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Privacy Policy Last Updated: 8 JULY 2026 1. Who We Are Runa Network Limited, Runa Network Inc., and Runa Network GMBH (“Runa”, “we”, “us” or “our”), each are a controller of your personal data in accordance with applicable data protection law and are committed to respecting and protecting your privacy. To that end, we want to inform you on how we will collect, use, store, share and protect your personal information when you transact with us. You accept this privacy policy (the “Privacy Policy”) whenever you access or use Runa products, services, features, and technologies including, but not limited to, www.runa.io (the “Runa Site”). Please read this Privacy Policy carefully. Runa has appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us via the details provided at the bottom of this Privacy Policy. 2. What Types of Data Collected and How We Use It This section breaks when and why we process (collect, store, analyze, and/or delete) your “Personal Data” or “Personal Information” which means any information about you from which you can be identified. This may include information kept in a pseudonymised form. We will only use your Personal Data when the law allows it. We will only use your personal data for the purposes for which we collected it, unless (where permitted by law) we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose, and provide notice regarding this new purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. Generally, outside the United States, a lawful basis is needed for processing your Personal Data and those basis are outlined below. Within the United States, by accepting this privacy policy you have consented to the processing. Most commonly, We will use your Personal Data in the following circumstances: to perform the contract we are about to enter (or have entered into) with you; as necessary for our legitimate interests; to comply with a legal obligation; pursuant to your consent to processing. Additionally, Runa may collect or retain data that has been de-identified, anonymised or aggregated, which are not personally identifiable and therefore are not considered Personal Data. We may use your Personal Data in de-identified form (de-identification being a process by which we eliminate any personal identifiers and personal details) for research or statistical purposes and to assist us in running our business. We may also share de-identified data in aggregated form with third parties for different purposes. When your Personal Data is included in anonymised, aggregated data, it becomes impossible to identify you or anything about you from that data. Use of Our Website or Services When you use our website, register for an account, or contact us for customer service we may collect the following “Personal Data” or “Personal Information”, which means any information about an individual from which that person can be identified. This may include information kept in a pseudonymised form. Identity: first name, last name, date of birth, social security number, curriculum vitae Contact Information: billing, mailing, or email address, and telephone number Professional: company name, your job title, and company address Technical Data: IP address, browser settings, browser plug-in types, operating system. Usage Data: information about how you use the Site. Marketing Comms: desires regarding marketing/communications from us or third-parties. Transactions: details about payments you may make on our website, refunds, bank account information, payment credentials which you send or request. Commercial: payout amounts, payor information and record of Services provided to you. Biometric Data: photograph and facial recognition information Data from other sources: Details from Google or social media providers or any other email provider you choose to use to log in to our website. Purpose/Activity Type of Data Non-US Lawful Basis for Processing To manage our relationship with you, which includes:(a) registering your account; (b) notifying you about changes to our terms or privacy policy; (c) asking you to leave a review or take a survey. IdentityContactProfessionalBiometric (a) Performance of a contract with you; (b) Necessary to comply with legal obligation; (c) Necessary for our legitimate interests (to improve customer satisfaction through feedback); (d) Necessary for our legitimate interests (verifying your identity). To assess and approve each proposed transaction IdentityContactFinancial (a) Performance of a contract with you; (b) Legitimate interest in verifying your identity. To process approve transactions on your behalf and retain records related to same IdentityContactFinancialTransaction (a) Performance of a contract with you To process, manage and investigate and resolve any claim or complaint raised by you IdentityContactFinancial (a) Performance of a contract with you; (b) Necessary to comply with a legal obligation. To use data analytics to improve our Site, products/services, customer relationships and experiences TechnicalUsage (a) Necessary for our legitimate interests (to define types of customers for our products/services, to keep our website updated and relevant and to develop business strategies) To make suggestions and recommendations to you about goods or services that may be of interest to you, and/or to send you other marketing communications IdentityContactTechnicalUsageMarketing Comms (a) Consent (marketing by text or email); (b) Necessary for our legitimate interests (to develop our products/services and grow our business). Recruitment and Employment Context If you apply for a job at Runa, we generally process your Personal Data to verify if we can be an employment match. Further, if you become employed by Runa, we process your Personal Data to facilitate our relationship as your employer. This may include information kept in a pseudonymised form. We may collect thePersonal Data, which may include: Identity: first name, last name, date of birth, social security number, curriculum vitae Contact Information: mailing, or email address, and telephone number Additional Information: information about your right to work in the relevant country; responses to application questions; questions regarding your notice period; salary expectations; willingness to commute; and the type of employment you seek. Additionally we may collect the following on an optional basis. Special Category Data: gender identity, ethnicity, sexual orientation, neurodiversity or disability status, other diversity-related information. Diversity monitoring (optional): Where you choose to provide diversity information for monitoring purposes, this information is collected on a voluntary basis. It is separated from your application and is not visible to recruiters or hiring managers assessing your candidacy. It is used only in aggregated and anonymised form for diversity monitoring, reporting, and improving the fairness and inclusiveness of our recruitment processes. Adjustments/accommodations (optional): Where you choose to provide information about a disability, health condition, or other needs in order to request adjustments/accommodations during the recruitment process, we will use this information only to assess and implement the requested accommodation and to support a fair recruitment process. Access to this information is restricted to those who need to know in order to provide the accommodation, and it will not be used for diversity monitoring unless you separately provide diversity information for that purpose. There is no obligation to provide special category data, and choosing not to do so will not affect your application. Where we process special category data, we do so only where permitted under applicable law and based on an appropriate legal condition (for example, where necessary for employment/equality law obligations and/or explicit consent where applicable Purpose/Activity Type of Data Non-US Lawful Basis for Processing Reviewing and assessing applications; background checks; reference checks; establishing/exercising/defending legal claims, fair recruitment process IdentityContact Legitimate interestLegal obligation Conducting interviews and assessments; communicating with candidates; retaining candidate profiles for future opportunities IdentityContact Legitimate interest Right to work and immigration checks IdentityContact Legal obligation Diversity and inclusion monitoring; fair recruitment process and arranging for practical accommodations IdentitySpecial Consent and/or substantial public interest 3. Other Details About Your Data Withdrawal of Consent: As applied to individuals outside of the United States, you may withdraw your consent at any time (as it relates to personal data processed solely pursuant to your consent) by completing a Subject Consent Withdrawal Form. This will be provided to you upon emailing our Data Protection Officer at the contact details below. As applied to individuals within the United States, you may withdraw your consent with regard to any sale/sharing for commercial purposes of your Personal Data as outlined herein. Artificial Intelligence and Automated Decisions: Runa utilizes artificial intelligence with regard to your Personal Data as follows: Use of Website or Services Context: fraud prevention and risk analysis in determining whether a company is given access to our platform and/or services. Runa has committed itself to monitoring for bias within its use of artificial intelligence with an eye towards fairness in its application. Recruitment and Employee Context: support certain parts of our recruitment process and improve the candidate experience. These tools are used to assist our recruitment team and are subject to human oversight. This may include reviewing CVs or applications against role-related criteria defined by our recruiters; supporting interview administration and note taking; and supporting interview recording or transcription (where used). AI-enabled tools may generate outputs such as summaries, transcripts, or other information to help our team review applications and interviews more efficiently. Recruiters and hiring managers review AI outputs and do not rely on them as the sole basis for decisions. All hiring decisions, including decisions relating to shortlisting, interviews, and offers, are made by employees following human review and consideration. Where interview recording or transcription tools are used, candidates will be informed in advance and may request not to be recorded or transcribed (where feasible). In some circumstances, we may use automated screening rules (that prevent progression in the recruitment process) within our recruitment systems to assess whether candidates meet mandatory eligibility requirements for a role. These checks are based on objective, bright-line criteria relevant to the position (and therefore do not involve the use of profiling or decision-making), such as: whether a candidate has the required right to work in the relevant location; whether sponsorship is available for the role; whether a candidate is located in a required location; or other essential role requirements If you have concerns about the use of AI-enabled tools in connection with your application, would like to correct an automated screening outcome made in error, or would like additional information about a recruitment decision, you may contact us at talent@runa.io. Accordingly, Runa utilizes human intervention to review automated recommendations involving decision-making regarding any significant decisions made about you. 4. How Is Your Personal Data Collected When You use the Site, we may collect Personal Data from you directly, or we may collect Personal Data automatically when you interact with the Site. Direct Interactions. You may give us your Personal Data by filing in forms or by corresponding with us through the Site (including when you process a transaction) or throughout the course of direct communication. Automated Technologies. As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. You can manage your cookie preferences when first accessing our Site. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about our use of cookies, please refer to our Cookies Policy. 5. Disclosures of Your Data Generally We may share your Personal Data with the parties set out below for the purposes outlined in the table in Section 2. Use of Our Website or Services Context Only: Brands to process your purchase transactions. E-Gift Card distribution services marketing tracking partners, messaging services, online and offline marketing services, to handle, store, or use certain Personal Data on our behalf. Recruitment or Employment Context Only: Recruitment platforms Recruitment agencies All Contexts Background Screening providers Service providers such as professional advisers (e.g. lawyers, accountants), web and app hosting services, website optimisation services, website usage services, email services, data management platform provision, customer relationship management services Our affiliates/subsidiaries. Third parties to whom we may sell, transfer or merge part of our business assets. Regulators or legal authorities (such as law enforcement) to meet our legal obligations, prevent criminal activity or for reasons of substantial public interest. Runa conducts impact assessments on the parties it shares your data with for AI-driven activities. History of Disclosures Within the past 12 months, Runa has disclosed Personal Data to third-parties as outlined above for business purposes as outlined in the table in Section 2. Within the past 12 months, Runa has not sold Personal Data for any commercial purpose or for monetary consideration. 6. International Transfers Personal data we collect may be transferred to, stored and processed in, the United States and any other county outside the European Economic Area (EEA) in which our data processors are located. Our processors are listed here: https://www.runa.io/subprocessor Personal data we collect may be transferred to, stored and processed in, the United States and any other county outside the European Economic Area (EEA) in which our data processors are located. We will ensure that transfers of personal data to a third country or an international organisation are subject to appropriate safeguards, including pursuant to the most recent standard contractual clauses. Where applicable, you may request a copy of the relevant transfer safeguards (such as the SCCs) by contacting legal@runa.io. 7. Data Security We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 8. Data Retention Recruitment Context: If your application is unsuccessful, you withdraw from the process, or you decline an offer, we will generally retain your personal information for up to 24 months in order to consider you for future opportunities and improve our recruitment processes. You may request deletion of your information at any time. After the 24-month retention period, unless you opt in to remain in our talent network, identifiable information relating to your application will be anonymised and aggregated for reporting and analytics purposes only. If you are offered and accept a position with us, your personal information will become part of your employment record. All Other Contexts: We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. 9. Your Legal Rights Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the following rights: Right to Know/Access: Often referred to as a “data subject access request”, you have the right to know the Personal Data we have collected about you. Right to Correct: You have the right to correct inaccurate Personal Data about you. Once we receive and verify your request, we will use commercially reasonable efforts to correct the inaccurate Personal Information about you. Right to Delete: You have the right to request that we delete the Personal Data we collected from you and maintained, subject to certain exceptions. Right to Portability: You have the right to receive Personal Data concerning yourself in a structure commonly used and machine-readable formation and to have that data transmitted to another controller. Right to Restrain: You have the right to restrain our processing of Personal Data: (i) for a period of time where the accuracy of the Personal Data is contested by You; (ii) where the processing is unlawful and you oppose erasure of the Personal Data; (iii) where we no longer need the Personal Data but it is required by you for establishment/defense of legal claims; and/or (iv) you have objected to our use of the Personal Data but we need to verify whether we have an overriding legitimate grounds for using the Personal Data. Right to Object: You have the right to object to our processing of Personal Data for direct marketing purposes; or on the basis of a legitimate interest. Right to Opt-Out/In of Sale/Sharing*: You have the right to opt-out or to opt-in to having your Personal Data sold or shared as defined under applicable law. Right to Non-Discrimination*: You have the right to not receive discriminatory treatment by us for the exercise of any of your above listed rights. We do not discriminate against users for exercising the rights granted to them under applicable law. To exercise your rights outlined above, you must provide us with sufficient information for us to determine your identity and describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it. Please submit your request to us by email: legal@runa.io. We do not use your Personal Data to profile you in furtherance of decisions that produce legal or significantly similar effects (as may be defined under applicable law). Additionally, you may choose to: lodge a complaint regarding our privacy practices with your applicable data privacy supervisory authority in your jurisdiction; submit a complaint to Runa if you believe that we have not complied with the UK GDPR in relation to your Personal Data or Part 3 of the Data Protection Act 2018 by submitting an email to legal@runa.io with the subject line “Section 164A Complaint”. 10. California Opt-Out of Sale / Sharing Disclosure You may opt out of the sale/sharing of your Personal Data: by submitting a request via email to legal@runa.io; or by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use. 11. Additional Details Data Protection Officer Contact Details If you have any questions or complaints about this Privacy Policy or Our privacy practices, you can reach Our data privacy officer by email at legal@runa.io. Controller Contact Details For users of the Runa Platform based in the UK: Controller Name: Runa Network Limited Controller Address: 21-33 Great Eastern Street, 1st Floor, London, EC2A 3EJ Controller Contact: legal@runa.io Supervisory Authority: ICO (Information Commissioner's Office), you may complain here. Controller Name: Runa Network Inc. Controller Address: 1440 W Taylor St #40 Chicago, IL 60607, USA Controller Contact: legal@runa.io Supervisory Authority: You may raise concerns with your relevant state Attorney General or regulator. For users of the Runa Platform based in the EU: Controller Name: Runa Network GmbH Controller Address: Eschersheimer Landstraße 42, Frankfurt am Main Controller Contact: legal@runa.io Supervisory Authority: EU candidates may lodge a complaint with their local supervisory authority (in Bulgaria, Commission for Personal Data Protection (CPDP)) Changes to the Privacy Policy We may make changes to the Privacy Policy from time to time to keep it up to date and accurate based on our privacy practices. If we make material changes, we will notify you by email. Third Party Links This website may include links to third-party websites (“TPW”), plug-ins, and applications. Clicking on those links or enabling those connections may allow third-parties to collect and disclose data about You. We do not control those TPWs, and are not responsible for their privacy practices. 12. Children Our products are not directed to individuals under the age of 16, and we do not knowingly collect or sell the personal information of children under the age of 16. 13. Glossary Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. Processing in relation to Personal Data, this means any operation or set of operations which is performed on it. This includes collecting, storing, recording, using, amending, analysing, disclosing or deleting it. 14. Changes to this Privacy Policy We may make changes to the Privacy Policy from time to time to keep it up to date and accurate based on our privacy practices. If we make material changes, we will notify you by email. v1.1.2