Privacy Policy

Introduction

Confirm Global, Inc. ("Confirm," "we," "our," or "us") provides the following Privacy Policy, which describes how we collect, use, disclose, and share or sell information that is personally identifiable to a user.

California users: The information below constitutes our Notice at Collection under the California Consumer Privacy Act.

We operate this website ("Website") and provide services which provide a path for users to apply for employment positions by uploading certain types of documents, including resumes, and collecting various pieces of information, generally through questions related to employment history and other candidate responses (collectively, the "Services"). This Privacy Policy does not apply to information collected by any third party, including through any application or content that may link to or be accessible from or through our Services.

Acceptance of Privacy Policy

By accessing and using the Website and Services, you consent to accept this Privacy Policy and you agree to the collection, use, storage, disclosure, and sharing of your information as described herein. If you do not intend to agree to the terms of this Privacy Policy, DO NOT use this Website.

For U.S. Residents Only

Please note that if you are not a U.S. resident, you are not permitted to use the Website and Services.

What Information We Collect

We may collect the following types of information:

• Identifiers, such as your name, email and postal address, telephone number, birth date and governmental-issued identification cards.
• Personal information, such as the Identifiers listed above, education, employment history, and financial information.
• Details of transactions or interactions you carry out on or through our website.
• Information included in your resume when you choose to voluntarily provide this information when applying for a position.
• Information related to users' consent to use the website, obtain third-party information, or to share information.
• Inferences drawn from other categories of information.
• Your government identification, professional certifications or licenses, and other identifiers.
• The computer or mobile device you use to access our websites and mobile applications, such as the hardware model, operating system and version, unique device identifiers, settings of the device and mobile network information.
• Location of your device or computer when you access or use the Websites, including geolocation information associated with your computer or device's IP address.
• When necessary and with your consent, we may process sensitive information, such as biometric data and government-issued identification numbers (such as Social Security numbers, driver's license numbers, or state ID numbers) ("Sensitive Personal Information" as used herein).

How We Collect Information

We may collect information from the following sources:

• Directly from users of the Website and Services, via registration, in response to questions about employment potential and history, through documents and information uploaded to the site, or in response to interview questions.
• From publicly available sources, such as internet searches, social media sites and news articles.
• From third-party sources with your consent when required, including information related to employment and financial history.
• Via our hosting servers, which collect information from users through various technological means when users access and interact with the Website, such as your domain name and/or your IP address, access times, pages or information viewed, and browsing behavior.
• From our service providers and business partners, third-party data analytics companies, marketing service companies, and list managers.
• From our employer clients, government agencies, or other third-parties through their direct interactions with us.
• From cookies (small text files placed on a user's browser by a website).
• By combining information, collected from various sources listed above, to augment and verify information and to improve the overall quality of our services.

How We May Use or Share the Information

We may use or share the information the following ways:

• To assist potential employers in making hiring decisions according to their specific criteria.
• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of Services to the user.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested Services.
• To send administrative information to you. We may process your information to send you details about our Services, changes to our terms and policies, and other similar information.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To enrich candidate profiles with historical application data. We may use historical data (e.g., previous applications, and interview outcomes) to contextualize new applications, support decision-making, and improve candidate-job matching for employers.
• To improve the performance and fairness of hiring processes, we may use candidate interaction data, such as interview responses and outcomes, to evaluate and refine our systems, ensuring accuracy, fairness, and reduced bias in hiring recommendations.
• To permit our technology vendors to access, monitor and improve the Website and Services.
• To respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims, or when we determine it necessary to comply with applicable laws and/or regulations.
• To disclose to appropriate third parties the event of a merger, acquisition, or in connection with a bankruptcy reorganization.

We do not sell user information for marketing or targeted advertising purposes.

Whom We Share Information With

We may share information with the following:

• Potential employers for employment decision-making.
• Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work.
• We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

When we share information with any third parties, including our employer partners and vendors, we enter into agreements that describe the purpose for which the information was shared, restrict its use to the agreement's specified purpose, and require that all information remain confidential and be protected from unauthorized disclosure. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold onto our behalf and to retain it for the period we instruct.

How We Use Artificial Intelligence, Automated Decision-Making and Biometric Information

As part of the Services we provide to our employer clients, we use artificial intelligence ("AI") technology to conduct virtual interviews with job applicants. During these interviews, our virtual agent may collect and analyze the following information:

• Your verbal responses to interview questions.
• Audio of your interview.
• Other information you provide during the interview.

Our AI technology evaluates your responses based on criteria established by the prospective employer, which may include job-relevant qualifications, skills, experience, and other factors specified by the employer. The AI does not evaluate or make decisions based on characteristics such as race, gender, age, disability, or other protected classifications.

Automated Screening and Ranking

Based on the information collected during the interview process and from other sources (such as your resume and application materials), our systems may automatically screen, rank, or prioritize applicants according to objective criteria provided by the prospective employer. In some cases, applicants who do not meet the employer's specified criteria may not be advanced in the hiring process. The criteria used for screening and ranking may be impacted by state laws and each employer client at their discretion may include factors such as:

• Required qualifications, certifications, or licenses.
• Relevant work experience.
• Skills and competencies.
• Availability and scheduling preferences.
• Other job-related requirements specified by the employer.

We may draw inferences from the information collected during the interview and application process to create a profile reflecting your qualifications, skills, and suitability for the position. These inferences are shared with the prospective employer to assist in their hiring decisions. While our AI technology assists in the interview and screening process, final hiring decisions are made by the prospective employer, not by Confirm. Employers may use the information and analysis we provide as one factor among many in their hiring process.

Collection of Biometric Information

Depending on the features enabled by the prospective employer and applicable law, our AI-powered virtual interview Services may collect biometric information from you, such as voice characteristics derived from audio recordings of your interview. If biometric information is collected, we may use it to analyze characteristics of your interview responses. You will be notified before any biometric data is collected and asked to provide your consent as required by state law before proceeding.

We do not sell, lease, or trade biometric information. If biometric information has been collected from you, you may request that we permanently destroy it by contacting us at Legal@Confirm.com. We will comply with such requests within thirty (30) days, unless retention is required by law.

If you do not consent to the use of AI to analyze your interview or, where applicable, to the collection of biometric information, or you do not agree to an online interview with our agent, you may request an alternative interview process by contacting us at Legal@Confirm.com before your scheduled interview.

How Long Do We Keep Your Information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, 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.

How We Keep Your Information Safe

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

How We Maintain Age Restrictions

We do not knowingly collect, solicit or share data from children under 18 years of age, or the equivalent age as specified by law in your jurisdiction. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at Legal@Confirm.com.

What Are Your Privacy Rights

Depending upon your state of residence, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

The table below shows the categories of personal information we may collect. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section What Information We Collect. We disclose personal information to service providers pursuant to written agreements solely to facilitate the employment applicant and hiring process and to improve delivery of Services. We may also disclose personal information to prospective employers at the direction of applicants to facilitate their job search. These disclosures are not a "sale" or "sharing" for cross-context behavioral advertising purposes under California, Colorado, or Virginia privacy laws.

When you consent to share your personal information with potential employers for employment decisions, this disclosure is made at your direction to provide the Services you requested. This is not a "sale" or "sharing" for cross-context behavioral advertising under California, Colorado, or Virginia privacy laws. Because this activity is not a sale or sharing for advertising purposes, it is not subject to opt-out rights under these laws, and Global Privacy Control signals do not apply to these consent-based disclosures. You may withdraw your consent to such disclosures at any time by contacting us at Legal@Confirm.com.

Disclosures for a Business or Commercial Purpose

We only collect sensitive personal information for the purposes allowed by law or with your consent where required. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

Under various US state privacy laws, these rights may apply to all personal data we collect about you, as described in this policy. However, these rights may not be applicable, are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")
• Right to request a qualified human reviewer evaluate any decision made through automated processing that significantly affects you

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
• Right to obtain a list of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
• Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Minnesota)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)

If biometric information has been collected from you, you may request that we permanently destroy it by contacting us at Legal@Confirm.com. We will comply within thirty (30) days, unless retention is required by law.

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at Legal@Confirm.com or by referring to the contact details at the bottom of this document.

We do not sell personal information or share it for targeted advertising or cross-context behavioral advertising purposes. Accordingly, Global Privacy Control (GPC) signals do not trigger opt-out actions, as there is no applicable sale or sharing activity to opt out of. If our data practices change in the future, we will update this policy and honor GPC signals as required by applicable law.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Under certain US state data protection laws, if we decline to act regarding your request, you may appeal our decision by emailing us at Legal@Confirm.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

How We Make Updates to This Policy

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

How to Contact Us About This Policy

If you have questions or comments about this Privacy Policy, you may contact us at: