Privacy Statement

Last modified: March 9, 2024

Introduction

Recognize Services Inc. ("Recognize" or "We") respect your privacy and are committed to protecting it through our compliance with this Privacy Statement.

This Privacy Statement describes our practices for collecting, using, maintaining, securing, and disclosing your Personal Data that we collect from you.

“Personal Data” as used in this Statement means information that identifies, relates to, describes, or can reasonably be linked directly or indirectly to a specific natural person. It does not include information that is considered anonymous, de-identified, or aggregated by applicable law.

This Privacy Policy does not apply to the extent we process Personal Data in the role of processor on behalf of our customer. If your information is being processed by Recognize on behalf of one of our customers, such customer’s privacy policy applies to the processing. Further information in this regard is provided in the corresponding section below.

What Personal Data do we collect?

We will collect Personal Data about you from a variety of sources, including information we collect from you directly (e.g., when you reach out to us through the online “Contact Us” forms) and information we collect about you from other sources as described below:

1. The categories of Personal Data we collect directly from you include:
• Name
• Contact details (e.g., phone number, postal address, or e-mail address)
• Content of enquiries (including your expressed interests) explicitly provided by you
• Information we collect automatically from you (e.g., data collected using cookies or other similar technologies (“Cookies”)) regarding your use of our website www.recognizeapp.com (“Website”). Further information about our use of Cookies is available in the Cookies Section below and our Cookie Notice.

When you are acting as an employee, representative, and/or agent of our customers, suppliers, providers, partners, or prospects, we may also collect the following information about you:

• Contractual data such as purchase orders, invoices, contracts, and other agreements between your company (or your employer) and Recognize that may include your contact information and signature
• IT related data such as your user ID, passwords, and logs about your usage (including profile details) of our Website
• Other details about our professional relationship, including our communications


2. We also collect some of the Personal Data listed above directly from publicly available sources (which would only include personal, professional, and contact details) from third parties that may provide us with Personal Data to improve and enhance our services.

We neither intend nor try to collect information on minors (16 years of age or younger). If a minor provides Personal Data to us without the consent of his or her parents or guardian, his or her parents or guardian may request us to remove the information we have about him or her.

How do we use your Personal Data?

1. Website visitors

Recognize processes Personal Data about you (as listed in the section above) while you visit and browse our Website (e.g., via Cookies), communicate with us through the Website (e.g., via “Contact Us” forms), and make use of other functions or services offered on our Website. We process such Personal Data for the following purposes:

1. We process your Personal Data on the basis of our legitimate interest to provide you with the requested Website and services for the following purposes:
   • Develop and provide you with our online features and content
   • Manage our Website
   • Deal with your inquiries and requests
   • Provide you with the required support
   • Ensure the security and/or integrity of our Website and IT infrastructure
   • To understand how you use our services and to enable us to improve and further develop the features, performance, and support available on our Website, which may entail the provision of anonymous statistical information about our visitors (however, without it being used to identify any individual user)
2. We process your Personal Data for the following purposes, provided you have granted your prior consent:
   • To send you personalized commercial communications (such as e-newsletters) via electronic and non-electronic means in relation to offers regarding our own products or services and those of our affiliates. You are free to choose whether or not to have your information used in this way. You will be provided with an unsubscribe link in all marketing communication we send you, and you can also revoke this consent at any time by contacting us at privacy@recognizeapp.com
   • For any other purpose disclosed to you at the time you provide us with your Personal Data to the extent that you have granted us your prior consent to that particular processing. For example, we will obtain your consent to collect and use certain types of Personal Data when we are required to do so by law (e.g., in relation to certain types of Cookies)
3. We will also process your Personal Data in order to ensure compliance with the applicable legal obligations to which Recognize is subject and cooperate with regulators and law enforcement bodies where necessary.

If you choose to provide some Personal Data via our Website, we will use that information for the purpose for which you provided it and in accordance with this Privacy Policy.

2. Employees, representatives, and/or agents of customers, suppliers, providers, partners, or prospects

Recognize processes Personal Data (as listed in the section above) about employees, representatives, agents, and/or other data subjects that have a relationship with our customers, suppliers, providers, partners, or prospects. We process such Personal Data for the following purposes:

1. We process your Personal Data on the basis of our legitimate interest for the following purposes:
   • Perform our contracts with our customers, suppliers, providers, partners, or prospects and/or in order to take steps to enter into such a contract and/or to comply with our record retention obligations;
   • To send you commercial communications (such as invitations to participate in Recognize hosted events) via electronic and non-electronic means in relation to offers regarding our own products or services and those of our affiliates, similar to those initially purchased/contracted by your employer under the agreement it has in place with us;
   • To improve, enhance, and further develop the features of our services;
   • All other purposes identified above for processing Website visitors’ Personal Data.
2. We process your Personal Data for the following purposes, provided you have granted your prior consent:
   • To send you personalized commercial communications (such as e-newsletters) via electronic and non-electronic means in relation to offers regarding our own products or services and those of our affiliates. You are free to choose whether or not to have your information used in this way. You will be provided with an unsubscribe link in all marketing communication we send you, and you can also revoke this consent at any time by contacting us at privacy@recognizeapp.com;
   • For any other purpose disclosed to you at the time you provide us with your Personal Data to the extent that you have granted us your prior consent to that particular processing. For example, we will obtain your consent to collect and use certain types of Personal Data when we are required to do so by law (e.g., in relation to certain types of Cookies).
3. We will also process your Personal Data in order to comply with the applicable legal obligations to which Recognize is subject and cooperate with regulators and law enforcement bodies where necessary.

You may contact your regular point of contact within Recognize if any of your Personal Data changes or if you would like to exercise any of your data protection rights with regard to your Personal Data that we maintain. In any event, you can also contact us at privacy@recognizeapp.com.

3. End users of Recognize’s services provided to our customers

In cases where we act as a processor on behalf of our customers who are your employers, such as when we act as an application service provider that delivers Recognize applications or services, we conduct such activities strictly in accordance with our customer’s instructions and pursuant to our contractual arrangements with them.

It remains the responsibility of our customers to inform their employees of the purposes for which they collect and use Personal Data, about the choices and means, and any ways that the individuals may limit the use or disclosure of their information. You should refer to your employer’s website or your human resources manager to understand the privacy practices that apply to Personal Data that we may maintain about you on our customer’s behalf.

Moreover, if you would like to exercise any of your data protection rights with regard to your Personal Data, you should contact your employer with any such requests. We will cooperate as appropriate with requests from our customers to assist with such responses.

How do we disclose your Personal Data and with whom?

Recognize will disclose your Personal Data to third parties under the following circumstances:

1. Recognize Group. Recognize works closely with other businesses and companies that fall under the Recognize group family. We will share certain information about you with other Recognize group companies for internal administrative purposes and insofar as it is reasonably necessary for the purposes stated in this Privacy Policy and relying on the corresponding legal basis.


2. Service providers. We will allow our service providers to access your Personal Data in order to carry out the data processing activities for the purposes described in this Privacy Policy to the extent applicable.
Additionally, we may disclose your Personal Data to third parties pursuant to our good faith belief that disclosure is necessary to the establishment of legal claims or defenses, to obtain legal advice, to exercise and defend our legal rights, to protect our rights and/or property and those of our affiliates, or to protect the life, body, or property of an individual.


3. Asset purchasers. We will also disclose your Personal Data with any third party that purchases or to which we transfer all or part of our assets and business. In these situations, Recognize will require the recipient of the data to protect the data in accordance with the relevant principles under the applicable data protection regulations and take steps to ensure that Personal Data is appropriately protected.


4. Customers, suppliers, providers, partners, and prospects. We will disclose your Personal Data with these recipients as necessary in connection with the performance of requested services or solutions or as otherwise reasonably necessary for the purposes stated in this Privacy Policy. In particular, we may disclose the following Personal Data to the following people:
   • Personal Data about employees, representatives, and/or agents of a customer to prospects in case you explicitly give us your permission to mention you as our reference.
   • Personal Data about employees, representatives, and/or agents of our suppliers, providers, or partners to our customers and prospects in case it is needed in the context of offering and/or providing our services.
   • Personal Data about employees, representatives, and/or agents of our prospects to our suppliers, providers, or partners in case it is needed to adequately offer and negotiate the provision of our services.


5. Law enforcement agency, court, regulator, government authority, or other third party with compelling authority. Please be aware that in certain circumstances it is possible that Personal Data may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders, or if required by applicable laws and regulations.

Where Recognize becomes aware that a third party is using or disclosing Personal Data in a manner contrary to this policy, Recognize will take reasonable steps to prevent or stop the use or disclosure.

How do we handle cross-border data transfer?

For data transfers to the United States of America, Recognize has certified itself under the Data Privacy Framework to provide an adequate level of protection to the Personal Data.

For data transfers to other jurisdictions that are not regarded as providing an adequate level of protection of the Personal Data, we have put in place additional appropriate safeguards (such as contractual commitments) in accordance with applicable laws and regulations to ensure that your Personal Data is adequately protected on the basis of the relevant sets of standard contractual clauses approved by the European Commission, available for consultation here. For more information on the appropriate safeguards in place, please contact us at the details below.

For how long do we store your Personal Data?

We will keep your Personal Data for as long as we have a relationship with you and insofar as the agreement with your employer is in force. Afterwards, we will retain your Personal Data for a period of time that enables us to defend ourselves against potential legal and contractual actions (during their expiration period) or as otherwise required under the relevant local laws. Finally, once these actions expire, we will proceed to delete your information.

What rights do you have over your Personal Data?

You have certain data protection rights regarding your Personal Data, including the following rights:

• To know how Recognize processes your Personal Data and to access the Personal Data we hold about you
• To request the rectification of inaccurate or incomplete Personal Data
• To request the erasure of your Personal Data when, among others, such data is no longer necessary for the initial purposes for which it was initially collected in accordance with applicable laws
• To restrict our processing of your Personal Data under certain circumstances
• To object to our processing of your Personal Data, having regard to the given circumstances and for reasons related to your particular situation
• To request the portability of your Personal Data, which will allow you to obtain and reuse the Personal Data in a usable electronic format for your own purposes and across different services without hindrance to usability, including its transmission to another third party
• To withdraw the consent you may have granted to a specific processing at any time
• To make a complaint to the competent supervisory authority

You may exercise the rights specified above by writing to your regular Recognize point of contact and/or by sending an email to us at privacy@recognizeapp.com.

Please note that if you send your request and we confirm that your request refers to the data held by Recognize as a processor, we are not responsible for and have no control over the privacy and data security practices of our customers, which may differ from those explained in this Privacy Policy. However, we may be under contractual obligation to notify your request to our customer(s) as appropriate. In such cases, they will contact you to respond to your request.

Please note that in case you are an employee, representative, and/or agent of a Recognize customer, supplier, provider, partner, or prospect, Recognize’s use of your Personal Data may be required to comply with Recognize’s agreement with your employer or representative, so you should discuss with them the consequences of restricting Recognize’s use of your Personal Data and eventually provide an alternate point of contact. Any failure to do so may result in an impossibility for Recognize to comply with our contractual obligations.

Third Party’s Links

Our Website may from time to time contain links to and from third parties’ websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that Recognize has no responsibility or liability for what the owners of such websites may do. Please check these policies before you submit any Personal Data to these websites.

How do we protect your Personal Data?

We intend to protect your Personal Data and to maintain its quality. We take reasonable precautions to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

Cookies

We collect information regarding your use of our Website through the use of Cookies. For example, we keep track of the domains from which people visit and we also measure visitor activity. Recognize may use this data to analyze trends and statistics and to help us provide better service.

In addition to cookies in the strict sense of the word, our Website may also contain electronic images known as Web beacons (sometimes called single-pixel gifs) that allow us to count users who have visited those pages and to deliver co-branded services.

On occasion, we may also personalize and customize our Website for certain visitors. If you visit one of these Websites, you may find it customized with references to products and/or services that we believe may be of interest to you based on your previous interactions with Recognize and information you have provided to us. While you are visiting these Websites, we may collect information about your visit to better tailor the site to your interests. An invitation to visit one of these Websites is usually presented as a personalized URL in an e-mail, a notice on a website registration page, or as a response to you logging on to a certain website.

If you choose to visit our Website, you are agreeing to let Recognize collect information about your visits and also to its association with other information about you and your relationship with Recognize.

For further information about the Cookies we use on our Website, please refer to our Cookie Notice here.

Data Privacy Framework

Recognize complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and, as applicable, the UK Extension to the EU-U.S. DPF and/or the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union, the United Kingdom, and/or Switzerland to the United States, respectively. Recognize has certified to the Department of Commerce that they adhere to the Data Privacy Framework Principles with regards to the processing of Personal Data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the Data Privacy Framework Principles, the Data Privacy Framework Principles shall govern.

For more details, please review the Recognize Data Privacy Framework Policy which applies to personal information transferred from member countries of the European Economic Area, the United Kingdom (including Gibraltar), and Switzerland pursuant to the DPF.

For more information about the Data Privacy Framework Principles and to view the certification for Recognize’s companies, visit the Data Privacy Framework website at https://www.dataprivacyframework.gov/. You may also contact us at privacy@recognizeapp.com to learn more about this certification.

Additional Specific Provisions Applying to Personal Data collected in California

If you are located in California, the following provisions apply to any Personal Data we collect about you.

The categories of personal information collected may be the following:

• Identifiers such as a real name, signature, alias, unique personal identifier, online identifier, internet protocol address, account name, or other similar identifiers
• Contact details such as postal address, email address, telephone number, mobile number
• Commercial information, including records of products or services purchased, obtained, or considered by you or your employer, or other purchasing or consuming histories or tendencies
• Bank account number, credit card number, debit card number, or any other financial information needed to charge you or your employer for services provided by Recognize or required to pay you for services rendered to Recognize
• Internet or other electronic network activity information, including but not limited to browsing history, search history, and information regarding your interaction with Recognize’s websites, applications, or advertisements
• Geolocation data
• Professional or employment-related information
• Inferences drawn from any of the information above described

You may find the business purposes for which we shall use your information in the chapter titled “How do we use your Personal Data and on what legal bases?”

The main sources from which we collect personal information are the individuals themselves, the Recognize websites, the cookies and web beacons we placed in them, our customers, suppliers, providers, partners, and prospects and their employees, agents, and representatives, the organizers of events we sponsor, the internet, and/or reputable providers of professional profiles/CVs.

You may find Recognize’s business and/or commercial purpose for collecting personal information in the chapter titled “How do we use your Personal Data?”

You may find the categories of third parties with whom Recognize shares personal information in the chapter titled “How do we disclose your Personal Data and with whom?”

You may have the right to ask Recognize to:

• Disclose the categories and specific pieces of information we have collected about you
• Access the personal information we have collected about you
• Delete the personal information we collected about you
• Disclose the sources from which the personal information is collected
• Opt out of the sale or sharing of personal information
• Limit the use or disclosure of sensitive personal information
• Disclose the business or commercial purpose for collecting or selling personal information
• Disclose the categories of third parties with whom Recognize shares personal information
• Disclose the categories of personal information that Recognize disclosed about you for a business purpose
• Not to receive discriminatory treatment for exercising these rights

You may exercise the rights specified above by filling out the form or by sending an email to us at privacy@recognizeapp.com.

Note that in the previous 12 months, we have collected and disclosed all of the categories of personal information we collect as explained in the “How do we disclose your Personal Data and with whom?” section of this Privacy Notice to third parties for a business purpose.

Please note that under California law, you also have the right to request us to disclose the categories of personal information that Recognize may have sold about you and the categories of third parties to whom the personal information was sold or shared. However, kindly note that Recognize does not sell personal information; there may be circumstances where we “share” personal information with third parties in a way that may be considered a “sale” under the CCPA or other similar laws (e.g., for cross-context behavioral advertising purposes where no money is exchanged). Specifically, this sharing occurs when we permit certain third-party advertising networks, social media networks, and similar businesses to process your personal information through cookies or tracking technologies in use when you visit or interact with our website. To opt out of cookies and tracking technologies on our website, please visit our homepage’s cookie banner and open the “Cookie Settings” link to visit the “Privacy Preference Center” where you can select your preferences and opt out of our use of cookie and tracking information.

Also kindly note that Recognize does not offer any financial incentives covered by section 1798.125 of the California Civil Code.

Dispute Resolution

Recognize will investigate and attempt to resolve complaints and disputes regarding the collection, use, and disclosure of Personal Data in accordance with the principles contained in this Privacy Policy. EU, United Kingdom, Gibraltar, or Swiss individuals with inquiries or complaints regarding our Data Privacy Framework policy should first contact Recognize through the following Form.

Recognize has further committed to cooperate with EU data protection authorities (DPAs), with the UK Information Commissioner’s Office (ICO) (and the Gibraltar Regulatory Authority (GRA), and with the Swiss Federal Data Protection and Information Commissioner with regard to unresolved Data Privacy Framework complaints concerning Personal Data transferred from the EU, UK (and Gibraltar), or Switzerland, respectively. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs, the ICO (and the GRA), or the Swiss Federal Data Protection and Information Commissioner, as applicable, for more information or to file a complaint. The services of EU DPAs, ICO (GRA), and of the Swiss Federal Data Protection and Information Commissioner are provided at no cost to you.

Under certain conditions more fully described on the Data Privacy Framework website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Questions

If you have any questions or comments about this Privacy Policy, or if you would like to exercise your rights with regard to the Personal Data that we maintain about you, please contact us at privacy@recognizeapp.com.

If you prefer to send us a letter, you may do so to the following addresses:

Changes to this Privacy Policy

This Privacy Policy may be amended from time to time consistent with the requirements of applicable data protection legislation.

If we change this Privacy Policy, we will notify you of the changes. Where changes to the Privacy Policy will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g., among others, to object to the processing). Moreover, and to the extent that Recognize relies on consent for the performance of any of its processing activities, we will make sure to request your consent where the aforementioned changes may have a substantial impact on the relevant processing before these changes are made effective.