Privacy Policy

PY LEARNING, INC. PRIVACY POLICY

Effective Date: August 26, 2018

Introduction

At Py Learning, Inc. ("Py"), we care about your personal data, so we have prepared this document to explain who we are, how we collect, use and share personal information about you, and how you can exercise your privacy rights. "Personal Information" means any information related to an identified or identifiable individual (e.g., name, email, phone number).

If you have questions about Py's use of your Personal Information, please contact us at privacy@getpy.com.

Py is a provider of cloud-based software services that help companies optimize their recruiting and hiring processes, headquartered in San Francisco, CA. We have separated this Privacy Policy into two sections, one that explains how Py collects and uses the Personal Information of visitors to our website (the "Website Privacy Policy"), www.getpy.com, and one that explains how our customers use our recruiting software platform (the "Services") to collect Personal Information from individuals who are either job applicants or employees of our customers (the "Services Privacy Policy"). Please note that the data controller of Personal Information collected through our website is Py Learning, Inc., and the data controller of Personal Information collected through our Services is the Py customer who purchased our Services.

WEBSITE PRIVACY POLICY

PERSONAL INFORMATION WE COLLECT

Py may collect the following information, including Personal Information from and about you:

From your interaction with Sales, Marketing, and Customer Support: We collect Personal Information such as your name, company name, email address and phone number when you request a demo of our Services, or request sales information or customer service.

Cookies, Scripts and Related Technologies: When you visit our website, www.getpy.com, we and our third-party service providers receive and record Personal Information that you may have provided and your digital signature, such as your IP address. The technologies we use to track your movements around our website include cookies, tracking scripts and pixels, and tagging technologies, which we may employ to understand your preferences, improve your experience on our website, etc. You can control the use of cookies at the individual browser level.

Collection of Data by Advertisers: We may also use third parties to serve ads on our website or to manage our advertising on other sites. Certain third party partners may automatically collect information about your visits to this and other websites, your IP address, your ISP, the browser you use to visit our website (but not your name, address, e-mail address or telephone number). They do this by using cookies, pixel tags or other technologies. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our website and the other sites tracked by these third parties. This policy does not apply to, and we are not responsible for, cookies or pixel tags in third party ads, and we encourage you to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technologies.

HOW PY USES YOUR PERSONAL INFORMATION

We may use the information that we collect about you and from you, including Personal Information, for the following purposes:

HOW PY MAY DISCLOSE OR SHARE YOUR INFORMATION

We do not sell or otherwise disclose Personal Information we collect about you, except as described in this Website Privacy Policy or as we disclose to you at the time this information is collected. As described in more detail below, we may share your Personal Information:

Our website may contain links to third party websites or third party applications ("apps"). When you click on a link to any other website, app or location, you will leave our website and go to another site and another entity may collect Personal Information or anonymized data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Website Privacy Policy do not apply to these outside websites, apps or content, or to any collection of your Personal Information after you click on links to such outside websites or apps. We encourage you to read the privacy policies of every website you visit or app you use. The links to third party websites, apps or locations are for your convenience and do not signify our endorsement of such third parties or their products, apps, content or websites.

HOW PY HOLDS AND SECURES YOUR INFORMATION

We care about the security of your Personal Information, and take appropriate steps including technical and organizational measures to ensure that your Personal Information is treated securely and in accordance with this Website Privacy Policy. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Information.

INTERNATIONAL DATA TRANSFERS

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, our Website servers are located in the United States, and our third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries. However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Website Privacy Policy.

If you are a visitor from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the Personal Information concerned and the specific context in which we collect it.

However, we will normally collect Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Information from you or may otherwise need the Personal Information to protect your vital interests or those of another person.

If we ask you to provide Personal Information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at privacy@getpy.com.

HOW LONG PY RETAINS YOUR PERSONAL INFORMATION

We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

YOUR DATA PROTECTION RIGHTS

You have the following data protection rights:

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Services Privacy Policy

This Services Privacy Policy does not apply to our customers, who manage the Personal Information they collect through our Services in accordance with their own privacy policies. Py only processes the Personal Information that is stored in our Services as a data processor on behalf of our customers and in accordance with their instructions (as defined in our customer agreements), and we have no direct relationship with the individuals whose Personal Information we process in connection with our customers' use of our Services. For example, if you apply to a job posted on a career page of a prospective employer that is one of our customers, your Personal Information will be automatically transferred to Py. However, the prospective employer is the data controller and you should contact that entity directly with any questions you may have regarding its privacy policies or data processing practices, and if you want to modify your Personal Information, restrict its processing, or delete it from our Services.

PERSONAL INFORMATION WE PROCESS

Py processes certain Personal Information input or uploaded into our Services by our customers' employees and prospective employees, including name and contact information.

Py will use such Personal Information only as necessary to provide and deliver the Services to the customer, to prevent or address any service or technical issues, to respond to a customer's support request, or for any other purpose provided for in the customer agreement, or in accordance with or as may be required by law.

HOW PY USES YOUR PERSONAL INFORMATION

Py may access or use the Personal Information collected through the Services for a range of reasons, which may include:

HOW PY MAY DISCLOSE OR SHARE YOUR INFORMATION

We do not sell or otherwise disclose Personal Information we process in our Services, except as described in this Services Privacy Policy or as we disclose to you at the time this information is collected. As described in more detail below, we may share your Personal Information:

Our customers may choose to integrate their Py accounts with other third party service providers. While we try to choose integration partners that share our standards for privacy, their websites and services are outside of our control and are not covered by this Services Privacy Policy, and we are not responsible for their content, security, or privacy practices.

HOW PY HOLDS AND SECURES YOUR INFORMATION

We care about the security of your Personal Information, and take appropriate steps including technical and organizational measures to ensure that your Personal Information is treated securely and in accordance with this Services Privacy Policy. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Information, and to protect it loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Such measures shall include, as appropriate:

INTERNATIONAL DATA TRANSFERS

Your Personal Information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, Services are hosted on servers located in the United States, and Py and its subprocessors are in the United States as well. This means that your Personal Information is processed in the United States. However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Services Privacy Policy.

If your use of the Services requires Py to process Personal Information falling within the scope of GDPR, you may obtain and execute Py's Data Processing Addendum ("DPA") by contacting us at privacy@getpy.com.

If you are a visitor from the EEA, our legal basis for collecting and using the personal information described above will depend on the Personal Information concerned and the specific context in which we collect it.

However, we will normally collect Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Information from you or may otherwise need the Personal Information to protect your vital interests or those of another person.

If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), we (or the relevant third party) will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at privacy@getpy.com.

HOW LONG PY RETAINS YOUR PERSONAL INFORMATION

We retain Personal Information we process where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

Any Personal Information we process on behalf of our customers is retained in accordance with the timeframes set out in the relevant customer agreements.

YOUR DATA PROTECTION RIGHTS

You have the following data protection rights:

Please note that you should direct any requests related to the data protection rights described above to the Py customer who holds the relevant Py account. As a data processor of any Personal Information stored and processed on the Services, Py will not be able to respond directly to such requests and will refer any such requests to the relevant Customer.

CHILDREN'S PRIVACY

We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of our website is directed to children under the age of 13. We will take steps to delete it if we learn we have inadvertently collected it.

If you learn that your child has provided us with Personal Information without your consent, you may alert us at privacy@getpy.com. If we learn that we have collected any Personal Information from children under 13, we will promptly take steps to delete such information and terminate the child's account.

UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

You can see when this Privacy Policy was last updated by checking the "last updated" date displayed at the top of this Privacy Policy.

CONTACT INFORMATION

If you want to provide comments or questions about our Privacy Policy, or to exercise your rights, feel free to contact us at privacy@getpy.com.