REQeV California Privacy Notice

This California Privacy Notice (“Notice”) is provided by ECDG, Inc., a California corporation, doing business as REQeV (“REQeV”, “we”, “us”). It supplements our Privacy Policy and explains how we handle personal information of California residents under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its implementing regulations (together, the “CCPA”).

Terms such as “personal information”, “sensitive personal information”, “business”, “service provider”, “sell” and “share” have the meanings given in the CCPA. If this Notice conflicts with our Privacy Policy for a California resident, this Notice controls.

1. Scope of This Notice

This Notice applies to California residents (“consumers” or “you”) whose personal information REQeV collects and handles as a business. That includes:

• Business contacts, such as prospects, customer administrators, vendors, partners and event attendees, including people acting in a business-to-business capacity.
• Visitors to reqev.com and our other websites.
• Individual users of the Services, such as REQeV ATS, REQeV Sourcing and REQeV Mission Control, when we process their account and usage information for our own purposes.
• Job applicants to REQeV itself.

Employees and contractors of REQeV receive a separate notice at the time of collection. This Notice does not describe personal information that we process only on behalf of our customers, which is addressed in Section 2.

2. When REQeV Acts as a Service Provider

Our customers are recruiting firms and employers. When they use the Services, they upload, source or generate information about candidates, contacts and other individuals (“Customer Data”). For Customer Data, the customer is the “business” and REQeV is its “service provider” or “contractor”.

We process Customer Data only to provide the Services and as the customer instructs, under a written contract that includes the restrictions the CCPA requires. We do not sell or share Customer Data, and we do not use it for our own purposes except as the CCPA permits a service provider to do.

If you are a candidate or contact whose information appears in a customer’s account, please submit your request directly to that customer, which decides how to respond. If you send the request to us, we will forward it to the relevant customer where we can identify them, or tell you that we cannot. Our Candidate Privacy Notice has more information.

3. Personal Information We Collect

The table below lists the categories of personal information defined in Cal. Civ. Code Section 1798.140 that we have collected about California consumers in the last 12 months. It also shows the categories of recipients to whom we disclosed each category for a business purpose. The same practices apply going forward unless we update this Notice.

Categories of service providers and contractors include providers of application hosting, database and storage, payment processing, email delivery, customer support, product analytics, error monitoring and AI features. Our current subprocessors for the Services are listed at Subprocessors.

We share (and may be considered to sell) the following categories to our website visitor identification provider (Instantly and its identification partners), a third party, as described in Section 7: identifiers (such as IP address, device identifiers, name and work email address); internet or other electronic network activity (such as pages viewed, time on site and browser); and professional information (such as company, job title and professional profile). Inferences we draw from this information about which businesses may be interested in REQeV are not sold or shared.

4. Sources of Personal Information

We collect personal information from the following categories of sources:

• Directly from you, for example when you create an account, contact sales, make a purchase, register for an event or apply for a job.
• Automatically, through cookies, server logs and similar technologies when you use our websites, emails and Services.
• From our customers, for example when an administrator invites you to join their account or provides your contact details for billing or support.
• From service providers, such as payment processors, analytics providers and event platforms.
• From publicly available sources and business contact data providers, such as company websites and professional networking profiles, for our own sales and marketing.
• From our website visitor identification provider (Instantly and its identification partners), which matches visits to www.reqev.com to business contact information.

5. Business and Commercial Purposes

We collect, use and disclose personal information for the following business and commercial purposes:

• Providing, operating and maintaining the Services, including authentication, account management and customer support.
• Processing payments, managing subscriptions and credit packs, and keeping financial records.
• Securing our systems, detecting and preventing fraud, abuse and security incidents, and debugging errors.
• Analyzing and improving our websites and Services, and developing new features.
• Communicating with you about the Services, including service announcements, security notices and changes to our terms.
• Marketing our Services, including sending marketing emails and, where you have not opted out, advertising on other sites.
• Evaluating job applicants and hiring for roles at REQeV.
• Complying with legal obligations, enforcing our agreements, and establishing, exercising or defending legal claims.
• Carrying out a merger, acquisition, financing, reorganization or sale of assets, subject to appropriate confidentiality protections.

6. Disclosures of Personal Information

We disclose personal information to the categories of recipients listed in the table in Section 3 for the purposes described in Section 5. We require service providers and contractors to use personal information only to perform services for us and to protect it as the CCPA requires.

We may also disclose personal information when you direct us to, for example when you connect an integration, or to a successor entity in a corporate transaction.

7. Sale and Sharing of Personal Information

The www.reqev.com website does not use advertising pixels or cross-context behavioral advertising. It does use a website visitor identification technology provided by Instantly, which collects identifiers and internet activity (such as IP address, browser and pages viewed) and may match them to professional information (such as name, company, job title and work email address) so that we can contact interested businesses. It runs only for visitors in the United States. Making identifiers, internet activity and professional information available to that provider is “sharing” and may be a “sale” under the CCPA, because the provider also uses it to maintain and improve its own data. When your browser sends a Global Privacy Control signal, this technology does not load. You can also opt out by emailing support@reqev.com or through our Your Privacy Choices page; we honor opt-out requests within 15 business days. We do not sell or share Customer Data processed on a customer’s behalf in our role as a service provider.

To submit an applicable opt-out request concerning personal information held by REQeV, email support@reqev.com or follow the instructions on Your Privacy Choices. Opt-out requests do not require identity verification, although we may need information to locate the records concerned.

8. Sensitive Personal Information

The sensitive personal information we collect is limited to account log-in credentials and, only if a REQeV job applicant chooses to provide it, voluntary self-identification information. We use and disclose this information only for purposes permitted by Cal. Code Regs. tit. 11, Section 7027(m), and not to infer characteristics about you (Cal. Civ. Code Section 1798.121(d)), such as providing the Services you request, securing accounts, preventing fraud and complying with law.

We do not use sensitive personal information to infer characteristics about you, and we do not sell or share it. Because our use is limited to these permitted purposes, the CCPA does not require us to offer a right to limit its use. You may still contact us with any questions about how we handle it, and Your Privacy Choices explains this further.

9. Retention

We keep each category of personal information only as long as reasonably necessary for the purposes described in this Notice. We decide how long to keep information based on:

• How long we need it to provide the Services and maintain your account.
• Whether we have an ongoing business relationship with you or your organization.
• Legal, tax, accounting and regulatory requirements, such as keeping billing records for the period required by law.
• Whether the information is needed to resolve disputes, enforce our agreements or defend legal claims.
• Security and fraud-prevention needs, such as retaining log data for a limited period to investigate incidents.

For example, account information is generally kept for the life of the account and a limited period afterward, and marketing contact information is kept until you unsubscribe or it is no longer useful. Information about identified website visitors is kept for 12 months unless you ask us to delete it sooner. Customer Data is retained and deleted as described in the customer’s agreement with us and applicable law. After the applicable export window, we delete data without undue delay unless retention is legally required or earlier deletion is requested. Backup copies are put beyond use pending scheduled overwrite. These arrangements do not extend applicable privacy-request deadlines.

10. Your California Privacy Rights

Subject to exceptions in the CCPA, you have the following rights:

• Right to know and access. You may request the categories of personal information we collected about you, the categories of sources, our business or commercial purposes, the categories of third parties to whom we disclosed it, and the specific pieces of personal information we hold about you. This covers information collected on or after January 1, 2022, unless providing it would be impossible or involve disproportionate effort.
• Right to delete. You may request that we delete personal information we collected from you, subject to exceptions such as completing a transaction, security, legal compliance and defending claims.
• Right to correct. You may request that we correct inaccurate personal information we hold about you.
• Right to opt out of sale and sharing. You may direct us not to sell or share your personal information, as described in Section 7.
• Right to limit use of sensitive personal information. You may direct a business to limit its use of sensitive personal information to permitted purposes. As explained in Section 8, we already limit our use in this way.
• Right to non-discrimination. We will not discriminate or retaliate against you for exercising your rights, including by denying goods or services, charging different prices or providing a different level of quality, except as permitted by law. We will not retaliate against a REQeV job applicant for exercising these rights.

You may make a request to know or access personal information no more than twice in a 12-month period.

11. How to Submit a Request

You may submit a request to know, delete or correct by any of these methods:

• Email support@reqev.com with the subject line “Privacy Request”.
• Use the request instructions at Your Privacy Choices.

To opt out of sale or sharing, use the methods in Section 7. Opt-out requests do not require identity verification, although we may ask for information needed to locate your records.

12. Verification

To protect your information, we must verify your identity before fulfilling a request to know, delete or correct. We will ask you to provide information that we can match against what we already hold, such as your name, email address and details of your account or interactions with us.

If you have a REQeV account, we may ask you to confirm the request from the email address on the account or while signed in at app.reqev.com. For requests for specific pieces of personal information, we apply a higher degree of certainty and may ask for additional matching data points and a signed declaration under penalty of perjury.

We will use information you provide for verification only to verify your identity and keep records of the request. If we cannot verify your identity, we will tell you and explain why.

13. Authorized Agents

You may use an authorized agent to submit a request on your behalf. The agent must provide proof that you gave it signed permission to act for you, unless it holds a valid power of attorney under California Probate Code Sections 4121 to 4130.

For requests to know, delete or correct, we may also require you to verify your own identity directly with us or confirm directly with us that you gave the agent permission. We may deny a request from an agent that does not provide adequate proof of authority.

14. Response Timing and Format

We will confirm receipt of a request to know, delete or correct within 10 business days and explain how we will process it. We will respond substantively within 45 calendar days of receipt. If we need more time, we may extend this by up to an additional 45 calendar days, and we will tell you the reason for the extension within the first 45-day period.

We will act on opt-out requests as soon as feasible and no later than 15 business days after receipt. Where feasible, we will provide personal information in a portable, readily usable format.

We do not charge a fee to process requests. We may charge a reasonable fee or decline a request that is manifestly unfounded or excessive, and we will explain our decision. If we deny a request in whole or in part, we will explain the reason.

15. Financial Incentives

REQeV does not currently offer financial incentives, such as rewards or price differences, in exchange for personal information. If we offer one in the future, we will update this Notice before it begins.

16. De-identified Information

When we use de-identified information, we maintain it in de-identified form and do not attempt to re-identify it, except to test whether our de-identification processes meet the CCPA’s requirements. We take reasonable measures to ensure the information cannot be associated with an individual and publicly commit to these practices. We contractually require anyone who receives de-identified information from us to comply with the same obligations.

17. California Shine the Light

California Civil Code Section 1798.83 lets California residents with an established business relationship with us ask whether we disclosed certain personal information to third parties for their direct marketing purposes during the prior calendar year. REQeV does not disclose personal information to third parties for their own direct marketing purposes.

You may still make a request by emailing support@reqev.com with the subject line “Shine the Light”. We will respond within 30 days.

18. Minors

Our websites and Services are designed for businesses and are not directed to children. We do not knowingly collect personal information from anyone under 16 years of age. If you believe we have collected such information, please contact support@reqev.com and we will delete it.

19. Changes to This Notice

We review this Notice at least once every 12 months and update it as our practices change. When we make changes, we will update the effective date shown at the top of this page. If changes are material, we will provide additional notice as required by law.

20. Accessibility

This Notice is designed to be readable on common devices and screen readers. If you need it in an alternative format, please contact support@reqev.com.

21. Contact

If you have questions about this Notice or our privacy practices, contact:

ECDG, Inc., a California corporation, doing business as REQeV, 236 West Portal Ave #390, San Francisco, CA 94127.

Privacy requests and questions: support@reqev.com