PowerToFly Inc. (“PowerToFly”, “we,” “us” or “our”) values your privacy. This Privacy Policy (“Privacy Policy”) describes the types of personal information we obtain through our website at www.powertofly.com (the “Site”) and in connection with our related events and services, how we use the personal information we obtain and with whom we may share it. We will refer to our Site and related events and services together as the “Services.”

Depending on what areas of the Services you use, we obtain different types of personal information from or about you. Our Services are available to prospective employers (each an “Employer”) and to talent who may be seeking employment, who may be of interest to Employers or who register for or participate in our events and other Services (each a “Candidate”). We primarily obtain personal information about Candidates. In addition, we obtain certain personal information about Employers’ representatives who use the Services to find or hire Candidates. Please keep in mind that you may not be able to access some areas of the Site or effectively use the Services without providing your personal information.

1.1 Basic Account Information. When you register for the Site or interact with our Services as a Candidate or Employer, we will ask you to provide your name and email address or to sign up using an existing social media account. If you sign up through a social media account, we will receive information from that account, such as your name, photo, job information and email address associated with that account.

1.2 Candidates Profile Information. If you are registering as a Candidate, we may ask for information such as your phone number, Skype ID, photo, work history, educational background, location, biographical information and skills. Candidates may also volunteer other information.

1.3 Employers. If you are registering as an Employer, we ask for an Employer’s representative phone number and job title in addition to the company name and size.

1.4 Contact Us. If you choose to contact us through our Site, including through our chat box, we may obtain your name, company name, phone number, email address and any other information you choose to submit to us.

1.5 Payment Information. We may obtain payment information from Candidates and Employers in connection with the Services. To process credit card payments, we obtain credit card information, including the card number, expiration date, authorization number or security code and billing information. We use a third party, Stripe, to process payments made through payment cards on the Site. Stripe’s use of your personal information is governed by their privacy policy, which is available at https://stripe.com/us/privacy. We also may obtain your bank account number and routing number in order to make payments to your account.

1.6 Cookies and Other Automated Means. When you visit or use the Site, we and our service providers may automatically collect certain technical information from your browser or mobile device, including through cookies, log files and other technologies. A cookie is a small amount of data (often including a unique identifier), that is sent to your browser from a website’s computers and stored on your computer’s hard drive or mobile device. We may use cookies to improve your experience with the Site, by, for example, allowing the Site to keep you logged in. We may also use cookies to collect aggregate information about Site users. The information collected for these purposes (including your IP address, browser or device information and other information collected by automated means) may be disclosed to or collected directly by our third-party web analytics service providers, such as Google Analytics. To learn more about opting out of these activities, click here: http://tools.google.com/dlpage/gaoptout. If you don’t want cookies, most web browsers include an option that allows you to not accept them. However, if you set your browser to refuse cookies, some portions of our Site may not function efficiently. We do not currently respond to web browser “do not track” signals on this Site.

1.7 Other Information. In addition, we may receive information about you, such as gender, public business profile photos, business contact information, and other employment-relevant details, from public business bio pages or business data providers, which we may combine with other information we have about you.

We use the personal information we obtain for a number of purposes, including, but not limited to:

• provide the Services, including creating and managing your PowerToFly Site account and connecting you with a potential Employer
• send you transactional communications (such as account confirmations and notifications) or promotional and marketing communications
• respond to your inquiries or requests
• communicate about, and administer your participation in, special events, programs, surveys, contests, sweepstakes, and other offers or promotions
• handle billing
• enable you to post on our blog and interact with PowerToFly through social media
• improve our Services, and generate and analyze statistics about your use of the Services
• support our business operations and perform accounting, auditing and other internal functions
• detect, prevent and respond to fraud, intellectual property infringement, violations of law or our terms of use and policies, or other misuse of the Services, and
• comply with and enforce applicable legal requirements, contractual obligations and our policies.

We also may aggregate the personal information we collect through the Site and in connection with our Services (the “Aggregated Data”) and use it for any and all purposes. We also may augment such Aggregated Data with data we obtain from other sources and use it for any purposes.

Interest-Based Advertising

On our Site, we and third parties may collect information about your online activities to provide you with advertising about services or products tailored to your interests. You may see certain ads on other websites because we or such third parties participate in advertising networks. Ad networks track your online activities over time by collecting information through automated means, including through the use of cookies, web server logs and web beacons. The information ad networks may collect includes information about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Site and on third-party websites or apps that participate in the ad networks. This process allows us and third parties to deliver more tailored advertising. In addition, it helps us track the effectiveness of our marketing efforts. To learn how to opt out of this ad network interest-based advertising, click here.

We share personal information about you:

• if you are a Candidate, with Employers who may have job opportunities available or interest in placing job candidates, or with other Candidates who use the Services
• with service providers, including our cloud storage provider, payment processor or chat software provider
• as required by law, such as to comply with a subpoena or other legal process, or to comply with government reporting obligations
• when we believe in good faith that disclosure is necessary (a) to protect our rights, the integrity of the Site or our services, or your safety or the safety of others, or (b) to detect, prevent, or respond to fraud, intellectual property infringement, violations of law or our terms of use and policies, or other misuse of the Services, and
• to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition, or sale of all or a portion of our assets (including in the event of a reorganization, dissolution or liquidation).

In addition, we may share Aggregated Data with third parties for any and all purposes.

The laws in some jurisdictions require companies to tell you about the legal grounds they rely on to use or disclose your personal information. To the extent those laws apply, our legal grounds are as follows:

• To honor our contractual commitments to you: Much of our processing of personal information is to meet our contractual obligations to Candidates or other individuals, or to take steps at their request in anticipation of entering into a contract with them.
• Consent: Where required by law, and in some other cases, we handle personal information on the basis of consent.
• Legitimate interests: In many cases, we handle personal information on the ground that it furthers our legitimate interests in commercial activities such as the following in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
• Facilitating useful connections between Employers and Candidates
• Providing customer service
• Engaging in marketing
• Protecting our customers, personnel and property
• Analyzing and improving our business
• Managing legal issues
• We may also process personal information for the legitimate recruiting interests of Employers.
• Legal compliance: We need to use and disclose personal information in certain ways to comply with our legal obligations.

The Site includes social media functions, such as Facebook and LinkedIn Sign In features, and widgets. These functions and widgets may collect information about you, including the IP address of the device you use to connect to the Internet. Your interactions with the social media platforms, including any functions and widgets they provide, are governed by the privacy policies of the relevant social media companies. We suggest that you review their privacy policies. You acknowledge and agree that we are not responsible for any acts or omissions by any social media site or other third-party service that you choose to use in connection with this Site or our services.

This Site may contain links to other websites, apps or other online services for your convenience and information. These websites, apps and services may be operated by companies not affiliated with PowerToFly. Linked websites, apps or services may have their own privacy policies or notices, which we strongly suggest you review. We are not responsible for the content and data handling practices of any third party websites, apps or services.

You can change your Candidate profile information at any time by editing your profile or the content that you have posted. You can unsubscribe from marketing emails by clicking the “unsubscribe” link they contain. Controls related to cookies and other automated data collection are described in the Use of Personal Information section above.

Residents of the European Economic Area and some other jurisdictions have certain legal rights to obtain confirmation of whether we hold personal information about them, to access personal information we hold about them, and to obtain its correction, update, amendment, or deletion in appropriate circumstances. In limited cases, they have the right to receive information we hold about them in portable form and to have it transmitted to a third party. They also have rights to object to our handling of their personal information, to restrict its processing, and to withdraw any consent they have provided.

For example, individuals have a right to opt out of our processing of personal information for direct marketing purposes.

To exercise your rights, or to have your account deleted, please contact us as described at the end of this Privacy Policy.

Many of the rights described above are subject to significant limitations and exceptions under the applicable law. For example, objections to the processing of personal information, and withdrawals of consent, typically will not have retroactive effect. Individuals also have a right to lodge a complaint with the relevant supervisory authority, but we encourage you to contact us first, and we will do our best to resolve any concern.

We maintain appropriate administrative, technical, and physical safeguards designed to protect the personal information collected through this Site. But, no method of data transmission over the Internet or data storage is 100% secure and therefore, we cannot guarantee the absolute security of any information.

We will retain your information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Information may persist in copies made for backup and business continuity purposes for longer than the original copy of the information.

We are based in the United States, and recipients of the information disclosures described in this Privacy Policy are located in the United States and elsewhere in the world, including where privacy laws may not provide as much protection as the laws of country in which you are located.

The Services are not intended for individuals under the age of 16. We do not knowingly collect personal information from individuals under 16, and no part of the Services are designed to attract anyone under the age of 16. If you become aware that your child has provided us with personal information, please contact us as indicated below.

We may revise our Privacy Policy from time to time. The most current version of the Privacy Policy will govern our use of your personal information and will be located on this webpage. If we make a change to our Privacy Policy that is material, we will notify you by posting a prominent notice on this Site. We also may notify you by email of such significant changes. By continuing to access the Site or otherwise use our Services after those changes become effective, you agree to the revised Privacy Policy.

If you have any questions about this Privacy Policy or any of our data handling practices, please contact us directly at privacy@powertofly.com or by mail to 228 Park Avenue South, Suite 75391, New York, NY 10003, USA.