Effective Date: 11/20/2020

OVERVIEW

This Privacy Statement applies to www.adicio.com, www.careercast.com, and all other websites owned and operated by ADICIO, Inc. Adicio, Inc., is committed to respecting the privacy of our users and complying with Privacy laws. We strive to provide a safe, secure user experience. This Privacy Statement sets forth the online data collection and usage policies and practices that apply to our website. By using the Adicio website, you consent to the policies and practices described in this Statement.

Your data will be stored and processed in whole or in part in the United States. If you access the Adicio website outside the United States, your usage of our site constitutes consent to the transfer of your data out of your country and into the United States.

Our site contains links to other websites over which we have no control. Adicio is not responsible for the privacy policies or practices of other websites to which you choose to link from the Adicio website. We encourage you to review the privacy policies of those other websites so you can understand how they collect, use and share your information. This Privacy Statement applies solely to the information we collect on the Adicio website, and does not apply to information we collect in any other fashion.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

EU-U.S. and Swiss -U.S. Privacy Shield

Adicio, Inc. (and its parent/subsidiary company CareerCast) participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Adicio, Inc. is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, in reliance on the Privacy Shield Frameworks, to the Frameworks’ applicable Principles. To learn more about the Privacy Shield Frameworks and view our certification, please visit https://www.privacyshield.gov/.

Adicio, Inc. is responsible for the processing of personal data it receives, under the Privacy Shield Frameworks, and subsequently transfers to a third party acting as an agent on its behalf. Adicio, Inc. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Adicio, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Adicio, Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

ADICIO, Inc. complies with the EU-U.S. Privacy Shield Framework (Privacy Shield) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom to the United States in reliance on Privacy Shield. ADICIO, Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

COLLECTION AND RETENTION OF INFORMATION

In some areas of our websites, Adicio requests or may request that you provide personal information, including your name, address, email address, telephone number, contact information, billing information and any other information from which your identity is discernible.

We also gather certain information about your use of our site, such as what areas you visit and what services you access. Moreover, there is information about your computer hardware and software that is collected by Adicio. This information can include without limitation your IP address, browser type, domain names, access times and referring website addresses. We gather this information automatically and store it in log files. We do not link this automatically collected date to other information we collect about you.

You can correct or update your Adicio account profile, resume(s) or application(s), or email alerts at any time. Moreover, you can delete your resume(s) or application(s) from Adicio's online database or close your account(s) at any time, in which event we will remove all our copies of your resume or application if applicable and cover letters. Please refer to the section that follows labeled "ACCESSING AND UPDATING YOUR INFORMATION" if you need assistance.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

We do not share, sell, rent or trade personal information with parties for their promotional purposes.

EMAIL A JOB TO A FRIEND

If you choose to email a job listing to tell a friend about a job opportunity, we will ask you for your friend's email address. We will automatically send your friend a one-time email containing a link to the job listing, inviting him or her to visit the site that the job is posted on. Adicio does not store this information and does not track the success of whether or not the email is received.

Your friend may contact us at privacy@adicio.com if they have any questions on this process.

USE OF INFORMATION BY ADICIO

We use the information we gather on an Adicio website, whether personal, demographic, collective or technical, for the purpose of operating and improving the Adicio website, fostering a positive user experience, and delivering the products and services that we offer.

We may also use the information we gather to inform you of other products or services available from Adicio.

We may use your contact information in order to send you email or other communications regarding updates at the Adicio site, such as new Adicio opportunities and additional listings which may be of interest to you. The nature and frequency of these messages will vary depending upon the information we have about you. In addition, at the time of registration for Adicio, you have the option to elect to receive additional communications, information and promotions including without limitation free informational newsletters from Adicio relating to topics that may be of special interest to you.

DISCLOSURE OF INFORMATION TO OTHERS

We will share your personal information with third parties only in the ways that are described in this privacy policy. We do not disclose to third parties your personal information for promotional purposes, combined personal and demographic information or information about your use of an Adicio website (such as the areas you visit or the services you access), except as set forth below.

1. We may disclose such information to third parties if you consent to such disclosure. For example, if you indicate that you would like to receive information about the products or services of third parties at the time you register for an Adicio account, we may supply your contact information to third parties such as employers, recruiters, agents, brokers, dealers, data aggregators, marketers or others for the purpose of sending you email or otherwise communicating with you. If you do not want us to share your personal information with these companies, contact us at customersupport@adicio.com.
2. We may disclose such information to companies and individuals we employ to perform functions on our behalf. Examples may include hosting our web servers, analyzing data, providing marketing assistance, processing credit card payments, and providing customer service. These companies and individuals will have access to your personal information as necessary to perform their functions, but they may not share that information with any other third party.
3. We may disclose such information if legally required to do so, if requested to do so by a governmental entity or if we believe in good faith that such action is necessary to: (a) conform to legal requirements or comply with legal process; (b) protect the rights or property of Adicio or its affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public.
4. We may disclose and transfer such information to a third party who acquires all or a substantial portion of Adicio's business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets. In addition, in the event Adicio becomes the subject of a bankruptcy proceeding, whether voluntary or involuntary, Adicio or its trustee in bankruptcy may sell, license or otherwise dispose of such information in a transaction approved by the bankruptcy court. If such event occurs we will display a prominent notice on our website.

Adicio may also share aggregated anonymous information about visitors to each of our ASP Client's websites with its clients, partners and other third parties so that they may understand the kinds of visitors to Adicio's site and how those visitors use the site.

Adicio supplies technology, hosting and related services to other leading companies to power recruitment, real estate and motors areas on their websites (sometimes referred to as "private label areas"). Personal and/or demographic information supplied by you in private label areas becomes part of the Adicio database, but it is not accessible by anyone other than you, Adicio and the company concerned without your consent.

Information gathered on a page in a private label area, or on a co-branded page (such as that of a contest co-sponsored by Adicio and another company), may become the property of the other company or of both Adicio and the other company. In that instance, the use of such information by the other company may be subject to the privacy policy of that company and, in any event, Adicio is not responsible for that company's use of your personal or demographic information. If you apply for a position through a co-branded site, you may be asked to provide information on your age, gender or race. Some employers are required by law to gather this information from job applicants for reporting and record keeping requirements. You should understand that if provided, this information will be used by employers only in accordance with applicable law and will not be used in making any employment decisions. All information provided will be kept separate from your expression of interest in any job opportunity. Providing this information is strictly voluntary and you will not be subject to any adverse action or treatment if you choose not to provide this information.

WIDGETS

Our Web site includes Social Media Features, such as the Facebook Like button [and Widgets, such as inThird parties with whom we partner to provide certain features on our website or to display advertising based upon your web browsing activity also use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. teractive mini-programs that run on our site]. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Widgets support functions that require that you disclose certain personal information given the user's choice of participation. This information is collected in many different ways such as: forms, surveys, contests, forums, subscribing or unsubscribing to mailings and correcting or updating personal information and are only used for the purpose in which they were collected. Forms which require sensitive information such as financial information (credit card) to process purchases for products or services are SSL encrypted to protect your sensitive information.

THIRD PARTY ADVERTISERS

We partner with third parties to either display advertising on our website or to manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may elect to turn off cookies or use your browser’s privacy settings to mask your identity, or you may opt-out by the following consumer choice mechanisms.

Please visit:
Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (http://optout.aboutads.info/) and mobile application-based “AppChoices” download page (https://youradchoices.com/appchoices)
European Interactive Digital Advertising Alliance (EDAA)’s consumer opt-out page (http://youronlinechoices.eu)
Network Advertising Initiative (NAI)’s self-regulatory opt-out page (http://optout.networkadvertising.org/).
Please note this does not opt you out of being served ads. You will continue to receive generic ads.

Google AdSense uses cookies and clear GIFs on this site, which allow it to recognize a user's cookie when a user visits this site. The information that Google AdSense collects and shares through this technology is not personally identifiable.

You may opt-out of the use of this cookie by visiting Google's Advertising and Privacy page: http://www.google.com/privacy_ads.html.

USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Technologies such as cookies, beacons, scripts and tags are used by Adicio and our partners, affiliates or analytics or service providers. These technologies are used in analyzing trends, administering the website, tracking users' movements around the site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. Various browsers may offer their own management tools for removing these types of tracking technologies.

We use cookies on our site to tell the web server that you have returned to a specific page. For example, if you personalize Adicio pages, or register for services, a cookie helps us to recall your specific information (such as user name, password and preferences). Because of our use of cookies, we can deliver faster and more accurate results and a more personalized site experience. When you return to the Adicio site, the information you previously provided can be retrieved, so you can easily use the features that you customized. We also use cookies to track click streams and for load balancing.

You may have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline all cookies if you prefer. Alternatively, you may be able to modify your browser setting to notify you each time a cookie is tendered and permit you to accept or decline cookies on an individual basis. If you choose to decline cookies, however, that may hinder performance and negatively impact your experience on the Adicio website. To protect your privacy, be sure to close your browser completely after you have finished conducting business with a website that does use cookies.

We and third parties with whom we partner to provide certain features on our website or to display advertising based upon your web browsing activity also use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.

ACCESSING AND UPDATING YOUR INFORMATION

Upon request and within 30 days, Adicio will grant individuals reasonable access to personal information that it holds about them. In addition, Adicio will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. Please contact customersupport@adicio.com to change your personal information gathered on the Site.

Upon request Adicio, Inc. will provide you with information about whether we hold any of your personal information. You may review, correct, update or delete your Adicio account information at any time. Simply log into your Adicio account, go to your Account Profile, review your account information and, if you wish, edit it with the options provided. If you do not remember your password for your account, you can simply enter your email address and click the 'forgot my password' link. You will be emailed your password to the email address you provided. If you do not remember the email address you used to create your account, you can access account information by emailing us at privacy@adicio.com. In this email, please include your first name, last name, email address and a phone number in the event we need additional information. Your account access information will be emailed to you within 5 business days.

If you opted to receive newsletters, commercial emails or other communications from Adicio or third parties at the time you registered with Adicio, but subsequently change your mind, you may opt-out by editing your Account Profile as described above. If you previously opted not to receive such communications, you may later opt-in by editing your Account Profile.

SECURITY

Adicio has implemented reasonable technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration or disclosure. Adicio also uses software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage to the information on our websites.

Unauthorized attempts to upload information or change information on our websites is strictly prohibited and may be punishable under the Computer Fraud and Abuse Act of 1986. However, we cannot guarantee that unauthorized third parties will never be able to defeat those measures or use your personal information for improper purposes.

When you place an order online at Adicio, your credit card information is protected through the use of encryption, such as the Secure Socket Layer ("SSL") protocol. SSL makes it difficult for your credit card information to be intercepted or stolen while being transmitted. Adicio uses a service company to process its credit card transactions. For further information on this company's privacy and security practices, please go to: https://www.paypal.com/us/cgi-bin/webscr?cmd=p/gen/ua/policy_privacy-outside.

CHILDREN

Adicio is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13.

CHANGES TO PRIVACY STATEMENT

If we decide to change our Privacy Statement for Adicio, we will post those changes here so that you will always know what information we gather, how we might use that information, and to whom we will disclose it. If at any time, you have questions or concerns about Adicio's Privacy Statement, please feel free to email our Privacy Officer, Samantha Miller at smiller@adicio.com or call us at 760.602.9502 and speak to one of our representatives. If we make material changes to this policy, we will notify you by email (sent to the e-mail address specified in your account or we will place a prominent notice on the home page of our website 30 days prior to implementing the change.

CONTACT INFORMATION

Adicio is a name under which Adicio, Inc., a California corporation with its principal place of business at 5857 Owens Avenue, Suite #300 Carlsbad, CA 92008, and certain of its affiliated companies worldwide, do business. ("Affiliated companies" means entities that control, are controlled by or are under common control with Adicio, Inc.) Adicio, Inc. is the legal entity which determines the purposes and means of processing the information gathered at the Adicio websites. The information we gather on our website may be shared within Adicio, Inc. and its affiliated companies. If you would prefer not to have your information shared with our affiliated companies, please contact us by e-mailing us at privacy@adicio.com or by calling us at 760.602.9502.

Adicio, Inc. has a Privacy Officer who is responsible for Adicio, Inc.'s compliance with and enforcement of this Policy. Adicio, Inc.'s Privacy Officer, Samantha Miller is available to any of its employees, customers, vendors, business partners, or others who may have questions concerning this Policy or data security practices. Adicio, Inc.'s Privacy Officer may be contacted by email at smiller@adicio.com, by telephone at 760.692.4147 or by mail at Adicio, Inc., 5857 Owens Avenue, Suite #300, Carlsbad, CA 92008. If users have questions or concerns regarding this statement, they should first contact Samantha Miller. If you do not receive acknowledgment of your inquiry, or if your inquiry is not satisfactorily addressed, you should then contact our U.S.-based third party Dispute Resolution provider at https://feedback-form.truste.com/watchdog/request. They will serve as a liaison with the website to resolve your concerns.

We welcome your comments concerning this Privacy Statement. If you believe that we have not adhered to this Statement, please contact us by e-mailing us at privacy@adicio.com or by calling us at 760.602.9502. We will use commercially reasonable efforts to promptly determine and remedy the problem.

II. ADICIO, INC.'S ASP PRIVACY POLICY

This ASP Privacy Policy applies only to all transfers of personal information ("Personal Information") received by Adicio, Inc. in any format through its hosted software platforms or servers, whether supplied directly by Adicio, Inc. customers or by candidates for employment at Adicio, Inc., or by customers anywhere in the world, including transfers from the European Economic Area (EEA) to the United States. Any other visitors to Adicio.com should refer to the Online Privacy Policy which covers non-ASP Adicio, Inc. website use.

We operate as a data processor for our hosted recruitment, real estate and motors software customers. Our hosted software customers fill the role of data controller. Individual users involved in recruitment, real estate or motors activities usually interact directly with Adicio, Inc.'s customers rather than with Adicio, Inc. Adicio, Inc. provides its customers the option of disclosing their relationship with us by providing notice to individual employees, candidates, agents, brokers, buyers, sellers and dealers of the customer about the Adicio, Inc. technology that they use. Adicio, Inc. maintains only that information related to the user process, which our customers' have asked us to process. This ASP Privacy Policy does not reflect the privacy practices of Adicio, Inc.'s customers and Adicio, Inc. is not responsible for its customers' privacy policies or practices. Adicio, Inc. does not review, comment upon or monitor its customers' compliance with their respective privacy policies, nor does Adicio, Inc. review its customer instructions to determine whether they are in compliance with or conflict with the terms of a customer's published privacy policy.

1. Notice/Use of Information

Because it supplies a hosted system, Adicio, Inc. operates as a data processor for our software customers. Our hosted software customers fill the role of data collector. Individual users involved in recruitment, real estate or motors activities usually interact directly with Adicio, Inc.'s customers rather than with Adicio, Inc. Adicio, Inc. provides its customers with the option of disclosing their relationship with us by providing notice to individual employees and candidates of the customer about the Adicio, Inc. technology that they use. Adicio, Inc. maintains only that information related to the recruitment, real estate or motors process, which our customers have asked us to process. It is the Adicio, Inc. customer's responsibility to ensure that the data the customer collects can be legally collected in the country of origin. The Adicio, Inc. customer is responsible to give its users the appropriate level of notification that Personal Information is being collected and maintained. Adicio, Inc. does collect aggregate and demographic data, which is not associated with an individual's Personal Information, that may be used for statistical analysis and training purposes.

2. Notification of Changes/Choice

We will maintain information in accordance with this ASP Privacy Policy. If we decide to change this Policy, we will post the changes on this page so that our software customers or their users are always aware of what information we process, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use Personal Information in a different manner, we will notify our customers by way of email or by posting a notice on our website for at least 30 days prior to the change in use. Customers, in turn, are responsible for notifying users and providing them a choice as to whether or not we use their information in this different manner.

3. Onward Transfer

We employ other companies and individuals to perform functions on our behalf. Examples may include customer service; information processing, and data storage. If we disclose information of our customers or customers' users to a third party that is acting as our agent or on our behalf, we will ensure that the third party has agreed to use your personal information only as necessary to provide these services to us and abide by the Privacy Shield principles or is subject to the Data Directive, or can otherwise assure adequate protection of such information. We may seek to assure adequate protection, for example, by entering into written agreements with third parties requiring such parties to provide at least the same level of privacy protection as is required by the Privacy Shield and/or the Data Directive.

4. Data Integrity

Adicio, Inc. will use Personal Information only in ways compatible with the purpose for which it was collected or subsequently authorized by our customers. Adicio, Inc. will take reasonable steps to ensure that Personal Information is relevant for its intended use, accurate and complete.

5. Security

Adicio, Inc. is committed to ensuring the security of the information it processes. To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we process. Adicio, Inc. strives to protect the privacy of the information we process, and inadvertent disclosure is extremely unlikely. In the event of such an inadvertent disclosure, Adicio, Inc. will take all commercially reasonable steps to limit and remedy the disclosure. However, we cannot guarantee that unauthorized third parties will never be able to defeat those procedures or use your personal information for improper purposes.

6. Access/Correction

In most cases, when Adicio, Inc. collects Personal Information we do so on behalf of another company (as an agent or data processor). Upon request Adicio will provide you with information about whether we hold any of your personal information. To request access to or correction of this information, please contact the company to which you provided it. Adicio, Inc. technology allows its software customer's access to all of the information processed on their behalf and allows for the processing of any requested corrections to such information. You can also access your account information 24 hours a day, 7 days a week, to make corrections, including deletions, to your account information. If you have forgotten your password you can use the "Forgot my password" link. If you do not have your account information, you can contact the company/site where you set up your account and request assistance. Your account access information will be emailed to you within 5 business days. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

7. Oversight/Enforcement

Adicio, Inc. has a Privacy Officer who is responsible for Adicio, Inc.'s compliance with and enforcement of this Policy. Adicio, Inc.'s Privacy Officer, Samantha Miller, is available to any of its employees, customers, vendors, business partners, or others who may have questions concerning this Policy or data security practices. Adicio, Inc.'s Privacy Officer may be contacted by email at smiller@adicio.com by telephone at 760.692.4148 or by mail at Adicio, Inc., 5857 Owens Avenue, Suite #300, Carlsbad, CA 92008. If users have questions or concerns regarding this statement, they should first contact Samantha Miller.