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GlassHiveTM Global Privacy Policy Last Updated: September 14, 2026 Version 1.08 CONTENTS INTRODUCTION IMPORTANT INFORMATION AND WHO WE ARE CONTACT US DATA PROTECTION OFFICER DEFINITIONS SENSITIVE PERSONAL INFORMATION / SPECIAL CATEGORY PERSONAL DATA HOW WE GET PERSONAL INFORMATION ABOUT YOU THE PERSONAL INFORMATION WE COLLECT HOW WE PROCESS AND USE PERSONAL INFORMATION LIMITS ON THE USE OF GOOGLE USER DATA LEGAL BASES FOR PROCESSING WITHDRAWING YOUR CONSENT HOW WE SHARE INFORMATION DATA SECURITY RESPONSIBLE DISCLOSURE DATA RETENTION TRANSFERS OF PERSONAL INFORMATION DATA PRIVACY FRAMEWORK THIRD PARTY SERVICES AND WEBSITES CHILDREN'S INFORMATION WHAT HAPPENS IF YOU DON'T PROVIDE YOUR INFORMATION COMMUNICATIONS AND OPTING OUT OF MARKETING COOKIES AND OTHER TRACKING TECHNOLOGIES YOUR PRIVACY RIGHTS ADDITIONAL INFORMATION FOR US RESIDENTS SALE OR SHARING OF PERSONAL INFORMATION ADDITIONAL INFORMATION FOR EEA, UK AND SWISS RESIDENTS ADDITIONAL INFORMATION FOR CANADIAN RESIDENTS UPDATES TO THIS POLICY QUERIES AND FEEDBACK 1. INTRODUCTION We take your privacy very seriously. Please read this Privacy Policy (“Policy”) and any other privacy policy, notice or fair processing notice we may provide on specific occasions carefully, as it is intended to help you understand what information we collect, why we collect it, and how you can update, manage, export and delete your information. This Policy supplements such other privacy policies, notices and privacy notices and is not intended to override them. This Policy has been drafted as to be applied to our operations and personal information processing activities globally. Our processing activities may be more limited in some jurisdictions due to restrictions imposed under local laws. For example, the laws of a particular country may limit the types of personal data we can collect or the manner in which we process that personal data. In those instances, we may adjust our internal policies and/or practices to adapt to the requirements of the relevant local law. This Policy is presented in a layered format so you can easily find to the information you want. Please click on the relevant headings or subheadings to read the full text in each section. 2. IMPORTANT INFORMATION AND WHO WE ARE We are GlassHive LLC (“GlassHive”, “we”, “us” and “our”), a limited liability company headquartered at 900 W Bethany Drive, Suite 240, Allen, Texas 75013, United States of America. The website located at https://www.glasshive.com/ and the features, functionality, content, and services accessible through it (the "Site") is offered by GlassHive. This Policy describes the privacy practices of GlassHive and provides information about how we may collect and use your personal information through your use of the Site as well as through your use of our social media pages from which you are accessing this Policy (our “Social Media Pages”). We refer to the Site and the Social Media Pages collectively as the "Services". We are the controller of User Data and Prospect Data as set out in this Policy. This means that in relation to User Data and Prospect Data, we determine what personal information will be collected by us, as well as how this information will be used and how it will be protected. If you are leveraging GlassHive as a Microsoft employee service or your data pertains to Microsoft Personal Data, then Microsoft's Privacy Policy applies instead. 3. CONTACT US Please use the following details to contact us: By email: [email protected] By mail: 900 W Bethany Drive, Suite 240, Allen, Texas, 75013, United States of America 4. DATA PROTECTION OFFICER We have appointed GRCI Law Limited as our Data Protection Officer (or DPO). Our DPO is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, our privacy practices or how we handle your personal data, please contact our DPO at [email protected]. 5. DEFINITIONS Personal information In this Policy, we use the term “personal information” to refer to any information that identifies, relates to, or could reasonably be linked to an identifiable individual. This includes for example, names, contact details, profile photograph, date of birth, phone number, account credentials, job title and other registration information, or any other unique identifier (including information such as IP addresses). Depending on where you are located, this type of information may also be referred to as “personal data” under local laws. Other terms used in this Policy In this Policy, we use the following terms to refer to the categories of personal information we process: Customer Data means data inclusive of personal information that we collect, process, and manage on behalf of our customers. Customer Data is processed by us strictly under the instruction of the customer. We act as a processor only in relation to Customer Data. User Data means personal information related to users of our Site and Services including (but not limited to) our customers' people and personnel who engage with our Site and / or the Services. Prospect Data means personal information related to visitors to the Site who are not already users of our Services, including (but not limited it) job applicants who apply for or enquire about job roles advertised via our Site or Social Media Pages, as well as persons who otherwise interact with us including via our Social Media Pages). 6. SENSITIVE PERSONAL INFORMATION / SPECIAL CATEGORY PERSONAL DATA Some categories of personal information are considered more sensitive and are subject to additional protections under laws in various countries. This may include information about your health, racial or ethnic origin, or religious or philosophical beliefs, to provide a few examples. We only collect and use sensitive personal information where it is necessary and permitted by applicable law, and we apply appropriate safeguards to protect it. 7. HOW WE GET PERSONAL INFORMATION ABOUT YOU In order for us to operate effectively, we may request and collect information about you, We collect personal information from you: Directly: for example, when you enter or send us information, such as when you register with us to use the Services or fill out forms in relation to the Services, integrate your GlassHive account with third party services, correspond with us through the Site, including through the use of the chat functionality on our Site, communicate with us by e-mail, phone, or through our Social Media Pages. Information we may collect from you directly in this way may include (but is not limited to) information you provide when you: register to use our Services. set up payments. enquire about or report a problem with our Services. subscribe to receive communications from us, including when you subscribe to join the GlassHive community. enquire about or apply for a vacancy with us. Indirectly: for example, through your browsing activity while on our Site. This may include (but is not limited to) the time and date you access the Site and the pages you access. from other third parties, for example when you attend events, webinars, or promotions that we sponsor or are involved with. from service providers, partners, or business networking platforms, such as LinkedIn. from integrations where you or one of the admins of your account has chosen to turn on a third-party integration. The third-party software may send information to (and / or receive information from) us. We will also collect information indirectly using the technologies explained in the section on 'COOKIES AND OTHER TRACKING TECHNOLOGIES' below. 8. THE PERSONAL INFORMATION WE COLLECT We collect personal information from users of our Services and visitors to our Site, inclusive of job applicants who enquire about and / or apply for our vacancies. What kind of personal information we collect, use, store and transfer about you will differ depending on our relationship with you and may include: Account Information: the information required to register with us, whether for a demo, trial or subscription usage of the Site, which may include email address, username and password, first and last name, telephone number, IP address(es), physical address, ZIP code, and country of residence; Activity Information: this may include information relating to views and interactions with our Services; Clickstream and Browsing Activity Information: this may include records of the sections or pages visited and the order you accessed them in, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from a page; Communication Information: such as the content of messages you send us, including emails, feedback forms, web forms, support enquiries and problem reports; Contact Information: such as your personal or business mailing address, email address, phone number, social media handle and any other contact details you may provide; Employment Information: such as information relating to your current and / or previous employer(s) or organisation(s), job title, business email address, and work contact details; Financial Information: including billing address, payment card details (like card number, expiry date and security code), payment amounts, transaction dates, and tax or invoice-related data; Identity Information: such as your first and last name, username or similar identifier, title, date of birth, ethnicity and gender; Images and Visual Data: such as profile pictures or photos; Location Information: such as your address details; Marketing Preferences: such as your choices about receiving marketing messages from us, for example when you subscribe to join the GlassHive community; Publicly Available Information: such as details from LinkedIn or other sources where your professional contact or identity data is publicly accessible, including website locations; References: references from previous and current employers and other relevant references (for example, in relation to the creditworthiness of a supplier); Resume and Application Information: includes resumes, information contained in covering letters submitted with resumes and / or otherwise in connection with job applications, responses to application submission questions, responses to job screening questions, questionnaires, and other application related materials submitted via our careers platform; Survey and Promotions Information: includes responses you give when you take part in surveys or promotions we run. Technical and Device Information; may include: IP address; browser agent, type, version and settings; operating system; login time stamps and session information; and time zone and location information (derived from IP address); Transaction Information: includes details of the Services purchased from us, including billing and order history; and Usage Information: may include information about how you interact with our Site and / or the Services, including searches, browsing patterns, and general behaviour when engaging with the Services. We may also use aggregated or de-identified data to understand audience trends, and we may share these insights with third parties. This type of information does not identify any individual. We use various analytics services, including Google Analytics, Microsoft Clarity, Plausible Analytics and Intercom, to better understand how visitors interact with our Services. These analytics services provide non-personally identifiable data including but not limited to data on where visitors came from, what actions they took on our site and where visitors went when they left our Site. For details of which service runs on which site, and how each one handles cookies and similar technologies, see our Cookie Policy. 9. HOW WE PROCESS AND USE PERSONAL INFORMATION We collect and use personal information so we can run our business, provide our Site, operate our Services and meet legal requirements. Depending on where you are located, and how you engage with us, the law allows us to use your information for different reasons. These include: To provide our Services and manage accounts: We use personal information to deliver our Services, respond to requests, create, provide and maintain customer accounts and public-facing profiles for accounts, and manage your relationship with us. To communicate with you: We may use personal information to contact you about enquiries that you make or about your account with us and updates to our Services, or to offer customer support, handle complaints or send service-related communications. We may also send you promotional emails in relation to our Services where you have opted in to receiving same and may contact you in order to administer contests, promotions and surveys in which you are participating. To improve our Site and Services: We use information to improve our offering of products and Services, as well as improvements to our Site. This may include the use of information as part of our technological development and research processes. To gather business intelligence in relation to our operations and Services: We may analyse information to monitor, measure and report on the performance of our Site and the Services. This may include the use of personal information to estimate audience size, analyse audience behaviours and improve our audience insights. To protect our systems, the Site and the Services: We use information to protect our systems, prevent fraud and misuse, protect the integrity of our Site and our Services and to make sure that they operate effectively for everyone. To meet our legal obligations: Sometimes we must use personal information to follow laws, respond to official requests, or meet our legal responsibilities as a business. This may include (but is not limited to), as the use of information as necessary in connection with legal claims, compliance, regulatory, investigative purposes (including disclosure of such information in connection with law enforcement requests, legal process or litigation), protecting our and others' rights, privacy, safety, or property, and enforcing our agreements. To carry our data analysis activities: We work with third parties that collect data about the use of our Site. For example, we use Google Analytics and other third-party services to improve the performance of our Services and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data, visit https://policies.google.com/technologies/partner-sites. Opt-out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/. To promote our Services: We may use your information to show you offers, updates, or promotions that may be relevant to you. Where required by law, we will ask for your permission first. You can opt out at any time. If you have any questions about how or why we use your personal information, please contact us through the details provided in the “Contact Us” section of this Policy. We may also use your information to contact you about our own goods and services that may be of interest to you. If you do not want us to use your information in this way, please contact us at [email protected]. 10. LIMITS ON THE USE OF GOOGLE USER DATA Notwithstanding anything else in this Policy, if you provide the Service access to the following types of your Google data, the Service's use of that data will be subject to these additional restrictions: The Service will only use access to read, write, modify, or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web email client that allows users to compose, send, read, and process emails and will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets. The Service will not use this Gmail data for serving advertisements. The Service will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for the Service's internal operations and even then only when the data have been aggregated and anonymized. GlassHive's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements. 11. LEGAL BASES FOR PROCESSING Depending on your location, we may be required to explain the legal basis we rely on to collect and use your personal information. For example, in the European Economic Area (EEA) and United Kingdom, we must tell you whether we are processing your personal information based on consent, contract, legitimate interests, legal obligation, or another basis. Our legal basis for processing personal information depends upon the specific context in which it is collected or used. We will only collect, process and/or use personal information where we are satisfied that we have an appropriate legal basis to do so. EEA, UK and Swiss residents: For more information about our basis for processing your personal information, please see the section entitled Additional Information for EEA, UK and Swiss Residents . California residents: For more information about our basis for processing your personal information, please see the section entitled Additional Information for US Residents below. 12. WITHDRAWING YOUR CONSENT If we rely on your consent to process your personal information, which may be express or implied consent according to the applicable law, you have the right to withdraw consent at any time. You can withdraw your consent by contacting us at [email protected]. Please note, withdrawal of consent will not affect the lawfulness of the processing before the withdrawal, nor when applicable law allows, will it affect the processing of your personal information on the basis of any other lawful ground other than consent. 13. HOW WE SHARE INFORMATION We will only share personal information to such parties where there is a lawful basis for us to do so. Insofar as reasonably necessary to enable us to deliver our Services to you and for the purposes set out in this Policy, we may share your personal information with the below parties in order to manage our business and deliver our Services. Internally: We may share information with our subsidiaries. We may do this for legitimate business purposes, such as for the purposes of providing the Services, managing internal operations, or improving customer experience. Service Providers and Contractors: We may engage third-party service providers and contractors and to support our business operations and assist in our delivery of the Services. These service providers and contractors may receive your personal information from us, or may access, process, or store it on our behalf and under our instructions, for purposes such as (but not limited to): data analytics and reporting; payment processing; customer service and support; maintenance and delivery of Services; communications including email activities and management; IT and infrastructure support; marketing and communications (where legally permitted); and verification or aggregation of data for business insights. By Law or to Protect Rights: We may disclose personal information to law enforcement agencies and / or relevant government authorities where such disclosure is necessary to comply with applicable laws, legal obligations, or lawful requests from public authorities (including to meet national security or law enforcement requirements and to respond to court orders, investigations, subpoenas or warrants served on us). We may also disclose information to enforce our terms of service or other agreements and / or to protect the rights (including but not limited to intellectual property rights), property, or safety of GlassHive, our employees, users, or others, in accordance with applicable data protection laws, including the EU General Data Protection Regulation (EU GDPR), the UK General Data Protection Regulation (UK GDPR), the Swiss Federal Act on Data Protection (FADP), the California Consumer Privacy Act (CCPA) and the California Privacy Rights Acts (CPRA) and, if necessary, to defend against legal claims. Such disclosures will be limited to what is necessary and proportionate in the specific circumstances, and we will ensure that any sharing of personal information with third parties (e.g., for fraud prevention or credit risk reduction) is subject to appropriate safeguards, including contractual obligations where required. Business Transfers: If we go through a business transfer, such as consolidation, merger, restructuring, acquisition, or sale of part or all of our assets, including in the event of bankruptcy, personal information may be among the assets transferred. Where such a transfer occurs, we will ensure that the acquiring party is contractually bound to protect your personal information in a manner that is consistent with this Policy and applicable data protection laws, including the EU GDPR, UK GDPR, FADP, CCPA and CPRA. Where required by applicable law, we will notify you before any such transfer and provide you with choices regarding your personal information. If the transaction results in a material change to how your personal data is processed, we will provide you with prior notice and, where legally required, seek your consent. Professional Advisors: We may share personal information with persons, companies, or professional firms providing us with professional services including advice and consulting in accounting, administrative, legal, tax, financial, debt collection, and other matters. Other disclosures: Unless otherwise specified in this Policy, we will inform you, at the time of collection, or before any such disclosure, where your personal information may be shared with third parties, and shall explain the purpose and legal basis of such sharing, as well as your rights regarding such sharing. Where required by applicable law, including the EU GDPR, UK GDPR, FADP, CCPA and CPRA, you will have the opportunity to opt out of, or object to certain types of disclosures, such as data sales, sharing for targeted advertising or processing based on legitimate interests. We do not share, sell, rent or otherwise distribute your personal information except as disclosed in this Policy. The specific kind of information we share in each case will depend on your activities with us and only to the extent as required or permitted by law, and/or with your consent. We require any third parties with whom we share personal information to protect that information, keep it confidential and use it only as permitted. Please bear in mind that whenever you voluntarily make your personal information available for viewing by third-parties online - for example through comments on our Social Media Pages or through participation in forums - that information can be seen, collected and used by others besides us. We are not responsible for any unauthorized third-party use of such information. Please also note that this Policy does not apply to sharing of personal information by third party providers who may collect personal information from you and may share it with us. In these situations, we strongly advise you to review the applicable the third-party provider's privacy notice before submitting your personal information to them. 14. DATA SECURITY We use industry standard physical, technical, and internal administrative security measures to protect the confidentiality and security of your personal information and to prevent it from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. The measures we employ include (but are not limited to) encryption where appropriate. We will review, monitor and update these security measures to meet our business needs, changes in technology and regulatory requirements. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties that have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. However, as effective as the security measures we implement may be, no security system is impenetrable. As a result, we cannot guarantee, ensure, or warrant the security of any information submitted to us. It is your responsibility to protect the security of your login information and to use good judgment before deciding to send information via the internet. We do not have any control over what happens between your device and the boundary of our information infrastructure. Please note that e-mails and other communications you send to us through the Services are not encrypted, and we strongly advise you not to communicate any confidential information through these means. We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. 15. RESPONSIBLE DISCLOSURE At GlassHive, we take the security of our systems and our users' data seriously. We value the work of security researchers who help us maintain a high standard of security and appreciate responsible disclosure of any vulnerabilities. If you believe you have discovered a security vulnerability in any GlassHive service, application, or infrastructure, we encourage you to report it to us responsibly. Please email us at [email protected] with a detailed description of the vulnerability, including: A description of the vulnerability and its potential impact. Steps to reproduce or a proof of concept. Any relevant screenshots, logs, or supporting materials. We ask that you: Allow us a reasonable amount of time to investigate and address the issue before making any public disclosure. Avoid accessing, modifying, or deleting data belonging to other users. Act in good faith to avoid privacy violations, service disruption, and destruction of data. We are committed to working with security researchers to verify and address reported vulnerabilities in a timely manner and will not take legal action against individuals who discover and report security vulnerabilities in good faith, in compliance with this policy. 16. DATA RETENTION We will keep your personal information, in line with our retention policy and applicable law and for no longer than is necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, reporting or other valid business requirements. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. 17. TRANSFERS OF PERSONAL INFORMATION GlassHive is a global business headquartered in the United States. Our data centers for the Services are currently governed by and operated in the United States. As a global company, we may centralize or store certain personal information in countries outside of the country in which it was originally collected, including jurisdictions that may not offer the same level of data protection as your home country. This may involve transferring your personal information across borders, including to or from the United States and other countries where we or our service providers operate or where our data centers are located. Where we transfer your information internationally, we do so in compliance with applicable data protection laws, including the EU GDPR, UK GDPR, FADP, CCPA and CPRA and other relevant laws. We ensure that an adequate level of protection is in place, such as by using approved Standard Contractual Clauses (SCCs), intra-group agreements, or other legally recognized safeguards. Prior to any transfer, we conduct appropriate due diligence and risk assessments to ensure your information remains protected. You can find more details of the protection given to your information when it is transferred overseas by contacting us. Where personal information is transferred outside of Canada, including to the United States, it may be subject to the laws of those jurisdictions and accessible to foreign courts, law enforcement, and national security authorities. GlassHive takes appropriate steps to ensure that personal information remains protected in accordance with applicable data protection laws. These measures include contractual safeguards, transfer risk assessments, and the implementation of appropriate technical and organizational security controls designed to protect personal information against unauthorized access, use, or disclosure. 18. DATA PRIVACY FRAMEWORK Compliance with the Data Privacy Framework GlassHive complies with the EU-U.S. Data Privacy Framework (“EU-US DPF”) the UK Extension to the EU-US DPF, and the Swiss-U.S. Data Privacy Framework (collectively, the “Data Privacy Framework”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union, UK, and Switzerland, to the United States. GlassHive has certified to the Department of Commerce that it adheres to the EU-US DPF Principles, the UK Extension to the EU-US DPF Principles and the Swiss-US Data Privacy Principles (collectively the “DPF Principles”) with respect to the processing of personal data received from the EU, UK and / or Switzerland in reliance on the Data Privacy Framework. If there is any conflict between the terms in this Policy and the DPF Principles, the DPF Principles shall govern. To learn more about the Data Privacy Framework program, and to view our certification, please visit the Data Privacy Framework website at https://www.dataprivacyframework.gov . Scope and Accountability for Onward Transfers This certification covers personal data received from the EU, UK, and Switzerland in reliance on the Data Privacy Framework. GlassHive is responsible for the processing of personal data it receives under the Data Privacy Framework and subsequently transfers to a third party acting as an agent on its behalf. We comply with the DPF Principles for all onward transfers of personal data from the EU, UK, and Switzerland, including the onward transfer liability provisions. Jurisdiction With respect to personal data received or transferred pursuant to the Data Privacy Framework, GlassHive is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). Dispute Resolution and Complaints In compliance with the DPF Principles, GlassHive commits to resolve complaints about our collection or use of your personal data. EU, UK, and Swiss individuals with inquiries or complaints regarding our Data Privacy Framework compliance should first contact us at: [email protected] If a Data Privacy Framework complaint or dispute cannot be resolved through our internal processes, we have committed to participate in the VeraSafe Data Privacy Framework Dispute Resolution Procedure. Subject to the terms of the VeraSafe Data Privacy Framework Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe and participate in the VeraSafe Data Privacy Framework Dispute Resolution Procedure, please submit the required information here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/ . Binding Arbitration If your complaint is not resolved through the above channels, under certain conditions you may invoke binding arbitration for some residual claims not otherwise resolved by other redress mechanisms. For more information about binding arbitration under the Data Privacy Framework, please visit: https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf 19. THIRD PARTY SERVICES AND WEBSITES Our Site may contain links to third-party websites and plugins, for instance a social media login plugin. If you choose to use these websites, plugins, or services, you may disclose your information to those third parties. We are not responsible for the content or practices of those websites, plugins, or services. The collection use and disclosure of your personal information will be subject to the privacy notices of these third parties and not this Policy. We are not responsible for the privacy notices or other practices employed by websites linked to or from, or integrated with, our Site, nor the information or content contained therein. We urge you to read the privacy and cookie notices of the relevant third parties. 20. CHILDREN'S INFORMATION Neither our Site nor our Services are intended for minors under the age of 16 years. We do not knowingly collect personal information from or direct our Services to children under the age of 16. If you are not 16 years of age or older, please do not register with our Services or use our Site. Do not submit your name, email address, or other personal information to us, use our web forms or use any of the interactive or public comment features of our Site or Social Media Pages. If we learn we have collected or received Personal Data from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16 years of age, please contact us at [email protected]. 21. WHAT HAPPENS IF YOU DON'T PROVIDE YOUR INFORMATION You may always choose what personal information (if any) you wish to provide to us. Please note, however, some of our products and services to you may be affected if you choose not to provide certain details, for example, we cannot reply to you without a name or contact details. We also need your personal information to be able to assess your application for our vacant job roles. 22. COMMUNICATIONS AND OPTING OUT OF MARKETING If you provide us with your contact details (e.g., your email address), we may contact you to let you know about the products, services, promotions, and events offered that we think you may be interested in. You can unsubscribe from our marketing and promotional communications by clicking on the unsubscribe link in the emails or by contacting us at [email protected]. You can also manage your notification preferences through your user settings. You will then be removed from the marketing list; however, we may still communicate with you for example to send you service related messages that are necessary to respond to your requests or for other non-marketing related purposes. For example, we may reach out to you with important information about our Services and your use of them. This could include (but is not limited to) notifications about changes to our Services, billing or operations occurring in your account. You will not be able to opt out of certain essential service communications. 23. COOKIES AND OTHER TRACKING TECHNOLOGIES Each time you interact with our Site, we may, depending on the consent provided and your jurisdiction, automatically collect personal information, including technical data about your device, your browsing actions and patterns, content and usage data. We collect this data using cookies and other technologies such as anonymous identifiers, container tags, and other similar technologies like pixels, tags and other identifiers in order to optimize our Services, analyze performance and marketing efforts, and customize your experience. These technologies may be temporarily stored on your device. Some cookies and similar technologies are used to retrieve personal information, like an IP address, that you have previously provided. Our Site and Services, along with some of our service providers, use technologies such as "cookies", anonymous identifiers, container tags, and others to deliver and optimize our Services, analyze performance and marketing efforts, and customize your experience. These technologies may be temporarily stored on your device. Some cookies and similar technologies are used to retrieve personal information, like an IP address, that you have previously provided. Where required by law, such as under the EU GDPR, UK GDPR, the CPRA, and other applicable US state laws, we ask for your consent before setting non-essential cookies. You can set your browser or mobile device to refuse all or some non-essential cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Site may then be inaccessible or may not function properly. Where analytics or similar cookies are used, the providers receive information as processors or sub-processors acting on our behalf. That processing may involve transfers outside the UK and the EEA; safeguards are described in those providers' privacy notices. For GlassHive's approach to international transfers, see the section on transfers of personal information. You can manage your cookie preferences at any time through our cookie settings tool or your browser. Some web browsers may transmit "do-not-track" signals to websites with which the browser communicates. Our Site does not currently respond to these “do-not-track” signals. To learn more about our practices concerning cookies and other tracking technologies please see our Cookie Policy. 24. YOUR PRIVACY RIGHTS In some regions such as the EEA, UK and certain states within the US, you have rights that allow you greater control of and access to your personal information. These rights may include the right: To request and obtain a copy of your personal information To request rectification and/or erasure To restrict processing of your personal information Data portability (if applicable) In certain circumstances you may also have the right to object to the processing of your personal data. You can make a request to exercise your rights by contacting us at [email protected]. We will not discriminate against individuals for exercising any of their privacy rights and will consider and act upon any requests in accordance with applicable data protection laws. 25. ADDITIONAL INFORMATION FOR US RESIDENTS This section applies to individuals residing in the United States, with specific provisions for residents of states with enacted privacy laws. It outlines how we process personal information, including practices related to consent and the rights granted to residents under applicable state laws, such as those in California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, New York, Oregon, Rhode Island, Tennessee, Texas, Utah, Vermont, and Virginia. US Residents Rights US Residents in certain states have specific rights regarding their personal information. These rights vary depending on the state, as indicated below. Right to Know: The right to request information on the categories and specific pieces of personal information we have collected, used, disclosed, or shared, as well as the sources, purposes, and third parties involved. (California, Colorado, Connecticut, Iowa, Utah, Virginia) Right to Access: The right to access copies of personal information held by us. (California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, New York, Nevada, Oregon, Rhode Island, Tennessee, Texas, Utah, Vermont, Virginia) Right to Correct: The right to request corrections to inaccurate personal information. (California, Colorado, Connecticut, Iowa, Utah, Virginia) Right to Delete: The right to request deletion of personal information, subject to legal limitations and exceptions. (California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, New York, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia) Right to Opt-Out of Sale or Sharing: The right to opt-out of the sale or sharing of personal information for purposes such as targeted advertising or profiling. (California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Vermont, Virginia) Right to Limit Use of Sensitive Personal Information: California residents have the additional right to limit the use and disclosure of their sensitive personal information to purposes specified under the CPRA. (California) Universal Opt-Out Mechanism: The right to use a recognized opt-out mechanism to signal privacy preferences across platforms (where applicable). (California, Colorado, Connecticut, Iowa) Consent Requirements Regarding Targeted Advertising, Sale of Personal Information, and Sensitive Data Processing In accordance with various state privacy laws, we provide consumers with the right to opt out of the use of their personal information for targeted advertising or its sale to third parties. While these laws do not always require upfront consent, they ensure that consumers have control over how their data is used for these purposes. Additionally, certain states require explicit consent to process "sensitive" personal information, which may include data such as race, ethnicity, health information, biometric data, and, in some cases, precise geolocation. We are committed to respecting these rights, providing options to manage the use of your personal information, and ensuring that your sensitive data is only processed in compliance with applicable legal requirements. Shine the Light Law and Similar Requirements Under California's Shine the Light law (California Civil Code Section § 1798.83), California residents are entitled to request and receive information regarding certain types of personal information that we share with third parties for their direct marketing purposes. In addition to California, the following states have similar, though narrower, laws concerning data transparency or opt-out rights: Nevada: Nevada law allows residents to opt-out of the sale of their personal information to third parties. While this law does not require detailed disclosures about data sharing for direct marketing, Nevada residents may request that we refrain from selling their personal information. For opt-out requests, please contact us at [email protected]. Vermont: Vermont's law requires data brokers to disclose certain data-sharing practices and allows residents to opt-out of the sale of personal information if their data is collected by a data broker. Vermont residents may contact us for more details on our data-sharing practices. To make a Shine the Light request or exercise similar rights under Nevada or Vermont law, please contact us including the term “Shine the Light Request” or “Data Sharing Request” in your subject line. Please specify the nature of your request (e.g., Shine the Light, Nevada Opt-Out, or Vermont Disclosure Request) and include sufficient details in your request to help us identify your records. We will process and respond to your request within the required timeframes. Please note, in all cases, we may require additional information to verify your identity before processing certain requests. The identity verification process may vary depending on how you submit your request but we will only ask for information needed to verify your identity. Once verified, we will respond within the timeframe specified by the relevant state law. Consistent with California law, you may designate an authorized agent to make a request on your behalf. If you do so, we may require proof of your identification, as well as proof of the authorized agent's identification and any other information that we may request in order to verify the request, including evidence of valid permission for the authorized agent to act on your behalf. 26. SALE OR SHARING OF PERSONAL INFORMATION In accordance with the CCPA and the CPRA we are required to disclose whether we have “sold” or “shared” personal information. The table below identifies the categories of personal information we may have sold or shared for commercial purposes in the 12 months preceding the effective date of this Policy, along with the categories of third parties to whom this information may have been disclosed. Category of Personal Information Categories of Third Parties To Whom Personal Information Is Sold/Shared None None 27. ADDITIONAL INFORMATION FOR EEA, UK AND SWISS RESIDENTS Applicable Laws We are subject to the EU GDPR, the UK GDPR and the FADP in relation to the goods and services we offer to individuals and our wider operations in the UK, European Economic Area (EEA) and Switzerland. EU Representative We have appointed Rickert Rechtsanwaltgesellschaft GmbH to act as our EU representative. If you wish to exercise your rights under the EU General Data Protection Regulation (EU GDPR) or have any queries in relation to your rights or general privacy matters, please email our representative at [email protected]. Please ensure you include our company name in any correspondence you send to our representative. UK Representative We have appointed Rickert Services Ltd UK to act as our UK representative. If you wish to exercise your rights under the UK General Data Protection Regulation (UK GDPR) or have any queries in relation to your rights or general privacy matters, please email our representative at [email protected]. Please ensure you include our company name in any correspondence you send to our representative. Swiss Representative We have appointed Haerting Attorneys-at-Law Ltd. to act as our Swiss representative. If you wish to exercise your rights under the Swiss Federal Act on Data Protection (FADP) or have any queries in relation to your rights or general privacy matters, please email our representative at [email protected]. Please ensure you include our company name in any correspondence you send to our representative. Further Details about our processing The table below describes the ways we may use your personal information and which lawful basis/bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Processing Purpose Types of Data Processed Lawful Basis Explanation of Legitimate Interest (If Applicable) To provide the Services: Set up and management of client accounts, fulfilment of transactions, inclusive of payments for Services purchased, and performance of contracts Account Information; Communication Information; Contact Information; Financial Information; Identity Information; Technical and Device Information; Transaction Information Contractual Necessity N/A To provide and improve our Site and Services, including management of the Site and Services to identify areas for improvement or update Activity Information; Clickstream and Browsing Activity Information; Communication Information; Location Information; Survey and Promotion Information; Technical and Device Information; Usage Information Contractual Necessity, Legitimate Interests Necessary to ensure the quality and integrity of our service provision Service updates and support: including customer support Activity Information; Communication Information; Contact Information; Identity Information; Location Information Contractual Necessity, Legitimate Interests Necessary to maintain communication and provide assistance to users of GlassHive Services / clients, ensuring efficient and responsive service to fulfil expectations Fraud prevention Account Information; Clickstream and Browsing Activity Information; Contact Information; Communication Information; Identity Information; Location Information; Technical and Device Information; Transaction Information; Usage Information Legitimate Interests (fraud prevention) Ensures the integrity, safety, and quality of services, protecting both users of our Services and GlassHive from potential risks, while improving / maintaining the quality of service delivery Service security: Ensuring the security of our Site and Services Clickstream and Browsing Information; Identity Information; Technical and Device Information; Usage Information Legitimate Interests (security) Necessary to protect against unauthorized access and to enhance service reliability, to ensure secure and consistent user experience Marketing: Offering relevant promotions and advertising, including the running of webinars and subscription to the GlassHive community Activity Information; Clickstream and Browsing Activity Information; Contact Information; Location Information; Marketing Preferences; Technical and Device Information; Usage Information Consent, Legitimate Interests Necessary to support client engagement by informing them of relevant offerings, updates, and promotions that align with their reasonable expectations as clients Marketing: Lead creation Activity Information; Clickstream and Browsing Activity Information; Contact Information; Location Information; Marketing Preferences; Publicly Available Information Consent, Legitimate Interests Necessary to nurture and support the creating of client relationships Surveys and promotions Contact Information; Identity Information; Location Information; Marketing Preferences; Survey and Promotion Information Consent, Legitimate Interest (surveys) Necessary to inform Service improvement and development Legal compliance Potentially All Data Types Legal Obligation N/A Recruitment: Processing job applications, operate referral process, screen candidates, conduct interviews, complete pre-employment checks and make hiring decisions Communication Information; Contact Information; Employment Information; Identity Information; Images and Visual Data; Location Information; Publicly Available Information; Resume and Application Information; [Sensitive Information] Consent (some jurisdictions only), Contractual Necessity, Legitimate Interests Necessary to enable the identification of possible candidates, assessment of candidate suitability, facilitation of efficient hiring practices and support of company growth and operational needs Managing our business: Maintaining and monitoring our Site and Services, and the performance and improvement of same Activity Information; Clickstream and Browsing Information; Communication Information; Contact Information; Identity Information; Location Information; Technical and Device Information; Transaction Information; Usage Information Legitimate Interests (business operations and service enhancement) Necessary to allow for required monitoring and enhancements to deliver high-quality, functional, and reliable Services, ensuring ongoing improvement to benefit customers and users Rights and claims: Enforcing terms, exercise rights, defend claims, and comply with laws and regulations Potentially All Data Types Legal Obligation, Legitimate Interests (legal defense and compliance) Necessary to protect GlassHive’s legal rights and interests, ensuring compliance with applicable laws and the defense against potential claims when required Data analytics: Improving our Site and Services to ensure high quality customer relationships, and user experience Activity Information; Clickstream and Browsing Activity Information; Location Information; Technical and Device Information; Usage Information Legitimate Interests (service and experience improvement) Necessary to support improvement of our products, services, and the user experience, including by analyzing patterns, enhancing customer satisfaction, and optimizing functionality within the Site Data subject rights: Verifying identity and fulfil data subject rights requests Potentially All Data Types Legal Obligation N/A Business acquisition or reorganization Communication Information; Contact Information; Financial Information; Identity Information; Publicly Available Information; Transaction Information Legitimate Interests (business continuity) Necessary to ensure that business operations can continue seamlessly in the event of a merger, acquisition, or reorganization, allowing for the transfer of necessary data in compliance with legal and contractual obligations Complaints and queries Account Information; Communication Information; Contact Information; Identity Information; Location Information; Marketing Preferences; Transaction Information Contractual Necessity, Legitimate Interest (customer service) Necessary to provide effective and timely resolution of complaints and queries to improve customer experience, ensure service satisfaction, and maintain customer trust Managing Payments, Fees and Charges Account Information; Contact Information; Communication Information; Financial Information; Publicly Available Information; Transactional Information Contractual Necessity, Legitimate Interest, Legal Obligation Necessary to ensure effective and reliable payment processing, the prevention of fraud and to ensure accurate business and accounting records are maintained Details about transfers of personal information overseas The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy. It is sometimes necessary for us to transfer your personal information to countries outside the UK and EEA. In those cases, we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal information. Under data protection laws, we can only transfer your personal information to a country outside the UK/EEA where: in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an 'adequacy regulation') further to Article 45 of the UK GDPR. in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an 'adequacy decision') further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here. there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Where we transfer your personal information outside the UK, we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal information outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this Policy. Where we transfer your personal information outside the EEA, we do so on the basis of an adequacy decision or (where this is not available) legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal information outside the EEA unless we can do so based on an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this Policy. Your rights Please see more details about your rights in the table below. In most circumstances, you do not need to pay any charge for exercising your rights. We have one month to respond to you. YOUR RIGHT DETAILS Right to be informed We have a legal obligation to provide you with concise, transparent, intelligible, and easily accessible information about your personal information and our use of it. We have written this Policy to do just that, but if you have any questions or require more specific information, please contact us. Right of access You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information. When you request this data, this is known as making a data subject access request (DSAR). In most cases, this will be free of charge; however, in some limited circumstances, for example repeated requests for further copies, we may apply an administration fee. Right to rectification You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. Right to erasure You have the right to ask us to erase your personal information in certain circumstances. We have the right to refuse to comply with a request for erasure if we are processing the relevant personal information for one of the following reasons: To exercise the right of freedom of expression and information. To comply with a legal obligation. To perform a task in the public interest or exercise official authority. For archiving purposes in the public interest, scientific research, historical research or statistical purposes. For the exercise or defence of legal claims. Right to restriction of processing You may ask us to stop processing your personal information. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies, you may exercise the right to restrict processing: The accuracy of the personal information is contested. Processing of the personal information is unlawful. We no longer need the personal information for processing, but the personal information is required for part of a legal process. The right to object has been exercised and processing is restricted pending a decision on the status of the processing. Right to object to processing You have the right to object to processing in certain circumstances. You can also object if the processing is for a task carried out in the public interest, the exercise of official authority vested in you, or your legitimate interests (or those of a third party). Right to data portability This right only applies if we are processing information based on your consent or for the performance of a contract and the processing is automated. Complaints We hope that we can resolve any query or concern you raise about our use of your information. Please contact us at [email protected] in the first instance and head your email “Complaint”. All complaints will be treated in a confidential manner, and we will try our best to deal with your concerns. You have the right to lodge a complaint with a supervisory authority in the EEA member state where you work or normally live, or where any alleged infringement of Data Protection Law occurred. The details of European supervisory authorities can be found here: Our Members | European Data Protection Board (europa.eu) The supervisory authority in the UK is the ICO, which may be contacted at https://ico.org.uk/concerns or by telephone on 0303 123 1113. The details of the supervisory authority in Switzerland can be found here: Startseite 28. ADDITIONAL INFORMATION FOR CANADIAN RESIDENTS GlassHive processes personal information in accordance with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA). Where personal information is transferred outside of Canada, including to the United States, it may be subject to the laws of those jurisdictions, including lawful access by courts, law enforcement, or national security authorities. If you have questions about our handling of your personal information, you may contact us using the details in the “Contact Us” section. If you are not satisfied with our response, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada (OPC). More information can be found at: https://www.priv.gc.ca/ 29. UPDATES TO THIS POLICY We may modify or amend this Policy from time to time at our discretion to reflect changes in our practices, legal requirements, or for other operational reasons. If we make material changes to this Policy, we will post the updated Policy on our Site and shall amend the revision date at the top of this page. If required by applicable law, we will also notify you directly or request your consent before the changes take effect. The modified or amended Policy shall be effective as to the personal information governed by this Policy as of the revision date. If we make material changes to how we treat your personal information, we will also notify you by email to the email address specified in your account and/or through a notice on the Site home page. The date this Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you. We encourage periodic review of this Policy to view any updates, so that you may stay informed about how we protect your personal information. 30. QUERIES AND FEEDBACK We welcome your feedback regarding this Policy. If you have questions, comments, or concerns about either one, please contact us by e-mail at [email protected]. We will respond in good faith to all privacy queries. You may additionally contact us using the contact details given in the “CONTACT US” section above and / or, where applicable, you may contact our EU, UK or Swiss Representatives using the additional details given for each respectively below: GlassHive EU Representative GlassHive UK Representative GlassHive Swiss Representative Rickert Rechtsanwaltsgesellschaft GmbH - GlassHive LLC - Colmantstraße 15 53115 Bonn Germany Rickert Services Ltd UK - GlassHive LLC - PO Box 1487 Peterborough PE1 9XX United Kingdom HÄRTING Attorneys-at-Law Ltd. Landis + Gyr-Strasse 1 6300 Zug