Talentral/ZippyApp Data Policy

The Data Policy describes the data protection practices of Talentral Corp. and ZippyApp (together referred to as “ZippyApp” “we,” “us,” or “our”). This Privacy Policy applies to all websites owned and operated by us that link to this Privacy Policy, and related online and offline services (collectively, the “Services”). Talentral/ZippyApp is a provider of cloud-based software services that help businesses (“Employers”) looking to hire employees. When applicable we have made distinctions in these sections between Employers and Applicants to be transparent about the different situations in which we may collect, use, or share personal information. When we handle information about Applicants who use our Services to fill out job applications or onboarding documents/forms for specific Employers or otherwise communicate directly with Employers (“Employer Communication”), we do so on behalf of the Employers as a service provider or processor. Employers determine how to engage with Applicants through our Services and thus act as the business that determines the purposes and means of handling Applicant data in relation to Employer Communication. In those circumstances, Applicants are ultimately subject to the privacy policies of the Employers with which they interact, and they should read those policies carefully. Talentral/ZippyApp is not responsible for the privacy practices of Employers. Talentral/ZippyApp acts as the business and not a service provider when Applicants build profiles and use related services. PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. By using Talentral/ZippyApp Services, you are expressly and voluntarily accepting the terms and conditions of this Privacy Policy and our Terms of Use that allow us to process information about you.

Data We Collect

From Applicants

We collect information directly from Applicants or the job boards we have a direct integration with. Applicants apply with their resume/application/profiles on other job boards such as Indeed, Monster, Facebook, etc.

Information We Collect	Purposes	Provided By
Account registration information, e.g. name, DOB, password, email address, username, phone number, wireless device, security questions and answers, city, state, ZIP code, and U.S. work eligibility ("Yes" or "No")	Communication Security Fraud Prevention	Applicant
Contact information, e.g. name, email address, postal address, and phone number	Services Application Information Communication Fraud Prevention	Applicant
Personal identifiers and employment eligibility information, e.g. photographs, video, driver's license number, operator's license number, motor vehicle license number, passport number, Social Security Number, other state or federal-issued identification numbers, and information you provide on tax and other government forms.	Services Application Information and new-hire onboarding	Applicant Employer
Customer service information, e.g. questions and other messages you address to us directly through online forms, by email, over the phone and summaries or voice recordings of your interactions with our customer support organization	Services Communication Fraud Prevention	Applicant
Information about others, e.g. if you submit information about your references or former employers; or if you use a "share" option (or similar feature) that allows you to send information to another person, we will collect, at a minimum, the recipient's contact information. In providing this information, you represent that you are authorized to provide it.	Services New-hire onboarding	Applicant

From Employers

We also collect information from Employers to provide the Services. The information we collect and the purpose for which we use it will depend to some extent on the specific Services you use and how you interact with us. The following table describes the categories of information about you that we collect and how we use such information:

Information We Collect	Purposes	Provided By
Account registration information, e.g. name, phone number, email address, postal address, account username, password, security questions and answers.	Services Communication Fraud Prevention	Employer
Business or company information, e.g. business name, industry, FEIN, business phone number, location(s), links to external business websites, pictures, business logo.	Services Fraud Prevention	Employer
Employment opportunity information, e.g. title, wage range, location(s), availability information, desired qualifications and skills, job description and expectations, job postings.	Services Communication Fraud Prevention	Employer
Other information, e.g. any other information you choose to directly provide to us in connection with your use of the Services.	Services Communication Fraud Prevention	Employer

Description of Purposes
Services, for example:

• Creating a profile and saving selected job postings
• Displaying job opportunities and potential candidates
• Processing and fulfilling your requests and transactions, including registrations, subscriptions, purchases, and payments
• Assisting you in submitting, requesting, processing, or reviewing an application
• Sending communications that you have requested on your behalf
• Understanding and resolving issues being reported

Application and New-Hire Onboarding, for example:

• Applying for a job employment eligibility screening
• Complying with applicable laws, including federal and state employment law
• Arranging for financial deposits and transactions and relevant trainings
• Facilitating logistics for employment, such as uniform sizing

Communication, for example:

• Responding to your requests for information and provide you with more effective and efficient customer service and technical support, including to investigate, respond to and resolve incidents and complaints
• Keeping you updated regarding job opportunities, interview requests, application reminders, and/or jobs you may be interested in
• Informing Employers about new applicants to posted jobs, account-specific information, and/or promotions regarding our Services
• Providing you with transactional updates and information about the Services (e.g., inform you about updates to our Services, information about your account, or information about ecommerce transactions that you conduct on the Services)
• In accordance with applicable legal requirements, contacting you by email, postal mail, phone, or SMS regarding our Services.

Fraud Prevention, for example:

• Complying with any applicable procedures, laws, and regulations where it is necessary for our legitimate interests or the legitimate interests of others
• Establishing, exercising, or defending our legal rights where it is necessary for our legitimate interests or the legitimate interests of others (e.g., to enforce compliance with our Terms of Use, Privacy Policies, or to protect our Services, users, or others)

Cookies and Online Analytics

We use a variety of online tracking and analytics tools (e.g., cookies, and pixel tags) to collect and analyze information as you use the Services. Among other things, these technologies allow us to offer you a more tailored experience in the future, by understanding and remembering your particular browsing and usage preferences. We may also use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze information collected through these technologies to assist us in auditing, research, or reporting; fraud prevention; and providing certain features to you. The types of tracking and analytics tools we and our service providers use for these purposes are:
“Cookies” are small data files stored on your computer or device to collect information about your use of the Services. Cookies may enable us to recognize you as the same user who used our Services in the past, and relate your use of the Services to other information we have about you. Cookies may also be used to enhance your experience on the Services (for example, by storing your username) and/or to collect general usage and aggregated statistical information. Most browsers can be set to detect cookies and give you an opportunity to reject them, but refusing cookies may, in some cases, limit your use of our Services or features. Learn more about the use of cookies, including how to manage or delete them. Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services.
“Local shared objects,” may be stored on your computer or device using a media player or other software. Local shared objects operate much like cookies, but cannot be managed in the same way. Depending on how local shared objects are enabled on your computer or device, you may be able to manage them using software settings.
“pixel tag” (also known as a “clear GIF” or “web beacon”) is a tiny image – typically just one-pixel – that can be placed on a web page or in our electronic communications to you in order to help us measure the effectiveness of our content by, for example, counting the number of individuals who visit us online or verifying whether you’ve opened one of our emails or seen one of our web pages.

How We Share Data:
We only share your data for the proposes of providing of services. We do not sell your data or share it with any party not related to the requested service.

Privacy Rights for California Residents

If you are a California resident, California law requires us to provide you with some additional information regarding your rights with respect to your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).

1. Your California Privacy Rights
   • If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to: Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information. Provide access to and/or a copy of certain personal information we hold about you. Delete certain personal information we have about you. Provide you with information about the financial incentives that we offer to you, if any.
   • The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.
   
   
   Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Service to you. We also will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name, email address, phone number, or other information. You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you or to comply with a legal obligation. In some circumstances if you still ask us to delete your information, you may no longer be able to access or use our Services. If you would like further information regarding your legal rights under California law or would like to exercise any of them, contact us at info@zippyapp.com. With regard to personal information collected by Employers through Employer Communication, Applicants should direct requests to exercise applicable rights to the Employer on whose behalf we handle the data. If we receive a request from an applicant directly in relation to information collected through an Employer Communication, we will refer that request to the appropriate Employer(s) and await each Employer’s instructions on how to handle it.
2. Collection, Use, and Disclosure of Californians’ Personal Information During the 12 months leading up to the effective date of this Privacy Policy, we collected (and continue to collect) account registration information, contact information, profile information, demographic and statistical information, business or company information, personal identifiers and employment eligibility information, application responses, financial and transactional information, employment opportunity information, customer service information, communications with other users, research, survey, or sweepstakes information, information about others, device information and identifiers, connection and usage data, social media information, geolocation, and other information, as described in the “Information We Collect” section of our Privacy Policy. This data was and continues to be used for providing our Services, facilitating employment applications, employment onboarding, sending communications, personalizing the Services, engaging in transactions, improving the Services, securing our Services and users, detecting and preventing fraud, defending our legal rights, and complying with the law, as described in more detail in the “Purposes” section of this Privacy Policy.

Privacy Rights for Nevada Residents

Under Nevada law, certain Nevada residents may opt out of the “sale” of “covered information” (as such term is defined under Nevada law) for monetary consideration to a person for that person to license or sell such information to additional persons. “Covered information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online. We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of the sale of your covered information under Nevada law by emailing us at info@zippyapp.com. Please note we will take reasonable steps to verify your identity and the authenticity of the request.

How We Protect Your Data and Our Services

We take measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure, and access. However, no method of transmission over the internet, and no means of electronic or physical storage, is absolutely secure. By using our Services, you acknowledge and accept that we cannot guarantee the security of your information and that use of our Services is at your own risk. You are responsible for keeping your account information—and especially your login information—confidential. We ask you not to share your login credentials with anyone. When you sign up for an account, you may be required to establish a username and password. If you create an account with us, you are responsible for maintaining the confidentiality of your account password and for any activity that occurs under your account. We are not responsible for any loss or damage arising from your failure to maintain the confidentiality of your password. If you use messaging features that allow you to interact with Employers or Applicants directly through our Services, please note that these communications are not encrypted and, for security purposes, you should not include any passwords, social security numbers, payment card information, or other sensitive information in such communications. Please refer to our Terms of Service and Privacy Policy agreement.

Retention of your Information

We store and maintain your information for the purposes for which it is processed by us. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

To remove your unsubmitted application data, please send a request to info@zippyapp.com.

Your Obligations

As discussed further in our Terms of Service and Data and Privacy Policy, Applicants and Employers have obligations that they must abide by in order to use the Services:

1. You must, at all times, abide by the terms and conditions of the then-current Data and Privacy Policy and Terms of Service. This includes respecting all intellectual property rights that may belong to third parties.
2. You must keep your username and password confidential and not share it with others
3. Any violation of these guidelines may lead to the restriction, suspension or termination of your account at our sole discretion.

Third-Party Links and Features

The Services contain links to third-party services, and you may also integrate our Services with third-party services. If you choose to use these third-party services or features, you may disclose your information not just to those third parties but also to their users and the public more generally, depending on how their services function. Talentral/ZippyApp is not responsible for the content or practices of such third-party services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third parties.