---

This privacy notice for PAIRIN (referred to as “we”, “us”, or “our”) explains how and why we may gather, store, use, and/or share your information when you use our services (referred to as “Service”), including when you use the My Journey application or any other application of ours that connects to this privacy notice.

What Information Do We Collect?

Personal Information You Disclose To Us

We gather personal information that you choose to give us when you sign up for our services, show interest in learning about our company or what we offer, join in activities on our platform, or reach out to us for any reason.

Personal Information

The type of personal information we gather depends on how you interact with us and our services, the decisions you make, and the specific products and features you utilize. This information may include:

• Names
• Phone Numbers
• Email Addresses
• Mailing Addresses
• Job Titles

Sensitive Information

When required and with your consent, or as permitted by law, we may process the following categories of sensitive information:

• Social Security Numbers or Other Government Identifiers

Third-Party Login Data

We might offer you the choice to sign up with us using your current third-party account details, such as Google, Apple, or others. If you decide to register in this manner, we will gather the information outlined in the section titled “How Do We Handle Your Third-Party Logins?” below.

It’s important that all the personal information you share with us is truthful, complete, and precise. If there are any changes to this information, please inform us promptly.

How Do We Process Your Information?

We use your information to deliver, enhance, and manage our services, to stay in touch with you, for security measures and fraud prevention, and to abide by legal requirements. Additionally, we may use your information for other purposes if you give us your consent.

We handle your personal information for various purposes, depending on how you use our services, including:

• Account Management: We process your information to help you create and log in to your account, as well as maintain the functionality of your account.
• Service Delivery: Your information is processed to deliver the services you’ve requested.
• Legal Compliance: We process your information to fulfill our legal responsibilities, respond to legal requests, and protect our legal interests.

When And With Whom Do We Share Your Information?

We might disclose information in particular scenarios outlined in this section and/or with the following third parties:

• Organization Partners: Your information may be shared with organization partners. They’ll use it to identify programs, services, or benefits you’re eligible for and to assist you in enrolling in and coordinating those opportunities. Progress and outcomes will be monitored across organization partners for program enhancement and for local and federal reporting purposes.
• Business Transfers: Your information could be shared or transferred in connection with, or during discussions of, any merger, sale of company assets, financing, or acquisition of all or part of our business by another company.

How Do We Handle Your Third-Party Logins?

If you decide to register or sign in to our services using a third-party account, we may gain access to certain details about you.

Our services allow you to register and sign in using third-party media account credentials (like Google or Apple logins). If you opt for this method, we will receive specific profile information from the provider. This information may vary based on the platform, but typically includes your name, email address, profile picture, and any other details you’ve chosen to share publicly on the platform.

We will only use the received information for the purposes outlined in this privacy notice or as explicitly stated on the relevant services.

Please be aware that we don’t control or bear responsibility for other ways your personal information may be used by your third-party provider. We advise you to review their privacy notice to comprehend how they collect, utilize, and disclose your personal information, as well as how you can adjust your privacy settings on their platforms and applications.

How Long Do We Keep Your Information?

We retain your information for as long as necessary to fulfill the purposes outlined in this privacy notice, unless legally mandated otherwise.

Your personal information will only be retained for as long as it’s needed for the purposes stated in this privacy notice, unless a longer retention period is necessary or permitted by law (such as for tax, accounting, or other legal obligations). None of the purposes mentioned in this notice require us to hold onto your personal information beyond the duration of your account with us.

When there’s no ongoing legitimate business need to use your personal information, we will either delete or anonymize it. If deletion or anonymization isn’t feasible (for instance, if your personal information is stored in backup archives), we will securely store your information and prevent any further processing until deletion becomes possible.

How Do We Keep Your Information Safe?

We strive to safeguard your personal information using a combination of organizational and technical security measures.

We’ve put in place appropriate and reasonable technical and organizational measures to ensure the security of any personal information we handle. However, despite our efforts, it’s important to understand that no method of electronic transmission over the Internet or storage technology can guarantee complete security. Therefore, we cannot assure or guarantee that hackers, cybercriminals, or other unauthorized third parties won’t be able to bypass our security measures and unlawfully access, steal, or modify your information.

While we are committed to protecting your personal information to the best of our ability, the transmission of personal information to and from our services carries some level of risk. It’s advisable to access our services only within a secure environment.

What Is Our Commitment To Children’s Privacy?

Protecting children’s privacy is of utmost importance to us. Therefore, we prohibit children under the age of 13 from creating an account and none of our service is intended for individuals under 13 years old.

Our service is designed to assist employers, schools, and school districts in utilizing the data we receive to better understand applicants, employees, and students. This helps in making informed hiring decisions, developing career pathways, and enhancing student education. However, PAIRIN does not knowingly collect personally identifiable information (PII) from anyone under the age of 13 unless and until you confirm to us that you have the necessary rights, consents, and permissions to provide us with such information in accordance with our Terms of Use.

What Are Your Privacy Rights?

You have the freedom to review, modify, or deactivate your account whenever you choose.

If we are processing your personal information based on your consent, whether it’s express or implied consent as per applicable law, you have the right to withdraw your consent at any time. You can do so by contacting us using the contact information provided in the “How Can You Contact Us About This Notice?” section below.

However, please be aware that withdrawing your consent will not affect the legality of the processing carried out before the withdrawal. Additionally, where permitted by applicable law, it will not affect the processing of your personal information that was conducted based on lawful grounds other than consent.

Account Information

If you ever want to review or modify the information in your account, you can simply log in to your account settings and make the necessary updates to your user account. If you decide to close your account, please reach out to support@pairin.com.

Once you request to terminate your account, we will deactivate or delete your account and associated information from our active databases. However, we may retain certain information in our records to prevent fraud, address issues, aid in investigations, enforce our legal terms, and/or comply with relevant legal obligations.

How Do You Handle Do-Not-Track Features?

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (DNT) feature or setting. Activating this feature signals your preference to avoid having data about your online browsing activities monitored and collected for privacy reasons. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is established in the future, we will reassess this practice.

Do United States Residents Have Specific Privacy Rights?

If you are a resident of California, Colorado, or Virginia, you are granted specific rights regarding access to your personal information. Please see the sections below for those details. For all residents of the United States, the following apply.

What Categories Of Personal Information Do We Collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category	Examples	Collected
Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	Yes
Personal information as defined in the California Participant Records statute	Name, contact information, education, employment, employment history, and financial information	Yes
Protected classification characteristics under state or federal law	Gender and date of birth	Yes
Commercial information	Transaction information, purchase history, financial details, and payment information	No
Biometric information	Fingerprints and voiceprints	No
Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements	No
Geolocation data	Device location	No
Audio, electronic, visual, thermal, olfactory, or similar information	Images and audio, video or call recordings created in connection with our business activities	No
Professional or employment-related information	Business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us	Yes
Education Information	Student records and directory information	Yes
Inferences drawn from collected personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	No
Sensitive personal information	Social security numbers	Yes

We will utilize and hold onto the gathered personal information for the duration necessary to offer our services or for as long as you maintain an account with us. We may gather other personal information beyond these categories when you engage with us directly in person, online, or via phone or mail. This can occur in various contexts such as:

• Seeking assistance through our participant support channels
• Participating in participant surveys
• Facilitating the delivery of our services and responding to your inquiries

How Do We Use And Share Your Personal Information?

Learn about how we use your personal information in the section, “How Do We Process Your Information?”.

Will Your Information Be Shared With Anyone Else?

We may share your personal information with our service providers under written agreements between us and each provider. For more details on how we share personal information, please refer to the section titled “When And With Whom Do We Share Your Information?”

We may use your personal information for our own business purposes, such as for research for technological development and demonstration.

California Residents

California Civil Code Section 1798.83, also known as the “Shine The Light” law permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at support@pairin.com.

If you are under 18 years of age, reside in California, and have a registered account, you have the right to request removal of unwanted data that you publicly post. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have the rights listed below. The California Code of Regulations defines a “residents” as:

1. Every individual who is in the State of California for other than a temporary or transitory purpose and
2. Every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.” If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

Your Rights With Respect To Your Personal Data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

• Whether we collect and use your personal information; the categories of personal information that we collect; the purposes for which the collected personal information is used; whether we sell or share personal information to third parties
• The categories of personal information that we sold, shared, or disclosed for a business purpose
• The categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose
• The business or commercial purpose for collecting, selling, or sharing personal information; and the specific pieces of personal information we collected about you

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right To Non-Discrimination For The Exercise Of A Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right To Limit Use And Disclosure Of Sensitive Personal Information

If the business collects any of the following you have the right to direct that business to limit its use of your sensitive personal information to that use which is necessary to perform the Services:

• Social security information, drivers’ licenses, state ID cards, passport numbers account login information
• Credit card numbers, financial account information, or credentials allowing access to such accounts precise geolocation racial or ethnic origin, religious or philosophical beliefs, union membership
• The contents of email and text, unless the business is the intended recipient of the communication genetic data, biometric data, and health data data concerning sexual orientation and sex life

Once a business receives your request, they are no longer allowed to use or disclose your sensitive personal information for any other purpose unless you provide consent for the use or disclosure of sensitive personal information for additional purposes.

Please note that sensitive personal information that is collected or processed without the purpose of inferring characteristics about a consumer is not covered by this right, as well as the publicly available information. To exercise your right to limit use and disclosure of sensitive personal information, please email support@pairin.com.

Verification Process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other Privacy Rights

You may object to the processing of your personal information. You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.

You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.To exercise these rights, you can contact us by email at support@pairin.com or by calling toll-free at 855-724-7466. If you have a complaint about how we handle your data, we would like to hear from you.

Colorado Residents

Under the Colorado Privacy Act (CPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. You have the right to:

• Be informed whether or not we are processing your personal data
• Access your personal data
• Correct inaccuracies in your personal data
• Request deletion of your personal data
• Obtain a copy of the personal data you previously shared with us
• Opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

To submit a request to exercise these rights described above, please email support@pairin.com. If we decline to take action regarding your request and you wish to appeal our decision, please email us at info@pairin.com. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Virginia Residents

Under the Virginia Consumer Data Protection Act (VCDPA):

“Consumer” means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. “Personal data” does not include de-identified data or publicly available information.

“Sale of personal data” means the exchange of personal data for monetary consideration.

If this definition of “consumer” applies to you, we must adhere to certain rights and obligations regarding your personal data.

Your Rights With Respect To Your Personal Data

You have the right to:

• Be informed whether or not we are processing your personal data
• Access your personal data
• Correct inaccuracies in your personal data
• Request deletion of your personal data
• Obtain a copy of the personal data you previously shared with us
• Opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

To exercise your rights provided under the Virginia VCDPA, you may email support@pairin.com.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification Process

We may request that you provide additional information reasonably necessary to verify you and your consumer’s request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right To Appeal

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at support@pairin.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

Do We Make Updates To This Notice?

Yes, we will update this notice as necessary to stay compliant with relevant laws.

The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may contact us at support@pairin.com or 855-724-7466.

How Can You Review, Update, Or Delete The Data We Collect From You?

Based on the applicable laws, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please email support@pairin.com.