CompassNet Privacy and GDPR Policy

Welcome to CompassNet, a recruiting service for job seekers and employers. This privacy policy describes how CompassNet (“us”, “we”) uses and protects the personal information it collects about its end users (“you”, “your”). The term “personal information” refers to information that can be used to identify, contact, or locate a single person or that can be used with other information to uniquely identify a single individual.

CompassNet is committed to safeguarding the information of the individuals who interact with its service, and ensuring that your information is used fairly and with your full understanding of how we’ll use it. This policy describes our practices in detail, but in general, here is what you need to know:

• We collect information you enter while using the CompassNet service, information you provide to the employers who have partnered with us, and information collected pursuant to our Cookies Policy. We also track your IP addresses and information about the devices you use when accessing our services.

• We use the information we collect to help to connect with job seekers and employers and to provide other services to you.

• We may disclose information we gain during your use of the CompassNet service to our third-party partners to the extent necessary to provide our services, or to law enforcement upon receipt of a valid legal request.

For users from the EU and Switzerland, please refer to “Personal Data from users in the EU and Switzerland” section of this Policy.

More information about our collection, use and disclosure of your information can be found in the sections below.

DATA COLLECTION

We will gather personal information about you under the following circumstances:

• When you access our website or visit a page that integrates our service: Our service gathers information automatically transmitted from the device(s) you use to access our website or the sites integrating our services, such as your IP address, unique device identifier, browser information, and system (e.g., operating system) information. This information, alone or combined with other information, may allow you to be identified.

• We collect your information such as your contact details, personal details and resume when you send your applications.

• We may collect or use information about you from publicly-available websites whether or not you have submitted your data. You will have the opportunity to claim or request removal of the information. However, we cannot guarantee that we will not later collect from publicly-available websites other information that pertains to you.

• When it is provided to us by third-party sources in connection with your use of our service: Employers affiliated with CompassNet may send us any information you have provided them, including your personal details (e.g., name, contact information) and details regarding your past and current applications sent and activity on their site.

• When you communicate with our customer support team: If you initiate communication with our customer support team, you will be prompted to provide additional information about yourself.

Children under the age of 18 are not allowed to use our service, and we do not knowingly collect or use any information from children or other individuals legally prohibited from using our website. To the extent you believe we have collected any information from children, please notify us immediately so we can take appropriate measures, including by promptly deleting it to the extent we are permitted to do so by law.

DATA USE

We only use your data for the following reasons:

• To offer the CompassNet service: We will use your personal information as necessary to provide the CompassNet service, including to the extent necessary to show you jobs advertisements, receive your applications, respond to you and communicate with you about the service.

• To manage risk and protect you, the site and the CompassNet service: Fraud prevention is a critical part of providing payment services, and we use your information to help us detect and prevent fraud.

• To comply with our legal obligations, including all applicable anti-money laundering laws, anti-terrorist financing laws, financial services regulations, and our contractual obligations to the third-party partners who provide or help to provide any payment method(s) you use on our service.

• For our other legitimate business needs: We may need to use your personal information in order to enforce our contracts and terms of service and monitor activity on the site.

DATA DISCLOSURE

Your data may be disclosed to third-parties in any or all of the following circumstances. Because your privacy is important to us, we have taken measures to ensure that all of the entities we share your information with have implemented strong data privacy and data protection practices of a level comparable to that which we employ.

• When our affiliates need it to help provide the CompassNet service: CompassNet has affiliates around the world that assist it in providing the CompassNet service. We may provide your information to these affiliates for any of the purposes we would ourselves use your information, including carrying out the transaction you requested, preventing fraud or illegal activity, and enforcing our terms and conditions.

• When other third-parties that provide us with services related to the CompassNet service require it in order to provide the services, such as our server hosting providers and independent auditors we engage for the purposes of analyzing our compliance with the law or relevant independent standards.

• To the extent required by law: We will share your information with third-parties to the extent we are required to do so by law. For example, we are required by law to undergo certain routine audits, which may require us to share your information with the third-party auditors we have engaged in relation to these requirements. Additionally, we may have to disclose your information when we receive a valid subpoena or other law enforcement request, or when the law requires us to affirmatively notify law enforcement in order to prevent harm or illegal activity. The necessity of all such disclosures will be determined in our sole discretion. For more information on our procedures related to legal requests, please contact help@compassnet.io.

• To the extent our legitimate business interests require us to do so, for example by transmitting it to our third-party partners for inclusion on their blacklists or lists of terminated merchants, to help us engage in our fraud reduction efforts, to support our corporate governance activities or facilitate the sale or other transfer of all or part of our business, or to protect us or our service.

DATA RETENTION

We are required to retain many types of your personal information by law, often for a period of several years. We may additionally retain your information for a longer period than is required by law to the extent it is in our legitimate business interests to do so (for instance, we may retain it to prevent fraud on our service) and is not otherwise prohibited by law.

DATA LOCATION

We use servers located in the United States and the European Union to store personal information gathered by the CompassNet service. Additionally, to the extent we transfer your information to a third-party, including our affiliates, as described in this policy, these third-parties may be located outside our usual business location and your country of residence. In all such cases, data transfers will be carried out only after we ensure the third-party provides comparable levels of data protection and that they will use your information only for the purposes set out in this policy.

END USER QUESTIONS AND ACCESS

Please feel free to contact us if you have any questions about our privacy practices via help@compassnet.io.

Users located in the EU: To exercise your right of data access, correction, or deletion, please send the privacy request form to support@compassnet.io, though in all cases we may not be able to comply where we are prohibited from doing so by other legal obligations. Note that photo identification may be required in order to grant individual access to their requested personal information. For further questions and concerns, you may reach our Data Protection Officer at dataprotection@compassnet.io. If you are not satisfied with the way we resolve your inquiries, you have the right to lodge a complaint with the Supervisory Authority for data protection located in your country of residence.

UNSOLICITED E-MAILS

CompassNet Ltd does not send unsolicited e-mails to private addresses or to anyone who has asked to remove from all CompassNet Ltd email lists. Any newsletters that we send are only sent to those who have subscribed to them. To stop receiving e-mails or newsletters from CompassNet, click on the unsubscribe link in the e-mail or newsletter.

Please feel free to contact us at help@compassnet.io if you have any questions about our privacy practices.

PERSONAL DATA FROM USERS IN THE EU AND SWITZERLAND

This policy applies to the data collected by CompassNet about its employees and candidates based in the European Union. Different rules and policies may apply to our employees and candidates based in offices outside the EU.

In this privacy policy, “CompassNet,” “us,” “we,” and “our” refers to CompassNet Inc., and its global affiliates. “You” or “your” refers to employees and candidates of CompassNet, as applicable. “Personal information” means any information that, alone or when combined with other combination, will allow an individual to be identified.

What information do we collect from our potential and newly hired employees?

• When you apply: When you apply, you will be prompted to provide us with basic personal information about you, such as your name, address, email address, nationality, phone number, past job history, and level of educational attainment. In addition to all information you enter on the application form, any information you provide us verbally during the hiring process may be written down in note form and saved to your file by the individual conducting the interview or other conversation on CompassNet’s behalf. If you provide reference information to CompassNet, we may also contact the references you listed and receive additional information about your past employment history from them.

• When you’re hired: Upon signing an offer of employment from CompassNet, you will be asked to provide your banking information, emergency contact name and phone number, your national identity number (for example, social security number), a copy of your national identity documents (such as a passport or driver’s license), your date of birth, and other information as legally required or is within our legitimate business needs to obtain from our employees.

WHERE WE STORE THIS DATA

Because CompassNet is a global company, we use servers located in the United States and the European Union to store personal information gathered about CompassNet employees. Additionally, to the extent we transfer your information to a third party, including our affiliates, as described in this policy, these third parties may be located outside our usual business location and your country of residence. In all such cases, data transfers will only be carried out after we ensure that your data will be given the same level of protection as required by EU law.

HOW WE USE YOUR PERSONAL INFORMATION

Personal information collected about potential and actual CompassNet employees will only be used for the reason it was collected – to make employment decisions, facilitate the employment relationship, and for our other legitimate business needs. We may also use it to the extent required by law in order to ensure our compliance with all the regulations to which we’re subject.

Circumstances under which we might disclose your information to third parties.

• For purposes of running a pre-employment background check, we may disclose it to a third party service we have engaged to perform such background checks on our behalf;

• To the extent required by law, for instance in cases where illegal conduct is suspected, we receive a valid subpoena or other legal request, or to satisfy requirements under employment law;

• To our affiliated entities as necessary to provide our services and conduct business;

• To third party partners and potential partners to the extent disclosure of certain basic details (name, email, job title) is necessary in order to facilitate business relationships.

What are your rights regarding data we have collected?

• You have the right to request all a copy of the personal information we have collected about you;

• You have the right to request a correction of any of your personal information;

• You have the right to request that we delete all personal information about you.

The foregoing rights only apply to the extent we are permitted to perform the relevant actions under all applicable laws. What this means is that anti-money laundering or employment laws, among others, may require us to decline certain requests you make regarding your personal information.

RESOLVING DATA PRIVACY CONCERNS

CompassNet maintains a comprehensive data privacy program to ensure the adequate protection of all personal information in its possession, including that of its employees. All complaints will be resolved in accordance with our complaint procedures and internal data privacy rules. If you are not satisfied with the way we resolve your inquiries, you have the right to lodge a complaint with the Supervisory Authority for data protection located in your country of residence.