PRIVACY POLICY
This Privacy Policy describes the policies and procedures of Joveo Inc. and its affiliate Ripple Labs LLC (“Joveo”, “Company”, “we”, “our” or “us”) on the collection, use and disclosure of information of any person who wishes to procure the Services (“Your” or “You”) on www.joveo.com, https://fastapplyjobs.com, https://ripplemedia.io/ or any applications created by us on third party websites (the “Site”) and the services, features, content or applications we offer (collectively with the Site, the “Services”). You can access several features of the Site and/ or the Services being offered by the Company. Please read this document closely when You use Site and / or Services, You agree to be bound by the terms and conditions of Joveo’s Privacy Policy.

OUR COMMITMENT TO PROTECT YOUR PRIVACY

At Joveo, we believe that the Internet is a better place when privacy of the users is respected by websites and businesses. At the same time, we also know that the web is not a ‘one size fits all’ ecosystem and that websites do require collecting some personal information from users so as to create a unique and personalized experience. These principles are close to our heart which is why we promise that if we collect any information from You, it’s because we want to provide You with a superior experience using Joveo’s Site and Services. As explained in detail further below, we recognize that just because You share information with us doesn’t mean You want to share it with the rest of the world. That’s why it is our priority to protect any information You give us. It’s our goal to make Your experience with the Site and Services both rewarding and safe
If You have questions or concerns regarding this statement, email us at privacy@joveo.com or privacy@fastapplyjobs.com. We are providing this privacy policy to inform You about how our technology platform processes information on behalf of online advertisers (direct employers), recruitment media agencies, website owners, job boards, data providers and other businesses that use our technology and services.

COMPLIANCE WITH PRIVACY SHIELD

Joveo complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield. Joveo has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

The Federal Trade Commission has jurisdiction over Joveo’s compliance with the Privacy Shield. Joveo is subject to the investigatory and enforcement powers of the FTC (Federal Trade Commission).

Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to privacy@joveo.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@joveo.com.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Joveo’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Joveo remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Joveo proves that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, Joveo commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact Joveo at: privacy@joveo.com

Joveo has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction. I. WHAT IS JOVEO INC

Joveo Inc is an advertising technology platform with its registered office in San Francisco. Joveo runs a technology buying platform for digital media. The Joveo technology allows our customers to buy ad space on websites, mobile apps, video players, and other devices and allows for the use of proprietary and third-party data in the purchase of that ad space. When ad space is bought or sold, our technology fulfills the transaction by delivering the ad to Internet users (job seekers) who visit that site, app, or device. Generally, an Internet user’s device (computer, mobile device or otherwise) comes into contact with Joveo technology when a user views a job ad delivered by our technology or clicks or taps on the ad to visit the advertiser’s website or app.

In accordance with applicable laws and regulations, including the European Union General Data Protection Regulation (EC Regulation 2016/679), the Company controls, collects, owns and directs the use of the PII and Usage Information and, in this regard, the Company is the data controller. The Company is a registered company in Delaware with its registered office at 1047 Whipple Avenue, Suite B, Redwood City, CA 94062. For any queries regarding this Privacy Policy and the collection and use of data collected or processed under this Privacy Policy, the Company can be contacted by mail at 1047 Whipple Avenue, Suite B, Redwood City, CA 94062; by phone at +1 650-376-8100 or by email at privacy@joveo.com or privacy@fastapplyjobs.com

Privacy practices for our technology Advertising supports free content and digital user experiences that we all like. Our goal is therefore to make advertising more effective by helping to display job ads that may be of interest to You. We believe that relevant job ads are more valuable to job seekers than less relevant ads. More relevance also helps the services that depend on advertising because advertisers pay more for effective job ads which in turn leads to higher quality and richer job seeker experiences. II. INFORMATION THAT WE COLLECT

For the purpose of providing You with Services, we collect information in two manners as given below:

(i). Information collected by Joveo You may be required to provide personally identifiable information which is information that may be used to identify the user personally inter alia Your name, gender, residential address, age, mobile number, email address (including where in the case of a company, similar information as relevant to that company) (“PII”). We may also collect certain information through various social media platforms and other third-party integrations and such PII collected may be stored by Us. Users may also upload their resumes from any device using third party cloud providers/ applications. In an event where You do not upload a resume, We may auto-generate a resume based on the PII provided by You and upload the same for the purpose of Services.

(ii). Information automatically collected In addition to the PII submitted by You to Us, to identify real time trends in the marketplace so they can reach targeted audiences more effectively, as opposed to collecting information on an individual’s internet usage, We may use other technologies (including cookies, please see the cookie policy below) to collect certain information (“Usage Information”) whenever you access the Site. This Usage Information may include the browser that You are using, the URL that referred You to the Site and information regarding the devices used by You to access the Site, among other information. Usage Information may be non-identifying or may be associated with You. Whenever we associate Usage Information or a device identifier with Your PII, we will treat it as PII and the conditions relating to PII under this Privacy Policy will be followed. Ad Tags Companies that work with us use our core algorithms and technology, which place ad tags on their websites. These ad tags are used to customise a user’s advertising experience, but they do not contain any PII. Rather, ad tags usually contain anonymous information about the web site, section of the site and size of the ad that the Services are optimizing.

III. COOKIES

We may use “cookies” to enhance Your experience with the Site. Cookies are text files that we may place in Your computer browser or any other device that You may use to access the Site from to store Your preferences. Cookies record various aspects of Your visit and assist us in providing You with uninterrupted service. One of the primary purposes of cookies is to store Your preferences and other information on Your computer in order to save You time by eliminating the need to repeatedly enter the same information and to display Your personalized content. However, no PII identifying the User is collected nor any data capture mechanism is employed. You may change Your browser settings to accept or reject cookies on personal preference.

We process the data collected through cookies either independently or with third party service providers, who analyses the data collected through cookies pursuant to contractual relationships with Us. The processing of such data is done to analyze the pages You visit, websites You visited before coming to the Site, and where You go after leaving the Site. The PII may be combined for marketing and for market research purposes, including internal demographic studies, so that we can optimize our products and Services and customize the Site for You and for the purpose of providing Our Services.

Please note that our Privacy Policy covers only our use of our Site and Services and does not cover the use of cookies by third parties, such as our clients. We do not control when or how third parties place cookies on Your computer. For example, third party websites to which a link points may set cookies on Your computer. We encourage You to take note of other sites’ Privacy Policies.

Opting out of Cookies

If You would like to opt-out from having Joveo collect Your Non-PII in connection with Our technology, We will place an opt-out cookie on Your computer. This cookie tells us not to collect Your Non-PII to tailor our online advertising campaigns. Alternatively, You may disable cookies Yourself through Your browser settings.

  1. Web Browser: Users can control the use of cookies at the individual browser level. For more information about cookies, please visit http://www.allaboutcookies.org/cookies/ . Please note that if You block, delete or restrict cookies in any way, or if You use a different computer or Internet browser, You may need to renew Your opt-out choice.
  2. Mobile Tracking:
    1. On your iOS mobile device enable the “Limit Ad Tracking” setting in your iOS phone’s settings.
    2. On Android devices, Your settings may allow You to “Opt out of Interest-Based Ads.” When You have opted out using this setting on a device and that information is passed to Joveo, Joveo will not use Non-PII data to target interest based ads to You or place You in segments for future marketing.

Location Tracking

When using Joveo, We may infer your non-precise geolocation data based on IP address with us for use in determining which ads to display. We use such data for targeting ads and evaluating their success, and may share it with other parties for similar uses (please see below for circumstances when We may share Your PII with other parties). This non-precise location data is maintained in our logs in accordance with our data retention policy (below). IV. HOW WE USE THE INFORMATION WE COLLECT?

We, our affiliates or third-party service providers may use PII or Usage Information collected in the following ways:
  1. To operate and improve the Site and tools associated with the Site;
  2. To confirm Your identity in order to determine Your eligibility to use the Site and avail the Services;
  3. To provide You the Services;
  4. To enable us to show you ads that are relevant to you;
  5. To protect against errors, fraud and other criminal activity;
  6. To observe, improve, administer the Services and diagnose technical problems;
  7. To transmit, share or transfer the PII provided by You to a prospective employer in order to enable Us to provide You with the Services;
  8. To enable you to upload your resume or permit Us to auto-generate a resume on Your behalf, search for job postings, and contact or be contacted by prospective employers who are also clients of Us;
  9. To assess Your qualifications and suitability for job opportunities;
  10. To allow you to login to Your account to manage your information and job search;
  11. To send you communications regarding status of Your applications, requests that You may have made to Us or any other communication that may be of interest to you by way of emails, or courier, or registered post, or telephone calls, or any other mode of communication;
  12. To notify you about changes to our Services;
  13. To generate and review reports and data about, and to conduct research on, our user base and Service usage patterns;
  14. To use your information to analyse and show multiple other relevant jobs to you;
  15. To apply quickly to multiple jobs without the need to completely fill the application form;
  16. To sign-up on your behalf and hold your credentials for future sign-ins; and
  17. For any other purpose with your consent.
 V. DATA TRANSFER

Your PII collected through the Site may be stored and processed in the USA or any other country in which We or Our subsidiaries, affiliates or service providers maintain facilities. We may transfer information that We collect about You, including PII, to affiliated entities, or to other third parties across borders and from Your country or jurisdiction to other countries or jurisdictions around the world. If Your PII is transferred to another country, We will ensure that your PII is protected and used according to applicable law in such country. VI. IS MY INFORMATION EVER SHARED WITH OTHER PARTIES?

Normally, we will never share any of Your PII with a third party unless You give us permission to do so. However, in some cases, we may choose to buy or sell assets. In these types of transactions, Your information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, Your information would be one of the assets that is transferred or acquired by a third party.

We may share Your information with our customers and partners including applicant tracking systems, CRMs, web publishers, job boards, demand side platforms, data management platforms, supply-side platforms, affiliate tracking systems and other third-party service providers that are necessary to perform Joveo and its affiliates services.

By using the Services, You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use Your PII as set forth in this policy. We also reserve the right to access, read, preserve, and disclose any information as it reasonably believes is necessary to
(i) satisfy any applicable law, regulation, legal process or governmental request,
(ii) enforce this Privacy Policy, including investigation of potential violations hereof,
(iii) detect, prevent, or otherwise address fraud, security or technical issues,
(iv) respond to user support requests, or
(v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention. VII. HOW DOES JOVEO KEEP MY INFORMATION SECURE?

Joveo uses industry standard security measures to ensure the security of its data, including any information You have given us. We routinely evaluate our data security practices to identify security threats or opportunities for improvement. Nonetheless, it is impossible to guarantee that the transmission of data through the Internet will be secure. By using the Services, You acknowledge that it may be possible for third parties to intercept or access transmissions or private communications unlawfully. VIII. WHAT ARE MY DATA PROTECTION RIGHTS?

This Privacy Policy is effective from May 25, 2018 for all users, provided that enhanced data protection rights in this Policy required by the EU General Data Protection Regulation became effective on May 25, 2018 for all EU-resident users who are natural persons. You have the following data protection rights in relation to the PII provided by You on the Site:

(a) obtain confirmation from Us that Your Personal Information is being collected and used by Us and to access the Personal Information held about You by Us;

(b) have Your PII corrected or updated at any time in case of inaccuracy or incomplete PII.

(c) block or suppress Us from collecting and using Your PII, which means We can continue to store Your PII but we cannot further collect or us it in any way;

(d) obtain and reuse any PII We hold about You for Your own purposes across different services, which allows You to move, copy or transfer Your PII easily from the Company to another place notified by You to Us in a safe and secure way without hindrance to the usability of Your PII.

(e) erasure, or the right to be forgotten, which means You can request the deletion or removal of any Personal Information We hold about You at any time. Please note that we may impose a small fee for access and disclosure of Your personal information where permitted under applicable law, which will be communicated to You beforehand.

(f) if we have collected and processed Your PII with Your consent, then You can withdraw Your consent at any time. Withdrawing Your consent will not affect the lawfulness of any processing we conducted prior to Your withdrawal, nor will it affect processing of Your PII conducted in reliance on lawful processing grounds other than consent. To request access, correction, deletion or transfer of Your personal information or withdrawal of consent to the processing described in this Privacy Policy, please email us at privacy@joveo.com or privacy@fastapplyjobs.com. You can also request for data deletion by clicking here : https://fastapplyjobs.com/w/gdprcompliance

Any request received by Us in relation to the aforesaid shall be acknowledged within 30 (thirty) days of receipt of such request.

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en IX. CHILDREN’S PRIVACY

Protecting the privacy of young children is especially important. For that reason, We do not knowingly collect or solicit PII from anyone under the age of 16. In the event that we learn that we have collected PII from a child under age 16, we will delete that information as quickly as possible. If You believe that we might have any information from or about a child under 16, please contact us at privacy@joveo.com or privacy@fastapplyjobs.com X. WHAT HAPPENS WHEN THERE ARE CHANGES TO THIS PRIVACY POLICY?

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make any material changes in the way we collect or use information, we will notify You by posting a notice on the Site prior to the change becoming effective or sending You an email to Your registered email address. Please note that You are bound by any changes to our Privacy Policy when You use the Site or Services after such changes have been first posted. XI. LIMITATION OF LIABILITY

YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER THE PRIVACY OF JOVEO DATA OR JOVEO’S PRACTICES IS SUBJECT TO THE PROVISIONS OF THIS PRIVACY POLICY.EXCEPT AS REQUIRED UNDER PRIVACY SHIELD. YOU AGREE THAT JOVEO’S LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE LIMITED TO THE GREATER OF THE VALUE OF THE TRANSACTIONS OR SERVICES PROVIDED TO YOU BY JOVEO OR $250 TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE BARRED. YOU FURTHER AGREE THAT THIS PRIVACY POLICY AND THE AGREEMENTS HEREUNDER ARE GOVERNED BY CALIFORNIA LAW WITHOUT REGARD TO CHOICE OF LAW PRINCIPLES AND THAT ANY ACTION ARISING FROM OR RELATED TO THIS POLICY WILL BE EXCLUSIVELY VENUED IN A STATE OR FEDERAL COURT SITUATED IN SAN FRANCISCO, CALIFORNIA.

You also agree that You have provided notice to, and obtained consent from, any third party individuals whose personal data You supply to Joveo with regard to: (a) the purposes for which such third party’s personal data has been collected; (b) the intended recipients or categories of recipients of the third party’s personal data; (c) which of the third party’s data are obligatory and which data, if any, are voluntary; and (d) how the third party can access and, if necessary, rectify the data held about them. XII. WHAT IF I HAVE QUESTIONS OR CONCERNS?

If You have any questions or concerns regarding this Privacy Policy or privacy using the Services, please send us a detailed message to privacy@joveo.com or privacy@fastapplyjobs.com. We will make every effort to resolve Your concerns.