Openwork Privacy Policy

At Openwork Holdings, LLC (our “Company,” “us,” “we,” or “Openwork”), we believe in protecting the private information of our customers, employees, and other users. We have developed this Privacy Policy to describe for you, as a user of recruiting and staffing services (“Services”) provided by one or our subsidiary entities (our “Portfolio Companies”), how we collect your information, how we use it, with whom it may be shared, and your choices about such uses and disclosures. It also covers your access to the websites we maintain for our Portfolio Companies (the “Websites”). Finally, this Privacy Policy applies to both our customers, which are generally companies seeking job applicants or temporary staffing (“Clients”) and the individuals we recruit on behalf of those Clients (the “Workers”). We sometimes refer to Clients and Workers collectively as the “Users.”

We encourage you to read this Privacy Policy carefully before using the Services of any of our Portfolio Companies, or otherwise sharing information with us. By using our Services or accessing the Websites, you are accepting the practices described in this Privacy Policy. If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us.

How we use the information we collect

In general, we may use information that we collect about you to:

• If you are a Worker, determine your eligibility to work in the United States, to check your background and credentials/qualifications, verify your references, and verify your identity for regulatory purposes;
• Deliver or help coordinate the Services that you have requested from us;
• Send you offers and promotions for Services;
• Manage your account and provide you with customer support;
• To prepare and deliver tax documents, such as W-2s;
• Send administrative information to you, such as information regarding the Websites, our Services, and changes to our service terms;
• Perform research and analysis about your use of, or interest in, products, services, or content offered by our Portfolio Companies, or the products, services and content offered by others via the Websites;
• Communicate with you by email, postal mail, telephone and/or mobile devices, or send newsletters or other information about events, products or Services;
• Carry out our ordinary business purposes, such as performing data analysis and audits; ongoing fraud monitoring and prevention; developing new products or services; enhancing, improving or modifying our products and services; identifying usage trends; and determining the effectiveness of our promotional and recruiting campaigns;
• Enforce our terms and conditions or otherwise comply with legal obligations; and
• Perform any other functions described to you at the time of collection.

We may use your financial information (such as bank or investment account numbers, payment account information, social security number, and other sensitive data) to pay you in the ordinary course of our business.

Information we collect about you

When you use the Services or access the Websites, we collect information from and about you, your devices, and your interactions with us. Some of this information identifies you directly or can be used to identify you when combined with other data. Such information could include:

Voluntary Information. We may collect and store any personal information you manually enter into the Websites or submit to us by application. This includes identifying information such as your name, address, e-mail address, telephone number, financial information (such as bank account numbers) and other personally identifiable information. For Workers, it includes all resume and CV details, including your previous employers, educational background, and other information you choose to provide us. You will generally provide this information to us when you create request Services, apply for a job, or otherwise seek to do business with us. It could also be obtained when you contact us with questions or for customer support, fill out surveys, or otherwise voluntarily engage with Openwork or a Portfolio Company’s representatives. Similarly, if you are a Worker, we may receive sensitive information about you from our Client, which is your employer.

Location Information. The Websites may collect and process location information, if you allow it. If location services are enabled, we collect your device’s precise location when you open and/or use the Websites, as you have authorized. This enables us to display relevant data based on your location, thereby enhancing your user experience. Please refer to your device or web browser’s user guide for more information.

Usage Information. We collect information about your use of the Websites, including the webpages and sections you access, the content you view, and the dates and times of your access. This information could also include the type of browser you use, your IP address and the page you visited before navigating to the Websites. We also collect information about the computer or mobile device you use to access the Websites, such as the hardware model, operating system and version, unique device identifiers, mobile network information, and browsing behavior. All of this enables us to ensure the Websites, and our systems, performadequately based on your device type, as well as to understand how our users engage with us.

You may adjust settings on your mobile device and mobile browser regarding cookies and sharing of certain information, such as your mobile device model or the language your mobile device uses, by adjusting the privacy and security settings on your mobile device. Please refer to the instructions provided by your mobile service provider or mobile device manufacturer. If you enable location services on your mobile device, we may collect the location of your device as described above.

Communications. We collect information about any phone, text message, e-mail, or online messaging function you use to communicate with Openwork or a Portfolio Company. This may include, in addition to the text of such communications, the participants’ phone numbers, the date and time, and the contents of SMS messages. All communications (in any form) between you and our customer service team may be recorded or monitored for quality assurance and customer service purposes in the jurisdictions where it is legal to do so.

Collection and sharing of information by third-party services

Some services we provide you require collection of your information directly by third parties. This includes, for example, the collection of Worker personal information by their employers (i.e., our Clients). Third parties to whom we may disclose personal information generally have their own privacy policies. Those policies will govern theiruse, handling and disclosure of your personal information. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties.

Similarly, there are some places on the Website where you may access other websites that do not operate under this Privacy Policy. You may be taken to a website that we do not control. These third-party websites may independently solicit and collect information, including personal information, from you and in some instances provide us with information about your activities on those websites. We recommend that you consult the privacy statements of all third-party websites you visit.

Finally, we will generally need to share personal information for our normal business purposes, such as by engaging with the companies that process our payroll, administer benefits, perform background checks, or otherwise contribute to the operation of the Openwork ecosystem.

Tracking

We use various technologies to collect information automatically when you access the Websites, including cookies, web beacons and other similar technologies. A cookie is a small text file that is stored in a user’s computer for record keeping purposes. For example, when you access or sign into a Website, we may record your user or member ID, the name on your user or member account, your device ID, or other identifying information in the cookie file on your computer. We also may record your password in this cookie file, if you indicated that you would like your password saved for automatic sign-in. For security purposes, we will encrypt any usernames, passwords, and other user or member account-related data that we store in such cookies. In the case of sites and services that do not use a user or member ID, the cookie will contain a unique identifier. You may delete or decline cookies by changing your browser settings.

How we share and disclose your information

We do not share your personal information with third parties except as indicated below,or when we inform you and give you an opportunity to opt out of having your personal information shared. In particular, we do not share or sell your information to third parties for advertising purposes, except as noted below. We will only share personal information that you provide to us in the following circumstances:

• With your consent. This happens when you submit service requests. For example, if you are a Worker, we may share your information with potential employers when you direct us to submit you for a job opening. In turn, those Users may use and disclose your information in accordance with their own privacy policies.
• To Partners with whom we conduct business. When we partner with other businesses to offer products and services, we may share information with those providers only as needed to provide those products and services and only subject to the terms of this Privacy Policy.
• Other situations. We also may disclose your information:
  • In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
  • When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of Openwork or its Portfolio Companies, our users, our partners, our employees, or others; or to enforce our website terms and conditions or other agreements or policies.
  • In connection with a substantial corporate transaction, such as a divestiture, spin-out, asset sale, merger or consolidation, or in the unlikely event of bankruptcy.
• Aggregated Information. We may share aggregated and non-personal information we collect under any of the above circumstances. We may also share aggregated information with third parties, including advisors, partners and potential or current investors or customers.

How we protect your personal information

Protecting your personal information is important to us, and we take appropriate security measures (including physical, electronic and procedural measures) to help safeguard your personal information from unauthorized access and disclosure. We want you to feel confident in trusting us with your personal information. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information, searches, or other communications will always remain secure.

Changes to this privacy policy

We will occasionally update this Privacy Policy to reflect changes in our practices and services. When we post changes to this Privacy Policy, we will revise the “last updated” date at the top of this Privacy Policy. If we make any material changes in the way we collect, use, and/or share your personal information, we will notify you by sending an email to the email address you most recently provided us in your account, profile or registration (unless we do not have such an email address). We recommend that you check our website from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.

Children under 13

The minimum age to use our Services is 18, and we do not knowingly provide Services to anyone under such age. In addition, access to the Website and our Services are not intended or appropriate for children under 13 years of age and we do not knowingly collect personal information from children under 13. No one under age 13 may provide any information to us in any manner. If we learn we have collected or received personal information from a child under 13, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at (512) 454-9561 or contact@openwork.com.

How to contact us

If you have any questions about this Privacy Policy or our information-handling practices, or if you would like to request information about our disclosure of personal information to third parties for their direct marketing purposes, please contact us by postal mail at 7320 N. Mopac Expy, Suite 101, Austin, TX 78731, attn: Privacy Coordinator, or by email at hi@openwork.com.