PRIVACY POLICY

Last updated: August 5, 2023

This privacy policy (the “Policy”) governs the processing of personal data that may be carried out by Kaayu Technologies Inc. and its subsidiaries (collectively, “we” or “KAAYU”) whose address for communication purposes is located at 600-2000 Av. McGill College, Montreal, QC H3A 3H3, and registered in the Quebec Companies Register (NEQ): 1173089542, via its website www.kaayu.io, son application mobile ( l’« Application ») and their respective subpages (collectively, the “Website”).

Through this Policy, KAAYU informs users of the Website (the “Users”) that they can freely and voluntarily determine whether they wish to provide KAAYU with any personal data that may be requested of them or that KAAYU may obtain in the scope of the detailed processing purposes. below in Purposes, legal bases and retention periods for personal data. The User is neither legally nor contractually obliged to provide KAAYU with the personal data specified in this Policy. However, the refusal to provide certain personal data to KAAYU may imply the impossibility of establishing a contractual relationship with the User and the User may not be able to use KAAYU’s services, or only to a limited extent.

We reserve the right to modify this policy at our discretion and at any time. When we make changes to this policy, we will post the updated notice on the Website and update the effective date of the notice. Your continued use of the Website following the posting of changes constitutes your acceptance of those changes.

General Data Protection Regulation

This section of our Policy applies to the processing of personal data by KAAYU in its role as controller, or otherwise covered by the General Data Protection Regulation 2016/679 (the “GDPR”).

Identity and contact details of the Data Controller

In accordance with the GDPR, the User is duly informed that KAAYU acts as the controller of personal data collected via the Website and that these data will be recorded in a register of processing activities belonging to KAAYU.

If you have any questions or complaints regarding data protection that you would like to direct to our Data Privacy Officer (“DPO”), you can do so at the above address or at the email address following: support@kaayu.fr.

Data processed

KAAYU may collect and process the following information concerning the User:

• When you visit the Website, you send technical information to our web servers, which we store in server log files. This happens regardless of whether you contact us later (e.g. via the contact form). In all cases, we collect the following web usage and access data (which we call “usage data”):
  • La date et l’heure de la visite et la durée d’utilisation du site Web ;
  • L’adresse IP de votre appareil ;
  • L’URL de référence (le site Web à partir duquel vous avez peut-être été redirigé) ;
  • Les sous-pages du site Web visité ; et
  • Plus d’informations sur votre appareil (type d’appareil, type et version du navigateur, paramètres, plug-ins installés, système d’exploitation).

  Le traitement est exclusivement pseudonyme. Nous ne pouvons pas vous identifier en tant que personne sur la base de ces données.

• KAAYU propose à ses utilisateurs une application permettant de mettre en relation des professionnels talentueux et qualifiés avec des employeurs. Par conséquent, KAAYU peut collecter les informations personnelles suivantes auprès de vous en tant qu’utilisateur :
  • Nom ;
  • Adresse e-mail ;
  • Phone number. The app can only be used by candidates who verify their phone number with a confirmation code;
  • Personal information, such as your biography and/or CV, your professional experience or level of education, as well as any special skills.
  • Date of birth or address ;
  • Professional references ;
  • Educational certificates ;
  • Work permit ;
  • Other official documents such as your driving license or other relevant documents ;
  • The offers you are applying for ;
  • Your search queries ;
  • Your video interviews ;
  • Your bank account ;
  • Your pay; And
  • Contract documents for current and past activities for employers
  • Phone number. The app can only be used by candidates who verify their phone number with a confirmation code

Data sources

Generally, we collect your personal data directly from you. However, we would like to emphasize that our services are designed to only place suitable candidates with suitable employers. That’s why our services use feedback and behavioral data from your past employers to determine whether you’re suitable for the jobs you’re applying for. In case you have previously had an assignment with KAAYU, we may be listed as a previous employer. We may be able to create a quality score from this after evaluating feedback and behavioral data from your past employers. Obtaining this feedback serves as a quality check in our services.

Purposes, legal bases and periods of retention of personal data

The personal data collected will be processed for the following purposes and on the following legal basis:

We process your personal data for as long and to the extent necessary to fulfill our contractual or legal obligations. Therefore, we process (unless otherwise stated above) the above-mentioned data during the duration of the contractual relationship with you and after termination only to the extent and for as long as required by law. If, after the termination of the contractual relationship or deletion of your user account, the data is no longer necessary for compliance with legal obligations (e.g. tax or commercial law), it will be deleted, unless further processing is necessary to preserve evidence or defend a legal right. claims against us. The periods concerned, e.g. according to Spanish civil law, the duration is between three and thirty years (for example in the case of retention of documents subject to the German Social Security Code and relevant for company pension schemes).

Automated decision-making

We do not process your personal data through exclusively automated processing for the purpose of making decisions which have a direct legal effect on you without human intervention or which significantly affect you in a similar way.

KAAYU uses an algorithm that automatically generates a ranking of the most suitable candidates for each available job offer, based on the information contained in its database, searching for candidates who best match the requirements and characteristics of each offer job received. These automated decisions are made based on personal data collected during the recruitment process, behavioral data of the Candidate if he or she has already had missions at KAAYU, as well as performance data sent by the Candidates’ former employers.

In this context, we automatically process data in order to offer you a user experience in our application that is best suited to your needs and to display offers corresponding to your interests.

Candidates most suitable for a particular job offer (i.e. those included in the ranking) will be notified by KAAYU, allowing them to decide whether they are interested in participating in the specific selection process.

Please note, however, that all employers make the decision whether or not to work with you, independently and within their own company policies and processes. If you disagree with an employer’s decision, please contact them directly.
The automated processing by KAAYU of Candidate data is necessary to carry out the tasks described in the agreement concluded with the Candidates, and thus provide the services offered by KAAYU via its platform.

If, as a candidate, you do not accept the automated processing of your personal data, you cannot accept this policy. In this case, it will be impossible for us to provide you with our services or to allow you to become a member of the KAAYU platform.

Acceptance and consent

The User declares to have been informed of the conditions relating to the protection of personal data, by accepting and consenting to the processing of this data by KAAYU, in the manner and for the purposes indicated in this Policy.

The user may cancel the service or revoke consents granted to KAAYU for data processing at any time. KAAYU uses two mechanisms through which users, upon request, can activate or cancel email communication services in a simple and free way, both during registration and in the access menu. For this purpose, the User must access the Candidate access menu and activate or deactivate the sending option in the email communications section. Additionally, this service can be canceled by following the instructions given at the bottom of the main text included in the emails. The User can also deactivate notifications in the mobile application from the settings of their own mobile device.

Accuracy and veracity of the data provided

Users undertake to provide true and accurate personal data, as well as to inform KAAYU of any modification or update of this data. Users are solely responsible for the veracity of their personal data. Failure to communicate or incomplete communication of the personal data necessary to formalize the rental of the Service will result in the impossibility of providing this Service and, therefore, where applicable, the termination of the contract.

Recipients of personal data

Processors

In certain cases, KAAYU will allow, for the proper provision of the Services, access to the personal data of Candidates by third parties. These third parties will act as data processors and will therefore not process this personal data for their own purposes or for purposes other than those stipulated in this Policy. KAAYU guarantees that all these entities comply with data protection regulations which, at the same time, are directly applicable to Subcontractors. Thus, these third parties will always follow the instructions given by KAAYU and will not under any circumstances disclose this information to third parties. It is possible that these Subcontractors in turn subcontract certain tasks related to the services mentioned in this contract to third parties, and that they also act as Subcontractors and, thus, they will be bound by the same provisions stipulated for Subcontractors in this policy.
The subcontracted entities that will act as subcontractors will be, among others:

• Providers of technological services and telecommunications networks necessary for the provision and management of services, as well as support for the Candidate:

Your personal data will also be transmitted for technical reasons if this is necessary for the provision of the website or services (i.e. our host and possibly other service providers, e.g. Kustomer, Inc., 1019 Market St, San Francisco, CA 94103 as a provider of our customer relationship management solution).

In this context, data recipients also include third-party providers mentioned in our overview of cookies and similar technologies. Detailed information about the third-party providers we use in this context, e.g. to process customer requests or web analysis, can be found in the information on cookies and similar technologies in the cookie policy.

• Business Processing Outsourcing (BPO) Providers for Interview Documentation and Validations

KAAYU may subcontract to third parties to assist with documentation selection and/or video interview validators.

• Agencies that help us manage candidates’ tax and professional obligations.
• Payroll providers:

KAAYU may subcontract third parties to help process all the payrolls and payroll

• Lawyers which provide us with legal services.

Transfers of personal data

Furthermore, in exceptional cases and if a corresponding legal basis is available, we will transfer personal data to third parties, who may process the user’s personal data for their own purposes. Among these third parties, we can find:

• Financial and criminal prosecution authorities, social security institutions or courts and, in certain circumstances, also upon request to the supervisory authority responsible for us under legal regulations in Germany, the Federal Employment Agency in Nuremberg.
• Potential Employers: The main purpose of our services is to connect you with potential employers. It therefore goes without saying that we pass on your profile information and application documents to the respective interested employers within the application so that they can contact you.
• Group companies: KAAYU has subsidiaries in various countries around the world. These help KAAYU provide the necessary services to give you the best possible user experience.
• Mutual social security partners and other organizations providing health care, occupational health and safety services are required to comply with the obligations applicable work related

Contrôleurs conjoints

En outre, en fonction de votre pays et du type de processus d’utilisation auquel vous participez, des conditions particulières seront appliquées au traitement des données par certaines des sociétés locales suivantes qui exécutent les services en tant que responsables conjoints du traitement. , avec KAAYU

• Kaayu Technologies France (France)
• Kaayu Technologies Inc. (QC, Canada)
• Contrat de niveau de service Kaayu Technologies (RDC)
• Kaayu Technologies USA, Inc. (Delaware)

Under no circumstances will data be transferred between these companies without your express consent, and you will always be informed of the company(s) that will process your data through the particular terms and conditions of the recruitment process in which you are participating. .

Data processing outside the European Economic Area (EEA)

We do not transfer your personal data to countries outside the EEA without taking appropriate safeguards. We will therefore always ensure that an adequate level of data protection is guaranteed at all times. To this end, we will ensure that sufficient safeguards within the meaning of the GDPR are in place, e.g. because so-called EU standard contractual clauses are included in our contracts with recipients in order to guarantee the security of processing and an appropriate level of data protection at all times, or because other appropriate guarantees within the meaning of the GDPR are in place, such as binding corporate rules or approved rules of conduct.

Security measures

Your data will be protected by technical and organizational security measures to ensure the security of personal information and to prevent its modification, loss, processing or unauthorized access, in light of the scope, context and circumstances. purposes of the processing. ; the state of the art and existing risks, such as information system security control procedures. When determining these measures, criteria such as the scope, context and purposes of the processing were taken into account, as well as the state of the art and the existing risks.

Exercise of rights

The User may exercise the following rights regarding data protection before KAAYU.

Furthermore, users can also revoke a given consent at any time. However, this revocation is only valid from that moment. Any processing that may have taken place before the revocation remains unaffected.

If Users wish to exercise their rights as data subjects, they can do so via the platform settings, or by modifying their Candidate profile. Alternatively, you can also contact the KAAYU DPO at support@kaayu.fr from the email address associated with the account on which you wish to exercise your rights. If sending a request by e-mail, it must include a copy of your identity document or any other equivalent identity document, as well as the minimum content stipulated in the applicable regulations.

If the application does not meet all specified requirements, KAAYU may request that it be corrected. No consideration for the exercise of any right will be required. The exercise of rights will be granted unless there is a legal or contractual obligation to retain them.

California residents may have additional rights and choices regarding personal information. Please see Your California Privacy Rights for more information.

Your California Privacy Rights

This section addresses specific disclosure requirements under the California Consumer Privacy Act of 2018 (“CCPA”). This applies to personal information about California residents using our website. For purposes of the CCPA, personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

If there is a conflict between this CCPA Notice and any of our other privacy notices, this CCPA Notice will govern only with respect to the personal information of California residents.

Categories of Personal Information

The table below describes the categories of personal information we collect and the sources from which we collect personal information, organized by the categories specified by the CCPA.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from the forms you fill out on our website.
• Indirectly from you. For example, by observing your actions on our website.

We use this personal information for the purposes described in the Purposes, legal bases and retention periods for personal data section set out above.

Sharing personal information

We may share your personal information by disclosing it to a third party for marketing purposes. We disclose these business purposes only pursuant to written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose other than performance of the contract. In the preceding twelve (12) months, we have disclosed personal information for marketing purposes to the categories of third parties indicated in the table below.

We do not sell personal information. In the preceding twelve (12) months, we have not sold any personal information. To learn more about your rights to sell personal information, see sectionon Rights to unsubscribe and opt-in to the sale of personal information.

Your rights and choices

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:

The categories of personal information we have collected about you.
• The categories of sources of the personal information we have collected about you.
• Our business or commercial purpose for collecting or selling this personal information.
• The categories of third parties with whom we share this personal information.
• If we have sold or disclosed your personal information for a commercial purpose, two separate lists disclose:
  • sales, identifying the categories of personal information purchased by each destination categorynatary; and
  • disclosures for commercial purposes, identifying the categories of personal information obtained by each category of recipients.
• The specific personal information we have collected about you (also called a data portability request).

Right to Delete

You have the right to request that we delete any personal information we have collected from you and retained, subject to certain exceptions (the “Right to Deletion”). Once we receive your request and confirm your identity (see Exercising your rights to know or delete), we will review your request to see if an exception allowing us to retain information applies. We may refuse your deletion request if retaining the information is necessary for us or our service providers to:

For instructions on exercising your opt-out or sales opt-in rights, see the Opt-out and Sales Opt-in Rights Regarding Personal Information section.

Response time and format

We will acknowledge receipt of your request within ten (10) business days. If you do not receive confirmation within ten (10) days, please contact support@kaayu.fr.

We endeavor to respond substantially to a verifiable consumer request within forty-five (45) days of receipt. If we need more time (up to an additional forty-five (45) days), we will notify you in writing of the reason and the extension period.

If you have an account with us, we will send you our written response to that account. If you do not have an account with us, we will send you our written response by mail or electronically, at your option.

Any information we provide will only cover the twelve (12) month period prior to receipt of your request. The response we provide will also explain the reasons why we cannot comply with a request, if applicable. For data portability requests, we will select a format for providing your personal information that is easily usable and should allow you to transmit the information from one entity to another entity without hindrance, including by email.
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 explain to you why we have made this decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are age sixteen (16) or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of any Users.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that may result in different prices, rates, or quality levels. Any CCPA-authorized financial incentive we offer will be reasonably related to the value of your personal information and will contain written terms describing important aspects of the program. Participation in a financial incentive program requires your prior consent, which you can revoke at any time.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section 1798.83) permits users of our website who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@kaayu.fr.

Contact details

If you have any questions or comments about this policy, how KAAYU collects and uses your information described in the policy, your choices and rights regarding such use, or if you wish to exercise your privacy, please do not hesitate to contact us at:

Canada

• Site Web : https://www.kaayu.ca/privacy-policy </li >
• Email : support@kaayu.fr.
• Adresse postale :
  Kaayu Technologies INC.
  600-2000 Av. Collège McGill, Montréal, QC H3A 3H3

Europe

• Phone: +33 7 62 79 11 55
• Website: https://www.kaayu.fr/privacy-policy
• Email: support@kaayu.fr
• Postal Address:
  Kaayu Technologies France. SLA
  du Stade de France, Porte E, Zac du Cornillon Nord, 93216 Saint-Denis
  Paris, France

United States

• Website: https://www.kaayu.us/privacy-policy
• Email: support@kaayu.us
• Postal Address:
  Kaayu Technologies INC. USA
  901 Mopac Expressway South Barton Springs, Building 1, Suite 300, Austin, TX 78746,
  United States

Congo DRC

• Website: https://www.kaayu.cd/privacy-policy
• Email: support@kaayu.cd
• Postal Address:
  Notebook Technologies INC. DRC
  4 Av. des Batetela, Kinshasa, Congo – Kinshasa
  Attn: WOOD