Talroo Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in Talroo’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). Any undefined capitalized terms used herein have the meaning ascribed to them in the Privacy Policy. We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, “CCPA/CPRA”), and any terms defined in the CCPA/CPRA have the same meaning when used in this notice.

Information We Collect

Our Digital Assets collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our Digital Assets have collected the following categories of personal information from consumers within the last twelve (12) months:

Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Company obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Website and Advertising.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information with us to express interest in certain employment opportunities, we will use that information to connect you with potential employers.
• To provide, support, personalize, and develop our Digital Assets, products, and services.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your experience on the Digital Assets and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Digital Assets, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Digital Assets, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA/CPRA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Talroo, Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Talroo, Inc. about our consumers is among the assets transferred.
• To provide and improve Extension features, including application autofill, job and application requirement extraction, similar-job recommendations, diagnostics, and support. Extension data is used solely for these purposes and is not used for advertising, targeted marketing, or any unrelated secondary purpose.
• To power AI-assisted features across the Talroo Platform — including resume ingestion and parsing, job application autofill (on Talroo-hosted forms and through the Extension), qualifying-question prefill, the job-search chat agent, conversation summarization, content and security filtering, candidate-to-job fit scoring, career-intent inference, personalized messaging, and normalization of screening answers and search queries — using AI service providers (currently Google Vertex AI (Gemini), Google Gemini API (direct, paid tier), OpenAI, AWS Bedrock, and Groq) acting as processors on Talroo’s behalf. All providers operate under enterprise or paid API terms that prohibit use of customer prompts, outputs, or data to train or improve their foundation models.
• To train or improve Talroo’s own proprietary job-matching models using Extension interaction data. Talroo will provide advance notice and obtain your consent where required by applicable law before using Extension data for this purpose.

Company will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

Company may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA/CPRA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

We share your personal information with the following categories of third parties:

• Service providers, including customer relationship management platforms that receive chat conversation data for internal sales and account management purposes.
• Employers in fields in which you have expressed an interest.
• AI service providers (Google Vertex AI (Gemini), Google Gemini API (direct, paid tier), OpenAI, AWS Bedrock, and Groq) acting as processors to power AI-assisted features across the Talroo Platform.
• Third-party applicant tracking systems (ATS), solely to the extent you direct the Extension to fill in an application form on a third-party job application page and submit that application.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

• Category A: Identifiers.
• Category B: California Customer Records personal information categories.
• Category C: Protected classification characteristics under California or federal law.
• Category F: Internet or other similar network activity.
• Category G: Geolocation data.
• Category I: Professional or employment-related information.
• Category K: Inferences drawn from other personal information.
• Category L: Sensitive Personal Information (SPI), where you have voluntarily provided demographic information for autofill purposes.

We disclose your personal information for a business purpose to the following categories of third parties:

• Service providers, including customer relationship management platforms that receive chat conversation data for internal sales and account management purposes.
• Employers in fields in which you have expressed an interest.
• AI service providers (Anthropic (Claude), Google Vertex AI (Gemini), Google Gemini API (direct, paid tier), OpenAI, AWS Bedrock, and Groq) acting as processors for AI-assisted features across the Talroo Platform.
• Third-party applicant tracking systems (ATS), at your direction when you submit an application through the Extension.

Your Rights and Choices

The CCPA/CPRA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA/CPRA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Company disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

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

Deletion Request Rights

You have the right to request that Company delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
7. Comply with a legal obligation.
8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Correction Rights

You have the right to request that Company correct inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes of processing. Once we receive and confirm your verifiable consumer request, we will use commercially reasonable efforts to correct the inaccurate information, unless an exception applies. To exercise this right, please submit a verifiable consumer request to privacy@talroo.com or at privacy.talroo.com.

Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right to direct Talroo to limit its use and disclosure of your Sensitive Personal Information (“SPI”) to uses necessary to perform the services you have requested or for other purposes permitted under CPRA. SPI that Talroo may collect includes racial or ethnic origin, disability status, sex life or sexual orientation, veteran or military status, and religion, where you voluntarily provide that information for autofill purposes through an Extension. Talroo does not use SPI for purposes beyond those permitted under CPRA without your consent. To exercise this right, please contact us at privacy@talroo.com or at privacy.talroo.com.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at privacy@talroo.com, or by submitting an online request at privacy.talroo.com.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. 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 that account. If you do not have an account with us, we will deliver our written response by mail or electronically, 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 useable and should allow you to transmit the information from one entity to another entity without hindrance.

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.

Non-Discrimination

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

Personal Information Sales and Sharing Opt-Out and Opt-In Rights

If you are age 16 or older, you have the right to direct us to not sell or share your personal information at any time (the “right to opt-out”). We do not sell or share the personal information of consumers we actually know are less than 16 years old. Consumers who opt-in to personal information sales or sharing may opt-out of future sales or sharing at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting privacy.talroo.com.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales or sharing. You may opt back in at any time by contacting us at privacy@talroo.com.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Digital Assets that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Talroo does not disclose your personal information to third parties for direct marketing purposes, but if you have any questions about this, please send an email to privacy@talroo.com or write us at: 9600 N Mopac Expressway, Plaza 2, Suite 625, Austin, TX 78759.

Changes to Our Privacy Notice

Company reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice through the Talroo Platform and update the notice’s effective date. We encourage you to review this notice periodically for any updates.

Contact Information

If you have any questions or comments about this notice, the ways in which Company collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

• Website: www.talroo.com
• Email: privacy@talroo.com
• Postal Address:
  • Talroo, Inc.
  • 9600 N Mopac Expressway, Plaza 2, Suite 625
  • Austin, TX 78759