). We will ask your consent to use your personal data for this purpose. You can unsubscribe from, our marketing emails at any time.

D. Other Purposes For Which We May Use The Personal Data We Collect

We may use any personal data we collect as described above for the following business purposes:

To develop our products and services. We may use your personal data to further develop our existing products and services, including artificial intelligence tools and features, or to develop new products and services.

To protect the Platform, us, and others. We may use your personal data as part of our efforts to keep the Platform safe and secure (for example, for fraud monitoring and prevention) and to protect others from harm or abuse.

To enforce our terms, conditions and policies. We may use your personal data to ensure you and others are complying with our terms, conditions and policies, including providing your information to law enforcement if we believe it is appropriate to do so and using your information in connection with legal proceedings brought by us or against us.

To respond to legal requests and comply with applicable law. If we receive a subpoena, discovery request, or other legal request, we may need to review and evaluate your personal data and potentially provide your personal data in response to the request. We may also need to use your personal data as needed to comply with applicable laws and regulations.

For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve the Platform, products, services, and your experience.

We have a legitimate interest in using your personal data for these purposes if you are our customer, otherwise we will obtain your consent. You also have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.

DO WE COLLECT DATA FROM MINORS?

Our Platform is not directed to minors under the age of 18 (or under the age of majority as determined by applicable, local law) and we do not intend to collect personal data from minors under the age of majority. Therefore, we recommend that parents or legal guardians be involved in the online activities of their children in order to prevent the collection of their personal data without parental consent. If you believe that we inadvertently have collected personal data about your child, please contact us at [email protected] and we will promptly delete or de-identify this information.

HOW WE HANDLE YOUR SOCIAL LOGINS

The Platform, one of our websites or mobile applications may offer you the ability to register and login using your third party social media account details (like your Facebook or Google logins). If you choose to do this, we will receive certain profile information about you from the social media company. The profile information we receive may vary depending on the social media provider, but will often include your name and email address.

We will use the information we receive for the purposes that are described in this Policy.

Please note that we do not control, and are not responsible for, other uses of your personal data by the social media company. We recommend that you review their privacy policy to understand how they collect, use and share your personal data, and how you can set your privacy preferences on their sites and applications.

USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

We may use cookies and similar tracking technologies (like web beacons and pixels) to collect or store information. Specific information about how we use such technologies and how you can refuse or disable certain cookies is set out in our Cookie Policy. The use of cookies other than essential cookies, including for the purposes of targeted advertising, is performed on the basis of your consent.

Do-Not-Track Features (U.S. Residents only) Many web browsers and some mobile operating systems and mobile applications include a “do-not-track” feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing do-not-track signals has been finalized and, as such, we do not currently respond to do not track browser signals or any other mechanism that automatically communicates your choice not to be tracked online. We will update this Policy if that changes in the future.

HOW YOUR PERSONAL DATA IS SHARED

We and our subsidiaries and affiliates may generally share personal data with each other so that we can provide our services to you, in so far as there is a legal basis. In addition, we may share your personal data with the following categories of third-party service providers for one or more of the purposes described above and if there is a legal basis:

- Chat service providers - Content optimization service providers - Invoice and billing service providers - Social media companies to which you enable access - Software service providers that parse and match resumes with job postings - Email job alert providers - Website and application analytics providers - Website hosting providers - Website testing and optimization service providers

In addition, we may share your personal data with the following types of marketing and advertising service providers for the purposes described in this Policy:

- Advertising, direct marketing, and lead generation providers - Social media site advertising providers - Targeted advertising platforms

Where we believe it necessary or appropriate to do so, we may share your personal data with: law enforcement; government agencies or regulators; courts; parties to legal proceedings in which a subpoena or legal request has been propounded to which such information would be responsive. In those circumstances we will make reasonable efforts to disclose only that information that is relevant to the reason for disclosure and to protect the privacy of such information to the extent reasonably possible.

Our services may also include distributing your resume, CV, and other related information to enterprise partners and third party job sites with your consent and at your request. Should you elect to receive such services, your information shall be governed by and subject to the privacy policy on the respective sites to which your information is sent. We are unable to effectuate any changes or deletions to your information on such sites once your information has been sent and any communications regarding your information on such sites must be made with those sites directly.

Finally, we may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

PROCESSORS AND INTERNATIONAL DATA TRANSFERS

We will only engage processors who adequately implement appropriate technical and organizational measures and who guarantee the protection of your rights. In order to ensure this, we enter into data processing agreements with our processors. This is compulsory under the data protection laws. The data processing agreement regulates, among other things, data security, confidentiality and your rights.

If your personal data are transferred to ‘third countries’ – i.e., countries outside the European Economic Area (“EEA”) – we will only do so if the third country offers an adequate level of protection. In some countries outside the EEA – which as at the date of the last update of this Policy include Andorra, Argentina, Canada (commercial organizations), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Republic of Korea, Switzerland , the United Kingdom under the GDPR and Directive (EU) 2016/680, the United States (commercial organizations participating in the EU-US Data Privacy Framework) and Uruguay (for more information and up to date list of the countries please, check here) – your personal data are sufficiently protected in accordance with European data protection laws and regulations. Where this is not the case, we provide appropriate safeguards to ensure adequate data protection, such is the most recent standard contractual clauses as approved by the European Commission and by additional safeguards, a copy of which can be obtained by sending an e-mail to [email protected]. If no appropriate safeguards are in place, we will only transfer your personal data if a legal exception applies. An example of a legal exception is explicit consent.

HOW LONG WE KEEP YOUR INFORMATION

We will only keep your personal data for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as business records, tax, accounting or other legal requirements). In determining data retention periods, we take into consideration the applicable law, contractual obligations, and your expectations.

When there is/are an indication(s) of potential legal claim(s) or liability, the retention period will be extended accordingly.

When we have no ongoing legitimate business need to process your personal data, i.e. when we no longer have a legal basis in accordance with applicable law, we will either delete or anonymize it and we will make such determination based on applicable laws. When the processing of personal data is based on your consent, the data will be stored for as long as there is valid consent for the processing.

HOW WE KEEP YOUR INFORMATION SAFE

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal data we collect, receive, use, or store, including measures designed to protect data transferred to different countries for use or processing in accordance with this Privacy Policy. We will do our best to protect your personal data taking into account the state of art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for your rights and freedoms posed by the processing. You should however access the Platform within a secure environment. If you believe your account has been compromised or you suspect any type of data breach, please contact us at [email protected]

YOUR PRIVACY RIGHTS AND CHOICES

The rights described in this section apply to all users. Note: Some data protection laws may use other terms to describe these rights differently. If you have any questions about these rights please contact us at [email protected].

Right to Access and to Know — You have the right to access the personal data collected about you. You also may request to know the categories of personal data collected about you, the information or categories of information shared with third parties, or the specific third parties or categories of third parties to which the information was shared; or, some combination of similar information. However, there are certain exemptions, meaning that data subjects may not always receive all of the information we process.

Right of Complaint — If you believe that the processing of your personal data violates applicable laws and regulations, please contact us at [email protected]. We will always try to find a solution together. Should this not be possible, you have the right to complain to a Data Protection Authority about our processing of your personal data. If you are in the EEA, please contact your local Data Protection Authority in the EEA. For contact details of your local Data Protection Authority, please see here.

Right to Correct — Without prejudice to your right to review or change the information in your account to make sure it is accurate and up-to-date, you also have the right to request rectification of any other of your personal data, provided to us if you consider it to be inaccurate or incomplete.

Right to Data Portability — Under certain circumstances, you may request us to transfer your personal data, provided by you, to another controller. Also, you have the right to receive your personal data, which have been provided by you, in a structured, commonly used and machine-readable format and to transmit those data to another controller.

Right to Delete / Erasure — You generally have a right to request your personal data or part of it to be erased (e.g., when your personal data are no longer necessary for the stated purposes in this Policy, the personal data have been unlawfully processed); however, we may not always erase your personal data because sometimes the processing is still necessary. For example, for complying with statutory obligations or for lodging, exercising or substantiating legal claims. Therefore, we will weigh your interest in having your personal data erased against the necessity of maintaining the personal data for our legitimate interests. Please be aware that if you request us to delete your personal data, you may also not be able to continue to use the Platform.

Right to Restriction. **Under certain circumstances, you may have the right to restrict a business’s ability to process personal data about you. **For example, if the accuracy of your personal data is contested, the processing is unlawful or personal data is no longer needed for purposes of the processing. However, we can still use restricted data in certain circumstances (e.g., when your personal data is needed for legal claims or to protect another data subject’s rights).

**Right to Notification of Correction, Deletion or Restriction. **Unless it is impossible or involves a disproportionate effort, we will inform the recipients of your personal data about correction, deletion or restriction of processing.

Right Against Automated Decision Making/ Profiling — **You may have the right to not be subject to a decision based solely on an automated process without human input. **

Right of Objection — Under certain circumstances, you may object to the processing of your personal data by us or third parties engaged by us. We will consider several factors when assessing an objection to our processing in furtherance of our legitimate interests, including: our users’ reasonable expectations; the benefits and risks to you, us, other users, or third parties; and other available means to achieve the same purpose that may be less invasive and do not require disproportional effort. Your objection will be upheld, and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons. For example, you may object to the use of your personal data for direct marketing purposes.

Right to Withdraw Consent — If we have requested your explicit consent for data processing, you have the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of the processing prior to the withdrawal.

Right to Opt In for Sensitive Data Processing — Under certain circumstances, you may have the right to opt in (or consent) before we can process your sensitive data.

Right to Opt Out of Sale or Sharing. Where applicable, in the U.S., you may opt out of the Sale or Sharing of personal data to third parties, as those terms are defined by U.S. federal, state and local laws. You may exercise this right by clicking on by submitting a request as described in the How to Submit a Request to Exercise Your Rights section below.

In addition, we will not discriminate against you if you exercise your privacy rights under any applicable privacy and data protection laws, including by:

- Denying you goods or services. - Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. - Providing you a different level or quality of goods or services. - Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

How to Submit a Request to Exercise Your Rights

Submission of Requests. You may submit a request regarding your personal data by emailing us at [email protected] – please provide your name, telephone number, and type of request.

What We May Need from You. 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 someone 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.

Verifying Your Identity. To protect your privacy and security, we will take reasonable steps to verify your identity before providing your personal data and before deleting your information. Only you or someone legally authorized to act on your behalf may make a verifiable request related to your personal data. For example, if you make a request, we will ask you to confirm your name, email address, and/or other information in our records to verify your identity, so that we can help protect your information.

Requests from Authorized Agents You may designate an authorized agent to make a request for you. If you designate an authorized agent to make a request on your behalf, we may require you to verify your identity and provide the authorized agent’s identity and contact information to us.

Responses to Requests. We will respond to your request as soon as possible, and no later than one month from receipt of your request. In doing so, we will also assess whether, and if so to what extent, we can or must comply with your request under the applicable laws. If a longer period of time is needed, we will inform you within one month of receipt of the request. The submission and processing of your request is free of charge, unless your request is manifestly unfounded or excessive, in particular because of a repetitive character.

Your Account and Communication Choices

Delete or Updating Account Information. If you are a registered user of our Platform, you may delete or correct the personal data in your account in your account settings. It is your responsibility to make sure the personal data we hold about you is accurate and up-to-date. Please note, we may not be able to delete or anonymize all your personal data where applicable law requires us to retain such information. Once the legal basis for its retention has expired, we will delete or de-identify your personal data in accordance with our data retention policy.

Opt Out of Email Marketing. We will send you marketing emails about our own products and services if you are our customer of have given your consent (opt in). However, you can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send. If you opt out of marketing emails, we may still send you service-related emails that are necessary for the administration and use of your account.

**Opt Out of SMS Messages (Applicable in U.S. Only). **We do not send SMS or text messages to you without your consent to do so. If you change your mind at any time, you can opt out of SMS messages by replying “STOP” to any message we send.

California Shine the Light Notice

We provide California residents with the option to opt-in to sharing of “personal information” as defined by California’s “Shine the Light” law with third parties, other than with our affiliates, for such third parties’ own direct marketing purposes. We do not share personal information with non-Affiliate third parties for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light law and/or withdraw previously given consent to sharing with non-Affiliate third parties for their direct marketing purposes by contacting using the methods in the How to Submit a Request to Exercise Your Rights section below. Requests must include “California Direct Marketing Privacy Request” in your description of which right(s) you wish to exercise. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the provided e-mail address or mailing address.

UPDATES TO THIS POLICY

We may update this Policy from time to time. The updated version will be indicated by the “Last Updated” date and the updated version will be effective as soon as it is accessible. If we make any material changes to the Policy, we will notify you by reasonable means, which may be by email or posting a notice of the changes on our website prior to the changes becoming effective. We encourage you to check this Policy from time to time.

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this Policy, you may contact our Data Protection Officer (DPO) by email at [email protected].

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

This Annex summarizes how Promote Technology Limited processes Personal Information in accordance with California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, “CCPA”), The terms used in this Annex 1 shall have the same meanings as given to them under the CCPA.

In the last 12 months, we have collected or received the following categories of Personal Information, where we have a legitimate interest, legal obligation or consent for processing:

**Note**: Promote Technology Limited Services include the ability for the user to upload and share unstructured personal data, such as resumes, cover letters, and biographies which could include personal data not included in this Privacy Chart. Promote Technology Limited does not intentionally collect or use any sensitive personal data.