Privacy Policy

Last Updated: September 10, 2024

Nexus Media Group, LLC., a company registered in the USA under EIN Registration Number 93-3252863 and having its registered address at 304 S. Jones Blvd #3545, Las Vegas, Nevada 89107, USA, and its subsidiaries and affiliates, (collectively, "Company", "we", "us", or "our") are committed to protecting your personal data and respecting your privacy rights. This Privacy Policy ("Privacy Policy" or "Policy") explains what personal data is collected and how it is processed by the Company when you access or use any website, mobile site or mobile application operated by us or our brands that link to this Privacy Policy (collectively, the "Platform"). This includes ResumeDirect (https://resume.direct) and CVDirect (https://cvdirect.uk) (hereafter the "Site" or "Sites"). This Privacy 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, the Company acts as the controller 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, and account 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.

Resume/CV Distribution

The Platform allows job seekers (hereafter the "Candidate" or "Candidates") to automatically send their resumes/CVs, contact information and job preferences (collectively the "Personal Information") to multiple recruiters and hiring managers (hereafter the "Recruiter and Hiring Manager" or "Recruiters and Hiring Managers") using a single online form.

Our resume/CV distribution service is complimentary for Recruiters and Hiring Managers who may have a legitimate interest in receiving the resumes/CVs of these Candidates to fill their open positions. Recruiters and Hiring Managers receive an email notification from the Platform when one or more Candidates match their recruiting focus, based on their public profile information (hereafter the "Public Information"). Recruiters and Hiring Managers may view and download Candidate resumes/CVs from their dashboard, update their profile (hereafter the "Profile"), contact details (hereafter the "Contact Details"), recruiting preferences (hereafter "Recruiting Preferences"), notification settings, or unsubscribe from our Platform.

What Personal Data We Collect And For What Purposes

We collect different types of data and we process them differently, depending on whether you are a Candidate, or a Recruiter and Hiring Manager.

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 Privacy Policy, please contact us at support@resumedirect.freshdesk.com.

CANDIDATES
The Platform uses personal data it collects directly from you, automatically from your device, or from third party providers.

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, work history, job preferences) 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 match you with the right Recruiters and Hiring Managers and send your resume/CV to them. Please note that without providing your personal data, you would not be able to use the resume/CV distribution services on our Platform. 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 new matches via email. We may use your email address and job related preferences to provide you with a list of new Recruiters and Hiring Managers that we have sent your resume/CV to. Therefore, the processing is based on your continued use of our resume/CV distribution service. 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 your name, location (city, state, country), job title, profile picture, social media profile URL. 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 your name, email address, location, and job preferences. We have a legitimate interest in doing this if you are our customer. 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. The personal data collected for these purposes include your browsing history on our Sites, your location and job preferences. You can opt out of these advertising 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 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 your name, email address, location, and job preferences. 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 at support@resumedirect.freshdesk.com.

Data automatically collected by us

We automatically collect certain information when you visit, use or navigate the Platform. For more information about the use of Cookies on our platform and the choices you have, please see our Cookies Policy.

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 have a legitimate interest in doing this if you are our customer, otherwise we ask for your consent. You can opt out of our advertising 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 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.

To deliver resume/CV distribution services. We provide Resume/CV Distribution As a Service to other career platforms and third parties. These career platforms and third parties offer our resume/CV distribution on their sites, and pass your Personal Information to us for processing and distribution of your resume/CV to Recruiters and Hiring Managers. Processing is necessary for the performance of the contract with these career platforms and third parties, or the processing is based on our legitimate interest.
To send administrative information 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. 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. For more information on how your personal data is processed by our third party payment provider, please review their relevant privacy policies: Stripe - https://stripe.com/privacy
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. 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: marketing leads and search results and links, including paid listings (such as sponsored links). You can opt out of our marketing emails at any time (see the section Your Account and Communication Choices

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. 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.

RECRUITERS AND HIRING MANAGERS
The Platform uses personal data it collects directly from you, automatically from your device, your public profile, or from third party providers.

Personal data you disclose to us

We collect personal data that you provide to us when engaging with our candidate notification emails, when registering on the Platform to view candidate resumes/CVs, expressing an interest in obtaining information about us or our products and services, 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, location (city, state, country), and other similar contact data; usernames, passwords, password hints, and similar security information used for authentication and account access; and employment and other job related data (e.g. job title, company, industry, years of service, top skills, recruiting preferences) 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 send you the right Candidate resumes/CVs. Please note that without providing your personal data, you would not be able to use the resume/CV distribution services on our Platform. 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 our products or services 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 deliver new Candidate matches via email. We may use your email address and recruiting preferences to provide you with a list new Candidate resumes/CVs that we have matched you with. Therefore, the processing is based on your continued use of our resume/CV distribution service. 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 your name, location (city, state, country), job title, profile picture, social media profile URL, company, industry. 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 your name, email address, location, industry, and recruiting preferences. We have a legitimate interest in doing this if you are our customer. 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. The personal data collected for these purposes include your browsing history on our Sites, your location, industry and recruiting preferences. You can opt out of these advertising 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 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 your name, email address, location, industry and recruiting preferences. 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 at support@resumedirect.freshdesk.com.

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 have a legitimate interest in doing this if you are our customer, otherwise we ask for your consent. You can opt out of our advertising 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 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.

Please refer to our Cookie Policy for more information on how we use cookies.

Data collected from other sources

We may use third party service providers to help us with our day-to-day business activities, or to invite you to join our Platform where we deem that you may have a legitimate interest in doing so. Where we use third parties, they may share personal data about you with us. We will use the information we receive for inviting you to join our Platform, and for the purposes that are described in this Privacy Policy.

To deliver resume/CV distribution services. Our service is complimentary for Recruiters and Hiring Managers who may have a legitimate interest in receiving the resumes/CVs of Candidates to fill their open positions. These Recruiters and Hiring Managers are pre-selected based on their public profile information (hereafter the "Public Information"), and an account is created on their behalf on our Platform. An introductory/invitation email is sent to each Recruiter and Hiring Manager, introducing our Platform and service. Recruiters and Hiring Managers receive an email notification from the Platform when one or more Candidates match their recruiting focus, based on their Public Information. Recruiters and Hiring Managers may view and download Candidate resumes/CVs on our Platform, update their profile (hereafter the "Profile"), contact details (hereafter the "Contact Details"), recruiting preferences (hereafter "Recruiting Preferences"), notification settings, or unsubscribe from all notifications.

We may receive personal and professional data about you from your Public Information, or from third parties. The data collected include your name, profile picture, email address, job title, location (city, state, country), social media profile URL, company, industry, length of service, top skills, company profile URL, and company website URL, as well as other information you choose to make public. The processing is based on our legitimate interest in providing the resume/CV distribution service, and your legitimate interest in receiving targeted Candidate resumes/CVs for your recruiting efforts. 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 legitimate interest assessment in such cases. If you have any questions about this, please contact us at support@resumedirect.freshdesk.com.

You can opt out of our Candidate resume/CV notification 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.

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.

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 support@resumedirect.freshdesk.com and we will promptly delete or de-identify this information.

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 Privacy Policy if that changes in the future. These features are not an alternative to the settings you choice in our cookie banner.

How Your Personal Data Is Shared

We may share your personal data with the following categories of partners and third-party service providers for one or more of the purposes described above and if there is a legal basis:

If you are a Candidate: Your Personal Information is shared with Recruiters and Hiring Managers who receive your resume/CV.
If you are a Recruiter and Hiring Manager: Career platforms or third party sites who offer our resume/CV distribution service. We only share your publicly available information, such as name, location (city, state, country), social media profile URL, company, job title, industry. Your Contact Details are never shared.
Content optimization service providers
Invoice and billing service providers
Software service providers that parse and match resumes/CVs with profiles of Recruiters and Hiring Managers
Email 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 Privacy 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.

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.

Sharing information outside the EU/UK

Where necessary, we may transfer and store your personal information outside of the UK. When doing so, we comply with the European data protection laws and regulations and UK GDPR, making sure appropriate safeguards are in place.

For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us at support@resumedirect.freshdesk.com.

Organization name: Liquid Web, LLC
Category of recipient: Website and Application Hosting Provider
Country the personal information is sent to: United States
How the transfer complies with EU/UK data protection law: The country or sector has a UK data bridge (also known as Adequacy Regulations).

For more information, see https://www.liquidweb.com/policies/security-and-trust/

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 Privacy 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.

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 support@resumedirect.freshdesk.com.

De-Identified (Anonymized) And Aggregate Data

The Company may de-identify (as also referred to as "anonymize") and aggregate data for its business purposes, including but not limited to, to improve the products and features of its services, to maintain the security and integrity of its systems, for analytics, and other legitimate business purposes. "De-identified Data" means information that cannot reasonably be used to infer information about, or otherwise be linked to a particular data subject. De-identified Data includes anonymized data and is no longer "personal data" under applicable data protection laws. Where we process De-identified Data, we commit to maintain and use the information in de-identified form and not attempt to reidentify the information, except where permitted by law. The Company may disclose De-identified Data to third parties who commit themselves to maintaining the De-identified Data in anonymized form and not attempt to re-identify the data for any business purpose.

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 support@resumedirect.freshdesk.com.

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 support@resumedirect.freshdesk.com. 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/UK, please contact your local Data Protection Authority. 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 Privacy 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 the 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, or to receiving Candidate resumes/CVs from our resume/CV distribution service.

Right to Withdraw Consent — You have the right to be removed from our Platform, or withdraw your consent at any time. This will not affect the lawfulness of the processing prior to the removal or withdrawal.

Right to Opt In for Sensitive Data Processing — Under certain circumstances, you may have the right to opt in (or consent) before a 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 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 support@resumedirect.freshdesk.com. 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 we have 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've been invited to use our Platform, or 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 candidate emails. Recruiters and Hiring Managers may receive one email per week with a list of Candidates that they have been matched with. This email contains links to download the resumes/CVs of these candidates. You can unsubscribe from our these notifications at any time by clicking on the unsubscribe link in the emails that we send. Once you opt out, you'll be removed from all of our communications.

Opt out of email marketing. We will send you marketing emails about our own products and services if you are our customer or 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.

California Shine the Light notice

We share the Personal Information of Candidates with Recruiters and Hiring Managers, as part of our resume/CV distribution service. The Public Information of Recruiters and Hiring Managers is shared with Candidates who use our resume/CV distribution service, including those who use our service on partner sites. This necessary in order to deliver the service through our Platform. We do not share the Contact Details of Recruiters and Hiring Managers with any third party, and do we share the contact information of our registered users with anyone.

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 us using the method in the "How to submit a request to exercise your rights" section above. 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 email address.

Updated To This Privacy Policy

We reserve the right, in our sole discretion, to make changes or modifications to this Privacy Policy at any time and for any reason. The updated version will be indicated by the "Last Updated" date and the updated version will be effective as soon as it is accessible. You waive any right to receive specific notice of each such change. It is your responsibility to periodically review this Privacy Policy to stay informed of updates. You will be subject to, and will be deemed to have been made aware of and to have accepted, the changes in any revised Privacy Policy by your continued use of the Platform after the date such revised Privacy Policy is posted.

How Can You Contact Us About This Privacy Policy

If you have questions or comments about this Privacy Policy, you may contact our Data Protection Officer (DPO) by email at support@resumedirect.freshdesk.com.

Candidates

Confidentiality of your Personal Information The Platform shares your Personal Information with Recruiters and Hiring managers, or people who identify as Recruiters and Hiring managers online, who receive your resume/CV. If you are concerned about confidentiality, then you should NOT use our Platform. Your Personal Information will be shared exactly as you provide it to us.

NOTE: If you choose to use the Platform, you must agree to do so at your own risk. Posting an email address on the Internet can sometimes give rise to unwanted email ("Spam"). If this is of concern to you, do NOT use the Platform.

Personal Information On our Platform you provide your Personal Information. Your Personal Information will be electronically reformatted and submitted to various Recruiters and Hiring managers, or people who identify as Recruiters and Hiring managers online.

The Company will not rent or sell any information gathered from a customer's use of our Platform. Your Personal Information will not be shared with any third parties for any reason other than what's described in this Privacy Statement or lawfully requested by federal or state authorities.

Recruiters

Resume/CV Distribution Our Service is complimentary for Recruiters and Hiring Managers who may have a legitimate interest in receiving the resumes/CVs of Candidates to fill their open positions. Recruiters and Hiring Managers receive an email notification from the Platform when one or more Candidates match their recruiting focus, based on their public profile information. Recruiters and Hiring Managers may view and download Candidate resumes/CVs from their dashboard, update their profile, contact details, recruiting preferences, notification settings, or unsubscribe from our Platform.

Confidentiality of your information On our Platform you provide your profile, contact details and recruiting preferences. Your Profile will be electronically reformatted and shared with candidates whose resumes/CVs you received. Only your profile is shared. Your contact details are never disclosed with candidates.

NOTE: If this is of concern to you, or if you do not wish to receive candidate resumes/CVs, do NOT use the Platform. You may unsubscribe from the Platform by contacting us at support@resumedirect.freshdesk.com, or by following the "unsubscribe" link from our email communications. You may also unsubscribe and request deletion of your account within your dashboard.

The Company will not rent or sell any information gathered from your use of our Platform. Your profile, contact details and recruiting preferences will not be shared with any third parties for any reason other than what's described in this Privacy Statement or lawfully requested by federal or state authorities.

Payment Information

Payment Information collected from customers on the Platform is securely transmitted for payment processing in real-time utilizing Stripe. The Platform does not store any credit card information for both authorized and declined transactions.

Log Ins

When a customer logs in to our Platform with their email and password, a record of that login may be captured, time stamped and stored in our database along with records of certain activities or functions performed by the customer during that session.

The login information will help us identify the customer associated with those activities and will be used for both statistical analysis as well as customer service. Login information may also be used to trigger an email to communicate with a customer regarding a procedure they may have started but not finished or to inform them that something they requested is now available online.

Employee Accountability

Only those Company employees that have a legitimate business purpose for accessing and handling Personal Information obtained by us are given authorization to do so. The unauthorized access or use of such information by any Company employee is prohibited and constitutes grounds for disciplinary action.

Additionally, our information management systems are configured in such a way as to block or inhibit employees from accessing information that they have no authority to access.

Cookies

A "cookie" is a small data file that gets sent by a web site to your web browser and may then be stored on your computer. Most web browsers allow users to choose to: never to accept cookies, automatically accept cookies, be notified prior to accepting receipt of a cookie from a web site. A received cookie is usually stored in a directory that can be deleted from your computer at any time.

The Platform uses cookies solely for the following reasons:

- To track a customers movement through our Sites and provide meaningful related information from page to page.

- To help aggregate all the information a customer provides on several web page forms into a single set of customer information for submission to Stripe for payment processing.

- To avoid the necessity of a customer having to continually enter his or her email and password after having logged on to our website.

The information contained in a cookie created by the Platform includes a randomly generated session ID and is combined with a portion of the customers IP address for added security.

Website Log Information

While not associated with any particular website visitor's contact information, we retain standard log information gathered by our web server software package for an indefinite period of time. This information will be used solely for statistical analysis. Standard log information includes:

- The web page requested.

- The host name or IP address of the user making the request.

- The date and time of the request.

- The web page address visited prior to the request.

- The users browser type.

- The users operating system.

Credit Card Fraud Protection

In the case of unauthorized use of your credit card, with proper notification to your issuing bank the Fair Credit Billing Act provides that your maximum liability is limited to $50.00 US. In the event you're held liable for unauthorized credit card charges resulting from a Platform secure website transaction, we'll happily reimburse you for your liability up to $50.00 US with the submission of supporting documents.

General Advertising

Our Platform, Sites and Services may be advertised using a variety of methods. Examples can include print, radio, television, banner, public relations and email marketing.

In order to determine the effectiveness of different advertising vehicles, the Company may create different website addresses for advertising vehicles in order to track and understand which vehicles are most effective. This would allow us to identify by virtue of the advertisement responded to, certain information about a customer that the customer didn't necessarily provide, such as their reading, viewing, listening or web surfing interests and habits. The Company may use this information internally to determine what other products or services our customers may be interested in as well as for statistical analysis of what type of customers or advertising vehicles are most effective.

Customer Surveys

The Company may from time to time conduct surveys that ask you for feedback on our products and services. We use that information for market research, to improve our product offerings, identify desirable new products, and perform site and service enhancements. We do not release information from individual survey responses outside the Company without prior permission. We may occasionally share aggregated data with selected business partners. Some surveys may be performed by outside professional firms on our behalf to minimize bias. Those professionals are bound by these same restrictions.

Email To Existing Customers

The Company may from time to time send its customers a promotional email messages to market a service or activity. However, we'll only send promotional email when we reasonably believe our customers would be interested in the subject matter. Nonetheless in every case we will provide clear and simple instructions on how to be removed from our mailing list.

Example topics for email messages to customers include: information about a new product or service, offers to try one of our existing services, invitations to beta test a new service or requests to participate in a survey.

Email To Prospective Customers

The Company's mission and objectives are to create innovative high quality products and services that: offer specific solutions to people with particular needs, save our customers time and money and offer exceptional value at reasonable prices.

The Company is not in support of untargeted, unsolicited mass email marketing to people who'd most likely have no interest in our products. However we do believe in targeted email marketing where: the mail is responsibly delivered, the message is honestly and respectfully written, there's good reason to believe the recipient is predisposed to be interested in the product, the recipient clearly understands why they'd receive such a message and recipients can easily and effectively remove themselves from our mailing list.

To that end, the Company may from time to time obtain, create, or acquire email lists of prospective customers who are known to be seeking employment or who are otherwise likely to be interested in the Company's services, such as recruiters and hiring managers. We may directly email these prospective customers, recruiters and hiring managers, or may use a third party email marketing company to send these prospective customers, recruiters and hiring managers an invitation to visit our Sites.

To better target and analyze our marketing efforts we may also keep database information and logs related to these prospective customers, recruiters and hiring managers for internal use only. This information may include: a recipients first name, last name, email address, residential information, the source of the email list they're on, the date we acquired the list they're on, the date(s) we sent that prospective customer an email, the content of the email message we sent, and the date the prospective customer may have requested to be removed from our list.

In the email itself we may include a special website address that would allow us to know which of the people we emailed actually visited our site. We would use this information for purposes such as: automatically removing web site visitors from our solicitation list, sending website visitors a different email message than non visitors and to perform internal statistical analysis to fine tune our marketing methods.

Remarketing

As you browse our Sites, advertising cookies will be placed on your computer so that we can understand what portions of our sites you have visited. Our display advertising partners then enable us to present you with retargeting advertising on other sites based on your previous interaction with us. The techniques our partners employ do not collect personal information such as your name, email address, postal address or telephone number.

How to Opt-Out from Email Marketing Communications

To Opt-Out or Unsubscribe from any future marketing related email send directly from the Platform, click the unsubscribe link that can be found at the bottom of the email you received.

Children's Use of Our Sites

Our sites are not targeted to nor are they particularly interesting or useful to children. Nevertheless our sites do not contain any mature or other content, which would be considered objectionable to a parent whose child may arbitrarily find our sites. Moreover, there's nothing inherent in our services or advertising that would likely attract children.

Our services are targeted and advertised specifically to adults who are looking to further their career, or those who are likely to be sourcing candidates for their open positions.

Contact Us

We invite your comments and assistance in helping us maintain our commitment to your privacy. If you feel that the Company, its affiliates, or any of their representatives or employees is violating this Privacy Statement, or you feel we can be handling private information more responsibly, please contact us at support@resumedirect.freshdesk.com.

Annex 1 - Additional Information for California Residents

This Annex summarizes how the Company 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:

Category	Sources	Purpose for Collection and Use	Sharing with Third Parties for a Business Purpose	Categories of Third Parties to whom Personal Information is Sold

A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	- Directly from you - Automatically from your device - From third parties	- Account registration - Candidates: Fulfilling customer orders for our resume/CV distribution services - Recruiters and Hiring Managers: Sending you notifications about candidate resumes/CVs that you may have a legitimate interest in to fill your open positions - Marketing our services - Customer service	- Service providers - Website and application analytics providers - Payment Providers - Partner sites (career portals) who offer our resume/CV distribution service - Affiliates and Subsidiaries	Not Sold

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, address, telephone number, education, employment, employment history, credit card number, debit card number. Some personal information included in this category may overlap with other categories.	- Directly from you - Automatically from your device - From third parties	- Account registration - Candidates: Fulfilling customer orders for our resume/CV distribution services - Recruiters and Hiring Managers: Sending you notifications about candidate resumes/CVs that you may have a legitimate interest in to fill your open positions - Marketing our services - Customer service	- Service providers - Website and application analytics providers - Payment Providers - Partner sites (career portals) who offer our resume/CV distribution service - Affiliates and Subsidiaries	Not Sold

C. Characteristics of protected classifications under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Not Collected	Not Collected	Not Collected	Not Sold

D. Commercial information. Records of products or services purchased, or considered, or other purchasing or consuming histories or tendencies.	- Directly from you - Automatically from your device - From third parties	- Account registration - Candidates: Fulfilling customer orders for our resume/CV distribution services - Marketing our services - Customer service	- Service providers - Website and application analytics providers - Payment Providers - Partner sites (career portals) who offer our resume/CV distribution service - Affiliates and Subsidiaries	Not Sold

F. Internet or other similar network activity. Browsing history, search history, information on an employee's interaction with a website, application, or advertisement.	- Automatically from your device - From third parties	- Web site optimization - Marketing our services	- Service providers - Website and application analytics providers - Payment Providers - Partner sites (career portals) who offer our resume/CV distribution service - Affiliates and Subsidiaries	Not Sold

G. Geolocation data. Data that can identify a consumer's physical location or movements.	- Directly from you - Automatically from your device - From third parties	- Web site optimization - Marketing our services	- Service providers - Website and application analytics providers - Payment Providers - Partner sites (career portals) who offer our resume/CV distribution service - Affiliates and Subsidiaries	Not Sold

H. Sensory data. Audio, electronic, visual, olfactory, or similar information.	Not Collected	Not Collected	Not Collected	Not Sold

I. Professional or employment-related information. Candidates: Resumes/CVs Recruiters: Job title, company, years of service at company, top skills, industry, social media profile URL	- Directly from you - Automatically from your device - From third parties	- Account registration - Candidates: Fulfilling customer orders for our resume/CV distribution services - Recruiters and Hiring Managers: Sending you notifications about candidate resumes/CVs that you may have a legitimate interest in to fill your open positions - Marketing our services - Customer service	- Service providers - Website and application analytics providers - Payment Providers - Partner sites (career portals) who offer our resume/CV distribution service - Affiliates and Subsidiaries	Not Sold

J. Education information that is not publicly available. Information that is not publicly available maintained by an education agency or institution related directly to a student.	Not Collected	Not Collected	Not Collected	Not Sold

K. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. For recruiters, it may include determining what candidate resumes/CVs this person may have a legitimate interest in.	- Directly from you - Automatically from your device - From third parties	- Recruiters and Hiring Managers: Sending you notifications about candidate resumes/CVs that you may have a legitimate interest in to fill your open positions - Marketing our services - Analytics and improvement of our services	- Partner sites (career portals) who offer our resume/CV distribution service - Affiliates and Subsidiaries	Not Sold

L. Sensitive personal information. Personal information that reveals a consumer's: Social Security number, driver's license number, state identification card number, or passport number; a consumer's account log-in, financial account, debit card, or credit card number in combination with any security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer's mail, email, and text messages (not business related); genetic data; biometric data used to uniquely identify a consumer; health data; or data related to sex life or sexual orientation.	Not Collected	Not Collected	Not Collected	Not Sold

Note: Our Platform includes the ability for a user to upload and share unstructured personal data, such as resumes/CVs, cover letters, and biographies which could include personal data not included in this Privacy Chart. The Company does not intentionally collect or use any sensitive personal data.