General Privacy Policy

Effective Date: May 24, 2025

Special Note for EU Users: If you are in the European Union (EU) or European Economic Area (EEA) and are a Business User or a visitor to our Sites, this General Privacy Policy does not apply to you. Instead, please see our EU User Privacy Policy.

Special Note for California Residents: The Additional Terms for California Residents available here also apply to you.

Your information privacy is extremely important to us. We have prepared this Privacy Policy to explain how we collect, use, protect, and disclose information and data when you use www.ninjahire.co and its affiliated websites, (the "Sites") and any mobile application, application programming interfaces, and other services offered by Ninjahire Inc. (collectively the "Services"). This Privacy Policy also explains your choices for managing your information preferences, including opting out of certain uses of your Personal Information. This Privacy Policy applies to all users of the Sites and Services, whether you are a passive candidate who is not actively applying for a particular job but listed in our proprietary Talent Database ("Candidate") or an HR manager or recruiter looking for prospective hires on behalf of your company ("Business User"). The Sites and Services are provided by Ninjahire Inc. ("Company", "we", "our" or "us").

BY USING THE SITES OR SERVICES, YOU ARE CONSENTING TO THIS PRIVACY POLICY. PLEASE READ IT CAREFULLY.

1. Personal Information We Collect

We collect the following categories and types of "Personal Information" concerning Candidates:

• Contact Information: your first and last name, email addresses, phone number and/or mobile phone number;

• Professional or employment-related information: work history, job title, skills, years of experience, education information, projects, and publications;

• Location: approximate location (at the level of city/metro area only);

• Photos: your professional social network picture;

• Inferences drawn from the categories described above as a processor, we help make inferences such as race, gender, and immigration (visa) status to assist employers with their diversity, equity, and inclusion efforts. As part of our other products, we may also act as a processor to assist our customers in their overall decision-making in their recruitment and hiring efforts. For further information, please see our customers' privacy notices.

Additionally, if you visit our Sites or use our Services, including if you are Business User, we collect the following additional categories of Personal Information:

• Other Identifiers: IP address; account name, company name, and address;

• Internet or other electronic activity: your browsing and click history, including the functions you use and searches you perform using the Services; browser agent name and version; web pages you view; links you click; your IP address; the length of time you visit our Sites and or use our Services; and the referring URL, or the webpage that led you to our Sites;

Our partners, such as Stripe, may collect financial information (including payment card information) directly from you; however, we will not have access to this information. We will collect billing addresses for our records.

2. Sources of Personal Information

We collect Personal Information from the following sources:

• For Candidates who appear in our Talent Database, we collect information about you from third parties. We collect your Personal Information from your public profiles (such as professional social network sites and social media sites where you have publicly posted information), other public websites and web platforms, from data brokers or other data vendors, and from our business customers.

• If you are a Business User or a visitor of our Sites, we collect additional information directly from you. We collect contact information, professional and employment information and other identifiers directly from you when we set up your account, or when you fill out a form on our website, such as to sign up for an event or to receive our newsletter or other marketing communications, or when you otherwise engage, interact, or communicate with our website's chat bots or similar technologies. Ninjahire Inc., or our vendors on our behalf, may record and store transcripts of these communications.

• If you are a Business User or a visitor of our Sites, we also collect information from you passively. We collect Internet or other electronic activity passively using tools like browser cookies. This activity is further described in the Cookies section below.

We may combine information collected from our different Sites and Services.

3. How We Use Personal Information

If you are a Candidate, we use your Personal Information for the following purposes:

• To Provide Candidate Search Services: We use Personal Information of Candidates from our Talent Database to help make great matches between employers and Candidates. Specifically, we use Candidate Personal Information to help our business customers engage with Candidates who may be interested in the prospective job opportunities. When our business customers search for Candidates with certain skills and talents, they can contact Candidates who match their searches, so the Candidates may learn more about the new job opportunities. Those job opportunities may be a better fit for their professional skills and interests or simply more exciting to them.

If you are a Business User or a visitor to our Sites, we use your Personal Information for the following additional purposes:

• Transactional Purposes: We use your contact information, other identifiers, and professional and employment information to provide you with the Sites and Services, including to open and maintain a user account for you and provide Services to you, and send you alerts and communicate with you about your registration or account. We use your billing address to determine your tax liability if you make a purchase of the Services through the Sites.

• Analytical Purposes: We use your other identifiers, and internet activity and browsing history to analyze, research and better understand how users access and use our Site and Services, both on an aggregated and individualized basis, to maintain, support, and improve our Site and Services, to respond to user preferences, and for research and analytical purposes.

• Marketing and Promotional Purposes: We use your Personal Information to:

  • To keep you informed of Ninjahire programs, products, and other services we think may be of interest to you;
  • To allow business customers and Business Users to contact you about job opportunities and interact with you through Ninjahire events; and
  • Provide you with other information from and about our Company, including personalized marketing communications.

• Maintenance and Improvement of the Sites and Services: We use your contact information, other identifiers, communication transcripts, and internet activity and browsing history to:

  • Handle your customer services requests;
  • Monitor and improve the Sites and Services;
  • Enhance your online experience and to enable us to provide you with an easier and more personalized experience and level of service;
  • Help us diagnose technical and service problems and administer our stores, websites, and apps.

• Security and Fraud Prevention: We use Personal Information to protect the Sites and Services, our Company and others, and to prevent fraud, theft, and misconduct.

We will not use your Personal Information we collected, as a Business or Controller as applicable under Data Privacy Regulations, for materially different, unrelated, or incompatible purposes other than the purposes indicated above without providing you notice.

4. How We Share Personal Information

Service Providers

We share Personal Information with our authorized service providers that perform certain services on our behalf ("Service Providers"). For example, we use a payment processor (i.e. Stripe) to process payments. We may contract with other Service Providers to provide certain services, such as hosting and maintenance of our databases and Sites, data storage and management, and marketing and promotions. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us.

Our Business Customers and Business Users

If you are a Candidate, we may share your Personal Information, including your contact information, professional and employment-related information, inferred demographic information, photos, and inferences drawn from the foregoing categories, with our business customers and Business Users for their job search and employment recruiting purposes. Specifically, we share this information with our customers to help them find talented Candidates who may meet their employment needs, and to help them contact and engage with Candidates regarding opportunities that fit those Candidates' skill sets and professional backgrounds. By sharing your Personal Information with our business customers and Business Users, we aspire to help you get to where you want to be professionally and personally, and hope that through our platform you will receive better job offers and career development opportunities from companies that you want to work with.

Advertising Partners

We may allow social media, third-party advertisers, and service providers to collect internet and other electronic activity data when you visit the Sites and Services. These companies include LinkedIn, Facebook, and digital advertising networks. These companies collect information to help us analyze the performance of our advertising, and they may also track your activity across different websites and over time to provide advertising based on your interests. These third parties typically use cookies to collect internet and other electronic activity data.

Our Affiliates and in Corporate Transactions

We may share Personal Information with businesses controlling, controlled by, or under common control with Ninjahire Inc.. Additionally, if Ninjahire Inc. is merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information in connection with such transaction. You will have the opportunity to opt out of any such transfer if, in our discretion, it will result in the handling of your Personal Information in a way that differs materially from this Privacy Policy.

Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas).

Customer Data Input or Uploaded by Business Users

As part of utilizing our Services, our Business Users may provide us with information about Candidates or prospective employees. Business Users may also provide us with credentials to third-party sites or services in order to synchronize certain emails or other information with our Services and may provide us with other information (collectively any such personal information we collect in these ways is "Business Customer Data"). We treat Business Customer Data as confidential and do not use it for any purposes other than delivering the Services to the customer or Business User who provided the Business Customer Data. We do not share or disclose Business Customer Data with any parties other than the customer or Business User who provided it.

5. Cookies and Automated Data Collection Technologies

We use cookies (a small text file placed on your computer to identify your computer and web browser) and may use anonymous identifiers (a random string of characters that is used for the same purposes as a cookie). We use cookies and other anonymous identifiers to help deliver the content of our Sites, for authentication purposes (to keep track of the fact that you have logged in) and to analyze use of and improve the Sites and Services. We also use cookies and similar technologies to personalize content and our advertising, and to provide social media features. Most web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. The "help" feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies and how to disable existing cookies. However, certain features of the Sites or Services may not work if you delete or disable cookies. We may combine information from cookies or other identifiers with Personal Information that you have provided to us.

To opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit:

• Digital Advertising Alliance (DAA)'s self-regulatory opt-out page (https://optout.aboutads.info/) and mobile application-based "AppChoices" download page (https://youradchoices.com/appchoices)

• Network Advertising Initiative (NAI)'s self-regulatory opt-out page (https://optout.networkadvertising.org/).

In the mobile environment, most mobile operating systems offer device-based opt-out choices that are transmitted to companies providing interest-based advertising. To set an opt-out preference for a mobile device identifier (such as Apple's IDFA or Android's GAID), visit the device manufacturer's current choice instructions pages, or read more about sending signals to limit ad tracking for your operating system here: https://www.networkadvertising.org/mobile-choices. Please note that these settings must be performed on each device (including each web browser on each device) for which you wish to opt-out, and if you clear your cookies or if you use a different browser or device, you will need to renew your opt-out preferences.

Response to Do-Not-Track Signals

The Sites do not respond to web browser "do not track" signals.

6. Be Careful When You Share Information with Others

Please be aware that if you share information on any public area of the Sites or Services or through our events, that information may be accessed by others, who may copy that information and make it public in other settings. This means that anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications.

7. Links

Our Sites and Services may contain links to other websites or allow others to send you such links. A link to a third party's website does not mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party websites. You access such third-party websites or content at your own risk. You should always read the privacy policy of a third-party website before providing any information to the website.

8. Children's Privacy

The Sites and Services are intended for users who are 16 years old or older. We do not knowingly collect Personal Information from children under the age of 16. If we become aware that we have inadvertently received Personal Information from a child under the age of 16, we will delete such information from our records. California users under the age of 18 may request the removal of their content or information publicly posted on the Sites or Services by emailing us at privacy@ninjahire.co. Please note that some of the user content that appears on our Sites or Services is stored and controlled by third-party providers; thus, complete and comprehensive removal of the content may not be possible.

9. Processing in the United States

Please be aware that your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that we process and store all information in the United States. The laws in the United States may not be as protective of your privacy as those in your location. By using the Sites or Services, you agree the collection, use, transfer, and disclosure of your Personal Information and communications will be governed by the applicable laws in the United States.

10. Managing Your Information Preferences if You Are a Business User

If you are a Business User, you can review, correct, update, delete, or change most of your Personal Information used to establish your account by using your account settings. You can also opt out of receiving certain emails and other communications from us by emailing us at privacy@ninjahire.co. You are able to opt out of receiving marketing emails from us; however, you cannot opt out of receiving all emails from us, such as emails about the status of your account with us. If you have questions or concerns regarding this Privacy Policy or would like to access, correct, or delete your personal information, please email us at privacy@ninjahire.co.

To exercise rights described above, you will need to verify your identity by providing us with your first and last name and an email address that we have on file for you, and we will remove your information from our system. We will follow up with you if we need further information to honor your request.

11. Candidate Data Privacy Rights

The Talent Database is a searching and sourcing service that we offer to users through the NinjaHire Site (the name "Talent Database" is subject to change from time to time at our discretion). We respect your control over your personal information and, upon request, we will confirm whether we hold or are processing information that we have collected or gathered about you. If we have collected your personal information, we will provide you with a copy of that information. You may also amend or update inaccurate or incomplete personal information, request deletion of your personal information, or request that we no longer use it. Under certain circumstances we will not be able to fulfill your request, such as when it interferes with our regulatory obligations, affects legal matters, we cannot verify your identity, or it involves disproportionate cost or effort. In any event, we will respond to your request within a reasonable timeframe and provide you an explanation of our course of action. To make a request, please email us at privacy@ninjahire.co using the email subject line "Opt-Out," or by calling our phone: +1-512-963-3956.

Our Talent Database helps our business customers and Business Users find candidates to fill their employment needs. To do this, we gather and index Personal Information of Candidates from the sources described above so it can be searched by our business customers and Business Users for employment recruiting purposes. We aim to provide the most comprehensive results when our business customers and Business Users search, source, evaluate, and manage talent to fill their employment needs.

To opt out or exercise other rights described above, you will need to verify your identity by providing us with your first and last name and an email address that we have on file for you and we will remove your information from our system. We will follow up with you if we need further information in order to honor your request.

Please note, we may need to retain certain data about you to ensure that we can continue to honor your request to opt out. We will maintain the minimum amount of information necessary for this purpose, and will not share this information with employers, recruiters, or other users of our services.

12. Security and Data Retention

We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information with encryption in transit and at rest. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Site or Services, we cannot and do not guarantee the security of any information you transmit on or through the Site or Services, and you do so at your own risk.

We will retain your Personal Information only for as long as it is necessary for the purposes set out in this Privacy Policy. Those purposes include needing to perform a service for you, complying with applicable laws or regulations, resolving legal disputes, or if it is necessary to pursue Ninjahire Inc.'s legitimate interest that is not overridden by your personal rights and freedoms.

13. Privacy Policy Changes

We may change this Privacy Policy from time to time. If we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Sites. Those changes will go into effect on the "Revised" date shown in the revised Privacy Policy. By continuing to use the Sites or Services, you are consenting to the revised Privacy Policy.

14. Contact Us

If you have any questions, feedback or to report a violation regarding this Privacy Policy, you may email us at privacy@ninjahire.co or contact us by mail addressed to:

Attn: Legal Department Ninjahire Inc. 4328 Trinity Woods St Leander, TX 78641 United States

PLEASE PRINT A COPY OF THIS PRIVACY POLICY FOR YOUR RECORD AND PLEASE CHECK THE SITES FREQUENTLY FOR ANY CHANGES.

Additional Terms for California Residents {#california-residents}

If you are a California resident, you have certain rights under California law, including the California Consumer Privacy Act ("CCPA"). These additional terms supplement the information in our General Privacy Policy and are intended for California residents only.

If you are not a California resident, these additional terms do not apply to you. Instead please review our General Privacy Policy or EU User Privacy Policy, which may apply to you. However, these additional terms may not cover all aspects of our business practice. You can reference our General Privacy Policy for any information that you may not be able to find here.

A. Ninjahire Inc.'s Roles under CCPA

Ninjahire Inc. as a Business in California

Under the CCPA framework, Ninjahire Inc. is defined as a Business as to the activities of collecting, sharing, and determining the means of processing California consumer information for Commercial Purposes. Ninjahire Inc. may collect Personal Information to provide Services to our customers including the customers' end users. Personal Information is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Commercial Purpose means to advance our commercial or economic interests.

Ninjahire Inc. as a Service Provider in California

Under the CCPA framework, in certain scenarios, Ninjahire Inc. may be considered as a Service Provider who processes Personal Information on behalf of a Business, Ninjahire Inc.'s customer. Ninjahire Inc.'s customer may disclose your Personal Information to Ninjahire Inc. for a Business Purpose pursuant to a written contract between Ninjahire Inc. and Ninjahire Inc.'s customer. Business Purpose means the use of Personal Information for the Business's or Service Provider's operational purposes, including auditing, detecting security incidents, debugging, short-term/transient use, performing customer services, internal research, and maintaining / improving / upgrading / enhancing services.

B. Personal Information We Collected for the Preceding 12 Months:

Specifically, Ninjahire Inc. collected Personal Information differently based on your role as a non-user or a user:

• Categories of Non-user Personal Information Collected: real name, alias, phone number, email, approximate location (city/metro area, not your actual address), job title, skills, education, work history, projects, publications, professional social network profile picture, professional social network link, and inferences drawn from the aforementioned information.

• Categories of User Personal Information Collected: real name, alias, address, phone number, mobile phone number, email, payment information, company name, computer/web browser/IP address information from cookies, web beacons and other identifiers, and other specific information you choose to provide us with or that you choose to include in your account.

C. Personal Information We Sold for the Preceding 12 Months

If you are a Candidate, we share the Non-user Personal Information described above with our customers, through Ninjahire Inc.'s paid services, so that they may reach out to you for career opportunities that you may have interest in, and which may better fit to your professional background.

D. Personal Information We Disclosed for Business Purposes for the Preceding 12 Months

If you are a Business User, your information provided in your user account is confidential to Ninjahire Inc., and we neither sell your Personal Information nor share your Personal Information with third parties, except that your Personal Information may be shared with your company's Admin and other users who have the authority to view your Personal Information in order to provide Services to the customer of ours with whom you are employed.

E. California Consumers' Rights under CCPA

CCPA provides California consumers' rights to control how their Personal Information is collected and shared by businesses. "California consumer" means a natural person who is a California resident as defined in 18 CCR §17014.

As a California consumer, you have the following rights regarding how Ninjahire Inc. processes your Personal Information:

• Right to Notice: Provides you the right to request Ninjahire Inc. disclose the categories of Personal Information to be collected and the purposes for which the categories of Personal Information will be used.

• Right to Access: Provides you the right to access your Personal Information free of charge, not more than twice within a year, upon Ninjahire Inc.'s verification of your identity. You can request Ninjahire Inc. to disclose categories of Personal Information collected, sold or disclosed; categories of sources of where the information was collected; Business or Commercial Purposes of collecting or selling the information; categories of third parties to whom the information was disclosed or sold; and specific pieces of information collected by Ninjahire Inc..

• Right to Delete Information: Provides you the right to request Ninjahire Inc. delete your Personal Information that Ninjahire Inc. collected, upon a verifiable request, unless such Personal information was collected for the purpose of completing a transaction involving you; detecting security related incidents or illegal activities; debugging or fixing errors; protecting other consumers' rights or other rights protected by law; preventing criminal offenses; engaging in scientific, historical or statistical reach in the public interest; internal uses that are reasonably aligned with your expectation; or compliance with a legal obligation.

• Right to Equal Services and Prices: Provides you the right to not be discriminated against for exercising your rights under CCPA. Examples of discrimination include: denying goods or services to you, charging you different prices or rates for goods or services, providing you with a different level or quality of goods or services, or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

• Right to Opt-out: Provides you the right to request to opt out and delete your personal information collected by Ninjahire Inc..

For more detailed information about your rights under CCPA and how to exercise them, please see our CCPA Policy.

F. Response Timing and Format

You may contact us at the methods set out in Section 11 above to exercise your rights as a California consumer. We endeavor to respond to a verifiable consumer request within 45 days of our receipt. If we need to request additional information from you to verify your identity, we will use that information solely for purposes of verification. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to your email address linked to your account. If you do not have an account with us, we will deliver our written response by email in our record or an alternative way at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance. Notwithstanding the foregoing, we have no obligation to respond to you if your Personal Information was collected for a single, one-time transaction, if such information is not sold or retained by Ninjahire Inc..

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We have no obligation to provide you with responses more than two times in a 12-month period.

PLEASE PRINT A COPY OF THESE ADDITIONAL TERMS FOR YOUR RECORD AND PLEASE CHECK THE SITE FREQUENTLY FOR ANY CHANGES.