JobPair

JOBPAIR PRIVACY NOTICE

Last Updated: 15 June, 2024

ABOUT THIS POLICY AND YOUR PRIVACY

Your privacy is important to JobPair ("JobPair", also referred to as "we", "us", and "our"). This Privacy Policy explains how we collect, use, and disclose your Personal Information when you interact with us or otherwise access or use any of the website, products, or services that are owned, operated, sold, or otherwise provided by JobPair, including our website (https://JobPair.ca/) and all associated subdomains (collectively, the "Website"), the JobPair platform (the "Platform"), and any other website, documents, applications, instruments, software, hardware, products, or services that contain a link or direction to this Privacy Policy (together, the "Services").

Please read this Privacy Policy carefully to understand how we deal with your Personal Information. By using or accessing our Services, you accept and agree to be bound by and comply with this Privacy Policy. If you do not agree with this Privacy Policy, you may choose not to use the Services. Please also refer our General Terms and Conditions.

JobPair will obtain consent where required by law for the collection, use, and disclosure of Personal Information. By accessing or using the Services or otherwise submitting your Personal Information to us, you consent to our collection, use, and disclosure of your Personal Information for the purposes and in the ways described in this Privacy Policy. If you do not agree, you may choose not to use our Services.

This Privacy Policy may change from time to time and at our sole discretion to comply with applicable privacy laws, regulations, standards, and best practices in Canada or elsewhere, as well as our process and available technologies. All changes will be effective immediately upon posting. Where such changes are significant or materially affect your rights under this Privacy Policy, we will provide you with notice of such changes by email. Your continued use of the Services after we make any changes means that you accept and consent to those changes, so please check this Privacy Policy regularly for updates. If you have any questions or concerns about this Privacy Policy, please contact our Privacy Officer at [email protected].

WHAT IS PERSONAL INFORMATION?

"Personal Information" is information relating to an identified or identifiable individual. It can include, but is not limited, to an individual’s name, home address, phone number, email address, age, sex, gender, health, marital or family status, identifying numbers, government identification information, financial information, educational history, technical information (including device and browser type), IP address, and geo-location information.

Personal Information does not include certain business contact information used for employment, business, or professional purposes, nor does it include de-identified, anonymous, or aggregated information used for statistical or research purposes.

HOW PERSONAL INFORMATION IS COLLECTED BY JOBPAIR

Purposes for Collection

Personal Information is collected from you (as a "User") when you access or use the Services. This Personal Information is collected in many ways and for different reasons, as explained in this Privacy Policy, but is generally collected for the following purposes:

· to deliver the Services and monitor their quality and operation, including the matching of employers with eligible employees based on job criteria and candidate profiles;

· to receive payments for the Services delivered to you;

· to understand your needs and preferences and those of our other clients;

· to respond to your requests about the Services;

· to conduct research and statistical analysis on our Services;

· to administer and enhance yours and other clients' relationship with us;

· to comply with audit, compliance, and legal requirements, including any reporting or enforcement requirements with respect to residential tenancies or human rights laws (including bylaws), policies, guidelines, boards, or tribunals in Canada or elsewhere;

· to manage and develop our business, including customizing our Services for current and future clients and creating new industry partnerships;

· to communicate about current or future products, technology, and service offerings;

· to allow you to participate in interactive features, chats, geo-location functions, or similar features on, in, or regarding our Services;

· to conduct due diligence and carry out business transactions that may involve the purchase, sale, disclosure, or transfer of Personal Information;

· to comply with this Privacy Policy; and

· any other purposes for which we have consent (or do not need consent) under applicable law.

Please note that as our Services involve matching prospective employees with prospective employers, some limited employee contact information may be shared with the employer to facilitate further communication once a match is made. After the match is made, however, we are no longer involved in the collection and sharing of your personal information. As such, once the match is made, it is your responsibility to exercise caution and use discretion when communicating with employers and other users of JobPair, including when providing or otherwise sharing any of your personal information, and, in the case of employers, to ensure compliance with all applicable privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and any applicable provincial privacy legislation.

Direct Collection

Most of the Personal Information we collect from you is collected directly, when you actively provide your Personal Information to us by creating an account, uploading your resume and other documents, sharing job preferences, or otherwise interacting with us or through our Website or Platform. The Personal Information we collect directly from you may include:

· individual information, such as name, age, date of birth, marital status, sex, gender, and/or preferred pronouns;

· contact information, such as email address, phone number, physical address, and mailing address;

· geo-location information, such as your exact or approximate location when using the Services in order to find employees or job postings close to you;

· employer account information, such as username and passwords to access the Services, your transaction history, interactions with us, communications and marketing preferences, and any other information provided in your account;

· employee account information, such as username and passwords to access the Services, identification information, geo-location information, communications preferences, and any other information provided in your account;

· biographical information, such as work history, education history, curriculum vitae, family information, hobbies, or interests;

· government identification information, including copies of photo identification for identify verification; and

· any other information you directly provide to JobPair.

This Personal Information is collected so you can create and maintain an account with us, purchase and use our Services safely and with full functionality, and otherwise communicate with us about our Services including our Website and Platform.

We also need this Personal Information to protect the security of your account, to allow you to access all of our Services' features, to deliver technical support and for troubleshooting with our Services, and to send you important information about JobPair and our Services, such as safety information, updated features, material changes to our General Terms and Conditions and this Privacy Policy, and any violations or breaches of our policies.

JobPair' payment collection services are provided by Stripe Payments Canada, Ltd. ("Stripe"), a third-party software platform used to accept payments in connection with web and mobile applications (“Payment Processing Services”). Stripe will collect Personal Information from you in order to accept your payments. Stripe has its own Privacy Policy which will govern how Stripe uses, collects and shares your Personal Information, however, you acknowledge and agree that in providing its Payment Processing Services, Stripe may transfer, process, disclose and store customer and payment data outside of Canada. For more information, on how Stripe may use your data, go to https://stripe.com/en-ca.

In addition:

· We only collect financial information to verify and process payments for our Services as well as for fraud detection and prevention, and tax and financial reporting. WE ARE NOT RESPONSIBLE FOR ANY PRIVACY OR INFORMATION BREACHES RELATED TO A THIRD-PARTY SERVICE LINKED OR DIRECTED THROUGH OUR WEBSITE.

· If you opt-in and consent to receive marketing information from JobPair, we will process your email address and send you marketing information about our Services, as well as newsletters and advertisements.

Automatic Collection

We also collect certain information automatically when you interact with us or the Services. The Personal Information we collect automatically from you may include usage information, such as information about your interaction with our Platform, Website or other online platforms such as search engine(s) and keywords used to find our Website, requested pages, referring pages, pages visited on our Website, log files for our Website and Platform, date and time of Website access, frequency of visits, and pairing of devices to your account; and

This Personal Information is collected to maximize how our Services work, to help identify and resolve technical errors, to monitor safety and operational issues, and to provide quality support.

WEBSITE COOKIES AND COLLECTED INFORMATION

Cookies are files which are stored on your computer or device after you visit the Website.

We may use cookies to understand how our Website are used and to help us improve your overall online experience. Except for strictly necessary cookies (as described below), most of the cookies on our Website expire at the end of your current session, except some that may have an extended lifespan. Some cookies, however, are persistent and will never expire.

Our Website may use the following types of cookies:

· Strictly Necessary – These cookies are necessary for the essential functions of the Website (for example, for effective security or communication) and cannot be switched off in our systems. You can set your browser to block or alert you about these cookies, but this may impact the functionality of the Website.

· Visitor Statistics and Performance – These cookies collect aggregate information and statistics from our Website regarding visitors, length of visit, date of visit, bandwidth used, pages viewed, and sites visited before and after leaving our Website. Personal Information is not directly linked to this information, such as your name, address, email, or telephone number.

· Website Preferences – These cookies are used to provide the Services or remember settings to enhance your visit; for example, text size or other preferences that improve your online experience. The information collected by these cookies is anonymous and does not enable us to track your browsing activity on other website. By using our Website, you agree that we can place these types of cookies on your device. If you prefer to restrict, block, or delete cookies from our Website, you can adjust your browser settings (see how to change cookie settings in Edge, Chrome and Safari). If you choose to disable all cookies, we cannot guarantee that the Website will work as expected.

HOW PERSONAL INFORMATION IS DISCLOSED TO THIRD-PARTIES

We may disclose your Personal Information to JobPair employees and contractors, or to companies that are related to us, including any parent companies or subsidiaries of JobPair. However, we will only do so on a need-to-know basis as described in this Privacy Policy or as permitted by applicable law.

We may also disclose Personal Information to third parties, including service providers for our Website and Platform, or to government departments, agencies, or authorities that regulate residential tenancies or human rights in Canada or elsewhere (the "Third-Parties"). Third Parties may also provide us with services related to customer support, information technology, payment processing, sales and marketing, data analysis, research, legal compliance, and surveys.

These Third-Parties may access the Personal Information for the following purposes:

· help maintain the security of our Website, network, and system;

· collect, store, and/or process data on behalf of JobPair;

· help us better deliver the Services and improve their features;

· provide marketing and/or promotional assistance;

· analyze how the Services are used;

· help JobPair create industry partnerships to improve our Services;

· monitor and enforce applicable laws, policies, and requirements; and

· with your consent, for any other purpose disclosed by us at the time you provide the information.

JobPair does not sell your personal information or disclose it for any reason other than for the purposes set out in this Privacy Policy.

Contractual Measures and Third-Parties

When possible, we will use contractual measures to restrict how Third-Parties use your Personal Information under this Privacy Policy and applicable law. Such contractual measures will require Third-Parties in Canada or internationally to:

· keep Personal Information confidential;

· use Personal Information only for the purposes for which we disclose it to them;

· use non-Personal Information that has been de-identified where possible;

· process Personal Information with at least the same standards set out in this Privacy Policy; and

· maintain privacy and security standards that comply with this Privacy Policy and applicable privacy laws.

Our Website may also include links to third-party website, plug-ins, services, social networks, or applications. By clicking on those links, you may allow the third-party to collect, use, or disclose your Personal Information. If you follow a link to a third-party website, please note that the policies of those third-parties will govern your interactions and any Personal Information collected by them. We do not accept any responsibility or liability for the policies of third-parties. Because we do not control third-party website, we encourage you to read the policies of every website you visit.

It is also possible that, despite our safeguards and best efforts, your Personal Information may be accessed by law enforcement, governmental agencies, or national security authorities in the places where the Third-Parties are located.

We may also disclose your Personal Information in the limited circumstances described below:

· When You Agree or Direct Us to Share: You may authorize us to disclose your Personal Information with others, including third party providers related to the operation of our Services. For example, we may need to disclose your Personal Information to third parties who provide hosting, analytics, and communication infrastructure.

· For External Processing: We may disclose Personal Information to Third-Parties and/or to other entities who are instructed to process the Personal Information for us, using appropriate confidentiality and security measures under this Privacy Policy.

· For Business Transactions: If JobPair’s business or assets are sold or financed (for example, in bankruptcy, receivership, or liquidation), Personal Information may be disclosed under confidentiality restrictions for due diligence purposes or collected, used, or disclosed by JobPair’s successor in accordance with this Privacy Policy.

· For Business Transfers: If JobPair’s data or information is transferred to a new entity in a business transfer (including reorganizations, amalgamations, mergers, and acquisitions) the privacy policy of that entity will be posted on the Website and will govern the collection, use, and disclosure of your Personal Information going forward. JobPair is not required to communicate such a transfer to you in advance; however, this Privacy Policy will be updated as needed as part of the business transfer.

· For Legal Reasons or to Prevent Harm: We may use or disclose Personal Information: to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims or proceedings; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, threats to the security of Services, public safety, or safety of an individual.

If a legal process (for example, a search warrant, court order, or subpoena) requires disclosure of your Personal Information, we will use our best efforts to notify you, except if the law prevents us from notifying you. If a legal process imposes a non-disclosure period, we will only provide notice to you after the non-disclosure period expires. We may not be able to provide you with notice in urgent or counterproductive circumstances either (for example, when there is a public safety issue or an individual emergency).

NON-PERSONAL INFORMATION

We may aggregate, redact, de-identify, or anonymize your Personal Information so that it can no longer be associated with you individually ("Non-Personal Information"). For example, we may use anonymous markers or anonymous IDs.

We reserve the right and may use or disclose any such Non-Personal Information for any legitimate purpose including research, statistical, or business purposes, without further notice to you and without your consent. Further, we may disclose such Non-Personal Information publicly or to Third Parties (for example, in public reports about our Services, in research, statistical, or scientific studies, and to our service providers).

HOW PERSONAL INFORMATION IS RETAINED AND PROTECTED

We will retain your Personal Information as long as needed or reasonable to fulfil the purposes for which it was collected, for our legitimate business interests, for legal and regulatory compliance, and to prevent harm, as described in this Privacy Policy.

JobPair processes and stores Personal Information at a private server location hosted by digitalocean in Toronto, Canada. We use physical, electronic, contractual, and administrative measures appropriate for the sensitivity of the Personal Information and designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. We may use Third-Parties to ensure the appropriate measures are used.

We only retain your Personal Information for as long as necessary to provide you with the Services or as required under law. We use appropriate security measures when destroying Personal Information, including shredding paper records and permanently deleting electronic records.

The security of your Personal Information also depends on you. Where you have a password to access your account or to use our Services, you must keep this password confidential. Please use a strong password and do not share your password with anyone.

Unfortunately, the Internet is not completely secure. Although we use all reasonable efforts to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted via our Website or to our Services. We are not responsible for any circumvention of privacy settings, or failure to comply with security measures, on the Website or in our Services.

HOW TO ACCESS, CORRECT, OR DELETE YOUR PERSONAL INFORMATION

JobPair uses all reasonable efforts to keep your Personal Information accurate and complete. We rely on you to tell us if your Personal Information needs changes. You also have the right to correct your Personal Information.

If you discover an error in your Personal Information, your JobPair account lets you change and delete certain Personal Information. For instance, you can edit or delete certain data you provide to us in your account and delete your account if you wish. You may also contact our Privacy Officer for this purpose and we will make changes where reasonable possible. We will not change your Personal Information if we believe the change would violate any legal requirement or cause the information to be incorrect.

We may ask you to send a correction or deletion request in writing, and we will need to confirm your identity before making a requested correction or deletion.

If you choose to delete your account and stop using our Services, we will use our best efforts to delete your Personal Information within 30 days. However, please note it may take up to 90 days to delete all your Personal Information, due to our systems and Third Parties who store and process data for us. We may also need to retain some information for legal or governmental reasons, for safety or security concerns, or to prevent harm.

You have the right to request access to your Personal Information. However, please be aware that JobPair may not provide access to information that is confidential commercial information, that was collected to investigate a breach of contract or a violation of law, that is related to dispute resolution, that may be withheld by law, or that may be subject to lawyer-client privilege or other form of confidentiality protection. To access the Personal Information we hold about you, please contact our Privacy Officer.

CONSENT AND HOW TO WITHDRAW

We use and disclose Personal Information only for the purposes for which the Personal Information was collected as described in this Privacy Policy. By agreeing to this Privacy Policy, you consent to our collection, use, and disclosure of your Personal Information as described in this Privacy Policy.

If we wish to collect, use, or disclose your Personal Information in any other way or for any new purpose not described in this Privacy Policy, we will ask for your consent to do so (including by updating our Privacy Policy), unless consent is waived under the applicable law.

When you consent to the collection, use, and disclosure of your Personal Information, you also have the legal right to later withdraw or modify your consent, completely or partially. To do so, please contact our Privacy Officer. Please note that any withdrawal or modification of consent could prevent us from being able to provide you with certain Services or to enable certain features or functions. We will do our best to explain the impact of your decision on the Services when you contact our Privacy Officer.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

JobPair does not transfer Personal Information outside of Canada, and our servers are located in Canada to limit the movement of your Personal Information across borders.

NO INFORMATION FROM CHILDREN

Our Services are not intended to be used or accessed by children (minors) under 18 years of age. We do not knowingly collect, use, disclose, or solicit Personal Information from children under such age and we ask that no one under such age provide their Personal Information to us. If we learn we have accidentally collected Personal Information from a child without parental consent, we will delete that Personal Information immediately. If you believe we might have received Personal Information about a child, please contact our Privacy Officer.

EUROPEAN UNION AND CALIFORNIA RESIDENTS

JobPair does not intend to collect, use, or disclose Personal Information or otherwise monitor the Personal Information of clients who visit the Website or purchase or use the Services from the European Union (the "EU") or from California, USA ("CA"). If we do end up collecting Personal Information from the EU or CA, we will take immediate action to safely dispose and destroy that Personal Information as soon as we are notified that we are in possession of Personal Information from the EU or CA. If you believe that we have collected, used, or disclosed Personal Information from the EU or CA, please notify our Privacy Officer immediately.

HOW TO CONTACT US AND OUR PRIVACY OFFICER

If you object to the collection, use, or disclosure of your Personal Information, if you are seeking access to your Personal Information that is held by us, or if you wish to complain, make an inquiry, or ask questions about this Privacy Policy please contact our Privacy Officer at [email protected].

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time as we add new Services, as we improve our current offerings, and as technologies and applicable laws change. You can check the “Last Updated” icon at the top of this page to see when changes are made. Any changes take effect as soon as we post them on our Website.

We will notify you if material changes are made to the Privacy Policy, and obtain your consent where required by applicable law. We will provide notice to you by email, by posting the notice on the Website, or by posting on any of our applications or platforms that link to this Privacy Policy.