Privacy Policy

Effective Date: May 18, 2018

We at TalentCircles, Inc. know that your privacy is important. This privacy policy is designed to assist you in understanding how we will collect and use the information you provide us when you use our Website TalentCircles.com, by offline means such as by mail or telephone or when you use our software Platform "TalentCircles". Please read this privacy policy to learn more about the ways in which we collect and use your information. If we make any material changes to this privacy policy, we will notify you in accordance with the process described in the Changes section of this privacy policy. By using our Website or our Platform, you consent to our collection, use, and disclosure of your information as described in this privacy policy.

This privacy policy is incorporated into and is subject to the TalentCircles, Inc. Terms of Use. Any capitalized terms not defined herein have the meaning set forth in the Terms of Use. By using the Platform, you expressly consent to the information handling practices described in this privacy policy.

PRIVACY SHIELD COMMITMENTS: TalentCircles, Inc. complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. TalentCircles has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

In compliance with the Privacy Shield Principles, TalentCircles commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact TalentCircles at: privacy@TalentCircles.com

TalentCircles has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the

Terms Applicable to Users of the Website/Network and To Information Shared Offline

Information We Collect - Information We Automatically Collect

When you access our Website, whether by computer, mobile phone or other device, we automatically collect certain information about your use of our Website (this information may include without limitation: geographical location and IDs of your computer, mobile or other device; bandwidth used; system and connection performance; browser type and version, operating system; referral source; length of visit; page views; IP address or other unique identifier for your computer, mobile phone or other device; your mobile carrier) using technologies such as Cookies and web beacons. *This information is not linked to personally identifiable information.

Information You Provide to Us

In some situations, you may provide us with your personal identifying information (called "PII"). PII could include, without limitation, your name, street address, telephone number, email address, information about your company or business, and, if necessary, date of birth and any other information we collect about you that by itself is not PII but if combined with PII could be used to personally identify you.

You also may provide us with PII when you: - submit the contact form on our Website - complete a survey - submit a product testimonial - subscribe to our Website Services, email notifications and/or newsletters - provide comments on our blog - engage in any other transactions between you and us on or in relation to our Website or Services.

How We Use Your Information

TalentCircles, Inc. will use Information we Automatically Collect to:

Improve your experience on our Website and our Services, to count users who visit our Website or open our HTML-formatted email messages, improve the delivery of our web pages to you to help us better manage content on our Website by informing us what content is effective and by helping to measure traffic on our Website.

We may use IP addresses to help diagnose problems with our server, administer our Website, analyze trends, track users' movement, gather broad demographic information for aggregate use in order for us to improve the Website, and deliver customized content.

TalentCircles, Inc. will use PII to: Respond to your inquiries, and/or other requests or questions - enable your use of the Services available on our Website and to send you:

• information and updates related to inquires - email notifications which you have specifically requested - email marketing communications relating to our business which we think may be of interest to you - email messages containing company news, product or service information.

Sharing PII with Third Parties

We may use third parties to perform certain services on our behalf. We may share your PII with these third parties solely to enable them to perform the services for us. Such third parties include hosting our Website/Networks, managing the functionality of our Website/Networks and enabling us to send you email.

We require that those third-party vendors maintain at least the same level of confidentiality that we maintain for such information. We do not provide your PII to parties unconnected with the Services we provide. Your information will not be sold to nor will it be exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering a product or Service.

Posting in Public Areas Of Our Website/Network

You may choose to participate in our message boards, chat rooms and other public areas (together "Public Spaces") where you may be able to engage in social networking, interact with others, and submit writings, video and/or audio recordings, computer graphics, pictures, questions, comments, testimonials, suggestions or other content, including PII. If there is information that you do not wish to disclose to everyone we suggest you do not post it. Anything you post to Public Spaces on our Website is public. Others will be able to view and access it and they may be able to use it and share it with third parties. The protections of this privacy policy will not cover your disclosure of information or content in Public Spaces. Carefully consider anything you intend to post before you post and use caution.

Testimonials

-We will obtain your consent prior to posting any testimonial with your name. If you post such content, it will be available to other users of the Website. Your posting may also become public and we cannot prevent such information from being used in a manner that may violate our privacy policy or the law. If you would like us to remove or delete your name or testimonial from our Website, you may contact us at privacy@talentcircles.com.

Note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of our Website for a period of time.

Third Party Websites

Our Website/Networks may contain links to third party content or websites that TalentCircles, Inc. does not control. This includes links from clients and partners. NOTE: if you click on these links and enter a third party's website these third parties may use their own Cookies to collect data or solicit PII. You should read the third-party website's privacy policy to learn how they will collect and use your information as their policies may differ from ours and will apply to your use of their website.

Our Website makes it easy for you to access social media with features such as a Share-This button, widgets, and other interactive programs. These features may collect your IP address, track which page you are visiting on our Website, and set Cookies. Treatment of any information shared with third party websites when you use these features are governed by the privacy policy of the company providing them.

TalentCircles, Inc. is not responsible for the treatment of your PII or any of your information by any third party.

Opting Out

You may opt out of having your PII shared with third parties except as required by law and you may also request updates or changes to your information or your preferences regarding receiving future promotional messages from us. To do this you may contact our Privacy Officer using the information in the Contact Us section of this privacy policy.

Please note that if you opt out of promotional/ marketing emails, you may continue to receive certain communications from us, such as administrative and Service announcements and/or messages about your account/profile.

Changing or Updating Your Information

By contacting us, you can review and change or update personal information you have provided and your subscriptions or preferences regarding information you receive from us. We will implement your requested changes as soon as we reasonably can. When you edit your information or change your preferences, information that you remove may remain in our databases or backup media because it is not always possible to completely remove or delete information from those locations. If you have made any postings in a Public Space of our Website, these cannot generally be removed.

Disclosure of Information/Sharing Your Information

We may disclose your PII (a) to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders or (b) if we sell or transfer all or a portion of our company's business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change or (c) to our subsidiaries or affiliates only if necessary for business and operational purposes or (d) to our vendors if necessary in order to provide you with Service as further described below.

Without your express consent, your information will not be sold, exchanged, transferred, or given to any other entity, other than companies acting as our agents to perform task(s) on our behalf and under our instructions, for any reason that is not compatible with the reason that you originally shared the information (except as described above).

If you do agree to allow us to share your PII with third parties for other reasons, you may opt in by emailing your consent to privacy@talentcircles.com. You may revoke this permission (opt out) at any time. See the section 'Opting Out' for more information.

We reserve the right to use, transfer, sell, and share aggregated, anonymous data, which does not include any PII, about our Website users as a group for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients and customers.

Except as provided in this privacy policy, we will not provide your information to third parties.

Notice to California Residents - Your California Privacy Rights

California's "Shine the Light" law, Civil Code section 1798.83, permits residents of California to request information about how a business shares their information with third parties for direct marketing purposes. However, under that law, a business is not required to provide this information if it has a policy not to disclose personal information of customers to third parties for the third parties' direct marketing purposes if the customer has exercised an option to opt out of such information sharing. We have such a policy and we will not share your information with third parties for their direct marketing purposes without your consent. If you would like to opt out of our sharing of your information with third parties for their direct marketing purposes or to find out more about your opt out rights, please contact our Privacy Officer by emailing privacy@talentcircles.com or writing to us at our mailing address as described in the 'Contact Us' section of this privacy policy.

Terms Applicable to Users Of The Platform

How the Platform Operates

The Platform enables our Company to create Talent Networks and allows Users to join these Networks. The Platform also allows Third Party Application Developers to develop Third Party Applications for use on the Platform. This privacy policy refers to Talent Networks created on the Platform as "Networks" and refers to Users who create Networks as "Recruiters." Users who join a Network are "Members" of that Network. Recruiters are also considered Members of the Networks they create.

Collection Of PII

In order to use the Talent Network, both Recruiters and Members must register for account credentials. When you register for account credentials, you elect to share certain personal identifying information (called "PII"). PII may include your name, email address, and a password that you create. Recruiters and Third Party Application Developers might use the Platform to collect, use, and retain part of or all information, including PII and Network Data, that is disclosed and uploaded by Members in connection with their use of Networks. "Network Data" means all data shared from a Network or Member and includes registration information (including the Internet protocol (IP) address used by a Member at the time of registration), profile data, answers to Network profile questions, all Content and other information contributed by Members, and statistical information and analytics relating to usage and interactions within the Network. When a User signs up to become a member of a Network, he or she is providing PII to that Network's Network Creator and such Network Creator and its designated administrators will have access to all PII and Network Data associated with any such Network. In addition, Recruiters will have the ability to reset Member passwords in the event that a Member loses or cannot remember it. Recruiters and Third Party Application Developers might also collect additional types of PII. Additionally, for each Third Party Application that you add to your Network or your profile, you should check with the Third Party Application Developer regarding its policies governing its collection, use and disclosure of PII.

Information Received From Third Party Sources

We may also obtain information, including PII, from third party sources. This includes certain PII that may be provided to us through the installation and use of our Platform's Applications on third party websites. If we directly combine information from other third parties with PII that we collect on the Platform, we will treat the combined information as PII and handle it in accordance with this privacy policy.

How PII Is Used

We may use PII to operate, provide, improve, and maintain the Platform, and our other Services and systems; to develop new products and Services; to prevent abusive and fraudulent use of the Platform and our other Services and systems; to send you administrative messages, and information about Networks, content; and for other administrative and internal business purposes.

When PII Is Disclosed

We do not sell or rent email addresses and other PII. We do not share PII with third parties except in the limited circumstances described in this privacy policy.

Our Platform's Service Providers

We may provide PII to third parties for their use in performing internal business functions (e.g., maintenance, security, data analysis, email transmission, or data hosting) on our behalf.

Recruiters

The Network Creator and their designated administrators of that Network have access to all Network Data that is shared on a particular Network and are required to comply with applicable laws (e.g., CAN-SPAM) and not to use or disclose Network Data or PII in a manner that violates this privacy policy. In particular, a Network Creator and the designated administrators of that Network have access to each Member's IP address, captured at the time of registration, for the purpose of blocking further sign ups from a particular IP address and otherwise preventing abuse on a Network, such as spam and malware. Please ensure you are comfortable with the accessibility of this data before becoming a Member of a Network. Your registration to become a Member of a Network constitutes your acknowledgement and agreement that if you have voluntarily provided information to our Platform or Recruiters that causes your IP address to link to personally identifying information, our obligations with respect to use and disclosure shall be the same as those that apply to any other PII provided hereunder.

Affiliates

We may share some or all of your PII with our parent company or any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us (collectively, "Affiliates"), in which case we require those Affiliates to honor this privacy policy.

Legal Requirements

We may disclose PII if we have a good faith belief that doing so is required by a subpoena or other judicial or administrative order or otherwise required by law. Additionally, we may disclose PII where we, in good faith, deem it appropriate or necessary to prevent violation of the Terms of Service, or our other agreements; take precautions against liability; protect the rights, property, or safety of our Platform, any individual, or the general public; maintain and protect the security and integrity of our Services or infrastructure; protect ourselves and our Services from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against third party claims or allegations; or assist government enforcement agencies.

Change of Ownership

In the event of a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we reserve the right to transfer all of your PII, including email addresses, to that entity. We will notify registered users in advance of such a transfer by a posting on our home page or elsewhere on the Platform and by sending an email to Members' email addresses as provided to us.

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration.

Security

We use industry standard security measures to protect against the loss, misuse, and alteration of PII under our control. Although we make good faith efforts to maintain the security of such PII, we cannot guarantee that it will remain free from unauthorized access, use, disclosure, or alteration. Further, while we work hard to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent "hackers" or other unauthorized persons from illegally accessing or obtaining this information. To help maintain the security of your account credentials, please keep your password secure. If we learn of a security breach, we will attempt to notify you electronically so that you can take appropriate protective steps. By using the Platform or providing PII to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Platform. If a security systems breach occurs, we will post a notice on our homepage, or elsewhere on the Platform and will send notice to you by email at the email address you have provided to us.

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration.

Privacy Settings and Profile Updates

You may, at any time, update, correct, or delete certain categories of PII that you have provided to us by signing in to your Network and updating the information. Additionally, you may update, correct, or delete certain categories of PII within your profiles on Networks by following the directions on the Network's "Account Settings" page. Members and Recruiters may restrict who may see certain aspects of their profile by following the directions on the Network's "Account Settings" page. Members may also, at any time, elect to leave a particular Network and delete their content on such Network by contacting us through the Support link at the bottom right of each page.

We will retain your PII for as long as your account status is active or as needed to provide you Services. We will retain and use your PII as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will provide you the option to delete your account profile with your PII permanently.

Email Communications And Unsolicited Commercial Email

We may send you administrative messages, and updates regarding your account, the Platform, and our Services, by email. Recruiters may also send administrative or promotional messages to the extent permitted by applicable law and the Terms of Use. You can choose to opt out of receiving messages from our Talent Network by following the directions on the bottom of the email message you receive. The Terms of Use prohibit Users from engaging in any activity involving the sending of email in violation of applicable law, including CAN-SPAM and other laws regulating unsolicited commercial email. Violations of these policies may result in immediate termination of service and legal action against any senders or initiators of such messages.

Third Party Services

The Platform, and Networks, may contain links to websites and services provided by third parties. Any PII you provide on third party websites or services is provided directly to that third party and is subject to that third party's policies governing privacy and security. We are not responsible for the content or privacy and security practices and policies of these third-party websites or services. We encourage you to learn about third parties' privacy and security policies before providing them with PII. Recruiters can enable "Social Sign In," which allows Members to share their account credentials from certain third-party services (such as LinkedIn, Facebook or other services) to sign in or sign up for a Network. As part of the sign-up process, the third-party service will transmit certain information used to complete the new Member's profile page, including name, email address and, where available, profile photo, birthdate, gender and location. Any of the shared profile information, except for email address, can be updated or changed during sign up. The email address as well as personal and professional information can be changed after sign-up. Recruiters can allow Members to share or "Like" content via Share Links or third-party Services (such as Facebook and Twitter).

International Users

The Platform may be hosted in the United States or in the European Union, based upon the requirements of our client/ Talent Network. If you use the Platform from the European Union, or any other region with laws governing data collection and use that may differ from U.S. law, please note that we may transfer your personal data to the United States. The United States does not have the same data protection laws as the European Union and other regions. By providing PII under this privacy policy, you consent to the use of PII in accordance with this privacy policy and the transfer of your PII to the United States.

Terms Applicable to All Users

Cookies and Web Beacons

A "Cookie" is a small file stored on your hard drive that contains information about your computer. We may use Cookies to enable us to track and target your interests for the purpose of enhancing your experience on our Website or Platform.

We may use web beacons (also known as clear GIFs) to access Cookies and count users who visit our Website or Platform or open our HTML-formatted email messages. Web beacons are single-pixel graphic files with a unique identifier, similar to Cookies. Web beacons are embedded invisibly on Web pages and are stored on a user's hard drive. You can modify your browser settings to control web beacons.

The information that is shared using these automated methods may include, for example, your IP address, Cookie information, a unique device or user ID, browser type, system type, the content and pages that you access on the Platform or Website, and the "referring URL" (i.e., the page from which you navigated to the Platform or Website). We also use Persistent Cookies on the Platform, that are stored on your computer, to recognize your account credentials (e.g., for sign in purposes), and to store references to your account credentials and session validators on your hard drive. Passively-collected information is used to administer, operate, and improve the Platform, Website and our other Services and systems, and to provide Services and information that are tailored to you. If any information gathered through passive means is combined with PII, we treat the combined information as PII under this privacy policy. Otherwise, information collected by passive means is used in aggregated or other non-personally identifiable forms.

The use of Cookies is industry standard, so your browser may be set to accept Cookies. If you would prefer not to accept Cookies, you can alter the configuration of your browser to reject all Cookies or some Cookies. Note, if you reject certain Cookies, you may not be able to access all of the features on our Website or Platform.

Our Website may also contain third-party Cookies from advertising partners. To opt out of these type of Cookies, visit the Network Advertising Initiative (NAI) website by visiting http://www.networkadvertising.org/choices/. Even if you opt out through the NAI website, you can still receive communications you have signed up to receive from us unless you opt out of those by using the information in the Opting Out and Updating Your Information sections of this privacy policy.

Security

TalentCircles, Inc. has implemented and follows commercially reasonable measures to protect against unauthorized access to and unlawful interception or processing of PII. Unfortunately, data transmission over the Internet is never 100% secure so we cannot guarantee the security of any information you transmit to us or from our Website therefore you use our Website at your own risk.

Changes to this Privacy Policy

We may update this privacy policy from time to time by posting a new version on our Website. We will post a notice on our homepage, or on the Platform, in advance of such changes. You should visit this page occasionally to ensure you agree with any changes. We will post our revised privacy policy on our Website and update the "Effective" date above to reflect the date of the changes.

By continuing to use our Website or Platform after we post any such changes, you accept the privacy policy as modified.

Questions or Concerns, Contact Us

If you have any questions about this privacy policy or our treatment of your information, please write to us our Privacy Officer by email at privacy@talentcircles.com

or by postal mail at
Attn: Susan Magrino, Privacy Officer
TalentCircles Inc.

P.O. Box 11134

Piedmont, CA 94611

If you need to communicate with us regarding your credit card or other payment information please contact us by phone at our designated customer support number. Do not include any account numbers in your email as email is not a secure form of communication.

Dispute Resolution for EU Safe Harbor Claims and U.S.-Swiss Safe Harbor Claims

If a complaint or dispute cannot be resolved through TalentCircles Inc.'s internal process, TalentCircles Inc. has agreed to cooperate with the EU Data Protection authorities and the Swiss Federal Data Protection and Information Commissioner and to participate in the dispute resolution procedures of the panel established by the EU Data Protection authorities.