PRIVACY POLICY

Current version of December 1, 2021

This Privacy Policy determines what data and information about Users (hereinafter referred to as "You", "Users") and how CallPanda: CallPanda FZ LLC, country of registration UAE, registration number 98130, Dubai Internet City, Building # 1, office 315, P.O. Box 73000 collects and processes during the use of our CallPanda service (a cloud platform for video interviews and evaluation of candidates), (hereinafter referred to as the "Service") and other sites where this Privacy Policy is posted. The pronouns "we", "our" and their derivatives also refer to CallPanda (hereinafter referred to as the "Company").

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THE SERVICE.

1. CONTROLLER OF USER DATA.

A data controller is a company that has the authority to determine the purposes and means of processing your personal data and monitors compliance with the requirements regarding the collection, use and retention period of information in accordance with the General Data Protection Regulations.

CallPanda FZ LLC performs the functions of a controller in relation to its Service.

2. LIST OF DATA ABOUT YOU THAT WE COLLECT:

2.1. Data that you provide to us directly:

2.1.1. Full name and contact information (first name, last name, email address, postal address, phone number and other contact information of this kind), nickname, age (mainly age range), which can be provided to us by you (at your discretion) or by our partners under a condition of a legitimate reason for this;

2.1.2. in the case of working with legal entities: the name of your company, the number of employees, the legal address and registration number of the company, your position;

2.1.3. credentials (passwords, password hints and other data used to verify the authenticity of the User's account and ensure the safe use of the Service);

2.1.4. when you contact the support service, send messages/ comments in chat rooms, forums and websites - data that you send at your discretion and/or with your consent;

2.1.5. in case of your participation in surveys - the data required to participate in the survey;

2.1.6. data of payment instruments used to pay for the services of the Service;

2.1.7. any types of identifiers for advertisers (IDFA, such as Apple IDFA and Google AAID) and other data required for your registration in our services through social media accounts, for linking your social media account to the Service (for example, Facebook, Twitter);

2.1.8. any information obtained from the above data used for analytics, including obtaining marketing, advertising or other statistics.

2.2. Data that we can collect automatically:

2.2.1. Cookies (more detailed information is available in our Cookie Policy), IP address, browser name, traffic source (including the source from which our games or applications were installed on your device);

2.2.2. technical specifications and data about the device (operating system, manufacturer, model, screen resolution, interface language);

2.2.3. traffic source (the source from which the Service was installed on your device);

2.2.4. general location data (usually your country and city, without identifying your specific location);

2.2.5. automatically collected information about the device used by the User of the Site to access the Service (information about the device and how the User and his device interact with the Service).

2.2.6. the facts of your contact the support service and filed requests in accordance with this Privacy Policy or the Terms of Use.

2.2.7. Data from payment partners to send you invoices when you make purchases, if applicable.

2.3. Publicly available data that we may collect:

2.3.1. Your reviews, comments, opinions about our Service and our services published by you in the form of texts, audio recordings, videos on publicly available resources.

2.4. Data that we do not collect:

2.4.1. We do not request or collect any special categories of personal data about you (for example, data about your health, race, religion, political views).

2.4.2. We do not record or store your payment data. Such data is collected and processed by our payment partners; we only provide them with the technical capabilities for such processing as part of our services. Since such partners usually do not have a general unified privacy policy applied in all regions, we recommend you familiarize yourself with the relevant documents by accessing them when making a payment through the partner services (for example, after you were redirected by our services to the website of the corresponding service during the payment procedure).

3. THE GROUNDS FOR PROCESSING YOUR USER DATA.

3.1. We use the information collected about you and your device solely for the purpose of providing you with Services and the operation of the Service. The goals and objectives that we follow when processing your user data include:

3.1.1. operation, administration and support of the Service;

3.1.2. receiving error messages in the operation of the Service, improving the quality of service, development, revision, improvement of the Service, Sites and related services;

3.1.3. provision by the Company to each User of the possibility of safe use of the functionality of the Company's Service;

3.1.4. providing the User with information about the Company, its products, services, and other events;

3.1.5. processing User requests, providing responses and communicating with the User when contacting the Company;

3.1.6. sending to the User news and other materials, additional information about the Company and produced products by means of mailings made to the User's e-mail address in cases where the User has requested or consented to receive such materials through the specified communication channel;

3.1.7. for internal purposes of the Company, such as audits, performing summary data analysis and business analytics, conducting other research, reporting on the Company's activities, to improve the Company's products, services and communication with customers;

3.1.8. to ensure the necessary level of security of the Service and Users, to detect and prevent fraud, to conduct investigations on suspicion of fraud or other illegal behavior or violation of any law or this policy or the rights of third parties; to resolve disputes and in connection with the conduct of legal proceedings; to disclose information required by law, decree or court decision; as well as to establish, protect or exercise legal rights.

3.1.9. compliance with applicable laws, fulfillment of legal obligations, realization or protection of our rights, protection of the vital interests of Users or the interests of others.

3.1.10. some of your user data may be available for viewing by other persons, for example, other Users may see the nickname and photo of your account, chat messages, comments.

4. TRANSFER OF USER DATA TO THIRD PARTIES. DATA STORAGE.

4.1. As a general rule, we do not disclose your user data to anyone and ensure their confidentiality. However, in some cases described in this Privacy Policy, we may transfer your user data to third parties:

4.1.1. legislative and law enforcement bodies of any country, regulators, court in order to comply with applicable law, to respond to their legitimate requests;

4.1.2. to our partners who process your user data for the purposes of statistics, analytics and providing you with personalized advertising on the Internet, to our advertising partners some of your user data (including email address) necessary for placement, personalization (targeting) of advertisements, accounting for advertising services rendered, to our partners who provide the following services to the extent necessary to provide the relevant service: (a) hosting, (b) support and testing of the Service; (d) conducting statistical and marketing research, information analysis, to partners providing two-factor authentication service.

4.1.3. In case of alienation of exclusive rights to the Service, transfer of operating rights (use) to another operator - user data to the acquirer of exclusive rights to the Service, a new operator, a buyer of the Company, or a new legal entity formed because of a merger with another company, respectively, without obtaining additional consent from you.

4.1.4. we may disclose information necessary to detect, investigate and prevent violations of the rules of the Service.

4.1.5. The Company and its affiliates may hire third-party professional companies for audit purposes, in connection with which some of your user data (your ID, email address, payment rates) may be transferred to such companies solely for audit purposes.

4.1.6. we have the right to conclude contracts with other partners and will make every reasonable effort to update the list of types of our partners in this Privacy Policy in a timely manner at least once every six months, or more often in case of a significant change in our data processing practices.

4.2. We store any personal data collected as long as your Account exists on our Service and as long as it is necessary to provide you with services. We delete your personal data after achieving the purposes for which the collection was carried out.

We work all over the world, and therefore we can transfer your user data to our partners in countries located both in the United Arab Emirates, the countries of the European Union and the European Economic Area, the United States of America, and beyond. At each transfer of your user data, we take reasonable measures to ensure confidentiality, including entering into standard contractual terms for the transfer of data accepted in these countries.

5. YOUR RIGHTS

5.1. Right of access.

5.1.1. You have the right with a reasonable frequency request from us information about our storage of your personal data or a copy of your stored personal data. To do this, you need to send a request to our support service and follow the provided instructions. Please note that in some cases, in order to fulfill the request, we may request from you some additional information necessary to identify you as our user. We undertake to fulfill your request free of charge within a period not exceeding one (1) month from the date of receipt of your request, and in some cases provided for by law this period may be extended to two (2) months. We have the right to refuse you to exercise this right if your request has no explicit justification or if you send us such requests too often.

5.2. The right to refuse to receive personalized advertising and direct marketing messages.

5.2.1. You can change your browser settings at any time and refuse to use analytical cookies on your device used to personalize advertising offers for you.

5.2.2. We have the right to send you targeted offers based on the analysis of your user data available to us in accordance with certain algorithms. These proposals do not significantly affect your rights and interests, they are intended to provide you with timely and interesting proposals, in our opinion, for you. However, if you want to opt out of receiving targeted offers from us, please let our support service know.

5.3. The right to clarify and delete data.

5.3.1. You have the right to request clarification of inaccurate personal data at any time. If any of your personal data processed by us has become irrelevant to you, please inform us at our email address. In some cases, in order to fulfill the request, we may request from you some additional information necessary to identify you as our user. We undertake to fulfill your request for clarification of data free of charge within a period not exceeding one (1) month from the date of receipt from you of the request and additional information requested by us, in some cases provided for by law, this period may be extended to two (2) months. You have the right to request the deletion of your personal data by sending us an appropriate email address. Please note that in some cases, in order to fulfill the request, we may request from you some additional information necessary to identify you as our user. We undertake free to fulfill Your request deletion of data within a period not exceeding one (1) month of receipt of your request and the additional information we requested, and in some cases provided by law, this period may be extended to two (2) months.

5.3.2. Please note that execution of a request deletion of Your personal data will delete the Account. Please note that we have the right to continue to store some of your data even after fulfilling your request to delete such data, including, but not limited to, in the following cases:

• we have a legal basis for further processing of your data, except for your consent. For example, we may be required to do this in order to comply with applicable law;
• your data is anonymized and cannot be used to identify you, and therefore is no longer data that allows you to establish your identity.

5.4. The right to object and transfer personal data.

5.4.1. You have the right to object to the processing of your personal data. Let us know if you have any objections by e-mail. You have the right to receive the personal data that you have provided to us, as well as the right to transfer this data to another controller from the current controller, if the processing is carried out by automatic means.

6. PERSONAL DATA OF CHILDREN.

6.1. As a general rule, our Service is not intended for children under the age of 16 (as well as children who have not reached the age of consent to dispose of their personal data in accordance with applicable law), and we do not intentionally collect personal data from them. If we know for certain that we have unintentionally collected personal data from a child under the age of 16 (or a child who has not reached a different age of consent in accordance with his personal law) without the consent of his legal representative, we will take all reasonable steps to delete this information as soon as possible.

7. INFORMATION PROTECTION

7.1. In order to ensure the security of the processing of your personal data, we are constantly developing and implementing technical and organizational measures to protect your personal data from unauthorized access, disclosure, misuse, modification, loss and destruction.

8. PRIVACY RIGHTS FOR EUROPEAN CITIZENS

8.1. If you reside in the European Economic Area, you have certain privacy rights available to you in accordance with applicable law. We will process your request in accordance with the applicable data protection legislation. We may need to retain certain information for accounting purposes or to complete transactions that you started prior to the deletion request.

8.1.1. We may refer to your consent to process certain personal data. In cases where we do this, you have the right not to give your consent or withdraw it at any time.

8.1.2 You have the right to access the personal data that we store about you, and in some limited cases, you may be provided with this data so that you can grant it to another provider.

8.1.3. Under certain circumstances, you have the right to delete the personal data that we store about you (for example, if they are no longer needed for the purposes for which they were originally collected).

8.1.4. You have the right to request that the Company stop processing your personal data and/or require us to correct any inaccurate or incomplete personal information.

8.1.5. You have the right to request that we restrict the processing of your personal data in certain circumstances (for example, if you believe that the personal data stored by us is not accurate or is stored on illegal grounds).

9. RESIDENTS OF CALIFORNIA.

9.1. The California Consumer Protection Act of 2018 ("CCPA") grants additional rights to receive information, delete data and refuse to process it and requires companies collecting or disclosing data to provide notifications and opportunities to exercise rights.

9.2. Users who are residents of California may request: a list of categories of our data disclosed by us to third parties during the immediately preceding calendar year for the own marketing purposes of such third parties; a list of categories of third parties to whom we disclosed such data. We may require additional information from you to verify your identity.

9.3. If the Company sells your data in accordance with the definition of the term "sale" in the CCPA, you have the right at any time to refuse to sell your data by us to third parties.

9.4. You may appoint an authorized representative to send requests on your behalf. However, to do this, we will need a written confirmation of the representative's authority and a direct verification of your identity.

9.5. CCPA allows companies to offer customers financial incentives for providing data. For example, a Company may offer a reward program or provide other benefits or offers to customers as compensation for data. If we offer these programs, your participation in them is optional. If you decide to participate in our programs, it will be regulated in accordance with the terms of this Privacy Policy.

10. FINAL PROVISIONS.

10.1. The current version of this Privacy Policy is published on the website on the Internet at: _________________. We may make changes to this Privacy Policy at any time. The changes take effect from the moment of publication of the updated version of the Privacy Policy on the above-mentioned sites unless a different effective date is indicated in the text of the new version of the Privacy Policy.

If, after reading this privacy policy, you still have any questions or doubts, please contact us at the email address: support@callpanda.com.