Candidate Privacy Policy

SeekOut Spot is a talent sourcing and recruiting service that matches qualified candidates with open roles at prospective employers. We also offer candidates the ability to engage with our career tools such as CareerSpot. SeekOut is committed to data privacy and protection as a core value and governing principle for our company, including at all times during the candidate experience.

This Candidate Privacy Policy (this “Privacy Policy”) explains:

• How ZipStorm, Inc., the provider of the SeekOut Spot services (“SeekOut”, “we”, “our”, or “us”) collects, uses, and shares personal information in order to provide the SeekOut Spot talent sourcing and recruiting services and to offer our career tools such as CareerSpot (the “Services”); and

• How you can exercise your privacy rights with respect to the personal information we collect.

This Privacy Policy does not apply to information we collect:

• In connection with providing and maintaining the SeekOut subscription platform and the SeekOut Candidate Database;

• When you visit our websites (including www.seekout.com and www.seekout.ai), our applications, or online services provided by us in connection with the SeekOut subscription platform; or

• When you submit an application for a job with SeekOut.

For information about our privacy practices related to the SeekOut subscription platform, SeekOut Candidate Database, website visitors, and SeekOut job applicants or to exercise your rights with respect to such data, please visit the SeekOut Privacy Policy located at www.seekout.com/privacy.

In this Privacy Policy, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. For the purposes of European data protection law, SeekOut is the data controller of your personal information as described in this Privacy Policy.

1. Personal Information We Collect

Prospective employers engage the SeekOut Spot Services to source and recruit qualified candidates for open job opportunities. Candidates engage with our career tools, such as CareerSpot, to learn about open job opportunities and receive guidance on job search plans, resume updates, interview prep, and networking advice. To provide the Services, we may collect personal information in the following ways.

Information You Provide to Us

If you elect to interact with SeekOut’s recruiters and the Services about open roles with prospective employers, including via email or by participating in screening interviews, you may be asked to voluntarily provide personal information. If you elect to engage with our career tools such as CareerSpot, you may also voluntarily provide personal information. Personal information you share could include name, contact information, professional qualifications, experience, skills, preferences, expectations, or interests.

Information Obtained from Other Sources

To provide the Services, we also collect data about potential job candidates from the SeekOut Candidate Database; information licensed from other companies; publicly available information; and interactions between candidates, the Services, and our recruiters. Prospective employers may also elect to share candidate information from their applicant tracking system. Data about potential job candidates includes name, contact information, education, professional qualifications, work history, work title, experience, and skills, as well as inferred information and assessments.

Via Recorded Meetings and Interviews

We may ask to record a call or video meeting with you. You may also elect to record interview answers to receive feedback, guidance on job search strategy, and enable job matching in the Services.

If we intend to record a call or video meeting, you will be notified in the meeting invite that you receive from us; through a notification from the third-party technology provider that we propose to use; and/or at the beginning of the call or video meeting.

• If you accept the invite, we will consider this your consent to being recorded.

• If you do not want your visual to be recorded, you have the option to switch off your camera during the meeting.

• If you do not want your audio to be recorded, please decline the meeting invite.

• If you accept the meeting and subsequently change your mind, you have the option to withdraw your consent by declining the meeting before the meeting commences.

If you elect to record interview answers in the Services, you will be notified prior to the interview. If you proceed with the recorded interview, we will consider this your consent to being recorded. If you do not want your visual to be recorded, you have the option to switch off your camera during the interview. If you do not want your audio to be recorded, please do not participate in the interview.

Information Collected Automatically

If you use our Services, we may automatically collect personal information from your device, including:

• Log Information: Including browser type and settings, access times, pages viewed, your IP address, and the page you visited before navigating to our websites.

• Device Information: Including the hardware model, operating system and version, unique device identifiers, and mobile network information related to your computer or mobile device.

• Location Information: Approximate location derived from your IP address.

• Usage Information: Including the content you view, features you use, and the frequency and duration of your activities.

• Cookies and Other Tracking Technologies: SeekOut and our service providers may collect personal information about your browser and device using various technologies, such as cookies and web beacons. We use cookies (small data files stored on your hard drive or in device memory) to count visits and traffic sources, see which areas and features of our Services are popular, and customize your browsing experience. We use web beacons (electronic images or pixels) to help deliver cookies, count visits, understand website usage, and measure marketing campaign effectiveness. You may disable the use of such cookies at any time by using your browser settings.

Information Collected About Children

We do not knowingly collect any personal information directly from children under the age of 18. If we discover we have received any personal information from a child under the age of 18, we will take reasonable steps to delete that information as quickly as possible. If you believe SeekOut has personal information about anyone under the age of 18, please contact us at privacy@seekout.com.

2. Use of Personal Information

SeekOut uses personal information relating to candidates to provide the Services, including to:

• Identify job candidates for open roles with prospective employers;

• Match candidate qualifications with job requirements;

• Notify job candidates of open roles that may be of interest to them;

• Provide recommendations and profiles of job candidates to prospective employers;

• Enable candidates to access and use the Services; and

• Communicate with candidates regarding the Services.

3. Disclosures of Personal Information

The personal information we collect about you will only be disclosed as described below and pursuant to this Privacy Policy:

• To Prospective Employers. If we identify you as a potential match for a job opportunity with a prospective employer, we may share your information with that employer.

• To Service Providers. We disclose personal information to our service providers who enable us to provide our Services, such as our hosting and technology providers. These service providers act on our behalf and are authorized to use your personal data only as necessary to provide services to us.

4. International Data Transfers

In providing our Services to certain customers, we transfer data from international jurisdictions (including European Economic Area (EEA) countries) to the United States. As a result, 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 than the laws of your country. We are committed to transferring personal information in accordance with applicable law, and we implement appropriate safeguards to protect your personal information in accordance with applicable law. In addition to our organizational and technical safeguards, we enter into data processing agreements where appropriate, including standard contractual clauses (SCCs) where applicable.

5. Data Retention

We retain your personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law, whichever is longer.

When we have no ongoing legitimate business need to process your personal information, we will delete 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. In some circumstances, we may anonymize your personal information so that it can no longer be associated with you, in which case it is no longer personal information.

6. Third Party Websites, Services, and Applications

The Services may include links to third-party websites, services, and applications that are not owned or operated by SeekOut. This Privacy Policy does not apply to those websites, services, or applications, which may have their own privacy policies or notices that you should review to understand how they may collect, use, or disclose your personal information. SeekOut is not responsible for the content or privacy practices of any linked websites, services, or applications that are operated by third parties.

7. Your Rights and Choices

Depending on where you reside, you may have the following privacy rights related to the personal information that we collect:

• Right to Know: You may request that we disclose what personal information we have collected, used, disclosed, sold, or shared about you, and how it is used and disclosed;

• Right to Data Portability: You may receive your personal information in a structured, commonly used, and machine-readable format, and you have the right to transfer this information to another data controller;

• Right to Delete: You may request that we delete the personal information we have collected from you (with some exceptions) and request that our service providers do the same;

• Non-Discrimination: You have the right not to receive discriminatory treatment for the exercise of your privacy rights under applicable law;

• Right to Correct: You may request that we correct inaccurate personal information that we have about you;

• Right to Restrict Processing: You may request that we restrict the processing of your personal information;

• Right to Object: You may object to the processing of your personal information on certain grounds; and

• Right to opt-out of sharing/targeted advertising: You may opt out of the “share” or use of your personal information for targeted advertising.

• Right to ask us to stop sharing your information with employers: You may request that we cease sharing your information with a particular employer or with any potential employers at any time.

If you wish to exercise any of these privacy rights, please submit a request via the Privacy Choices Portal or via email at privacy@seekout.com.

In order to protect your personal information from unauthorized access or deletion, we may require you to verify your identity before we can process a privacy request related to your personal information. If we cannot verify your identity, we may be unable to comply with your request to provide, correct, or delete your personal information.

8. Additional Information for Individuals in Certain U.S. States

This section provides additional information for residents of California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia relating to their privacy rights under the consumer privacy laws enacted in those states that grant their residents certain rights and require additional disclosures (“State Laws”). If you are a resident of one of these states, this section applies to you.

This Privacy Policy describes the categories of personal information we have collected, disclosed for a business purpose, or sold. Please refer to the “Personal Information We Collect”, “Use of Personal Information”, and “Disclosures of Personal Information” sections above to see specifically what personal information is collected about you and how and to whom we disclose that personal information. As required by certain State Laws, below we use tables to explain this same information, including the categories of personal information we collect, types of entities to which we disclose such information, and the ways we use each category of information.

Collection, Use, and Disclosure of Personal Information for Business Purposes

Disclosure of Personal Information to Potential Employers

The purpose of the Services is to source and recruit potential candidates for job opportunities with prospective employers. To match potential candidates with prospective employers, we provide professional information about such candidates to the prospective employers. Such disclosures are further reflected below. We do not disclose personal information from the Services to third parties for purposes of targeted advertising.

Privacy Rights

For information on privacy rights available under the State Laws and how to exercise your rights, see the Your Rights and Choices section above.

Authorized Agents

If you are an authorized agent seeking to make a request to opt out of sales, sharing, or targeted advertising on behalf of a consumer, please submit your request via the Privacy Choices Portal. California residents may also use an authorized agent to submit privacy requests on their behalf. If you would like to submit a request as an authorized agent on behalf of a California resident, please submit the request via the Privacy Choices Portal.

Upon submission, the authorized agent will be required to upload documentation showing proof of written permission from the resident authorizing the agent to submit a request on their behalf. We reserve the right to require residents to confirm their request and/or identity. We may deny a request from an agent that does not submit proof that they have been authorized by the consumer to act on the consumer’s behalf.

Appeals

If we deny your request, you may appeal our decision by contacting us at privacy@seekout.com. If you have concerns about the result of an appeal, you may contact the attorney general in the state where you reside.

9. Additional Information for Individuals in Europe

If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, the following section applies to you.

Legal Basis for Processing

When we process your personal data as described above, we do so in reliance on the following lawful bases:

When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).

To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of communications).

When we have your consent to do so. When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time. This will not affect the lawfulness of our actions before you withdrew your consent.

Data Subject Rights

For information on privacy rights available to you and how to exercise your rights, see the Your Rights and Choices section above.

SeekOut can only fulfill privacy requests with respect to information for which we act as a data controller.

10. Disputes Regarding Our Privacy Practices

Except for residents of the EU, UK, and Switzerland, if you have a dispute relating to our privacy practices, please email us at privacy@seekout.com. For residents of the United States, SeekOut is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

For residents of the EU, UK, and Switzerland, you have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

11. Updates to this Privacy Policy

We may update this Privacy Policy from time to time. When we update this Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. If we make material changes, we will provide you with additional notice and may obtain your consent 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.

12. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please feel free to contact us at privacy@seekout.com or at the mailing address below. If you would like to exercise your privacy rights, please submit your request via the Privacy Choices Portal.

Mailing Address:

SeekOut Attn: Legal Department 1100 112th Ave NE, Suite 150 Bellevue, WA 98004