1. Purpose

This Privacy Policy is incorporated by reference into the Hireflow Terms of Service (the “Terms”). The terms “Hireflow,” “we,” and “us” include Neatly Technologies, Inc. d/b/a Hireflow's and our affiliates and subsidiaries. This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt-out of a use or correct or change such information. All other terms not defined herein will have the meanings set forth in the Terms.

2. Scope

This Privacy Policy applies to Personal Information that is Processed by Hireflow in the course of our software as a service business, including on Hireflow.ai and other Hireflow websites (each a “Site” or “Sites”), forums, blogs, and other online or offline offerings (together with any and all future mobile, online, and offline offerings operated by or on behalf of Hireflow, the “Services”). All individuals whose responsibilities include the Processing of Personal Information on behalf of Hireflow are expected to protect that data by adherence to this Privacy Policy. This Privacy Policy is intended to meet requirements in North America and APAC.

This Policy applies to all Hireflow's operating divisions, subsidiaries, affiliates, and branches, including its U.S. affiliates, and any additional subsidiary, affiliate, or branch of Hireflow that we may subsequently form.

3. Transparency/Notice - Types Of Personal Information We Collect And How We Use It

The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Hireflow and the requirements of applicable law. Some of the ways that Hireflow may collect Personal Information include:

• You may provide Personal Information directly to Hireflow through interacting with the Services, participating in surveys, during events such as sweepstakes, and requesting Services, or information.
• As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below. We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.

We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.

3.1 Types Of Personal Information We Collect

Hireflow collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, and guests (collectively “Individuals”).

• Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an account with Hireflow, purchasing a Plan from Hireflow, requesting Services or information, or contacting us directly through the “Contact Us” feature or by some other method, we may ask you to provide some or all of the following types of information:
• Communications with Us. We may collect Personal Information from you such as name, email address, phone number, company or organization name, location, or mailing address when you use the “Contact Us” feature, register for Hireflow, choose to request information about our Services, request to receive customer or technical support, or otherwise communicate with us. We may also receive a confirmation when you open an email from us, which helps us make our communications with you more interesting and improve our Services.
• Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Sites and/or Services and in any manner consistent with the policies provided herein.
• Purchase of a Plan. When you purchase a Plan on the Site you must provide your email address, first and last name, credit card number, card expiration date and card CVC code. The credit card information is encrypted and transmitted to a Third Party payment processor for processing and storage to a high security vault according to strict industry standards. Once the data reaches the vault it is “tokenized”. No credit card information is received or retained in Hireflow's own systems. Your credit card information is not exposed anywhere in our own systems. Please do not send your credit card information to our team directly. Please use our secure, online system to enter your credit card information.
• Offline Information. As you might expect, we usually collect or receive information through our Site. But we also may collect information offline and it’s important to us that we preserve the privacy of your Personal Information both online and off. For example, if we speak with you by phone as part of our sales process, we may ask for your location. There are other ways we could learn of Personal Information offline, but this Privacy Notice doesn’t try to predict all those methods. We just want you to know that we try to treat offline information collection, uses and disclosures consistently with our online privacy practices.
• Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, and other browser or device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geolocation information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences. If you click on a link to a Third-Party website or service, a Third-Party may also transmit cookies to you. This Privacy Policy does not cover the use of cookies by any Third-Parties and we are not responsible for their privacy policies and practices.
• Information Submitted Via Services. You agree that Hireflow is free to use the content of any communications submitted by you via the Services, for the purposes of feedback, support, bug reports, suggestions, tips, advice or similar uses, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. Hireflow will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or we are required to do so by law.
• Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you (for example, lead or data enrichment services). . This supplemental information allows us to verify information that you have provided to Hireflow and to enhance our ability to provide you with information about our business, products, and Services. Through cookies we place on your browser or device, we may also collect information about your online activity after you leave our Site. We use this information to improve the Site and customize your online experience.
• Information from Third Party Accounts. You may choose to integrate your Service account with certain third-party services, by opting to upload certain of your information (“User Content”) (such as your Gmail contacts,) into the Service. No such integrations happen by default; they must be initiated by you. If you choose to connect the Hireflow Service with a third-party service, you give us permission to store authorization tokens for that service and to access and use your information from that service as permitted by that service only if it directly relates to our ability to provide Services. For email integrations, this is limited to only accessing the email headers for all messages in your account, as well as email headers and message bodies for any email messages Hireflow composes for you and any subsequent correspondence in response to such email messages.

3.2 Personal Information Collected And Controlled By Customers

• Hireflow helps facilitate email and other types messaging ("Message Data") under the direction of its Customers. Message Data may contain Personal Information of the recipients of these messages. Hireflow has no direct relationship with these individuals.

3.3 Additional Limits on Use of Your Google User Data

• Notwithstanding anything else in this Privacy Policy, if you provide Hireflow access to the following types of your Google data, Hireflow's use of that data will be subject to these additional restrictions:
• Hireflow will only use access to read, write, modify, or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a recruiting and sales outreach workflow tool that allows users to compose, send, read, and process emails and will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
• Hireflow will not use this Gmail data for serving advertisements.
• Hireflow will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for Hireflow's internal operations and even then only when the data have been aggregated and anonymized.

3.4 How Hireflow Uses Your Information

We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:

• To Provide Products, Services, or Information Requested. Hireflow may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
• Generally manage Individual information and accounts;
• Respond to questions, comments, and other requests;
• Provide access to certain areas, functionalities, and features of Hireflow's Services;
• Contact you to answer requests for customer support or technical support;
• Allow you to register for events.
• Administrative Purposes. Hireflow may use Personal Information about you for its administrative purposes, including to:
• Measure interest in Hireflow's Services;
• Develop new products and Services;
• Ensure internal quality control;
• Verify Individual identity;
• Communicate about Individual accounts and activities on Hireflow's Services and systems, and, in Hireflow's discretion, changes to any Hireflow policy;
• Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
• Process payment for products or Services purchased;
• Process applications and transactions;
• Prevent potentially prohibited or illegal activities;
• Enforce our Terms.
• Marketing Hireflow Products and Services. Hireflow may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Hireflow may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
• To tailor content, advertisements, and offers;
• To notify you about offers, products, and services that may be of interest to you;
• To provide Services to you and Third Parties
• For other purposes disclosed at the time that Individuals provide Personal Information; or
• Otherwise with your consent.

You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 5 below.

• Research and Development. Hireflow may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Hireflow may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and Services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
• Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third-Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Hireflow's or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 5 below.
• Services via Mobile Devices. From time to time, Hireflow may provide Services that are specifically designed to be compatible and used on mobile devices. Hireflow will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Mobile versions of Hireflow's Services may require that users log in with an account. In such cases, information about use of mobile versions of the Services may be associated with accounts. In addition, Hireflow may enable Individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to Hireflow to enable Individuals to access accounts and to enable Hireflow to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. Hireflow may use personal or non-identifiable information transmitted to Hireflow to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices Hireflow provides.
• Anonymous and Aggregated Information Use. Hireflow may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Hireflow's Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Hireflow may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Hireflow and with Third-Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
• Other Uses. Hireflow may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

3.5 Cookies, Pixel Tags/Web Beacons, Analytics Information, And Interest-Based Advertising

We, as well as Third-Parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our Sites, Services, applications, messaging, and tools, and to recognize you across devices.

• Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
• Analytics. We may also use certain analytics tools to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop Site content. This analytics data is not tied to any Personal Information.

Our uses of such Technologies fall into the following general categories:

• Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our Sites, Services, applications, and tools. This includes technologies that allow you access to our Sites, Services, applications, and tools; that are required to identify irregular Site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;
• Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our Sites, applications, Services, and tools, including as part of our analytic practices to help us understand how our visitors use our Sites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our Site content, applications, Services, or tools;
• Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our Sites, Services, applications, or tools. This may include identifying you when you sign into our Sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our Sites;
• Advertising or Targeting Related. We may use first-party or Third-Party cookies and web beacons to deliver content, including ads relevant to your interests, on our Sites or on Third-Party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

If you would like to opt-out of the Technologies we employ on our Sites, Services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

3.6 Third-Party Websites, Social Media Platforms, And Software Development Kits

The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Hireflow does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk. Hireflow's Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by Third-Parties for any number of purposes.

3.7 Third-Party Payment Processing

When you purchase a subscription for the Services, we process your payments through a Third-Party payment processor. The Third-Party payment processor may collect certain financial information from you to process a payment on behalf of Hireflow, including your name, email address, address and other billing information.

4. Onward Transfer - Hireflow May Disclose Your Information

4.1 Information We Share

We may share your information as described in this Privacy Policy (e.g., with our Third-Party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission.

• We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site. Hireflow has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
• Business Partners. Hireflow may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or Service that you have requested. Hireflow may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Hireflow. Hireflow requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Hireflow provided them.
• Marketing – Interest-Based Advertising and Third Party Marketing. Through our Services, Hireflow may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Hireflow related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt-out of such sharing at no cost by following the instructions in Section 5 below.
• Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Hireflow policies or contracts; (v) to collect amounts owed to Hireflow; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
• In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
• Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, Hireflow will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.

4.2 Data Transfers

All Personal Information collected via or by Hireflow may be stored anywhere in the world, including but not limited to, the United States, Canada, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Hireflow, you consent to the storage of your Personal Information in these locations.

5. Opt-Out (Right To Restrict Processing)

5.1 Email And Telephone Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding Hireflow and our Services and you will not be able to opt-out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

WE MAINTAIN TELEPHONE “DO-NOT-CALL” AND “DO-NOT-MAIL” LISTS AS MANDATED BY LAW. WE PROCESS REQUESTS TO BE PLACED ON DO-NOT-MAIL, DO-NOT-PHONE AND DO-NOT-CONTACT LISTS WITHIN 60 DAYS AFTER RECEIPT, OR SUCH SHORTER TIME AS MAY BE REQUIRED BY LAW

5.2 Mobile Devices

Hireflow may occasionally send you push notifications through our mobile applications with information that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Hireflow may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.

5.3 “Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

5.4 Cookies And Interest-Based Advertising

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt-out of certain mobile ads via their device settings.

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/.

To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device. Advertisements on Third-Party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners’ use of this information for interest-based advertising purposes.

6. Data Retention

Hireflow retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

7. Security of Your information

We take security seriously and we take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure due to a breach or attack on Services over which we have no reasonable control or responsibility.

By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.

8. International Users

By using the Site, Hireflow will transfer data to the United States and may transfer data to other jurisdictions, including, but not limited to, Canada. By choosing to visit the Site, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the United States and the adjudication of any disputes arising in connection with Hireflow or the Site will be in accordance with the Terms.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.

9. Children’s Privacy

The Services are not directed to children under 13 (and in certain jurisdictions in the EU under the age of 16) years of age, and Hireflow does not knowingly collect Personally Identifiable Information from children under 13 (and in certain jurisdictions in the EU under the age of 16) years of age. If you are under the age of 18, you must have your parent’s permission to access the Services. Hireflow urges parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when online. If you learn that your child has provided us with Personal Information without your consent, you may alert us at privacy@hireflow.ai. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions in the EU under the age of 16), we will promptly take steps to delete such information and terminate the child’s account.

10. Redress/Compliance and Accountability

If you have any questions about our privacy practices or this Privacy Policy, please contact Hireflow by email at privacy@hireflow.ai. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

11. Other Rights and Important Information

11.1 Changes To Our Privacy Policy And Practices

This Privacy Policy may change from time to time. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted on the Services. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Services.

• Revision to the Privacy Policy. We may revise this Privacy Policy in our sole discretion, so review it periodically. If you continue to visit this Site and use the Services made available to you after such changes have been made, you hereby provide your consent to the changes.
• Posting of Revised Privacy Policy. If there are any material changes to this Privacy Policy, Hireflow will notify you by email or as otherwise required by applicable law. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.
• New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Hireflow will comply with the law or contract.

11.2 California Privacy Rights

This Policy shall be implemented by Hireflow and all its operating divisions, subsidiaries and affiliates. Hireflow has put in place mechanisms to verify ongoing compliance with Privacy Shield Principles and this Policy. Any Hireflow employee who violates these Privacy Shield Principles and/or this Policy will be subject to disciplinary procedures.

12. Definitions

The following capitalized terms shall have the meanings herein as set forth below.

• “Agent” means any Third-Party that Processes Personal Information pursuant to the instructions of, and solely for, Hireflow or to which Hireflow discloses Personal Information for use on its behalf.
• “Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
• “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
• “Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.
• “Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Hireflow or Hireflow's Agents.

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